Minnesota Family Investment Program Demonstration Waiver FAQs

This FAQ provides information about recent communications and directives from the USDA regarding Minnesota’s long-standing MFIP demonstration waiver. 

While DCYF is continuing to reach out to the USDA to understand the USDA’s request in their August 3 letter. Currently there are no changes to MFIP eligibility and reporting requirements at this time. 

County and Tribal Nation eligibility workers should continue to follow existing MFIP policies under state statute and in the Combined Manual. 

What is the MFIP waiver? 

The Minnesota Family Investment Program (MFIP) provides cash and food assistance to eligible families with children. MFIP is funded in part through a federal program called Temporary Assistance for Needy Families (TANF), which gives block grants to states along with criteria for how those grants can be used, and through the Supplemental Nutrition Assistance Program (SNAP), which provides food benefits to eligible households. 

Since 1998, MFIP has been administered under a federal demonstration waiver from the USDA that authorizes the state to combine TANF cash benefits with SNAP benefits into a single household benefit with both a cash and food portion. By combining cash assistance and food benefits under a single program, the state makes it easier for families to participate in MFIP and work toward economic stability by having just one set of policies and reporting requirements to follow. This streamlined approach reduces administrative complexity while reducing barriers to employment and self-sufficiency. 

What is the current situation with the waiver?

During the 2023 legislative session, the Minnesota Legislature enacted legislation requiring MFIP to transition from monthly reporting to a six-month budgeting cycle. The reform improved economic stability for MFIP participants while aligning MFIP more closely with SNAP, which typically uses six-month periods for calculating benefits. The statutory change became effective on March 1, 2025. Following implementation, the USDA notified DCYF in January 2026 that Minnesota's reporting requirements did not align with certain SNAP regulations and directed the state to submit a formal waiver modification request.

On May 7, 2026, Minnesota submitted a formal request to amend the demonstration waiver to reflect the statutory changes and align the waiver with current state law. On August 3, 2026, the USDA formally denied Minnesota's amendment request. The denial extended beyond the legislative reforms implemented in March 2025 and included provisions related to: 

• SNAP Simplified Reporting 
• Minnesota Paid Leave 
• Substantial lottery and gambling winnings 
• MFIP reporting requirements required under Title IV of the Social Security Act (TANF) 

The USDA directed Minnesota to align MFIP with certain SNAP rules within 120 days or risk termination of the demonstration waiver. Notably, several of the issues raised by the USDA had previously been approved under the state’s long-standing MFIP waiver, whereas several others conflict with certain TANF requirements that had not previously raised concern from the USDA. 

What is the USDA requesting of Minnesota?

The USDA has raised the following four issues with Minnesota’s current MFIP waiver. While DCYF is continuing to reach out to the USDA to understand these four requests from their August 3 letter, please note that there are no changes to MFIP eligibility and reporting requirements at this time. County and Tribal Nation eligibility workers should continue to follow existing MFIP policies under state statute and in the Combined Manual. 

SNAP Simplified Reporting

The USDA is requesting that MFIP follow SNAP’s simplified reporting requirements rather than MFIP’s unique six-month budgeting requirements that require MFIP participants to report additional changes during the certification period, at recertification, and for periodic reports. Specifically, the USDA requested that MFIP households report when gross income exceeds 130 percent of the federal poverty guidelines during the certification period, when work hours fall below 20 hours per week, and substantial lottery or gambling winnings. Previously, the USDA did not require MFIP participants to report when income exceeds 130 percent of the federal poverty guidelines, as MFIP has its own income reporting requirements. Additionally, MFIP participants were considered exempt from the SNAP-specific work rules that apply to time-limited recipients in SNAP since MFIP participants are already following TANF-specific work rules. Finally, MFIP already requires reporting substantial lottery or gambling winnings. 

Minnesota Paid Leave

The USDA is requesting that MFIP treat Minnesota Paid Leave as unearned income, as required under SNAP rules. MFIP currently treats Minnesota Paid Leave benefits as earned income under state law. Previously, the USDA allowed Minnesota the authority under its waiver to define different types of income as earned or unearned income for MFIP, including paid leave. 

Substantial lottery and gambling winnings 

The USDA is requesting that MFIP participants with substantial lottery or gambling winnings (currently defined as $4,750 or more) have their cases closed, as is required under SNAP categorical eligibility rules. Under SNAP rules, households with substantial lottery or gambling winnings can reapply as non-categorically eligible households, meaning they must meet the federal rather than the state’s income and asset tests. Previously, the USDA did not apply this rule to MFIP, though MFIP requires participants to report substantial lottery or gambling winnings and treat them as assets. MFIP has long had a separate asset test of $10,000 and its own income limit standards. 

MFIP reporting requirements required under Title IV of the Social Security Act (TANF) 

The USDA is requesting that Minnesota no longer require MFIP participants to report certain household changes during the certification period, even those required under federal TANF rules. Specifically, MFIP requires households to report the following:

• Any change in eligibility for SSI, RSDI and other federal income support. 
• Any pregnancy that does not result in a live birth when there are no other minor children in the home. 
• Any change in school attendance for a parent under the age of 20. 
• An 18-or 19-year-old parent graduating or leaving high school. 

Previously, the USDA allowed Minnesota to require MFIP participants to report these changes because they are required for Minnesota to maintain compliance with federal TANF requirements. 

Why can’t Minnesota just do what USDA is telling them to do?

DCYF wants to ensure that Minnesota fully complies with federal laws and regulations and prefers to maintain an integrated approach for MFIP under the waiver.  However, some parts of what USDA is directing Minnesota to do would conflict with guidance from the U.S. Department of Health and Human Services, which oversees the TANF program that partially funds MFIP. In sum, complying with some of the USDA’s requests would put Minnesota out of compliance with federal TANF requirements.

Additionally, the changes that the USDA is requiring need time for necessary implementation work to be completed first, including amending Minnesota statutes, revising policy guidance and training curricula, programming the changes into the MAXIS eligibility system, and communicating with the local agencies that work directly with SNAP and MFIP recipients to ensure that any changes to MFIP are implemented in an orderly and responsible fashion that does not undermine program oversight and administration. The timeline requested by the USDA is not feasible and would lead to significant disruptions for MFIP participants and county and Tribal agencies that administer the program.

What is the timeline of events?

• MFIP has operated under a waiver since its statewide implementation in 1998 (and earlier pilots).
• In 2023, the USDA approved the current waiver for the 2024–2028 demonstration period. 
• During the 2023 legislative session, Minnesota enacted legislation requiring MFIP to transition from monthly reporting to a six-month budgeting cycle. That statutory change became effective on March 1, 2025.
• On January 27, 2026, the USDA notified DCYF that Minnesota's reporting requirements no longer aligned with SNAP regulations and directed the State to submit a formal waiver modification request. 
• On May 7, 2026, Minnesota submitted a formal request to amend the waiver to reflect the statutory changes and align the waiver with current state law. 
• On August 3, 2026, USDA formally denied Minnesota’s request to amend its waiver.
• On August 10, 2026, DCYF submitted a formal letter to the USDA seeking clarification on issues raised by the USDA that were previously approved under the state’s waiver or which put the state out of compliance with TANF rules.
• On September 15, 2026, after no response from the USDA, DCYF submitted a second letter to the USDA seeking clarification on issues raised by the USDA and requesting a meeting to work toward a resolution.
• On October 13, 2026, after no response from the USDA, DCYF submitted a third letter to the USDA seeking clarification on issues raised by the USDA and requesting a meeting to work toward a resolution.
• On October 21, 2026, the USDA responded to DCYF regarding outstanding issues raised in the USDA’s August 3 letter and inviting DCYF to schedule a meeting.
• On October 26, 2026, DCYF submitted proposed meeting dates for the week of November 9.

What are the next steps?

At this time, there are no changes to MFIP eligibility and reporting requirements. County and Tribal Nation eligibility workers should continue to follow existing MFIP policies under state statute in the Combined Manual. 

Minnesota has reached out several times to USDA officials since receiving notice of the denial of our proposed amendment to the current waiver, with the goal of clarifying and discussing the conflicting provisions of SNAP and TANF policy and the challenges that the USDA’s August 3 amendment denial presents.