Key provisions and impacts of the new law
Re-evaluation of the Thrifty Food Plan: Section 10101
What changes: The Thrifty Food Plan is the benchmark used by the U.S. Department of Agriculture (USDA) to set SNAP benefit amounts annually. Under the new law, all future re-evaluations of the Thrifty Food Plan must be cost neutral and any increases in SNAP benefit amounts will be limited by changes to the Consumer Price Index instead of reflecting actual changes in food costs. The USDA may re-evaluate the Thrifty Food Plan no earlier than October 1, 2027.
Implementation date: October 1, 2025, and will affect SNAP benefit amounts starting October 1, 2027.
Minnesota impact:
- SNAP benefits will lose value over time, reducing purchasing power.
- In 2027, roughly 440,000 Minnesotans who receive SNAP will receive $5 less per month on average than they would have without this provision.
- Local retailers and economies will also experience reduced demand as customers reduce spending.
Modifications to SNAP work requirements: Section 10102
What changes: The new law expands SNAP work requirements to adults through age 64 (previously age 54); limits the parent exemption to households with children under age 14 (previously age 18); removes exemptions for veterans, people experiencing homelessness, and youth leaving foster care; creates a new exemption for American Indians, Alaska Natives, Urban Indians, and California Indians; and restricts waivers to areas where unemployment is above 10 percent.
Implementation date: November 1, 2025. State agencies must apply updated exceptions to new and ongoing participants after they are screened, in accordance with 7 CFR 273.24(k).
Minnesota impact:
- About 4 percent of SNAP participants, or almost 18,000 more adults in an average month, will be subject to work requirements.
- About two-thirds are older adults (ages 55-64), and a quarter are adults with children aged 14 and older.
- Roughly a third are projected to eventually lose benefits because of the work requirements.
- Prior to enactment of H.R. 1, 17 counties and 9 Tribal Nations had waivers due to high unemployment rates and low availability of job opportunities. Now, only three Tribal Nations qualify under the new law.
Communications to program participants:
Standard utility allowances and energy assistance: Section 10103
What changes: Limits the use of LIHEAP or similar state-funded energy assistance payments to automatically qualify for the heating/cooling standard utility allowance (HCSUA) unless elderly or disabled members are in the household.
Implementation date: November 1, 2025. This policy must be applied at initial certification for new applicants and to ongoing households at recertification.
Fiscal impact: DCYF does not project a fiscal impact because people should still qualify for the HCSUA.
Minnesota impact: Households receiving energy assistance payments would still be eligible for the same standard utility allowance provided they have heating and cooling costs.
Restrictions on internet expenses: Section 10104
What changes: Prohibits internet costs from being included in excess shelter deductions for SNAP.
Implementation date: October 1, 2025.
Fiscal impact: None.
Minnesota impact: None. Prior to the new law, Minnesota had planned to implement use of internet costs in benefit calculations beginning in FFY 2026.
Matching funds requirement: Section 10105
What changes: States must pay up to 15 percent of SNAP benefit costs, depending on their Payment Error Rate (PER) in prior years. The PER is set by the federal government based on a sample of SNAP cases and reflects both overpayments and underpayments.
PER match structure:
- PER below 6 percent: 0 percent state match
- PER 6 to 7.99 percent: 5 percent state match
- PER 8 to 9.99 percent: 10 percent state match
- PER 10 percent or higher: 15 percent state match
- PER 13.34 percent or higher: Exempt from state match for two years
Implementation date: October 1, 2027.
Fiscal impact: The amount will be variable based on each year’s PER, which is published by USDA annually in June. Based on Minnesota’s PER for FFY 2024, the non-federal share of SNAP benefits would be 10 percent of the state’s benefit costs or roughly $97 million annually.
Minnesota impact: This policy will increase state and county costs.
Administrative cost sharing: Section 10106
What changes: Federal reimbursement for administering SNAP is reduced from 50 percent to 25 percent. States are now forced to cover 75 percent of program administration costs beginning on October 1, 2026. SNAP outreach also loses reimbursement.
Implementation date: October 1, 2026.
Fiscal impact: $37 million annual loss in federal reimbursements. SNAP outreach also loses $2.1 million.
Minnesota impact: Fewer administrative resources at the state, county, and community levels.
SNAP-Ed funding eliminated: Section 10107
What changes: Ends federal funding for SNAP Education (SNAP-Ed) on October 1, 2025.
Implementation date: October 1, 2025.
Fiscal impact: Loss of $9.5 million annually.
Non-Citizen SNAP eligibility restrictions: 10108
What changes: Prior to enactment of H.R. 1, SNAP was limited to U.S. citizens and certain legal non-citizens; the new law further restricts SNAP for non-citizens to only lawful permanent residents, Cuban/Haitian entrants, and residents of Micronesia, the Marshall Islands, and Palau. The new law also requires counting all household members’ resources, including those members who are ineligible for SNAP benefits.
Implementation date: March 1, 2026.
Fiscal impact: Reduces federal benefits to Minnesota; higher administrative costs for eligibility verification.
Minnesota impact: About 9,000 fewer Minnesotans in an average month will be eligible for federal SNAP benefits. Impacted groups include:
