SNAP Enrollment Is Finally Falling: Partly Reform Driven, Partly Normalization

For the first time since the pandemic-era expansion of the welfare state, the Supplemental Nutrition Assistance Program (SNAP) is beginning to shrink back toward normalcy.

Between January 2025 and January 2026, the number of individuals receiving SNAP benefits declined by nearly 4.3 million. Roughly 3.5 million of that decline occurred after the passage of the One Big Beautiful Bill Act (OBBBA) in July 2025.

Even after the recent drop in enrollment, SNAP participation remains approximately 1.7 million individuals above pre-pandemic levels. Meanwhile, the average cost per household (adjusting for inflation) is still about 18 percent higher than before the pandemic.

How SNAP Became Larger and More Expensive

Prior to the pandemic, the average SNAP benefit was roughly $235 per household. That changed dramatically beginning in March 2020, when Congress authorized states to provide all SNAP households with the maximum benefit regardless of income.

The expansion continued under the American Rescue Plan in 2021, which implemented a 15 percent across-the-board increase to maximum SNAP benefits.

Although many of these changes were advertised as temporary emergency measures, the Biden administration later made a substantial portion of the expansion permanent. In 2021, the USDA reevaluated the “Thrifty Food Plan” and permanently increased SNAP benefit levels by 21 percent above the normal annual inflation adjustment.

This administrative change was historically unprecedented. Traditionally, reevaluations of the Thrifty Food Plan were expected to remain cost neutral. Instead, the Biden USDA used the process to permanently ratchet benefit levels higher.

By January 2026, average SNAP benefits per household were approximately 48 percent higher than pre-pandemic levels. During that same period, the overall cost of living increased by roughly 26 percent.

Benefits therefore rose substantially faster than inflation. At the same time, participation surged. SNAP enrollment peaked at roughly 43 million individuals in 2020 and remained elevated long after the economy reopened.

Beginning in April 2020, work and work-training requirements were largely suspended. States were granted broad “flexibility” regarding eligibility verification and recertification. Interview waivers, automatic benefit extensions, and relaxed administrative oversight made it substantially easier to remain enrolled in the program.

In 2020 alone, SNAP participation increased by more than 6 million individuals.

The SNAP program also faces a chronic problem that predates the pandemic: improper payments. In recent years, SNAP erroneous payment rates have hovered around 9 to 10 percent, nearly double the rate seen seven years earlier. These erroneous payments cost taxpayers roughly $10 to $12 billion annually.

Importantly, most improper payments are not necessarily intentional fraud. Many result from administrative errors, incorrect eligibility determinations, or failures to update household information. But regardless of the cause, the fiscal consequences are enormous.

A program that in some years costs $120 billion annually cannot sustain persistent error rates near double digits without meaningful reform.

What the OBBBA Changed

The OBBBA represented the most significant SNAP reform in years. One important provision restored the traditional expectation that future reevaluations of the Thrifty Food Plan remain cost neutral. This prevents future administrations from unilaterally expanding SNAP benefit levels above inflation through administrative reinterpretation alone.

However, the legislation did not reverse the Biden-era benefit increase already implemented in FY2022.

More consequential reforms involve state financial responsibility. Historically, SNAP benefit costs were fully federally funded, while administrative costs were split evenly between states and the federal government. Beginning in 2027, states will be responsible for 75 percent of administrative costs, with the federal government covering only 25 percent.

More importantly, for the first time in the program’s history, states will also share direct responsibility for benefit costs themselves. Under the new structure, states will cover between 5 and 15 percent of benefit costs depending on their payment error rates. States with high erroneous payment rates will pay more, while states with lower error rates will pay less.

Under the previous structure, states faced weak incentives to aggressively reduce payment errors because the federal government absorbed nearly the entire cost of mistakes. The new system introduces real fiscal consequences for poor administration.

The OBBBA also tightened work requirements for able-bodied adults without dependents and reduced states’ ability to issue broad waivers. At the same time, the age threshold for work requirements was increased from 54 to 64.

Finally, eligibility rules were tightened for certain non-citizen groups, including refugees and asylees.

Why Is SNAP Enrollment Falling?

The OBBBA is clearly one important explanation for the recent decline in enrollment. Between December 2024 and July 2025, before the legislation passed, SNAP participation had already fallen by about 1 million individuals. But after enactment, enrollment declined by another 3.5 million.

The timing strongly suggests the reforms accelerated the downward trend, but policy changes are probably not the entire explanation.

As AEI scholar Angela Rachidi recently observed, some of the largest declines occurred in states like Florida and Georgia that did not previously maintain broad work requirement waivers for able-bodied adults. That suggests broader economic and post-pandemic normalization effects are also playing a major role.

Indeed, after the Great Financial Crisis, SNAP enrollment eventually declined by nearly 11 million individuals as labor markets recovered. Following the COVID-19 recovery, however, participation remained unusually elevated for years despite a strong labor market.

In that sense, some correction was inevitable. The pandemic-era welfare expansion significantly increased both the generosity and accessibility of SNAP. What we are seeing now is not simply “cuts,” but rather a gradual return toward something closer to historical norms.

Further Reforms Are Still Needed

The recent decline in SNAP participation is encouraging, but the program still remains substantially larger and more expensive than before the pandemic. Additional reforms could further improve both program integrity and long-term sustainability.

First, current reporting rules only require disclosure of payment errors exceeding $57 per individual. That threshold should be eliminated entirely so that all payment errors are disclosed and tracked. Since states will now bear part of the financial burden of erroneous payments, greater transparency would strengthen incentives to identify and prevent errors.

Second, SNAP EBT cards remain technologically outdated. Unlike modern credit and debit cards, many EBT cards still lack chip security features, making them more vulnerable to fraud and theft. Some states, including Oklahoma, have already moved toward chip-enabled EBT cards that better match modern banking standards. USDA should require all states to adopt this model.

Finally, Congress should consider aligning SNAP’s definition of “elderly” with the Social Security Administration’s full retirement age of 67. Current eligibility rules use a lower threshold that no longer reflects modern workforce participation patterns or retirement norms.

The SNAP program exists to provide temporary nutritional assistance for vulnerable households. But over the past several years, temporary emergency expansions evolved into a far more permanent enlargement of the welfare state.

The recent enrollment decline suggests that process is finally beginning to reverse. The question now is whether policymakers will finish the job.