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    USDA SNAP Proposal Could Affect 6.3 Million People: Comment by Dec. 10

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    USDA wants to change a SNAP rule that helps working families, seniors, and people with a little money saved. By USDA’s own estimate, about 6.3 million people could lose their food benefits if the proposal takes effect.

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    This is only a proposal. Nothing changes on your EBT card today, so keep using SNAP and responding to your renewal notices as usual.

    But you have until December 10, 2026, to tell USDA what this change would mean for you.

    You can submit a public comment through Regulations.gov. We’ll explain what the proposal would do, who could be affected, and how to make your voice heard.

    What Is USDA Proposing?

    The rule has a complicated name: broad-based categorical eligibility, or BBCE. But the basic idea is simple.

    Under federal SNAP rules, households that receive certain other public benefits can qualify for SNAP without having to pass its separate income and savings tests.

    That’s called categorical eligibility.

    BBCE allows states to extend that treatment to households receiving certain services funded by Temporary Assistance for Needy Families (TANF), not just households receiving TANF cash assistance.

    States have used this flexibility to raise SNAP’s gross income limit as high as 200% of the federal poverty level, instead of the usual 130%. They can also raise or eliminate the savings limit for qualifying households.

    According to the Center on Budget and Policy Priorities, 41 states using BBCE eliminated the SNAP asset test for qualifying households.

    USDA reports that 46 of the nation’s 53 SNAP state agencies, a count that includes certain territories and Washington, D.C., use BBCE.

    The proposed rule would sharply restrict this flexibility.

    Under the proposal, categorical eligibility based on TANF would generally be limited to households receiving TANF assistance as defined by federal regulations, rather than broader TANF-funded services.

    Households in which every member receives Supplemental Security Income (SSI) or qualifying state general assistance would continue to have categorical eligibility under existing rules.

    Other households that lose categorical eligibility would generally have to meet SNAP’s regular federal income and resource requirements, including special rules for households with older adults or people with disabilities.

    This change has not been enacted by Congress or finalized by USDA. It is a separate regulatory proposal, and the public has an opportunity to comment before the agency makes a final decision.

    Who Could Lose SNAP?

    USDA estimates that approximately 3.2 million households, representing 6.3 million people, could lose SNAP when the proposed rule reaches its full effect in fiscal year 2029.

    The agency estimates that about 5.4 million people could lose eligibility because of resource limits, while roughly 2 million could be affected by income limits.

    These groups overlap, so the numbers should not be added together.

    Working Families Could Lose Benefits

    Working families are among the households that could be affected.

    According to a February 2026 analysis by the Center on Budget and Policy Priorities, about 3.5 million people in working families qualified for SNAP through BBCE in 2023.

    Those households received an average benefit of approximately $150 per month.

    BBCE can help families whose earnings are slightly above SNAP’s usual income limits but who still struggle to afford groceries after paying for housing, child care, transportation, and other expenses.

    The research group gives an example of a single mother with two children who earns $16 per hour.

    If she receives a 70-cent hourly raise, her household could lose SNAP without BBCE and end up approximately $180 per month worse off.

    With BBCE, the same raise could leave her family about $78 per month better off.

    This example illustrates what’s sometimes called a benefits cliff: a small increase in earnings can trigger a much larger loss of assistance.

    Seniors and People With Disabilities Could Be Affected

    The same CBPP analysis found that approximately 1.4 million people in households with older adults or people with disabilities qualified for SNAP through BBCE in 2023.

    Those households received an average benefit of about $35 per month.

    That may not sound like much, but even a modest monthly benefit can help someone living on a fixed income buy groceries.

    USDA’s proposal could also affect households that have saved money for emergencies.

    For fiscal year 2027, the regular federal SNAP resource limit is:

    • $3,000 for most households.
    • $4,750 for households with a member who is age 60 or older or has a qualifying disability.

    These amounts come from USDA’s fiscal year 2027 SNAP cost-of-living adjustments.

    Certain assets, including a household’s primary home and qualifying retirement accounts, are generally excluded from SNAP resource calculations.

    But money in checking and savings accounts can count.

    Imagine you’re 68, living on Social Security, and you’ve managed to save $5,000 for car repairs or funeral expenses.

    If your household currently qualifies through BBCE without an asset test, those savings may not affect your eligibility.

    Under the proposal, losing that categorical eligibility could mean your savings put you over the regular federal resource limit.

    Your income wouldn’t have increased, but your SNAP eligibility could change.

    Of course, not every household would be affected the same way. Other eligibility rules, exclusions, and household circumstances still matter.

    And many people who need SNAP have very little saved.

    A Brookings analysis found that the median value of liquid assets among households meeting SNAP’s income requirements was just $141 in 2023 dollars, based on survey data collected from 2013 through 2016.

    That finding doesn’t describe every current SNAP recipient, but it shows how limited savings can be among households with low incomes.

    For those families, bringing back an asset test could mean more paperwork to document resources they barely have.

    Children Could Lose Automatic Access to School Meals

    The proposal could also affect programs connected to SNAP eligibility.

    USDA estimates that approximately 1.78 million children could lose automatic eligibility for free school meals through SNAP.

    The agency projects that about 97% of those children would still qualify for free meals through another eligibility pathway, although some families would need to complete a separate application.

    USDA also estimates that approximately:

    • 93,000 children could move from free to reduced-price school meals.
    • 28,000 children could become responsible for full-price school meals.
    • 42,000 children could lose Summer EBT eligibility once the proposal reaches its full effect.
    • 5,500 WIC participants could lose eligibility connected to SNAP.

    These are USDA projections, not changes that have already happened.

    The proposal’s effects could extend beyond the households receiving SNAP directly.

    Is This Rule Final?

    No. USDA has proposed the change, but it has not finalized it.

    The agency published its proposal on November 10, 2026, and opened a public comment period.

    USDA must consider the comments it receives before deciding whether to issue a final rule. The final version could change, and the agency could decide not to move forward.

    The agency projects that the proposal’s full effects would be reached in fiscal year 2029, although some changes could occur earlier if a final rule is adopted and implemented.

    USDA tried a similar change before.

    In July 2019, the agency proposed restricting categorical eligibility. That proposal was withdrawn on June 10, 2021, without becoming final.

    The new proposal also asks for feedback on an alternative based on the earlier approach.

    For now, your state’s current SNAP rules still apply.

    You do not need to reapply for SNAP or report your savings simply because this proposal was published. Continue following your existing reporting requirements and responding to notices from your SNAP agency.

    If you’re an older adult or have a disability, our guide to SNAP rules for seniors and people with disabilities explains some of the protections that apply under current rules.

    Why Does USDA Say It’s Doing This?

    USDA argues that categorical eligibility should be tied more closely to households receiving TANF assistance, rather than broader TANF-funded services.

    The agency says states have used BBCE to expand SNAP eligibility beyond the regular federal income and resource limits. It argues that restricting the policy would better align SNAP with federal eligibility requirements and direct benefits toward households meeting those standards.

    USDA also estimates that the proposal would reduce federal SNAP benefit spending by approximately $44.6 billion from fiscal years 2027 through 2031.

    That’s a projected reduction in federal spending, not money already saved.

    At the same time, USDA estimates that states would face approximately $928.5 million in additional administrative costs over five years, largely because of the work required to verify eligibility and resources.

    In the proposed rule, USDA raises concerns about households receiving categorical eligibility through limited TANF-funded services, such as informational materials or referrals.

    The agency also points to cases in which people with substantial assets received SNAP benefits.

    One well-known example involves Rob Undersander of Minnesota.

    Undersander and his wife received approximately $6,000 in SNAP benefits over 19 months. He told MPR News that he applied largely to demonstrate what he considered a loophole in the system. He also said he donated an equivalent amount to charity.

    That case illustrates USDA’s concern about households with significant assets qualifying through BBCE.

    However, it doesn’t represent every household using the policy.

    People who qualify through BBCE must still complete the SNAP application process and meet applicable program requirements. Their benefit amounts are calculated using SNAP’s regular benefit formula.

    Research from CBPP shows that BBCE also helps working families, older adults, and people with disabilities who may have modest savings or earnings slightly above the usual income limits.

    The central question is whether restricting categorical eligibility would prevent inappropriate access without causing substantial hardship for households that still struggle to afford food.

    That’s one of the questions USDA is asking the public to address.

    How Do I Submit a Comment?

    Anyone can comment on this proposal.

    You don’t have to receive SNAP, and you don’t need to be a policy expert.

    You can explain how the rule might affect you, your family, or people in your community.

    The comment deadline is December 10, 2026. Comments submitted through the online docket must be received by 11:59 p.m. Eastern Time.

    Option 1: Submit Your Comment Online

    Visit the official Regulations.gov comment page for docket FNA-2026-0661.

    Then:

    1. Open the comment form.
    2. Write your comment or attach a document.
    3. Complete the required information.
    4. Review your submission and select Submit Comment.

    Keep any confirmation or tracking number you receive.

    You can also find the proposal by searching for FNA-2026-0661 on Regulations.gov.

    Option 2: Submit Your Comment by Email

    You can send comments to:

    sm.fn.snappdbrules@usda.gov

    Include the docket number FNA-2026-0661 and the title Supplemental Nutrition Assistance Program: Reforming Categorical Eligibility in the subject line.

    Make sure your email is sent before the comment deadline.

    Option 3: Submit Your Comment by Mail

    Send written comments to:

    SNAP Program Development Division
    Food and Nutrition Administration
    5601 Sunnyside Ave.
    Beltsville, MD 20705

    Include FNA-2026-0661 at the top of your letter.

    Mailed comments must arrive by the deadline, so allow enough time for delivery.

    What Should You Say?

    You don’t need to write a long letter.

    A clear comment that explains your situation and concerns can be useful.

    Consider including three things:

    1. Who you are and how SNAP helps you. For example: “I’m 67, I live alone, and SNAP helps me buy groceries at the end of the month.”
    2. How the proposal could affect you. For example: “I have $5,000 saved for emergency car repairs, and I’m concerned that a new savings limit could affect my benefits.”
    3. What you want USDA to consider. You might ask the agency to keep BBCE, explain why you support the proposed restrictions, or suggest changes that would protect households with limited savings.

    You can also discuss the proposal’s potential effects on working families, older adults, people with disabilities, or children receiving school meals.

    The most helpful comments explain a concern clearly and connect it to the proposed rule.

    Protect Your Personal Information

    Public comments and the identities of people submitting them may be made publicly available.

    Do not include your Social Security number, SNAP case number, private financial account information, or medical details you wouldn’t want others to see.

    If you need help using the online form, consider asking a trusted friend or family member.

    USDA also published a separate proposal concerning SNAP work requirements.

    That proposal has its own rulemaking process. If it affects you, review it separately and submit a comment to the appropriate docket.

    Relief Recap

    USDA has proposed changing SNAP’s categorical eligibility rules, and the agency estimates that 6.3 million people could lose benefits when the change reaches its full effect.

    Working families, older adults, people with disabilities, and households with modest savings could be affected. Some children could also lose automatic access to free school meals.

    But the proposal is not final. Your SNAP benefits and current reporting responsibilities have not changed simply because USDA published it.

    If you want USDA to understand how this change could affect your household, you can submit a comment by December 10, 2026.

    Visit the official comment page, explain your situation in your own words, and share what you want the agency to consider.

    Your experience can help inform the decision before any final rule is adopted.

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