States Are Using Much-Needed Temporary Flexibility in
SNAP to Respond to COVID-19 Challenges
Since March 2020, states have been using temporary SNAP (food stamp) flexibility to provide emergency benefit
supplements, maintain benefits to households with children missing school meals, and ease program administration
during the pandemic. These options have allowed states to deliver more food assistance to struggling families, help
manage intense administrative demands, and ensure that participants maintain much-needed benefits.
The far-reaching health and economic effects of COVID-19 and widespread
business closures to limit its spread made it even more difficult for many low-
income households to afford food and other needs. Data have shown a
substantial number of families have reported difficulties affording adequate
food and other basic needs at some point during the pandemic. SNAP is
essential to helping these families put food on the table.
The Families First Coronavirus Response Act of March 2020 gave the
Agriculture Department (USDA) authority to let states temporarily modify
procedures to make it easier for families to continue participating in or apply
for SNAP. Many of those temporary changes were extended by subsequent
legislation and administrative action. Also, Families First temporarily
suspended, nationwide, SNAP’s three-month time limit on benefits for
unemployed adults under age 50 without children in their home. In addition to
provisions in the law, USDA encouraged states to use existing program
flexibility to improve access to SNAP, such as by using online or telephone
SNAP applications if they weren’t already, or allowing participants to stay on
SNAP without reapplying for the maximum amount of time allowed under
program rules. Families First also included a temporary boost of emergency
supplementary benefits and school meal replacement benefits, which were also extended and strengthened by
subsequent legislation and administrative action from the Biden Administration.
Benefit Enhancements
Families First included two ways for states to raise benefits for many SNAP participants and other households
experiencing falling income and rising food needs:
• Provide SNAP households with emergency allotments. States can give SNAP households emergency
supplementary benefits; all states have used this option. (Originally, a Trump Administration interpretation of this
Families First policy left out the lowest-income SNAP households from these benefits when states began issuing
them in March 2020. The Biden Administration reversed this policy, and beginning April 2021 all households in
states with these benefits have received emergency allotments of at least $95.)
USDA may approve states to provide these benefits as long as the federal government has declared a public
health emergency and the state has issued an emergency or disaster declaration. The Biden Administration has
stated that the federal public health emergency will remain in place through at least October 2022.
1
Some states
have taken steps toward ending or have ended their state COVID-related emergency declarations, and a number
of states have ceased issuing allotments.
2
Households experience a significant benefit cut when these allotments
end. Figure 1 below shows the months for which these allotments have been approved through August 2022.
In addition to these allotments, the COVID relief package enacted in December 2020 included a 15 percent
increase in SNAP’s maximum benefit for January through June 2021; the American Rescue Plan Act, enacted in
March 2021, extended that increase through September 2021. This increase — which applied in all states and
territories participating in SNAP — amounted to about $28 more in SNAP benefits per person per month, or just
over $100 per month in food assistance for a family of four.
How to Find Out If You Can
Get Help From SNAP
SNAP eligibility is complicated. If you
think you need help, the best thing
to do is apply.
• Find your state’s online application
and telephone number
• Find a local food bank for
immediate food help
Notes: Sometimes states use a
different name for SNAP, like the Food
Stamp Program, CalFresh, or food
benefits. All states offer the program.
SNAP has special rules and resources
following natural disasters.
Separately, and not related to the pandemic, in August 2021 USDA announced it had completed the
congressionally mandated revision of the Thrifty Food Plan (TFP), the basis for SNAP benefits, which raised
benefits for SNAP households in October 2021 (and for future years). This update, which will enable the program
to provide benefits that more accurately reflect the cost of a healthy diet, raised the maximum SNAP benefits by
21 percent compared to what they would have been. Because the 15 percent SNAP benefit increase ended at the
same time, in October 2021, households received a modest increase in their SNAP benefits. For example, a
household of three receiving the maximum benefit (all households in states that are continuing to distribute
emergency allotments) saw a $42 increase in October compared to September 2021, from $782 to $835.
• Replace lost school meals through P-EBT. Families First allowed states to provide meal replacement benefits
through SNAP, known as P-EBT, for households with children who attended a school that was closed beginning in
the spring of 2020 for at least five days and who otherwise would have received free or reduced-price meals.
Spring 2020 through September 2020: All states and territories eligible to provide these benefits (except for
Guam) selected the option and issued these benefits by mid-summer 2020 to replace meals lost during the
2019-2020 school year. Families First allowed states to provide these benefits through fiscal year 2020 (which
ended September 30, 2020), and 20 states chose to extend the benefits through August and September 2020
under this law.
2020-2021 School Year and Summer 2021: The government funding law enacted in October 2020 extended P-
EBT through September 2021 and included some expansions, including extending the program to pre-school-
aged children and to some territories originally left out of P-EBT.
3
The December 2020 COVID relief package
included additional simplifications. The American Rescue Plan allowed states to continue their P-EBT program
during the summers and through the remainder of the public health emergency for children who miss out on
school meals because of the pandemic, as well as clarifying that the expansion to certain children under age 6
applies to all territories as well as states.
4
Also, the Biden Administration strengthened P-EBT benefits and issued
guidance incorporating further simplifications.
Nearly every state, Washington, D.C., Puerto Rico, the U.S. Virgin Islands, and the Commonwealth of the Northern
Mariana Islands received approval and issued benefits for the 2020-2021 school year; most states were also
approved to issue benefits for pre-school-aged children in addition to school-aged children. Almost every state
was approved to provide benefits for summer 2021 to both school-aged children receiving free- and reduced-price
school meals and children under age 6.
5
2021-2022 School Year and Summer 2022: The Biden Administration also provided guidance for states to
provide benefits for students in the 2021-2022 school year for students learning virtually due to COVID.
Developing 2021-2022 state plans for school-aged children has been challenging for some states because they
have to determine whether absences are COVID-related. USDA also issued updated guidance for child care plans
that makes their approval fairly straightforward. For more detail on states’ implementation of P-EBT for spring
2022 benefits, see “States Have an Important Opportunity to Address Childhood Hunger This Summer.”
Table 1 shows the states with current or past P-EBT adoptions. P-EBT benefits may be issued retroactively once
states are approved. States can submit plans for approval at any time. P-EBT doesn’t require a state public health
or emergency declaration, but it does require that a national public health emergency declaration related to the
COVID pandemic be in effect during the school year.
While not through Families First, USDA also expanded access to a key flexibility for households to use their SNAP
benefits. The 2014 farm bill created a pilot program for states to test the feasibility and outcomes resulting from
allowing retailers to accept SNAP benefits for online food purchases. In 2019, New York became the first state to
launch a pilot, joined by Washington State in January 2020 and three other states in March 2020 (Alabama, Iowa,
and Oregon). All 50 states and the District of Columbia now have such a program. USDA lists the retailers that accept
SNAP online.
SNAP Operations Waivers
Families First and subsequent legislation allowed states to temporarily adjust their operations to help manage their
workloads and help participants gain and maintain access to the program. Nationally, the number of SNAP
participants grew from about 37 million in February 2020 to about 43 million in June 2020. The number of
participants has fallen since, but in March 2022, the most recent data available, more than 41 million people
participated — 12 percent more than the number of participants in February 2020. State SNAP agencies have had to
manage this greater volume through office closures staffing shortages, and other challenges due a remote work
environment during the pandemic. These temporary adjustments have been critical to help state SNAP agencies
process applications and help keep participants connected to the program, as many state agencies reported in a
2021 survey.
Some states began transitioning off these flexibilities in the second half of 2020, as USDA began approving fewer
extensions, but the October 2020 government funding law restored many of these options. USDA has allowed states
to extend these flexibilities through the month following the end of the national public health emergency, though
states must confirm that their state public health emergency declaration remains in effect every three months. This
guidance also encourages states to use these flexibilities as needed to aid in the transition to regular operations,
such as by applying the flexibility only to a portion of the caseload or reducing the number of households affected by
the flexibility each month.
• Extend certification periods and adjust reporting requirements. SNAP participants get approved to receive
benefits for a certain period, called a “certification period.” Ordinarily, every month a portion of SNAP participants
must submit paperwork and complete an interview to continue receiving benefits when their certification period
ends; this is called the recertification process. Participants must also update or report certain changes in their
circumstances at different intervals, depending on the state.
Most states requested and received this waiver through the initial months of the pandemic; some states stopped
requesting waivers in the summer of 2020. Under December 2021 guidance, states may request to extend
waivers available through the month after the month in which the federal public health emergency ends. Table 2
shows the expiration of states’ most recent usage of this option.
• Waive interview requirements. SNAP rules require all households to be interviewed either in person or over the
telephone by a state eligibility worker at initial application and usually at least once a year thereafter. This
requirement can be an important way for states to gather accurate information and for applicants to have their
questions answered, but it can be a labor-intensive task and delay approval. USDA has allowed states to dispense
with the interview temporarily for many households, originally at both initial application and recertification, as long
as state agencies verify identification and households provide mandatory verifications, such as of income. USDA
also has allowed states to approve, without an interview, households that are entitled to shortened timelines for
processing applications (known as “expedited processing”) due to their very low incomes and resources, provided
that state agencies verify the households’ identity and attempt to contact them. Finally, USDA has allowed states
to not offer in-person interviews and to waive the requirement that state agencies provide in-person interviews
upon request from SNAP participants and applicants.
There is evidence that some states apply these flexibilities only to some SNAP households. For example, a 2021
survey of state SNAP agencies found that most continued to conduct interviews for some households, such as
when information was missing or incomplete, even when they waived the interview requirement.
Over 40 states took up USDA’s spring 2020 nationwide waiver of the required interview at the application or
recertification stage to ensure that newly eligible households can access food assistance through SNAP and that
those already participating can remain enrolled. Many states began transitioning off the waivers, but the October
2020 government funding law allowed states to implement the original versions of the waiver through June 2021
without requesting USDA approval, and many states began using this flexibility again. Under the December 2021
guidance, states may continue this flexibility through the month after the month in which the federal public health
emergency ends. Table 2 shows the states extending this flexibility.
• Adapt telephonic signature requirements. Before the crisis, many states had implemented technology to let
households apply for SNAP by phone, including using a stored telephonic signature. Current regulations require
states to record verbal assent in an audio file to ensure that there is a record of applicants understanding and
agreeing to information gathered and used by the state worker. The waiver allows states to take SNAP
applications by phone by allowing a state eligibility worker to document the household’s attestation to the
collected information on the client’s behalf without requiring a recorded signature. This temporary step has
helped states process applications in the pandemic environment, where offices have been closed in many states
and not all clients can access online applications. USDA has continued to allow states to extend this waiver, as
shown in Table 2.
• Use periodic report procedures instead of the more extensive recertification process. SNAP participants are
required to provide updates about their circumstances at certain intervals; this is a much more streamlined
process than recertification, which requires an application and interview. This option, included in the October
2020 government funding law, allows states to extend this flexibility for households due to recertify through the
month after the month in which the federal public health emergency ends.
Other Administrative Options and Waivers
In addition to extending approvals for states to use flexibility under existing SNAP regulations, USDA has approved and
extended other waivers under Families First that temporarily suspended administrative requirements for states, not
shown in the tables below. USDA has continued to let states request these options through the month after the month in
which the federal public health emergency ends.
6
USDA also had introduced some limited options in the fall of 2020
meant to transition states to regular operations, but because the October 2020 government funding law restored many
flexibilities that had been previously offered, states stopped using those narrower options.
7
In addition, USDA has approved waivers to modify aspects of states’ quality control processes. States must independently
check the accuracy of household eligibility and benefit levels for a share of their cases each month. The process typically
involves an in-person interview with households, often at their home. All states opted to use Families First’s flexibility to
conduct quality control interviews by phone instead of in person, which USDA made available through June 2022. USDA
approved state extensions of the waiver through June 2020 for 49 states, approved extensions of the waiver for all states
through December 2020, and notified states in April 2021 that they could request this waiver through December 2021.
Also, in March 2020 USDA gave all states and territories participating in SNAP an extension of the deadlines for reporting
findings from households that were reviewed in December 2019 through February 2020. USDA subsequently allowed all
states and territories participating in SNAP to suspend these reviews for March, April, and May 2020. Later legislation
suspended many requirements related to these reviews for June 2020 through June 2021, when they resumed.
8
FIGURE 1
FIGURE 1
TABLE 1
Pandemic EBT, as of August 16, 2022
State
Provided
benefits for
households
with children
missing school
meals in 2019-
2020 school
year
1
(P-EBT)
Provided P-
EBT,
August-
Sept.
2020
1
Provided P-
EBT to school-
aged children,
2020-2021
school year
1
Provided
P-EBT to
children
under age
6, 2020-
2021
school
year
2
Provided P-
EBT,
summer
2021
Provided P-
EBT to
school-aged
children,
2021-2022
school year
Provided P-
EBT to
children
under age 6,
2021-2022
school year
Provided P-
EBT,
summer
2022
Alabama
X
X
X
X
X
X
Alaska
X
X
X
X
Arizona
X
X
X
X
X
X
Arkansas
X
X
X
X
X
X
X
California
X
X
X
X
X
X
X
X
Colorado
X
X
X
X
X
X
X
Commonwealth of the
Northern Mariana
Islands
3
X
X
X
Connecticut
X
X
X
X
X
X
X
Delaware
X
X
X
X
X
X
X
X
District of Columbia
X
X
X
X
X
X
X
Florida
X
X
X
X
X
Georgia
X
X
X
X
X
Guam
X
X
Hawai’i
X
X
X
X
X
X
X
Idaho
X
X
X*
Illinois
X
X
X
X
X
X
X
Indiana
X
X
X
X
X
X
X
X
Iowa
X
X
X
X
Kansas
X
X
X
X
X
X
Kentucky
X
X
X
X
X
X
X
Louisiana
X
X
X
X
X
X
X
Maine
X
X
X
X
X
Maryland
X
X
X
X
X
X
X
Massachusetts
X
X
X
X
X
X
X
X
TABLE 1
Pandemic EBT, as of August 16, 2022
State
Provided
benefits for
households
with children
missing school
meals in 2019-
2020 school
year
1
(P-EBT)
Provided P-
EBT,
August-
Sept.
2020
1
Provided P-
EBT to school-
aged children,
2020-2021
school year
1
Provided
P-EBT to
children
under age
6, 2020-
2021
school
year
2
Provided P-
EBT,
summer
2021
Provided P-
EBT to
school-aged
children,
2021-2022
school year
Provided P-
EBT to
children
under age 6,
2021-2022
school year
Provided P-
EBT,
summer
2022
Michigan
X
X
X
X
X
X
X
Minnesota
X
X
X
X
X
X
X
Mississippi
X
X
X*
X
X
Missouri
X
X
X
X
X
Montana
X
X
X
X
X
X
X
Nebraska
X
X
X
X
X
X
Nevada
X
X
X
X
X
X
X
New Hampshire
X
X
X
X
New Jersey
X
X
X
X
X
X
X
New Mexico
X
X
X
X
X
X
X
X
New York
X
X
X
X
X
North Carolina
X
X
X
X
X
X
X
X
North Dakota
X
X
X
X
Ohio
X
X
X
X
X
X
X
X
Oklahoma
X
X
X
X
X
X
X
Oregon
X
X
X
X
X
X
Pennsylvania
X
X
X
X
X
Puerto Rico
3
X
X
X
X
X
X
Rhode Island
X
X
X
X
X
X
X
South Carolina
X
X
X
X
X
X
South Dakota
X
X
X
X
Tennessee
X
X
X
X
X
X
Texas
X
X
X
X
X
X
X
Utah
X
X
X
X
X
X
X
Vermont
X
X
X
X
X
X
X
Virgin Islands
X
X
X
X
X
Virginia
X
X
X
X
X
X
X
TABLE 1
Pandemic EBT, as of August 16, 2022
State
Provided
benefits for
households
with children
missing school
meals in 2019-
2020 school
year
1
(P-EBT)
Provided P-
EBT,
August-
Sept.
2020
1
Provided P-
EBT to school-
aged children,
2020-2021
school year
1
Provided
P-EBT to
children
under age
6, 2020-
2021
school
year
2
Provided P-
EBT,
summer
2021
Provided P-
EBT to
school-aged
children,
2021-2022
school year
Provided P-
EBT to
children
under age 6,
2021-2022
school year
Provided P-
EBT,
summer
2022
Washington
X
X
X
X
X
X
West Virginia
X
X
X
X
X
X
X
Wisconsin
X
X
X
X
X
X
X
Wyoming
X
X
X
X
X
Total
52
20
55
51
54
33
36
37
Note: Please see the Food and Nutrition Service (FNS) website for the most current P-EBT approvals with any updates after the "as of" date listed:
https://www.fns.usda.gov/snap/state-guidance-coronavirus-pandemic-ebt-pebt.
1
The Families First law, which originally authorized P-EBT, authorized the program through September 2020 (fiscal year 2020). USDA originally approved states to provide
benefits in the 2019-2020 school year for days when schools were closed, and approved extensions for states to provide benefits in August and September of the 2020-
2021 school year under that law. The October 2020 government funding law extended this option through September 2021 and expanded the program by including
schools using a mix of in-person and virtual learning and certain children under age 6 receiving SNAP benefits. The December 2020 COVID-19 relief package and further
action from the Biden Administration allowed for further simplifications, particularly for children under age 6. States that were not originally approved to issue benefits for
August and September 2020 under Families First may issue benefits for those months once approved for the 2020-2021 school year. All states that were approved after
October 2020 for the 2020-2021 school year were approved to provide benefits dating back to the start of the school year for school-aged children. The American Rescue
Plan allows states to provide P-EBT benefits during the summer of 2021 and throughout the COVID-19 pandemic.
2
States that were approved to issue benefits for children under age 6 for the 2020-2021 school year were approved to begin doing so in October 2020.
3
Puerto Rico, which operates a SNAP-like block grant in lieu of SNAP but participates in the child nutrition programs that the states participate in, was excluded from P-EBT
under Families First. The October 2020 government funding law extended the option to Puerto Rico to participate in P-EBT in the 2020-2021 school year. American Samoa
and the Commonwealth of the Northern Mariana Islands, which operate block grants in lieu of SNAP and receive separate grants for child nutrition programs, were also
originally excluded but are eligible to implement P-EBT under the October 2020 law. The American Rescue Plan Act also clarified that the provisions extending the program
to certain children under age 6 apply to those territories (Puerto Rico, Commonwealth of the Northern Mariana Islands, and American Samoa) as well as to states and
territories participating in SNAP. Guam and the U.S. Virgin Islands participate in SNAP and have been eligible for all rounds of P-EBT.
*States with an asterisk are states that only provided summer P-EBT benefits to school-age children (and not children under age 6) in 2021.
TABLE 2
USDA-Approved SNAP Operations Waivers, as of July 18, 2022
Listed by last month option or waiver is in effect
State
Extend
certification
periods and
adjust periodic
reports
Waive initial/
recertification
interviews
Not offer
face-to-
face
interviews
Waive
expedited
interviews
Adapt
telephonic
signature
requirements
Use periodic
report
procedures to
recertify
households
Alabama
Sep. 2022
Sep. 2022
Sep. 2022
Alaska
Jul. 2022
Jul. 2022
Jun. 2020
Jun.2020
Aug. 2020
Arizona
Jun. 2021
Jun. 2022
Jun. 2020
Jun. 2020
Jun. 2022
Arkansas
May 2020
Jun. 2021
Jun. 2020
Jun. 2020
Oct. 2020
California
May 2020
Sep. 2022
Dec. 2021
Jun. 2020
Sep. 2022
Colorado
Jun. 2021
Jun. 2021
Jun. 2020
Jun. 2020
Jul. 2020
Connecticut
Sep. 2022
Sep. 2022
Jun. 2021
Sep. 2022
Sep. 2022
Delaware
Aug. 2020
Sep. 2022
Jun. 2020
Sep. 2022
Sep. 2022
District of
Columbia
Aug. 2022
Oct. 2022
Oct. 2020
Jun. 2020
Jul. 2020
Oct. 2022
Florida
Aug. 2020
Jun. 2021
Jun. 2020
Jun. 2021
Georgia
Jun. 2022
Jun. 2022
Jun. 2020
Jun. 2020
Guam
Jun. 2020
Jun. 2020
Hawai’i
Dec. 2021
Jun. 2022
Jun. 2022
Jun. 2022
Jun. 2022
Dec. 2021
Idaho
May 2020
Illinois
Sep. 2022
Sep. 2022
Dec. 2020
Jun. 2020
Sep. 2022
Indiana
Jun. 2022
Aug. 2020
Jun. 2022
Aug. 2020
Iowa
Aug. 2020
Jun. 2020
May 2020
Kansas
Jun. 2020
Dec. 2021
Jun. 2020
Jun. 2020
Kentucky
Jun. 2021
Jun. 2021
Jun. 2020
Jun. 2021
Louisiana
May 2021
Apr. 2022
Jun. 2020
Jun. 2020
Dec. 2020
Maine
Jun. 2020
Sep. 2022
Jun. 2020
Jun. 2020
Aug. 2020
Maryland
Jun. 2022
Mar. 2022
Jun. 2021
Sep. 2022
Dec. 2021
Massachusetts
Nov. 2022
Nov. 2022
Jun. 2020
Nov. 2022
May 2021
Nov. 2022
Michigan
Jun. 2020
Aug. 2020
Sep. 2022
Jun. 2020
Sep. 2022
Minnesota
Dec. 2021
Mar. 2022
Sep. 2022
Dec. 2020
Mississippi
Jun. 2020
Aug. 2020
Jun. 2020
Jun. 2020
Missouri
Aug. 2020
Jul. 2021
Jun. 2021
Jun. 2020
Montana
Jun. 2020
Jun. 2020
Jul. 2020
Jun. 2020
Dec. 2020
Nebraska
May 2020
May 2020
Nevada
Jun. 2020
Jun. 2022
Jun. 2020
Jun. 2020
New Hampshire
Jun. 2020
Sep. 2022
New Jersey
Dec. 2021
Sep. 2022
Jun. 2020
Jun. 2020
Sep. 2022
New Mexico
Jul. 2022
Dec. 2021
Jun. 2021
Jun. 2020
Nov. 2020
Sep. 2022
New York
Mar. 2022
Jun. 2022
Aug. 2020
Jun. 2021
Sep. 2022
North Carolina
Sep. 2022
Sep. 2022
Jun. 2021
Jun. 2020
Sep. 2022
North Dakota
Jun. 2020
Jun. 2020
Jun. 2020
Ohio
Jun. 2022
Jun. 2022
Jun. 2022
Jun. 2020
Dec. 2020
Oklahoma
Oct. 2022
Nov. 2022.
Jun. 2020
Jun. 2020
TABLE 2
USDA-Approved SNAP Operations Waivers, as of July 18, 2022
Listed by last month option or waiver is in effect
State
Extend
certification
periods and
adjust periodic
reports
Waive initial/
recertification
interviews
Not offer
face-to-
face
interviews
Waive
expedited
interviews
Adapt
telephonic
signature
requirements
Use periodic
report
procedures to
recertify
households
Oregon
Jun. 2022
Jun. 2022
Jul. 2020
Aug. 2020
Jun. 2022
Jun. 2022
Pennsylvania
Mar. 2022
Jan. 2022
Jun. 2021
Jun. 2020
Dec. 2020
Rhode Island
Sep. 2022
Sep. 2022
Sep. 2022
Sep. 2022
Jun. 2020
Sep. 2022
South Carolina
May 2021
Sep. 2022
Jun. 2021
Jun. 2020
South Dakota
Jun. 2020
Jun. 2020
Jun. 2020
Jun. 2020
Tennessee
Aug. 2020
Jun. 2020
Jun. 2020
Texas
Aug. 2022
Aug. 2022
Jul. 2020
Jun. 2020
Utah
Vermont
Nov. 2020
May 2020
Virgin Islands
Dec. 2021
Jul. 2022
Jun. 2021
Jul. 2022
Virginia
Jun. 2020
Sep. 2022
Jan. 2021
Jun. 2020
Jun. 2020
Washington
Jun. 2022
Jun. 2022
Mar. 2022
West Virginia
Sep. 2022
Sep. 2022
Dec. 2021
Sep. 2022
Dec. 2020
Wisconsin
Dec. 2021
Sep. 2021
Sep. 2022
Wyoming
Total
48
48
43
42
25
13
Notes: This table includes waivers under the Families First law, which require USDA approval, and were originally largely approved from March through
August 2020, until USDA gave state agencies the option in May 2021 to request waivers through December 2021 or the end of their state (or the
national) public health emergency. For more on states’ use of waivers, see https://www.fns.usda.gov/programs/fns-disaster-assistance/fns-responds-
covid-19/snap-covid-19-waivers. For extensions approved under the May 2021 guidance, see https://www.fns.usda.gov/snap/extension-covid-19-
administrative-flexibilities-may-2021-and-beyond. This table also includes options from the October 2020 government funding law that did not require
USDA approval and that states implemented through June 2021 (or through December 2021 for the option to use periodic report procedures to
recertify households). For more on states’ use of these options, see https://www.fns.usda.gov/snap/cr-state-options. States can choose how to
implement these waivers, and some states extend these flexibilities for just a portion of their caseload or in otherwise limited fashion; this table only
shows states’ usage of these waivers as reported by USDA. This table also shows the last month the state has opted to extend the flexibility; states
may have had months without this flexibility. Please see the FNS website for a spreadsheet of Active COVID Waivers by State for any updates after the
"as of" date listed: https://www.fns.usda.gov/snap/extension-covid-19-administrative-flexibilities-january-2022-and-beyond.
Sources: USDA Food and Nutrition Service (FNS) and state agencies
Updated January 25, 2023
1
In July, Department of Health and Human Services (HHS) Secretary Xavier Becerra renewed the federal public health emergency (PHE)
through mid-October. Recognizing the significant changes that will need to happen at the end of the PHE and the need for adequate time to
prepare, HHS has promised states that it will provide 60 days’ notice before ending the PHE.
2
A state in which the governor or a state agency (such as the health department) has declared a public health emergency is eligible to issue
emergency allotments. States may issue allotments for one additional month following the last month the emergency declaration is in effect.
As of August 2022, 16 states (Arizona, Arkansas, Florida, Georgia, Idaho, Indiana, Iowa, Kentucky, Mississippi, Missouri, Montana, Nebraska,
North Dakota, South Dakota, Tennessee, and Wyoming) had stopped issuing allotments. Other states may also cease issuing these allotments
in coming months.
3
Puerto Rico, the Commonwealth of the Northern Mariana Islands, and American Samoa, which receive nutrition block grants instead of
SNAP, were not originally included in P-EBT and could not issue those benefits for the 2019-2020 school year; the October 2020 government
funding bill extended eligibility to them. Guam and United States Virgin Islands do participate in SNAP and have had the same eligibility as
states.
4
P-EBT benefits can be issued to eligible school-aged children to cover a period "in any school year in which there is a public health
emergency designation" or "in a covered summer period following a school session," which means that P-EBT benefits for school-aged children
could extend for some period beyond the end of the public health emergency. However, P-EBT benefits for eligible children under age 6 can
only be issued for periods "during a public health emergency." See Section 1101(a) and (h) of the Families First Coronavirus Response Act (7
U.S.C. 2011 note; Public Law 116-127).
5
All states except North Dakota have been approved to provide summer 2021 P-EBT benefits, but Mississippi and Idaho were only approved
to provide those benefits to school-aged children.
6
For a brief summary of many of these waivers, all of which can be found at the Food and Nutrition Service, see “SNAP: COVID-19 Waivers by
State,” https://www.fns.usda.gov/disaster/pandemic/covid-19/snap-waivers-flexibilities. USDA has allowed state agencies to extend these
through month after the month in which the federal public health emergency ends as well.
USDA originally allowed 25 state agencies to temporarily stop pursuing certain claims and not consider related payments delinquent. (When
SNAP households receive more benefits than they are eligible for — for example, because the SNAP eligibility worker made a mistake, or the
household misunderstood the rules or provided incorrect information by mistake or intentionally — SNAP state agencies must collect the
amount overpaid, unless pursuing the claim is not cost effective.) All of these states had these waivers extended through June 2020, and
some 13 states received July 2020 extensions, with smaller numbers approved for extensions past July 2020, including at least four states
extending through December 2021. USDA also approved one state (California) for an extension on submitting data to USDA on claims
collection. In November 2021, USDA provided options for states facing challenges in administering claims due to the pandemic; several states
have been approved to adjust their overpayment policies.
At least 23 states were approved for waivers to extend the timeframe to complete fair hearings, which states are required to provide for SNAP
participants to appeal a state decision that affects their participation, such as denying or terminating benefits; these hearings are an
important tool for clients to exercise their rights. All of these states had these waivers extended through June 2020 and fewer states were
extended through subsequent months, including at least eight states with extensions through December 2021. These waivers have now
expired.
At least four states have received waivers to extend the timeline for administrative disqualification hearings, which states must provide to
determine that an individual has committed an intentional violation of program rules (such as making a false statement). Fewer states were
approved past June 2020.
USDA approved several state waivers to temporarily suspend use of the Income and Eligibility Verification System, a database in which states
ordinarily must verify certain income and other information in spring 2020.
Three states received approval to extend the period of time granted to households that have attempted to but are unable to provide a Social
Security number, and USDA approved some states to continue to extend these waivers through December 2021. As of August 2022, four
states are still operating under this waiver.
At least two states received approval in spring 2020 to delay notices that states must issue to households with multiple EBT card replacement
requests.
Three states received waivers to allow certain community partners that assist SNAP applicants with the application process to sign the
application on the client’s behalf after obtaining consent to serve as the client’s authorized representative. USDA has continued to approve
extensions of these waivers for some states.
At least four states were approved to suspend in-person collection of applications and verification documents. Some of those states had
extensions up through December 2021.
At least two states were approved to streamline the process to determine whether individuals are unable to meet certain work requirements.
(Though Families First suspended the time limit nationwide, states that receive funding to offer a slot in a work or training program to
individuals subject to the time limit can still apply the time limit to those individuals unless they have “good cause” for not meeting the
requirements. Similarly, states can determine whether an individual has good cause not to comply with more general SNAP work requirements
for which they could otherwise be sanctioned. One of the waivers streamlines the process to determine whether individuals subject to the time
limit who are offered slots in training programs have good cause. The other streamlines this good-cause determination for individuals subject
to SNAP’s general work requirements.)
7
Beginning in August 2020, USDA limited approvals of many waivers that modified SNAP procedures and began approving states for narrow
versions of these waivers, though these waivers were replaced by the more flexible options included in the October 2020 government funding
law. USDA approved waivers for states, called either “core verification and interview adjustment” or “periodic report flexibility for non-extended
recertification cases” waivers, that give states more flexibility to streamline the renewal process for households that are due to renew in
coming months, such as limiting the number of households required to complete an interview at recertification. These waivers are not shown
in the tables.
8
The October 2020 government funding law suspended these reviews from June 2020 through September 30, 2021; the December 2020
COVID-19 relief package moved up the end of this flexibility to June 30, 2021.
