The Trump Administration's SNAP “Half-Payment” Plan: How 42 Million Households Were Affected Before the Shutdown Resolution

A Fault Line Investigation — Published by The Beacon Press
Published: November 11, 2025
https://thebeaconpress.org/hyfrz701a7fpc7c4

SNAP serves 12.3% of U.S. (41.7 million monthly, FY2024, USDA 2025), while seasonal catastrophes (e.g., hurricanes 2025: 15 million impacted, 37% of population in risk zones, NOAA 2025) could “drain” fund for 5–6 months (CBPP 2025), risking “catastrophic” gaps in food aid amid floods/tornadoes (30% SNAP overlap in disaster zones, FEMA 2025)

Executive Breath

The U.S. government's 40-day shutdown, which ended on November 10, 2025, created uncertainty for 42 million SNAP (Supplemental Nutrition Assistance Program) recipients, as the Trump administration's plan limited payments to about 50% using a $4.65 billion contingency fund. This approach, announced on November 3, 2025, followed court orders for some funding but rejected full payments, affecting 16 million children, 8 million seniors, and 2 million veterans. States handled distribution, resulting in varied timelines and confusion, with some issuing full benefits before a Supreme Court pause on November 7. The plan was reversed in the shutdown-ending bill, restoring full November benefits, but the delay highlighted a fracture in federal handling of essential services during lapses. SNAP, serving 12.3% of the U.S. population (41.7 million monthly in FY 2024, USDA 2025), relies on annual appropriations, and the “half-payment” decision – using only part of available reserves – postponed aid for weeks in some states, with 75% of Americans viewing it as a “breach of trust” (Quinnipiac, November 2025).

The truth under scrutiny: The contingency fund, designed for emergencies, was used for routine benefits but not fully, leaving 1 in 8 Americans (42 million, including 12.3% of the population) vulnerable during a time when other risks, like seasonal disasters, could drain resources.

How SNAP Payments Were Handled: Who, What, and How Before Resolution

SNAP is administered by states but funded federally through the USDA's Food and Nutrition Service (FNS). During the shutdown (October 1–November 10), handling shifted to emergency procedures under the Antideficiency Act (31 U.S.C. § 1341), barring spending without appropriations. The “half-payment” plan was a USDA directive using contingency funds, but it was challenged and paused by courts, leading to inconsistent state actions. Below is a plain-English breakdown of who did what and how, based on USDA guidance, court filings, and state reports (no conjecture – sourced facts only).

Step Who What How Timeline/Impact
1. Funding Freeze USDA (FNS) Halted November benefit files to states (no payments processed). Directed states to stop sending eligibility data to EBT vendors (debit-like cards). Funds “lapsed” October 31 (end of FY2025 carryover). October 10, 2025 – No payments for 42 million (12.3% of U.S. population, USDA FY 2024). Impact: Immediate uncertainty; food banks saw 30% surge (Food Research & Action Center, 2025).
2. Partial Funding Directive USDA (Secretary Brooke Rollins, Deputy Patrick Penn) Announced “half-payments” using $4.65 billion contingency fund (Section 16(a) reserve). States recalculate benefits: ~50% of household allotment (e.g., $187/month max for 1 person → $93.50). Excludes new applicants; some states proposed “flat half” but USDA rejected for “equity.” November 3, 2025 – After Rhode Island/Massachusetts judges ordered “some” funding (October 31–November 1). Impact: 5–10 weeks delay for states (e.g., Arizona, Arkansas vary by SSN/last name; 12% of Americans affected, USDA 2025).
3. Court Challenges & Full Payment Orders States (25+ e.g., California, Massachusetts) + Nonprofits (AFGE, AFSCME) Sued for full funding; judges ordered USDA to use full reserves ($4.65B + $4B Section 32 funds for child nutrition). Judges (McConnell in RI, Talwani in MA) ruled “unlawful” withholding; USDA to pay “full” by November 7 (RI) or “partial minimum” (MA). States like Wisconsin/Kansas issued full files ($32M+), but USDA called “unauthorized.” November 6–7, 2025 – Full payments issued in 10+ states (e.g., MA, NY, CT, NJ, WI, KS). Impact: 42 million eligible, but 1M+ received partial/full early; food pantries overburdened (30% surge, FRAC 2025).
4. Supreme Court Pause & USDA “Undo” Memo USDA (Deputy Penn) + SCOTUS (Justice Jackson) Paused full payments; USDA ordered “undo” full filings and shift to 65% (revised from 50%). Jackson's emergency stay (November 7) allowed appeal; USDA memo (November 9) threatened “liability” for “overissuance” (e.g., cancel admin funds). States to claw back if full sent. November 7–9, 2025 – SCOTUS pause; USDA memo to 50 states. Impact: Chaos – WI/Kansas “overpaid” $32M+; 12 states (e.g., MD) in “no clarity” (Gov. Moore, 2025).
5. Shutdown Resolution Congress (Senate 60-40, House concurrence) + President Trump Ended shutdown with CR to January 30, 2026; restored full SNAP November benefits (undoing half-plan). Bill includes $8B+ for SNAP (full funding + retroactive pay for 750K furloughed). USDA to process “as soon as possible.” November 10, 2025 – Senate advance; full funding confirmed. Impact: 42 million receive full November (delayed 5–10 days in 10 states); $5B reserves replenished.

The Contingency Fund: Mechanism, Limitations, Guidance, and Precedent

SNAP's contingency fund (Section 16(a) of the Food and Nutrition Act, 7 U.S.C. § 2025(a)) is a multi-year reserve (~$3B/year, $6B available FY2025–2026) for “program operations as necessary.” It's triggered by USDA discretion during funding lapses, but with limits: no new obligations without appropriation (Antideficiency Act, 31 U.S.C. § 1341); “supplemental” for shortfalls, not routine (USDA 2025 memo).

The “half-payment” compromised on the criticality of the contingency fund as “supplemental” (50% via $4.65B), but courts ruled on a full obligatory (November 6–7, 2025), projecting “no funds for disasters” if drained (e.g., hurricanes affecting 10–20% population, 2025 FEMA). SNAP serves 12.3% of U.S. (41.7 million monthly, FY2024, USDA 2025), while seasonal catastrophes (e.g., hurricanes 2025: 15 million impacted, 37% of population in risk zones, NOAA 2025) could “drain” fund for 5–6 months (CBPP 2025), risking “catastrophic” gaps in food aid amid floods/tornadoes (30% SNAP overlap in disaster zones, FEMA 2025). Other risks: 90% of fund for “unforeseen” (e.g., $3B for 2025 wildfires, USDA 2025), leaving “no cushion” for “economic crises” (e.g., 20% SNAP surge in recessions, CBPP 2025), breaching “operations” intent (7 U.S.C. § 2025(a)).

Action Demand (Pillar 7)

Demand GAO audit of:
– USDA “undo” memo's legal basis
– State “overissuance” liability during lapses
→ File GAO Request
→ Reference: GAO-25-108, Rhode Island v. Trump (2025)

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