Snapshot Mitigating SNAP Benefits Cliffs

Inefficient processes increase states’ administrative costs and prevent eligible families from receiving assistance. Inefficiencies resulting from burdensome administrative requirements can negatively impact both states and families. For example, frequent recertification or in-person interviews can require applicants and participants to miss work and thereby lose employment-related income or conversely lose their SNAP benefits. Additionally, bureaucratic administrative processes often lead to long wait times and application backlogs, which can increase human error in the application review process and result in erroneous application denials. They also contribute to higher administrative costs for states because federal law requires states to cover 50% of SNAP administrative costs. 

Asset limits can have unintended consequences. Under federal law, SNAP participants and applicants are subject to asset or resource limits—meaning they cannot receive assistance if they have assets over a certain value. Proponents of asset limits argue they are necessary to prevent dependence on public benefits; however, some research shows the opposite may be true. For example, asset limits disincentivize savings and leave low-income families more vulnerable to job loss or emergency costs. They may also force low-income families to choose between owning assets, such as a vehicle to get them to work, and receiving SNAP benefits. States have flexibility to eliminate SNAP asset limits through broad-based categorical eligibility. This allows states to bypass the federal asset limit if they align their SNAP eligibility requirements with those of other programs such as Temporary Assistance for Needy Families (TANF). 

Absolute income limits are the primary driver of benefits cliffs. Federal law requires SNAP participants and applicants to satisfy gross and net monthly income limits equal to 130% and 100% of the federal poverty guidelines, respectively. Most states have absolute rather than gradual or tiered income thresholds, meaning a small increase in earnings over the income limit can result in a sudden and total loss of assistance. This is a bigger factor when income limits are not indexed to inflation and effectively shrink over time. 

SNAP’s complex income calculations can destabilize household finances. SNAP participants must satisfy income limits, and what counts as income varies by state. Generally, all income is considered for SNAP eligibility determinations, including income received from other public assistance programs. Some deductions are allowable under federal law, such as a 20% deduction from earned income, a standard deduction for small households and a dependent care deduction for work, training or education. Some states also allow deductions for costs such as child support payments. 

Work requirements can be complex and difficult to satisfy. Individuals ages 16 to 59 must satisfy a general work requirement to receive SNAP benefits unless they meet a qualifying exemption. Able-bodied adults without dependents must satisfy an additional work requirement unless they are a veteran, experiencing homelessness, pregnant, age 24 or younger and in foster care on their 18th birthday, unable to work due to physical or mental limitation or have someone in their household under 18. These work requirements must be satisfied by participating in allowable work activities, which vary by state. For example, some states allow education-related activities. For some families, barriers such as the cost or lack of child care and absence of paid family and sick leave make work requirements difficult to satisfy.  

Simplify the certification and recertification process. 

• Indiana (S 334, 2023) simplified administrative requirements for SNAP by shortening the application form, reducing the number of verification requirements and allowing individuals to waive recertification interview requirements. The bill also reduces the occurrence of benefits cliffs by allowing SNAP participants who certify or recertify for benefits under the simplified requirements to remain eligible for benefits for 36 months. 
• New Jersey (A 1715, 2023) authorized the commissioner of human services to establish a standard certification period greater than 12 months for SNAP participants and 24 months if all adult household members are elderly or disabled. 

Make asset limits less restrictive. 

• Arkansas (S 306, 2023) adjusted the asset limit for inflation, sets the SNAP asset limit equal to the federal resource limit at the time the department obtains the waiver and authorizes the department to grant temporary, one-year increases in the asset limit to households whose assets are greater than the federal limit. 
• Michigan (S 35, 2023) eliminated the asset limit for SNAP eligibility. 
• Texas (H 1287, 2023) disregards from the SNAP asset limit up to $22,500 for an applicant or participant’s first vehicle and up to $8,700 for each additional vehicle. 

Adopt tiered income limits. 

• Missouri (S 45, 2023) requires transitional TANF, SNAP and child care assistance for recipients who become ineligible for benefits due to an increase in income. Transitional assistance gradually steps down the monthly benefit proportionate to the increase in income so that recipients experience a 20% reduction of monthly benefits per specified income tier.  

Exclude other public assistance from consideration as income. 

• Arkansas (H 1340, 2023) directed the Department of Human Services to seek a waiver from the U.S. Food and Nutrition Service to exclude veteran disability assistance as income for SNAP eligibility determinations. 
• New York (S 1353, 2023) requires the state’s Commissioner of Social Services to seek any federal waivers necessary to exclude income provided to an individual as part of their participation in a direct cash transfer pilot program from being considered for SNAP eligibility purposes. 

Allow education, training and non-traditional jobs to satisfy work requirements. 

• California (S 609, 2021) requires its Department of Social Services to include adult education and career technical education programs in the list of programs that meet the SNAP employment and training exemption. 
• Oregon (S 609, 2023) requires its Department of Human Services to consider hours worked as a graduate assistant as hours worked in employment for the purpose of meeting employment and training or other SNAP work requirements.