Pending Federal Proposals Would Reduce SNAP Benefits, Including Enrollment of Households with Children

The Supplemental Nutrition Assistance Program (SNAP), known as the Food Stamp Program in New Hampshire, helps families and individuals with lower-incomes put food on the table. Eligibility for SNAP is based on gross and net income, assets, household size, and other factors. Additionally, a large portion of SNAP eligibility is dependent on meeting certain work requirements. In September 2019, 73,671 Granite Staters were enrolled in SNAP, including 28,361 children. About one in nine children in New Hampshire receive SNAP benefits, based on these most recent data. Enrolled older adults and individuals with disabilities also rely on SNAP for food assistance. The median household income for a household in New Hampshire receiving SNAP benefits was only about $23,000 per year, compared to the statewide median of approximately $71,000 per year, averaged over 2013 to 2017.

SNAP helps households near or below the poverty line experience less food insecurity, which is when households are unable to acquire adequate food for one or more household members due to insufficient resources for food. Food insecurity may affect certain individuals more quickly during times of job loss or economic downturns, especially if those individuals and families have lower incomes. SNAP’s eligibility and benefit guidelines are specifically designed to reach individuals and families with lower incomes, as they are more likely to be food insecure. The maximum benefits, which are reserved for households with the lowest net incomes, are $509 dollars per month for a family of three, which is the equivalent of about $1.82 per meal. According to research from the Urban Institute, the estimated cost of a likely meal for SNAP recipients in New Hampshire in 2015 was over $2.40 in every county of the state. Despite these objectively low benefits, research indicates SNAP is one of the most effective programs for reducing food insecurity.

Studies of food insecurity have identified profoundly negative effects on adults and children. Food insecurity in adults has been linked to lower levels of health. The average life expectancy of food insecure individuals was less than their food-secure counterparts. Children experiencing hunger at home are more likely to experience developmental impairments, perform poorly in school, have more behavioral and social problems, and worse overall health than their food-secure peers. Additionally, research studying the long-term effects of youth food insecurity reveals a likelihood of lower incomes later in life.

Thus far in 2019, there have been three major federal proposals from the United States Department of Agriculture (USDA) to change the eligibility guidelines, work requirements, and benefit calculations for SNAP. These proposals have the potential to disenroll thousands of households in New Hampshire, and millions of individuals and families across the country.

Revision of Categorical Eligibility

Broad-based categorical eligibility (BBCE) is a federal rule that has allowed states to expand the eligibility guidelines of SNAP. Thirty-nine states have some form of expanded eligibility. In New Hampshire, expanded categorical eligibility was implemented in 2009 as a result of BBCE, allowing for households with gross incomes up to 185 percent of federal poverty guidelines to be eligible for SNAP if they are receiving non-cash or in-kind benefits from another public assistance program,  Temporary Assistance for Needy Families (TANF). New Hampshire is the only state requiring households have at least one dependent child to be considered under expanded categorical eligibility.

The proposed revision aims to redefine expanded categorical eligibility. The USDA estimates about 3.1 million people, with incomes under 200 percent of the federal poverty guidelines, would be disenrolled from SNAP resulting from this change. The USDA noted this change may increase levels of food insecurity. In New Hampshire, the unique requirement that a dependent child must be in a household for it to be considered for SNAP through expanded categorically eligibility leads to this revision primarily affecting families. In the Granite State, about 3,500 households, all with children, would be disenrolled from SNAP benefits, according to an analysis from Mathematica.

Additionally, many children who receive SNAP benefits are directly certified to receive free or reduced-price school lunches. A federal analysis from the USDA revealed that about half a million children who receive free meals at school would either now need to pay a reduced rate or pay for a full-priced lunch as a result of this proposed rule change. In New Hampshire, portions of state funding for school districts, particularly Adequate Education Aid, are calculated using the number of students who are enrolled in the Free and Reduced-Price School Lunch Program. In addition to potentially disenrolling thousands of families with low incomes, this rule may decrease state aid to certain school districts in New Hampshire.

The comment period for this proposed rule change was reopened on October 18, 2019 and will remain open through November 1, 2019 for comments related to children and school meals. Comments can be submitted for review by the USDA at, linked directly here.

Standardization of State Heating and Cooling Allowances

Households can deduct certain expenses, such as heating and cooling expenses, when calculating their net incomes to determine their SNAP benefits. Currently, individual states are allowed to set their own guidelines and rates for heating and cooling standard utility allowances (HCSUAs), as well as allowances for other types of utilities. This proposed rule change aims to standardize the way states calculate these types of deductions based on a consistent methodology. According to this proposal, the USDA would calculate a state’s HCSUA, which may not reflect heating expenses in New Hampshire in the same manner as current state allowances.

The federal government estimates this change would reduce SNAP benefits on net nationally, with some states seeing overall increases in aid and some states seeing decreases. Nationally, about 16 percent of SNAP recipients would see an increase in aid, and 19 percent would see a decrease.

The comment period for this proposed rule change is open through December 2, 2019. Comments can be submitted for review by the USDA at, linked directly here.

Requirements for Able-Bodied Adults Without Dependents

Able-bodied adults without dependents (ABAWDs) must comply with stringent work requirements, in addition to normal work requirements for most individuals with children, if they require benefits for more than three months in a 36-month period. In areas with a lack of sufficient jobs, states can apply for certain areas to become waiver-eligible, which waives this time limit on benefits. The proposed rule outlines methods to reduce the extent of waiver coverage. Nationally, about two-thirds of ABAWDs would lose benefits after three months. In New Hampshire, a future economic downturn or the closure of a major employer, which would reduce job opportunities and increase unemployment statewide or in a region, may lead to more people needing SNAP benefits. This proposed rule will remove most of the flexibility the state has in applying for waivers in the future, if implemented.

This proposed federal rule change was announced in February 2019 and the comment period was closed in April 2019. This rule change has not yet been finalized or implemented.

Potential Impacts on New Hampshire

All these proposed rule changes have the potential to increase food insecurity. The reduction of federal dollars, which fund all SNAP benefits, flowing to New Hampshire would cause households, particularly households with children, to have fewer resources for food. The largest impact of these three changes would come from the proposal to alter expanded categorical eligibility, which would disenroll thousands of households with children in New Hampshire. This proposal would also have a secondary impact on households with students, as some children currently receiving free school meals would likely have to pay for those meals after being disenrolled from SNAP. Additionally, any enrollment reductions in the Free and Reduced-Price School Lunch Program in New Hampshire communities would affect state aid to local school districts for public education. Higher levels of food insecurity may increase pressure on other assistance programs in New Hampshire to address the additional needs of Granite Staters if these proposals were to take effect.


For an overview of SNAP and the New Hampshire Food Stamp Program, see NHFPI’s updated Fact Sheet, The New Hampshire Food Stamp Program.

For NHFPI’s overview analysis of these three proposed rules, see NHFPI’s Fact Sheet, Three Proposed Rules Changes to SNAP.

To learn more about SNAP and the risks of two of these rule changes, see NHFPI’s recent report, The Potential Impacts of Proposed SNAP Eligibility and Work Requirement Changes on Food Insecurity.

— Michael Polizzotti, Policy Analyst


Updated October 28, 2019