toseeall.net Nutrition
The Fine Print · Food policy

The Year the Country Stopped Counting

In July 2025 Congress tied state food assistance costs to an administrative error rate. Two months later the Department of Agriculture ended the national measurement of hunger. Vermont's error rate is 5.38 percent and New Hampshire's is 8.85 percent, and the two states are twelve miles apart.

By Jason Coplan August 21, 2026 Reading time · 11 min

Beginning October 1, 2027, most states will pay part of the cost of SNAP food benefits. It will be the first time in the modern history of the program. The amount each state owes is set by a single number: its payment error rate, the share of benefit dollars its caseworkers calculated in the wrong amount.

Vermont's rate for fiscal 2025 was 5.38 percent, the lowest in New England. Vermont will owe nothing. New Hampshire's was 8.85 percent. The Center on Budget and Policy Priorities estimates New Hampshire's obligation at about $15 million a year.

The rule that produces those two outcomes was enacted in the budget reconciliation law of July 2025. Two months later, on September 20, 2025, the Department of Agriculture announced it would stop publishing the annual report that measured food insecurity in the United States.

This piece sets out what each of those decisions does, what the numbers are, and how the two states on either side of the Connecticut River are positioned under the new rules.

I · The measurement

What ended in September 2025#

Each December since the late 1990s, the Census Bureau added a set of questions to the Current Population Survey asking households whether they had cut meal sizes, skipped meals, or gone without food for lack of money. The Agriculture Department's Economic Research Service used the answers to produce the Household Food Security report, the official national statistic on the subject. The framework had been consistent since 2001.

The final edition covered 2024. It found roughly one in seven American households food insecure at some point that year, a population of about 47.4 million people.

USDA's announcement described the reports as "redundant, costly, politicized, and extraneous." The department noted that measured food insecurity had held roughly steady through a period when SNAP spending rose by more than 87 percent, and said it would rely on other data sets. The December 2025 supplement was cancelled.

The argument for ending it

Researchers at the American Enterprise Institute had criticized the measure for years. Their objections: the headline figure covers a full year and includes households that worried about affording food without anyone missing a meal, a distinction routinely lost in news coverage; and at least eleven other federally sponsored surveys ask households some form of food-hardship question.

In July 2026 the same AEI researchers published an assessment of the termination. They identified the loss of a consistent, nationally representative series as the principal cost, and concluded that without it there is no way to evaluate whether nutrition policy changes improve or worsen conditions. Their recommendation was to reinstate the supplement in revised form.

The Food Research and Action Center, CLASP, and CSIS opposed the termination on the same evidentiary grounds. No replacement instrument has been announced.

II · The financing

How SNAP was paid for#

Under the arrangement in place before 2025, the federal government paid 100 percent of SNAP benefits. States administered the program — taking applications, verifying income, determining eligibility, issuing notices — and the federal government reimbursed about half of those administrative costs.

Two consequences followed from that structure. Benefit levels and eligibility rules did not vary with a state's fiscal condition, so a state in recession could not be forced to ration assistance as its revenues fell. And because enrollment rises automatically in a downturn, SNAP functions as an automatic fiscal stabilizer.

States retained discretion over other elements: outreach spending, asset tests, application procedure, and the use of exemptions. Vermont and New Hampshire exercised that discretion differently well before the law changed.

III · The 2025 law

Two cost shifts, thirteen months apart#

The reconciliation law changed both halves of the financing.

Administrative costs. Effective October 1, 2026, the federal match falls from 50 percent to 25 percent. States will carry three-quarters of the cost of running the program. New Hampshire Hunger Solutions estimates the state's additional share at a minimum of $5.75 million a year.

Benefit costs. Effective October 1, 2027, most states pay a share of benefits, on a schedule keyed to the payment error rate.

The schedule

State share of SNAP benefit costs, beginning FY2028

Error rateState paysNotes
Under 6%NothingBenefits remain fully federally funded. Nine states qualified on FY2025 rates.
6% – 8%5% of benefitsNevada entered this tier at 6.20%.
8% – 10%10% of benefitsNew Hampshire's tier, at 8.85%.
10% and above15% of benefitsTwenty states and D.C. were above 10% in FY2025.
13.33% and aboveDelayedStart pushed to FY2029 or FY2030.
For FY2028 a state may use its FY2025 or FY2026 rate, whichever is lower. From FY2029 the share is set by the rate from three fiscal years earlier. Sources: Congressional Research Service; USDA FY2025 payment error rate release, June 2026.

The law also changed eligibility. The age ceiling for work requirements rose from 54 to 64. The exemption for parents now ends when the youngest child turns 14 rather than 18. Exemptions for veterans, people experiencing homelessness, and adults aging out of foster care were removed. Most immigrants holding humanitarian protections lost eligibility. An adult who does not document 80 hours a month of work, training, or volunteering is limited to three months of benefits in any three-year period.

The schedule is not final. A draft farm bill released by the Senate Agriculture Committee chairman on July 31, 2026 would delay benefit cost-sharing by one year, to FY2029, and raise the maximum state share from 15 percent to 20 percent beginning in FY2031. The House-passed bill, H.R. 7567, contains no cost-sharing provision. The Senate committee took up the draft on August 6, 2026.

IV · The metric

What the payment error rate measures#

The rate is the share of benefit dollars issued in an incorrect amount, counting both overpayments and underpayments. It is calculated from federally required quality-control reviews of sampled cases. It excludes retailer trafficking. For the FY2025 calculation, discrepancies below roughly $57 a month were generally excluded.

Three properties of the metric bear on how it functions as a financing trigger.

It does not measure fraud. The errors are largely clerical — a missed pay stub, a late household composition change, a miscalculated deduction. Recipient fraud is handled through separate processes and is not counted here.

It does not measure need. A state's error rate is independent of its poverty rate, its food insecurity rate, and its enrollment.

It responds to caseload composition. Households with variable gig income, multiple part-time jobs, shared housing, or irregular expenses are the most difficult to calculate correctly. A state can lower its error rate by improving accuracy or by carrying fewer complex cases.

The tiering has also produced a documented timing incentive. States at or above 13.33 percent receive a one- or two-year delay before cost-sharing begins. Seven jurisdictions cleared that bar on FY2025 rates and owe nothing in FY2028: Alaska, the District of Columbia, New Mexico, Delaware, Georgia, Illinois, and Oregon. States in the intermediate range begin paying immediately. Testifying to her state legislature, the director of New Mexico's Income Support Division said the division was sequencing corrective measures deliberately, because reducing the error rate before 2030 would forfeit the delay and increase state costs.

The national FY2025 rate was 10.62 percent, against a 2017–2019 average near 6.6 percent. USDA put total improper payments at $10.1 billion. Nine states and the U.S. Virgin Islands finished under 6 percent. South Dakota was lowest at 2.50 percent; Nebraska cleared the threshold by a tenth of a point at 5.90 percent.

Estimates of the aggregate transfer differ. The Center on Budget and Policy Priorities puts it near $9 billion a year on FY2025 rates. AEI, which supports the cost share as an accountability measure, estimates close to $11 billion.

Where the line falls

SNAP payment error rate, FY2025 — selected states

6% line
South Dakota2.50%
Vermont5.38%
Nebraska5.90%
Nevada6.20%
New Hampshire8.85%
National average10.62%
Oregon14.10%
Georgia15.20%
New Mexico16.80%
District of Columbia18.70%
Alaska23.20%
0%6%12%18%24%
Blue: below the threshold, no benefit cost share. Amber and red: cost-sharing tiers. The five highest states shown are above 13.33% and receive a delay, so several owe nothing in FY2028 while New Hampshire, at 8.85%, begins paying. Source: USDA payment error rates for FY2025, released June 2026.
V · Two states

Vermont and New Hampshire under the new rules#

Brattleboro and Keene are about thirty minutes apart. Bellows Falls and Walpole face each other across the river. The two states share a labor market, a grocery market, a housing shortage, and a climate. On the FY2025 error rates they fall on opposite sides of the threshold.

The same valley, two ledgers

Vermont and New Hampshire under the new financing rules

Vermont

5.38% — below the line
Benefit cost share, FY2028
$0Lowest error rate in New England.
People served
≈63,400About one in ten Vermonters, in roughly 39,000 households.
Average household benefit
$319 / moAbout $79 a week. September 2025.
November 2025 lapse
Backfilled$6.3M in state funds for 15 days of benefits; $250,000 to the Vermont Foodbank.
Connecticut River

New Hampshire

8.85% — above the line
Benefit cost share, FY2028
≈$15M / yr10% tier. Rate rose from 7.57% the prior year.
People served
73,528Lowest participation rate in New England, about 5,360 per 100,000 residents.
Average household benefit
$167 / mo62% of participants are in families with children.
November 2025 lapse
No backfillMobile pantries organized with the New Hampshire Food Bank.
Enrollment: Vermont, September 2025 (Hunger Free Vermont testimony); New Hampshire, April 2026 (USDA via NH DHHS). Cost share estimates from the Center on Budget and Policy Priorities. Average benefit figures come from different reporting periods and are not directly comparable.

Vermont#

Vermont administers SNAP under the name 3SquaresVT. The Vermont Foodbank is the state's only statewide application assister, working with applicants in all fourteen counties. Universal school meals use 3SquaresVT enrollment for direct certification, so households that enroll for groceries are certified for school meals automatically. Crop Cash matches benefit dollars spent at farmers markets. State officials, including the treasurer and legislative leadership, have held public events urging residents to enroll and stay enrolled.

When federal SNAP funding lapsed on November 1, 2025 — the first such lapse in the program's history — Vermont's Emergency Board approved $6.3 million to cover fifteen days of benefits for more than 38,000 households, plus $250,000 for the Vermont Foodbank. Rep. Emilie Kornheiser of Brattleboro chaired the joint fiscal committee that moved it. The Vermont attorney general joined a suit by 22 attorneys general and three governors arguing that federal contingency funds were legally available.

Enrollment fell anyway. Hunger Free Vermont told the legislature in February 2026 that approximately 4,000 people had left 3SquaresVT over the preceding year, more than double the prior year's decline and substantially more than the number who lost eligibility outright. The organization attributed the difference to reporting requirements, procedural complexity, and uncertainty about the program's future.

Vermont's enrollment gap is also large. Hunger Free Vermont estimates that about one in four Vermonters would qualify, against roughly one in ten who participate. The Vermont Foodbank estimates that about 60 percent of eligible Vermonters are not enrolled.

New Hampshire#

New Hampshire's 8.85 percent error rate is below the national average of 10.62 percent and second-lowest in New England. It is above the 6 percent threshold, which is the only comparison the statute makes. The rate rose from 7.57 percent in FY2024.

New Hampshire has the lowest SNAP participation rate in New England, roughly 5,360 recipients per 100,000 residents against about 15,205 in Massachusetts. New Hampshire Hunger Solutions calculates that about 32 percent of eligible residents statewide are enrolled, with wider gaps in some counties. Federal funds are available to states that adopt a SNAP outreach plan; Sen. Jeanne Shaheen has stated that New Hampshire went years without one and has been slow to release outreach funding after being required by legislation to implement a plan.

Enrollment fell from 75,831 in April 2025 to 73,528 in April 2026, a decline of about 3 percent. Over the same period, the Gather pantry in Portsmouth reported demand in June up 40 percent year over year. Feeding America's 2026 Map the Meal Gap, using 2024 data, found food insecurity rising in seven of the state's ten counties; child food insecurity reached 18.3 percent in Sullivan County and rose from 14.1 to 16.6 percent in Strafford County.

A state official at NH DHHS described the implementation of the new federal rules as difficult for both the agency and recipients, and said the November 2025 lapse contributed to uncertainty about the program.

VI · Where the demand goes

The charitable system#

For every one meal provided by the charitable food system, 3SquaresVT provides nine.John Sayles, CEO, Vermont Foodbank

That ratio sets the limit on substitution. The Vermont Foodbank distributes through more than 300 partner sites and is, by its own accounting, roughly a ninth the size of the federal program in the state. It is also absorbing federal funding reductions of its own.

SNAP delivers about $155 million a year into Vermont's economy, more than $12 million a month, spent at grocery stores and farmers markets. Benefits not claimed are federal dollars that do not enter the state.

National enrollment is falling. SNAP participation in April 2026 was just over 37 million, down nearly 13 percent from April 2025. Every state but one recorded a decline; half declined by 10 percent or more. Arizona's caseload fell 54.8 percent. Florida, Georgia, and Louisiana each fell more than 20 percent.

Some states have told federal officials they may suspend SNAP operations rather than absorb a benefit cost share.

What can and cannot be measured from here#

Administrative records will continue. Enrollment counts, benefit totals, and payment error rates are all statutory reporting requirements, so the number of people on the program and the accuracy of the calculations will remain public.

Food insecurity will not be measured on the prior basis. The Household Food Security series ended with 2024 data. Feeding America's Map the Meal Gap, state dashboards, and several federal surveys that ask narrower questions remain available, but none reproduces the terminated series or connects to it.

The changes now in progress — the administrative cost shift in October 2026, the benefit cost share in October 2027, expanded work requirements, and the eligibility exclusions already in force — will therefore be evaluated on enrollment and error rates. Whether they change the number of Americans who go without food is a question the federal government has stopped collecting the data to answer.

Sources

  1. USDA, "USDA Terminates Redundant Food Insecurity Survey," September 20, 2025.
  2. Food Research & Action Center, statement on the termination of the ERS food security reports, September 22, 2025.
  3. CSIS, "The Last U.S. Hunger Data."
  4. CLASP, "Fading to Invisible."
  5. American Enterprise Institute, "The End of the Food Security Supplement in the Current Population Survey: Next Steps," July 2026.
  6. American Enterprise Institute, "SNAP's New Cost Share Requirement Is a Blunt, But Necessary Tool."
  7. Congressional Research Service, Insight IN12723, on the cost-sharing schedule and the Senate farm bill draft.
  8. Center on Budget and Policy Priorities, "New Data Underscore SNAP Cost Shift's Harm."
  9. Ballotpedia News, on the FY2025 error rate release, July 13, 2026.
  10. Associated Press via Live 5 News, on state error rates and the cost-sharing exemption, June 25, 2026.
  11. Concord Monitor, "N.H. could face $15M cost-share penalty," July 2, 2026.
  12. New Hampshire Hunger Solutions, hunger data dashboard.
  13. NH Hunger Solutions via NH Food Alliance, analysis of the federal SNAP changes.
  14. New Hampshire Public Radio, "SNAP enrollment drops in NH, nationwide," July 22, 2026.
  15. New Hampshire Union Leader, on the 2026 Map the Meal Gap findings.
  16. Office of Sen. Jeanne Shaheen, on New Hampshire's SNAP outreach plan.
  17. Vermont Department for Children and Families, on the state-funded emergency benefit, October 31, 2025.
  18. Vermont Public, "Vermont will backfill SNAP benefits for at least 15 days," October 29, 2025.
  19. VTDigger, on the state-funded stopgap, October 2025.
  20. VTDigger, on the new work requirements, February 16, 2026.
  21. Hunger Free Vermont, testimony to House Human Services, February 5, 2026.
  22. Vermont Foodbank, "3SquaresVT Provides Help with Groceries."
  23. Vermont Business Magazine, on the nine-to-one ratio and state economic impact, October 1, 2025.
  24. Grocery Dive, "Where SNAP participation has fallen the most," August 17, 2026.
↑ Top