We won’t know the specifics until the proposed rule is published, but we know where this is likely headed from Project 2025 & a similar proposal from the first Trump Administration. The end result will be more hunger & hardship.

Ending BBCE would terminate SNAP for nearly 6 million people nationwide & would have harmful ripple effects, especially for families with children. Kids who are cut off SNAP would also lose automatic enrollment for free school meals & streamlined eligibility for WIC.

It’s wrongheaded & deeply unfair to leave people worse off when they try to get ahead. But that’s what this proposal would do: cut people off SNAP entirely because they earn a small raise or manage to save a bit to weather emergencies.

What we expect to see soon: A proposed rule that would gut broad-based categorical eligibility (BBCE), a longstanding policy 40+ states have adopted that allows people to earn slightly more & build modest savings without immediately being cut off SNAP.

This timeline was always unrealistic, but it was exacerbated by USDA's delays in providing even very basic preliminary guidance & shutdown chaos. The end result: more people will lose SNAP unnecessarily & states are being set up to fail as they face huge new error rate penalties.

I asked Georgetown law prof David Super wtf is going on with this latest demand for states to claw back benefits already sent out.
He says the law doesn't allow for this, and if the USDA is mad that states already sent out SNAP money, too bad—they were following USDA's own guidance. Full comments:

Along the way, USDA also directed states to issue partial benefits, realized they did the math on the reductions wrong, and then directed states to issue *different* partial benefits.

It didn't need to be this way – USDA has the authority to transfer funds to provide full benefits & they should have been ready to do so weeks ago. Their refusal to do so means millions of families who need assistance to buy groceries continue to wait.

While most SNAP households can expect a larger share of their November benefits than they would have gotten under USDA’s initial plan, changing federal guidance will likely cause more delays in getting benefits out to the people who need them.

Under USDA’s revised plan, we estimate over 650,000 households containing nearly 2.6 million people will still receive $0 for November. Another 4.2 million households will receive the minimum benefit for 1- and 2-person households, which is $16 under USDA’s revised plan.

In the revised plan, USDA matched our analysis that a 35% reduction in max benefits is needed to stay within their estimate of available funds, far less than their original 50% cut. But the benefit calculation means most households will see more than a 35% cut to their benefits.