Impact of Federal Changes on SNAP

In the past few years, New Mexico has expanded the reach and impact of the Supplemental Nutrition Assistance Program (SNAP) to address the state’s high food insecurity rate (16.6%)⁴ by taking advantage of available flexibilities built into the federal program, and creating state supplements to maximize benefits. Households earning up to 200% of the federal poverty level ($64,300 for a family of four in 2025)⁵ are currently eligible for SNAP. However, recent federal changes, including harsher work requirements and shifting a share of the cost of benefits to the states, will cause more families and children in New Mexico to face challenges in accessing affordable, nutritious food.

Expanded Work Requirements and Time-Limit Waiver Eliminations Immediately Threaten Benefits

The One Big Beautiful Bill Act (OBBBA) is subjecting many more New Mexicans to a three-month time limit on benefits, unless they meet new, burdensome work reporting requirements.  This change alone is anticipated to impact 55,000 New Mexicans, including 27,000 in households with children ages 14 and older.⁶ An estimated 36% of those recipients are estimated to lose their SNAP benefits entirely.⁷ The full list of changes from the OBBBA include:

• Expanding work requirements to adults up to 65 years old;
• Eliminating work requirement exemptions for veterans, people experiencing homelessness, and youth up to 25 who were previously in foster care; and
• Applying work requirements to parents of children as young as 14, and removing exemptions for full-time caregivers, even if the other parent or another adult in the household meets the work requirement.

Prior to passage of the OBBBA, only adults without dependents or disabilities were expected to meet these time-limit work requirements.⁸ In addition, states had flexibility to request geographic waivers if local economic conditions were worse than national averages.⁹ In New Mexico, 29 counties previously received work requirement waivers¹⁰ for the 16% of SNAP participants subject to time-limit work requirements.¹¹ Under the new provisions in the OBBBA, only counties with an unemployment rate of 10% or higher qualify, leaving all but one county in New Mexico ineligible for a waiver (Luna County).¹²

As a result, previously-exempt SNAP participants are now required to not only find stable employment where it might be difficult to do so, but also document their work hours to continue receiving benefits for more than three months in a three-year period. This additional paperwork barrier, combined with a likely lack of suitable job opportunities, will mean more New Mexicans will lose the benefits they need to keep food on the table. Time and again, research finds SNAP work requirements to be ineffective, because they often cause participants to lose benefits without improving local unemployment rates.¹³

Shifting a Percentage of the Cost of Benefits to New Mexico Will Create Painful Trade-Offs

For the first time, the OBBBA will force a percentage of the cost of SNAP benefits to shift to the states between October 2027 and October 2029.¹⁴ Although the cost shift has a delayed implementation, the upcoming annual expense to states may quickly become unsustainable—potentially leading to more policies that restrict or limit the reach of New Mexico’s SNAP program, and resulting in even more people losing access to benefits.

Under the new provisions, SNAP program error rates will determine each state’s percentage share of benefit costs (see Table 1). Error rates refer to mistakes made in the application or recertification process that are later reported and corrected, and do not signify waste, fraud, or abuse of the program. To avoid a cost shift under the OBBBA, a state must have an error rate below 6%; currently only eight states have error rates low enough for exemption from the cost shift.¹⁵ Since FY 2019, New Mexico’s error rate has ranged from 9.3-14.6%¹⁶, and if this trend persists, the state will have to shoulder an additional $153M annually to maintain benefits at current levels.¹⁷

Table 1: New Mexico’s Error Rate Will Determine the Cost to Maintain SNAP Benefits¹⁸

Loss of Benefits for Previously-Eligible Immigrants

Although undocumented immigrants have never been eligible to apply for or receive SNAP benefits, federal law previously allowed certain “lawfully present” immigrants – including refugees, asylees, and noncitizen survivors of serious crimes, trafficking, or violence who have been granted humanitarian immigration relief – to access federal programs and public benefits. However, following the passage of OBBBA, more than 16,000 lawfully present immigrants in New Mexico will no longer be eligible for benefits that help survivors of violence and trauma to put food on the table while they heal and build a new life.¹⁹