Federal SNAP changes adopted in 2025 shift new costs and responsibilities to states, reshaping how Maryland administers benefits and budgets for one of its largest public assistance programs. With the 2026 Legislative Session approaching, MACo is profiling major issues, including public benefit programs such as supplemental nutrition, that are likely to garner significant attention.
The federal budget reconciliation legislation enacted in July 2025, the One Big Beautiful Bill Act (OBBBA) or HR 1, makes sweeping changes to the Supplemental Nutrition Assistance Program (SNAP), with significant implications for benefit recipients and state finances. While SNAP benefits themselves remain federally funded, the legislation shifts new costs and responsibilities to states and introduces policy changes that will affect program administration, eligibility, and benefit calculations over several years.
As previously covered by MACo, historically, the federal government covered SNAP benefits and split administrative costs with states. Under HR 1, states must now shoulder 75% of administrative expenses. For Maryland, that means increasing its current $115 million share by another $57.5 million annually, totaling roughly $172.5 million a year just to run the program.
HR 1 significantly expands SNAP work requirements by increasing the age range for “Able-Bodied Adults Without Dependents” (ABAWDs) from 18–54 to 18–64 and eliminating many long-standing exemptions.
From the Issue Papers, page 114 of the pdf:
The OBBBA increased the age range for ABAWD work requirements to 18 to 64 and removed exemptions for veterans, people experiencing homelessness, and young adults formerly in foster care. The exemption for caring for a dependent child now applies only to parents with a child younger than 14 (reduced from 18). Furthermore, states can only receive a waiver of the ABAWD three-month time limit in areas where unemployment is greater than 10%. Baltimore City and Dorchester, Kent, Somerset, and Worcester counties had waivers for the ABAWD time limit through June 30, 2025, impacting approximately 10,250 ABAWD customers, but that waiver was discontinued. No Maryland jurisdiction qualifies under the revised exemption criteria.
As a result, Maryland must begin tracking compliance under the new rules as of July 2025, with case closures expected to begin in early 2026 following recertification cycles. The Maryland Department of Human Services (DHS) estimates nearly 80,000 individuals could be affected, though exemptions will still be applied on a case-by-case basis.
Additionally, an HR 1 provision limits automatic eligibility for the Heating and Cooling Standard Utility Allowance (HCSUA) based on receipt of minimal energy assistance. This change is expected to reduce benefits for some households unless they can document actual utility expenses. DHS estimates nearly 119,000 Maryland households will lose the excess shelter deduction and see reduced SNAP benefits, with changes phased in through new applications and recertifications beginning November 2025.
As previously covered by MACo, in fiscal year 2028, states will begin paying for SNAP benefits depending on their “error rate,” or how much they over- or underpaid on benefits in previous years. For the first round of payments, states can choose to use error-rate data from fiscal years 2025 or 2026 to determine their share. However, from 2029 onward, states will use data from three years prior to calculating their annual cost-sharing amount.
From the Issue Papers, page 117 of the pdf:
Beginning in federal fiscal year 2028, states with error rates above 6% must pay between 5% and 15% of benefit costs. Maryland’s error rate has exceeded 10% in recent years, meaning the state could be responsible for the maximum 15% cost share, estimated at roughly $144 million in FFY 2028 and growing to $200 million in FFY 2029.
From the Issue Papers, page 118 of the pdf:
The OBBBA altered SNAP eligibility to exclude certain lawfully present individuals. This change primarily impacts refugees, asylees, and other humanitarian parolees. The exact number of households with this immigration status receiving SNAP benefits in Maryland is unclear. However, DHS advises that in FFY 2024 there were 2,912 refugees, 2,094 asylees, and 2,641 humanitarian paroles or special immigrant visa holders receiving any services through the Maryland Office for Refugees and Asylees.
Collectively, these changes represent a substantial shift in supplemental nutrition or SNAP policy, increasing administrative complexity and state financial exposure while tightening eligibility and slowing benefit growth. Counties, as frontline partners in service delivery, are likely to feel downstream effects as the State implements these requirements and households adjust to the new rules over the coming years.
