SNAP Benefits Double-Dippers Beware: States to Share Your Secrets
Published Date: 3/3/2026
Notice
Summary
The USDA is updating how states share info to stop people from getting extra SNAP benefits in more than one state. This change affects state agencies and aims to keep the program fair and accurate without costing extra money. Public comments on this update are open until May 4, 2026, so everyone can weigh in!
Analyzed Economic Effects
7 provisions identified: 2 benefits, 5 costs, 0 mixed.
States Must Set Up NAC Reporting
Under 7 CFR 272.18(b)(1), 53 State agencies must set up a process to report SNAP caseloads to the National Accuracy Clearinghouse (NAC). Of the 53 agencies, 26 have not yet implemented the NAC and each of those 26 is estimated to need 5,760 hours (36 weeks) to set up reporting for a total of 149,760 one-time burden hours; the revision reports an increase of 48,000 hours compared with the currently approved estimate.
Huge Increase in NAC Queries
Under 7 CFR 272.18(c)(1)-(2), State agencies must query the NAC at new application, recertification, or when adding a household member. FNS estimates about 1,246,146.97 queries per State agency (66,045,789.54 total queries) at roughly 0.0167 hours (1 minute) per query, for 1,102,964.69 annual burden hours nationwide — an increase of 802,246.61 hours compared to the currently approved ICR.
Eligibility Worker Training Burden
FNS estimates 200 eligibility workers in each of the 26 remaining State agencies (5,200 workers total) will need about 10 hours of training each on using the NAC, for a total of 52,000 burden hours. The revised estimate for this training is 52,000 hours (a decrease of 54,000 hours from the currently approved ICR).
Daily Caseload Uploads Required
Per 7 CFR 272.18(b)(2)-(4), all 53 State agencies must submit their SNAP active caseloads to the NAC once per working day (about 261 days/year). FNS estimates 261 daily responses per agency (13,833 total responses) and 1 hour per daily upload for an annual burden of 13,833 hours; FNS reports no change from the currently approved ICR for this activity.
State Actions After Positive NAC Match
When the NAC returns a positive match, State agencies must verify information, issue a notice of match results, and (if applicable) issue a combined notice of match results and adverse action. FNS estimates about 849.87 such responses per State agency (45,043.05 total responses) and revised annual burdens of 4,513.31 hours for verification, 2,256.66 hours for notices of match results, and 2,256.66 hours for combined notices. These revised estimates represent decreases compared with the currently approved ICR (verification decreased by 19,976.88 hours; notices decreased by 18,269.79 hours each).
Removed Individual Verification Burden
FNS removed from this ICR a prior individual/household burden estimate for ‘verification of questionable information following positive NAC match at query,’ which previously estimated 244,413 household responses at 0.0668 hours each (16,326.79 hours). FNS states this activity was duplicative of responding to notices and has been removed, reducing individual/household burden by 16,326.79 hours.
Households Must Respond to NAC Notices
Per 7 CFR 272.18(c)(5) and 273.12(c)(3)(iii), an estimated 45,043.05 individuals/households will need to respond to a notice of match results (and 45,043.05 will need to respond to a combined notice of match results and adverse action). FNS estimates 1 response per household at about 0.0835 hours (5 minutes) each, for 3,761.09 annual burden hours; this revised estimate reflects a decrease of 30,449.66 hours from the currently approved ICR.
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