The updated numbers matter because SNAP participation is falling as states implement changes to eligibility, work-related rules and program administration under Public Law 119-21, enacted July 4, 2025. At the same time, states are preparing for a new requirement to help pay for SNAP benefits beginning in fiscal year 2028.

CBPP’s tracker, updated July 21, found that the number of children receiving SNAP fell by 1,069,158 across 19 states with public or shared child-participation data. Total SNAP participation in those states fell by 2,442,853 people, or about 12 percent. Child participation fell by about 13 percent.

The most recent state figures generally run through March, April, May or June 2026, depending on the state. Because the reporting periods and definitions vary, the figures should be read as a measure of the change in those states, not as a final national tally.

What the national estimate means

CBPP separately estimates that more than 1.5 million children may have lost SNAP access nationally based on the available state reporting. The organization cautions that the 19-state sample may not represent the country. Arizona’s unusually large decline is one reason the state-level results should not be mechanically treated as a national rate.

CBPP also says USDA data show that total SNAP participation nationwide fell by more than 4.5 million people, or about 11 percent, between the law’s enactment in July 2025 and April 2026. That national comparison uses federal participation data, while the newer child estimate relies on state reporting because federal child-level tables do not provide the same timely national measure.

USDA’s Food and Nutrition Service remains the authoritative federal source for SNAP participation, benefits and payment-error data. Its public tables and state reports do not all update on the same schedule, and the newest month of federal data is often preliminary. State agencies may also count or revise participation somewhat differently.

A decline in participation does not show that every affected household was improperly denied. People can leave SNAP voluntarily, lose eligibility under enacted rules, miss an interview or recertification deadline, face processing delays, or be terminated incorrectly. The available participation figures do not separate those causes for every state.

Why families may be losing assistance

Public Law 119-21 expanded SNAP work-related requirements, restricted eligibility for some lawfully present immigrants and changed benefit and administrative rules. States have had to revise procedures, update eligibility systems, train workers and communicate new requirements to participants.

Those changes can create practical barriers for households that may still qualify under some circumstances. Missing a deadline, submitting incomplete documentation, failing to reach a call center or encountering an agency backlog can interrupt benefits. CBPP has reported examples of increased documentation demands, processing delays and more frequent recertification in some states. Such interruptions can produce “churn,” when a household loses benefits and later reenrolls.

The updated participation figures also do not prove that need has declined. CBPP notes that participation fell in most states and that some of the largest reductions followed changes in policy and administration. But participation data alone cannot measure food insecurity or establish why each household stopped receiving benefits.

States face future SNAP costs

Beginning October 1, 2027, most states are expected to pay between 5 percent and 15 percent of SNAP benefit costs, with the percentage tied to payment-error rates. The law provides delayed implementation for some states with especially high error rates.

USDA reported a national SNAP payment-error rate of 10.62 percent for fiscal year 2025, combining a 9.28 percent overpayment rate and a 1.33 percent underpayment rate. Payment-error rates measure benefit overpayments and underpayments; they do not treat an improper denial or termination of an eligible household as the same type of error.

Using fiscal year 2025 error rates and estimated benefit spending, CBPP projects that 35 states and one U.S. territory could face substantial new costs in fiscal year 2028, totaling roughly $9 billion. Those are projections, not enacted charges or final state budget liabilities. Actual amounts will depend on fiscal year 2025 or 2026 error rates, participation, benefit levels and economic conditions.

The new cost structure could affect state budget decisions and program administration. States may need to spend more of their own money on benefits while also receiving a smaller federal share of administrative costs beginning in fiscal year 2027. Whether that produces tighter eligibility administration, slower processing, reduced access or other changes will depend on state decisions and future federal guidance.

What to watch next

The next important developments include newer USDA participation tables, final fiscal year 2026 payment-error rates, state budget decisions and any congressional or court action affecting the cost shift or SNAP eligibility rules. USDA is not expected to finalize fiscal year 2026 error rates until June 30, 2027, according to CBPP’s analysis.

People who receive a SNAP denial or termination notice should read the stated reason and deadline carefully, contact their state SNAP office and ask about appeal or fair-hearing procedures. The notice may explain whether benefits can continue while an appeal is pending.

Sources

• USDA Food and Nutrition Service SNAP data tables
• CBPP SNAP Tracker, updated July 21, 2026
• Public Law 119-21

The rule was published in the Federal Register on July 20, 2026, and takes effect September 18, 2026. It applies to applications for admission made on or after that date and to adjustment-of-status applications postmarked or submitted electronically on or after that date.

What changes on September 18

The final rule rescinds the public-charge regulations adopted in 2022. Those regulations defined the benefits that could be considered, listed regulatory exemptions and established a more structured framework for determining whether an applicant was likely to become a public charge.

Under the new rule, DHS is removing those regulatory definitions, the specified benefit list, the prior structured minimum-factor framework and the regulatory list of exemptions and waivers. Officers will instead be able to consider means-tested public benefits, the statutory factors and other individualized facts under a totality-of-the-circumstances review.

DHS says the change will restore broader discretion and allow more individualized decisions. The Federal Register says USCIS will issue subregulatory guidance on or before September 18 to inform, but not prescribe, officers’ determinations.

How the transition works

The date an application is filed or submitted matters. Applications for admission made before September 18 are not governed by the new rule. Adjustment-of-status applications postmarked or filed electronically before that date also fall outside the new rule’s application timing.

The final rule says receipt of means-tested public benefits before September 18, 2026, will be considered consistently with the 2022 framework. That framework focused on a narrower set of benefits and circumstances. On or after the effective date, DHS says it will consider receipt of any means-tested public benefits along with other relevant case-specific facts.

The rule does not mean that receiving public benefits automatically results in denial of a visa or green-card application. Officers must assess the applicant’s circumstances as a whole, and the applicable legal standard, statutory exclusions and other protections can vary by immigration category and type of application.

Why families may feel the effects

The policy could affect households that are trying to balance immigration applications with health care, food or housing needs. In mixed-status families, a U.S. citizen child or another household member may receive benefits even when the immigrant applicant is not the direct recipient. Families may still worry that enrollment, household finances or other circumstances could affect an immigration review.

The Associated Press reported that advocates and public-health experts expect the rule to create confusion and discourage some eligible people from seeking assistance. That concern is commonly called a chilling effect: people avoid programs they are legally allowed to use because they fear immigration consequences.

Reuters reported that food assistance and Medicaid could be relevant under the broader approach. The final rule does not create a new closed list of programs, which is one reason the USCIS implementation guidance will matter.

DHS estimates billions in forgone benefits

DHS estimates that federal and state benefit transfers could decline by about $13.05 billion annually as people in households that include immigrants disenroll from or forgo enrollment in public-benefit programs.

That figure is a projection, not a confirmed reduction already occurring. DHS says the estimate is uncertain and could be affected by other policy changes, including separate changes to Medicaid and the Supplemental Nutrition Assistance Program. The agency also says reduced benefit transfers could affect health-care providers, grocery retailers, landlords and other parts of local economies.

What to watch next

USCIS is directed to issue subregulatory implementation guidance on or before September 18. That guidance should help explain how officers will apply the broader discretion, what evidence applicants may need and how different immigration categories are treated, although the Federal Register says the guidance will inform rather than prescribe individual outcomes.

People considering an immigration filing should not assume that using a benefit guarantees denial or that every program is treated the same way. Because the rule’s practical application may depend on the case, the benefit involved and the final USCIS guidance, applicants should consult a qualified immigration attorney or an accredited representative before changing benefits or filing strategy.

Sources

• Federal Register: Public Charge Ground of Inadmissibility, 91 FR 45324
• Associated Press: Trump administration revives rule that may deny green cards to immigrants using public benefits
• Reuters: US to revive rule that could deny green cards to immigrants using public benefits
• USCIS: Public Charge