On July 4, 2025, President Trump signed H.R. 1, which contained several programmatic changes to the Supplemental Nutrition Assistance Program (SNAP), including the introduction of a new benefit cost-share penalty, increases to states’ share of administrative funding, and changes to eligibility and work requirements. As implementation timelines advance and deadlines approach, Governors are charting short and long-term changes to their programs. The SNAP Implementation Post-Reconciliation session at the 2025 NGA Health & Human Services Institute explored solutions for states to strategically curtail payment error rates with minimal delivery disruption for beneficiaries.
Session Panelists
- Dillon Vrosh, Design Lead, U.S. Digital Response
- Maria Reyes-Gaskin, Technical Product Lead, U.S. Digital Response
- Doug Howard, Senior Vice President, Maximus
- Chloe Green, Assistant Director of Policy, American Public Human Services Association
- Moderated by Jess Kirchner, Senior Policy Analyst for Children and Families, National Governors Association
This session kicked off with a brief presentation from U.S. Digital Response (USDR), before opening into a panel discussion on technical solutions to lower payment error rates. USDR, a pro-bono non-partisan organization working with state, local, and tribal governments to build and grow technical capacity in states, USDR is working with a few select states to provide a deep dive into states’ processes and operations for SNAP. Specifically, USDR detailed their recent efforts working with Arizona to identify opportunities to lower the state’s Payment Error Rate (PER) to under 6% by Fiscal Year 2027. USDR’s presentation laid out a tentative process for states or territories to replicate a root-cause analysis with the following estimated timeline:
- Planning and preparation (2-4 weeks)
- Qualitative and quantitative research (2-3 weeks)
- Analysis and synthesis (2 weeks)
Key Recommendations for States and Territories
Quality Control and Case Review:
- Prioritize identifying client-reported changes to their SNAP status to reduce client-driven errors
- Refine criteria for doublechecking cases and leverage top quality-control performers to form a “review team” for complex cases
- Prioritize quality over quantity: focus on scrutinizing high-complexity cases over cases with simple or streamlined applications
- Identify the true drivers of both client and administrative errors by conducting a root-cause analysis of error drivers (e.g., identifying which type of income is more closely associated with errors)
- Involve frontline workers in quality control improvement by gathering qualitative information via interviews or surveys, and incorporate their insight about common client hiccups or confusions that drive errors
- Improve client interview questions and develop standard practices for follow-up questions to increase specificity around identified error drivers (e.g., income disclosures, shelter expenses) as a tool to reduce error rates
- Develop consumer-facing notices, like app updates or call center scripts, that use plain and human-centered language to highlight the stakes of reporting critical information to encourage proactive and honest consumer engagement
Technological Investments
- Consider framing technological or improvement investments as a hedge against benefit penalty costs: what would it cost to not address errors?
- Invest in multi-pronged approaches (like technological improvements or stronger client interviews) that address preventing errors rather than remediating them
- Consider how to leverage AI and automation to mitigate human error, given the complexity of benefit determinations and the need to maximize staff capacity
- Take advantage of the existing state-federal match (50% federal, 50% state) now before states’ share of administrative costs increases to 75% state, 25% federal in October 2026
Workforce Support
- Consider pursuing a waiver for short-term third-party surge capacity: recent indications show that the Trump administration could open flexibility on this option that has been previously prohibited
- Improve frontline workers training quality to ensure that increased training hours yield adequate results given burden on staff time
- Identify workforce overlap for SNAP and Medicaid eligibility determinations to anticipate threats to worker capacity and burnout, map out caseload flow over the course of the year
- Boost staff morale by making intentional efforts to empower and elevate the work of eligibility workers, e.g., increased access to leadership or public praise
- In September 2025, Virginia Governor Glenn Youngkin met with over 1,500 Department of Social Services workers to build momentum for SNAP FORWARD, the Commonwealth’s initiative to reduce SNAP error rates.
Background
Starting in October 2027, states and territories will be forced to pay a benefit cost share penalty, depending on their Payment Error Rate (PER), which is broadly the rate of over- and under-payments to SNAP recipients. PERs are calculated through a complicated quality control process, and in Fiscal Year 2024, the national average PER was around 10%. Under the new rules created in HR. 1, two-thirds of states may have to pay $100 million for a cost-share penalty, which is leading to an intense push from states and territories to decrease PER before the start of Fiscal Year 2028.
