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Re:

USDA Memo Said It Would Not Use Emergency Funds for November 2025 SNAP Benefits

USDA’s October 24 memo opposed using contingency funds for November 2025 SNAP benefits, but court action and a later partial-funding plan changed the agency’s position.
From TheFinanceBase Team3 min to read
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On October 24, 2025, USDA said it would not use SNAP contingency funds for November benefits, arguing that the regular-benefit appropriation for fiscal year 2026 no longer existed. That was USDA’s position during the federal shutdown—not the final outcome: court action followed, and USDA later announced a partial-funding plan.

What did USDA’s October 24 memo say?

USDA said the contingency fund could not pay regular SNAP benefits for fiscal year 2026 because, in the agency’s view, the appropriation for regular benefits no longer existed. Reuters reported that the memo stated: “The contingency fund is not available to support FY 2026 regular benefits, because the appropriation for regular benefits no longer exists.” USDA said it would reserve the contingency funds for natural disasters and other emergencies. It also said it would not use other agency funds for SNAP or reimburse states that chose to fund benefits themselves. Reuters reported the memo’s position on October 24, 2025.

The court’s later chronology says the October 24 directive would suspend all November allotments beginning November 1 until sufficient federal funding was provided or the Food and Nutrition Service (FNS) directed states otherwise. The funding rationale was USDA’s legal interpretation, not a final judicial ruling. The District of Rhode Island court opinion later rejected the cutoff decision as likely contrary to law and arbitrary and capricious.

Did that mean November SNAP benefits were canceled?

No. The October memo described the agency’s position at that point in the shutdown. The court ordered the defendants to distribute funds as soon as possible. It reasoned that contingency funds had been appropriated for program operations and that USDA had not explained why they could not be used, despite prior agency recognition that they could be used during a shutdown.

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The court described different funding paths, including full funding using Section 32 funds, contingency funds, or both, and partial payment from contingency funds. USDA initially chose the partial-funding path. The court record says that on November 3 USDA decided to use $4.65 billion from the contingency fund, which it described as covering 50% of benefits due to each recipient. The opinion also identified a $600 million discrepancy in the defendants’ accounting of remaining contingency funds. Both figures and the court’s discussion appear in the opinion.

What did a 50% reduction mean for a household?

A reduction of 50% to the maximum allotment did not necessarily mean a household would receive exactly half its usual SNAP payment. Actual benefit amounts depend on household circumstances, including income. North Carolina DHHS said USDA directed states to issue November 2025 benefits at a 50% reduction of maximum allotments. For the 2025 benefit year, North Carolina listed a maximum of $994 per month for a household of four and a reduced maximum of $497. Those are maximum amounts, not a prediction of what any particular household would receive. North Carolina DHHS’s November 2025 guidance explains the state figures.

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What should SNAP households check?

  • Check your state SNAP agency’s official updates. The issuance schedule and household amount may depend on your state and circumstances; the available sources do not establish one final nationwide payment date or household-by-household outcome.
  • Check your state benefits account or notice. Use your state agency’s official channel for information about your own allotment rather than assuming the maximum-allotment reduction applies identically to every household.
  • If food assistance is urgent, contact local resources. A state or local social-services agency can direct you to food banks and other available assistance.

USDA’s later update listings show that official guidance continued after the October memo, with updates dated November 7, November 8, and November 13. Those listings establish that guidance followed the initial position, but do not by themselves establish detailed payment timing or final deposits for every state or household. USDA’s SNAP program page is the federal program resource.

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