SNAP Benefits Disruptions

• Routt County issued a press release on October 28. Click HERE to view.
• Teller County launched a local food assistance program. Click HERE to read more.
• Adams County:  Upcoming Community Partner Rapid Response Meeting: Thursday, Nov. 13 at 2 p.m.
  •  Community Rapid Response Community Partner webpage: This is the webpage specifically for you all as community partners with a contact list, resources, and media kits which are in progress.
  • Community Partner Food Bank Capacity:  The shared excel doc has our community food banks most up to date food capacity.
  • Adams County Food Resources: Resources for clients impacted by the federal government shutdown
  • Adams County Serves: This webpage highlights ways our community can donate, volunteer, and support

Nov. SNAP Benefits:

As of 4 p.m. on today, Nov. 7, the federal government and USDA Food and Nutrition Service has been directed to cover full November benefits to both ongoing and new SNAP recipients. All SNAP recipients will receive their full Nov. benefits on their EBT cards within the next week.

News from Colorado Department of Human Services (CDPHS):

Please see the press release here and updated client comms.

News from NACo:

• This afternoon, FNS released guidance (see below) that they are working toward implementing full November benefit issuances.
• This afternoon, we expect a ruling on the appeal made by DOJ on the orders that required USDA to utilize the SNAP contingency fund for partial benefits, and the ruling that called on USDA to use its transfer authority to fund November benefit issuances.
• NACo, along with the other “Big 7” state and local organizations, have once again called on Congressional leadership to find an end to the government shutdown.

News from NACo:

On November 4, USDA released guidance to administrators outlining their plan to distribute the SNAP contingency fund to states, in response to the two SNAP lawsuits in the email below from last week. USDA also released issuance tables that reflect the reduced maximum allotments for households. However, after an analysis by the Center for Budget and Policy Priorities yesterday that claimed these revised allotments are lower than what is required by the court’s rulings last week, FNS revised the issuance tables last night. Due to this revision, SNAP recipients will receive a higher benefit amount from the contingency funds than FNS originally instructed. 

Additionally, a district court in Rhode Island has a hearing set for today on a motion that calls for USDA to provide full funding for SNAP benefits, meaning that they would have to utilize additional funding separate from the SNAP Contingency Fund. We will keep you posted on the results.

There are a few companies that are offering discounts to SNAP recipients, including Instacart, DoorDash, and GoPuff. Read more here.

News from NACo:

NACo Calls for the Release of SNAP Contingency Funds: This morning NACo, along with the National League of Cities (NLC), sent a letter to the U.S. Department of Agriculture calling for the release of the SNAP contingency funds. You can read the letter HERE.

SNAP Lawsuits: This afternoon, U.S. District Judge Jack McConnell ordered USDA to utilize contingency funds to maintain at least some of the benefits issued each month. In a separate lawsuit that was brought on by state attorney generals and governors, U.S. District Judge Indira Talwani gave USDA until Monday to decide how it will distribute benefits, either reduced or in full, and said that they “are likely to succeed on their claim that … suspension of SNAP benefits is unlawful.” As I mentioned yesterday evening, even with this ruling, (or even if lawmakers were to reopen the government today), SNAP benefits would still be delayed. It is unclear at this time if the Justice Department will try to appeal the decision. More can be read HERE.

NACo County News Article: Today, NACo County News published an article on counties, community organizations, and food banks efforts to mitigate the impact of disruptions to SNAP and WIC. WIC received emergency funds from the Administration this month and is not expected to face the same disruptions as SNAP tomorrow. Last week, NACo joined 43 national organizations in signing a letter urging additional funding to keep the program running well into November. While there are signs that WIC will receive this funding, it has not yet been confirmed. Without it, the program could begin experiencing disruptions as early as next week.

FNS Issues H.R. 1 Guidance on Noncitizen Eligibility: Today, FNS published guidance on the implementation of the changes to non-citizen eligibility under H.R. 1. Same as the guidance on the changes to the ABAWD time limit, the guidance states that the hold harmless period for states and counties to implement these changes begins tomorrow, November 1.

Retailer Guidance: Available HERE is guidance to this email that was distributed by FNS yesterday, reminding retailers that they are not authorized to offer discounts or services only to SNAP customers, unless they have a SNAP Equal Treatment waiver.

Statement from NACo:

We are expecting a ruling this evening from a federal judge on whether to grant state officials request for a temporary restraining order on USDA’s decision to halt the flow of nutrition benefits due to the government shutdown. At this time, we believe that if the judge rules in the favor of the state officials, USDA could be forced into releasing the SNAP Contingency Funds. The SNAP Contingency Fund contains up to $6 billion, which could partially cover November SNAP benefits, which are estimated to cost $8 billion.

The plaintiffs are disputing USDA’s statements that it doesn’t have the legal authority to use the $5 billion it has in emergency funds to pay for at least part of SNAP. They also argue that USDA could tap Section 32 funds, which it did to tide over the Special Supplemental Nutrition Program for Women, Infants, and Children, to fully fund SNAP next month.

In the event that the case is ruled in the state’s favor, we are hearing that it is likely that SNAP benefits would still be delayed. However, this would likely be on a state-by-state basis as counties/states work through processing benefits with their EBT vendors.

More on the lawsuit HERE.
More on the contingency fund HERE.

• New 10/23 – CDHS has provided county directors with information via email on: “How to use TANF funds and alternatives to EBT cards to help support SNAP clients” for suggestions on how counties can leverage their existing annual TANF allocation to provide emergency food aid through a variety of channels and/or provide clients with alternative ways of accessing Colorado Works and Adult Financial cash assistance.
• New 10/22 – CDHS Media document with FAQs available for your use. And a new heat map with SNAP cases per congressional district & county.
• FNS Memo on SNAP lapse and contingency funds
  • Explainer on contingency funds from the Center on Budget and Policy Priorities (CBPP)

New 10/24 Office of Economic Security (OES) received a guidance letter from FNS on Friday, 10/24. Here are the high-level takeaways:

• Confirms suspension of benefits effective November 1
• “FNS encourages state agencies to limit administrative expenses only to the activities necessary to support the eligibility and issuance processes, integrity/oversight, and system maintenance”
• “Households shall receive retroactive benefits once the suspension is lifted upon the availability of federal funding”
• It clearly states that households can continue to redeem benefits at eligible retailers during November.
• These updates have been incorporated into the media statement & has been sent out to grocery partners.

– On October 15, 2025 CDHS shared with County Directors that on October 10, 2025, the Food and Nutrition Service (FNS) of the U.S. Department of Agriculture (USDA) informed all States to hold the November 2025 benefits of the Supplemental Nutrition Assistance Program (SNAP) until further notice, due to the lapse in federal appropriations resulting from the ongoing federal shutdown.

– On October 16, 2025 CDHS shared with counties a link to a document for all Client Communications regarding this development.

– On October 17, 2025, Governor Polis issued the following statement, “Looming Federal SNAP Shut Off Threatens Colorado Families & Economy”

– CDHS has prepared CBMS to send out automated speed notifications to clients regarding their November benefits and updated the CDHS website, social media, and PEAK portal with messaging to clients.

– As of right now, please direct all clients impacted to: Colorado 211: Dial 2-1-1 or (866)760-5489 or visit https://www.211colorado.org AND/OR Feeding Colorado Resources at https://feedingcolorado.org/find-food/ or info@feedingcolorado.org to identify their local food back.

– For those in your communities that would like to help during this time, please direct them to donate financial cash funds to local food banks and pantries to meet the demand. Cash funds allow food banks to purchase the most food at scale in the quickest way.

– As a reminder, all eligibility workers are to continue to process cases as normal.

Governor Jared Polis announced today that he is requesting $10 million in emergency funding from the Joint Budget Committee to support food banks and pantries across Colorado. The state is also launching a philanthropic initiative through Feeding Colorado to help bridge the gap for families in need.

“We’re providing emergency state support for food banks, extending WIC access, and giving every Coloradan an opportunity to help by donating to FeedingColorado.org/donate,” Polis said.

More than 600,000 Coloradans, half of them children, rely on SNAP benefits, and without federal action, these households face severe food insecurity. Read the full announcement HERE.

CCI hosted a virtual meeting with the Colorado Department of Human Services (CDHS) to brief Commissioners on the situation and discuss county-level impacts and response strategies.

Resources from the Webinar

• Slide Deck: CDHS and CCI Presentation – Addressing Urgent Hunger Needs
• Webinar Recording: Available on the Colorado Counties YouTube channel
• CDHS Client Communications Document: Living Document – SNAP Disruption Updates
• CDHS Webinar on SNAP Benefits: In-chat Questions for CDHS on Expiration of SNAP Benefits
  • Note: This document will be updated in real time as more details become available.

Here’s what you need to know:

• No November SNAP benefits can be issued until federal funding resumes.
• New SNAP applicants after October 15 will receive October benefits only for now.
• Ongoing SNAP households will not receive November benefits on the usual schedule (Nov 1–10).
• CDHS sent notices to affected households on October 21 explaining the delay.
• Benefits will resume once the shutdown ends, but timing and amount remain uncertain.

What this means for counties:

• Expect increased calls, walk-ins, and frustration from clients who rely on these benefits.
• Staff may need to spend additional time meeting with clients during this difficult period.
• Administrative costs may rise; consider mobilizing volunteers or preparing commodity boxes for clients in immediate need.

What CDHS is doing:

• Preparing clear public messages (texts, emails, web updates, and lobby postings).
• Exploring partnerships with community food pantries to help fill the gap.

How Commissioners Can Help:

• As of right now, please direct all clients impacted to: Colorado 211: Dial 2-1-1 or (866)760-5489 or visit https://www.211colorado.org AND/OR Feeding Colorado Resources at https://feedingcolorado.org/find-food/ or info@feedingcolorado.org to identify their local food back.
• Support local food banks and pantries, encourage donations or volunteer efforts.
• Prepare for higher call and walk-in volumes; consider temporary staffing increases.
• Enhance safety and communication, encourage staff to practice empathy and review security protocols.