Congress’ “Big Beautiful Bill” that passed last summer could prove to be far more damaging to the Supplemental Nutrition Assistance Program in Illinois than most people know. A SNAP “death penalty” is built into the budget reconciliation law.
Before we go further, there’s a caveat: The US Department of Agriculture’s Food and Nutrition Service has not yet released definitive guidance for how the federal government intends to enforce the law.
As I’ve told you before, Illinois’ SNAP “error rate” (providing too many benefits or not enough) was 11.6 percent last year, according to the U.S. Department of Agriculture. The new law requires states with error rates above 10 percent to pay 15 percent of the SNAP benefit costs.
That would translate to a $705 million price tag for Illinois – which is obviously money the state cannot afford.
Analyses from several experts claim that if Illinois does not lower its error rate and cannot pay the full federal penalty of potentially hundreds of millions of dollars, then the SNAP program may disappear here.
The widely held assumption was that if the state couldn’t pay the error rate penalty, then SNAP spending would be lowered by the same amount. And that could still happen if the coming federal guidance allows the state to reduce eligibility. But benefits would have to be cut by up to 17 percent if none of the $705 million penalty can be paid. Not good in an era of rising grocery prices.
However, according to those experts, if the state can’t pay the penalty in the 2027 federal fiscal year, which begins next October, the entire SNAP program could quite possibly be shut down in Illinois.
An analysis by David Super, the Carmack Waterhouse Professor of Law and Economics at Georgetown University, concluded that “(I)f a state does not pay its state share, USDA could find the state in violation of the Act and terminate the state’s participation on that basis.”
The only option, according to Super, would be if the state cut SNAP eligibility, which would lower the cost of the program and, therefore, the state’s cost share.
This topic came up in testimony to an Illinois House appropriations committee last month by Illinois Department of Human Services Secretary Dulce Quintero. “The state match requirements are all or nothing,” Quintero told the committee. “If we’re unable to pay all of the state share, we will receive no federal funding, putting the entire SNAP program for Illinois at risk.”
Chloe Green with the American Public Human Services Association told the U.S. House Committee on Agriculture in September: “Absent any change to the current legislation, our understanding is that if states cannot pay the funding that has been shifted to them, they will not be able to operate a SNAP program.”
Again, this could change when FNS releases guidance.
The governor’s office is confident the state can lower the state’s error rate (and therefore the penalty) in the coming months. They’re hiring 250 people to tackle the problem. They’re also re-training workers, rolling out some new tech to alert caseworkers to potential errors and to evaluate data collected from recipients, as well as “identify and resolve Integrated Eligibility System defects.” They’re requiring more info about shelter and medical costs (big reasons for the error rates). And they’re reinstating six-month eligibility periods instead of annual reviews, and doing in-person interviews. They’re also conducting a public awareness campaign.
According to IDHS, “inadvertent” recipient errors make up two-thirds of the error rates. An example: “A customer applied for SNAP and reported $570 in monthly rent paid to the landlord. During Quality Control Review, IDHS discovers their rent is $500, with $70 paid to the landlord for utilities and internet.”
Another third is blamed on agency errors: “A caseworker verifies the customer’s income as $525 but accidentally enters $255 in the eligibility system.”
Despite all the hype about fraud, IDHS insists it’s “less than 0.10% of errors.”
Illinois’ error rate has historically been lower than 10.6 percent. The state claims that a big reason for the increase is “technical errors.” Quintero told the House appropriations committee last month that the feds “moved the goalposts” in 2022 by including technical mistakes in the error rates. New Jersey, Quintero pointed out, saw its error rate skyrocket from “below 4 percent to 35 percent” after that federal change.
Whatever the case, a whole lot is riding on the state’s effort to lower its error rates, including possibly the very existence of SNAP here.
Rich Miller also publishes Capitol Fax, a daily political newsletter, and CapitolFax.com.
The reported SNAP error rate in Illinois is 11.6 percent, but the unseen error rate is far higher — at least 60 percent more. This is because current practices misclassify Supplemental Security Income (SSI) and disability benefits as countable income, even when recipients are in poverty. By redistributing SSI payments through federal programs like HUD and SNAP benefit offsets, the system defeats the purpose of SNAP, which was designed to increase food purchasing power and basic subsistence. Because of the state’s accounting practices, families with extremely low income don’t see their income supplemented in the receipt of benefits; their income is replaced with benefits and redistributed across programs.
These misinterpretations inflate adjusted income, reduce eligibility, and distort benefit calculations. They are not captured in USDA’s error statistics, yet they represent systemic overcharges and under‑payments that harm the poorest households. Correcting even simple errors, such as an intake worker omitting the disability deduction, requires an appeal hearing in Chicago, when it is a very simple correction. The underlying problem is unaligned systems and fragmented processes. Every agency has a different method for determining eligibility and calculating income. Federal budget and accounting practices for federal programs are grounded in the Internal Revenue Code, and all federal agencies are required to align their accounting methods to ensure uniformity across government. The rules for the agency are not in compliance itself, what is conveyed is not understood, or its not enforced. There is no oversight at the state level.
SNAP is an entitlement; an inequitable economy makes it necessary. The entitlement cannot be eliminated for state residents. Administration of the program by a state agency can. The state is a pass through for federal funding, but SNAP is dispersed by electronic transfer. It can be paid directly from the federal government in the way that social security disability benefits are. The answer to inadequate administration is not to expand the team at the expense of the principle. I recommend the state, pull out and regroup and approach again with a level head and a clear perspective.