On March 5, 2024, Candice Jacques, a Nashville mother with a two-year-old daughter, was supposed to receive a phone call from the state agency handling her SNAP application. The call never came, according to a federal lawsuit filed the following year. Instead, the agency sent Jacques a “Notice of Missed Interview.” Two weeks later, it denied her application. When she tried again, the agency missed another scheduled call. Jacques spent hours on hold trying to reach someone, at one point waiting two and a half hours before being disconnected and having to start over. It was not until May that her application was approved.
The state had failed to make the call, but Jacques was the one held responsible for missing it. An administrative mistake had become grounds for denying a mother and her child food assistance.
In practice, qualifying for government assistance and successfully obtaining it are two different things. A household can meet SNAP’s income requirements and still be denied benefits because of procedural errors along the way.
The Urban Institute published a nationally representative study which found that in 2024, nearly one in four working-age adults in families receiving SNAP benefits had those benefits stopped or interrupted. More than half of those interruptions were attributed to procedural issues. Among those who lost assistance because of recertification difficulties, 32% said they never received a renewal notice at all.
The consequences of the administrative hurdles in SNAP applications become even more apparent when examining state-level records. The Center on Budget and Policy Priorities (CBPP) analyzed SNAP records from one unnamed state in the Mountain Plains region between 2011 and 2022. Nearly 63% of new applications were denied, and 56% of those denials resulted from procedural failures rather than a determination of ineligibility. These were not merely first-time applicants struggling to enter the system. Among households already receiving assistance, 40% were denied continued benefits during recertification, with procedural failures accounting for 81% of those denials. Even having no earnings was no guarantee of keeping assistance: 39% of recipients who reported no earnings in the preceding year were denied at recertification. Consider that alongside the national finding that nearly a third of those who lost benefits over recertification difficulties reported never receiving a renewal notice in the first place.
The core reason why procedural difficulties account for such a high share of SNAP denials is rooted in state-level policy choices that amplify administrative burden, transforming a tedious verification process into an insurmountable barrier for eligible applicants. According to the CBPP, states wield substantial discretion over the administration and verification of SNAP benefits. States decide how much money to invest in outreach that informs eligible households about SNAP, whether application instructions are written in languages people can understand, and what assistance is available to help them navigate the process.
States also determine how flexible interview scheduling will be and how applicants are expected to submit the documentation required to establish eligibility. Consider what these decisions mean for a parent working an hourly job to support their family. A caseworker's call arrives in the middle of a shift, and answering it could mean losing wages they cannot afford to spare. Missing the call, however, could mean losing the food assistance they rely on to feed their children. What the state records as a missed interview can translate into a family having no money for groceries, despite no change in their financial circumstances. The problem is not merely that the application process is inconvenient. It is that the consequences of failing to navigate it fall on families who may have the least time, money, and flexibility to spare.
In Los Angeles County, researchers studied what happened when applicants were allowed to call for their eligibility interviews at a convenient time instead of waiting for a phone call. SNAP participation increased by 13%. No income threshold had changed. No new category of people had been declared eligible. The government had simply made an existing requirement easier to complete.
Rigorous verification of SNAP eligibility is both reasonable and necessary. A government distributing billions of dollars in public funds has an obligation to prevent improper payments and protect taxpayers. But a verification system should be judged by its ability to accurately determine eligibility, not simply by its ability to prevent benefits from being issued. There is a fundamental difference between denying assistance to someone who does not qualify and denying it to someone who faced significant challenges completing the process required to prove that they do.
That distinction has become especially important under the 2025 federal budget reconciliation law, which introduces substantial financial consequences for states with high SNAP payment error rates. A payment error rate measures the estimated dollar value of benefits incorrectly issued, including both overpayments and underpayments, as a percentage of total benefits distributed. According to the Department of Agriculture, the national payment error rate reached 10.62% in fiscal year 2025 (this includes both overpayments and underpayments). Beginning in October 2027, states with error rates of 6% or higher will generally be required to cover between 5% and 15% of their SNAP benefit costs, using state rather than federal funds.
The goal is to hold states financially accountable for mistakes. But the formula exposes a significant blind spot in how those mistakes are measured. SNAP's payment error rate only applies to households receiving benefits. If an eligible family is denied assistance altogether, the mistake is measured separately and carries no equivalent financial consequence under the new formula. A state therefore faces a direct financial consequence for issuing inaccurate payments without an equivalent consequence for mistakenly denying an eligible household. Under pressure to reduce their error rates, states may respond by adding more documentation requirements, tightening verification procedures, or delaying approvals. For households already struggling to navigate a burdensome application and recertification process, each additional requirement creates another opportunity to lose assistance. Rather than correcting the administrative barriers that already prevent eligible families from receiving benefits, the new financial incentives risk compounding them.
Making benefits harder to obtain does not necessarily make eligibility decisions more accurate. When an eligible household is denied assistance before any benefits are issued, there is no incorrect payment to count toward the state's error rate. The government may have made a mistake, but not one that carries a financial penalty under this formula. States could therefore reduce their exposure to payment errors without improving their ability to distinguish eligible households from ineligible ones. That is the fundamental flaw in this approach to accountability: it creates a financial incentive to avoid improper payments without an equivalent incentive to prevent improper denials. And while those denials may never appear in the figures used to determine a state's financial penalties, their consequences are felt by families who qualify for assistance but are left with less money to put food on the table.
