Foodlink submitted the following letter to the Federal Register earlier this month regarding the U.S. Department of Agriculture’s (USDA) Food and Nutrition Administration (FNA)  proposed rule, “Supplemental Nutrition Assistance Program: Changes in Federal-State Administrative Cost Sharing,” which was published on June 24, 2026:

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Please accept Foodlink’s comments below on the United States Department of Agriculture’s (USDA’s) Food and Nutrition Administration (FNA) Supplemental Nutrition Assistance Program (SNAP) Administrative Cost Sharing Proposed Rule.  

Foodlink is a Feeding America food bank serving 10 counties within the Rochester and Finger Lakes region of New York. We act as the hub of the emergency food system for 400+ nonprofits throughout a 7,000-square mile area, and administer myriad programs and initiatives that address both the symptoms and root causes of food insecurity.   

We are writing this letter at the outset of Hunger Action Month, so it’s worth reiterating that SNAP is the most important anti-hunger program in our nation. When SNAP benefits are reduced or interrupted, the need for emergency food goes up commensurately. Since SNAP eligibility criteria changed earlier this year, we have seen consistent increase demand for our services. Any threat to diminish SNAP overburdens the emergency food system and impacts local economies during a time when the cost of food is forcing many families to visit their local food pantry for the very first time.  

More than 150,000 people in our service area rely on SNAP to feed their families. USDA data shows that most of those households include a child, an older adult, or a person with a disability. This translates to approximately one out of every eight neighbors in our service area. That rate doubles or triples in certain zip codes where poverty rates have been historically among the highest in the state.   

This is why we are extremely concerned about USDA’s proposal to reduce the federal reimbursement rate for most SNAP administrative costs from 50 percent to 25 percent beginning in Fiscal Year 2027.  

In New York, this proposal shifts billions of dollars in administrative costs from the federal government to counties. The reduction in federal funding will force local governments to make difficult budget decisions that could reduce administrative capacity and hinder effective program operations. The administration says it is reducing “waste, fraud and abuse” with these new measures. In reality, it is hampering the administrative efforts of the municipalities charged with carrying out those goals – for a problem that does not exist.  

According to the USDA’s latest data, state agency investigators referred 30,238 fraud investigations (typically either trafficking or eligibility fraud) to hearing officials through the court system. Considering 42 million participated in SNAP over the same time period, that equates to a fraud rate of .07%.     

This is a bipartisan issue. Both Republican and Democratic led counties are speaking out against these proposed changes. The Orleans County Legislature recently adopted a resolution urging federal leaders to delay implementation of the SNAP administrative and benefit cost-sharing changes. The resolution reflects growing concern among local governments across New York about the fiscal and operational challenges these changes will create for counties and the families who rely on SNAP assistance.  

The resolution emphasizes the critical role SNAP plays in supporting food security for millions of New Yorkers and sustaining local economies. Under the new federal law, counties in New York would assume new financial responsibility tied to SNAP payment error rates. County leaders argue that these changes represent an unprecedented shift of federal costs to state and local governments, creating substantial unfunded mandates at a time when counties have limited revenue-raising authority and numerous existing obligations.  

Orleans County notes that the new requirements would require additional verification, reporting, staffing, training, and technology investments, adding complexity to an already highly regulated program. The resolution further points out that payment error rates are often the result of administrative or eligibility-processing issues rather than fraud, waste, or abuse, yet counties could still bear substantial financial consequences under the new framework.  

In response, the Legislature calls on Congress to enact a two-year delay of both the administrative cost shift and the SNAP benefit cost-sharing provisions to allow adequate time for planning, implementation, and the development of sustainable funding solutions. The resolution also urges New York State to hold counties harmless should the federal government move forward with these changes, recognizing that local governments are not equipped to absorb the added costs without reducing essential services or increasing the burden on taxpayers. Ultimately, the resolution seeks to protect both vulnerable SNAP recipients and local communities from unintended disruptions and financial hardship.  

We urge USDA to fully evaluate and publicly release a comprehensive regulatory impact analysis of this rule’s operational, fiscal, and human consequences before finalizing it.  

Reducing federal administrative support while expanding state and county responsibilities will strain state budgets, weaken administrative capacity, impede technology modernization, increase operational challenges, and ultimately make it more difficult for eligible households to access nutrition assistance accurately and efficiently.  

We appreciate your consideration.