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This Week In Washington

October 17, 2025

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After nearly three weeks, Congress remains in a stalemate with no progress on negotiations to secure a continuing resolution after the lapse in federal funding took effect October 1. APHSA is closely monitoring shutdown developments and engaging with our federal partners to elevate the needs of human services agencies. We will continue to keep state and local CEOs apprised of any changes through our real-time Special Update emails. Additional materials are also available on our member resources page. Please reach out to Lexie Kuznick, Director of Policy and Government Relations, with any questions or ideas on how we can support you.

Administrative Updates

USDA's FNS Warns of Insufficient Funding of SNAP Should Government Shutdown Continue and APHSA Responds


On Friday, October 10, the U.S. Department of Agriculture's (USDA's) Food and Nutrition Service (FNS) sent a letter to states confirming that if the current federal shutdown continues, there will be insufficient funds to maintain Supplemental Nutrition Assistance Program (SNAP) benefits through November.


FNS has shared "that states can continue to conduct activities for which funds were already obligated following approved state plans, but further SNAP Ed or E&T obligations are discouraged until federal funding is provided." APHSA has requested further information on implications for states who were not yet obligated funds for their approved plans and we hope to see this clarification in a forthcoming Q&A.


SNAP is an appropriated entitlement, meaning Congress must appropriate funds to support the continuation of benefits. Below is an outline of our current understanding of the process and possible next steps.


  • Benefit Authority:
  • USDA: A month prior to allocation, USDA sends a line of credit to the Treasury detailing what is expected to be spent in SNAP benefits the next month.
  • State Agency: In that prior month, states also send data to Electronic Benefits Transfer (EBT) processors, detailing what they expect to authorize in SNAP benefits. This timeline can range significantly across states, from the middle of the month to the end of the month. In the aforementioned letter from FNS, they advised states to hold these files until more information is provided.


  • Retailer Authority:
  • USDA also sends the Retailer Electronic Data Exchange File (REDE) to EBT processors, which provides information on which retailers are authorized to accept SNAP benefits for the next month.
  • In a shutdown, it is possible that SNAP retailers can be deauthorized and thus no longer able to accept SNAP or similar EBT benefits. However, APHSA has encouraged FNS to work together with EBT processors to ensure that this does not happen.


For additional context, during the 2018-2019 shutdown, FNS directed states to pre-issue February benefits in January. This decision, however, was met with this response from the Government Accountability Office (GAO).


Today, in response to ongoing questions and needs for urgent clarification, APHSA submitted the following letter on behalf of our members:

APHSA Events

The Public Human Services Attorneys (PHSA) Education Conference kicks off this Sunday, October 19 in Reno, NV. There is still time to register and join us as we host legal professionals across human services for an event that covers legal trends, policy updates, and best practices in public sector law. We hope to see you there!

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