Improving Eligibility Verification to Support Program Integrity

DATE:	April 24, 2025
TO:	State SNAP Agencies
FROM:	John Walk Acting Deputy Under Secretary for Food, Nutrition, and Consumer Services
SUBJECT:	Improving Eligibility Verification to Support Program Integrity

On Feb. 19, 2025, President Donald J. Trump issued Executive Order 14218, declaring his "Administration will uphold the rule of law, defend against the waste of hard-earned taxpayer resources, and protect benefits for American citizens in need, including individuals with disabilities and veterans." Executive Order 14218 directs the United States Department of Agriculture (USDA) to "enhance eligibility verification systems, to the maximum extent possible, to ensure that taxpayer funded benefits exclude any ineligible alien who entered the United States illegally or is otherwise unlawfully present in the United States."

Further, Secretary Brooke Rollins sent a letter to state agencies and Tribal partners that shared her guiding principles for USDA nutrition assistance programs, including a commitment to "[t]ake swift action to minimize instances of fraud, waste, and program abuse" and "[c]larify statutory, regulatory, and administrative requirements."

In compliance with Executive Order 14128 and the Secretaryʼs priority of program integrity, this memo sets the minimum expectations for eligibility verification to ensure that only individuals who meet all eligibility requirements obtain Supplemental Nutrition Assistance Program (SNAP) benefits and prevent "ineligible aliens" from participating in the program.

By law, only United States citizens and certain lawfully present aliens may receive SNAP benefits. The Personal Responsibility and Work Opportunity Reconciliation Act of 1996 (PL 104-193) established that "aliens within the Nation's borders not depend on public resources to meet their needs." SNAP is not and has never been available to illegal aliens.

To ensure that tax dollars do not fund SNAP benefits to illegal aliens or other ineligible aliens, state agencies should carefully examine their identity and immigration status verification practices and make necessary enhancements.

At minimum, state agencies must do the following:

• Verify identity of the applicant (i.e., the intended beneficiary is who they claim to be) and should do so before proceeding to confirm immigration status;
• Collect and verify social security numbers (SSNs) for all household members applying for SNAP benefits;
• Compare SSNs to the Social Security Agency's Death Master File and also use any available information to confirm the SSN belongs to the person who submits it as his or her own.
• Query the Department of Homeland Security (DHS) Systematic Alien Verification for Entitlements (SAVE) system for all alien applicants and complete all additional verification steps prompted by SAVE before determining that the individual meets the qualifying status requirements. State agencies are advised of a letter to Governors from Department of Homeland Security Secretary Kristi Noem that SAVE is now available at no cost and encouraging its use to confirm benefit eligibility;
• Collect immigration documents intended to show qualifying status during the initial application process rather than wait for a prompt from SAVE;
• Pursuant to 7 CFR 273.2(f)(2)(i), and prior to certification of the household, verify United States citizenship for any applicant for whom there is an indicia that the applicant's claim to United States citizenship (whether natural born, naturalized, acquired, or derivative) is questionable through, at a minimum, use of the SAVE system. States are advised DHS has established a mechanism to process a SAVE inquiry without the use of a unique DHS identifier for applicants that claim natural born United States citizenship.

To further enhance verification processes for identity and immigration status, the Food and Nutrition Service (FNS) strongly encourages state agencies to:

• Using 7 CFR 273.2(f)(3), mandate verification of all applicants' claims to United States citizenship by the applicant.
• Adopt the Identity Authentication State Option that allows applicants to authenticate their identity using a set of multiple-choice authentication questions, such as questions on high school attendance, prior addresses, or credit card use;
• States should review the effectiveness of eligibility interviews and their support of accurate eligibility determinations. States should encourage greater use of in-person interviews;
• Discontinue the use of pre-populated application forms to avoid inadvertent carryover of incorrect information; and
• Use SAVE to continuously verify the immigration status of all aliens in the state participating in SNAP since immigration status can quickly change. If changes to immigration status no longer supports a claim to being a qualified alien, SNAP benefits must be discontinued in accordance with program rules.

Receipt of SNAP by illegal aliens and other ineligible aliens is a serious program integrity concern. In 2024, USDA reported $10.5 billion in improper SNAP payments made in the preceding fiscal year alone. This represented nearly 12 percent of payments by SNAP. As reported by the Government Accountability Office (GAO), the failure by state agencies to verify program eligibility requirements was a main reason for improper payments. Citizenship and identity were two of seven examples of eligibility requirements that GAO found state agencies were not sufficiently verifying, leading to improper payments.

State agencies are advised that FNS will assess the effectiveness of identity and immigration status verification practices in regular management evaluations for program compliance. Among other factors, FNS will evaluate whether state agency processes are effective to verify identity and immigration status. Negative findings will result in issuance of corrective actions to ensure state agencies satisfy all statutory and regulatory requirements and that SNAP benefits are only provided to individuals eligible under existing law.

Benefit fraud is unacceptable in all forms, including use by illegal aliens. This guidance serves as a foundation for future compliance endeavors that will not only deter, but end access to benefits by illegal aliens. I appreciate your attention and assistance in making certain only those eligible receive SNAP benefits.

Sincerely,

John Walk
Acting Deputy Under Secretary
Food, Nutrition, and Consumer Services