On October 15, the Illinois House Appropriations - Health and Human Services Committee held a subject matter hearing to examine proposed changes to Illinois’s SNAP (Supplemental Nutrition Assistance Program) rules under H.R. 1 ("Big Beautiful Bill Act"). The hearing focused on three central topics:
- Expanded work requirements
- State liability via Payment Error Rate (PER) sharing
- Restrictions on immigrant eligibility
The implications are broad: they could reshape who qualifies for benefits, shift costs from the federal government to states, and disrupt food security for vulnerable populations.
H.R. 1 and SNAP Reform
In July 2025, President Trump signed H.R. 1, a sweeping domestic policy bill that includes significant reforms to SNAP. Key provisions affecting SNAP that were highlighted at the House Committee hearing and in state briefings include:
Expanded work requirements — e.g. raising the age cap for able-bodied adults without dependents (ABAWDs), altering waivers, narrowing exemption categories.
Cost shifting to states via PER-based liability — Illinois, like other states, may be required to bear a portion of SNAP costs tied to its error rate.
Changes in non-citizen eligibility — H.R. 1 restricts which lawful immigrants remain eligible for SNAP.
Other administrative shifts — including freezing provider taxes and reductions or elimination of SNAP-Ed (nutrition education) funding.
The federal USDA has already issued an implementation memo to states explaining many of these changes, noting effective dates and providing guidance.
Given those changes, the October 15 hearing aimed to scrutinize how Illinois will adapt, what costs lie ahead, and how constituents will be affected.
Highlights from the October 15 Hearing
The following is a summary of the scope and content of the October 15 Committee hearing:
Expanding Work Requirements and Narrowing Exemptions
One of the most contentious topics at the hearing involved the expansion of work requirements for SNAP recipients. Under current federal rules, Able-Bodied Adults Without Dependents (ABAWDs) must satisfy work or training requirements and are subject to a three-month limit in a 36-month period unless exempt. H.R. 1 modifies that framework in several ways:
The upper age bound for mandatory work shifts upward. The new law raises the age for work-mandated individuals to 64 (from 54) for ABAWDs.
The dependency threshold narrows: only individuals caring for a child under age 14 are exempt from ABAWD rules, meaning more parents will now be subject to strict requirements.
Exemptions previously allowed for veterans, homeless individuals, foster care leavers, and younger adults are removed under the new law in many circumstances.
Waiver standards are tightened: states outside Alaska and Hawaii may only seek waivers when a local area has an unemployment rate at or above 10% — a threshold few Illinois counties currently meet.
In practical terms, Illinois projects that the pool of SNAP participants subject to new work rules would balloon from around 189,000 to 446,000.
State agencies testified to the significant administrative burden these changes will impose. More staff will be required to screen applicants, monitor compliance, and adjudicate exemptions.
There was also discussion around the “general work requirement,” where H.R. 1 broadens the age window (16–59 currently) to 17–64.
Critics at the hearing warned that many low-income households may find it difficult to meet the 80 hours per month requirement (through work, volunteering, or approved training), especially in communities with limited job or training capacity.
State Liability via Payment Error Rate (PER)
Another focal point was the cost-shifting mechanism tied to a state’s payment error rate — the rate at which SNAP benefits are overpaid or underpaid due to administrative or household errors.
Under H.R. 1:
States with an error rate above 10% may have to cover 15% of the cost of benefits in excess of that threshold in future years.
Illinois recorded an 11% error rate in FY 2024, meaning the state is at risk of liability under the new standard.
Starting in FY 2027, states’ reimbursement rate for SNAP administrative costs will drop from 50% to 25%, putting further financial pressure on state budgets.
Illinois estimates that under these changes, its annual additional liability could reach $705 million.
In addressing these new demands, Illinois anticipates hiring 258 new full-time employees and incurring $20 million in extra annual costs just for eligibility and application administration.
Some hearing participants pressed state officials on strategies to reduce error rates, including leveraging technology, improved training, and adopting best practices from other states. The idea is that by lowering error rates, Illinois could mitigate some of its future financial exposure.
Restrictions on Immigrant Eligibility
One of the most politically charged sections of the hearing revolved around immigrant eligibility for SNAP. Under the new law:
Many immigrants with humanitarian protections — such as refugees, asylees, victims of human trafficking, and certain parolees — will lose eligibility for federally funded SNAP benefits.
Eligible categories will be narrowed to U.S. citizens, lawful permanent residents (LPRs) who have resided in the U.S. for at least five years, Cuban and Haitian entrants, and individuals under the Compact of Free Association (COFA).
The state briefing projected that 20,000 currently eligible refugees, asylees, and parolees in Illinois could be stripped of benefits.
Some argued in the hearing that these changes undermine the principle of assistance to vulnerable populations who rely heavily on SNAP as a safety net.
Illinois lawmakers questioned how these eligibility shifts would be implemented, how notice to affected individuals would occur, and what recourse those individuals might have.
Administrative, Budgetary, and Implementation Challenges
Beyond the core policy changes, the hearing highlighted a series of operational and fiscal challenges facing Illinois:
The freeze on provider taxes and caps on state-directed payments (SDPs) in Medicaid.
The elimination of SNAP-Ed funding was flagged. SNAP-Ed provides nutrition education, outreach, and helps recipients navigate program rules. Its removal would create gaps in awareness and support.
To accommodate the changes, Illinois estimates it will need hundreds of new staff and additional technological systems, at a multi-million-dollar cost.
The timeline for implementation is tight. Some provisions take effect immediately; others phase in over 2026–2028.
State representatives at the hearing stressed the need for clear federal guidance, waiver flexibility, and “good faith” transitions to avoid abrupt coverage losses.
Impacts and Risks: What’s at Stake for Illinois Residents
The following risks and impact vectors were identified during the hearing:
Loss of Benefits for At-Risk Groups
Thousands of Illinois SNAP recipients — particularly low-income adults, new immigrants, and those in tight labor markets — may lose access to benefits if unable to meet stricter work mandates or if disqualified by immigration status.
The expanded work mandates may push some into a “benefits cliff” scenario: if individuals can’t meet 80 hours of work/training per month, they risk benefits termination after three months.
For immigrant communities, the withdrawal of eligibility could exacerbate food insecurity and destabilize families already facing barriers to employment or resources.
Fiscal Pressure on the State Budget
With the new cost-sharing, Illinois could be liable for hundreds of millions of dollars annually.
The state must absorb more administrative burden — staffing, systems, outreach — without matching federal relief.
Tight timelines for implementation may force the state to rush, potentially increasing errors or causing unfair disqualifications.
Administrative Complexity and Implementation Risk
Implementing sweeping eligibility rules, waiver criteria, work verifications, and benefit calculations will require major system overhauls and staff training.
Errors or confusion in transitions could lead to wrongful benefit denials or overpayments, compounding the state’s future PER liabilities.
Insufficient outreach or poor communication may disproportionately harm marginalized communities that lack access to information or assistance.
Legal, Political, and Ethical Concerns
Some stakeholders may challenge the legality or fairness of imposing strict work mandates in areas with limited job availability.
The removal of eligibility for immigrants raises ethical questions about whether the safety net is being weakened for already vulnerable populations.
Illinois policymakers must navigate between implementing the law and protecting constituents from harsh outcomes.
Recommendations and Considerations Moving Forward
During the hearing, committee members and advocacy organizations floated a number of strategies to mitigate harm and improve the state’s readiness. A distilled set of recommendations are listed below:
Pursue “Good Faith” or Transitional Waivers
Seek federal flexibility or transitional phases so that residents are not abruptly cut off as systems are updated.
Invest in Error-Reduction Strategies
Because PER-based liability is a key lever, the state should prioritize reducing overpayments and underpayments through better training, automation, and process improvements.
Intensive Outreach and Education
Particularly for immigrant communities, provide clear notices, multilingual resources, and community partnerships to prevent people slipping through the cracks.
Strengthen Partnerships with Community Organizations
Leverage nonprofit, legal aid, and advocacy groups in navigating clients through changes and appeals.
Evaluate State-Funded Coverage Alternatives for Immigrants
Explore whether Illinois can use state funds or alternative subsidies to buffer the loss of SNAP eligibility for immigrant households.
Monitor Labor Market Capacity and Enforce Waiver Criteria
If a region lacks sufficient jobs or training infrastructure, that should be a basis to petition for waiver or delay in implementation.
Phased Implementation and Testing
Roll out pilot programs or phased transitions in select counties to surface technical and administrative challenges before full statewide deployment.
Legal Review and Safeguards
Ensure that implementation plans respect due process, allow for appeals, and guard against disproportionate impacts on protected populations.
Conclusion
The October 15 committee hearing laid bare the magnitude of the upcoming shifts to Illinois’s SNAP program under H.R. 1. Expanded work requirements, tightened immigrant eligibility, and state-shared financial responsibility all pose profound risks to food security and administrative capacity in the state. How Illinois responds in staffing, outreach, system modernization, and legislative advocacy will determine whether the changes result in widespread hardship or can be managed with minimal disruption.
Additional Resources
H.R. 1 Resource Hub
Federal Reconcilation Package Raises Concerns and a Call for Action to Communicate Impacts