Illinois is implementing significant changes to the Supplemental Nutrition Assistance Program (SNAP) following enactment of the federal budget reconciliation law, Public Law 119-21, in July 2025. While SNAP continues to provide food assistance to eligible Illinois residents, new work requirements, eligibility changes and shifts in federal funding are altering how the program operates and creating substantial new fiscal exposure for the State.
More than 1.8 million Illinois residents receive SNAP benefits, with approximately $4.7 billion in federal food assistance flowing into the state annually, according to the State of Illinois.
Expanded Work Requirements Now in Effect
One of the most immediate changes involves expanded work requirements for certain SNAP recipients.
Beginning February 1, 2026, Illinois implemented new federal requirements affecting able-bodied adults ages 18 through 64 who do not live with a child under age 14 and are physically and mentally able to work.
Individuals subject to the requirement generally must spend at least 80 hours per month working, participating in an approved employment or training program, volunteering with an approved state or community workfare/training program, or engaging in a combination of qualifying activities. Those who do not meet the requirement and do not qualify for an exemption generally may receive SNAP benefits for only three months during a three-year period.
The federal changes significantly expanded the population potentially subject to these requirements. Illinois officials have warned that the changes could reduce SNAP participation or benefits for hundreds of thousands of residents.
State Administrative Costs Increase October 1
Another major change takes effect on October 1, 2026, when the federal government's share of SNAP administrative expenses decreases.
Historically, SNAP administrative expenses have generally been divided evenly between the federal government and states. Under the new federal law, the federal match drops from 50 percent to 25 percent. This shifts the burden to the state's General Revenue Fund.
Illinois estimates that the change will increase state costs by approximately $80 million annually. The State's FY2027 budget notes that the additional expense will affect the General Funds budget by reducing federal reimbursement while requiring Illinois to provide more funding to maintain SNAP administration. Larger State Fiscal Exposure Could Begin in 2027
An even more consequential change is scheduled to begin October 1, 2027.
For the first time, states may be required to pay a portion of SNAP food benefits themselves. The amount will be determined by each state's SNAP payment error rate, or PER.
A payment error rate measures whether SNAP benefits were issued in the correct amount based on federal eligibility and benefit rules. Importantly, an error does not necessarily indicate fraud; errors can result from mistakes by recipients or administering agencies.
Illinois' FY2027 budget identifies this provision as a potentially significant financial risk. For the first year of the new benefit cost-sharing requirement, states will be able to use their federal fiscal year 2025 or 2026 payment error rate.
If Illinois were subject to the maximum 15 percent state cost share, the State estimates that it could face approximately $705 million annually in additional SNAP costs, based on roughly $4.7 billion in annual benefits.
Consequently, reducing Illinois' SNAP payment error rate has become an important state fiscal issue as well as an administrative priority.
Illinois Responds to Federal Changes
Illinois has taken several steps to prepare for the new requirements.
The State has directed the Illinois Department of Human Services (IDHS) to analyze the primary causes of its SNAP payment error rate and implement policies intended to reduce errors. IDHS has also been directed to work with community organizations to help SNAP recipients understand and comply with the new work requirements and to pursue appropriate federal waivers where available.
Illinois' FY2027 budget also provides additional resources intended to strengthen SNAP administration as the State prepares for the federal changes.
Why Counties Should Pay Attention
Although SNAP is administered by the State of Illinois rather than county governments, the changes could have implications for counties and the communities they serve.
Reductions in SNAP participation could increase demand on food banks, nonprofit organizations and other local safety-net providers. Because SNAP benefits are spent at grocery stores and other authorized retailers, reductions in benefits could also have economic effects in communities across Illinois.
The fiscal implications for state government are also significant. Beginning October 1, Illinois will assume approximately $80 million in additional annual administrative costs, while the future benefit-sharing requirement could create hundreds of millions of dollars in additional state obligations depending on Illinois' payment error rate.
Those costs will become part of the broader state budget picture and could compete with other state priorities important to counties and local government, including state-shared revenue and grant funding opportunities.
What Comes Next
The next important milestone is October 1, 2026, when Illinois' share of SNAP administrative expenses increases to 75 percent.
Attention will then turn increasingly toward the State's payment error rate and preparations for the new benefit cost-sharing requirement scheduled to begin October 1, 2027.
ISACo will continue monitoring implementation of the federal SNAP changes, their impact on Illinois residents and communities, and the potential implications for the State budget and county governments.