Matt Suzor is a third-year law student at the University of Maryland Carey School of Law and a guest contributor to this blog.
Update: Since this blog post was written, the 2025 budget reconciliation bill passed. The impacts of the budget bill on the Thrifty Food Plan, effective immediately, call for cost neutrality every five years. This could prevent benefits allocations from being increased to reflect actual food costs, which would result in reduced purchasing power for shopper relying on SNAP benefits. Additionally, SNAP benefits will be reduced by approximately $15 per month for all recipients by 2034. Current estimates find that this will affect 22.3 million American households, many of which will lose these benefits entirely.
How might the 2025 budget reconciliation – the “big, beautiful bill” – impact Supplemental Nutrition Assistance Program (SNAP) dollars going to the over 40 million individuals participating in the program? This is a question widely-debated and protested as Congressional passage of the joint budget resolution necessitates finding $1.5 trillion in overall savings over 10 years.
One aspect of the SNAP program that faces scrutiny in the budget debates is the Thrifty Food Plan (TFP). The 2024 House’s budget Resolution targeted both the TFP and SNAP, calling President Biden’s 2021 revision to the TFP “careless, ill-conceived, and poorly executed.” House Agriculture Committee Chairman Glenn Thompson recommended an alternative funding framework for the next Farm Bill, calling for a sizable cut to SNAP and a provision to reverse the TFP back to pre-2021 levels.
Although the 2025 Joint Budget Resolution (passed on April 10, 2025) does not contain the same call-outs on the TFP or SNAP program, it requires the House Agriculture Committee to find $230B worth of funding cuts over the next 10 years – which would be the largest in U.S. history. A change of this magnitude could have substantial implications on the over 42 million Americans receiving benefits. Given that nearly 94% of SNAP spending goes directly to recipients, which itself spurs local economies via multiplier effects and job creation, this would no doubt impact beneficiaries more than target administrative inefficiencies.
A Change in the Arithmetic
As part of the United States Department of Agriculture’s (USDA) growth over the 20th century, key legislative milestones like the Agricultural Adjustment Acts of the 1930s, strengthened federal oversight of nutrition and food security and allowed the USDA to introduce programs like the food stamp initiative in 1939 and the TFP in 1975. However, despite advances in nutritional science in the following decades, the TFP remained largely outdated until significant reforms were implemented in 2021.
For over 65 years, the USDA determined SNAP inflated-adjusted benefit amounts for its four Food Plans based on nutritional data from its 1955 Household Food Consumption Survey and its economy (thrifty) food plan, developed by government scientists to assess basic minimums for a balanced and nutritious diet for those operating at a low budget. At the time, the USDA assumed that a standard American family of four[1] would eat, among other outdated dietary trends, approximately 12 pounds of potatoes, 25 pounds of milk, 20 pounds of orange juice, and five pounds of fresh oranges a week.
All plans – Thrifty, Low-Cost, Moderate- Cost, and Liberal – were reevaluated in 2007 and adjusted for inflation. Then in the 2018 Farm Bill, Congress directed the USDA to reevaluate the Thrifty Food Plan every five years “to reflect updated data on food prices, food composition, and consumption patterns, and current dietary guidance in the Dietary Guidelines for Americans, 2020-2025.”
In 2021, the Biden administration re-evaluated the Thrifty Food Plan, marking a gravitational shift for the increasing number of Americans receiving SNAP benefits. It replaced those hefty sums of fruit juice and potatoes with recommendations for over 35 pounds of vegetables and nearly seven pounds of whole grains per family of four per week. While the TFP’s assumption about dairy intake remained similar – still projecting that the budgeted American family would consume over 41 pounds of dairy products a week – this section caught up with modern health science by suggesting that low-and-non-fat dairy products account for well over half of the weekly total.
On the back of its studies finding that almost 90% of SNAP participants encountered obstacles to maintaining a healthy diet, with the high cost of nutritious foods being the most common challenge, the USDA created a more comprehensive baseline via the TFP that raised SNAP benefit minimums by 23%. This change granted many SNAP recipients the minimum budget necessary to achieve a semblance of a balanced and healthy diet – an achievement that some hail as the most important of President Biden’s time in office. In dollars and cents, the average household received an average increase in benefits of $36 per person – or about $1.20 per day. However, there is concern that this could be undone.
Are We Heading Back to the Meat and Potatoes Diet?
Any budget cuts to the SNAP program would likely necessitate downsizing total SNAP participation, decreasing minimum benefits via a TFP recalculation, or potentially both.
The next TFP reevaluation is anticipated in 2026. Since that 2021 TFP reconfiguration, there have been multiples calls among prominent government officials to reduce food assistance. The last version of the proposed Farm Bill (H.R. 8467, the Farm, Food, and National Security Act of 2024) included a provision to cap annual increases in the cost of the Thrifty Food Plan (TFP) at the rate of growth in the consumer price index for all urban consumers.
Although the Agriculture Committee members deny any intention to cut SNAP benefits during the current negotiations for the budget reconciliation, the $230 billion in cuts aligns with the estimates from the Congressional Budget Office that the 2021 Thrifty Food Plan reevaluation amounted to a $250 – $300 billion increase in outlays over a 10 year period. More recently, (February 2025) the USDA’s new Secretary, Brooke Rollins, noted in her Vision for the Department’s 16 Nutrition Programs that the new regime is committed to targeting instances of fraud, inefficiencies, and program abuse via budget cuts and new eligibility requirements.
In December 2024, USDA published a commissioned TFP Reevaluation report (authored by Mathematica) that identified three alternative approaches for future re-evaluations that use an entirely different approach from the current optimization model:
- Purchase-based: Based on household food purchase data, identify households that purchase foods making up a healthy diet. The TFP cost would be calculated based on the cost and composition of the foods purchased by the selected households. The Summary notes that difficulties associated with this approach as:
- Menu-Based: Nutritionists develop healthy, lower cost menus that meet current dietary guidance to serve as the basis for the market basket. The TFP cost would be calculated by averaging the costs of the individual menus.
- Economics-based: Model the cost of purchasing a healthy diet based on household food purchase data at varying levels of healthfulness. A demand model would maximize utility based on preferences for food items, subject to cost and nutrition constraints
Although no feasibility testing was done for the alternatives proposed, modeling of what would be defined as “healthy” foods or nutrition guidance for standardized dietary standards would be necessary at the very least.
Signs indicate that policing eligible foods that can be purchased with benefit dollars is the likeliest path that policymakers will attempt. The Healthy SNAP Act of 2025 was introduced to restrict eligible accessory food options for SNAP beneficiaries to exclude “soft drinks, candy, ice cream, or prepared desserts, such as cakes, pies, cookies, or similar products,” and similar bills were introduced in Arkansas and Indiana. Additionally, on May 2, 2025, the CBO published “A Call for New Research in the Area of Nutritional Standards in SNAP,” seeking research on how “adding nutritional standards to SNAP might affect the federal budget,” including that data from “simulation studies suggest that restricting purchases of sugar-sweetened beverages with SNAP dollars would improve health outcomes.”
The new FDA Secretary Robert Kennedy Jr. and USDA Secretary Rollins want to begin a larger policy discussion between states and the federal government about “how we think about nutrition and programs.” They also announced that they are in the process of revising the report that the Dietary Guidelines Advisory Committee delivered under President Biden, which is meant to inform updates to the dietary standards, and they “are going to come up with a document that is simple, that lets people know with great clarity what kind of foods their children need to eat, what kind of foods they can eat, and what’s good for them.”
Given that SNAP participation has risen since the pandemic, program budget reduction and TFP reversion could return Americans to times of greater food insecurity. For those who retain at least some of their benefits, this could mean a TFP that assumes hefty weekly amounts of dairy and starches – which is itself no small potatoes.
[1] A Reference Family is legally defined in the Food and Nutrition Act of 2008 (P.L. 88–525) as “A family of four persons consisting of a man and a woman 20 through 50 years, a child 6 through 8 years, and a child 9 through 11 years.”
The views and opinions expressed on the FBLE Blog are those of the authors and do not necessarily reflect the official policy or position of FBLE. While we review posts for accuracy, we cannot guarantee the reliability and completeness of any legal analysis presented; posts on this Blog do not constitute legal advice. If you discover an error, please reach out to contact@farmbilllaw.org.
