Testimony delivered on February 26, 2026

Chairperson Frumin and members of the Committee, thank you for the opportunity to testify today. My name is Tazra Mitchell, and I am the Chief Policy and Strategy Officer at the DC Fiscal Policy Institute (DCFPI). DCFPI is a non-profit organization that shapes racially-just tax, budget, and policy decisions by centering Black and brown communities in our research and analysis, community partnerships, and advocacy efforts to advance an antiracist, equitable future.

My testimony focuses on the widespread harm that the One Big Beautiful Bill Act (OBBBA) will have on the Supplemental Nutrition Assistance Program (SNAP) and the actions that the DC Council and Department of Human Services (DHS) can take to reduce this harm.

SNAP serves as the nation’s first line of defense against hunger and is crucial to District economic wellbeing, for both residents and businesses. SNAP’s reach and scope is shrinking drastically under OBBBA, which made the largest cut to SNAP in history and will increase poverty and hunger, including among children.^[1] Approximately 17,000 DC residents are now at risk of losing some or all of their food assistance due to OBBBA’s significant expansion of the SNAP time limit for parents of children aged 14 and up, adults aged 55 to 64, and other vulnerable populations such as people experiencing homelessness.^[2] OBBBA also ends food assistance for residents with a lawful immigration status based on humanitarian need, and it passes the buck to DC lawmakers by shifting substantial new costs onto DC government.

The quality of DHS’s implementation of OBBBA cuts will affect how deep the damage goes. For example, the success or failure of DHS efforts to ensures that no eligible residents lose benefits due to new “red tape” and complexity will determine whether more or fewer District residents can put food on the table. And DHS’s ability to improve its SNAP error rate—which stands at 19.8 percent—amidst an intensive implementation workload will either save, or cost, DC millions of dollars in administrative costs under new OBBBA rules.^[3]

Based on their oversight responses, DCFPI commends DHS for taking comprehensive steps to quickly understand the depth of OBBBA’s changes, making crucial implementation decisions under tight time constraints, and reducing certain reporting burdens on SNAP recipients. Yet, much remains unclear, such as when the clock on countable months will officially begin for adults subject to the time limit and how they will screen for immigration status changes. DCFPI urges the committee to:

• Set a goal to achieve effective implementation of the SNAP changes in ways that do not cut off a single resident or household unnecessarily, sustaining as many families’ access to food assistance as possible.
• Prepare for the shared costs that OBBBA will require in the District budget.
• Continue working with DHS and the advocacy community to provide regular opportunities to share implementation updates, identify and address any challenges, and to track outcomes on the harm that these federal changes will have on DC residents.

The SNAP cuts come at a time when DC residents are likely facing the largest reduction to DC’s safety net in a generation, adding an urgent imperative for DHS to achieve effective implementation of the OBBBA changes to ensure that no one loses their SNAP unnecessarily.

OBBBA Reduces the Reach of SNAP, a Crucial Poverty-Fighting Tool

SNAP is the nation’s most important anti-hunger program, serving about 1 in 4 households in the District and disproportionately serving more Black households than white households.^[4],[5] SNAP helps residents afford a nutritionally adequate diet, directly influencing their health, productivity, and quality of life. Many DC residents face barriers to food security and rely on SNAP due to systemic and racial inequalities, including the high cost of living, wage disparities, and limited access to grocery stores East of the River. For example, more than 30,000 District households—or 1 in 11 households—didn’t have enough nutritious food to eat on a regular basis between 2021 and 2023, on average, due to limited funds and access to food (Figure 1).^[6] SNAP plays a vital role in addressing these challenges by helping residents with low incomes afford the food they need.

Figure 1.

In 2024, before federal lawmakers approved OBBBA, SNAP kept 3.6 million people above the poverty line across the US and reduced the depth of poverty for millions more.^[7] The cuts to SNAP imposed by OBBBA will reduce these gains, including among households with children, older adults, people with disabilities, workers with low and irregular wages, and people with low incomes broadly. Experts estimate that 1 million US children will see their food assistance cut or terminated due to OBBBA, meaning that the federal changes will also worsen child poverty in the District, which already spiked by 11.2 percentage points between 2023 and 2024, the largest year-to-year increase in a decade.^[8]

Under OBBBA, some 17,000 adults could be cut from SNAP due to the law’s expansion of a rule limiting SNAP to three months in a three-year period for certain individuals who can’t document that they are exempt (for example, because of a disability) or are working or participating in a qualifying activity for 20 hours a week or more. The law eliminated the exemption to the work requirement for veterans, people experiencing homelessness, and youth who recently aged out of foster care, and it newly subjected older adults aged 55 to 64 to work requirements as well as adults with children in the home aged 14-17. Of those 17,000 adults, DHS anticipates that up to 12,900 of them may lose their benefits due to the time limit.^[9] In addition, certain immigrants who are living lawfully in the US and have been granted humanitarian protection will be cut from SNAP, and benefits will be reduced for some households without an elderly or disabled member who can’t provide documentation of their utility costs. In addition, by creating the potential for enormous paperwork burdens, the legislation will potentially harm many others.

For the District, this attack on residents’ nutrition and economic wellbeing comes at a particularly damaging time. Federal attacks on DC’s local economy through cuts to the federal workforce and contractors, along with the escalation of attacks on DC’s fiscal autonomy, are already destabilizing local revenues and some residents’ ability to make ends meet. Alongside these historic cuts to SNAP, DC residents are also likely facing the largest reduction to DC’s safety net in a generation. The fiscal year 2026 budget includes significant cuts to critical local programs—including health care for immigrants, rental assistance, cash support for moms struggling to get a toehold in the labor market, and living wages for early educators. As a result, more DC residents will experience economic hardship, homelessness, and deep poverty, and the lasting harm will disproportionately fall on Black and brown people because of systemic racism.

Implementation Will Have a Major Effect on District Residents’ Poverty and Economic Success

The Council and DHS should set a goal that no family or individual will lose access to SNAP and fall deeper into poverty due to flawed implementation, which the experience of other states suggests is a major reason for benefit loss in addition to actual work requirements.^[10]

OBBBA changes create burdensome paperwork that can be confusing for residents in need of SNAP. People who face challenges navigating the red tape of the reporting and exemption systems will be at risk of losing the food assistance they need to buy groceries, even if they are eligible. For example, people who reported having a disability—who likely should have been exempt from the three-month time limit—lost SNAP at the same rate as people without a disability, one study found.^[11] This may happen when state eligibility workers without medical training may lack the tools to sufficiently screen participants for exemptions or because people are challenged by the paperwork required to adequately document their health conditions. It is critical for DHS to take every possible step to avoid these implementation pitfalls and help residents retain access to benefits.

DHS’s responses to performance oversight questions indicate that the agency is working vigorously to achieve this outcome and to avoid bureaucratic bottlenecks. For example, DHS is leveraging existing agency IT systems to pull information about SNAP participants to ease the paperwork burden as much as possible, making it easier to report exemptions and work hours by incorporating related forms into District Direct (DC’s public assistance portal), and expanding SNAP work programs and permissible volunteer opportunities to help adults report work activities and avoid the three-month benefit time limit. While DHS is working on a communications plan to ensure that SNAP households are informed of the OBBBA changes, it will be important to ensure that the notices that DHS sends to residents are easy to understand and provide information specific to their case. It is our understanding that DHS’s initial notice on the time limit in January left some SNAP participants confused (including some not even subject to the time limit), according to other public benefit advocates.

The federal cuts to SNAP will also affect the District’s budget. DC lawmakers must prepare for how OBBBA increases the state share of administrative costs to 75 percent from 50 percent in FY 2027, which could cost DC nearly $19 million.^[12] OBBBA also imposes state-level costs for benefits for the first time but allows states with high SNAP error rates like DC to postpone cost sharing until FY 2030. States will be required to pay 5, 10, or 15 percent of food benefits if their error rate exceeds certain thresholds—for DC, that could cost up to $48 million per year.^[13] The tiered cost-shift penalty structure creates a high level of unpredictability of how much DC may be required to pay year to year, given a small increase in the error rate could require the District to pay tens or even hundreds of millions of dollars more than in the prior year.

It is commendable that one of DHS’s stated primary goals is to improve its SNAP error rate to 6 percent from 19.8 percent by FY 2027 through various strategies that a “SNAP Payment Accuracy Core Team” will advance, according to their oversight response.^[14] The Committee should ask DHS whether they need additional staff to achieve this goal, as the administrative savings related to a lower error rate would far exceed the cost of additional positions.

Transparency and Clarity Are Crucial to Success

DCFPI acknowledges the difficult challenge of implementing the SNAP changes, particularly given that the federal government ended DC’s waiver for work requirements an entire year early, leaving less time to plan. DCFPI also appreciates the detail in the oversight responses and the collaboration we’ve had with Chairman Frumin’s office on DHS’s progress on implementation. Transparency and clarity will be important to success and limiting harm. When the Council and the public have clear information about the changes DHS seeks to implement, the number of people affected, and the challenges the Department encounters, we can work together to track the impact, reduce confusion among those potentially affected, and support the Department in overcoming the challenges.

Some implementation steps remain unclear, such as when the clock on countable months will officially begin for adults subject to the time limit and how DHS will screen for immigration status changes. DHS stated that “immigration status…changes do not require additional data to implement” in its performance oversight responses, leaving it unclear how they plan to screen immigrants who transition from an ineligible category like refugee to lawful permanent resident, particularly before their recertification.^[15] DCFPI encourages DHS and the Committee to ensure transparency as implementation continues, identify a system to track and publish monthly or quarterly data reports on initial effects of OBBBA implementation once residents begin to lose benefits, and consider hosting a roundtable to continue to sort through implementation challenges if they arise.

Thank you for the opportunity to testify.