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All County Letter No. 25-92 Page Two

Supplemental Nutrition Assistance Program (SNAP), known as CalFresh in California, as a result of House of Representatives 1, An Act to Provide Reconciliation Pursuant to Title II of H. Con. Res. 14 (H.R. 1) (Public Law (P.L.) 119-21). For additional information regarding H.R. 1 and its impact to CalFresh, reference ACL 25-50 and ACL 25-50E, issued July 14, 2025, and August 26, 2025, respectively.

Due to the complexity of the recent changes in federal law and policy, and delays resulting from the Food and Nutrition Service (FNS) only recently issuing complete guidance (described further below), the guidance set forth in this ACL is effective April 1, 2026. This date reflects the time required to train county staff and to design and implement the necessary automation changes within the California Automated Welfare System (CalSAWS) to ensure consistent and accurate application of the guidance statewide. It also reflects the extended exclusionary period through April 9, 2026, that FNS is required to provide pursuant to the district court’s order in New York et al. v. Rollins et al., No. 6:25-cv-02186-MTK (D. Or.), which is described further below.

The guidance provided in this letter supersedes any previous guidance on issues addressed within this ACL regarding noncitizen eligibility. This letter does not supersede or alter guidance on issues not specifically addressed herein.

BACKGROUND

On July 4, 2025, President Trump signed H.R. 1 into law, thereby limiting CalFresh eligibility to citizens and a narrower group of noncitizens compared to those previously eligible. On October 31, 2025, the U.S. Department of Agriculture, FNS issued guidance on this change via a memorandum titled Supplemental Nutrition Assistance Program (SNAP) Implementation of the Big Beautiful Bill Act of 2025 – Alien SNAP Eligibility, which is attached for reference. The October 31, 2025, guidance is the subject of litigation New York et al. v. Rollins et al., No. 6:25-cv-02186-MTK (D. Or.) (Filed Nov. 26, 2025) because of inconsistencies, omissions, and related concerns. On December 9, 2025, FNS issued guidance in the form of a question-and-answer document that conflicts with FNS’ October 31 guidance. On December 10, 2025, FNS issued a revised version of the question-and-answer document, which is attached for reference. The revised question-and-answer document conflicts with the October 31st guidance but does not purport to revoke or supersede it. However, on December 15, 2025, the district court issued a preliminary injunction extending the Quality Control (QC) exclusionary period through April 9, 2026.

Consequently, this letter provides direction based on the California Department of Social Services’ (CDSS) best understanding of the federal requirements despite the inconsistencies and errors in the guidance documents issued by FNS since October 31, 2025. If FNS provides additional clarification that changes any part of the guidance provided via this letter or if there are impacts from the ongoing litigation, CDSS will issue updated guidance.