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Page 3 of 11 Implementation Section 10108 of the OBBB was effective upon enactment, July 4, 2025. State agencies must immediately apply the new eligibility criteria to new applicants at initial certification. For households already receiving SNAP, State agencies must review household circumstances and apply these policies at recertification. If an alien does not fall into one of the groups listed in section 6(f) of the FNA, as amended by OBBB, the alien is no longer eligible for SNAP and must be removed from the household at that time.4 Changes During the Certification Period The Food and Nutrition Act of 2008 requires State agencies to use the Systematic Alien Verification for Entitlements (SAVE) program to verify the immigration status of all aliens participating in SNAP prior to certification. FNS strongly encourages States to check SAVE whenever required changes or recertifications actions are made. Through these updates, State agencies may obtain information during a household’s certification period that indicates an alien is no longer in a SNAP-eligible immigration status or designation. State agencies must review household circumstances to take appropriate action when this occurs and follow program rules for acting on changes and resolving unclear information at 7 CFR 273.12(c). Quality Control and Technical Assistance FNS will, as appropriate, hold States harmless for Quality Control (QC) purposes for 120 days from the required implementation date in accordance with 7 CFR 275.12(d)(2)(vii). The 120-day variance exclusion period will not apply if the State agency does not implement the new provision in accordance with 7 CFR 275.12(d)(2)(vii)(D). State agencies that implement a provision later than the required implementation date, but before the end date 4 Pursuant to USDA regulations at 7 CFR 273.12(a)(1), 7 CFR 273.12(d), and 7 CFR 273.18, households are not liable for a claim due to a change in circumstances the household is not required to report. Since households are not required to report a change in immigration status, aliens who lose SNAP eligibility at recertification due to the OBBB SNAP eligibility changes, are not subject to a claim for over issuance for the benefits received after the OBBB changes took effect. Guidance documents lack the force and effect of law, unless expressly authorized by statute or incorporated into a contract. USDA may not cite, use, or rely on any guidance that is not available through their guidance portal, except to establish historical facts.