Trump Action Archive

Supporting reports

• USDA removes contingency funding plan from website and denies legal authority to use emergency reserves for SNAP — The USDA removed its late-September contingency funding plan from its website while simultaneously issuing a memo claiming emergency reserve funds are "not legally available" to cover SNAP benefits during the shutdown. The removed plan had previously stated Congress's "evident" intent was for SNAP operations to continue during closures and identified "multi-year contingency funds" available for that purpose. The agency's current position contradicts its own earlier legal analysis and denies access to approximately $6 billion in reserves despite having authority to use them.
• USDA removes guidance authorizing contingency funds for SNAP benefits — The USDA issued guidance on September 30, 2025, explicitly stating that multi-year contingency funds could be used to fund SNAP participant benefits during a lapse in appropriations. The guidance cited Congressional intent and the plain language of appropriations bills (2024 and 2025) reserving funds "to carry out program operations." The Trump administration has since removed this guidance from the USDA website, now asserting that the $6 billion contingency reserve "are not legally available to cover regular benefits" and can only be used for disaster response. The removal occurred after the administration determined that withholding funds was "politically advantageous."