Key Takeaways
Under the One Big Beautiful Bill Act, an estimated 286,000 stateside Puerto Rican able-bodied adults, aged 18 to 64 years, without dependents younger than 14 years old, would be required to fulfill a 20 hour-per-week work requirement to access food assistance via the Supplemental Nutritional Assistance Program (SNAP) or be subject to a three-month time limit over 3 years on SNAP benefits, based on estimates derived from the 2023 American Community Survey 1-year Public Use Microdata Sample (PUMS).
Puerto Rican adults aged 18 to 64 years, “able-bodied”, and without dependents younger than 14 years were twice as likely as non-Puerto Rican adults in the same group to live in households receiving SNAP in 2023 (15.4% vs. 7.6%, respectively), meaning the ABAWD changes fall on a population with notably higher baseline SNAP participation.
The state-level distribution of Puerto Rican ABAWDs is shaped by both count and rate: New York, Florida, and New Jersey account for the largest absolute numbers of exposed Puerto Rican adults, but Massachusetts and Connecticut stand out by rate. Nearly 40% of SNAP-enrolled ABAWDs in Massachusetts are Puerto Rican.
States face compounding fiscal pressure from the law’s shift of the majority of SNAP administrative costs to states and the law’s new payment error rate penalties, provisions that could impact all SNAP participants in those states, not just able-bodied adults without dependents.
In 2023, approximately 47.7 million people, or 14.6% of the total population living in households, lived in households receiving SNAP over the last 12 month period. Puerto Ricans were twice as likely to live in households receiving SNAP over the same time period: an estimated 1.7 million Puerto Ricans lived in households receiving SNAP, representing 29.1% of all Puerto Ricans living in households.
Across the 15 states with the largest Puerto Rican populations in 2023, Puerto Ricans were consistently more likely than the overall state population to be part of SNAP-receiving households and to live in poverty. This overrepresentation implies that strains to state-provided food benefit assistance programs will fall more heavily on Puerto Ricans relative to all SNAP recipients in those states.
SNAP and the Stateside Puerto Rican Population
This is the second post in a series examining how Public Law 119-21, the “One Big Beautiful Bill,” enacted on July 4, 2025, may affect Puerto Ricans living in the United States. The first post analyzed projected impacts on health coverage. Here, we analyze potential impacts to the Puerto Rican population that relies on the Supplemental Nutrition Assistance Program (SNAP), the largest federal nutrition assistance program.
In 2023, 19.6% of Puerto Ricans living in the United States lived below the federal poverty line, compared to 12.4% of the overall U.S. population, according to estimates from the 2023 ACS 1-year PUMS. As documented in the first post in this series, Puerto Ricans’ elevated poverty rates are not new: between 2005 and 2023, the poverty rate among stateside Puerto Ricans declined from 25.8% to 19.6%, a meaningful improvement, but one that still left the community at substantially greater risk of economic hardship than the general population.
The Supplemental Nutritional Assistance Program (SNAP) is the largest federal nutritional assistance program. In fiscal year 2023, over 42 million people received SNAP every month. Children accounted for nearly 40% of all participants, as well as adults 18 to 59 years old. The remaining 20% of participants were 60 years of age and older. SNAP is designed as food security and income support for low-income households, and the elevated poverty rates in the Puerto Rican population described above translate directly into higher rates of SNAP participation among Puerto Ricans living in the United States. According to 2023 ACS 1-year PUMS estimates, an estimated 29.1% of the Puerto Rican population living in households received SNAP in the last 12 months, approximately 1.7 million Puerto Ricans, compared to 14.6% of the total population living in households, or about 47.7 million people total (see Figure 1). Whereas 11.8% of all households in the U.S. received SNAP, Puerto Rican households were disproportionately overrepresented, with an estimated 21.5% of Puerto Rican households in the U.S. receiving SNAP in 2023.
Puerto Rican households receiving SNAP benefits and the Puerto Ricans who live in these households are not a marginal share of the community: they represent hundreds of thousands of families and individuals whose food budgets are at least partially supported by federal nutrition assistance. In terms of the population living in these households, over a third (36.9%) of all Puerto Rican children living in households in the United States in 2023 lived in households receiving SNAP, contrasted to 22.1% of all children living in households. Close to a third (30.3%) of Puerto Rican adults aged 65 years and above lived in households receiving food stamps, compared to 10.1% of all adults aged 65 years and above. Whereas 28.7% of all disabled non-elderly adults living in households lived in households receiving SNAP, nearly 45% of all Puerto Rican disabled non-elderly adults living in households lived in households receiving SNAP in the last 12 months in 2023 (see Figures 1 and 2).
Understanding how PL 119-21 may affect the populations that benefit from SNAP requires understanding what the law changes about SNAP, and why those changes affect Puerto Rican households more than the general population. The One Big Beautiful Bill Act (OBBBA) modifies SNAP through two main mechanisms: (1) the population subject to time limits is expanded, as work requirements are imposed on a broader age range of able-bodied adults without dependents (the dependent-child exemption is narrowed to those who have children under 14 years old, and the age limit for the population subject to time limits is increased from 54 to 64 years), and (2) it shifts a greater share of SNAP administrative costs to states while strengthening payment error rate penalties.
Before we address the two main mechanisms outlined above and how they impact Puerto Ricans in the United States, we provide a brief history of Able-Bodied Adults Without Dependents (ABAWDs) policy, a short explanation of payment error rates, and situate H.R. 1’s changes in the context of the COVID-19 pandemic and federal fiscal spending.
A Brief History of SNAP ABAWD Work Requirements
Work requirements for ABAWDs were not part of federal food assistance until the Personal Responsibility and Work Opportunity Reconciliation Act of 1996 (PRWORA), enacted under President Bill Clinton’s administration. Under PRWORA’s original SNAP framework, able-bodied adults aged 18 to 49 years without dependents were limited to three months of SNAP benefits within three years unless they were working or participating in a qualifying work or training program for at least 20 hours per week. States could request waivers of these time limits for their ABAWD population living in geographic areas with unemployment rates above 10% or that otherwise qualified as areas of insufficient jobs.
The waivers became widely used during economic downturns, effectively suspending time limits for millions of individuals who would have otherwise lost access to SNAP benefits during periods of high unemployment. The American Recovery and Reinvestment Act of 2009 suspended ABAWD time limits nationally during the Great Recession. During the COVID-19 pandemic, the Families First Coronavirus Response Act again suspended ABAWD time limits nationally. Moreover, because of the nature of the public health emergency, during the critical years of the COVID-19 pandemic, SNAP beneficiaries received the maximum SNAP benefit amount allowed for their household size, which lasted until early 2023.
The One Big Beautiful Bill Act (OBBBA) made three significant changes to the pre-existing ABAWD framework. First, it raised the ABAWD age ceiling from 54 to 64 years, bringing adults ages 55 to 64 under the time-limit and work-requirement structure for the first time. The Fiscal Responsibility Act of 2023 had already raised the ceiling incrementally over a period of 16 months from the original 49 years to 54 years. Second, OBBBA changed the caregiver exemption. Previously, any adult caring for a dependent child under 18 was exempt from ABAWD rules. PL 119-21 limited this exemption to adults caring for a child under age 14 years in the household. Finally, the law eliminated the criteria for “insufficient jobs” time limit waivers. Before PL 119-21, states could obtain waivers for areas that met either the over 10% unemployment standard or the “insufficient jobs” criterion. PL 119-21 leaves only the over 10% unemployment threshold as grounds for a waiver. The combined effect of these changes is to expand the population subject to time limits and to reduce the flexibility states have to protect their population during economic downturns, impacting SNAP’s ability to buffer recessions. Critics have noted that SNAP’s tendency to expand during recessions and contract during recoveries is an intentional design feature, and that OBBBA’s restrictions on waivers could limit the program’s ability to respond to future economic downturns.
SNAP Payment Error Rates
SNAP payment error rates measure the accuracy of a state’s SNAP benefit determinations. The payment error rate for a state combines overpayments, where a household receives more than it is entitled to, and underpayments, where a household receives less than that it is entitled to. Both count as errors under the quality control process the USDA Food and Nutrition Service (FNS) uses to compute a national payment error rate (NPER) every year. Most payment errors arise from not fully verifying the eligibility and income information households report at certification or recertification of SNAP benefits. This is exacerbated by the difficulty of accurately capturing income information for households with volatile earnings or fluctuating work hours. Data for one month can misrepresent a household’s actual circumstances, which is important to keep in mind for low-income earners who seek SNAP as income support for food security in the first place.
During the first two fiscal years of the COVID-19 public health emergency, fiscal years 2020 and 2021, Congress suspended quality control reporting requirements for states. When reporting resumed, payment error rates had risen well above pre-pandemic levels. When pandemic-era flexibilities wound down, many states returned to standard eligibility verification procedures without rebuilding full staffing capacity. Additionally, changes in the methodology used by the FNS to count overpayments contributed to higher error rates in 2022 and 2023. Whereas the NPER had been 7.4% in fiscal year 2019, it reached 11.5% in fiscal year 2022 and 11.7% in fiscal year 2023.
Public Law 119-21 attaches state fiscal consequences to elevated payment error rates. Before the enactment of the law, the federal government shouldered 100% of the cost of providing SNAP benefits to those deemed eligible. Starting in fiscal year (FY) 2028, states with payment error rates equal to or greater than 6% will have to pay a share of SNAP benefit costs (see Figure 3), placing unprecedented pressure on state budgets that are also impacted by the mandated increase in SNAP administrative costs, from 50% to 75%, effective October 2026, that their budgets must now cover. An additional fiscal year grace period has been given to states whose payment error rates exceed 13.33% in FY2025 or FY2026. This increase in administrative cost burden borne by states is also part of what was enacted by PL 119-21. Alongside payment error rate benefit cost-sharing penalties, this could impact state fiscal decisions and budgets to come, potentially forcing cuts to programs beyond those that ensure food security, since states must maintain balanced budgets.
Pandemic-Era Benefit Expansions, the Thrifty Food Plan, and Federal Fiscal Context
During the COVID-19 pandemic, two overlapping policy changes drove federal SNAP costs to historic highs between 2020 and 2023: the issuing of emergency allotments during the public health emergency, and the 2021 reevaluation of the Thrifty Food Plan. The Thrifty Food Plan (TFP) is a guide developed by the U.S. Department of Agriculture detailing the basket of foods needed to prepare cost-effective and nutritional meals at home.
The Families First Coronavirus Response Act, enacted in March 2020, authorized the USDA to issue emergency allotments to SNAP households. Emergency allotments supplemented regular monthly benefits by raising each participating household’s benefit to the maximum allowed for its household size, regardless of income. Households already receiving maximum benefits received no additional amount, and households receiving partial benefits due to income received the difference between their regular benefit and the maximum. According to 2024 data from the USDA Economic Research Service, national SNAP enrollment was approximately 42 million average monthly participants in fiscal years 2022 and 2023. The Consolidated Appropriations Act of 2023 ended emergency allotments as of February 2023. As a result, inflation-adjusted federal spending on SNAP fell more from fiscal year 2023 to fiscal year 2024 than for any other year on record.
In addition to the emergency increase in allotments, the U.S. Department of Agriculture completed a reevaluation and update of the Thrifty Food Plan in 2021, which raised the maximum SNAP monthly benefits by 21%. Public Law 119-21, as currently enacted, prohibits the U.S. Department of Agriculture from conducting any future reevaluation of the TFP’s food basket, regardless of future food price inflation or the impacts these policies have on food insecurity in the United States. The update to the TFP in 2021 was the first in SNAP’s history that led to an increase in the average daily SNAP benefit amount, which averaged to $1.19 per person per day.
Proponents of the SNAP provisions that made it into PL 119-21 argued that SNAP’s rapid growth during the pandemic and the 2021 Thrifty Food Plan expansion represented spending increases difficult to unwind without legislative action. SNAP has been one of the federal government’s largest means-tested expenditure programs, yet its scale relative to the broader budget is frequently overstated in public debate. In fiscal year 2023, federal SNAP spending totaled approximately $113 billion, representing roughly 1.8% of total federal spending ($6.1 trillion) and about 0.4% of GDP. For comparison, federal spending on Medicare in the same year was approximately $850 billion, payments on interest on the federal debt were $875.5 billion, and spending on defense, including discretionary spending and veteran support, was approximately $1.1 trillion. The Congressional Budget Office (CBO) projected that the Nutrition subtitle in PL 119-21 would reduce federal spending by almost $190 billion over ten years, making it among the largest spending reductions in the law. Note that PL 119-21 made the tax cuts in 2017’s Tax Cuts and Jobs Act permanent, leading to a net revenue loss of $4.5 trillion over fiscal years 2025 to 2034. Critics characterize the changes enthroned in the One Big Beautiful Bill Act as a massive transfer of wealth from the bottom income earners to the top income earners in the United States, as evidenced by a CBO analysis of the distributional effects of the law.
Two Mechanisms of Impact on Stateside Puerto Ricans
As mentioned above, the OBBBA modifies SNAP through two main mechanisms: expanding the population subject to ABAWD time limits and work requirements, and shifting administrative costs to states while penalizing them with benefit-cost sharing for maintaining large SNAP benefit payment error rates. These modifications to SNAP will affect Puerto Rican SNAP households through two distinct channels. The first is direct: the ABAWD age expansion and tighter work requirements apply individually to Puerto Rican adults who fall into the newly covered age range, have dependents over 13 years old, and are currently receiving SNAP. The second is indirect: the administrative cost shift and payment error rate penalties will affect every SNAP participant in all states, including those where Puerto Ricans are concentrated, through the administrative and fiscal pressure those provisions place on state agencies and budgets.
We analyze each channel utilizing estimates from the 2023 ACS 1-year PUMS. To maintain consistency with the first post in this series, which analyzed health coverage impacts using 2023 ACS data, this analysis uses 2023 ACS 1-year estimates and PUMS throughout. The 2024 1-year ACS estimates were available at the time of data analysis and writing, but were not used to preserve comparability across the blog series. The 2023 ACS PUMS data predate PL 119-21’s enactment and do not capture any behavioral or administrative responses to the law. SNAP participation as measured in the ACS is self-reported, does not indicate the time internal over 12 months that respondents had access to benefits, and likely differs from actual participation relative to administrative records. The exposure estimates we present here reflect population risk, not predicted outcomes. The effects of the law will depend on how states implement the new changes, as well as economic conditions at the time of implementation.
Direct Exposure: Puerto Ricans subject to SNAP ABAWD time limits
Our ABAWD exposure analysis focuses on adults who meet the following four criteria: (1) non-disabled, (2) ages 18 to 64 years, (3) without dependents younger than 14 years living in their households, and (4) who lived in households that reported receiving SNAP in the last 12 months, based on the 2023 ACS 1-year PUMS. Before PL 119-21, the ABAWD age ceiling was 54 years. PL 119-21 raised it to 64 years. This means that adults ages 55 to 64 years who were previously exempt from ABAWD time limits are now subject to them, alongside the narrowed dependent-child exemption described above. Our analysis captures the updated age range (18 to 64 years) and the new dependent-child age threshold to reflect the Puerto Rican population exposed under PL 119-21’s expanded definition.
Among SNAP-enrolled adults in the population subject to time limits per PL 119-21, average household income as a percentage of the federal poverty level (FPL) was estimated at approximately 222% FPL, and among Puerto Ricans in the exposed population, 214% FPL, based on 2023 PUMS data. This indicates that these are households with limited financial cushion who need SNAP benefits to supplement their income to maintain food security. In addition, low-income working age adults have limited access to a supportive safety net. Many experience income and work volatility, which limits their ability to care for themselves and their households. As mentioned above, data for one month can misrepresent a household’s actual circumstances, and deem a household ineligible for food assistance. Research on prior ABAWD expansions found that enforcement of work requirements produces significant procedural denials, particularly among low-income adults navigating competing demands on their time. Procedural denials lead to loss of benefits due to paperwork and administrative barriers rather than an actual failure to meet work requirements.
According to estimates extracted from the 2023 1-year ACS PUMS, there were approximately 1.9 million non-disabled Puerto Rican adults ages 18 to 64 years living without dependents younger than 14 years in the United States. Of those, roughly 286,000 lived in households that received SNAP in the last 12 months in 2023, or about 15.4% of that population, compared to approximately 7.6% of non-Puerto Rican adults in the same population group (see Figure 4). This 2-to-1 disparity reflects the combination of higher poverty rates and higher SNAP participation rates among the Puerto Rican population compared to the total population mentioned above.
The Puerto Rican ABAWD population subject to time limits and work requirements isn’t equally distributed among all states. New York and Florida have the largest counts of directly exposed Puerto Rican adults, reflecting the size of the Puerto Rican communities there (see Figure 5). However, in Connecticut and Massachusetts, Puerto Ricans represent a substantially higher share of the overall ABAWD-exposed SNAP population (Figure 6), meaning that enforcement of the new time limits will fall more heavily on Puerto Rican households relative to all SNAP households in those states. Massachusetts and Connecticut are also two states where Puerto Ricans have very high poverty rates relative to the overall population (Figure 7).
Not all of the 286,000 estimated Puerto Ricans will necessarily lose benefits. Some will satisfy the new work requirements; others may qualify for exemptions (for disability, caretaking responsibilities, or enrollment in qualifying education or training). However, research on prior ABAWD implementations suggests that administrative burden and procedural complexity generate losses beyond what the weekly work hours requirement alone would predict. The scale of the exposed population and its concentration in a small number of states make this a meaningful risk. Research has also documented that administrative complexity in SNAP enrollment and recertification disproportionately affects participation among communities with lower English proficiency, higher housing instability, and less access to technology. These characteristics are more prevalent among Puerto Rican SNAP households than among SNAP households overall.
State-System Exposure: Administrative and benefit payment cost burden
The direct ABAWD exposure documented above affects a specific demographic subset of working-age “able-bodied” adults without dependents younger than 14 years. The state-system channel is potentially broader in impact because it touches every SNAP household through the fiscal and administrative changes that PL 119-21 imposes on state SNAP agencies. The two channels are connected: more people subject to ABAWD work requirements to avoid benefit time limits lead to more people that need to document their work and present it to the state for SNAP eligibility and benefit determination. In return, additional complex caseloads for state agencies to manage lead to greater administrative burden and increased room for payment error.
Before PL 119-21, the federal government covered 50% of SNAP administrative costs, with states covering the remaining 50%. PL 119-21 shifts this to a 25%-to-75% federal-to-state split, increasing states’ administrative cost burden by 50% relative to prior law. For large states with big SNAP caseloads, New York, Massachusetts, Pennsylvania, and Illinois among them, this represents a large new fiscal obligation. States facing budget pressure in response to these costs may reduce administrative capacity, slow processing times, or curtail outreach and enrollment assistance, all of which could affect participation rates across the full SNAP caseload.
To compound the increase in SNAP administrative costs to states, PL 119-21 adds benefit cost-sharing penalties to states with high SNAP benefit payment error rates. SNAP’s payment error rate (PER) measures the share of benefits issued to ineligible households or in incorrect amounts, including overpayments and underpayments of benefit amounts. PL 119-21 penalizes states with payment error rates greater than or equal to 6% by making them responsible for covering up to 15% of SNAP benefit costs (recall Figure 3). This is unprecedented in SNAP’s history and will strain state budgets: before these provisions in the One Big Beautiful Bill, the federal government paid 100% of SNAP benefits to households. As of fiscal year 2025, states with substantial Puerto Rican communities had the following PERs: New York, 13.2%; Florida, 13.0%; Massachusetts, 12.5%; Connecticut, 9.1%. These are states with a sizable number of Puerto Ricans living in households receiving SNAP or where Puerto Ricans represent a large share of the total state population that received SNAP benefits in 2023 (see Figure 8). Over 35% of Puerto Ricans residing in Massachusetts, Pennsylvania, New York, and Connecticut receive SNAP (see Figure 9).
The state-system exposure channel is less visible than the direct ABAWD mechanism but is broader in reach. Although a household with children younger than 14 years, elderly adults, or disabled members is categorically exempt from ABAWD time limits to receive SNAP benefits, that same household could live in a state that may face increased administrative pressure, slower processing, and payment error rate penalties. The administrative strain introduced by PL 119-21’s cost and PER penalty provisions does not distinguish between household types when it affects a state agency’s capacity.
According to 2023 PUMS data, the population of Puerto Ricans living in households receiving SNAP in New York, Florida, Pennsylvania, Massachusetts, New Jersey, and Connecticut exceeded over 100 thousand each (see Figure 8). New York had the highest number of Puerto Ricans receiving SNAP in the last 12 months in 2023, with over 350 thousand Puerto Rican SNAP recipients (Figure 8). Massachusetts was the state where Puerto Ricans had the highest SNAP recipiency rate in 2023 (see Figure 9), with over half of the population, or 55.8%, living in households receiving SNAP in the past 12 months, followed by Pennsylvania (44.8%), New York (37.9%), Connecticut (35.8%) and Wisconsin (33.6%). These are also states with a high poverty rate among their Puerto Rican population (see Figure 7).
Across the 15 states with the largest Puerto Rican populations in 2023, Puerto Ricans were consistently more likely than the overall state population to be part of SNAP-receiving households and to live in poverty (See Figure 10), although the size of those gaps varied widely by state (Figure 11). Connecticut and Massachusetts show the widest disparities: Puerto Ricans in Connecticut are nearly 2.5 times as likely to live in poverty as the state’s general population, and nearly 2.7 times as likely to live in a household receiving SNAP. In Massachusetts, those ratios rise to roughly 3 and 3.3, respectively. By contrast, in states like California, Texas, Georgia, and Virginia, Puerto Ricans’ poverty and SNAP participation rates roughly track with the state rates for the total population, with little disparity in either direction. The gap in SNAP participation tends to run wider than the gap in poverty rates alone, most visibly in Wisconsin, where a modest poverty disparity corresponds to a much larger SNAP disparity, suggesting factors beyond poverty status, such as eligibility thresholds above the federal poverty line or differences in program take-up, are also at play.
When considering states’ FY2025 SNAP payment error rates, the fiscal year with the latest published payment error rate data, a few states stand out for different reasons: Connecticut and Massachusetts, which show the greatest Puerto Rican overrepresentation relative to their population share, sit at moderate SNAP payment error rate levels. New York and Florida, meanwhile, are home to the largest number of Puerto Ricans in SNAP households in absolute terms, and both carry FY2025 payment error rates above 10%, placing them on track, under the cost-sharing provisions in H.R. 1, to pay 15% of SNAP benefit costs starting in FY2028, unless their FY2026 error rates come in low enough to shift them into a lower cost-share tier.
The fiscal pressure that states will feel from having to partially cover the cost of SNAP benefits could have consequences that are not to be taken lightly. The need for states to reduce their payment error rates to avoid covering a portion of SNAP benefit costs, combined with growing caseloads due to an expansion in the population subject to time limits and a reduction in administrative funding for states to run SNAP is likely to have a negative impact on both SNAP beneficiaries and other state-provided services, since most states (all but Vermont) have to keep balanced budgets.
Discussion and Conclusion
The analysis above documents two distinct mechanisms through which PL 119-21 may affect SNAP participation among Puerto Ricans living in the United States, based on 2023 ACS 1-year PUMS estimates and federal administrative data.
The direct ABAWD exposure channel identifies approximately 286,000 Puerto Rican adults in the target age range who are currently in SNAP households and would be subject to the new time limits. The disproportionately high SNAP participation rate among Puerto Rican adults in this demographic (15.4% vs. 7.6% for non-Puerto Rican adults) reflects the elevated poverty rates of the Puerto Rican population relative to the overall population in the United States. At state level, the administrative and fiscal pressure that PL 119-21 will place on state agencies and state budgets starting this fiscal year impacts the broader SNAP caseload, including the majority of Puerto Rican SNAP households whose members are exempt from ABAWD time limits.
The data clearly establish that Puerto Ricans in the United States are disproportionately represented in the SNAP caseload relative to their population share, that they are concentrated in states that face significant administrative and fiscal pressure under PL 119-21, and that the population subgroups most exposed to the new ABAWD rules are precisely those with the least financial margin to absorb a benefit disruption.
Tracking ACS PUMS data in subsequent years, alongside state-level SNAP administrative data on participation, error rates, and benefit issuance, will be essential to assess how these structural changes translate into actual outcomes for Puerto Rican communities across the states.