Methodology: SNAP Coverage at Risk
How county-level SNAP exposure ranges are computed under P.L. 119-21
Exposure does not equal loss
This page identifies Michigan SNAP participants who fall into categories that CBO, MLPP, and CBPP project may be affected by provisions of P.L. 119-21. Being in an affected category is not the same as losing benefits. Individual outcomes depend on state implementation, work requirement compliance pathways, employment status, and administrative factors that vary by county and over time. The ranges on this page describe populations at elevated exposure — they do not predict who will or will not retain SNAP enrollment.
Sources
CBO: Estimated Budgetary Effects of P.L. 119-21 on SNAP Participation
Congressional Budget Office, August 2025. cbo.gov/system/files/2025-08/61367-SNAP.pdf — Provides the enacted-law national projection of 2.4 million/month average SNAP participation reduction over FY2025–2034. This is the primary numeric input to the state and county models. Accessed April 2026.
CBPP: SNAP Fact Sheet — Michigan
Center on Budget and Policy Priorities, 2025. cbpp.org/snap-state-factsheets — Michigan-specific SNAP participation context and analysis of P.L. 119-21 impact. Accessed April 2026.
MLPP: The Cost of the Federal Megabill — Food Assistance
Michigan League for Public Policy, November 2025. mlpp.org — Food Assistance analysis — Michigan-specific analysis citing 74,000 Michigan adults in affected categories, 123,000 total Michiganders in affected households, and an estimated $410M in new annual state costs. Sourced from CBO/CBPP/FNS. Accessed April 2026. Note: the 123,000 household figure and $410M state-cost figure are cited here for context and are not independently modeled by accessmi.org. Only the 74,000 adult figure is used as the state-level input to the county allocation model.
GAO-19-56: SNAP — Improved Monitoring of States' Use of Work-Related Exemptions and Reporting of Work Requirements
U.S. Government Accountability Office, 2019. gao.gov/products/gao-19-56 — Historical analysis of SNAP work requirement implementation across states, including actual vs. projected participation loss. Provides the basis for the ±40% uncertainty band used in county range estimates. Accessed April 2026.
USDA FNS: SNAP Employment and Training
U.S. Department of Agriculture Food and Nutrition Service. fns.usda.gov/snap-et — SNAP E&T program overview, including state plan requirements and participation data. Used to contextualize the gap between work requirement imposition and actual E&T slot availability. Accessed April 2026.
Perspectives supporting P.L. 119-21 work requirement provisions
We searched for analyses from organizations that support the P.L. 119-21 work requirement expansion, including Heritage Foundation, AEI, and CMS communications. As of April 2026, no published analyses were identified that provide Michigan-specific county-level projections comparable to the MLPP/CBPP figures used here. The CBO score (source 1 above) is the enacted-law authoritative figure and is used here as a neutral baseline, not as an advocacy estimate. If such analyses are published, this methodology will cite them.
Projection methodology
Plain language
We take CBO's national projection of 2.4 million monthly SNAP participant reductions under P.L. 119-21 and apply it proportionally to each Michigan county based on each county's share of the state's total SNAP enrollment (the most current available county-level data, USDA FNS FY2022). We then apply Michigan's share of the national projection using MLPP's Michigan-specific estimate of 74,000 adults in affected categories. We present the result as a range — never a point estimate — using an uncertainty band derived from GAO's historical study of work requirement implementation, which found actual participation losses ranging from approximately 60% to 140% of projected amounts.
Technical steps
- National CBO projection — P.L. 119-21 is projected to reduce SNAP participation by an average of 2.4 million persons/month over FY2025–2034, primarily through expansion of ABAWD (Able-Bodied Adults Without Dependents) work requirements to ages 55–64 and adults with children 14+, and through tightening of categorical eligibility. Source: CBO pub. 61367, August 2025.
- Michigan state estimate — MLPP derives a Michigan-specific estimate of 74,000 adults at risk (39,000 ages 55–64; 35,000 with children age 14+) in households totaling 123,000 people. This figure is sourced from CBO/CBPP/FNS. We use MLPP's 74,000 as the state-level input rather than applying Michigan's enrollment share to the national 2.4M directly, because MLPP has already accounted for Michigan's ABAWD-eligible population mix.
- County allocation — Each county's projected range midpoint is computed as:
county_enrollment / sum(all_county_enrollments) × 74,000. The enrollment figures are USDA FNS FY2022 county-level annual average monthly participants, sourced from USDA Food and Nutrition Service published county data tables (see Sources). These figures are surfaced on accessmi.org's Feature 1 dashboard at /data/snap-michigan. This uses straight enrollment share as a proxy for adult ABAWD share at the county level. The simplification is documented here: the FNS county-level data (FY2022) does not break enrollment down by ABAWD eligibility category. A more precise allocation would require county-level ACS PUMS microdata on SNAP participation by age, household type, and employment status. That data is not publicly available at county level in published tables. - Uncertainty band — GAO-19-56 examined historical SNAP work requirement implementations and found that actual participation losses ranged widely relative to projections. We apply a ±40% uncertainty band:
low = midpoint × 0.60,high = midpoint × 1.40. Both bounds are rounded to the nearest whole person. All results are displayed as ranges; the midpoint is never shown in isolation. - Display — Every county shows a low–high range. No point estimate is displayed. The "At-risk low" and "At-risk high" column headers each carry a "(modeled range — not a point estimate)" qualifier directly beneath the sort button. A section subtitle above the table repeats the qualifier. The page-level disclaimer repeats "Exposure does not equal loss" and links to this methodology page.
What this does not do
- Does not predict individual benefit outcomes
- Does not account for state-level implementation choices — for example, Michigan could expand E&T program capacity, negotiate waivers, or implement exemptions that reduce the affected population below the modeled range
- Does not model the separate participation loss from administrative burden increases (tightened redetermination frequency, eligibility verification costs) — CBO projects these cause additional losses beyond work requirement impact, but they are not modeled at county level from public data
- Does not substitute for MDHHS operational guidance or legal advice
- Does not include second-order effects on food insecurity rates, authorized retailer viability, or emergency food network load
- Does not model geographic variation in E&T program slot availability, rural transportation access, or employer density — all factors that affect compliance capacity
- Does not use county-level ABAWD eligibility data — such data is not publicly available from FNS at county level; straight enrollment share is used instead (documented above)
Why we publish this
No public source currently provides county-level estimates of P.L. 119-21's SNAP impact for Michigan. CBO publishes national figures. MLPP publishes a state total. Individual counties — which are responsible for implementing the law through local MDHHS offices, food banks, and E&T providers — have no public baseline for planning. accessmi.org publishes this model not as an advocacy document but as a planning input: a rough, sourced, uncertainty-bounded estimate that a county health department, food pantry network, or journalist can use to frame a question, not answer it. The methodology is public, the uncertainty is explicit, and the model will be updated when better data becomes available. Making the uncertainty visible is more useful than leaving this question unanswered in public planning records.
Change log
Every change to this methodology is recorded here with date and reason.