A government shutdown is exactly the kind of emergency the contingency fund can be used for; it has been listed as a means to fund SNAP during a shutdown going back to at least 2018.
Lapse of Funding Plan September 30, 2025
Supplemental Nutrition Assistance Program (SNAP): OMB’s General Counsel provided a letter to USDA on May 23, 2025 stating that there is a bona fide need to obligate benefits for October – the first month of the fiscal year – during or prior to the month of September, thereby guaranteeing that benefit funds are available for program operations even in the event of a government shutdown at the beginning of a fiscal year. In addition,
Congressional intent is evident that SNAP’s operations should continue since the program has been provided with multi-year contingency funds that can be used for State Administrative Expenses to ensure that the State can also continue operations during a Federal Government shutdown. These multi-year contingency funds are also available to fund participant benefits in the event that a lapse occurs in the middle of the fiscal year.
Preparations for Shutdown as a Result of a Lapse in Appropriations 2024
Core programs of the nutrition safety net, including the Supplemental Nutrition Assistance Program (SNAP), the Child Nutrition (CN) programs and the Special Supplemental Nutrition Program for Women, Infants and Children (WIC) will continue operations during a lapse in appropriations, subject to the availability of funding. Multi-year carry over funds and
contingency reserves would be apportioned by OMB to support program operations during the period of the lapse to the extent such funding exists; funding from continuing resolutions, including the special mandatory payments provision generally included in continuing resolutions, would also be available to support program operations in a lapse the follows the expiration of a continuing resolution
Preparations for Shutdown as a Result of a Lapse in Appropriations 2021
FNS CONTINGENCY PLAN:
For Shutdown Due to a Lapse in Appropriations 2018