DECEMBER 2018

Note: Unless otherwise indicated, all years referred to are federal fiscal years, which run from October 1 to September 30 and are 

designated by the calendar year in which they end. Numbers may not sum to totals because of rounding. The vertical bars in the 

figures indicate the duration of recessions, which extend from the peak of a business cycle to its trough.

A Review of CBO’s Estimate of the 

Effects of the Recovery Act on SNAP

In February 2009, in response to significant weakness in 

the economy, lawmakers enacted the American Recovery 

and Reinvestment Act of 2009. That legislation funded 

a broad range of new and existing federal programs and 

reduced revenues through changes in federal tax law. The 

Congressional Budget Office monitored actual spending 

under the Recovery Act (or ARRA) for several years after 

that enactment to assess the accuracy of its estimates of 

outlays for the legislation—both in total and for individual years and programs. 

For the 2009–2013 period, outlays resulting from ARRA 

totaled $596 billion, about $54 billion (or 10 percent) 

above CBO’s original estimate of $542 billion for that 

period.1 Provisions related to unemployment insurance, 

nutrition assistance, and refundable tax credits together 

account for the underestimate.2 In particular, CBO’s 

estimate of spending for the Supplemental Nutrition 

1. See Congressional Budget Office, cost estimate for the 

conference agreement for H.R. 1, the American Recovery and 

Reinvestment Act of 2009 (February 13, 2009), www.cbo.gov/

publication/41762.

2. Congressional Budget Office, “The Accuracy of CBO’s Budget 

Projections,” CBO Blog (March 25, 2013), www.cbo.gov/

publication/44017. For additional discussion, see Congressional 

Budget Office, Estimated Impact of the American Recovery and 

Reinvestment Act on Employment and Economic Output in 2014 

(February 2015), www.cbo.gov/publication/49958.

Assistance Program (SNAP, which helps people in 

low-income households to purchase food) accounted for 

a substantial share of that underestimate. For all other 

programs, taken together, CBO’s estimates of outlays 

from ARRA over the 2009–2013 period were within 

6 percent of the actual total. This report focuses on the 

underestimate for SNAP and the reasons for it.3

Among its many other provisions, ARRA increased 

monthly benefits for SNAP participants. When the 

law took effect, the maximum monthly benefit for a 

household of four was raised by 13.6 percent, from $588 

to $668. Benefits for households of other sizes increased 

similarly, and the law specified that the maximum 

benefits would remain at those amounts until the routine 

inflation adjustment that otherwise would have been 

applied to the benefit amount exceeded the increase 

provided under ARRA. 

At the time of the law’s enactment, CBO estimated 

that ARRA would increase spending on SNAP, relative 

to CBO’s baseline, by $20 billion—or by 3 percent of 

total projected SNAP spending—over the 2009–2019 

period, with nearly all of that spending occurring in the 

3. On December 11, 2018, CBO issued a cost estimate for H.R. 2, 

the Agriculture Improvement Act of 2018 (the farm bill), which 

reauthorized SNAP (www.cbo.gov/publication/54880). This 

analysis is not related to that estimate or to the legislation.
2 A Review of CBO’s Estimate of the Effects of the Recovery Act on SNAP DECEMBER 2018

first five years. CBO now estimates that ARRA increased 

total spending on SNAP by $43 billion over the 10-year 

projection period.4 That is, the ARRA-related increase in 

spending on SNAP was more than double the amount 

CBO estimated in 2009.

About $19 billion of the estimated $20 billion increase 

in SNAP spending was for benefit payments. The rest 

encompassed outlays for changes to administrative 

funding, the Food Distribution Program on Indian 

Reservations, block grants for Puerto Rico and American 

Samoa, and time limits for able-bodied adults without 

dependents. CBO underestimated ARRA-related outlays 

on SNAP benefits by $22 billion over the 2009–2013 

period (see Table 1).

This report explains the methods that CBO used in 

February 2009 to estimate additional federal spending as 

a result of the provision in ARRA that raised the maximum SNAP benefit. It also provides details about the 

4. That number excludes $5.2 billion in spending made under 

ARRA’s authority in October 2013 for routine SNAP benefit 

payments during a three-week lapse in appropriations for the 

program.

factors that contributed to CBO’s underestimate of that 

spending. In particular, CBO’s estimate of ARRA-related 

spending on SNAP benefits in February 2009 was substantially below the actual amount over the 2009–2013 

period for two main reasons, both involving CBO’s 

baseline projections:

• About 90 percent of the difference is attributable 

to CBO’s baseline projections of SNAP’s average 

monthly benefits, which were substantially higher 

than the actual amounts. In its January 2009 baseline 

(which preceded the law’s enactment), CBO overestimated the routine inflation adjustment applied 

to SNAP benefits, which was based on the agency’s 

projection of the consumer price index (CPI) for food 

at home. That in turn caused CBO to underestimate 

the ARRA-related change in average benefits per 

person. Had CBO correctly projected the change in 

the CPI for food at home, the projection of ARRArelated spending on SNAP benefits would have been 

higher than it was and substantially closer to the 

actual amounts.

Table 1.

ARRA-Related Outlays for SNAP Benefits, Estimated in February 2009 and Actual

Billions of Dollars

Total

2009 2010 2011 2012 2013 2014 2015 2016 2017 2018 2019

2009–

2013

2009–

2019

Estimated in February 2009 

Based on Provisions in ARRA 4.4 5.6 4.1 3.0 1.6 0a 0 0 0 0 0 18.7 18.7

Estimated Actualb† 4.3 10.6 11.9 8.2 5.9 0.4 0 0 0 0 0 41.0 41.4

Overestimate or Underestimate (-)† 0.1 -5.1 -7.8 -5.1 -4.3 -0.4 0 0 0 0 0 -22.3 -22.7

Memorandum:

Outlays for SNAP Benefits, Projected in 

CBO’s January 2009 Baseline† 45.2 53.8 57.6 58.8 56.4 54.5 52.9 51.2 50.7 50.1 50.0 271.9 581.3

Source: Congressional Budget Office.

CBO estimated $20.0 billion in ARRA-related SNAP outlays over the 2009–2019 period. That estimate included $18.7 billion in outlays for benefits. The 

rest of the outlays were for administrative funding, the Food Distribution Program on Indian Reservations, block grants for Puerto Rico and American 

Samoa, and waiver rules for able-bodied adults without dependents.

ARRA = American Recovery and Reinvestment Act; SNAP = Supplemental Nutrition Assistance Program.

a. Excludes a small amount of spending on standard SNAP benefit payments for participants who enrolled in response to the increase in benefits.

b. Estimates of actual outlays are from the Office of Management and Budget, Budget of the U.S. Government: Appendix (various years), “Detailed 

Budget Estimates by Agency: Department of Agriculture.” The 2014 amount is adjusted to exclude $5.2 billion in spending on standard SNAP benefit 

payments during a lapse in appropriations in October 2013.

[†Values corrected on January 18, 2019]
DECEMBER 2018 A Review of CBO’s Estimate of the Effects of the Recovery Act on SNAP 3

• The remaining 10 percent of the difference is 

explained by CBO’s underestimate of SNAP 

participation, which arose in part from CBO’s 

baseline projections of economic conditions. 

Two factors affected actual ARRA-related spending on 

SNAP benefits between 2014 and 2019 that CBO could 

not have anticipated in completing its February 2009 

estimate. The first was the 2010 enactment of legislation 

that ended ARRA-related spending on SNAP benefits 

after October 31, 2013. (In October 2010, CBO estimated the effects of repealing those benefits; see Box 1 

on page 8.) The second was the federal government’s 

shutdown in October 2013. 

Any comparison of CBO’s estimates with actual results 

is complicated by legislation that is enacted after an 

estimate is completed. CBO does not attempt to predict 

future legislative changes or their effects on outlays when 

it prepares its baseline budget projections or its cost 

estimates. In this case, ARRA-related spending on SNAP 

between 2014 and 2019, and thus CBO’s underestimate 

of that spending, would have been substantially larger 

if not for the subsequent legislation that eliminated the 

increase in SNAP benefits provided under ARRA. Had 

the benefit increase not been repealed, CBO estimates, 

ARRA would have increased spending on SNAP benefits by another $21 billion over the 2014–2019 period, 

bringing the total estimated increase in outlays for 

benefits to $62 billion over the 2009–2019 period, or 

$43 billion more than CBO estimated in 2009.†

CBO can compare its estimates of ARRA-related spending on SNAP with actual spending for two reasons. First, 

ARRA required federal agencies to report separately on 

spending arising from that law’s provisions. Typically, 

changes in spending caused by changes in legislation 

are reported as part of overall program spending and 

therefore are difficult to isolate. In this case, however, 

the Treasury has reported its estimates of actual ARRArelated spending. Second, SNAP benefits increased for 

all participating households in an identifiable way. Thus, 

the actual cost of the increase is easier to estimate than it 

would have been if the effects of the legislation depended 

more on participants’ behavior or on decisions made by 

state and local governments. For example, the effects of a 

policy that would change the application process would 

be much more difficult to estimate because of other 

factors that also influence the process. 

How Did CBO Estimate the 

Effects of ARRA on SNAP?

SNAP eligibility is generally based on participation 

in other federal assistance programs or on household 

income and assets. In 2018, the federal government 

spent $68 billion on SNAP. In an average month that 

year, 40 million people (or one in eight U.S. residents) 

received benefits.

In February 2009, CBO estimated that outlays for the 

ARRA-related increase in SNAP benefits would be 

$19 billion, with all of that increase occurring between 

April 1, 2009, and September 30, 2013. That estimate 

was based on projections from CBO’s January 2009 

baseline and CBO’s assessment of the effects of the 

provisions in ARRA affecting SNAP.5

CBO based its estimate of the ARRA-related increase 

in outlays for SNAP benefits on its projection of the 

ARRA-related change in the average monthly benefit 

per person and of the number of people participating in 

SNAP. For example, in February 2009, CBO estimated 

that in 2010, the first full year of ARRA’s implementation, the average monthly benefit would increase by 

$13 (over its January 2009 baseline projection) and that, 

on average, 36.4 million people would participate each 

month (see Table 2). CBO estimated as a result that the 

ARRA-related increase in SNAP benefits in 2010 would 

be $5.6 billion. 

Change in the Average Monthly Benefit per Person

The standard SNAP benefit (that is, the benefit amount 

had ARRA not been enacted) for any household is based 

on that household’s net income and size and on the cost 

of the Thrifty Food Plan (TFP).6 The TFP is a basket 

of foods selected by the Department of Agriculture that 

5. See Congressional Budget Office, “Supplemental Nutrition 

Assistance Program—January 2009 Baseline” (January 2009), 

www.cbo.gov/sites/default/files/recurringdata/51312-2009-01-

snap.pdf (14 KB).

6. Under current law, SNAP benefits are awarded to “food assistance 

units”—the general equivalent of households (the term used 

in this report) consisting of people who live together who are 

not necessarily members of a family but who share purchasing, 

preparation, and consumption of food.

[†Values corrected on January 18, 2019]
4 A Review of CBO’s Estimate of the Effects of the Recovery Act on SNAP DECEMBER 2018

would provide a nutritious diet for a household of a 

particular size.7

CBO estimated that the ARRA-related increase in the 

average monthly benefit would be largest in 2009 and 

would subsequently lessen—as the standard benefit 

rose—until 2014, when the standard benefit would overtake the benefit set by ARRA. At that point, the ARRArelated change would be zero. CBO’s estimate of the 

change was based on the difference between its baseline 

projection in January 2009 and its estimate in February 

2009 of the benefit.

Baseline Projection in January 2009. In January 2009, 

CBO projected that the average monthly SNAP benefit 

per person would increase by about 8 percent in 2010, 

from $114 to $124, a historically large increase. CBO 

projected that average benefit growth in subsequent years 

would then be about 2 percent. 

7. For more information, see Andrea Carlson and others, Thrifty 

Food Plan, 2006, CNPP-19 (Department of Agriculture, 

Center for Nutrition Policy and Promotion, April 2007), 

https://go.usa.gov/xPeGb.

The baseline projection of the average benefit in a given 

year was based on the average benefit in the prior year, 

adjusted for recently enacted legislation, and on the 

projected change in the maximum benefit for a household of four people. CBO’s projection of the change in 

the maximum benefit depended critically on the cost of 

the TFP, which was based on its projection of the change 

in the CPI for food at home. In the years before 2009, 

that method generally yielded projections that were quite 

close to the actual amounts. 

Estimate Under ARRA in February 2009. To estimate 

average monthly benefits under ARRA, in February 

2009, CBO generally used the same method but substituted the benefit amount specified in ARRA. CBO 

estimated that benefits would average $136 between 

April 1, 2009, and the end of that year and then would 

decline slightly through 2014 because the agency 

expected participants’ earnings to increase, on average, as 

the economy improved.

CBO estimated that the benefit amount set by ARRA 

would have been above the cost of the standard benefit amount from April 2009 to September 2013. At 

that time, the standard benefit amount would have 

Table 2.

Monthly SNAP Benefits and Participation from 2009 to 2013, Estimated in February 2009 and 

Projected in CBO’s January 2009 Baseline

2009 2010 2011 2012 2013

Average Monthly Benefit per Person Dollars

Estimated in February 2009 based on provisions in ARRA 136 136 135 135 134

Projected in CBO’s January 2009 baseline 114 124 126 128 131

Increase 22 13 9 7 4

Number of People Participating Millions of People

Estimated in February 2009 based on provisions in ARRA 33.2 36.4 38.0 38.2 36.0

Projected in CBO’s January 2009 Baseline 33.0 36.3 38.0 38.2 36.0

Increase 0.2 0.1 * * *

Memorandum:

Maximum Monthly Benefit in SNAP for a Household of Four Dollars

Estimated in February 2009 based on provisions in ARRA 668 668 668 668 668

Projected in CBO’s January 2009 baseline 588 624 637 645 655

Increase† 80 45 32 23 13

Source: Congressional Budget Office.

ARRA provisions affecting SNAP were scheduled to go into effect on April 1, 2009, thus affecting spending for six months in 2009.

ARRA = American Recovery and Reinvestment Act; SNAP = Supplemental Nutrition Assistance Program; * = between zero and 50,000 people.

[†Values corrected on January 18, 2019]
DECEMBER 2018 A Review of CBO’s Estimate of the Effects of the Recovery Act on SNAP 5

then overtaken the benefit amount set by ARRA, CBO 

estimated. 

Number of SNAP Participants 

In general, CBO’s projections of SNAP participation 

are based on historical trends, projections of economic 

conditions (primarily the unemployment rate), and the 

agency’s assessment of how much and how quickly participation would respond to changes in the economy.

CBO estimated that ARRA would increase the number 

of SNAP participants each month by 200,000 people, on 

average, in 2009 and by 100,000, on average, in 2010. 

CBO estimated no additional ARRA-related change in 

participation for 2011 or subsequent years. 

Baseline Projection in January 2009. In the January 

2009 baseline, CBO projected that average monthly 

participation in SNAP would peak at 38 million people 

in 2012 before declining to 34 million people in 2014. 

That peak projection was higher than SNAP participation had ever been. CBO expected that the number of 

beneficiaries would rise substantially during an economic 

downturn like the one occurring in January 2009. CBO 

also expected that SNAP participation would continue 

to rise for about two years after a peak in the unemployment rate, as had been the case previously. As people’s 

economic situations subsequently improved, the agency 

expected, some participants would leave the program 

and fewer people would newly enroll. In addition, 

CBO expected, some participants would remain in the 

program but receive smaller benefits as their earnings 

improved. Nevertheless, CBO expected that participation after the economic downturn would not drop back 

to its prerecession level.

Estimate Under ARRA in February 2009. CBO estimated that SNAP participation would increase slightly 

above the baseline projection—by less than 1 percent—

in 2009 and 2010 because of benefit increases under 

ARRA. It estimated that the increase in the average 

monthly benefit would be 19 percent in 2009 and 

10 percent in 2010 and that the change would result in 

a slight rise in participation, mainly among people who 

were made eligible for a small benefit by the new law.

In CBO’s assessment, no new participants would enroll 

in 2011 or later years in response to the change in benefits. However, some of the participants who enrolled in 

2009 and 2010 in response to the increase would remain 

in the program in those later years.

Why Did CBO’s Estimate Differ From 

Actual Amounts Between 2009 and 2013?

In February 2009, CBO estimated that spending on 

SNAP for the benefit increase provided in ARRA would 

total $19 billion over the 2009–2013 period. Actual 

spending for those years was $41 billion, $22 billion 

more than CBO had projected.8 The discrepancy can be 

attributed to two factors:

• Differences between the estimated and actual increase 

in the average monthly benefit amount that resulted 

from ARRA accounted for about 90 percent.

• Differences between estimated and actual 

participation in SNAP accounted for about 

10 percent.

In general, although CBO’s estimates of the budgetary 

effects of legislation might not always match actual 

effects because of program changes that are implemented 

differently than expected, CBO correctly anticipated the 

ARRA-related changes to SNAP: That is, the increase in 

the maximum benefit amount affected benefits for participating households as CBO expected it would. Rather, 

the error stemmed from CBO’s baseline projections.

Change in the Average Monthly Benefit per Person

CBO underestimated the cost of increasing the standard 

SNAP benefit to the amount provided for in ARRA. 

That amount was known, but CBO’s baseline projection 

of the standard SNAP benefit amount turned out to 

be too high. Specifically, CBO’s January 2009 baseline 

(which was constructed before the provisions of ARRA 

were assessed) overestimated the annual increases in 

SNAP benefits under then-current law. In turn, the 

estimate of the difference between the standard benefit and the higher benefit specified in ARRA was too 

low (see Figure 1). CBO estimated that ARRA would 

increase the average benefit by about $13, from $124 

to $136 in 2010 (the first full year for which ARRA 

affected benefits). CBO now estimates that the standard 

benefit would have been $113. The actual average benefit 

8. Estimates of actual outlays are from Office of Management 

and Budget, Budget of the U.S. Government: Appendix (various 

years), “Detailed Budget Estimates by Agency: Department of 

Agriculture.”
6 A Review of CBO’s Estimate of the Effects of the Recovery Act on SNAP DECEMBER 2018

under ARRA was $134. That is, ARRA raised the average 

benefit from $113 to $134, or by $21—over one and a 

half times the amount CBO estimated in 2009.

CBO’s projection of the standard SNAP benefit amount in 

the January 2009 baseline was too high largely because of 

its projection of the change in the CPI for food at home. 

The Role of Food Prices. The CPI for food at home 

fell by more than one and a half percent in 2009, but 

CBO’s January 2009 baseline had projected a rise of 

4 percent. Because the annual TFP projection is based on 

the amount in the previous year, adjusted for inflation, 

CBO’s overestimate of the increases in the food index 

for the first few years of the projection window caused 

it to overestimate the cost of the TFP throughout the 

2009–2013 period. 

The January 2009 forecast of food prices was based on 

information available to CBO through the third quarter 

of 2008—in the midst of economic turmoil associated 

with the recession. The forecast also coincided with a 

peak in food price inflation—already on the increase for 

about two years—driven by surging agricultural commodity prices around the world. Although CBO projected that inflation in the price of food at home in 2009 

would be much lower than it was in 2008, prices in 

2009 turned out to be even lower than CBO projected 

(see Figure 2). That swing in food price inflation between 

2008 and 2009 was one of the largest since the 1950s. 

In particular, in the second quarter of 2009, the CPI for 

food at home had its largest single-quarter decline since 

the first quarter of 1967. 

Had CBO correctly projected the CPI for food at home, 

its estimate of ARRA-related spending on SNAP benefits 

per person would have been higher and quite close to 

actual amounts because of the strong link between the 

standard SNAP benefit, based on the cost of the TFP, 

and the CPI for food at home. Other factors, such as the 

distribution of income among beneficiaries, also affect 

that average.

Considerations for Future Estimates. If CBO again 

needed to assess the cost of legislation that set a higher 

maximum benefit per household for SNAP, the agency 

would consider generating its cost estimate on the basis 

of an average of spending under different possible paths 

of food price inflation rather than on spending related to 

a single projected path. 

Such an approach would give some weight to the possibility that the cost of the TFP either would decline or 

would increase more slowly than projected and that the 

effects on spending could be larger than estimated. That 

approach also would give some weight to the possibility 

that the cost of the TFP would increase more quickly 

than projected and that the effects on spending could be 

smaller—closer to zero. Because of the legislation’s specified maximum benefit amount, estimation errors could 

be much greater in the first case. That is, if the cost of 

the TFP declined or increased slowly, the ARRA-related 

increase in benefits would be large and would remain 

large for many years. However, if the cost of the TFP 

increased quickly, the ARRA-related increase would be 

small and would decline to zero rapidly. CBO estimated 

that ARRA-related spending on SNAP benefits would be 

$19 billion over the 10-year window. The lowest that the 

actual amount could have been was zero, and therefore the largest possible overestimate of spending was 

$19 billion. Averaging over different likely paths of food 

Figure 1.

Change in the Average Monthly SNAP 

Benefit per Person Resulting From ARRA

Dollars

Estimated Actual a

Estimated in February 2009 

Based on Provisions in ARRA

0

5

10

15

20

25

2009 2010 2011 2012 2013

Source: Congressional Budget Office.

ARRA = American Recovery and Reinvestment Act; SNAP = Supplemental 

Nutrition Assistance Program.

a. CBO estimated the actual change in the average monthly benefit 

amount per person in two steps. First, the agency estimated the 

average monthly benefit amount under the standard rules of SNAP. 

Second, CBO subtracted that amount from the actual average monthly 

benefit amount under ARRA.
DECEMBER 2018 A Review of CBO’s Estimate of the Effects of the Recovery Act on SNAP 7

inflation would incorporate that asymmetry in a way 

that using a single path cannot. 

That approach is applicable more broadly. In general, 

when the possible costs of legislation are not distributed 

evenly around a single path, CBO considers generating 

a cost estimate on the basis of an average of spending 

under different likely paths. For example, if a single 

projected path for the unemployment rate in CBO’s 

April 2018 baseline was used, CBO would estimate 

that legislation to provide additional benefits when the 

unemployment rate exceeds 5 percent would generate 

no increase in spending. In CBO’s current projections, 

the unemployment rate does not exceed 4.9 percent 

over the next 10 years. If that was the only unemployment rate considered, legislation that would generate 

spending when unemployment tops 5 percent would not 

be projected to result in any cost to the federal government. However, given the uncertainty around economic 

forecasts, there is some chance that the unemployment 

rate would exceed 5 percent during that period. So, in 

that case, CBO would take into consideration different possible paths for the unemployment rate, some of 

which would be associated with increases in spending 

and some of which would not.9 CBO’s decision about 

whether to generate a cost estimate in that way is based 

on its assessment of the value and difficulty of such an 

estimate relative to a typical cost estimate and its ability 

to complete such an estimate while ensuring that it will 

be available for Congressional deliberation. 

Number of SNAP Participants

Although projections of changes in the average monthly 

benefit account for most of the difference between 

CBO’s estimate and actual ARRA-related SNAP spending on benefits, some of the difference between 2009 and 

2013 arises from an underestimate of SNAP participation for that period (see Figure 3 on page 10). That 

underestimate occurred even though CBO projected that 

the share of the population participating in SNAP in 

2012—that is, at the peak—would be about 15 percent 

higher than it had ever been. CBO’s projection of SNAP 

participation depended on historical trends in participation, its projections of economic conditions, and its 

9. See Congressional Budget Office, Estimating the Costs of 

One-Sided Bets: How CBO Analyzes Proposals with Asymmetric 

Uncertainties (October 1999), www.cbo.gov/publication/11843.

assessment of how responsive participation would be to 

those changing conditions.10

The Role of Economic Conditions. For its 2009 estimate, CBO primarily used its projections of the unemployment rate as an indicator of economic conditions. 

That projection of the unemployment rate for the 2009–

2013 period turned out to be lower than the actual rate. 

Although CBO had projected a rise, the rate climbed 

faster and stayed higher for longer than the agency—

and many other forecasters—anticipated (see Figure 4 

on page 11). Projecting the rate was difficult: The 

increase in unemployment between December 2008 and 

December 2009 was substantially greater than had been 

the case in the previous two recessions; it was the largest 

rise in 27 years. Moreover, although CBO projected that 

unemployment would ultimately decline to 5 percent in 

the fourth quarter of calendar year 2014, the rate did not 

fall to that level until the end of calendar year 2015. 

10. CBO’s projection also accounted for changes in the program, 

including those affecting eligibility. In CBO’s assessment, those 

changes were not a significant factor in the agency’s underestimate of participation. See Congressional Budget Office, 

The Supplemental Nutrition Assistance Program (April 2012), 

www.cbo.gov/publication/43173.

Figure 2.

Quarterly Change in the Consumer Price Index for 

Food at Home

Percent 

Projected in CBO’s 

January 2009 Baseline

Actual

−4

−2

0

2

4

2000 2004 2008 2012

Source: Congressional Budget Office.
8 A Review of CBO’s Estimate of the Effects of the Recovery Act on SNAP DECEMBER 2018

Box 1 .

CBO’s 2010 Estimate of the Effects of Repealing ARRA-Related Spending on SNAP Benefits

In August 2010, the Congressional Budget Office estimated 

that a repeal after October 31, 2013, of the increase in benefits stipulated by the American Recovery and Reinvestment 

Act of 2009 (ARRA) for the Supplemental Nutrition Assistance 

Program (SNAP) would result in $14 billion in savings over the 

2014–2020 period.1 That projection, relative to CBO’s March 

2010 baseline (updated to account for the announced 2011 

SNAP benefit amount), differs from a projection that might have 

been made relative to CBO’s cost estimate for ARRA, which 

showed no ARRA-related costs over that period. By 2010, however, it was apparent that CBO’s 2009 estimate of costs during 

that period was too low. In particular, in 2010 it was clear that 

it would take longer for the ARRA-related increase in benefits 

to fall to zero. CBO had incorporated that new information into 

its 2010 baseline projections. 

CBO currently estimates that cumulative savings from that repeal 

will be $22 billion and that the savings will be realized over the 

2014–2020 period. That is, CBO’s 2010 estimate of savings was 

$9 billion below its current estimate (see the table).†

How Did CBO Arrive at Its 2010 Estimate of 

Savings From the Repeal? 

CBO’s 2010 estimate for the savings from repealing the 

ARRA-stipulated increase in SNAP benefits was done in two 

steps. 

1. In August 2010, Public Law 111-226 eliminated the ARRA increase in 

SNAP benefits after March 31, 2014. See Congressional Budget Office, 

cost estimate for Senate Amendment 4575, containing proposals related 

to education, state fiscal relief, the Supplemental Nutrition Assistance 

Program, rescissions, and revenue offsets (which became H.R. 1586 

and, subsequently, P.L. 111-226) (August 4, 2010), www.cbo.gov/

publication/21718. In December 2010, P.L. 111-296 eliminated the ARRA 

increase in SNAP benefits after October 31, 2013. See Congressional 

Budget Office, cost estimate for S. 3307, the Healthy, Hunger-Free Kids Act 

of 2010 (August 5, 2010), www.cbo.gov/publication/21729. 

First, the agency estimated the amount of SNAP spending for 

benefits that were the same as would have been paid out in 

the absence of ARRA. That estimate was based on CBO’s estimates of changes in average benefits and participation. CBO’s 

estimates of the changes in average benefits under standard 

SNAP rules were, in turn, based on its projections of the cost 

of the Thrifty Food Plan (TFP). The participation estimate was 

based on the projection in the March 2010 baseline, updated 

for changes in the price of the TFP announced by the Department of Agriculture in the summer of 2010. In CBO’s assessment, repealing the ARRA-stipulated increase in SNAP benefits 

would not lead to a decline in participation because the change 

in benefits was not large enough to cause such a response. 

Second, CBO subtracted that estimate of SNAP spending from 

SNAP spending projected in the March 2010 baseline, updated 

for changes in the price of the TFP. 

How Did CBO Arrive at Its Current Estimate of 

Savings From the Repeal?

CBO has now estimated the savings associated with the 

repeal of the ARRA-stipulated increase in SNAP benefits after 

October 31, 2013, on the basis of its April 2018 baseline, 

updated for changes in the price of the TFP announced in 

summer of 2018. For 2010 to 2013, ARRA was current law 

and so there were no savings. For 2014 to 2017, savings were 

estimated on the basis of the actual number of participants and 

the difference between the estimate of the average monthly 

benefit amount had the ARRA-stipulated increase remained 

in place and the actual changes in the price of the TFP. For 

2018 to 2020, savings were estimated on the basis of CBO’s 

projections of the number of participants and of the difference 

between CBO’s baseline projection of the average monthly 

benefit and its estimate of the average monthly benefit if 

benefits were as specified in ARRA. 

For this estimate, CBO also considered its projections of 

the changes in the CPI for food at home as an indicator 

of economic conditions. CBO projected that the index 

would rise—a factor in its projection that participation 

in the SNAP program would increase above its historical peak. However, the index did not rise as CBO had 

anticipated, and CBO’s overestimate caused it to project 

a larger increase in participation than it otherwise would 

have. That effect, however, was dwarfed by the other 

economic effects.

Had CBO’s projection of economic conditions in 

January 2009 been closer to the actual case, its projection 

of SNAP participation in the ensuing years might have 

been slightly higher than it was and might have stayed 

higher for longer. Despite that, CBO’s projection would 

Continued

[†Value corrected on January 18, 2019]
DECEMBER 2018 A Review of CBO’s Estimate of the Effects of the Recovery Act on SNAP 9

What Explains the Difference?

The difference between the original estimate and the current 

estimate of the savings over the 2014–2020 period from 

repealing ARRA’s increase in SNAP benefits is associated with 

two factors: the number of people participating and the change 

in benefits per person that was associated with the repeal.

The more significant factor was that CBO’s projection of SNAP 

participation over the 2010–2017 period was too low. In 2010, 

CBO expected that participation would be higher than it had 

anticipated in 2009, but it still did not project the full increase 

in participation that occurred. 

CBO also underestimated the change in benefits associated 

with repealing the ARRA-related increase. CBO’s 2010 estimate 

of the average standard SNAP benefit over the 2010–2020 

period was too high because its projection of the change in the 

consumer price index for food at home was too high. That is, 

CBO projected that the standard SNAP benefit amounts would 

catch up to and exceed the amounts specified in ARRA more 

quickly than has occurred. Thus, CBO underestimated both the 

amount and the duration of ARRA-related spending on SNAP 

benefits per person.

Savings Associated With Eliminating the ARRA-Related Increase in SNAP Benefits 

After October 31, 2013

Billions of Dollars

2010 2011 2012 2013 2014 2015 2016 2017 2018 2019 2020

Total, 

2010–

2020

Estimated in August 2010 0 0 0 0 5.3 4.3 2.7 1.2 0.4 0 0 13.9

Estimated in 2018a† 0 0 0 0 4.7 2.7 2.9 3.8 3.5 3.2 1.7 22.4

Overestimate or 

Underestimate (-)† 0 0 0 0 0.6 1.6 -0.2 -2.5 -3.1 -3.2 -1.7 -8.5

Source: Congressional Budget Office.

A change in law in August 2010 (Public Law 111-226) eliminated the increase in SNAP benefits specified in ARRA after March 31, 2014, 

and a change in law in December 2010 (the Healthy, Hunger-Free Kids Act of 2010, P.L. 111-296) eliminated the increase in SNAP benefits 

specified in ARRA after October 31, 2013.

ARRA = American Recovery and Reinvestment Act; SNAP = Supplemental Nutrition Assistance Program.

a. Estimated on the basis of the April 2018 baseline (updated to account for changes in the price of the Thrifty Food Plan announced by the 

Department of Agriculture in the summer of 2018). That baseline includes actual participation and average benefits from 2010 to 2017 

and projections for 2018 and later.

Box 1. Continued

CBO’s 2010 Estimate of the Effects of Repealing ARRA-Related Spending on SNAP Benefits

not have been substantially higher: It would still have 

been well below the actual increase in participation. 

Considerations for Future Cost Estimates. Cost estimates reflect both the baseline projection under current 

law and the methods used to analyze changes in law. If 

the country faced economic conditions now that were 

similar to those that prevailed over the 2008–2013 

period, CBO’s baseline projection of the attendant 

increase in SNAP participation probably would be larger 

than it its January 2009 projection. The new evidence 

for such a rise in program participation would cause the 

agency to consider an increase to be likelier than it did in 

2009. The actual increase in 2009 also means that many 

more people now have experience with SNAP. In CBO’s 

assessment, those people would be more likely to participate than would people who have never enrolled at all.

[†Values corrected on January 18, 2019]
10 A Review of CBO’s Estimate of the Effects of the Recovery Act on SNAP DECEMBER 2018

Although in CBO’s assessment, the increase in participation was largely the result of weak economic conditions, 

the data the agency examined do not distinguish whether 

the underestimate of participation in SNAP stemmed 

from a baseline projection of participation that was 

too low or from a cost-estimating method that underestimated the response to the increased benefit. As it 

prepares to analyze future proposals, CBO will continue 

to monitor the research about participation in response 

to changes in benefit amounts. 

What Factors Affected CBO’s Estimates 

Between 2014 and 2019?

Two additional events affected ARRA-related spending on SNAP between 2014 and 2019: the enactment 

in 2010 of legislation eliminating the ARRA increase in 

SNAP benefits after October 31, 2013, and the federal 

government’s shutdown in October 2013.

Legislation in 2010

In February 2009, CBO estimated that there would 

be minimal ARRA-related spending on SNAP after 

October 31, 2013. Then, in December 2010, the Healthy, 

Hunger-Free Kids Act of 2010 eliminated the ARRA 

increase in SNAP benefits after October 31, 2013.11

Hence, the actual outcome for the 2014–2019 period 

turned out to closely match CBO’s February 2009 

estimate.

However, ARRA-related spending on SNAP between 

2014 and 2019, and thus CBO’s underestimate of that 

spending, would have been substantially larger if not 

for that subsequent legislation. Had the benefit increase 

not been repealed, CBO estimates, ARRA would have 

increased spending on SNAP well beyond 2014, adding 

another $21 billion over the 2014–2019 period.

By early 2010, as it does every year, CBO had updated 

its baseline to reflect new information on spending and 

revenues, newly enacted legislation, significant economic 

developments, and improvements to projections. At that 

point, the decline in food price inflation had become 

more apparent, and CBO projected that ARRA-related 

spending on SNAP would continue after October 31, 2013. 

Relative to the March 2010 baseline updated for changes 

in the price of the TFP announced by the Department of 

Agriculture in the summer of 2010, CBO estimated in 

August 2010 that legislation repealing the ARRA-related 

increase in SNAP benefits after October 31, 2013, would 

reduce that spending by $14 billion. Nevertheless, as it 

had in February 2009, CBO underestimated ARRArelated outlays on SNAP benefits and thus underestimated the savings from eliminating those outlays 

(see Box 1 on page 8).

Government Shutdown

On October 1, 2013, appropriated funds lapsed and 

normal operations of the federal government were suspended (that is, the government entered what is often 

called a partial shutdown). Normal operations of the 

federal government resumed on October 17, 2013. On 

October 1 of that year, the Department of Agriculture 

issued guidance that households eligible for SNAP benefits would still receive them in October, despite the lack 

11. That law superseded Public Law 111-226, enacted in August 

2010, which eliminated the ARRA increase in SNAP benefits 

after March 31, 2014. See Congressional Budget Office, cost 

estimate for S. 3307, the Healthy, Hunger-Free Kids Act of 2010 

(August 5, 2010; that bill became P.L. 111-296), www.cbo.gov/

publication/21729, and the cost estimate for Senate Amendment 

4575, containing proposals related to education, state fiscal relief, 

the Supplemental Nutrition Assistance Program, rescissions, and 

revenue offsets (August 4, 2010; that bill became H.R. 1586 and, 

subsequently, P.L. 111-226), www.cbo.gov/publication/21718. 

Figure 3.

Participation in SNAP

Millions of People

Estimated in 

February 2009 

Based on 

Provisions in ARRA

Actual

0

10

20

30

40

50

60

2000 2004 2008 2012

Source: Congressional Budget Office.

ARRA = American Recovery and Reinvestment Act; SNAP = Supplemental 

Nutrition Assistance Program.
DECEMBER 2018 A Review of CBO’s Estimate of the Effects of the Recovery Act on SNAP 11

of appropriated funds.12 According to the department, 

the authority to make such payments came from ARRA, 

in which the Congress provided “such sums as are necessary” to finance SNAP benefits at the level provided for 

in that law.13 (Effectively, ARRA authority was used to 

increase SNAP benefits from zero when the government 

shut down on October 1.)

As a result, the ARRA-related costs of $5.6 billion for 

that month encompass the full cost of SNAP benefits, 

not just the portion related to the increase stipulated in 

ARRA.† Most of that spending—$5.2 billion—would 

12. For budgetary purposes, SNAP is designated in law as a direct 

spending program, a category that generally consists of programs 

that do not receive annual appropriations. However, funds 

are appropriated each year to cover program costs. For further 

information, see Congressional Budget Office, The Supplemental 

Nutrition Assistance Program (April 2012), www.cbo.gov/

publication/43173.

13. Jessica Shahin, Associate Administrator, Supplemental Nutrition 

Assistance Program, Department of Agriculture, letter to SNAP 

state agency directors, “Update on Food and Nutrition Service 

Operations, Supplemental Nutrition Assistance Program 

(SNAP)” (October 1, 2013).

This report evaluates a CBO cost estimate. Such 

evaluations help guide CBO’s efforts to improve 

the quality of its projections and, as background 

information, are intended to assist Members of 

Congress in their use of the agency’s estimates. 

In keeping with CBO’s mandate to provide 

objective, impartial analysis, the report makes no 

recommendations.

Molly Dahl wrote the report, Kathleen FitzGerald 

prepared the estimates, and Jordan Berne provided 

research assistance. Sheila Dacey, Theresa Gullo, 

Joseph Kile, and Sam Papenfuss provided guidance. 

Comments were provided by Alissa Ardito, Robert 

Arnold, Tia Caldwell, Gloria Chen, Sebastien Gay, 

Jennifer Gray, Edward Harris, and John McClelland. 

Randy Aussenberg of the Congressional Research 

Service, Angela Rachidi of Mathematica Policy 

Research, and Dottie Rosenbaum of the Center on 

Budget and Policy Priorities also offered comments. 

The assistance of external reviewers implies no 

responsibility for the final product, which rests 

solely with CBO. 

Wendy Edelberg, Mark Hadley, Jeffrey Kling, and 

Robert Sunshine reviewed the report; Kate Kelly 

edited it; and Casey Labrack prepared it for 

publication. This report is available on CBO’s 

website (www.cbo.gov/publication/54864). 

CBO seeks feedback to make its work as 

useful as possible. Please send comments to 

communications@cbo.gov.

Keith Hall

Director

have occurred later in the month, once the appropriation 

was enacted. Moreover, when CBO estimated the effects 

of ARRA on SNAP, such spending was projected in the 

baseline because it was attributable to then-current law. 

CBO does not include those costs when comparing its 

estimate with actual spending.

Figure 4.

Unemployment Rate

Percent

Projected in CBO’s 

January 2009 Baseline

Actual

0

2

4

6

8

10

2000 2004 2008 2012

Source: Congressional Budget Office.

The unemployment rate is a measure of the number of jobless people 

who are available for work and are actively seeking jobs, expressed as a 

percentage of the labor force.

[†Value corrected on January 18, 2019]