On July 21, 2025, GBPI’s President and CEO, Staci Fox, submitted the following formal comment to the U.S. Department of Agriculture.
The Georgia Budget and Policy Institute (GBPI) submits these comments in response to the System of Records Notice for USDA/FNS-15: “National Supplemental Nutrition Assistance Program (SNAP) Information Database,” published in the Federal Register by the U.S. Department of Agriculture (USDA) on June 23, 2025.[1]
GBPI has grave concerns regarding both the proposed new Database and the accompanying Notice.
GBPI is a nonpartisan policy research and advocacy organization with a mission to advance lasting solutions that expand economic opportunity and well-being for all Georgians. The organization does this through data and evidence-informed analysis, strategic communications, and administrative and legislative advocacy.
SNAP is an indispensable resource to combat hunger in our nation. Congress established SNAP to “promote the general welfare… [by] safeguard[ing] the health and well-being of the Nation’s population and raise levels of nutrition among low-income households.”[2] SNAP is the largest food assistance program in the country.[3] GBPI focuses on several policies and programs that contribute to economic opportunity for all Georgians, and the Supplemental Nutrition Assistance Program (SNAP) is an important part of the organization’s work. GBPI strives to preserve and strengthen the SNAP program to ensure all Georgians at risk of food insecurity have access to food assistance to keep them well-nourished and healthy.
The Notice for the proposed National SNAP Information Database (NSID) exhibits significant errors and omissions, particularly regarding the scope of data collection. USDA has not provided a full and exhaustive list of the data being sought. This lack of clarity on the records that will be collected creates widespread confusion for State agencies, SNAP applicants and beneficiaries, and organizations that help connect individuals to SNAP services. For example, the Georgia Department of Human Services submitted a comment on July 11, 2025—two days after the renewed demand letter—seeking clarification on what data to submit and how.[4] However USDA’s Food and Nutrition Service has not offered any response to the state.
Furthermore, the System of Record Notice (SORN) fails to provide clear and legitimate reasons for such a wide-ranging data collection. The stated primary purposes of validating eligibility and strengthening program integrity contradict existing statutes and robust systems already in place to ensure program integrity. For instance, the National Accuracy Clearinghouse (NAC), established pursuant to Congressional direction in the 2018 Farm Bill, already serves to prevent interstate dual participation in SNAP through a shared database of eligibility information. The Notice contains no evidence that existing systems like the NAC are not functioning as intended or that there is a meaningful gap in lawful data collection that merits building a new Database.
Beyond the issues of purpose and clarity, the SORN’s outlined “routine uses” for SNAP data are excessively sweeping and fundamentally conflict with the program’s foundational statute. Routine Use 8, for example, envisions unfettered sharing of data for law enforcement, a scope significantly wider than the explicitly permitted disclosures of SNAP participant information under the authorizing legislation. The relevant statute permits data sharing on a highly individualized, household-specific basis.[5] In stark contrast, this Notice mandates an extensive, unrestricted collection and dissemination of sensitive data, effectively transforming a vital federal benefit program into a comprehensive data repository for law enforcement.[6] Similarly problematic is Routine Use 11, which grants the USDA broad discretion to release SNAP data to any domestic government entity involved in federal benefits programs, provided the USDA deems such disclosure “reasonably necessary . . . to prevent, deter, discover, detect, investigate, examine, prosecute, sue with respect to, defend against, correct, remedy, or otherwise combat fraud, waste, or abuse in such programs.”[7] This provision extends considerably beyond the limited data disclosures authorized by Congress.
Finally, the federal government is not allowing meaningful public comment on this critical issue. On July 9—halfway through the comment period—USDA sent another letter to states setting a new and rapidly approaching deadline of July 24 for the same data that had already been requested and paused once.[8] This date, immediately following the close of the SORN public comment period, leaves USDA no time to consider, let alone meaningfully address, any comments or concerns from the public, including state agencies seeking to responsibly comply without violating federal privacy laws or similar state laws. The vital importance of SNAP and the highly sensitive data being requested warrant a more thoughtful and thorough approach than the one exhibited here.
For these reasons, GBPI respectfully requests that the System of Records Notice for the Food and Nutrition Service (FNS): “National Supplemental Nutrition Assistance Program (SNAP) Information Database” be withdrawn, and that USDA abandon its proposal to establish a data system and halt all data collection related to the Notice. If USDA must proceed with the creation of the Database, we recommend that it provide more clarity on all the data states will need to submit and how, create a reasonable schedule to receive the data and work with states to ensure the data is protected, accurate and adequately reviewed.
[1] Privacy Act of 1974; System of Records, 90 Fed. Reg. 26,521.
[2] Food Stamp Act of 1964, Pub. L. No. 88-525, § 2, 78 Stat. 703, 703 (1964). https://www.congress.gov/88/statute/STATUTE-78/STATUTE-78-Pg703.pdf
[3] U.S. Dep’t of Agriculture Economic Research Service, Supplemental Nutrition Assistance Program (Jan 8, 2025), https://www.ers.usda.gov/topics/food-nutrition-assistance/supplemental-nutrition-assistance-program- snap/#:~:text=The%20Supplemental%20Nutrition%20Assistance%20Program,program%20for%20low%2Di ncome%20Americans.
[4] Id.
[5] 7 U.S.C. § 2020(e)(8), (15).
[6] See 90 Fed. Reg. 26,522-23.
[7] Id. at 26,523.
[8] SNAP Database – Letter to State Agencies (July 9, 2025), https://www.fns.usda.gov/snap/admin/database-letter.
