Food stamp benefits can be wiped from an EBT card nine months after they were issued, even when the card is in regular use. The U.S. Department of Agriculture put that in writing in a November 2025 memo to state SNAP agencies, and it said states are “strongly encouraged” to work this way. Federal law requires that old SNAP benefits be expunged after nine months, and the memo lays out how states may count the nine months.
The counting method decides whether swiping the card protects older money. Under one permitted option it does, and under the option USDA prefers it does not.
What did the USDA memo say?
The memo is dated Nov. 18, 2025 and was issued by Ronald Ward, acting associate administrator of the SNAP program at USDA’s Food and Nutrition Service. It went to state agency directors and regional directors, and its stated purpose was to clarify SNAP EBT expungement policy in an effort to reduce fraud, waste and abuse. The USDA memo cites Section 7(c) of the Food and Nutrition Act of 2008, which requires expungement after nine months and requires sufficient notice to households.
The memo also cites 7 CFR 274.2(i)(1), the regulation that lets a state choose between two ways of measuring the nine months. Those two options are the heart of the story.
How do the two options differ?
Under the first option, a state expunges benefit allotments that have been inactive for nine months. An account is inactive if the household has not started activity that changes the balance, such as a purchase or a return. In practice that is nine months since the last time the card was used.
Under the second option, a state expunges allotments nine months after issuance, regardless of account activity. A household that shops every week can still lose the benefits that reach their ninth month, because the clock runs from the date each month’s deposit was issued. The memo says states “are strongly encouraged” to expunge on this basis.
USDA says the second approach “will generally result in a higher value of expungements” because unused benefits are removed even from active accounts.
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Does using the card protect the older money?
For a SNAP household, the question is whether the state it lives in counts from the last use or from issuance. The memo does not say which states use which option, and it makes the choice permissive, not required. Under the inactivity option, regular shopping keeps the whole balance alive. Under the issuance option, the oldest deposits expire on their own schedule whether or not the card is used.
That makes the order of spending the practical issue. In a state that counts from issuance, the oldest benefits are the ones at risk, and a card with a growing balance is carrying deposits that are approaching their ninth month. The memo gives no exceptions to the nine-month rule and does not address disasters.
Why is USDA pushing the second option?
The memo gives four reasons: recouping funds sooner, budget planning, preparing for cost-sharing changes under the One Big Beautiful Bill Act of 2025, and limiting large balances that could make households targets for theft. Expungement recoups SNAP funds, and the memo does not say more about where they go.
It sets no compliance deadline. If a state changes its approach, the memo says it should update its State Plan of Operation and notify SNAP households. States must give “sufficient notice” before expunging, though the memo gives no specific timeframe or method for that notice.
The memo also says guidance documents lack the force and effect of law unless authorized by statute or incorporated into a contract. The nine-month requirement itself comes from the statute. The encouragement to use the issuance option is the part that is guidance.
Where can a household check the state’s rule?
Questions about a specific state go to the state SNAP agency, and the memo directs state agencies with questions to their FNS regional offices. USDA’s SNAP page for recipients is the federal starting point.
The memo leaves one question for each household: which option the state uses, and how soon the notice arrives if that changes. Until a state says, the safest reading of the federal text is that benefits near nine months old are the ones that matter.
Not sure which nine-month rule applies to the card?
A household that assumes regular use protects the balance could lose its oldest deposits, because USDA’s preferred option counts nine months from the date each deposit was issued.
The SNAP & Medicaid Renewal Organizer includes 51 state packs and a renewal and reporting calendar, and Part 7, Reporting Changes and EBT Problems, covers what to do when a card balance looks wrong.
Get the state pack and reporting calendar for an aging EBT balance →
More Financial Reading
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This article was produced with AI assistance and edited for accuracy against the sources linked above.
