Colorado’s hunger relief organizations, still reeling from the freeze in SNAP funding last month, now face the possibility that federal funding for the nation’s largest food assistance program will be withheld from the state.

Earlier this month, USDA Secretary Brooke Rollins said the Trump administration is considering withholding SNAP funding from states that refuse to comply with requests for personal information, such as full names and immigration statuses, of benefit applicants and recipients.

“We asked for all the states for the first time to turn over their data to the federal government to let the USDA partner with them to root out this fraud, to make sure that those who really need food stamps are getting them,” Rollins said, “but also to ensure that the American taxpayer is protected.”

In July, Rollins argued that “the generosity of the American taxpayer” has been abused by “faulty interpretations” of a 1996 law that tightened SNAP eligibility by imposing work requirements and restricting access for certain legal immigrants.

“Illegal aliens should not receive government dollars,” Rollins said. “This effort is one of many by the Department of Agriculture to eliminate waste, fraud, and abuse of USDA’s programs and policies.”

Undocumented immigrants have never been allowed to receive SNAP benefits, and under House Resolution 1, also known as the “One Big Beautiful Bill Act,” refugees and asylum seekers will no longer be eligible either.

According to PBS, 29 states have complied with the USDA’s data request. Twenty-two states, including Colorado, have filed a lawsuit against the agency, arguing that it is misinterpreting the congressional budget’s SNAP provisions. Specifically, the states said their lawsuit concerns food stamp eligibility for lawful permanent residents, regardless of the path they took before their immigration status was adjusted.

The states said the USDA has excluded legal permanent residents and green card holders based on their previous status, including refugees, people granted asylum and parolees.

In their lawsuit, the attorneys general also noted that the congressional budget imposes “massive financial penalties” on states for their error rates in issuing SNAP payments. But the USDA gave them only one day — rather than 120 — as a grace period for any misapplication of the new law.

As such, the states now face “massive penalties,” they said.

Gov. Jared Polis told Colorado Politics that he has not received any notice from the federal government about plans to withhold funding.

“While it is unknown whether SNAP funds will be withheld from Colorado and the other 20 states that have so far refused to turn over data — and legal challenges would almost certainly arise if any such plans were to become more real — Colorado’s hunger relief providers see it as another blow after an extremely difficult past few months,” he said. “Hungry Americans, like everyone, deserve access to food.”

Brandon McKinley works for Metro Caring, a Denver-based anti-hunger organization that operates its own food market. When the waitlist to enter the market began filling up a month in advance, the organization began distributing prepackaged food boxes for people who couldn’t wait that long.

“People were going online and booking them faster than they ever booked them before, so that was the first key indicator that people are worried,” he said.

Metro Caring also reached out to the community for help, setting a goal to reach $150,000 in donations. McKinley said they had surpassed that goal.

The state also secured funds in anticipation of the fall funding freeze: in October, the governor signed an executive order requesting the Joint Budget Committee’s approval of up to $10 million in General Fund revenue to support Colorado’s food banks and pantries. The JBC swiftly approved the request, and the funds were allocated to organizations like Metro Caring through the state’s Community Food Grant Assistance Program.

McKinley said Metro Caring was given credits that allow them to purchase food from the Food Bank of the Rockies, but only through the end of the year.

“It’s crazy, but that $10 million goes quick,” he said.

Marissa Cantrell, a SNAP recipient who works for a Lakewood-based nonprofit that provides housing for people at risk of homelessness, said she and her partner started a food bank there two years ago. While the food pantry is small, she said it has been invaluable to the immigrant community, many of whom don’t qualify for SNAP benefits.

Unfortunately, Cantrell said, they’ve had to limit the number of people the pantry can serve each day due to growing demand.

“If people were like, ‘hey, my buddy needs some food, can we get a care box for them?’ We were like, ‘sure, of course,’ but now it’s becoming more and more, ‘hey, we can only help people who are part of this community right now,'” she said.

Like McKinley, Cantrell was astonished to see how many community members pitched in to help people in need during the SNAP freeze. However, she noted, if a freeze were to become more permanent, organizations like hers wouldn’t be able to survive on the kindness of strangers alone.

The SNAP freeze “showed a lot of gaps” within the state’s hunger relief infrastructure, Cantrell said.

“There are real budgetary limitations to the state getting us more money and tapping into emergency reserves, because what about wildfires? What about other emergencies that may come up down the road? How often would we have to tap into those emergency funds to feed people, then whenever SNAP gets delayed, or cut, or whatever the federal administration decides to do?” she said. “This brought to light really big, glaring budgetary concerns from the state level, from the county level, and in the cities. Everybody wants to help, and then they find out there’s no money here, so do we need to generate more money? Those conversations are now starting to happen, but they’re a long way off.”

McKinley agreed: “I think we’re looking at potentially cascading emergencies or just a constant state of emergency that I don’t know if we’ve ever seen in our country,” he said. “When I think back to the pandemic, the federal government actually increased SNAP benefits to help folks; they introduced child tax credits, and there were all these programs that were actually proving to be really, really effective at reducing child poverty and hunger. It’s the government’s responsibility to make sure people have access to food, and it’s their obligation to make sure we have our right to food.”

Colorado’s hunger relief organizations are concerned that funding for food assistance may be left solely to the state, given the state’s budgetary challenges in recent years.

“I just don’t know that we have the resources or the ability to cover in full SNAP benefits, because it’s such a hugely effective program, that to be able to replace it overnight with something is just, I think, outside the realm of possibility,” McKinley said.

Brace Gibson, policy director at Provecho Collective, a nonprofit collective focused on improving the state’s food system, proposed a solution:

“We need to, as a state, consider a graduated income tax to generate additional revenue,” she said. “I truly think that we are in a time where we have to get creative, given all of the issues that we’re facing — not just food security, but also the rising health care costs and just affordability in general.”

Gibson is referring to a proposed initiative for the 2026 ballot that would change the state’s flat 4.1% income tax rate to a graduated income tax, under which individuals with incomes up to $500,000 would receive a small tax cut. Those who earn more would see an increase.

Because instances of SNAP fraud are relatively rare, according to the Congressional Research Service, Gibson believes the federal government’s motivations for obtaining personally identifying information about SNAP recipients and applicants extend beyond sifting out fraudulent activity.

“The demand for SNAP data is unprecedented, and it’s not as much about fraud as it is about surveillance and continued assaults on our immigrant communities,” she said. “Undocumented folks and some people present in the United States under temporary visas have long been ineligible to receive SNAP benefits, so that eligibility restriction and general exclusion is not new. What is new is the Trump Administration’s ceaseless demands for personally identifiable data, not just for people who have received SNAP, but also for folks who have applied for benefits but were ultimately denied issuance. Ultimately, this is an attempt to spread harmful narratives that support immigration enforcement and are part of a larger effort to completely dismantle our social safety net.”

Gibson called the data request a “true and real risk” to some of Colorado’s most vulnerable populations.

“I think something that gets lost is that there are so many different types of documentation, and they all have legal status,” added Cantrell. “Everybody [that resides in her organization’s community] has legal status in some way, but they still don’t qualify for SNAP. They’ve done everything right, they are legal, they are documented, and they still don’t qualify for SNAP.”

While Gibson believes the courts would not allow the federal government to withhold SNAP benefits from states as a form of retaliation, there could still be serious impacts on people who receive SNAP benefits while litigation unfolds.

“There are still very real negative impacts to what’s happening,” she said. “The likely results of punishing states in this way is a total dissolution of the integrity of the nation’s largest and most effective food assistance program, and even greater distrust in our social service programs amongst individuals and families who remain eligible to receive assistance, and in that regard, even more widespread suffering as folks become too fearful to even apply for benefits.”

While the SNAP freeze, which left some people without money for food for several weeks, was devastating, it was temporary, McKinley said. If the Trump administration were to withhold funding from Colorado and other states and the court allows it, the impact could last for years.

“I mean, we’re looking at families and children genuinely going without food and genuinely going hungry,” he said. “We’re wrestling with the fact that SNAP is one of the most effective programs at reducing hunger and food insecurity in the country right now with our current food system, and the rollback of it, which is really going to have catastrophic health and wellness impacts in our community that the nonprofit sector isn’t built to take over.”

Cantrell, who works with several other organizations and groups dedicated to ending hunger in Colorado, noted the heavy toll the ordeal has taken not only on SNAP recipients but also on those working to help them.

“Our helpers, they’re all experiencing a lot of burnout since this happened,” she said. “That’s what I keep hearing from all of the different groups I’m in, talking with people I know one-on-one; the stress that is caused from having to scramble — we’re going to do it, we’re going to feed people, but it’s taken a lot of emotional toll, and I just want to make sure that that gets recognized.”