COMMITTEE ON LEGISLATIVE RESEARCH
OVERSIGHT DIVISION
FISCAL NOTE
L.R. No.:2638H.01I Bill No.:HB 1222 Subject:Public Assistance; Food Type:Original Date:March 3, 2025Bill Summary:This proposal prohibits the use of SNAP benefits to purchase certain foods.
FISCAL SUMMARY
ESTIMATED NET EFFECT ON GENERAL REVENUE FUNDFUND AFFECTEDFY 2026FY 2027FY 2028
General*
$0
($15,182,353 to
Unknown) or
($30,364,706 to
Unknown)
($105,983) or
($211,967)
Total Estimated Net
Effect on General
Revenue
$0
($15,182,353 to
Unknown) or
($30,364,706 to
Unknown)
($105,983) or
($211,967)
*Range reflects the difference between a 50% Federal match and no Federal match.
ESTIMATED NET EFFECT ON OTHER STATE FUNDSFUND AFFECTEDFY 2026FY 2027FY 2028Total Estimated Net
Effect on Other State
Funds $0$0$0
Numbers within parentheses: () indicate costs or losses. L.R. No. 2638H.01I
Bill No. HB 1222
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March 3, 2025
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ESTIMATED NET EFFECT ON FEDERAL FUNDSFUND AFFECTEDFY 2026FY 2027FY 2028Federal*Total Estimated Net
Effect on All Federal
Funds $0$0$0
*Income and expenses are estimated at $0 or $15 million to Unknown in FY 2027, and $0 or
$105,000 in FY 2028 and ongoing and net to zero. Range reflects the difference between a 50%
Federal match and no Federal match.
ESTIMATED NET EFFECT ON FULL TIME EQUIVALENT (FTE)FUND AFFECTEDFY 2026FY 2027FY 2028General Revenue01 or 21 or 2Federal Funds 00 or 10 or 1Total Estimated Net
Effect on FTE 022
☒ Estimated Net Effect (expenditures or reduced revenues) expected to exceed $250,000 in any
of the three fiscal years after implementation of the act or at full implementation of the act.
☐ Estimated Net Effect (savings or increased revenues) expected to exceed $250,000 in any of
the three fiscal years after implementation of the act or at full implementation of the act.
ESTIMATED NET EFFECT ON LOCAL FUNDSFUND AFFECTEDFY 2026FY 2027FY 2028Local Government$0$0$0 L.R. No. 2638H.01I
Bill No. HB 1222
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March 3, 2025
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FISCAL ANALYSIS
ASSUMPTION
§ 208.025 - SNAP benefits to purchase certain foods
Officials from the Department of Social Services (DSS) state the proposed legislation requires
the Director of DSS to request a waiver from the U.S. Department of Agriculture (USDA) to
exclude candy and soda, as defined in this legislation, from the definition of eligible foods under
7 CFR 271.2 for Supplemental Nutrition Assistance Program (SNAP) purchases. If the waiver is
granted, the purchase of candy and soft drinks, as defined in this section, will be prohibited for
purchase with SNAP benefits. If the waiver is denied, the Director will request the waiver
annually, until it is granted.
Currently, 7 CFR 272.3 allows state agencies to request waivers from the U.S. Department of
Agriculture’s Food and Nutrition Service (FNS) to deviate from certain SNAP regulations.
If the waiver is approved, the purchase of candy and soda would be prohibited for purchase with
SNAP benefits. FSD currently utilizes a third-party vendor to administer SNAP benefits.
The EBT vendor estimates that implementing the proposed functionality would require the
development of a new solution at both the retailer and national levels. This solution would
require Food and Nutrition Service (FNS) approval and collaboration with all impacted
stakeholders, including national retailers. The current SNAP system does not support individual
food item restrictions, new technology must be developed, which would include the collection of
Universal Product Code (UPC) data. Retailers would be required to reprogram point-of-sale
(POS) systems to comply with these changes.
The current EBT vendor estimates the necessary programming changes to support these purchase
restrictions would require significant development efforts and will cost approximately $30
million to unknown and require additional approval from FNS.
If the waiver is approved, FNS and the state would be responsible for enforcing compliance
with the provisions of this legislation. These responsibilities could include overseeing retailer
compliance and enforcement of purchase restrictions. FSD estimates an additional 2 Program
Specialists will be needed to administer the provisions of this legislation.
If the waiver is approved, FSD will need to notify all SNAP households of the change in
allowable food purchases. As of December 2024, there were 328,068 SNAP households actively
receiving SNAP benefits in Missouri. As of January 2025, the mailing rate for first class mail is
$0.69 per piece. FSD estimates that it will cost $227,000 (328,068 * $0.69 = 226,366.92,
rounded up) to mail notification letters to all active SNAP households. L.R. No. 2638H.01I
Bill No. HB 1222
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March 3, 2025
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FSD estimates that it will take approximately six months to obtain waiver approval from FNS
and approximately one year for the EBT vendor to implement the required changes. Therefore,
the provisions of this legislation could not be implemented until approximately January 2027.
FSD defers to the Office of Administration for information sharing and procurement changes
necessary to implement the provisions of this legislation.
If the waiver is approved and federal matching funds of 50% is determined allowable by
FNS, the estimated fiscal impact to FSD to implement the provisions of this legislation is
$15,113,500 to Unknown in General Revenue for the EBT vendor costs and one-time mailing
costs in FY 2027, in addition to 50% of the cost for 2 FTE.
If the waiver is approved and federal matching funds of 50% is NOT determined allowable
by FNS, the total fiscal impact to FSD to implement the provisions of this legislation is
$30,227,000 to Unknown in General Revenue for the EBT vendor costs and one-time mailing
costs in FY 2027, in addition to 100% of the cost for 2 FTE.
Officials from the Office of Administration (OA) assume the proposal will have no fiscal
impact on their organization. Oversight does not have any information to the contrary.
Therefore, Oversight will reflect a zero impact in the fiscal note.
Oversight does not have information to the contrary. Oversight notes implementation of the
proposal is contingent on the approval of a waiver by FNS. If the proposal is passed, but no
waiver is granted, the cost of the provisions of this proposal will be $0 unless or until a waiver is
approved by FNS. For fiscal note purposes, Oversight assumes the waiver will be granted.
Therefore, Oversight will reflect the estimates as provided by the DSS with and without the 50%
match from FNS. L.R. No. 2638H.01I
Bill No. HB 1222
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FISCAL IMPACT – State GovernmentFY 2026
(10 Mo.)
FY 2027
(6 Mo.)
FY 2028GENERAL REVENUECosts – DSS, FSD (§ 208.025) p. 3-4 Personal service
$0
($28,387) or
($56,775)
($57,342) or
($114,685)
Fringe benefits
$0
($23,519) or
($47,037)
($37,245) or
($74,490)
Equipment and expense
$0
($16,947) or
($33,894)
($11,396) or
($22,792)
EBT Vendor Costs p. 3-4
$0
($15,000,000 to
Unknown) or
($30,000,000 to
Unknown)$0
One-time mailing p. 3-4
$0
($113,500) or
($227,000)$0
Total Costs - DSS, FSD
$0
($15,182,353 to
Unknown) or
($30,364,706 to
Unknown)
($105,983) or
($211,967)
FTE Changes01 or 21 or 2
ESTIMATED NET EFFECT ON
GENERAL REVENUE$0
($15,182,353 to
Unknown) or
($30,364,706 to
Unknown)
($105,983) or
($211,967)
Estimated Net FTE Change on the
General Revenue Fund01 or 21 or 2
FEDERAL FUNDSIncome – DSS, FSD (§ 208.025)
Reimbursement for SNAP benefit
changes p. 3-4$0
$0 or $15,182,353
to Unknown$0 or $105,983
Costs – DSS, FSD (§ 208.025) p. 3-4 Personal service$0$0 or ($28,387) $0 or ($57,342) Fringe benefits$0$0 or ($23,519) $0 or ($37,245) L.R. No. 2638H.01I
Bill No. HB 1222
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FISCAL IMPACT – State GovernmentFY 2026
(10 Mo.)
FY 2027
(6 Mo.)
FY 2028 Equipment and expense$0$0 or ($16,947) $0 or ($11,396) EBT Vendor Costs p. 3-4
$0
$0 or ($15,000,000
to Unknown) $0
One-time mailing p. 3-4$0$0 or ($113,500) $0Total Costs - DSS, FSD
$0
$0 or
($15,182,353)
$0 or
($105,983)
FTE Changes00 or 10 or 1ESTIMATED NET EFFECT ON
FEDERAL FUNDS$0$0$0
Estimated Net FTE Change on Federal
Funds00 or 10 or 1
FISCAL IMPACT – Local GovernmentFY 2026
(10 Mo.)
FY 2027FY 2028$0$0$0
FISCAL IMPACT – Small Business
Small business retailers would be required to reprogram point-of-sale (POS) systems to comply
with these changes.
FISCAL DESCRIPTION
This bill requires the Director of the Department of Social Services to request a waiver from the
United States Department of Agriculture to exclude candy and soft drinks, as those terms are
defined in the bill, from the definition of eligible foods under federal law governing provisions of
the Supplemental Nutrition Assistance Program. If the waiver is not granted, the Director is
required to request the waiver on an annual basis until it is granted. (§ 208.025)
This legislation is not federally mandated, would not duplicate any other program and would not
require additional capital improvements. It would require rental space. L.R. No. 2638H.01I
Bill No. HB 1222
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SOURCES OF INFORMATION
Department of Social Services
Office of Administration
Julie MorffJessica HarrisDirectorAssistant DirectorMarch 3, 2025March 3, 2025