The Squeeze: When Two Broken Systems Land on the Same Parent
By Michael Phillips | Father & Co.
A federal memo rescinded on July 20 doesn’t sound like news that touches custody court. But for a subset of parents already caught in the gap between an unenforced parenting-time order and a job market that hasn’t recovered, it’s about to become one more variable in an already unstable equation.
The Policy, Plainly
The Food and Nutrition Administration’s July 20, 2026 memo rescinds a 2024 directive that had discouraged states from disqualifying SNAP recipients over child support noncooperation or arrears. In its place, FNA reissued a May 2019 memo — first-Trump-administration guidance — reminding states of three long-standing options under the Food and Nutrition Act:
- States may deny SNAP to a custodial parent who won’t cooperate with the state Child Support Agency on paternity or support establishment — but the state can apply a good-cause exception, including when cooperation would work against the child’s interest.
- States may deny SNAP to a non-custodial parent found to have refused cooperation — with no good-cause exception available at all once “refusal” is determined.
- States may deny SNAP to either parent for any month they’re delinquent on a court-ordered support payment — unless a court has approved a delayed-payment plan, or the person is actively complying with an approved plan.
That last clause is the hinge. The rule isn’t a blanket cutoff for missed payments; it’s a cutoff for missed payments without a plan on file. Maryland already runs a plan that fits this description — the state’s own Payment Incentive Program — but as of the most recent federal data, Maryland hasn’t adopted the SNAP disqualification itself. Whether that changes now that federal discouragement is gone, and whether the state’s existing payment-plan option is proactively offered to parents before enforcement rather than after, is the reportable gap.
The rule isn’t a blanket cutoff for missed payments; it’s a cutoff for missed payments without a plan on file.
The Part That Doesn’t Show Up in the Policy Memo
None of this exists in isolation. Parents who fall behind on support are frequently the same parents fighting, unsuccessfully, for court-ordered access to their kids — and the two systems don’t talk to each other.
Parents who fall behind on support are frequently the same parents fighting, unsuccessfully, for court-ordered access to their kids — and the two systems don’t talk to each other.
A parent can be in full compliance with a custody order, be denied that access anyway, return to court for enforcement, and have the court decline to act — all while a separate agency evaluates their SNAP eligibility purely on payment history, with no mechanism to weigh whether their inability to pay is connected to a loss of stability triggered by the same conflict. The systems are built to ask “did you pay” and “did you comply,” but neither is built to ask why not, or what else is happening in that parent’s life at the same time.
The systems are built to ask ‘did you pay’ and ‘did you comply,’ but neither is built to ask why not.
This isn’t an argument that the SNAP rule causes denied parenting time, or that it’s a deliberate weapon — that’s not a claim the record supports, and Father & Co. won’t make it. The more precise, defensible failure is structural: a parent already failed by a non-enforcement system now faces a second system that treats non-payment as unwillingness by default, with no space for a parent stuck in an enforcement gap that isn’t their fault.
A parent already failed by a non-enforcement system now faces a second system that treats non-payment as unwillingness by default.
Where the Reporting Goes Next
Neither system is built to ask why a parent is in crisis before imposing another consequence.
- Which states have actually moved. As of the USDA’s 17th-edition State Options Report (data reference period October 2024), only three states had adopted any version of this disqualification: Arkansas and Mississippi apply it to noncustodial-parent noncooperation and arrearage together; Kentucky applies it to both custodial and noncustodial parents for noncooperation. Maryland is not among them as of that data — meaning the question isn’t hypothetical; it’s trackable: does the state move now that the federal discouragement is gone?
- What “cooperation” actually requires in practice. A separate federal evaluation — an eight-state Mathematica study of cooperation requirements, covering Arkansas, Idaho, Kansas, Michigan, Mississippi, Ohio, Tennessee, and West Virginia — found requiring cooperation did not meaningfully increase child support payments to SNAP households on average, and that good-cause exemptions (largely built around domestic-violence risk) were inconsistently applied by states that had them. That’s a documented federal finding, not conjecture, and it undercuts the stated rationale for the rule.
- Payment-plan access in Maryland, specifically. The state already runs a mechanism that maps almost exactly onto the rule’s escape hatch: the Payment Incentive Program, open to a noncustodial parent with a Maryland court order and household income under 225% of the federal poverty line. Twelve consecutive months of paying as ordered cuts state-owed arrears in half; twenty-four consecutive months zeroes it out. The program explicitly gives consideration for prior periods of unemployment due to no-fault termination — meaning a documented, involuntary income gap is something the state’s own criteria are built to account for, not ignore. Whether the Maryland Child Support Administration proactively tells parents this exists, versus parents having to find it themselves, is worth reporting out directly.
- First-person accounts from parents navigating arrears and denied access simultaneously — sourced, on the record where possible, anonymized where necessary.
Sources: USDA/FNS memo, “SNAP – State Policy Options Related to Custodial and Non-Custodial Parent Cooperation with State CSAs” (rescission, July 20, 2026, reissuing the May 1, 2019 memo); USDA/FNS memo of June 6, 2024 (rescinded); USDA FNS SNAP State Options Report, 17th Edition (Oct. 2024 data); Mathematica/MEF Associates, “Evaluation of Child Support Enforcement Cooperation Requirements in SNAP” (final report); Maryland Department of Human Services, Payment Incentive Program and Noncustodial Parent Services pages; New York Post, July 31, 2026.
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