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“Deemed Too Tedious:” Struggling to Make Sense of Iowa’s SNAP Restriction Waiver

Iowa’s SNAP restriction waiver went into effect on January 1, 2026. SNAP participants are now only able to use their benefits to purchase foods and beverages that are not subject to the state sales tax. While this has been branded as a “healthy eating” waiver similar to a candy and soda ban, the truth is these restrictions are much more complex and confusing. In fact, the Iowa Department of Health and Human Services (HHS) found that creating a complete list of ineligible food items was “deemed too tedious” to complete.

These restrictions do nothing to make healthy food more affordable. Instead, Iowa’s waiver is increasing stigma for SNAP participants, creating confusion at checkout counters, raising grocery prices for everyone, and harming our local economies, especially in rural areas and border counties.

Are you a SNAP participant struggling to make sense of Iowa’s new restrictions? We want to hear from you!

Creating Confusion, Stigma, and Shame

The guidelines for SNAP-eligible foods and beverages follow Iowa’s state sales tax code. This requires SNAP participants to be experts in Iowa’s sales tax code to know which items are and are not eligible. Navigating these confusing new guidelines is already creating tension and stress for SNAP participants and retail workers.

The research on stigma and public benefit programs is well-established. Increased social stigma for SNAP leads to adverse physical and mental health effects for program participants, a loss of community belonging and self-worth, and decreased program enrollment.

Despite how this waiver is being branded, Iowa’s new restrictions have less and less to do with “health” the closer you examine them. Below are some examples that highlight the complexities, inconsistencies, and nonsensical nature of Iowa’s SNAP food and beverage restrictions.

  • “Candy” is banned, unless it contains flour or requires refrigeration. Granola bars, fruit leather, yogurt-covered raisins, and barbeque-coated peanuts all fall under this definition of “candy,” and are now banned from SNAP.

  • Soft drinks and all sweetened beverages with less than 50% fruit or vegetable juice are banned. This applies to sodas of all varieties, including sugar-free and zero-calorie options, as well as other sweetened beverages like lemonade, sweet tea, Kool-Aid, Gatorade, Hi-C, Capri Sun, Hawaiian Punch—even Pedialyte.

  • While hot prepared foods were already ineligible for purchase with SNAP, Iowa’s waiver goes even further and bans cold “foods prepared for consumption.” This definition is especially difficult to navigate. Whether or not a retailer has a microwave available for use, seating, and free utensils can dictate if certain items are SNAP-eligible. For example, if a store cuts up fruit and sells it in a cup with a fork, it is considered “food prepared for consumption,” and is banned from SNAP, but when served without a fork, it is still SNAP eligible. Pre-prepared deli sandwiches, salads, and other cold prepared foods are only eligible under certain circumstances, at certain retailers. These guidelines are confusing, inconsistent, and end up punishing convenience rather than promoting “health” since they are based on our taxable food and beverage list and not created to actually support nutrition. 

Harming Iowa’s Local Economies

  • One in three SNAP participants in Iowa lives in a county that borders another state.
    Nearly 88,000 Iowans on SNAP live in a border county—1 out of every 3 SNAP participants in the state. Collectively, those Iowans receive a total of $15 million in SNAP benefits every month, generating roughly $23 million in local economic activity through SNAP’s economic multiplier. All of this money for our local economies is at risk of shifting to neighboring states.

Adding Costs for Retailers and Consumers

  • SNAP restriction waivers increase costs for retailers and consumers alike. A recent report found SNAP restrictions are likely to cost retailers $1.6 billion in upfront costs and $759 million in annual ongoing costs to implement across multiple states. As a direct result of this, “consumers stand to ultimately see higher food prices and reduced purchasing power.”

  • 61% of SNAP recipients say affordability is the main barrier to healthier eating. The cost of groceries has increased by nearly 30% since 2020, despite declining inflation. Putting these restrictions in place without giving folks the resources to afford healthier foods will only increase food insecurity in our state.  
  • Iowa’s waiver could cause some retailers to opt out or not qualify for the SNAP program.  If retailers opt out of SNAP due to added costs or are disqualified due to misinterpreting Iowa’s restrictions, this will only increase the number of food deserts across our state. Retailers have been given a “two strike” policy, with an involuntary expulsion from the program occurring on the second offense.

The Nitty-Gritty Details of Iowa’s SNAP Restriction Waiver

The state of Iowa submitted a formal SNAP restriction waiver request to USDA FNS on April 1, 2025, and it was officially approved on May 22, 2025. On December 12, 2025, USDA FNS sent an “amended approval letter” to Iowa HHS to clarify that in addition to soda and candy, Iowa would also be restricting certain prepared foods from SNAP.

Iowa’s waiver with USDA FNS is for a period of 2 years, from January 1, 2026 to December 31, 2027, with “the option to request three annual extensions thereafter for a total Project period not to exceed 5 years.” Any request for extension must be submitted by June 30, 2027.

Prior to Iowa implementing the SNAP restrictions on January 1, 2026, the state was required to meet a number of terms and conditions of the waiver, including submitting:

  • a finalized proposed budget;

  • a finalized communications plan for SNAP-authorized retailers, including providing a designated centralized communication resource and dedicated point-of-contact for SNAP-authorized retailers;

  • a finalized communications plan for SNAP households, and updating the Iowa HHS SNAP webpage to provide information about the waiver to SNAP households;

  • a finalized evaluation plan defining health outcomes and behaviors, including how the state defines success of the waiver and a detailed description of all data points and metrics that the state will be collecting and how they will be analyzed;

  • copies of completed contracts between the state and any other entities (including Altarum Institute, Conduent, and Iowa State University Extension & Outreach) the state is working with to evaluate the waiver; and

  • a finalized compliance and monitoring plan for SNAP-authorized retailers.

Iowa does appear to have submitted the required documents to USDA FNS, given that the state did move ahead with implementation, but these documents provide little additional details and lack specificity. For example, the state’s finalized “compliance and monitoring plan” for SNAP-authorized retailers is a single-page, 246-word document.

In addition to these initial items, Iowa is also required to submit the following information to USDA FNS on a quarterly basis throughout the duration of the waiver: 

  • quarterly costs to the state associated with the waiver;

  • baseline and monthly data collection for out of state transactions for all states that border Iowa and total amount of SNAP dollars spent out of state;
  • total monthly amount of SNAP client hearings filed related to the waiver; and

  • total monthly number of compliments and complaints received related to the waiver, and a qualitative summary of comments received from each of the following groups:
    • SNAP-authorized retailers
    • SNAP households
    • advocacy, community, or retailer association groups.

The Iowa Hunger Coalition will be working to stay on top of these quarterly reports and sharing information on how Iowa’s SNAP restrictions are impacting households, retailers, and local economies.

The Future of SNAP Restrictions in Iowa: What Comes Next?

On January 13, 2026, less than two weeks into Iowa’s SNAP waiver going into effect, Governor Kim Reynolds called for making the restrictions permanent.

Iowa was one of the first states in the country to refocus two federal food assistance programs on the reason they were created: to help low-income families afford nutritious foods.

With USDA’s approval, SNAP and Summer EBT in Iowa will help families purchase fresh produce, grains, meat, and dairy—but candy, sweets, and soft drinks are no longer covered.

This year, I’m asking the legislature to make sure our state always maintains a nutrition first focus for these programs by directing the Iowa HHS to maintain a federal waiver going forward.

Governor Kim Reynolds, Condition of the State Address, January 13, 2026

We have not yet seen any bill language introduced, but are very concerned that only two weeks into the waiver, Iowa’s Governor is already attempting to make these changes permanent.

For one, it’s not clear that Iowa would even be legally allowed to do this. The state’s agreement with USDA clearly states that the waiver is not to exceed 5 years. The entire reason USDA allowed states like Iowa to put this waiver into place is to study whether or not this is an effective policy. The Governor’s desire to codify this waiver before ever exploring the results and outcomes could call into question the validity of the state’s waiver with USDA.

We’ve also seen previous attempts to use “contingent” language to tie these food restrictions to the state’s investment in Double Up Food Bucks. Would the Governor’s bill attempt similar measures with SNAP and Summer EBT? This could hold these vital programs hostage if we were to see changes on the federal level, whether that be nationwide restrictions or a change in administration at USDA.

For now, we have until June 30, 2027 to advocate against extending Iowa’s SNAP waiver and instead returning to normal purchasing guidelines. But we need your help!

What Can SNAP Participants Do?

  • Submit your feedback on Iowa’s SNAP waiver directly to Iowa HHS:
  • Share your SNAP story with us:
  • Share your experience directly with your State Representative and Senator:

What Can Retailers Do?

What Can Advocates Do?

  • Submit your feedback on Iowa’s SNAP restriction waiver and the impact you are seeing first-hand through Iowa HHS’s Contact Form.

  • Share the impact of these changes with your State Representative and Senator: