Legislative and Policy Analysis

Section 10302: Base acres

Executive Summary

Section 10302 changes the farm commodity safety net by allowing USDA to add up to 30 million additional base acres to eligible farms beginning with the 2026 crop year.[1] Base acres matter because Agriculture Risk Coverage and Price Loss Coverage payments are generally calculated from historical base acres, not simply from what a farmer plants in the current year.[2]

This section does not provide a fixed dollar appropriation. Instead, it expands the acreage base that can generate future mandatory commodity program payments. That means the budget effect will show up indirectly through ARC and PLC outlays administered by USDA’s Farm Service Agency and financed through the Commodity Credit Corporation.

The practical result is a one-time administrative reset: USDA must identify eligible farms, notify owners, allow opt-outs and appeals, allocate acres among covered commodities, assign payment yields, and apply a pro-rata reduction if eligible acres exceed the 30 million acre national cap.[1]

What Section 10302 Actually Does

Section 10302 amends Section 1112 of the Agricultural Act of 2014. It extends the relevant base-acre authority from 2023 to 2031 and adds a new subsection for “Additional Base Acres.”[1]

The core financial value in the section is not a direct dollar amount. It is a statutory expansion of the acreage eligible to support future farm program payments.

A farm is generally eligible if its 2019-2023 five-year average of planted and prevented-planted covered commodity acreage, plus a limited amount of eligible noncovered commodity acreage, exceeds its covered commodity base acres as of September 30, 2024.[1] Farms with no recent covered commodity plantings are excluded.[1]

The section also requires USDA to allocate additional base acres among covered commodities planted on the farm during 2019-2023. If total eligible acres nationwide exceed 30 million acres, USDA must reduce allocations across the board on a pro-rata basis so the final national allocation equals 30 million acres.[1]

For PLC purposes, USDA must assign payment yields to the new base acres. If the farm already has a payment yield for the covered commodity, that yield applies. If not, USDA uses the county average yield or another statutory yield-setting method.[1]

USDA has announced that eligible landowners have from June 1 through August 31, 2026, to review and consider base-acre increases for farms enrolled in ARC and PLC.[3]

Legislative Mechanism

Section 10302 works by amending the existing commodity title framework rather than creating a new standalone grant or payment program. It changes the eligibility architecture for ARC and PLC by expanding the number of acres that may be treated as base acres.

The mechanism has five main parts:

1. Statutory extension. The section extends base-acre-related authority through the 2031 crop year.[1]

2. Eligibility calculation. USDA compares a farm’s recent 2019-2023 planting and prevented-planting history against its existing covered commodity base acres as of September 30, 2024.[1]

3. Administrative notice and appeals. USDA must notify eligible owners and explain eligibility and appeal rights.[1]

4. Commodity allocation. Additional acres are assigned among covered commodities based on the farm’s 2019-2023 covered commodity planting history.[1]

5. Payment-yield assignment. USDA establishes PLC payment yields for the newly allocated base acres.[1]

The section does not require a farmer to plant the covered commodity in the current year in order for PLC or ARC-CO payments to be connected to that commodity’s base acres. USDA’s ARC/PLC materials explain that PLC and ARC-CO payments are not dependent on planting the covered commodity or planting the applicable base crop on the farm.[2]

Expenditure Tracking and Reporting Protocol

Section 10302 creates a federal financial flow because additional base acres can increase future ARC and PLC payments when statutory payment conditions are met. The section itself does not create a separate public reporting system for Section 10302 dollars, so section-specific outlays may be difficult to isolate from broader commodity program payments.

Likely tracking sources include:

Reporting is likely to be mixed. USDA can track base-acre allocations at the farm and commodity level internally, but public datasets may show ARC and PLC data by program year, county, commodity, or payment category rather than isolating “Section 10302” as a separate spending line.

Because ARC and PLC are mandatory farm support programs, the expenditure pathway is best understood as a program-payment flow rather than a grant or procurement flow:

Section 10302 statutory authority
        |
        v
USDA Farm Service Agency identifies eligible farms
        |
        v
Owners receive notice, opt-out option, and appeal rights
        |
        v
FSA allocates additional base acres
        |
        v
FSA assigns covered commodities and PLC payment yields
        |
        v
Farms enroll in ARC or PLC
        |
        v
Market prices or revenues determine whether payments trigger
        |
        v
Commodity Credit Corporation finances eligible payments
        |
        v
USDA, Treasury, OMB, CBO, GAO, IG, and Congress track or review results
        |
        v
Public visibility is partial and often aggregated

The strongest public tracking will likely be through USDA ARC/PLC program data, CBO baseline materials, USDA budget materials, and oversight reports. The weakest public tracking will be farm-level allocation detail, because individual farm records and payment calculations may not be fully public.

Day-to-Day Government Process Changes

Section 10302 requires USDA and FSA county offices to do substantial implementation work.

First, FSA must use historical planting and prevented-planting records from 2019 through 2023 to identify farms that may qualify. That likely requires reconciling crop acreage reports, farm records, base-acre records, ownership changes, and prior-owner planting histories.

Second, USDA must send notices to eligible farm owners. The notice must tell owners that allocation is occurring, explain eligibility, and describe how to appeal an ineligibility determination.[1]

Third, owners must decide whether to accept or decline additional base acres. The statute makes the allocation automatic unless the owner opts out within 90 days after receiving USDA notice.[1]

Fourth, FSA must handle appeals. That adds a casework layer for farms that dispute eligibility, acreage calculations, ownership history, treatment of prevented planting, treatment of noncovered commodity acres, or commodity allocation.

Fifth, FSA must assign new base acres among covered commodities and establish PLC payment yields. Those determinations affect future ARC and PLC payment calculations.

Finally, if eligible acres exceed the 30 million acre cap, USDA must apply a national pro-rata reduction. That requires USDA to complete or estimate the national eligibility pool before finalizing allocations.

Effects on Consumers

The direct consumer impact is limited. Section 10302 does not change SNAP benefits, grocery eligibility rules, retail food prices, labeling, or consumer-facing nutrition programs.

Indirect effects are possible. By expanding the acreage base for commodity support, the section may increase farm income support for some producers when ARC or PLC payments are triggered. That can stabilize some farm businesses during low-price or low-revenue years, but commodity program payments are not designed as a direct grocery-price reduction tool.

Consumers may see little visible change because ARC and PLC payments generally flow to producers and land interests through farm program administration rather than through retail food channels.

Effects on Businesses

The business impact is concentrated in agriculture.

Farms that qualify for additional base acres may receive larger future ARC or PLC payments when payment conditions are triggered. This can improve cash-flow stability, support operating loans, and affect landowner-tenant negotiations.

The section may especially matter for farms whose recent covered commodity and eligible noncovered commodity acreage exceeds their existing base acres. Analysts at farmdoc note that the 30 million acre cap is likely to be exceeded, which would require pro-rating, and that Plains and Midwest states may add large numbers of new base acres.[7]

Agricultural lenders, crop advisors, accountants, farm managers, and attorneys may see increased demand for help reviewing FSA notices, acreage history, appeals, payment-yield questions, and lease impacts.

The provision may also create distributional differences among farms. Farms that already have base acres closely aligned with planted acres may gain less than farms with larger gaps between recent planting history and current base acres.[7]

Environmental and Climate Impact

Section 10302 does not create a conservation program, climate-smart agriculture program, emissions standard, land retirement program, or environmental compliance program.

The environmental impact is therefore indirect. Because ARC and PLC payments are tied to base acres rather than necessarily to current-year planting, the provision does not directly command farmers to plant more covered commodities. USDA materials state that PLC and ARC-CO payments are not dependent on planting the covered commodity or planting the applicable base crop on the farm.[2]

However, expanding base acres can still influence land economics. Higher expected support payments may affect land values, rental negotiations, and producer risk calculations. Over time, that could influence cropping patterns, especially where added base acres make commodity program participation more valuable.

The climate impact is uncertain and likely hard to isolate. Section 10302 does not include measurable greenhouse gas targets, soil carbon incentives, water-quality requirements, or climate-resilience reporting. Any environmental effect would depend on how the expanded commodity safety net interacts with producer decisions, conservation compliance rules, crop insurance, market prices, weather risk, and local land-use conditions.

Impact Summary

Section 10302 is a major commodity-program implementation provision. It does not appropriate a fixed dollar amount, but it expands the acreage foundation for future ARC and PLC payments by up to 30 million acres nationwide.

The largest operational burden falls on USDA’s Farm Service Agency, which must identify eligible farms, issue notices, manage opt-outs and appeals, allocate acres, assign payment yields, and potentially apply a national pro-rata reduction.

The largest financial benefit is likely to flow to eligible farms and land interests that gain new base acres and later receive ARC or PLC payments. The largest transparency limitation is that public reporting may show broader ARC and PLC program payments rather than cleanly isolating the budgetary effect of Section 10302 alone.

For consumers, the impact is mostly indirect. For farm businesses, lenders, and landowners, the provision may be significant. For environmental and climate outcomes, the effect is indirect, uncertain, and not separately tracked by the statute.

Key References and Sourcing

[1] GovInfo, “H.R. 1, 119th Congress, Section 10302, Base acres,” statutory text for additional base acres, eligibility, allocation, pro-rata reduction, payment yields, and new-owner treatment, https://www.govinfo.gov/content/pkg/BILLS-119hr1eas/html/BILLS-119hr1eas.htm.

[2] USDA Farm Service Agency, “Agriculture Risk Coverage and Price Loss Coverage,” ARC/PLC fact sheet, payment acres and payment mechanics, https://www.fsa.usda.gov/sites/default/files/2025-09/FSA_ARC%20%26%20PLC_3pg_Fact%20Sheet-SEPT%202025_final.pdf.

[3] USDA Farm Service Agency, “USDA Announces Base Acre Increase Opportunity for Agriculture Risk and Price Loss Coverage Safety Net Programs,” implementation announcement, https://www.fsa.usda.gov/news-events/news/05-26-2026/usda-announces-base-acre-increase-opportunity-agriculture-risk-price.

[4] USDA Farm Service Agency, “ARC and PLC Data,” program-year data portal for payment rates, prices, yields, and base-acre information, https://www.fsa.usda.gov/resources/programs/arc-plc/program-data.

[5] USDA, “Commodity Credit Corporation,” description of CCC and principal programs funded by CCC, https://www.usda.gov/farming-and-ranching/resources-small-and-mid-sized-farmers/commodity-credit-corporation.

[6] Congressional Budget Office, “Estimated Budgetary Effects of Public Law 119-21, to Provide for Reconciliation Pursuant to Title II of H. Con. Res. 14,” enacted-law budget estimate, https://www.cbo.gov/publication/61570.

[7] farmdoc daily, “The New Base Acre Provisions in the 2025 Farm Bill,” agricultural policy analysis of new base-acre provisions, proration, state distribution, and implementation questions, https://farmdocdaily.illinois.edu/2025/07/the-new-base-acre-provisions-in-the-2025-farm-bill.html.

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Legislative and Policy Analysis

Section 10301: Effective reference price; reference price

Executive Summary

Section 10301 changes the commodity-program price floors used in federal farm safety-net programs. It raises statutory reference prices for covered commodities beginning with the 2025 crop year, changes the effective-reference-price formula by replacing 85 percent with 88 percent of the five-year Olympic average market-year price, and creates a future 0.5 percent annual reference-price escalator beginning with the 2031 crop year, capped at 113 percent of the 2025 statutory reference price.[1]

This section does not create a standalone appropriation with a fixed dollar total. Instead, it changes formulas that can increase mandatory farm-program outlays when commodity prices or county revenues fall enough to trigger Price Loss Coverage or Agriculture Risk Coverage payments.[2] The practical effect is to make PLC and ARC support more likely, or larger, for covered commodity producers in low-price or low-revenue years.

What Section 10301 Actually Does

Section 10301 amends section 1111 of the Agricultural Act of 2014, codified at 7 U.S.C. 9011. It makes two core changes.

First, it changes the effective-reference-price formula. Beginning with the 2025 crop year, the effective reference price may reflect 88 percent of the Olympic average of the five most recent market-year average prices, instead of 85 percent under prior law.[1] USDA’s Economic Research Service explains that effective reference prices are a key component for both PLC payment rates and ARC-CO benchmark revenues.[2]

Second, it replaces the statutory reference-price schedule for covered commodities beginning with the 2025 crop year.[1] These are not appropriated amounts; they are per-unit price floors used in farm-program formulas.

Beginning with the 2031 crop year, each covered commodity’s reference price increases by multiplying the prior crop year’s reference price by 1.005, but no covered commodity’s reference price may exceed 113 percent of the reference price listed for that commodity in the new statutory schedule.[1]

Because PLC payments are triggered when the effective price falls below the effective reference price, higher reference prices can increase federal support when market prices weaken.[3] For ARC-CO, USDA ERS states that the effective reference price is also used in benchmark revenue calculations, so the change can affect revenue-based support as well.[2]

Legislative Mechanism

Section 10301 is a formula amendment, not a grant program or agency operating appropriation. It changes the definitions that USDA uses to administer commodity-program payments.

The mechanism is:

1. Amend the effective-reference-price formula in 7 U.S.C. 9011(8)(B)(ii).
2. Replace the statutory reference-price schedule in 7 U.S.C. 9011(19).
3. Apply the new schedule beginning with the 2025 crop year.
4. Add an annual 0.5 percent reference-price escalator beginning with the 2031 crop year.
5. Cap each commodity’s reference price at 113 percent of the new statutory reference price.[1]

The policy effect is to increase the federal safety-net floor for covered commodity producers. It does not guarantee a payment every year. Payments still depend on market-year average prices, loan rates, base acres, payment yields, ARC or PLC election rules, and other eligibility limits.[2]

Expenditure Tracking and Reporting Protocol

Section 10301 affects federal financial flows through USDA commodity programs, primarily Price Loss Coverage and Agriculture Risk Coverage. The administering agency is USDA’s Farm Service Agency, and the likely financing source is the Commodity Credit Corporation, which traditionally funds major farm commodity support programs.

Public tracking is likely to be partially visible but not cleanly isolated by Section 10301 alone. Payments may appear in USDA Farm Service Agency program data, USDA budget execution materials, Treasury outlay reporting, USDA financial statements, and CBO cost estimates. However, because Section 10301 changes payment formulas inside broader ARC and PLC programs, public datasets may not separately identify the incremental payment amount attributable only to the reference-price change.

Reporting is likely to work through routine USDA and federal budget channels. Producers report acreage, ownership, and program participation information to FSA. USDA calculates program eligibility and payment amounts after market-year data and program parameters are available. USDA and Treasury record outlays. CBO estimates budget effects for legislation and baselines. Oversight can occur through USDA financial reporting, USDA Inspector General work, GAO reviews, and congressional oversight.

flowchart TD
    A[Section 10301 formula change] --> B[USDA FSA updates ARC and PLC rules]
    B --> C[Commodity prices and farm records]
    C --> D[Payment calculations]
    D --> E[PLC payments]
    D --> F[ARC payments]
    E --> G[Commodity Credit Corporation outlays]
    F --> G
    G --> H[Treasury and USDA accounting]
    H --> I[Budget execution reports]
    H --> J[USDA financial statements]
    H --> K[CBO estimates]
    H --> L[Oversight reviews]
    I --> M[Public visibility mixed]
    J --> M
    K --> M
    L --> M

The key limitation is attribution. A farmer may receive an ARC or PLC payment that reflects several statutory changes at once, including reference prices, effective reference prices, ARC formulas, base acres, producer elections, market prices, and yields. Therefore, section-specific fiscal effects may be clear in budget estimates but less clear in award-level or producer-level public data.

Day-to-Day Government Process Changes

For USDA and FSA, Section 10301 requires administrative updates to commodity-program software, producer notices, payment calculators, handbook guidance, county-office training, and public-facing ARC and PLC materials. FSA must apply the new reference-price schedule beginning with the 2025 crop year and prepare systems for the 2031 escalator.

For county FSA offices, the change means more producer questions about whether PLC or ARC will be more favorable under the new reference prices. USDA’s public ARC and PLC materials already explain that PLC payments are triggered when market-year average prices fall below the effective reference price and that these programs protect against low prices or revenue shortfalls.[3]

For producers, the practical administrative change is that farm-program planning becomes more sensitive to the new reference prices. Producers and advisers will compare ARC and PLC outcomes using updated commodity-specific floors, updated effective reference prices, and expected market-year prices. University farm-policy analysts have projected that higher reference prices can materially increase payments for corn and soybeans in some scenarios, though actual payments depend on final prices and yields.[4]

Effects on Consumers

Section 10301 primarily affects producers, not consumers directly. It does not create a consumer rebate, change SNAP eligibility, change retail food labeling, or regulate grocery prices.

Consumer effects are indirect. Higher farm-program support may help stabilize income for producers of major covered commodities, which can support continuity in production during periods of low prices. However, farm-program payments are tied to base acres and statutory formulas, not directly to grocery-store prices. The section is therefore unlikely to produce immediate, transparent consumer price changes.

There may also be distributional effects. Taxpayers finance mandatory commodity-program outlays when payments are triggered. CBO estimated that Public Law 119-21 as a whole would increase the unified budget deficit by $3.4 trillion over fiscal years 2025 through 2034, though that estimate is for the entire law and not Section 10301 alone.[5]

Effects on Businesses

The most direct business effects fall on farms producing covered commodities, agricultural lenders, crop advisers, grain merchandisers, and businesses tied to row-crop regions.

For covered commodity farms, higher statutory reference prices and a higher effective-reference-price escalator can improve downside revenue protection when market prices fall. That can affect cash-flow planning, operating-loan underwriting, land-rent negotiations, and risk-management decisions. Farmdoc analysis found that statutory reference prices increased from 2018 levels for all program crops through 2030, including corn rising from $3.70 to $4.10 per bushel, soybeans from $8.40 to $10.00 per bushel, and wheat from $5.50 to $6.35 per bushel.[4]

Agricultural lenders may treat the higher safety-net floor as one factor in repayment-risk analysis, especially for farms with large covered-commodity base acres. Landlords and tenants may also factor expected ARC or PLC payments into rent negotiations, though actual payment timing can lag the crop year.

Agribusinesses serving covered-commodity producers could see some stabilizing benefit if farm income support helps preserve input purchases, equipment maintenance, storage use, and local farm spending during low-price periods. But the benefits are uneven: farms without eligible base acres, specialty-crop producers, livestock-only operations, and businesses outside covered commodity regions receive less direct support from this section.

Environmental and Climate Impact

Section 10301 does not directly amend conservation compliance, climate programs, pesticide rules, nutrient-management standards, crop-insurance conservation requirements, or greenhouse-gas reporting. Its environmental effects are therefore indirect.

Because ARC and PLC payments are generally tied to base acres rather than requiring current-year planting of the covered commodity, the provision is less directly production-coupled than a payment tied strictly to current planted acres. That reduces, but does not eliminate, potential land-use incentives. Higher commodity-program support can still influence farm financial expectations, credit conditions, land rents, and the relative attractiveness of maintaining land in covered-commodity agriculture.

The climate impact is mixed and difficult to isolate. On one hand, stronger income support may help farms absorb weather and market shocks. On the other hand, higher price floors for covered commodities may reinforce existing commodity-crop systems unless paired with conservation, soil-health, or climate-resilience incentives elsewhere. Section 10301 itself contains no dedicated environmental guardrail or climate reporting mechanism.

Impact Summary

Section 10301 is a major farm safety-net formula change. It raises statutory reference prices, increases the effective-reference-price formula from 85 percent to 88 percent of the five-year Olympic average market-year price, and creates a 2031 forward escalator capped at 113 percent of the new statutory reference price.

The largest direct beneficiaries are covered-commodity producers with eligible base acres when market prices or revenues are low enough to trigger ARC or PLC payments. The main government-process effect is administrative: USDA must update program formulas, producer guidance, payment systems, budget estimates, and reporting. The main fiscal effect is not a fixed appropriation but potentially higher mandatory outlays through ARC and PLC when payment conditions are met.

Public visibility will be uneven. ARC and PLC payments may be visible in aggregate USDA and budget data, but the incremental effect of Section 10301 alone may be difficult to isolate from other commodity-title changes and market conditions.

Key References and Sourcing

[1] GovInfo, “H.R. 1, 119th Congress, Engrossed Amendment, Section 10301,” https://www.govinfo.gov/content/pkg/BILLS-119hr1eas/html/BILLS-119hr1eas.htm.

[2] USDA Economic Research Service, “Title I: Crop Commodity Program Provisions,” effective reference price and ARC/PLC explanation, https://www.ers.usda.gov/topics/farm-economy/farm-commodity-policy/title-i-crop-commodity-program-provisions.

[3] USDA Farm Service Agency, “Agriculture Risk Coverage (ARC) & Price Loss Coverage (PLC),” program description and payment triggers, https://www.fsa.usda.gov/resources/income-support/arc-plc.

[4] farmdoc daily, “Impacts of the Commodity Title Changes Under the One Big Beautiful Bill Act (OBBBA) for Midwestern Farms in 2025,” reference-price and payment-impact analysis, https://farmdocdaily.illinois.edu/2025/07/impacts-of-the-commodity-title-changes-under-the-one-big-beautiful-bill-act-obbba-for-midwestern-farms-in-2025.html.

[5] Congressional Budget Office, “Estimated Budgetary Effects of Public Law 119-21, to Provide for Reconciliation Pursuant to Title II of H. Con. Res. 14, Relative to CBO’s January 2025 Baseline,” enacted-law budget estimate, https://www.cbo.gov/publication/61570.

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Legislative and Policy Analysis

Section 10201: Rescission of amounts for forestry

Executive Summary

Section 10201 rescinds unobligated balances from selected forestry appropriations originally enacted in the Inflation Reduction Act of 2022. It does not repeal the underlying forestry statutes or programs. Instead, it cancels remaining unspent budget authority from specified portions of four Inflation Reduction Act forestry provisions: Forest Service environmental review and old-growth forest work, several non-federal forest landowner grant categories, Urban and Community Forestry grants, and USDA forestry administrative costs.[1]

The affected Inflation Reduction Act appropriations originally totaled up to $2.2 billion across the targeted lines, but the operative rescission applies only to balances that remained unobligated when Section 10201 took effect.[2] CBO estimated the enacted provision would reduce budget authority by $150 million and reduce outlays by $150 million over fiscal years 2025 through 2034.[3]

The environmental and climate impact is negative. The section reduces funding that would otherwise support forest resilience, urban tree canopy, carbon sequestration, old-growth and mature forest work, environmental review capacity, and climate-related forestry assistance. The magnitude depends on which balances were unobligated at enactment, but the direction is not neutral: the section narrows the financial pathway for climate, conservation, and community forestry work.

What Section 10201 Actually Does

Section 10201 is a rescission provision. It identifies particular appropriations made by Public Law 117-169 and cancels the unobligated balances of those appropriations.[1] The word “unobligated” matters: the section does not automatically claw back funds already legally obligated through grants, cooperative agreements, contracts, or other binding federal commitments.

The targeted Inflation Reduction Act forestry lines are:

The total original appropriation authority in the targeted lines was up to $2.2 billion. However, because Section 10201 rescinds only unobligated balances, the actual federal savings depend on how much of those lines had not yet been obligated by the date of enactment. CBO’s enacted-law estimate shows a $150 million reduction in budget authority in fiscal year 2025 and a $150 million reduction in estimated outlays over the 2025-2034 window.[3]

This means the legal scope of the section is broad in program categories but limited by timing. A program line may appear in the rescission list, yet previously obligated awards under that line may continue unless separately cancelled under other legal authority. Planned awards, future grant rounds, administrative work, and implementation support that had not yet reached legal obligation are the most vulnerable.

Legislative Mechanism

Section 10201 works by referencing prior appropriations in Public Law 117-169 rather than rewriting each underlying forestry program. The mechanism is:

1. Identify specific Inflation Reduction Act appropriations by section and paragraph.
2. Rescind unobligated balances from those appropriations.
3. Leave already obligated funds outside the automatic rescission.
4. Leave the underlying program authorities generally intact, unless they depend on the rescinded balances for continued activity.

The section targets the funding stream, not the entire policy architecture. For example, the Urban and Community Forestry Assistance program continues to exist as a statutory and administrative program, but the unobligated portion of the $1.5 billion Inflation Reduction Act infusion is cancelled.[2] Similarly, Forest Service NEPA capacity and old-growth inventory work may continue through other appropriations or already obligated funds, but the specified remaining Inflation Reduction Act balances are removed.

Day-to-day implementation will therefore depend on USDA and Forest Service budget execution records: which awards were obligated, which planned awards were pending, which agreements were signed, and which administrative funds remained available but unused.

Expenditure Tracking and Reporting Protocol

The affected funds are federal financial flows administered mainly through USDA and the Forest Service. They include direct agency spending, competitive grants, cooperative agreements, landowner-support grants, and administrative funds. The likely tracking sources include Treasury account data, OMB apportionment documents, USDA and Forest Service budget execution records, USAspending.gov award data, grant records, agency financial reports, Inspector General audits, GAO reviews, and congressional oversight materials.

The relevant administering agency is USDA, primarily the Forest Service. The relevant implementation streams include National Forest System work, State and Private Forestry programs, Urban and Community Forestry grants, landowner-support grants, and USDA administrative accounts.

Because Section 10201 cancels only unobligated balances, the critical tracking question is not merely the amount originally appropriated. It is whether a particular dollar had already been obligated before enactment. Public award-level data may show grants or cooperative agreements that moved forward, but unobligated balances, internal administrative reserves, and rescission accounting are more likely to appear in agency budget execution and apportionment records than in a clean public project list.

Section 10201 does not create a dedicated public rescission dashboard. CBO provides a clear enacted-law score for budget authority and outlays, but project-level visibility is likely mixed: clear for some grants already posted to USAspending.gov, delayed or aggregated for agency budget execution, and difficult to isolate for administrative funds or planned awards that were never obligated.[3]

flowchart TD
    A[Statutory rescission] --> B[USDA and Forest Service identify unobligated balances]
    B --> C[OMB and Treasury adjust budget authority controls]
    C --> D[USDA budget execution updates accounts and plans]
    D --> E[Implementation effects]

    E --> F[Planned grants reduced or cancelled]
    E --> G[Internal agency work scaled back]
    E --> H[Existing obligated awards generally continue]

    F --> I[Tracking and oversight]
    G --> I
    H --> I

    I --> J[CBO budget estimate]
    I --> K[OMB apportionment records]
    I --> L[Treasury and USDA financial reporting]
    I --> M[USAspending.gov award data where awards exist]
    I --> N[USDA Inspector General GAO and congressional oversight]

    J --> O[Public visibility mixed]
    K --> O
    L --> O
    M --> O
    N --> O

    O --> P[Award level data may be visible but unobligated rescissions may be aggregated]

OMB apportionment records are relevant because apportionments are OMB-approved plans for using budgetary resources and are publicly posted after approval.[4] USAspending.gov is relevant for award-level visibility where grants, cooperative agreements, or contracts were actually awarded, but it may not show cancelled plans that never became reportable awards.[5]

Day-to-Day Government Process Changes

For USDA and the Forest Service, Section 10201 changes budget execution more than program design. Staff must determine which balances in the listed appropriations were obligated, which were unobligated, and which planned actions can no longer proceed using those funds.

Likely process changes include:

The biggest administrative distinction is between “planned” and “obligated.” Communities or organizations that had submitted applications, received informal encouragement, or anticipated future funding are in a weaker position than recipients with signed award documents. That distinction can produce uneven local results: some communities may keep existing awards, while similarly situated communities that were later in the queue may lose access to comparable support.

Effects on Consumers

The direct consumer effect is limited because Section 10201 does not change household eligibility rules, taxes, utility rates, or consumer product standards. The main consumer-facing impacts are indirect and local.

Residents in communities expecting Urban and Community Forestry projects could see fewer or slower tree planting, urban heat mitigation, stormwater, shade, public-health, and neighborhood greening projects if funds were not obligated before the rescission. USDA describes the Urban and Community Forestry Inflation Reduction Act grants as supporting tree planting, urban forest planning and management, and related activities, with more than $1 billion announced for grants to community organizations, governments, tribes, nonprofits, public institutions, and related entities.[6]

Consumers living near national forests may also experience indirect effects if reduced environmental review capacity slows some forest restoration, old-growth inventory, wildfire-risk reduction planning, or forest resilience work. Consumers in hotter urban neighborhoods may face a more immediate community-level effect if expected urban canopy projects are reduced, because trees and urban forests can affect shade, heat exposure, stormwater absorption, and local air quality.

The consumer impact will vary sharply by location and by whether projects were already obligated. The section does not create a uniform household cost, but it can reduce the availability of local environmental and resilience benefits that consumers experience through parks, streets, schools, neighborhoods, and nearby forests.

Effects on Businesses

The provision can affect several business categories:

Businesses with existing signed federal awards may continue under those agreements. Businesses hoping to compete for future rounds of funding may face fewer opportunities. The impact is especially relevant for nurseries, arborists, forestry service providers, restoration contractors, environmental consultants, and organizations that scaled staffing or project pipelines around expected Inflation Reduction Act forestry implementation.

Environmental and Climate Impact

Bottom-line characterization: negative. Section 10201 reduces funding for climate, conservation, environmental review, forest resilience, carbon sequestration, urban forestry, and environmental-justice-adjacent community greening work. The magnitude depends on which balances were unobligated at enactment, but the direction is materially negative because the section removes financial capacity from programs designed to improve forest and community environmental outcomes.

The immediate legal effect is a rescission of unobligated balances. The section does not itself approve logging, development, mining, roadbuilding, or fossil-fuel extraction. It also does not repeal NEPA, the Urban and Community Forestry Assistance program, or Forest Service authorities for old-growth and mature forest work. Those safeguards and program authorities remain in place.

That legal caveat should not neutralize the environmental assessment. Section 10201 changes the baseline by making climate and conservation forestry work less funded than it otherwise would have been. It makes future or pending projects harder to carry out where they had not yet been obligated. The reduced funding pathway can affect the following environmental categories:

The reasonably foreseeable implementation effect is reduced or delayed project activity in places where awards were not yet obligated. That can mean fewer trees planted, fewer community forestry plans implemented, reduced technical assistance for underserved forest landowners, reduced participation in forest carbon or resilience markets, and less dedicated administrative capacity for USDA forestry implementation.

The contingent effects depend on later agency, state, local, tribal, nonprofit, and private-sector decisions. Some projects may proceed with already obligated funds or replacement funding. Others may be scaled down, delayed, or never awarded. The uncertainty is about magnitude and geography, not the direction of impact.

Existing environmental safeguards remain formally intact, but the section reduces funding for work that helps agencies, communities, and landowners use those safeguards and programs effectively. Reduced NEPA support can constrain planning capacity. Reduced old-growth and mature forest funding can slow inventory or protection work. Reduced urban forestry and landowner assistance can weaken the practical ability of local communities and private landowners to implement climate-beneficial forestry practices.

Impact Summary

Section 10201 is a targeted forestry funding rescission. It does not abolish USDA forestry programs, but it cancels unobligated Inflation Reduction Act balances in selected forestry accounts. The original targeted funding lines totaled up to $2.2 billion, while CBO estimated the actual enacted budget authority reduction at $150 million.[2][3]

The section’s main impact is on future or pending implementation rather than on awards already legally obligated. It may reduce future grant availability for urban forestry, private forest resilience, landowner climate-market participation, carbon-sequestration practices, old-growth inventory and protection, environmental review capacity, and USDA forestry administration.

The environmental and climate impact is negative because the section rescinds funding that would otherwise support climate resilience, carbon sequestration, urban tree canopy, old-growth and mature forest work, and community-level environmental benefits. The harm is contingent in timing and location, but reasonably foreseeable and cumulative where planned grants, administrative capacity, or landowner assistance are reduced before obligation.

Public tracking will be clearest through CBO scoring and award-level data where awards exist, but harder to isolate for cancelled plans, internal agency work, and unobligated balances that never became public awards.

Key References and Sourcing

[1] Public Law 119-21, “Sec. 10201. Rescission of amounts for forestry,” https://www.govinfo.gov/content/pkg/PLAW-119publ21/pdf/PLAW-119publ21.pdf.

[2] Public Law 117-169, “Subtitle D—Forestry,” sections 23001, 23002, 23003, and 23005, https://www.govinfo.gov/content/pkg/PLAW-117publ169/pdf/PLAW-117publ169.pdf.

[3] Congressional Budget Office, “Estimated Budgetary Effects of Public Law 119-21, to Provide for Reconciliation Pursuant to Title II of H. Con. Res. 14, Relative to CBO’s January 2025 Baseline,” and accompanying section-by-section workbook, https://www.cbo.gov/publication/61570 and https://www.cbo.gov/system/files/2025-07/61570-pl119-21-2025Recon-CLB.xlsx.

[4] Office of Management and Budget, “Approved Apportionments,” https://apportionment-public.max.gov/.

[5] USAspending.gov, federal award spending database, https://www.usaspending.gov/.

[6] USDA Forest Service, “Urban Forests,” https://www.fs.usda.gov/managing-land/urban-forests.

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Legislative and Policy Analysis

Section 10108: Alien SNAP eligibility

Executive Summary

Section 10108 narrows Supplemental Nutrition Assistance Program eligibility for noncitizens by rewriting section 6(f) of the Food and Nutrition Act of 2008. After this change, a household member must be a U.S. resident and must fall into one of four categories to receive SNAP: a U.S. citizen or national, a lawful permanent resident, a Cuban or Haitian entrant, or a person lawfully residing in the United States under a Compact of Free Association.[1]

The practical effect is that several humanitarian and other previously eligible noncitizen categories lose federal SNAP eligibility unless they also qualify under one of the remaining categories. USDA guidance identifies groups such as refugees, asylees, parolees, certain trafficking survivors, battered aliens, certain American Indians born abroad, and certain Hmong or Highland Laotian tribal members as no longer eligible unless they fit within a remaining eligible status such as lawful permanent residence.[2]

CBO estimates that Section 10108 will make about 90,000 people ineligible for SNAP benefits in an average month, and that those people would otherwise have received about $210 per month on average over the 2026 through 2034 period.[3] That implies roughly $230 million per year in affected benefits at a constant 90,000-person monthly caseload, or roughly $2.0 billion over nine years before accounting for timing, interactions with other SNAP provisions, household-level recalculations, or state implementation patterns.

What Section 10108 Actually Does

Section 10108 amends section 6(f) of the Food and Nutrition Act of 2008, codified at 7 U.S.C. 2015(f). Instead of relying on the prior broader set of qualified-alien and humanitarian eligibility categories, the rewritten subsection limits SNAP eligibility to individuals who are residents of the United States and who are either U.S. citizens or nationals, lawful permanent residents, Cuban or Haitian entrants, or Compact of Free Association residents.[1]

The section does not appropriate new money, create a new grant program, authorize a new loan program, or establish a new dedicated funding account. Its fiscal effect comes from reducing federal SNAP benefit obligations by excluding some people who otherwise would have been eligible.

The section also changes how mixed-status households are treated. The amended text says that the income and financial resources of an individual made ineligible under this subsection are still considered when determining the eligibility and allotment value of the household, subject to state option for a pro rata share of income.[1] In plain terms, an ineligible household member may be excluded from receiving benefits, while some or all of that person’s income and resources may still count in the household calculation.

Legislative Mechanism

Section 10108 uses a direct statutory substitution. It does not add a pilot, waiver, regulation, or discretionary implementation program. It rewrites section 6(f) of the Food and Nutrition Act so that the eligibility rule itself becomes narrower.

The mechanism has three core parts:

1. It creates a threshold rule that no otherwise eligible household member may participate in SNAP unless the person is a U.S. resident and belongs to one of the listed citizenship or immigration categories.[1]
2. It removes federal SNAP eligibility for several groups that had previously been eligible through PRWORA-linked categories or humanitarian-status rules, unless those individuals also qualify under one of the remaining categories.[2]
3. It preserves household deeming treatment by counting income and resources of the ineligible person when calculating the household’s eligibility and allotment, with limited state-option treatment for pro rata income.[1]

Because this is an eligibility restriction, implementation happens through USDA Food and Nutrition Service guidance, state SNAP eligibility systems, caseworker procedures, recertifications, notices, immigration-status verification, quality control, and benefit calculation rules.

Expenditure Tracking and Reporting Protocol

Section 10108 affects federal financial flows by reducing SNAP benefit payments. It does not create a new account or a section-specific public spending line. The likely tracking will occur through normal SNAP budget execution, state agency eligibility and issuance systems, Treasury outlay data, USDA Food and Nutrition Service reporting, SNAP quality control, and CBO estimates.

The relevant federal program is SNAP, administered by USDA’s Food and Nutrition Service in partnership with state SNAP agencies. At the case level, state agencies determine eligibility, verify immigration status, calculate household allotments, issue benefits through EBT systems, and report program activity through existing SNAP reporting channels. USDA guidance directs state agencies to apply the new criteria to new applicants at initial certification and to existing households at recertification.[4]

The public visibility of Section 10108-specific savings is likely to be limited. Aggregate SNAP participation, benefit costs, and quality-control information are publicly visible, but a distinct “Section 10108 savings” line may not appear in routine public spending datasets. CBO provides the clearest section-specific estimate by identifying the expected affected monthly caseload and average monthly benefit.[3]

Statutory eligibility change
        |
        v
USDA Food and Nutrition Service guidance
        |
        v
State SNAP agencies update eligibility rules
        |
        v
Applications and recertifications
        |
        v
Immigration status checks and case record review
        |
        v
Benefit denial approval or recalculation
        |
        v
EBT issuance and federal SNAP outlays
        |
        v
USDA budget execution and state reporting
        |
        v
Public visibility mostly aggregated
        |
        v
Oversight through SNAP quality control CBO GAO IG and Congress

The reporting protocol is therefore indirect. State agencies report SNAP caseload, issuance, quality-control, and administrative information to USDA. USDA uses that information for program oversight, financial management, and national reporting. Treasury and OMB reflect SNAP spending in federal budget execution and outlay totals. CBO and congressional analysts estimate federal budget effects. GAO or USDA Inspector General reviews could later examine implementation problems, improper denials, payment errors, or state compliance, but those reviews would occur after implementation and may not isolate every affected household.

Day-to-Day Government Process Changes

For state SNAP offices, Section 10108 turns immigration-category screening into a more restrictive gatekeeping step. Caseworkers and eligibility systems must distinguish between noncitizen categories that remain eligible and categories that were formerly eligible but are now excluded.

USDA guidance says the provision was effective on July 4, 2025, must be applied immediately to new applicants at initial certification, and must be applied to already participating households at recertification.[4] This means implementation will occur unevenly across households depending on certification periods, reporting cycles, and state system updates.

The day-to-day process changes include:

This will likely increase pressure on state eligibility systems, call centers, community navigators, legal aid organizations, and immigrant-serving groups because affected households may need individualized explanations about why a household member was removed, why benefits changed, and whether a different immigration status restores eligibility.

Effects on Consumers

The most direct consumer effect is the loss or reduction of food assistance for affected noncitizens and mixed-status households. CBO estimates that about 90,000 people will become ineligible in an average month and that their projected average benefit would have been about $210 per month.[3]

For a household, the effect may appear in several ways:

The policy may also create a “chilling effect,” where eligible household members avoid applying because they fear immigration consequences, misunderstand the rule, or believe the entire household is barred. That risk is especially relevant where households include citizens, lawful permanent residents, humanitarian-status members, and undocumented family members in the same home.

Effects on Businesses

Section 10108 does not directly regulate businesses, impose employer mandates, change business taxes, or create a new compliance obligation for retailers. The business effects are indirect.

SNAP-authorized grocery stores, supermarkets, farmers markets, and other food retailers may see a small reduction in SNAP-funded purchases in communities with larger affected immigrant populations. Because CBO estimates an average affected benefit of about $210 per month for about 90,000 people, the broad national effect is modest relative to the full SNAP program, but the local effect may be more noticeable in neighborhoods where excluded populations are concentrated.[3]

Businesses and nonprofits that provide eligibility assistance, case management, immigration legal services, food pantry operations, or refugee resettlement support may experience increased workload. They may need to explain eligibility changes, help families respond to notices, screen for alternative benefits, and distinguish between household members who remain eligible and those who do not.

Employers may also see indirect effects for low-wage workers whose household food budgets shrink. Reduced food assistance can increase financial stress, schedule instability, and reliance on emergency food resources, though Section 10108 itself does not change wage law or employer reporting obligations.

Environmental and Climate Impact

Section 10108 has no direct environmental permitting, emissions, land use, energy, transportation, or climate-policy mechanism. It is a SNAP eligibility restriction, not an environmental statute.

The indirect environmental impact is likely minimal and difficult to isolate. A small reduction in SNAP-funded food purchases could slightly change consumer food demand, but the affected caseload is too small relative to the national food system to support a meaningful climate or emissions estimate. Local food pantries and emergency feeding programs could see increased demand, which may shift some food distribution from retail purchases to charitable food networks, but that effect would be indirect and not tracked as a Section 10108 environmental outcome.

Impact Summary

Section 10108 is a targeted eligibility cut within SNAP. It does not create a new program or new appropriation; it reduces federal benefit eligibility for certain noncitizens by narrowing the statutory categories that can receive SNAP.

The strongest impacts are administrative and household-level. State SNAP agencies must revise eligibility systems and recertification practices, while affected households may lose benefits or see allotments recalculated. CBO’s clearest quantified estimate is that about 90,000 people become ineligible in an average month and would otherwise have received about $210 per month in SNAP benefits.[3]

The biggest policy concern is not only the direct loss of benefits for excluded people, but also the complexity for mixed-status households. Some members may remain eligible while others are excluded, and the income of excluded members may still count against the household. That combination can reduce food assistance while making notices, appeals, and community outreach more complicated.

Key References and Sourcing

[1] Congress.gov, “Text – H.R.1 – 119th Congress (2025-2026): An act to provide for reconciliation pursuant to title II of H. Con. Res. 14,” Section 10108, https://www.congress.gov/bill/119th-congress/house-bill/1/text.

[2] USDA Food and Nutrition Service, “Supplemental Nutrition Assistance Program (SNAP) Implementation of the One Big Beautiful Bill Act of 2025 – Alien SNAP Eligibility,” attachment comparing pre- and post-OBBB eligibility categories, https://www.usda.gov/sites/default/files/guidance-documents/fns.snap-obbb-alien-eligibility.pdf.

[3] Congressional Budget Office, “Estimated Effects of Public Law 119-21 on Participation and Benefits Under the Supplemental Nutrition Assistance Program,” supplemental information for Public Law 119-21, August 11, 2025, https://www.cbo.gov/system/files/2025-08/61367-SNAP.pdf.

[4] USDA Food and Nutrition Service, “Supplemental Nutrition Assistance Program (SNAP) Implementation of the One Big Beautiful Bill Act of 2025 – Alien SNAP Eligibility,” implementation guidance to all SNAP state agencies, October 31, 2025, https://www.usda.gov/sites/default/files/guidance-documents/fns.snap-obbb-alien-eligibility.pdf.

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Legislative and Policy Analysis

Section 10107: National education and obesity prevention grant program

Plain-English Summary

Section 10107 ends the permanent mandatory funding stream for the Supplemental Nutrition Assistance Program Nutrition Education and Obesity Prevention Grant Program, commonly known as SNAP-Ed, after fiscal year 2025.[1] The section does this through a short statutory edit: it changes the Food and Nutrition Act so the program’s annual funding formula applies only “for each of fiscal years 2016 through 2025,” rather than “for fiscal year 2016 and each subsequent fiscal year.”[1]

In practical terms, this does not repeal every paragraph describing SNAP-Ed’s purposes, planning rules, eligible services, reporting requirements, or evaluation framework. Instead, it removes the automatic future funding that made those activities operate as an ongoing national grant program.[2] USDA has interpreted the change as ending required SNAP-Ed funding with the fiscal year 2025 grant allocation.[3]

What This Section Actually Does

Core Legal Mechanism

Section 10107 is a funding cutoff, not a broad rewrite of nutrition education policy. The existing statute still describes eligible individuals, state plans, evidence-based uses, coordination with other nutrition programs, annual state reports, annual federal reports, technical assistance, and an information clearinghouse.[2] But without the continuing mandatory funding reservation, those operational provisions no longer have the same automatic funding engine after fiscal year 2025.[1]

flowchart TD
    A[Food and Nutrition Act Section 28] --> B[SNAP-Ed statutory program rules]
    B --> C[State nutrition education plans]
    B --> D[Evidence-based nutrition and obesity prevention activities]
    B --> E[Reports, evaluation, technical assistance]
    A --> F[Mandatory annual funding formula]
    F --> G[Pre-OBBBA: FY 2016 and each subsequent fiscal year]
    F --> H[Section 10107 edit]
    H --> I[Post-OBBBA: FY 2016 through FY 2025 only]
    I --> J[No required mandatory SNAP-Ed funding after FY 2025]

Day-to-Day Government Process Changes

Section 10107 changes the daily work of USDA, state SNAP agencies, extension programs, public health departments, food banks, schools, and community organizations that use SNAP-Ed funding.

Implementation Timeline

Consumer Impact

Consumers most directly affected are SNAP participants, people eligible for SNAP, school meal participants, and residents of low-income communities who received SNAP-Ed-supported nutrition education or community health programming.[2]

The impact is not a direct cut to monthly SNAP food benefits. Section 10107 does not itself reduce the Electronic Benefit Transfer amount loaded onto a household’s card. Its effect is on the education, outreach, prevention, and community-health side of SNAP, not the benefit allotment formula.[1]

Business and Local Economic Impact

Section 10107 can affect businesses and nonprofit contractors that participate in the SNAP-Ed delivery network.

Businesses that sell less nutritious foods are unlikely to face direct new restrictions from this section because Section 10107 does not regulate product sales, SNAP retailer eligibility, labeling, advertising, or nutrition standards. Its effect is fiscal and programmatic.

Environmental and Climate Impact

Section 10107 has no direct environmental permitting, emissions, energy, land-use, or climate regulation component. It does not amend the Clean Air Act, Clean Water Act, National Environmental Policy Act, conservation programs, forestry programs, or agricultural conservation incentives.

The environmental impact is therefore mostly indirect and local. SNAP-Ed has included policy, systems, and environmental change strategies, often called PSE strategies, that can support healthier food environments in places where people eat, learn, live, play, shop, and work.[6] USDA’s SNAP-Ed materials describe environmental-setting work as measuring changes in policies, systems, and environments at qualified sites and organizations.[6]

Potential indirect impacts include:

The strongest conclusion is that Section 10107 has a low direct climate impact but a potentially meaningful indirect local food-system impact in communities where SNAP-Ed funds supported gardens, farmers markets, food pantry redesign, school wellness partnerships, or other healthy-food environment projects.

Equity and Public Health Considerations

The original SNAP-Ed statute targets eligible individuals including SNAP participants, people eligible through certain child nutrition programs, people living in communities with significant low-income populations, and other low-income individuals determined eligible by USDA.[2] Ending the mandatory funding stream therefore concentrates program loss among lower-income households and communities.

Public health effects will vary by state and locality. States with alternative state, philanthropic, university, or public health funding may preserve some services. States and counties that depended heavily on federal SNAP-Ed grants may experience sharper reductions in nutrition education staffing, community programming, and evaluation.

Practical Bottom Line

Section 10107 ends the automatic federal funding stream for SNAP-Ed after fiscal year 2025. It leaves much of the statutory program architecture in place but removes the mandatory money that made the national program operate year after year. For government agencies, the main change is a shift from annual grant administration to closeout, transition planning, and possible program termination. For consumers, the change means less access to nutrition education, food budgeting, healthy cooking, physical activity promotion, and community-level healthy food environment programs. For businesses and community partners, the change may mean lost contracts, reduced staffing, and fewer partnerships with universities, nonprofits, food retailers, food banks, farmers markets, and local health organizations. Environmental and climate effects are not direct, but local food-system and community garden projects may be affected where they were supported by SNAP-Ed.

Key References and Sourcing

[1] U.S. Government Publishing Office, “Public Law 119-21—One Big Beautiful Bill Act,” Section 10107, https://www.govinfo.gov/link/plaw/119/public/21.

[2] Office of the Law Revision Counsel, U.S. House of Representatives, “7 U.S.C. 2036a: Nutrition education and obesity prevention grant program,” https://uscode.house.gov/view.xhtml?edition=prelim&num=0&req=granuleid%3AUSC-prelim-title7-section2036a.

[3] USDA Food and Nutrition Service, “Supplemental Nutrition Assistance Program Nutrition Education and Obesity Prevention Grant Program (SNAP-Ed) Questions and Answers,” implementation guidance for Section 10107, https://www.fns.usda.gov/snap-ed/grant-qas.

[4] USDA Food and Nutrition Service, “One Big Beautiful Bill Act of 2025,” official implementation resources hub, https://www.fns.usda.gov/obbb.

[5] Senate Committee on Agriculture, Nutrition, and Forestry, “Section-by-Section,” summary of Section 10107 funding effect, https://www.agriculture.senate.gov/imo/media/doc/senate_anf_section_by_section_final.pdf; Federal Funds Information for States, “One Big Beautiful Bill Act: Nutrition Provisions Affecting SNAP,” fiscal estimate for Section 10107, https://eohhs.ri.gov/sites/g/files/xkgbur226/files/2025-08/FFIS%20-%20SNAP%20%282025%29.pdf.

[6] USDA Food and Nutrition Service, “SNAP-Ed Evaluation Framework and Interpretive Guide,” evaluation and program framework, https://snaped.fns.usda.gov/administration/evaluation-framework; USDA Food and Nutrition Service, “Environmental Settings – Evaluation Framework,” https://snaped.fns.usda.gov/administration/framework/Environmental-Settings-level.

[7] USDA Food and Nutrition Service, “Policy, Systems, and Environmental Change,” SNAP-Ed resource on community health and environmental change strategies, https://snaped.fns.usda.gov/resources/policy-systems-environmental-change.

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Legislative and Policy Analysis

Section 10106: Administrative cost sharing

Executive Summary

Section 10106 changes who pays to administer the Supplemental Nutrition Assistance Program (SNAP). It amends the Food and Nutrition Act of 2008 so that, beginning in fiscal year 2027, the federal government reimburses states for 25 percent of most approved SNAP administrative costs instead of 50 percent.[1] That means the non-federal share rises from 50 percent to 75 percent for ordinary SNAP administration.

This does not directly reduce the statutory SNAP benefit formula for households. Instead, it shifts the cost of running SNAP eligibility, issuance, customer service, hearings, systems, outreach, investigations, and related administrative functions onto states and, in county-administered states, potentially onto counties.[2] The practical risk is that states facing higher administrative costs may cut staffing, delay technology upgrades, reduce outreach, tighten operating procedures, or seek state budget offsets elsewhere.

CBO’s enacted-law budget materials estimate that the administrative cost-sharing provision reduces federal budget authority by roughly $24.7 billion over fiscal years 2025 through 2034, with no federal savings in fiscal years 2025 or 2026 and savings beginning in fiscal year 2027.[3] The policy is therefore best understood as a federal savings provision achieved through a state and local cost shift, not as a direct benefit-cut provision.

What Section 10106 Actually Does

Section 10106 amends the SNAP administrative cost-sharing rule in 7 U.S.C. § 2025(a). Under the amended statute, the Secretary of Agriculture is authorized to pay state agencies 50 percent of covered administrative costs through fiscal year 2026, and 25 percent for fiscal year 2027 and each fiscal year thereafter.[1]

The section does not create a new grant program, new benefit category, new tax credit, or new federal appropriation. Its financial effect comes from changing the reimbursement percentage for an existing open-ended administrative reimbursement stream.

The provision also matters because SNAP administration is not optional infrastructure. States must process applications, verify eligibility, issue benefits, maintain electronic systems, conduct hearings, operate quality-control procedures, manage fraud investigations, and communicate program rules. Reducing the federal reimbursement rate changes the budget math for every one of those functions.

Legislative Mechanism

The mechanism is a targeted statutory amendment to the Food and Nutrition Act’s administrative cost-sharing provision. Before this change, ordinary state SNAP administrative costs were generally reimbursed at 50 percent by the federal government. Section 10106 replaces that single reimbursement rule with a time-based rule: 50 percent through fiscal year 2026 and 25 percent from fiscal year 2027 forward.[1]

This is a cost-shift mechanism. The federal government does not need to deny individual benefits to generate savings under this section. Instead, it pays a smaller share of the administrative bills submitted by state SNAP agencies. States must then either appropriate more state funds, shift costs to counties where county administration is used, reduce administrative capacity, redesign operations, or use a combination of those responses.

The mechanism also interacts with other OBBBA SNAP provisions. For example, expanded work requirements, payment-error cost sharing, changes to utility allowance rules, and immigration eligibility restrictions can increase operational complexity at the same time that Section 10106 reduces the federal share of ordinary administrative funding. That combination may make the administrative cost shift more consequential than the reimbursement percentage alone suggests.

Expenditure Tracking and Reporting Protocol

The spending affected by Section 10106 is likely to be tracked through USDA Food and Nutrition Administration budget execution and SNAP financial reporting, state agency accounting systems, Treasury outlay data, OMB budget materials, state budget documents, single audits, and federal award reporting systems. The current administering agency for federal nutrition programs is USDA’s Food and Nutrition Administration, formerly the Food and Nutrition Service as of June 1, 2026.[5]

The relevant federal program is SNAP, authorized under the Food and Nutrition Act of 2008 and commonly associated with Assistance Listing 10.551 for SNAP benefits and administration. State SNAP agencies will continue to incur allowable administrative costs and claim reimbursement from USDA. The change is that the federal reimbursement percentage for most ordinary administrative costs falls to 25 percent beginning in FY 2027.

Public visibility will likely be partly clear but not section-specific. The reduced federal reimbursement should appear in federal SNAP budget execution and CBO/OMB estimates, and states may show higher state-share costs in state budget documents. However, a member of the public may not be able to isolate “Section 10106 dollars” in USAspending.gov or Treasury data because the provision changes a reimbursement rate inside a broader SNAP account rather than creating a new standalone account.

flowchart TD
    A[Section 10106 authority] --> B[USDA nutrition agency]
    B --> C[State SNAP agency]
    C --> D[Eligibility and issuance]
    C --> E[Systems and hearings]
    C --> F[Outreach and operations]
    D --> G[State cost claims]
    E --> G
    F --> G
    G --> H[Federal reimbursement at 25 percent]
    G --> I[State share at 75 percent]
    H --> J[Treasury and OMB tracking]
    H --> K[USDA budget execution]
    I --> L[State budget tracking]
    I --> M[County budgets where applicable]
    J --> N[Aggregated public visibility]
    K --> N
    L --> O[State level visibility]
    M --> O
    N --> P[GAO audits and Congress]
    O --> P

Likely reporting pathway:

If the section creates fiscal pressure but does not establish a dedicated public report, the most important limitation is that public datasets may show lower federal administrative reimbursement without clearly labeling the reduction as “Section 10106.” State budget documents may be more useful than federal award databases for understanding the real-world fiscal impact on a particular state or county.

Day-to-Day Government Process Changes

For state SNAP agencies, the change is operationally significant. The same eligibility and benefit-administration tasks remain, but federal reimbursement covers a smaller portion of those costs. Agencies will need to revise budget requests, update cost-allocation plans, adjust reimbursement assumptions, and revisit contracts or staffing models tied to SNAP operations.

State budget offices may have to identify additional general fund, special fund, or county contributions to maintain the same service level. County-administered states face an additional governance issue because state law determines whether counties absorb part of the higher non-federal share. The National Association of Counties has warned that in 9 of the 10 county-administered SNAP states, counties may have to contribute more or fully cover the administrative cost shift.[2]

Technology planning is also affected. USDA guidance states that recently approved Advanced Planning Document Updates must be adjusted to reflect the new 25 percent federal reimbursement rate beginning in FY 2027, and applicable updates must be submitted for review or approval at least 90 days before the start of FY 2027.[4] That matters for eligibility systems, call centers, verification tools, data matching, notices, and other automated processes.

For frontline workers and applicants, the practical changes may include longer processing queues, slower call-center response times, fewer outreach partnerships, more restrictive documentation workflows, or delayed system improvements if states do not replace the lost federal administrative funding.

Effects on Consumers

Section 10106 does not directly change SNAP benefit amounts, eligibility categories, or household allotment formulas. A household’s monthly SNAP benefit is not reduced by this section alone.

However, consumers can still be affected indirectly. SNAP recipients and applicants rely on administrative capacity to apply, recertify, report changes, resolve notices, attend fair hearings, correct errors, and receive timely benefits. If a state responds to the lower federal reimbursement rate by cutting staff, reducing outreach, delaying technology projects, or tightening call-center operations, eligible households may face more friction even when their legal eligibility has not changed.

The consumer impact is likely to be greatest for people who already have difficulty navigating administrative systems: older adults, people with disabilities, rural households, people without reliable internet access, people with limited English proficiency, working families with unstable schedules, and households that need help resolving notices or documentation problems.

Effects on Businesses

The most direct business effects fall on vendors, contractors, nonprofits, and technology providers that support SNAP administration. These may include eligibility-system contractors, call-center vendors, document-management firms, data-matching vendors, community-based outreach partners, legal aid organizations, and county service providers.

If states reduce administrative spending, some vendors may see smaller contracts, delayed procurements, or more pressure to lower prices. If states instead invest in automation to offset staffing costs, some technology vendors may see increased demand for eligibility modernization, identity verification, document processing, data analytics, and quality-control tools.

Retail food businesses are not directly regulated by Section 10106. But if administrative underfunding reduces participation among eligible households or slows benefit access, grocers, farmers markets, corner stores, and other SNAP-authorized retailers could see reduced SNAP purchasing activity in affected communities. Those effects would be indirect and would vary by state implementation choices.

Environmental and Climate Impact

Section 10106 has no direct environmental permitting, emissions, land-use, energy, transportation, or climate provision. Its statutory object is SNAP administrative financing.

Any environmental or climate impact would be indirect. For example, reduced outreach or administrative capacity could affect participation in food assistance, which may in turn affect household food purchasing patterns, emergency food demand, and local food distribution systems. But those effects are too attenuated to attribute a direct climate impact to this section alone.

The more concrete environmental-administration issue is digital and operational infrastructure. If states delay system modernization or reduce field operations, the environmental effect is likely negligible compared with the fiscal and service-delivery effects. This section should therefore be classified as having no direct environmental or climate impact, with only speculative indirect effects.

Impact Summary

Section 10106 is a major SNAP governance and fiscal federalism change. It leaves the basic federal SNAP benefit structure in place but sharply reduces the federal government’s contribution to the cost of administering the program. Beginning in FY 2027, states must finance 75 percent of most ordinary SNAP administrative costs instead of 50 percent.

The core impact is not a direct benefit cut; it is a cost shift. But cost shifts can still affect access. SNAP depends on state and local administrative machinery. If that machinery is underfunded, eligible households can experience delays, confusion, wrongful denials, reduced outreach, or difficulty maintaining benefits.

For oversight purposes, this section should be tracked through federal SNAP budget execution, state budget documents, county budget materials where relevant, single audits, USDA guidance, and future GAO or Inspector General reviews. Public tracking will likely be fragmented because the provision changes a reimbursement rate inside an existing program rather than creating a separate, clearly labeled account.

Key References and Sourcing

[1] Legal Information Institute, “7 U.S.C. § 2025 — Administrative cost-sharing and quality control,” codified Food and Nutrition Act reimbursement language and amendment note, https://www.law.cornell.edu/uscode/text/7/2025.

[2] National Association of Counties, “H.R. 1 and the Supplemental Nutrition Assistance Program (SNAP): What Counties Should Know,” county-administered state and local fiscal impact discussion, https://www.naco.org/resource/hr-1-and-supplemental-nutrition-assistance-program-snap-what-counties-should-know.

[3] Congressional Budget Office, “Estimated Budgetary Effects of Public Law 119-21, to Provide for Reconciliation Pursuant to Title II of H. Con. Res. 14, Relative to CBO’s January 2025 Baseline,” enacted-law budget estimate, https://www.cbo.gov/publication/61570.

[4] USDA Food and Nutrition Service, “Supplemental Nutrition Assistance Program Provisions of the Big Beautiful Bill Act of 2025, Section 10106 Administrative Cost Sharing: Questions and Answers,” May 21, 2026, https://www.usda.gov/sites/default/files/guidance-documents/fns.snap-obbb-section10106-adminCostSharing-qas.pdf.

[5] USDA Food and Nutrition Administration, “Reorganization,” current agency naming and reorganization notice, https://www.fns.usda.gov/about/reorganization.

[6] Georgetown Center on Poverty and Inequality, “SNAP Changes Will Upend State Budgets,” state budget impact analysis, https://www.georgetownpoverty.org/issues/snap-changes-will-upend-state-budgets/.

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Legislative and Policy Analysis

Section 10105: Matching funds requirements

Executive Summary

Section 10105 changes SNAP’s benefit-financing structure by requiring states with SNAP payment error rates of 6 percent or higher to pay part of the cost of SNAP benefit allotments beginning in fiscal year 2028.[1] Before this change, SNAP household benefits were federally funded, while states shared administrative costs.[2]

The section ties a state’s new benefit-cost share to its SNAP payment error rate. States below 6 percent pay no benefit-cost share. States at or above 6 percent pay 5 percent, 10 percent, or 15 percent of benefit costs depending on the error-rate tier.[1] The Congressional Budget Office estimated that Section 10105 will reduce federal direct spending by $41 billion over fiscal years 2028 through 2034, with about $35 billion of that reduction coming from states paying a portion of SNAP benefits.[3]

This is not a direct benefit cut written into the statutory formula for every household. It is a fiscal-pressure mechanism. It makes SNAP accuracy systems, state budgeting, eligibility administration, and quality-control performance much more consequential for households because states may respond by increasing administrative scrutiny, restricting optional choices where available, seeking new state appropriations, or, in extreme cases, reconsidering program participation.[3]

What Section 10105 Actually Does

Section 10105 amends Section 4(a) of the Food and Nutrition Act of 2008 to create a “State quality control incentive” for SNAP benefit allotments.[1] The mechanism is based on each state’s SNAP payment error rate, which measures the accuracy of eligibility determinations and benefit payments and includes both overpayments and underpayments.[3]

CBO estimated that Section 10105 reduces federal direct spending by $41 billion over fiscal years 2028 through 2034.[3] About $35 billion of that reduction comes from states paying a portion of SNAP benefit costs, while about $7 billion comes from expected state responses that reduce or eliminate SNAP benefits for about 300,000 people in an average month over the 2028 through 2034 period.[3] CBO also estimated a related $170 million reduction in child nutrition program spending over the 2028 through 2034 period, affecting about 96,000 children in an average month.[3]

The state share is determined by error-rate tiers:

For fiscal year 2028, a state may elect to use its fiscal year 2025 or fiscal year 2026 payment error rate to determine the applicable state share.[1] For fiscal year 2029 and later years, the statute uses the applicable prior-year framework established in the amended Food and Nutrition Act.[1]

The section also includes a delay rule for comparatively high-error states. If a state’s fiscal year 2025 or fiscal year 2026 payment error rate, multiplied by 1.5, exceeds 20 percent, the state may avoid paying the benefit-cost share until fiscal year 2029 or fiscal year 2030, respectively.[3] In practical terms, that means some states with very high error rates may receive a temporary delay before the new state cost-share obligation begins.

USDA’s fiscal year 2024 SNAP payment error data reported a national payment error rate of 10.93 percent, consisting of a 9.26 percent overpayment rate and a 1.67 percent underpayment rate.[4] That national rate is above the 10 percent statutory threshold that would place a state in the highest 15 percent cost-share tier if the same rate applied to an individual state under the Section 10105 framework.

Legislative Mechanism

Section 10105 works by changing the federal-state financing rule for SNAP allotments. It does not create a new grant program, a new tax credit, or a new discretionary appropriation. Instead, it amends the underlying SNAP authorization so that USDA may not pay more than the applicable federal share of benefit costs for states whose payment error rates trigger a state share.[1]

The mechanism has four core parts:

1. Error-rate trigger. The state’s SNAP payment error rate determines whether the state owes a share of benefit costs.
2. Tiered state contribution. The state contribution rises from 0 percent to 5 percent, 10 percent, or 15 percent as the payment error rate crosses the statutory thresholds.
3. Federal payment cap. USDA’s federal payment obligation is capped at the applicable federal share.
4. Delayed application for certain high-error states. Some states with very high error rates in fiscal year 2025 or fiscal year 2026 receive delayed implementation under the special rule described by CBO.[3]

This structure changes SNAP from a system in which the federal government financed household food benefits nationally to a system in which state quality-control performance can directly affect state fiscal exposure.[2]

Expenditure Tracking and Reporting Protocol

Section 10105 involves federal financial flows because it changes who pays SNAP benefit allotment costs. The likely tracking chain runs through USDA Food and Nutrition Administration budget execution, Treasury outlay records, state SNAP agency financing, SNAP Quality Control reporting, and CBO or congressional oversight estimates.

The most relevant tracking sources are likely to include:

Because Section 10105 changes the federal share of existing SNAP allotment payments, section-specific public tracking may be difficult to isolate in standard federal datasets. USAspending.gov may show SNAP assistance obligations at a broad program level, but it may not cleanly separate “savings caused by Section 10105” from other SNAP eligibility, participation, benefit, or administrative changes enacted in the same law.

flowchart TD
    Law[Section 10105] --> USDA[USDA FNA]
    USDA --> QC[Quality control rates]
    QC --> Tier[State share tier]
    Tier --> Federal[Federal benefit share]
    Tier --> State[State budget share]
    Federal --> EBT[SNAP EBT benefits]
    State --> EBT
    Federal --> Treasury[Treasury outlays]
    State --> StateReports[State budget reports]
    QC --> PublicData[USDA public data]
    Treasury --> OMB[OMB and CBO review]
    StateReports --> Oversight[GAO and IG oversight]
    PublicData --> Oversight

The reporting protocol is likely to work as follows: state SNAP agencies continue to conduct and submit quality-control case review information; USDA validates or calculates payment error rates; those rates determine each state’s cost-share tier; USDA limits federal benefit funding to the applicable federal share; states finance the remaining state share through state budget mechanisms; federal outlays are reported through Treasury, USDA, OMB, and CBO channels; and oversight may occur through USDA, GAO, Inspector General reviews, and congressional hearings.[4]

Public visibility is likely to be mixed. Payment error rates are public and relatively clear. State fiscal exposure may be visible in state budgets. But household-level effects, state policy responses, and the exact portion of SNAP outlay changes attributable only to Section 10105 may be delayed, aggregated, or difficult to isolate.

Day-to-Day Government Process Changes

For USDA and state SNAP agencies, Section 10105 turns payment accuracy into a direct state budget issue. SNAP quality-control work already mattered for program integrity, but this section makes the financial stakes much larger because the error rate can determine whether a state owes 0 percent, 5 percent, 10 percent, or 15 percent of benefit costs.[1]

Day-to-day state operations may change in several ways:

USDA’s SNAP Quality Control materials explain that payment error rates measure the accuracy of state eligibility and benefit determinations, and USDA requires corrective action when state agencies have a payment error rate of 6 percent or more or fail to review at least 98 percent of the required sample size.[5] Section 10105 adds a major fiscal consequence to that same 6 percent threshold.

Effects on Consumers

Section 10105 does not directly rewrite the household benefit formula for every SNAP recipient. However, it can still affect consumers because states may respond to new state costs by changing administrative practices, tightening eligibility operations, seeking additional documentation, or making policy choices that reduce enrollment or benefits where legally available.

CBO estimated that state responses to the new benefit-cost share may reduce or eliminate SNAP benefits for about 300,000 people in an average month over fiscal years 2028 through 2034.[3] Consumers most likely to feel the effect are households in states with higher payment error rates, households with unstable income or housing, households with complicated deductions, and households that struggle to produce paperwork quickly.

Potential consumer impacts include:

CBO’s estimate that 96,000 children may see reduced child nutrition subsidies in an average month over 2028 through 2034 underscores that the effects may extend beyond SNAP households alone.[3]

Effects on Businesses

The most direct business impact falls on food retailers, EBT processors, eligibility-system contractors, call-center vendors, document-management vendors, data-matching vendors, and consulting firms that support state SNAP administration.

For grocery stores, farmers markets, superstores, corner stores, and other SNAP-authorized retailers, the key risk is reduced purchasing power if state responses lead to lower participation or benefit disruptions. SNAP benefits are spent quickly and locally, so reductions can affect food retailers in lower-income communities.

For contractors and technology vendors, the effect may run in the opposite direction. States facing new fiscal penalties may purchase more eligibility automation, data-matching tools, identity proofing, quality-control analytics, case-management upgrades, and training services. Businesses that sell administrative technology to state human-service agencies may see new demand.

Environmental and Climate Impact

Section 10105 has no direct environmental permitting, emissions, land-use, energy, or climate provision. Its environmental and climate impact is therefore indirect.

The most plausible indirect effects come from changes in food purchasing and food insecurity. If SNAP participation or benefit access declines in some states, households may shift toward cheaper, less flexible food options, rely more heavily on emergency food systems, or make fewer grocery trips. Food banks and charitable distribution networks may face higher demand, which can increase logistics needs such as storage, refrigeration, and transportation.

At the same time, these effects are too indirect and state-dependent to quantify from the statutory text alone. The section does not itself fund climate projects, rescind climate funds, change agricultural conservation policy, alter energy rules, or regulate emissions.

Impact Summary

Section 10105 is one of the most structurally significant SNAP financing changes in Public Law 119-21. It converts SNAP benefit funding from a fully federal benefit obligation into a conditional federal-state cost-sharing system tied to state payment error rates.

The major fiscal effect is a $41 billion federal direct spending reduction over FY2028-FY2034, with about $35 billion shifted to states and about $7 billion associated with expected reductions or eliminations of benefits for some participants.[3] The practical effect is that state quality-control performance, state budget capacity, and state administrative choices become central to whether households experience stable food assistance.

The policy’s supporters are likely to describe it as a payment-accuracy incentive. Its critics are likely to describe it as a federal cost shift that may punish households for state administrative errors and pressure states to reduce access. Both interpretations flow from the same core mechanism: Section 10105 makes state SNAP error rates financially consequential.

Key References and Sourcing

[1] U.S. Government Publishing Office, “Public Law 119-21, One Big Beautiful Bill Act,” Section 10105, https://www.govinfo.gov/link/plaw/119/public/21.

[2] Congressional Research Service, “Supplemental Nutrition Assistance Program (SNAP) and Related Nutrition Programs in P.L. 119-21: An Overview,” background on prior SNAP financing and enacted Section 10105, https://www.everycrsreport.com/reports/R48552.html.

[3] Congressional Budget Office, “Estimated Effects of Public Law 119-21 on Participation and Benefits Under the Supplemental Nutrition Assistance Program,” August 11, 2025, Section 10105 estimates, https://www.cbo.gov/system/files/2025-08/61367-SNAP.pdf.

[4] USDA Food and Nutrition Service, “SNAP Payment Error Rates,” FY2024 payment error-rate data and explanation, https://www.fns.usda.gov/snap/qc/per.

[5] USDA Food and Nutrition Service, “SNAP Quality Control,” explanation of payment error rates, weighted national rate, and corrective action expectations, https://www.fns.usda.gov/snap/qc.

[6] Senate Committee on Agriculture, Nutrition, and Forestry, “Section-by-Section,” Section 10105 summary, https://www.agriculture.senate.gov/imo/media/doc/senate_anf_section_by_section_final.pdf.

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Legislative and Policy Analysis

Section 10104: Restrictions on internet expenses

Executive Summary

Section 10104 changes SNAP benefit calculations by prohibiting internet service fees from being counted when calculating the excess shelter expense deduction under Section 5(e)(6) of the Food and Nutrition Act of 2008.[1] In practical terms, households can no longer use internet costs to lower countable net income through the shelter deduction, which can reduce monthly SNAP benefits for affected households.

The section does not create a new appropriation, grant program, tax credit, loan authority, or direct payment. Its budget effect comes from reduced SNAP benefit outlays. CBO estimates that the change will reduce monthly SNAP benefits by about $10 for roughly 65 percent of households, on average, in each year over the 2026–2034 period.[2] A later summary of Public Law 119-21 reports CBO-estimated savings of $10.09 billion over 10 years for this provision.[3]

What Section 10104 Actually Does

Section 10104 amends Section 5(e)(6) of the Food and Nutrition Act of 2008 by adding a new rule: any service fee associated with internet connection may not be used in computing the excess shelter expense deduction.[1]

The excess shelter deduction is part of SNAP’s net income calculation. A household’s SNAP allotment generally rises when allowable deductions lower net income, because SNAP benefits are designed to fill the gap between a household’s expected food contribution and the maximum benefit for its household size.[4] By removing internet expenses from the deduction calculation, Section 10104 can increase countable net income and reduce monthly SNAP benefits for households that previously benefited from counting internet costs.

The provision is narrow but consequential. It does not say that internet service is irrelevant to household life, work, school, telehealth, or job searches. It says that internet connection service fees may not be used in this specific SNAP calculation.

Legislative Mechanism

Section 10104 uses a direct statutory amendment. It adds a new subparagraph to Section 5(e)(6) of the Food and Nutrition Act of 2008, the part of SNAP law that governs deductions from income when determining eligibility and benefit amounts.[1]

The mechanism is not a pilot program, waiver authority, or discretionary rulemaking instruction. It is a categorical exclusion. State SNAP agencies and eligibility systems must treat internet connection service fees as non-countable for the excess shelter expense deduction.

This also reverses the practical direction of recent SNAP utility policy. USDA’s 2024 standard utility allowance rulemaking allowed internet expenses to be included in utility allowance calculations, recognizing internet access as part of modern household utility costs.[5] Section 10104 overrides that approach for SNAP shelter-deduction purposes.

Expenditure Tracking and Reporting Protocol

Section 10104 affects federal financial flows by reducing SNAP benefit payments that otherwise would have been made to households. It does not create a dedicated account or a separately labeled payment stream. The relevant federal program is SNAP, administered nationally by USDA’s Food and Nutrition Service and implemented by state SNAP agencies.

The likely tracking sources are:

Reporting will likely be clearer inside agency systems than in public datasets. State agencies report SNAP participation, issuance, administrative data, and quality-control information to USDA. USDA publishes aggregate program data, while CBO estimates federal budget effects. But because Section 10104 changes the formula used to calculate benefits, rather than creating a separate payment or grant, the public may not be able to isolate every dollar of savings attributable to this section in routine spending databases.

Simple implementation and tracking flow:

Section 10104 statutory exclusion
        |
        v
USDA FNS guidance and state implementation instructions
        |
        v
State SNAP eligibility systems update deduction rules
        |
        v
Caseworkers and online systems stop counting internet fees
        |
        v
Household net income may increase for SNAP purposes
        |
        v
Monthly SNAP allotment may decrease
        |
        v
Aggregate effects appear in USDA SNAP data, CBO estimates,
state QC reviews, audits, and oversight reporting

Public visibility is likely to be delayed and aggregated. The change may show up as lower average benefits, revised state utility allowance methods, or quality-control issues, but not as a clean public line item labeled “Section 10104 internet expense savings.”

Day-to-Day Government Process Changes

For USDA, Section 10104 requires implementation guidance, conformity checks, and coordination with state SNAP agencies. USDA’s OBBB implementation page identifies Sections 10103 and 10104 as SNAP eligibility provisions and links related implementation resources, including guidance on fiscal year 2026 standard utility allowance values.[6]

For state SNAP agencies, the day-to-day work changes are more direct:

The administrative burden is not simply deleting one line from a form. States may need system programming, worker training, notice templates, revised manuals, call-center scripts, and public-facing explanations. Counties that administer SNAP may also absorb additional workload because clients may not understand why a real household bill no longer counts in the calculation.

Effects on Consumers

The direct consumer impact falls on SNAP households that pay for internet service and previously could benefit from counting that cost in the shelter-deduction calculation. CBO expects the average monthly SNAP benefit to decrease by about $10 for roughly 65 percent of households, on average, in each year from 2026 through 2034.[2]

For a household already balancing rent, utilities, broadband, transportation, and food, $10 per month is not trivial. It can mean fewer groceries, less flexibility when prices rise, or a harder tradeoff between food and digital access. FRAC estimates that more than 14 million SNAP households will be affected and describes the change as an elimination of the internet deduction.[4]

The policy is also likely to matter more in households where internet access supports job searches, remote work, school assignments, telehealth, benefits management, or communication with caseworkers. The provision does not directly cut internet service, but it weakens the SNAP formula’s recognition that internet bills are part of modern household costs.

Effects on Businesses

The most direct business effects are indirect and localized.

Grocery retailers and food retailers could see lower SNAP purchasing power among affected households. Because SNAP benefits are spent quickly and locally, even modest monthly reductions can reduce food spending in communities with high SNAP participation.

Internet service providers are not directly regulated by Section 10104. The section does not cap prices, change broadband subsidies, or alter telecommunications rules. However, by removing SNAP’s recognition of internet costs, it may make broadband harder to afford for some low-income households. That could contribute to pressure on subscription retention among price-sensitive customers, especially after the end of the Affordable Connectivity Program increased broadband affordability challenges for low-income households.[4]

State eligibility-system vendors, call-center contractors, and benefits administration contractors may see implementation work tied to system updates, notices, and training. These are administrative effects rather than new program benefits.

Environmental and Climate Impact

Section 10104 has no direct environmental permitting, energy production, land use, conservation, emissions, or climate funding provision. Its environmental impact is therefore indirect and likely small compared with provisions that directly affect energy or land management.

There are still second-order considerations. Internet access can reduce transportation needs by enabling online benefits management, telehealth, remote work, remote education, and digital document submission. If reduced benefit adequacy makes internet access harder to maintain, some households may need more in-person trips for services that could otherwise be handled online. That effect is plausible but not quantified in the statutory text or the major budget sources reviewed.

The more concrete climate-related conclusion is that Section 10104 does not provide climate funding, does not rescind climate funding, and does not establish a climate reporting mechanism. Its primary impact is food assistance benefit calculation.

Impact Summary

Section 10104 is a formula change with real household consequences. It does not appropriate money or create a new program. Instead, it narrows what counts as an allowable household cost in SNAP, reducing benefits for many households that pay for internet service.

The strongest policy critique is that the section treats internet access as outside the shelter-and-utility cost structure even though modern households often need internet access for work, school, health care, and benefits administration. The strongest administrative concern is that states must reprogram and explain a benefit calculation change that may be hard for households to understand because the excluded expense is still real.

The clearest budgetary effect is lower SNAP spending. The clearest household effect is lower monthly benefits for affected SNAP households. The clearest public-tracking limitation is that the savings will generally appear inside aggregate SNAP spending and eligibility data rather than as a separately visible Section 10104 spending line.

Key References and Sourcing

[1] GovInfo, “H.R. 1 Engrossed Amendment Senate,” Section 10104, https://www.govinfo.gov/content/pkg/BILLS-119hr1eas/html/BILLS-119hr1eas.htm.

[2] Congressional Budget Office, “Estimated Effects of Public Law 119-21 on Participation and Benefits Under the Supplemental Nutrition Assistance Program,” August 11, 2025, https://www.cbo.gov/system/files/2025-08/61367-SNAP.pdf.

[3] American Medical Association, “Summary of Select Provisions and Implementation Dates in Public Law 119-21,” 2025, https://www.ama-assn.org/system/files/select-provisions-implementation-dates-obbba-summary.pdf.

[4] Food Research & Action Center, “H.R. 1 Changes to SNAP — Elimination of the Internet Deduction,” April 2026, https://frac.org/wp-content/uploads/HR-1-SNAP-Elimination-Internet-Deduction.pdf.

[5] Federal Register, “Supplemental Nutrition Assistance Program: Standardization of State Heating and Cooling Standard Utility Allowances,” 2024, https://www.federalregister.gov/d/2024-26845.

[6] USDA Food and Nutrition Service, “One Big Beautiful Bill Act of 2025,” page updated February 24, 2026, https://www.fns.usda.gov/obbb.

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Legislative and Policy Analysis

Section 10103: Availability of standard utility allowances based on receipt of energy assistance

Executive Summary

Section 10103 narrows when receipt of energy assistance can automatically qualify a Supplemental Nutrition Assistance Program household for the Heating and Cooling Standard Utility Allowance, or HCSUA. Before this change, a household generally could use receipt of more than $20 in Low Income Home Energy Assistance Program, or similar energy-assistance, benefits during the current month or prior 12 months as a pathway to the HCSUA. Section 10103 limits that automatic pathway to households that include an elderly or disabled member.[1]

For households without an elderly or disabled member, energy assistance alone no longer automatically establishes HCSUA eligibility. Those households may still qualify if they actually incur heating or cooling costs, but they may need to document those costs through the normal SNAP eligibility process.[2]

The practical effect is a benefit-calculation change, not a direct new appropriation. CBO estimated that Section 10103 will reduce monthly SNAP benefits by roughly $100 for about 3 percent of households, on average, in each year from 2026 through 2034.[3] FRAC estimates the change will cut SNAP benefits for more than 670,000 households.[4]

What Section 10103 Actually Does

Section 10103 amends the Food and Nutrition Act of 2008 in two related ways.

The first change narrows the automatic HCSUA rule. The statutory text inserts “with an elderly or disabled member” into the provision governing households that receive energy assistance, meaning that energy assistance receipt alone automatically triggers the HCSUA only for households with an elderly or disabled member.[1]

The second change addresses third-party energy assistance payments made under state law. USDA guidance explains that, after Section 10103, third-party state energy assistance payments do not count as income for SNAP households with an elderly or disabled member, but households without an elderly or disabled member must continue to count those payments as income. USDA also states that households without an elderly or disabled member may no longer count expenses covered by those payments toward shelter costs for the excess shelter deduction.[2]

The section does not eliminate the HCSUA entirely. Households without an elderly or disabled member may still qualify for the HCSUA if they incur heating or cooling expenses under the Food and Nutrition Act rules. If they do not qualify for the HCSUA, they may qualify for another standard utility allowance or use actual expenses, depending on the state’s SNAP policy.[2]

Legislative Mechanism

Section 10103 is a targeted amendment to SNAP eligibility and benefit-calculation law. It does not create a new program, grant, account, or appropriation. Instead, it changes the statutory conditions under which energy assistance can be used as proof for a utility deduction.

Mechanically, the section amends:

Because SNAP benefits are calculated from household income, deductions, shelter costs, and allotment rules, changing the HCSUA pathway can lower the shelter deduction and therefore lower the SNAP allotment for affected households.

Expenditure Tracking and Reporting Protocol

Section 10103 changes federal SNAP benefit outlays by changing eligibility-calculation rules. It does not provide a stand-alone appropriation, so there is unlikely to be a clean public spending line labeled “Section 10103.”

The likely tracking pathway is through normal SNAP benefit issuance, state eligibility systems, USDA Food and Nutrition Service oversight, Treasury outlays, CBO estimates, SNAP Quality Control reviews, and aggregate USDA program data. Public tracking is likely to be aggregated and difficult to isolate by section because the benefit reduction is embedded inside household-level SNAP calculations.

Likely tracking sources include:

Section 10103 statutory change
        |
        v
USDA FNS implementation guidance
        |
        v
State SNAP agencies update eligibility rules
        |
        v
Caseworkers and eligibility systems review utility deductions
        |
        +-----------------------------+
        |                             |
        v                             v
Household has elderly or        Household does not have
disabled member                 elderly or disabled member
        |                             |
        v                             v
Energy assistance can still     Energy assistance alone no
trigger automatic HCSUA         longer triggers HCSUA
        |                             |
        v                             v
SNAP benefit calculation        Review actual heating or
uses applicable deduction       cooling costs or other SUA
        |                             |
        +--------------+--------------+
                       |
                       v
SNAP allotment issued through normal EBT process
                       |
                       v
Tracked through state systems, USDA, Treasury, QC, CBO
                       |
                       v
Public visibility likely aggregated and delayed

USDA instructed state agencies to apply the policy to new applicants at initial certification immediately after enactment and to apply it to ongoing households no later than the household’s next recertification.[2] USDA also provided a 120-day Quality Control variance exclusion period for misapplication of Section 10103 changes through November 1, 2025, if states implemented within the applicable rules.[2]

Day-to-Day Government Process Changes

For SNAP agencies, this section changes front-line eligibility work. State systems and eligibility workers can no longer treat qualifying LIHEAP or similar energy assistance as automatic proof of HCSUA eligibility for every household. They must first determine whether the household includes an elderly or disabled member.[2]

For households without an elderly or disabled member, agencies may need to collect or evaluate additional information about heating or cooling costs. That can mean new notices, revised interview scripts, updated case-processing rules, system coding changes, and recertification reviews.

The change also makes coordination between SNAP and energy-assistance programs less administratively simple. The prior “receipt of energy assistance” shortcut reduced documentation burdens. Section 10103 keeps that shortcut for elderly or disabled households but removes it for other households.

Effects on Consumers

The main consumer impact is lower SNAP benefits for affected households. CBO estimated that the monthly SNAP benefit will decrease by roughly $100 for about 3 percent of households, on average, each year from 2026 through 2034.[3] That is roughly $1,200 per year for an affected household if the household experiences the full $100 monthly reduction for 12 months.

Affected households are likely to include low-income renters and families who receive energy assistance but do not directly pay a separately billed heating or cooling expense, or who have difficulty documenting those costs. Households with elderly or disabled members retain the automatic HCSUA pathway based on qualifying energy assistance receipt.[2]

Consumer-facing burdens may include:

Effects on Businesses

The section does not directly regulate private businesses. Its business effects are indirect.

Grocery retailers, farmers markets, corner stores, superstores, and other SNAP-authorized retailers may see reduced SNAP purchasing power from affected households. Because SNAP benefits are spent quickly and locally, lower monthly allotments can reduce food sales in communities with high SNAP participation.[5]

Utilities and energy vendors are not directly paid or regulated by this section. However, the section changes how certain energy-assistance payments interact with SNAP benefit calculations. If households have lower SNAP benefits, they may face tighter monthly budgets across food, utilities, rent, and transportation.

Businesses that assist clients with benefits navigation, such as community-based service providers, may also face increased demand for help documenting utility expenses.

Environmental and Climate Impact

Section 10103 has no direct environmental permitting, emissions, energy-production, or climate-infrastructure provision. It does not fund or repeal an energy program.

The climate and environmental effects are indirect. The section weakens the automatic link between energy assistance and SNAP utility deductions for households without elderly or disabled members. In practice, that may reduce the value of an administrative bridge between food assistance and home energy affordability.

During extreme heat or cold, households with lower SNAP benefits may face sharper tradeoffs between food, cooling, heating, and other necessities. The section does not directly change LIHEAP eligibility or funding, but it changes how energy assistance affects SNAP benefit calculations.

Impact Summary

Section 10103 is a technical SNAP deduction change with concrete household consequences. It narrows the automatic HCSUA pathway to households with elderly or disabled members, while requiring other households to qualify through actual heating or cooling expenses or another applicable utility allowance.

The section does not create a new appropriation or direct spending line. Its fiscal effect comes from lower SNAP benefit calculations for affected households. CBO estimated a roughly $100 monthly SNAP benefit decrease for about 3 percent of households, on average, over 2026-2034.[3]

The biggest implementation challenge is administrative: states must update eligibility systems, train staff, revise notices, and distinguish between households that retain automatic HCSUA access and households that must document costs. Public expenditure tracking will likely be aggregated through normal SNAP budget and oversight systems rather than visible as a distinct Section 10103 account.

Key References and Sourcing

[1] Congress.gov, “H.R. 1 — Public Law No. 119-21,” Section 10103, https://www.congress.gov/bill/119th-congress/house-bill/1/text.

[2] USDA Food and Nutrition Service, “SNAP Implementation of the One Big Beautiful Bill Act of 2025 — Treatment of Energy Assistance Payments,” August 29, 2025, https://www.usda.gov/sites/default/files/guidance-documents/fns.SNAP-admin-energy-assistance-payments.pdf.

[3] Congressional Budget Office, “Estimated Effects of Public Law 119-21 on Participation and Benefits Under the Supplemental Nutrition Assistance Program,” August 11, 2025, https://www.cbo.gov/system/files/2025-08/61367-SNAP.pdf.

[4] Food Research & Action Center, “H.R. 1: Changes to the Standard Utility Allowance,” https://frac.org/research/resource-library/hr-1-standard-utility-allowance.

[5] USDA Food and Nutrition Service, “Standard Utility Allowances,” https://www.fns.usda.gov/snap/eligibility/deduction/standard-utility-allowances.

[6] Federal Register, “Supplemental Nutrition Assistance Program: Standardization of State Heating and Cooling Standard Utility Allowances,” November 18, 2024, https://www.federalregister.gov/documents/2024/11/18/2024-26845/supplemental-nutrition-assistance-program-standardization-of-state-heating-and-cooling-standard.

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Legislative and Policy Analysis

Section 10102: Modifications to SNAP work requirements for able-bodied adults

Executive Summary

Section 10102 narrows access to Supplemental Nutrition Assistance Program benefits by expanding the population subject to the able-bodied adult work requirement and by limiting state waiver flexibility. It amends Section 6(o) of the Food and Nutrition Act of 2008, the provision that limits SNAP eligibility to 3 months in a 36-month period unless a covered adult works, participates in qualifying work activities, or qualifies for an exception.[1]

The practical effect is that more adults ages 18 through 64 must document at least 80 hours per month of work, workfare, volunteering, or approved employment and training activity to keep SNAP beyond the time limit.[2] CBO estimates that Section 10102 will reduce SNAP participation by roughly 2.4 million people in an average month over the 2025-2034 period.[3] CBO’s supplemental budget crosswalk reports an estimated federal spending reduction of about $68.6 billion over the 2025-2034 period for Section 10102.[4]

What Section 10102 Actually Does

Section 10102 does not create a new grant, appropriation, loan authority, or direct payment stream. Instead, it changes eligibility rules for an existing mandatory benefit program. The fiscal effect comes from reduced SNAP participation and lower federal benefit outlays.

Substantively, Section 10102 makes four major changes.

First, it revises the list of exceptions from the ABAWD time limit. The new statutory exception applies to individuals who are under 18 or over 65, medically certified as physically or mentally unfit for employment, responsible for a dependent child under 14, otherwise exempt under the general work-requirement provision, pregnant, an Indian or Urban Indian as defined in the Indian Health Care Improvement Act, or a California Indian described in that Act.[1]

Second, it effectively extends the age range affected by the ABAWD work requirement. Before enactment, USDA described the ABAWD rule as applying to certain adults ages 18-54 without dependents, with a requirement to work or participate in qualifying activities for at least 80 hours per month to receive SNAP for more than 3 months in 3 years.[2] CBO explains that Section 10102 expands the requirement to able-bodied adults through age 64 who do not live with dependent children and to adults ages 18 to 64 who live with children age 14 or older.[3]

Third, it removes several prior exceptions. CBO states that Section 10102 eliminates exclusions from work requirements for veterans, people experiencing homelessness, and people ages 18 to 24 who were in foster care when they turned 18.[3]

Fourth, it limits waiver authority. Before the law, states could seek waivers for areas with unemployment above 10 percent or areas without a sufficient number of jobs. Section 10102 restricts waiver flexibility and creates special rules for noncontiguous states, with Alaska and Hawaii able to seek limited exemptions tied to good-faith compliance efforts and subject to expiration no later than December 31, 2028.[1]

Legislative Mechanism

Section 10102 amends 7 U.S.C. 2015(o), the Food and Nutrition Act provision governing the ABAWD time limit. It does not operate by annual appropriations language. It changes the underlying eligibility statute for SNAP, which means state SNAP agencies must apply the revised federal eligibility rules in certification, recertification, case maintenance, notices, compliance tracking, and fair-hearing processes.

The section uses three mechanisms:

1. It replaces the statutory exception list for the ABAWD time limit.
2. It modifies waiver rules, including special treatment for noncontiguous states.
3. It requires quarterly progress reports from noncontiguous states that receive temporary exemptions while moving toward compliance.[1]

Because SNAP benefits are mandatory spending, changing eligibility rules changes federal outlays without Congress separately appropriating or rescinding a Section 10102 funding line.

Expenditure Tracking and Reporting Protocol

Section 10102 affects federal financial flows by reducing SNAP benefits paid through the existing SNAP issuance system. The relevant administering agency is USDA’s Food and Nutrition Service, while state agencies determine eligibility, track compliance, issue notices, and administer case actions. Benefits are federally funded and issued through state-administered Electronic Benefit Transfer systems.

Likely tracking sources include USDA-FNS SNAP participation and benefit data, state SNAP eligibility systems, state quality-control systems, Treasury and OMB budget execution data, CBO estimates, and oversight by USDA’s Office of Inspector General, GAO, and congressional committees. Public tracking will be partly clear at the aggregate SNAP level but difficult to isolate precisely for Section 10102 because benefit reductions will appear as lower participation or lower outlays inside the broader SNAP account rather than as a separately labeled public expenditure line.

Reporting is likely to follow existing SNAP protocols: states report participation, issuance, administrative, and quality-control data to USDA-FNS; USDA publishes national and state-level SNAP data; CBO estimates federal budget effects; and oversight bodies may review implementation. For the special noncontiguous-state exemption, Section 10102 specifically requires quarterly progress reports to the Secretary of Agriculture on milestones, risks, barriers, and mitigation plans.[1]

Section 10102 statutory eligibility change
        |
        v
USDA Food and Nutrition Service guidance
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        v
State SNAP agencies update eligibility systems
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        v
Caseworkers verify exception status and work activity
        |
        v
EBT benefit issuance continues for eligible households
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        v
Lower participation and lower federal benefit outlays
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        v
Tracking through USDA SNAP data, state reports, CBO estimates,
Treasury and OMB budget execution, IG and GAO oversight
        |
        v
Public visibility is partly clear in aggregate SNAP data
but difficult to isolate as Section 10102-only savings

The biggest tracking limitation is attribution. A person may lose or avoid SNAP participation because of work requirements, documentation burdens, state waiver changes, immigration rules, benefit calculation changes, or household changes. Public data may show total participation declines, but not always the exact statutory reason for each case closure.

Day-to-Day Government Process Changes

For USDA, Section 10102 requires guidance, policy memoranda, model notices, waiver review standards, and technical assistance to states. USDA’s OBBB implementation page lists Section 10102 work-requirement guidance, including ABAWD exceptions and ABAWD waiver implementation materials.[5]

For state SNAP agencies, the section increases operational complexity. Eligibility systems must identify adults ages 18 through 64, household child ages, exception status, work activity hours, waiver status, and time-limit months. States must also train eligibility workers and call-center staff, revise notices, update online applications, coordinate with employment and training providers, and prepare for more fair-hearing disputes.

For applicants and recipients, the change turns more routine SNAP interactions into documentation-heavy compliance events. A covered adult may need to prove hours worked, volunteer hours, work-program participation, medical unfitness, pregnancy, responsibility for a child under 14, Tribal or Indian Health Care Improvement Act status, or another exception.

For noncontiguous states, especially Alaska and Hawaii, the law creates a separate temporary compliance pathway. A state may request an exemption based on good-faith efforts, but that exemption can expire, cannot be renewed beyond December 31, 2028, and requires quarterly progress reporting.[1]

Effects on Consumers

The primary consumer impact is reduced access to food assistance for adults who cannot document qualifying work or an exception. CBO estimates a roughly 2.4 million-person average monthly participation reduction over 2025-2034 from Section 10102.[3]

The people most exposed are adults ages 55 through 64 without dependent children, adults in households with children age 14 or older, people in unstable work with fluctuating hours, people whose work is informal or difficult to document, people in areas that previously qualified for waivers, and people who face transportation, caregiving, disability, housing instability, or paperwork barriers.

Consumers may experience:

The policy may also increase churn: people may lose benefits for noncompliance, later regain eligibility, and then cycle through documentation and recertification again. That churn can reduce food security even when a person is legally eligible.

Effects on Businesses

Retail food businesses may see reduced SNAP purchasing power in communities with high numbers of affected adults. SNAP dollars are spent quickly and locally, so benefit reductions can affect grocery stores, corner stores, farmers markets, discount retailers, and food delivery or transportation patterns.

Employers may see some workers seeking more scheduled hours to meet the 80-hour monthly threshold. However, the effect depends on whether employers can offer stable hours, whether workers can document those hours, and whether local job availability matches recipients’ transportation, health, caregiving, and schedule constraints.

Businesses that contract with states for eligibility systems, call centers, document management, employment and training, or compliance analytics may see increased demand. States will need system modifications, worker training, reporting tools, and interfaces with employment and training providers.

Environmental and Climate Impact

Section 10102 has no direct environmental permitting, emissions, land-use, energy, or climate provision. Its environmental effects are indirect and likely small relative to the SNAP program as a whole.

Possible indirect effects include shifts in household food purchasing, increased reliance on emergency food networks, and additional administrative activity by state agencies and nonprofit partners. If households lose benefits, they may make fewer grocery trips or purchase lower-cost foods; food banks may see increased demand and distribution activity. These effects are real for communities but are not the central statutory purpose of the section and are unlikely to be separately measured in federal climate or environmental reporting.

Impact Summary

Section 10102 is a major SNAP eligibility tightening provision. It does not appropriate money; it reduces federal spending by narrowing who can remain eligible for food assistance unless they document work or qualifying activity. CBO estimates about $68.6 billion in federal savings over 2025-2034 and roughly 2.4 million fewer SNAP participants in an average month.[3][4]

The section’s most important practical impact is administrative. It pushes more eligibility decisions onto documentation, state tracking systems, work-hour verification, exception screening, waiver determinations, and case closures. The public will likely see aggregate changes in SNAP participation and federal outlays, but section-specific effects may be difficult to isolate because the reductions will flow through ordinary SNAP eligibility and benefit systems rather than a separately labeled spending account.

Key References and Sourcing

[1] GovInfo, “Public Law 119-21,” Section 10102, https://www.govinfo.gov/content/pkg/PLAW-119publ21/html/PLAW-119publ21.htm.

[2] USDA Food and Nutrition Service, “SNAP Work Requirements,” updated August 29, 2025, https://www.fns.usda.gov/snap/work-requirements.

[3] Congressional Budget Office, “Estimated Effects of Public Law 119-21 on Participation and Benefits Under the Supplemental Nutrition Assistance Program,” August 11, 2025, https://www.cbo.gov/system/files/2025-08/61367-SNAP.pdf.

[4] Congressional Budget Office, “Supplemental Budget Crosswalk for Public Law 119-21,” August 2025, https://www.cbo.gov/system/files/2025-08/61452-Supplemental-Info.xlsx.

[5] USDA Food and Nutrition Service, “One Big Beautiful Bill Act of 2025,” updated February 24, 2026, https://www.fns.usda.gov/obbb.

[6] USDA Food and Nutrition Service, “SNAP Provisions of the One Big Beautiful Bill Act of 2025: ABAWD Exceptions – Implementation Memorandum,” updated February 25, 2026, https://www.fns.usda.gov/snap/obbb-abawd-exemptions-implementation.

[7] USDA Food and Nutrition Service, “SNAP Provisions of the One Big Beautiful Bill Act of 2025: ABAWD Waivers – Implementation Memorandum,” updated February 25, 2026, https://www.fns.usda.gov/snap/obbb-abawd-waivers-implementation.

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