What documentation do states require to claim actual utility expenses for SNAP after 2024 verification changes?
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Executive summary
The 2024–25 regulatory changes shifted SNAP toward standardized utility allowances (SUAs) but preserved a path for households to claim actual utility costs — with states insisting on verifiable documentation when households pursue actual expenses instead of the SUA; specifics vary by state and are governed by FNS guidance and a 2025 statute that narrowed automatic SUA qualification [1] [2] [3]. Federal rulemaking and subsequent congressional action also produced a conflict over internet costs that changes what counts and how states must document claims [4] [5].
1. What the federal rule changed and the paper trail states must follow
A November 2024 final rule required states to adopt transparent methodologies for setting SUAs, to update those methodologies regularly, and to include internet as an allowable basic utility in their calculations — but it did not eliminate the option for households to claim actual bills; when a state allows actual-cost claims, the federal guidance explicitly requires documentation for all claimed costs [6] [3] [1]. The Food and Nutrition Service (FNS) instructed states to submit methodologies for approval and to implement updated SUAs by Oct. 1, 2025, while reminding states that in jurisdictions where SUAs are optional, households choosing actual expenses must substantiate every line item they claim [3] [5] [1].
2. What documentation states generally require when households claim actual utility expenses
Federal materials and state policy examples show a common pattern: paper or electronic evidence of payment or obligation — utility bills, receipts, vendor statements, or evidence of vendor payments — is required to support claimed heating, cooling, water/sewer, electricity, and related costs; some state manuals explicitly permit LIHEAP (energy assistance) records or vendor-paid portions to be counted but stress documentation of the household’s responsibility for the expense [1] [7]. The FNS guidance warns states to design SUAs and alternative documentation rules to reflect low‑income household conditions and to retain documentation standards that allow verification during eligibility reviews [3] [6].
3. How 2025 legislation narrowed automatic qualification and raised documentation burdens
The One Big Beautiful Bill Act of 2025 (referred to in FNS memos) changed who automatically qualifies for the heating and cooling SUA: previously households receiving certain energy-assistance benefits automatically got the HCSUA; after the statute, automatic qualification was limited to households with elderly or disabled members, while other households must now provide documentation of their heating and cooling expenses to claim that allowance or to have actual costs included [2] [5]. The legislative change therefore shifts more applicants into a documentation pathway and increases the administrative role of both caseworkers and applicants in proving expenses [2].
4. The internet wrinkle: conflicting rulemaking and statute that affects documentation
Regulatory finalization had added basic internet as an allowable utility for SUA purposes and urged states to include a basic internet allowance to reflect modern needs, which would have been incorporated into SUAs to avoid per‑household bill verification; but the July 2025 statute then prohibited treating internet costs as an allowable shelter expense for the excess shelter deduction, creating a direct tension between FNS rule intent and congressional action [4] [5]. That conflict matters for documentation because it changes whether internet bills can be counted at all and whether states must collect internet bills from applicants pursuing actual-cost claims — FNS guidance and state plans are the only source to resolve how each jurisdiction will treat internet documentation [5] [3].
5. Where the record is thin and what states are doing in practice
Federal guidance provides the framework, and state manuals (for example Virginia and Texas) show typical operational practices — specific SUA dollar values and examples of allowable documentation — but the sources do not enumerate a single, uniform checklist of exact documents every state must accept; instead, states retain discretion to define acceptable bills, receipts, or vendor statements and to require originals, copies, or electronic records in their application processes [7] [8] [1]. Given that variability, the most reliable claim supported by the record is procedural: if a household opts to claim actual utility expenses where SUAs are optional or where the household doesn’t qualify automatically, it will need verifiable documentation of each utility cost claimed, and the precise acceptable forms are set at the state level under FNS oversight [1] [3] [6].
Conclusion
After the 2024 rule and 2025 statutory changes, the default for many states remains the SUA as a simplifier, but the pathway to claim actual utility expenses survives only with documentation: utility bills, proof of payment, vendor statements, or comparable evidence accepted by the state agency, with the precise list and standards determined by each state’s implementation plan submitted to and overseen by FNS — and with the added complication that Congress’s 2025 law narrowed automatic SUA access and restricted internet’s role, forcing more households into documentation-dependent claims [1] [2] [5] [3] [6].