How do individual states set Standard Utility Allowances (SUAs) for SNAP and how often are they updated?
Executive summary
States set Standard Utility Allowances (SUAs) for SNAP by developing a methodology that estimates typical low-income household utility costs and submitting amounts and methods to USDA’s Food and Nutrition Service (FNS) for approval; federal rules require states to review and adjust SUA dollar amounts at least annually and to resubmit their underlying methodologies for FNS approval at least every five years [1] [2]. Recent federal rulemaking standardized minimum methodological criteria, added internet as an allowable utility in many cases, and clarified timelines and approval processes while preserving substantial state flexibility [3] [4].
1. How states actually pick the dollar figures: state-created methodologies, data choices, and flexibility
States are responsible for constructing SUA dollar values by choosing a methodology intended to reflect typical utility expenditures for low-income households—states may rely on energy surveys, federal data, or hybrid approaches developed from studies such as FNS’s Methods to Standardize State Standard Utility Allowances [5] [6]. Current regulations do not force a single data source or formula; instead, FNS has historically allowed “considerable latitude” for states to balance administrative simplicity against accuracy, while expecting the SUA to reduce error rates in benefit determinations [1] [4].
2. The annual review requirement: update amounts each year to reflect cost changes
Federal rules mandate that state agencies review SUA amounts at least annually and adjust the dollar values to reflect changes in the cost of utilities, rounding to the nearest dollar, and must provide changed amounts to FNS when they are adopted [1] [7]. FNS guidance for FY26 even authorized a simplified approach—states may adjust FY25 values by the CPI change from June 2024 to June 2025 for expedited approval—underscoring that year‑to‑year updates are the norm [3].
3. The five-year methodological checkpoint: periodic reapproval and baseline data standards
While dollar values are updated yearly, the underlying methodologies must be formally submitted to and approved by FNS at least every five years; the 2024 final rule requires methodology submissions to demonstrate that baseline expenditure data and analytic approaches reflect recent trends and to meet specified data-quality standards [2] [8]. This two‑tier system—annual numeric updates plus quinquennial methodology resubmissions—aims to preserve stability while forcing periodic modernization of how SUAs are calculated [6].
4. New policy frictions: internet inclusion, federal standardization, and political pushback
The final rule adopted in late 2024 standardizes methodological criteria and encouraged states to include a basic internet component in SUAs beginning Oct. 1, 2025—something advocates argue reflects modern household needs [3] [9]. However, subsequent political developments referenced in FNS materials complicate the picture: one document notes a law (cited as enacted July 4, 2025) that would bar states from counting internet costs as an allowable shelter expense for excess shelter deductions, creating potential conflicts between FNS rulemaking and later statutory limits [3]. Source materials indicate states still keep flexibility on whether and how to adopt internet allowances and that impacts will vary by state [4].
5. Administrative mechanics and safeguards: approvals, reporting, and options for smoothing changes
States must notify FNS when they change SUA amounts and need FNS approval when they change methodologies; FNS also provides technical assistance, templates, and an approval pathway intended to expedite FY26 values [3] [10]. FNS recognizes that abrupt annual adjustments could reduce benefits for unchanged households and has previously allowed phased or staggered implementation to preserve benefit stability in unusual cost shifts [7].
6. Points of contention and where reporting is thin
Advocates warn that tightening methodological standards or excluding certain costs could lower benefits for some households, while FNS argues standardization improves integrity and comparability across states [9] [4]. The sources document these positions, but they do not resolve which specific state methodologies will change outcomes in which jurisdictions; state-by-state impacts depend on each agency’s data choices and timing, information not uniformly published in the cited federal materials [6] [4].