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How do I document utility expenses (electric, gas, water) for SNAP in 2025?
Executive summary
States usually use a state-set Standard Utility Allowance (SUA) when calculating SNAP shelter deductions; most states require the SUA rather than actual bills, but in states that allow actual expenses you must document every claimed cost [1]. Recent federal changes in 2025 — including a final rule standardizing heating/cooling SUAs, additions and removals of what counts, and the One Big Beautiful Bill Act (OBBB) — mean states updated SUAs for FY2026 and changed treatment of certain third‑party payments; applicants who do claim actual heating/cooling expenses may need to provide documentation and states must apply new rules at certification or recertification [2] [3] [4].
1. What rules control whether you show bills or accept the state SUA?
Federal SNAP rules let states set SUAs and in most states using an SUA is mandatory; only in states that permit an “optional SUA” or allow actual expenses can a household submit bills for actual utility costs — and if actual costs are claimed the state requires documentation of all claimed costs [1]. The Food and Nutrition Service (FNS) guidance to states for FY26 encourages states to update SUA values using the CPI adjustment, and discourages substantially different methods [3]. State practice therefore determines whether you must supply bills or can rely on the standard amount [1] [3].
2. What changed in 2024–2025 that affects documentation and which utilities count
A November–January federal rule standardized heating and cooling SUAs and added basic internet as an allowable utility in the SUA framework; FNS gave states through their next Cost of Living Adjustment (Oct. 1, 2025) to implement updated SUAs and reporting methods [2]. But the OBBB law enacted July 4, 2025, also changed SNAP treatment of certain third‑party energy assistance payments and prohibited treating internet costs as an allowable shelter expense for the excess shelter deduction under some provisions — creating competing regulatory effects that states had to reconcile when updating SUAs for FY26 [2] [3] [4].
3. Who specifically needs to provide receipts, bills, or other paperwork?
If your state allows actual utility expenses instead of the SUA, the household must provide documentation for all claimed costs — that is, bills, receipts, or other proof covering each utility dollar claimed [1]. FNS directed state agencies to apply statutory changes immediately for new applicants and at the next recertification for ongoing cases, so expect states to request verification during application or recertification periods [4] [3].
4. What counts as an allowable utility for the deduction — and where are disagreements?
FNS lists heating/cooling fuel, electricity, water/sewer and other utility costs as items that may be included in SUA calculations, and states may create different SUAs (for example, telephone-only vs. heating/cooling SUA) — but they cannot count the same expense under two standards [5]. The final rule added basic internet to SUA options, which advocacy groups viewed as helpful [2]. However, the OBBB law contains language that restricts treating internet costs as allowable for the excess shelter deduction in certain contexts, forcing states to follow FNS implementation guidance and statutory limits [3] [4]. Advocacy groups warned that the SUA resets could reduce benefits for some households, while FNS focused on standardized methods and CPI adjustments [2] [3].
5. Practical steps to document utilities for SNAP in 2025
- Check your state SNAP agency’s SUA policy first: whether the state uses mandatory SUA, optional SUA, or accepts actual expenses (not all states are the same) [1].
- If your state accepts actual expenses, collect utility bills (electric, gas, water, sewer, fuel, and any state‑allowed items) covering the certification month[6]; provide payment receipts or screenshots if online payments were used — states require documentation for all claimed costs [1].
- Expect states to request proof at application and again at recertification because FNS expects agencies to apply FY26 SUA updates during certification cycles [4] [3].
- If you share utilities with others, state guidance and legal-help resources show households may still receive the full SUA or may have rules about splitting responsibility — check your state manual or legal help page for details [7] [8].
6. Pitfalls, tradeoffs and who benefits or loses
Using the state SUA is administratively simpler and often mandatory; claiming actual expenses requires paperwork and may yield a higher deduction only if your verified costs exceed the SUA [1]. The FY25–FY26 regulatory adjustments and the OBBB statutory changes have created winners and losers: some households (especially those with higher heating costs, and some with elderly or disabled members) may see changes in benefit levels after SUAs are reset, while FNS urged standardized CPI‑based updates to avoid arbitrary state variance [2] [3]. Advocacy groups warned lower SUAs could reduce benefits; FNS framed its guidance around orderly implementation [2] [3].
Limitations: available sources do not provide a state-by-state list of which states require SUAs versus accept actual expenses; check your state SNAP office for exact documentation lists and forms (not found in current reporting).