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.
| Program or activity | Amount | What the money supports |
|---|---|---|
| SNAP household benefit calculation through HCSUA | No new appropriation stated in the section | The section changes how shelter and utility deductions are calculated for certain SNAP households, which can reduce monthly SNAP benefit amounts. |
| Estimated affected SNAP benefits | Roughly $100 per month benefit decrease for about 3 percent of households | CBO estimates lower monthly SNAP benefits for affected households over the 2026-2034 period.[3] |
| Estimated affected households | More than 670,000 households | FRAC estimates the LIHEAP-SUA change will reduce benefits for more than 670,000 households.[4] |
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:
| Legal provision changed | Operational effect |
|---|---|
| Food and Nutrition Act of 2008, Section 5(e)(6)(C)(iv)(I) | Limits automatic HCSUA availability based on energy assistance receipt to households with an elderly or disabled member.[1] |
| Food and Nutrition Act of 2008, Section 5(k)(4) | Changes how state-law third-party energy assistance payments are treated for SNAP income and shelter-deduction purposes, based on whether the household has an elderly or disabled member.[1] |
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:
| Tracking source | What it may show | Visibility limitation |
|---|---|---|
| State SNAP eligibility systems | Household utility deduction category, HCSUA eligibility, certification and recertification actions | Usually not public at household level. |
| USDA Food and Nutrition Service oversight | Implementation guidance, state compliance, Quality Control treatment | Public guidance exists, but state-level operational detail may vary. |
| Treasury and USDA budget execution | Aggregate SNAP benefit outlays | Section-specific savings may not be separately visible. |
| CBO estimates | Estimated benefit and participation effects | CBO provides national estimates, not household-level case records. |
| SNAP Quality Control | Error-rate and variance treatment during implementation | QC findings may be delayed and aggregated. |
Section 10103 statutory change
|
v
USDA FNS implementation guidance
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v
State SNAP agencies update eligibility rules
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v
Caseworkers and eligibility systems review utility deductions
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+-----------------------------+
| |
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
| |
+--------------+--------------+
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v
SNAP allotment issued through normal EBT process
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v
Tracked through state systems, USDA, Treasury, QC, CBO
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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:
| Consumer issue | Likely effect |
|---|---|
| Documentation | More households may need to show heating or cooling costs. |
| Benefit adequacy | Lower deductions can reduce SNAP allotments. |
| Administrative churn | Households may lose the HCSUA at recertification if costs are not documented. |
| Utility-food tradeoff | Some households may have less food assistance while still facing energy costs. |
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
| Source | Relevance |
|---|---|
| Congress.gov, H.R. 1 Public Law text | Primary statutory text for Section 10103 and the amendments to the Food and Nutrition Act of 2008. |
| USDA Food and Nutrition Service, Treatment of Energy Assistance Payments | Federal implementation guidance explaining how state SNAP agencies must apply Section 10103. |
| Congressional Budget Office, Estimated Effects of Public Law 119-21 on SNAP | CBO estimate of Section 10103’s effect on monthly SNAP benefits and affected households. |
| USDA Food and Nutrition Service, Standard Utility Allowances | Explains how SUAs function in SNAP eligibility and benefit calculations. |
| Food Research & Action Center, H.R. 1: Changes to the Standard Utility Allowance | Secondary policy analysis estimating household impact and explaining benefit consequences. |
| Federal Register, SNAP Standardization of State Heating and Cooling Standard Utility Allowances | Background on the pre-OBBBA regulatory framework for SUAs and energy-assistance treatment. |
[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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