On May 27, 2026, the U.S. Department of Agriculture's Food and Nutrition Service (FNS) published a notice in the Federal Register, inviting public comment on a proposed revision to an existing information collection. This action signals a notable shift in the administrative responsibilities for state agencies participating in the Supplemental Nutrition Assistance Program (SNAP), particularly concerning how they manage Standard Utility Allowances (SUAs) and self-employment income calculations for program beneficiaries.
The Core of the Proposed Changes
This revision updates an already approved information collection under the Paperwork Reduction Act of 1995. Its primary focus is on the reporting and recordkeeping burdens placed upon state agencies as they establish and review SUAs and develop methodologies for offsetting the cost of producing self-employment income. While these mechanisms have long been part of SNAP administration, a key development outlined in a final rule published on November 18, 2024, significantly alters the landscape for SUAs.
Previously, state agencies were required to review and adjust their SUAs annually to reflect changes in utility costs, often utilizing indices such as the Consumer Price Index. The 2024 final rule, however, added a new and substantial requirement: state agencies must now submit their entire SUA methodologies for FNS approval at least every five years. These submissions are not merely administrative formalities. They necessitate a rigorous process to demonstrate that the baseline expenditure data and underlying methodology are current and accurately reflect recent trends and changes. Furthermore, the final rule specifies that these methodologies must:
- Reflect the entire state or the specific geographic area the SUA covers.
- Utilize data sourced from utility providers or other similarly reliable sources.
- Accurately reflect expenses incurred by low-income households.
- Specifically account for residential utility expenses.
For self-employment income, SNAP regulations at 7 CFR 273.11(b) mandate that state agencies exclude the cost of producing such income when calculating a household's net income. States are allowed, with FNS approval, to establish their own methodologies for this offset, provided the procedure does not increase program costs. This aspect of the collection also sees updated burden estimates.
Anticipated Impact on State Agencies: An Increased Burden
FNS's notice provides detailed estimates of the projected annual burden hours for state agencies, highlighting a substantial increase in overall administrative effort. The total annual burden for both reporting and recordkeeping is projected to rise to 2,131.25 hours, marking an increase of 743 hours compared to the previous collection.
Specifically, the estimated burdens are broken down as follows:
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Self-Employment Methodology: FNS estimates that five state agencies annually will establish a new methodology or update an existing one for offsetting self-employment income costs. Each response is estimated to take 10 hours, totaling 50 annual burden hours for this activity.
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Annual SUA Updates: All 53 state agencies are expected to continue submitting preliminary and final annual updates to their SUAs, reflecting year-to-year changes in utility costs. This activity is estimated at 10 hours per response, with two responses per agency, leading to 1,060 annual hours. This actually represents a decrease of 265 hours from the previous estimate, as the comprehensive methodology updates are now separated.
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Five-Year SUA Methodology Updates: This is where the bulk of the increased burden lies. All 53 state agencies must now submit full baseline SUA methodologies every five years. FNS estimates that each agency will require 40 hours per submission, with two submissions per cycle (preliminary and final), totaling 4,240 hours over five years. When annualized, this contributes 848 hours annually, a direct increase attributed to the November 2024 final rule.
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Contractor Support for SUA Methodologies: Recognizing the complexity of these new five-year updates, FNS anticipates that some state agencies will need to solicit contractor support for data analysis and methodology revision. FNS estimates five state agencies annually will engage contractors, spending approximately 160 hours each to solicit, award, and manage these contracts. This adds an annualized burden of 160 hours.
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Recordkeeping: All 53 state agencies are required to maintain one record of information submitted, with an estimated 0.25 hours per record, leading to 13.25 annual recordkeeping hours.
This shift underscores the federal government's commitment to ensuring that SUAs accurately reflect current costs for low-income households, while simultaneously placing a greater analytical and reporting demand on state administrators. The move to discontinue OMB Control Number 0584-0651, as noted by FNS, aims to streamline and consolidate duplicative information collections, ensuring a more organized approach despite the increased overall burden.
Opportunity for Public Input
The FNS notice serves as an official invitation for public comment on this proposed information collection. Interested parties, including state and local governments, tribal governments, and other public agencies, have until July 27, 2026, to submit their feedback. FNS is particularly interested in comments addressing:
- The necessity and practical utility of the proposed information collection.
- The accuracy of the agency's burden estimates and the validity of its methodology.
- Ways to enhance the quality, utility, and clarity of the information to be collected.
- Strategies to minimize the burden on respondents, including the use of appropriate automated or electronic collection techniques.
All submitted comments will be summarized and included in the request for Office of Management and Budget (OMB) approval, becoming part of the public record. This comment period represents a critical juncture for stakeholders to influence the final shape of these reporting requirements, ensuring they are both effective for federal oversight and manageable for state agencies.
