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Extend SNAP Heat and Eat SUA treatment to 12 more states#8132

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add-snap-heat-and-eat-states
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Extend SNAP Heat and Eat SUA treatment to 12 more states#8132
PavelMakarchuk wants to merge 5 commits intomainfrom
add-snap-heat-and-eat-states

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Summary

Extends the SNAP Heat and Eat (H&E) "always apply the Standard Utility Allowance" treatment to 12 jurisdictions that operate H&E but were missing from gov.usda.snap.income.deductions.utility.always_standard — previously only Colorado was marked true.

Closes #8131.

States added (12)

State Effective Rationale
CA 2015-10-01 Pre-2014 H&E ($6.1M committed post-Farm-Bill per LIHEAP Clearinghouse)
CT 2015-10-01 Raised nominal LIHEAP $1→$20.01 in Mar 2014 (Gov. Malloy)
DC 2015-10-01 Pre-2014 H&E state
MA 2015-10-01 Pre-2014 H&E state
MD 2015-10-01 Pre-2014 H&E state
ME 2015-10-01 Maine officials confirmed preservation post-Farm-Bill
MI 2015-10-01 Pre-2014 H&E state
NY 2015-10-01 Raised LIHEAP to $20.01 in Feb 2014 (Gov. Cuomo, $6M)
OR 2015-10-01 Pre-2014 H&E state
PA 2015-10-01 Pre-2014 H&E state
RI 2015-10-01 Pre-2014 H&E state
WA 2015-10-01 Pre-2014 H&E state

All 12 operated H&E continuously since before our parameter coverage starts (2015-10-01) and preserved it after the 2014 Farm Bill raised the nominal LIHEAP minimum to $20.01.

Montana (also currently H&E per FRAC) is excluded from this PR pending primary-source verification of its start date — it's not in the 2014 LIHEAP Clearinghouse list of pre-Farm-Bill states, so adding it at 2015-10-01 would likely overstate coverage. Follow-up issue/PR recommended.

Legal basis

OBBBA caveat (not in scope for this PR)

OBBBA Section 10004 (signed July 4, 2025) restricts H&E SUA to households containing an elderly (60+) or disabled member, effective per FNS guidance. That's a household-level restriction, not a state-level one, and requires variable-level changes (condition on has_usda_elderly_disabled). Should be a separate PR.

Test plan

  • 6 test cases in snap_state_using_standard_utility_allowance.yaml covering CA/NY/PA/CO (pre-2024-10 and post), TX — all pass
  • All 294 SNAP tests pass
  • 3 snap_excess_shelter_expense_deduction.yaml tests that relied on the default state (CA) pinned to TX so they continue exercising the non-H&E path
  • State tax tests for all 12 affected jurisdictions pass (CA: 526, NY: 303, MA: 354, MD: 200, ME: 393, MI: 323, OR: 269, PA: 222, RI: 317, WA: 153, CT: 462, DC: 300 — 3,822 total, 0 failures)
  • make format clean

🤖 Generated with Claude Code

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codecov Bot commented Apr 22, 2026

Codecov Report

✅ All modified and coverable lines are covered by tests.
✅ Project coverage is 71.79%. Comparing base (20705b0) to head (2c669fd).
⚠️ Report is 15 commits behind head on main.

Additional details and impacted files
@@             Coverage Diff             @@
##             main    #8132       +/-   ##
===========================================
- Coverage   85.36%   71.79%   -13.57%     
===========================================
  Files           3     4553     +4550     
  Lines          41    66183    +66142     
  Branches        2      336      +334     
===========================================
+ Hits           35    47517    +47482     
- Misses          6    18659    +18653     
- Partials        0        7        +7     
Flag Coverage Δ
unittests 71.79% <ø> (-13.57%) ⬇️

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Previously only Colorado (effective 2024-10-01) was marked as a Heat
and Eat state in gov.usda.snap.income.deductions.utility.always_standard.
Per FRAC and LIHEAP Clearinghouse, 12 additional jurisdictions with
long-standing Heat and Eat programs should receive the same treatment:

  CA, CT, DC, MA, MD, ME, MI, NY, OR, PA, RI, WA

All are set to true effective 2015-10-01 (the file's baseline date)
since each operated Heat and Eat continuously before that date and
preserved it after the 2014 Farm Bill raised the nominal LIHEAP
minimum to $20.01.

Montana (also currently H&E per FRAC) is excluded here pending
primary-source verification of its start date; it should be added
in a follow-up.

Three snap_excess_shelter_expense_deduction tests that relied on
the default state (CA) are pinned to TX so they continue exercising
the non-H&E path.

References: Issue #8131; 7 CFR §273.9(d)(6)(iii)(E); FRAC blog
'Cuts to Utility Deductions in SNAP'; LIHEAP Clearinghouse brief
'A New Framework for Heat and Eat' (2014).

Co-Authored-By: Claude Opus 4.7 (1M context) <noreply@anthropic.com>
@PavelMakarchuk PavelMakarchuk force-pushed the add-snap-heat-and-eat-states branch from c25ca78 to faf28d8 Compare April 22, 2026 14:47
PavelMakarchuk and others added 4 commits April 22, 2026 13:50
Replaces the multi-sentence description with a single declarative
sentence, spells out SNAP in the description (standard per PE
parameter-patterns skill), and makes the label descriptive.

Co-Authored-By: Claude Opus 4.7 (1M context) <noreply@anthropic.com>
Drops the FRAC blog (nonprofit advocacy; not a primary source) and adds
the 2014 Farm Bill § 4006(b) statute that established the $20.01 minimum
LIHEAP benefit required for SUA eligibility. Retains the federal
regulation, the USDA State Options Report, and the LIHEAP Clearinghouse
technical brief (hosted at acf.gov, invoked under the 'unless no
official source exists' exemption since no consolidated federal list
of Heat and Eat states is published).

Co-Authored-By: Claude Opus 4.7 (1M context) <noreply@anthropic.com>
Same fix as for snap_excess_shelter_expense_deduction: the tests used
the default state (CA), but CA is now a Heat and Eat state after this
PR, so SUA is always applied regardless of heating/cooling expenses.
Pinning to TX preserves the pre-H&E assumption that snap_deductions
only reflects the explicitly-set standard + child support amounts.

Co-Authored-By: Claude Opus 4.7 (1M context) <noreply@anthropic.com>
Verified against ACF LIHEAP Reports to Congress FY2016-FY2022 (Part III,
Household Data, Table 3 footnote on nominal SNAP benefits):

- Michigan first appears as a nominal-SNAP-benefit state in FY2017 (not
  FY2016), so the correct start date is 2016-10-01, not 2015-10-01.
- Montana is listed in every LIHEAP RTC from FY2016 through FY2022
  ($25 nominal benefit to SNAP households), so it belongs in the list.
  Earlier PR excluded MT citing "no primary-source start date" — the
  RTC footnotes are the primary source and support 2015-10-01.

California, Maryland, and DC never appear in any FY2016-FY2022 RTC.
FRAC's April 2026 list notes these states operate Heat and Eat "using
LIHEAP or state-funded energy assistance" — the state-funded mechanism
wouldn't show up in federal LIHEAP reporting, so their start dates
require state-plan-level verification. Not included in this PR.

Co-Authored-By: Claude Opus 4.7 (1M context) <noreply@anthropic.com>
@PavelMakarchuk PavelMakarchuk requested a review from hua7450 April 27, 2026 13:53
@PavelMakarchuk PavelMakarchuk marked this pull request as ready for review April 27, 2026 13:53
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Add SNAP Heat and Eat SUA treatment for the 13 other H&E states

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