Public Comment to the U.S. Department of Agriculture Regarding Proposed Standardization of Supplemental Nutrition Assistance Program (SNAP) State Heating and Cooling Standard Utility Allowances (SUA)

The Center for Community Solutions

November 27, 2019

Comments authored by: Tara Britton, Director of Public Policy and Advocacy

As a nonpartisan, nonprofit think tank focused on health, social and economic issues throughout Ohio, The Center for Community Solutions welcomes this opportunity to submit public comment on the United States Department of Agriculture’s (USDA) proposed rule, Supplemental Nutrition Assistance Program (SNAP): Standardization of State Heating and Cooling Standard Utility Allowances (SUA) (RIN: 0584-AE69).

This proposed change to standardize the standard utility allowance (SUA) would limit states’ ability to respond to varying utility costs across the country, running counter to Congressional intent. As a result, $4.5 billion would be cut from SNAP over 5 years resulting in 7 million people in 3 million households experiencing a benefit cut. Ohio is one of 16 states that would be most impacted by this proposed change.[1]

SNAP, as evidenced by its name, is intended to only provide for a portion of a household’s food. This change to the SUA, if it went into effect today, would threaten the overall wellbeing of 272,000 Ohioans by reducing their SNAP benefits. It is important to take a closer look at how this would impact specific populations:

  • Nearly 40 percent of all SNAP households with children would experience a benefit cut, as would over half of all SNAP households with older adult members and nearly 61 percent of households with members who have disabilities.[2]
  • The average reduction in benefits for these households ranges from $40 to $43 a month. This constitutes a significant portion of Ohio’s average monthly issuance of $127.[3]

The USDA states that the differences in how states calculate SUAs varies so much that this standardization is necessary to provide equitable benefits across the nation, but Food and Nutrition Services (FNS), within USDA, currently has the authority to work directly with states on their SUAs. FNS can work directly with any states that are determined to calculate SUAs inaccurately or with outdated measurements to adjust their approach.

Finally, capping the SUA at the 80th percentile of actual household utility costs is arbitrary and counter to the intent of the law. This translates to 20 percent of low income households having utility expenses beyond what is counted in their shelter deduction, reducing the amount of SNAP benefits they receive. This change is inconsistent with FNS policy that SUAs should account for nearly all household utility costs.

The enactment of the proposed rule would reduce access to basic nutrition assistance for low- income families with children and people with fixed incomes, predominately older adults and individuals with disabilities. SNAP is a crucial component of the safety net and the SUA has made it possible for states to appropriately respond to differing utility costs across the country.

[1] FNS Regulatory Impact Analysis –

[2] CBPP analysis of the FY 2017 SNAP Quality Control Data