** 08/19/25 - NASBO Washington Report - Reconciliation Resources + FNS Releases SNAP Guidance Documents + Rising Construction Costs: Analyzing the Contributors to Cost Escalations and the Impact on Federal Transportation Infrastructure Investments

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Aug 19, 2025, 11:46:10 PMAug 19
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Reconciliation Resources

Following enactment of H.R. 1, the One Big Beautiful Bill Act (OBBBA), several resources have been released examining potential impacts of the bill and providing implementation resources.
  • The Food and Nutrition Service (FNS) issued questions and answers for the Supplemental Nutrition Assistance Program (SNAP) Education and Obesity Prevention Grant Program (SNAP-Ed). The law ended required funding of the program with the fiscal year 2025 grant allocation. FNS is requesting state agencies provide notification of intent to close their fiscal year 2025 SNAP-Ed grant and return unexpended grant funding.
  • The Treasury Department and Internal Revenue Service (IRS) issued guidance, consistent with the executive order “Ending Market Distorting Subsidies for Unreliable, Foreign-Controlled Energy Sources,” regarding when construction of an applicable wind facility or solar facility has begun for purposes of determining whether such facility is subject to credit termination provisions added by OBBBA.
  • The Congressional Budget Office (CBO) published a report examining the effects of a potential sequestration in accordance with the Statutory Pay-As-You-Go Act of 2010 that could occur as a result of enactment of OBBBA. Federal Funds Information for States (FFIS) also published a brief on the topic (subscription required).
  • The Congressional Research Service (CRS) published a report examining changes in the law that affect marginal effective tax rates on investment.
  • The National Association of Medicaid Directors (NAMD) released a Medicaid policy timeline, outlining key Medicaid policy changes in the law, along with upcoming deadlines for state and territory agencies.

FNS Releases SNAP Guidance Documents

Last week the Food and Nutrition Service (FNS) released three guidance documents for the Supplemental Nutrition Assistance Program (SNAP). The documents include the Quality Control Error Tolerance Threshold for fiscal year 2026, which sets a monetary threshold for determining which quality control errors are included in the calculation of payment error rates. The next memo provides the fiscal year 2026 Cost-of-Living Adjustments (COLA) to the SNAP maximum allotments, income eligibility standards, and deductions. The COLAs are effective as of October 1, 2025. The final memo examines a simplified process for fiscal year 2026 Standard Utility Allowance (SUA) values and notes FNS is reviewing SNAP regulations pertaining to SUAs to determine changes necessary to comply with the One Big Beautiful Bill Act (OBBBA).  






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August 19, 2025

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This Week in DC  

The House and Senate are out until September.

Reconciliation Resources

Following enactment of H.R. 1, the One Big Beautiful Bill Act (OBBBA), several resources have been released examining potential impacts of the bill and providing implementation resources.
  • The Food and Nutrition Service (FNS) issued questions and answers for the Supplemental Nutrition Assistance Program (SNAP) Education and Obesity Prevention Grant Program (SNAP-Ed). The law ended required funding of the program with the fiscal year 2025 grant allocation. FNS is requesting state agencies provide notification of intent to close their fiscal year 2025 SNAP-Ed grant and return unexpended grant funding.
  • The Treasury Department and Internal Revenue Service (IRS) issued guidance, consistent with the executive order “Ending Market Distorting Subsidies for Unreliable, Foreign-Controlled Energy Sources,” regarding when construction of an applicable wind facility or solar facility has begun for purposes of determining whether such facility is subject to credit termination provisions added by OBBBA.
  • The Congressional Budget Office (CBO) published a report examining the effects of a potential sequestration in accordance with the Statutory Pay-As-You-Go Act of 2010 that could occur as a result of enactment of OBBBA. Federal Funds Information for States (FFIS) also published a brief on the topic (subscription required).
  • The Congressional Research Service (CRS) published a report examining changes in the law that affect marginal effective tax rates on investment.
  • The National Association of Medicaid Directors (NAMD) released a Medicaid policy timeline, outlining key Medicaid policy changes in the law, along with upcoming deadlines for state and territory agencies.
 
 

Appellate Court Rules Only GAO Can Sue Over Funding Freezes

Last week the U.S. Court of Appeals for the District of Columbia ruled 2-1 that only the U.S. Government Accountability Office (GAO) may sue the administration over funding freezes. The decision was made in a case brought by plaintiffs affected by a freeze in foreign aid spending. The ruling finds that under the Impoundment Control Act (ICA) only the Comptroller General (the head of the GAO) can sue when the administration withholds funds approved by Congress. A press clip on the ruling can be found here.
 
 

Administration Launches Initiative on State Laws Affecting Economic Activity

On Friday the Department of Justice (DOJ) and the National Economic Council (NEC) announced an effort to identify state laws that significantly and adversely affect the national economy or interstate economic activity and to solicit solutions to address such effects. The announcement highlights multiple executive orders addressing regulatory burdens and invites the public to provide input to aid in the administration’s efforts to alleviate the burdens. This request for comments seeks information pertaining to state laws, regulations, causes of action, policies, and practices that adversely affect interstate commerce and business activities in other states. Comments must be submitted by September 15 and will be posted here.
 
 

Treasury Updates CPF, ERA Reporting Resources

The Treasury Department recently updated reporting resources for the Capital Projects Fund (CPF) and Emergency Rental Assistance 2 (ERA2) programs. For CPF, the department updated the Compliance and Reporting Guidance, with updates outlined in the Revision Log on pg. 19. For ERA2, the department published the ERA2 Final Report User Guide, which provides step-by-step guidance on completing and submitting the ERA2 Final Report.
 
 

CMS Issues Medicaid Managed Care Rate Development Guide

Last week the Centers for Medicare and Medicaid Services (CMS) released the 2025-2026 Medicaid Managed Care Rate Development Guide. The guide is a resource for states to use when setting capitation rates with managed care plans for the care beneficiaries receive through Medicaid managed care programs. The guide provides details about information that must be included in the states’ actuarial rate certifications for CMS to review and approve for rating periods between July 1, 2025, and June 30, 2026.
 
 

Education Proposes New Conditions for Public Service Loan Forgiveness Program

On Monday the Department of Education (ED) issued a notice of proposed rulemaking that would prevent benefits under the Public Service Loan Forgiveness (PSLF) program from being provided to borrowers whose employers are engaged in activities with a substantial illegal purpose. The proposed rule would clarify the definition of a qualifying employer, define activities that have a substantial illegal purpose, address the impact on borrower eligibility, and ensure employers are given notice and the opportunity to respond to an adverse finding. Comments on the proposed rule are due by September 17.
 
 

FNS Releases SNAP Guidance Documents

Last week the Food and Nutrition Service (FNS) released three guidance documents for the Supplemental Nutrition Assistance Program (SNAP). The documents include the Quality Control Error Tolerance Threshold for fiscal year 2026, which sets a monetary threshold for determining which quality control errors are included in the calculation of payment error rates. The next memo provides the fiscal year 2026 Cost-of-Living Adjustments (COLA) to the SNAP maximum allotments, income eligibility standards, and deductions. The COLAs are effective as of October 1, 2025. The final memo examines a simplified process for fiscal year 2026 Standard Utility Allowance (SUA) values and notes FNS is reviewing SNAP regulations pertaining to SUAs to determine changes necessary to comply with the One Big Beautiful Bill Act (OBBBA).
 
 

DOL Launches Workforce Program Performance Dashboard

On Wednesday the Department of Labor (DOL) announced the launch of a performance dashboard that provides information on the effectiveness of federally-funded Workforce Innovation and Opportunity Act (WIOA) Adult, Youth, and Dislocated Worker programs. The dashboard includes data from over 550 local workforce development boards nationwide, giving a granular view of WIOA program performance, and can be filtered by state and territory. The dashboard shows several program performance indicators from program year 2023 including participant employment rates, participants’ median earnings, rate of participants attaining a credential, and rate of training participants who gained one or more measurable skills.
 
 

DOT Announces Funding Opportunities

Last week the Department of Transportation (DOT) made two funding announcements. First, DOT announced $175 million in funding under the Federal Highway Administration’s Ferry Boat Program to 35 states, Puerto Rico, U.S. Virgin Islands, and American Samoa. The formula funding is intended to improve ferry service and provide more cost-effective travel options for communities that rely on ferries to get to work, promote tourism, and enable commerce. A funding distribution table can be found here. Second, the department’s Build America Bureau released a notice of funding opportunity for the Innovative Finance and Asset Concession Grant Program. The notice makes $45.98 million available to assist public entities in facilitating and evaluating public-private partnerships and exploring innovative financing and alternative delivery opportunities for TIFIA-eligible projects. Applications are due by October 1.
 

Recently Released Reports

Electric Vehicle Taxes by State, 2025
Tax Foundation
 
Rising Construction Costs: Analyzing the Contributors to Cost Escalations and the Impact on Federal Transportation Infrastructure Investments
Eno Center for Transportation
 
An Increase in Pension Obligations Adds to States' Unfunded Liabilities
The Pew Charitable Trusts
 

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