** 11/25/25 - Washington Report - Reconciliation Resources + Administration Updates Approach on SNAP Reapplications + FNS Releases Memo on SNAP Expungement Options

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Nov 30, 2025, 8:52:11 PM (3 days ago) Nov 30
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Reconciliation Resources

Following enactment of H.R. 1, the One Big Beautiful Bill Act (OBBBA), a number of resources have been released examining the legislation's impact and providing implementation guidance. Newly released resources are included below.
 
  • The Centers for Medicare and Medicaid Services (CMS) released an informational bulletin containing a summary of Medicaid and Children’s Health Insurance Program (CHIP) related provisions in OBBBA. The appendix includes information on key dates, opportunities for additional financial support for states, and applicability to the territories. A legislation overview slide deck can be found here. Additional information on OBBBA provisions from Medicaid.gov can be found here.
  • State Health and Value Strategies released an expert perspective on the preliminary guidance issued by the Centers for Medicare and Medicaid Services (CMS) interpreting OBBBA’s new limits on Medicaid provider taxes.
  • The Internal Revenue Service (IRS) issued guidance for workers eligible to claim the deduction for tips and overtime compensation for tax year 2025. The IRS is in the process of updating income tax forms and instructions for taxpayers to use this filing season that will assist them in claiming these deductions.
  • The Internal Revenue Service (IRS) issued guidance for a new tax benefit for certain lenders that make loans secured by rural or agricultural real property. The agency is providing interim guidance that taxpayers may rely on until the IRS issues forthcoming proposed regulations. The guidance relates to section 139L of the tax code that was added by OBBBA.
    

Administration Updates Approach on SNAP Reapplications

According to updated media reports, the administration is no longer planning to have Supplemental Nutrition Assistance Program (SNAP) participants reapply for benefits, instead relying on existing policies. Following reports the previous week that participants would need to reapply, the U.S. Department of Agriculture (USDA) is clarifying that it will use current verification processes. Per the press clip, “state and local SNAP administrators will continue to recertify participants’ work history, income, and other personal information as often as every six months to ensure they are eligible for benefits.”
 
 

FNS Releases Memo on SNAP Expungement Options

Last week the Food and Nutrition Service (FNS) released a policy memo intended to clarify Supplemental Nutrition Assistance Program (SNAP) Electronic Benefits Transfer (EBT) expungement policy. States are strongly encouraged to expunge benefit allotments nine months after issuance, regardless of the household’s SNAP activity, in accordance with regulatory requirements. Regulations also require states to provide sufficient notice to the household before expungement.
 



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November 25, 2025

Economic Indicators

The Bureau of Labor Statistics released additional revised news release dates following the reopening of the federal government.

Source

+119,000

Jobs (September)

Source

Unchanged

Real Earnings

Source

This Week in DC  

The House and Senate are out, returning next week.

Reconciliation Resources

Following enactment of H.R. 1, the One Big Beautiful Bill Act (OBBBA), a number of resources have been released examining the legislation's impact and providing implementation guidance. Newly released resources are included below.
 
  • The Centers for Medicare and Medicaid Services (CMS) released an informational bulletin containing a summary of Medicaid and Children’s Health Insurance Program (CHIP) related provisions in OBBBA. The appendix includes information on key dates, opportunities for additional financial support for states, and applicability to the territories. A legislation overview slide deck can be found here. Additional information on OBBBA provisions from Medicaid.gov can be found here.
  • State Health and Value Strategies released an expert perspective on the preliminary guidance issued by the Centers for Medicare and Medicaid Services (CMS) interpreting OBBBA’s new limits on Medicaid provider taxes.
  • The Internal Revenue Service (IRS) issued guidance for workers eligible to claim the deduction for tips and overtime compensation for tax year 2025. The IRS is in the process of updating income tax forms and instructions for taxpayers to use this filing season that will assist them in claiming these deductions.
  • The Internal Revenue Service (IRS) issued guidance for a new tax benefit for certain lenders that make loans secured by rural or agricultural real property. The agency is providing interim guidance that taxpayers may rely on until the IRS issues forthcoming proposed regulations. The guidance relates to section 139L of the tax code that was added by OBBBA.
 
 

Administration Updates Approach on SNAP Reapplications

According to updated media reports, the administration is no longer planning to have Supplemental Nutrition Assistance Program (SNAP) participants reapply for benefits, instead relying on existing policies. Following reports the previous week that participants would need to reapply, the U.S. Department of Agriculture (USDA) is clarifying that it will use current verification processes. Per the press clip, “state and local SNAP administrators will continue to recertify participants’ work history, income, and other personal information as often as every six months to ensure they are eligible for benefits.”
 
 

FNS Releases Memo on SNAP Expungement Options

Last week the Food and Nutrition Service (FNS) released a policy memo intended to clarify Supplemental Nutrition Assistance Program (SNAP) Electronic Benefits Transfer (EBT) expungement policy. States are strongly encouraged to expunge benefit allotments nine months after issuance, regardless of the household’s SNAP activity, in accordance with regulatory requirements. Regulations also require states to provide sufficient notice to the household before expungement.
 
 

Treasury Releases Updated Data for Pandemic Relief Programs, SLFRF Closeout Checklist

The Treasury Department recently released updated programmatic data for three COVID-19 pandemic relief programs. The department released an updated public data dashboard (through June 2025) and quarterly reporting data for the State and Local Fiscal Recovery Fund (SLFRF) program. Treasury also released cumulative compliance data through the second quarter of 2025 for the Homeowner Assistance Fund (HAF) and Emergency Rental Assistance 2 (ERA2) program. In a recent newsletter, the department also highlighted the SLFRF Award Closeout Preparation Checklist, which notes “the early closeout process will occur prior to the end of the SLFRF period of performance (December 31, 2026).”
 
 

ACF Launches Initiative on Foster Home Ratios

On Monday the Administration for Children and Families (ACF) announced the launch of “A Home for Every Child,” a national initiative aimed at right-sizing the ratio of foster homes to the number of children in the foster care system. The effort helps implement the executive order Fostering the Future for American Children and Families. The initiative sets a goal of achieving a foster home-to-child ratio greater than 1:1 in every state; currently, for every 100 children entering foster care, there are 57 licensed foster homes available nationwide. According to the announcement, the agency plans to leverage all $11.4 billion in its annual federal funding for foster care and child welfare to advance this mission and will come alongside state agencies to give broad latitude, flexibility, and technical support to reimagine community-specific interventions. The initiative will also include quarterly progress reviews tracking data elements in each state.
 
 

EPA Announces $7 Billion in Available WIFIA Funding

On Thursday the Environmental Protection Agency (EPA) announced $6.5 billion in Water Infrastructure Finance and Innovation Act (WIFIA) funding available for water systems and $550 million in additional funding available to states through the State WIFIA (SWIFIA) program. EPA also announced the approval of five loans that invest in water infrastructure projects in Texas, Illinois, Oregon, and Florida.
 
 

DOT Announces $2 Billion for Transit Bus Modernization Projects

On Thursday the Department of Transportation (DOT) announced $2 billion for 165 transit projects in 45 states and Washington, DC. The funding was awarded through the Federal Transit Administration’s (FTA) Grants for Buses and Bus Facilities Program and the Low or No Emission Grant Program to help modernize bus infrastructure, reduce traffic congestion, and help people travel more efficiently and affordably. A full list of project selections can be found here.
 
 

DOI Announces $14.6 Billion in Fiscal Year 2025 Energy Revenue

Yesterday the Department of the Interior’s (DOI) Office of Natural Resources Revenue announced the disbursement of $14.6 billion in revenues generated in fiscal year 2025 from energy production on federal and Tribal onshore lands and federal offshore areas. The disbursement includes $4.07 billion to 34 states, $1.05 billion to the Land and Water Conservation Fund, and $5.01 billion to the U.S. Treasury. The announcement includes a list of states receiving the highest disbursements.
 
 

DOE Announces Organizational Realignment

Last Thursday the Department of Energy (DOE) announced an organizational realignment intended to strengthen the department’s ability to restore American energy dominance. The realignment reflects the administration’s priorities of expanding American energy production, accelerating scientific and technological leadership, and ensuring the continued safety and readiness of the nation’s nuclear weapons stockpile. A press clip on the reorganization can be found here.
 
 

House Passes Bill to Reauthorize State and Local Cybersecurity Grant Program

Last week the House approved H.R. 5078, the Protecting Information by Local Leaders for Agency Resilience Act (PILLAR Act), which includes a reauthorization of the State and Local Cybersecurity Grant Program for ten years. The program expired at the end of September but received a temporary reauthorization in the continuing resolution that reopened the federal government. A press clip on the bill, which does not authorize funding for the program, can be found here. A report on the program by the U.S. Government Accountability Office (GAO) found that as of August 1, 2024, the grants were funding 839 state and local cybersecurity projects. The legislation now moves to the Senate for consideration.
 
 

DOI Proposes Rules on Endangered Species

Last Wednesday the Department of the Interior’s (DOI) Fish and Wildlife Service (FWS) announced four proposed rules intended to restore Endangered Species Act (ESA) regulations to their 2019 and 2020 framework. The proposals would revise regulations from the prior administration that were finalized in 2024 while also implementing executive orders on Unleashing American Energy and Department of Government Efficiency Deregulatory Initiative. The four proposed rules are Listing and critical habitat, Interagency cooperation, Threatened species protections, and Critical habitat exclusions. Public comments may be submitted until December 20.
 
 

Treasury Department Plans Regulations Related to Eligibility for Certain Tax Credits

Last week the Treasury Department announced it will issue regulations concerning the treatment of certain refundable individual income tax credits under the Personal Responsibility and Work Opportunity Reconciliation Act of 1996 (PRWORA). Treasury will issue a forthcoming notice of proposed rulemaking to clarify that the refunded portions of certain individual income tax credits, including the Earned Income Tax Credit, the Additional Child Tax Credit, the American Opportunity Tax Credit, and the Saver’s Match Credit, are “federal public benefits” within the meaning of PRWORA. Following the issuance of a notice of proposed rulemaking, the department’s final regulations are expected to apply beginning in tax year 2026.
 

Recently Released Reports

Human Services Pain Points During the Federal Government Shutdown: Lessons Learned
National Governors Association
 
How States are Assessing the Impact of Federal Policy Changes
The Pew Charitable Trusts
 
The State of Rural Primary Care in the United States
The Commonwealth Fund
 

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