Extend SNAP Heat and Eat SUA treatment to 13 more states and DC

[PavelMakarchuk]

Summary

Extends the SNAP Heat and Eat (H&E) "always apply the Standard Utility Allowance" treatment to the 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 (13 + DC)

State	Effective	Rationale	Primary source
CA	2015-10-01	Pre-2014 H&E (SUAS / SB 855); date conservative — actual SUAS effective 2014-07-01	CDSS ACWDL "State Utility Assistance Subsidy ('Heat and Eat')"
CT	2015-10-01	Raised nominal LIHEAP $1→$20.01 in late Feb 2014 (Gov. Malloy)	LIHEAP Clearinghouse
DC	2015-10-01	Pre-2014 H&E jurisdiction	LIHEAP Clearinghouse
MA	2015-10-01	Pre-2014 H&E state	LIHEAP Clearinghouse
MD	2025-04-01	MD did not operate H&E pre-2025; first stood up under IM 25-15 on April 1, 2025 (Md. Hum. Serv. Art. § 5-506)	MD DHS AT 26-08 (supersedes IM 25-15)
ME	2015-10-01	Continuous regulatory automatic FSUA-on-LIHEAP rule	10-144 C.M.R. Ch. 301 § 555-5
MI	2017-08-01	State-paid $20.01 LIHEAP H&E launched August 1, 2017 (not 2016)	MI DHHS BPB 2017-016 / BEM 554
MT	2015-10-01	Pre-2014 H&E state (Gov. Bullock)	LIHEAP Clearinghouse
NY	2015-10-01	Raised LIHEAP to $20.01 in early Mar 2014 (Gov. Cuomo, $6M)	LIHEAP Clearinghouse
OR	2015-10-01	Pre-2014 H&E state	LIHEAP Clearinghouse
PA	2015-10-01	Pre-2014 H&E state	LIHEAP Clearinghouse
RI	2015-10-01	Pre-2014 H&E state	LIHEAP Clearinghouse
VT	2015-10-01	Pre-2014 H&E state — explicitly listed in LIHEAP Clearinghouse chart (21,000 households, $400K)	LIHEAP Clearinghouse
WA	2015-10-01	Pre-2014 H&E state	LIHEAP Clearinghouse

The 2015-10-01 effective date is conservative — the LIHEAP Clearinghouse confirmed states publicly preserved H&E in early 2014 (Feb–Apr 2014). 2015-10-01 aligns with PolicyEngine's earliest SNAP parameter coverage.

Maryland correction: Maryland Hunger Solutions' 2021 testimony (SB0913) explicitly stated MD was "leaving the benefit on the table" — MD did not operate H&E from 2015 to 2025. The program was first stood up under IM 25-15 on April 1, 2025 and was subsequently revised by AT 26-08 in November 2025 to align with H.R. 1 (2025) restrictions. So MD is false from 2015-10-01 and true from 2025-04-01.

Michigan correction: MI BPB 2017-016 documents the state-paid $20.01 LIHEAP launching August 1, 2017 — not 2016. (MD Hunger Solutions 2021 testimony also explicitly groups MI with non-acting states: "Michigan similarly did not make the necessary accommodations to fulfill federal guidelines and 159,000 households saw an $80 reduction.")

Legal basis

• 7 CFR §273.9(d)(6)(iii)(E) — a SNAP household receiving LIHEAP can claim the full SUA.
• The 2014 Farm Bill (PL 113-79) Sec. 4006 required a minimum LIHEAP benefit greater than $20/year for this trigger.
• LIHEAP Clearinghouse — A New Framework for Heat and Eat — enumerates the 10 jurisdictions publicly preserving H&E post-Farm-Bill (CT, DC, MA, MT, NY, OR, PA, RI, VT, WA).
• California CDSS ACWDL – State Utility Assistance Subsidy ('Heat and Eat') — California SUAS.
• Maryland DHS AT 26-08 – H.R. 1 (2025) Treatment of Energy Assistance Payments — supersedes IM 25-15 (April 1, 2025), the original Maryland H-EAT stand-up.
• Michigan DHHS BPB 2017-016 – FAP LIHEAP Payments — effective August 1, 2017.
• Michigan DHHS BEM 554 – FAP Allowable Expenses — codifies the H&E rule.
• Maine 10-144 C.M.R. Ch. 301 § 555-5 – Food Supplement Program Deductions — codifies automatic FSUA on LIHEAP ≥ $20.

OBBBA caveat (not in scope for this PR)

OBBBA Section 10004 / H.R. 1 (2025) Section 10103 (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 baseline tests pass
• All 84 SNAP deductions tests pass
• All 523 MD + MI baseline state tests pass (no downstream breakage from date corrections)
• 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
• make format clean

🤖 Generated with Claude Code

[codecov]

Codecov Report

✅ All modified and coverable lines are covered by tests.
✅ Project coverage is 71.72%. Comparing base (20705b0) to head (cc5bd64).
⚠️ Report is 115 commits behind head on main.

Additional details and impacted files

@@             Coverage Diff             @@
##             main    #8132       +/-   ##
===========================================
- Coverage   85.36%   71.72%   -13.65%     
===========================================
  Files           3     4658     +4655     
  Lines          41    67710    +67669     
  Branches        2      341      +339     
===========================================
+ Hits           35    48563    +48528     
- Misses          6    19140    +19134     
- Partials        0        7        +7     

Flag	Coverage Δ
unittests	71.72% <ø> (-13.65%)	⬇️

Flags with carried forward coverage won't be shown. Click here to find out more.

☔ View full report in Codecov by Sentry.
📢 Have feedback on the report? Share it here.

🚀 New features to boost your workflow:

• ❄️ Test Analytics: Detect flaky tests, report on failures, and find test suite problems.

[hua7450]

Update following primary-source review (commit cc5bd64):

Parameter corrections in always_standard.yaml:

• VT: added at 2015-10-01: true — explicitly listed in LIHEAP Clearinghouse "States Keeping Heat and Eat" chart (21,000 households, $400K) but missing from the original PR.
• MD: corrected from 2015-10-01: true to 2015-10-01: false + 2025-04-01: true. Maryland did not operate H&E pre-2025 — the program was first stood up under IM 25-15 on April 1, 2025 (Md. Hum. Serv. Art. § 5-506). Maryland Hunger Solutions' 2021 testimony in support of SB0913 explicitly stated H&E was "a benefit that Maryland is leaving on the table." Modeling MD as H&E from 2015 onward would misrepresent ~10 years of MD SNAP benefits.
• MI: corrected from 2016-10-01 to 2017-08-01. MI BPB 2017-016 explicitly states the $20.01 LIHEAP H&E payment was deposited around July 28, 2017 with the heat/utility standard taking effect August 1, 2017. The PR's prior 2016-10-01 date was off by 10 months.

Reference corrections:

• Farm Bill anchor: #page=143 → #page=139 (Sec. 4006 STANDARD UTILITY ALLOWANCES is on file page 139, not 143).
• Removed FNS State Options Report reference (cited at #page=12) — that section lists the 48 jurisdictions with Mandatory SUAs, a broader concept than Heat and Eat that includes states like TX/AL/FL. It cannot corroborate H&E status.
• Added primary-source references for MD (AT 26-08), MI (BPB 2017-016 + BEM 554), and ME (10-144 C.M.R. Ch. 301 § 555-5).

Changelog update: "12 additional states and DC" → "13 additional states and DC" with MT and VT added to the list.

Verification:

• 84/84 SNAP deductions tests pass
• 294/294 full SNAP baseline tests pass
• 523/523 MD + MI state baseline tests pass (no downstream breakage)
• make format clean

Outstanding (deferred):

• Boundary tests for MD (2025-04-01) and MI (2017-08-01) transitions, and a 2015-10-01 boundary test for any of the early states.
• An integration test demonstrating actual SNAP benefit increase for an H&E state household with no utility bills relative to TX.
• Optional: backdate the 9 LIHEAP-Clearinghouse-confirmed states to 2014-04-01 to match documented operational dates. Not applied — current 2015-10-01 is conservative and aligns with PolicyEngine's earliest SNAP parameter coverage.

[PavelMakarchuk]

@hua7450 feel free to approve and merge if you think this is complete