Policy Briefing · October 2026

What H.R. 1 Means for SNAP and Medicaid Payment Accuracy

The 2025 federal budget reconciliation law, known as the One Big Beautiful Bill Act (Public Law 119-21), was signed on July 4, 2025. It makes payment accuracy a direct budget issue for states. This briefing summarizes the provisions that affect SNAP and Medicaid error rates, the deadlines that matter, and where states stand today.1

Oct 1, 2026
SNAP admin cost shift begins
FY 2028
SNAP benefit cost share begins
FY 2030
Medicaid eligibility error penalties
At a Glance

The Numbers Behind the Pressure

10.62%
National SNAP payment error rate, FY 20252
$10.1B
SNAP improper payments, FY 20252
$37.4B
Medicaid improper payments, FY 20255
$1T+
CBO estimate of reduced federal health spending under the law over 10 years6
SNAP

States Now Share the Cost of Errors

Before H.R. 1, the federal government paid all SNAP benefits and half of administrative costs. The law changes both.

Benefit cost share by payment error rate

Payment error rateState share of benefits
Below 6%0%
6% to under 8%5%
8% to under 10%10%
10% or higher15%

For fiscal year 2028, a state may use either its FY 2025 or FY 2026 error rate. From FY 2029 on, the rate from three years earlier applies. States whose rate multiplied by 1.5 is 20% or more (about 13.33%, or 20 divided by 1.5) get a delayed start: FY 2029 if based on the FY 2025 rate, FY 2030 if based on FY 2026.3

Other SNAP changes that affect error rates

  • Administrative costs. The federal share drops from 50% to 25% starting October 1, 2026, so states (and in some states, counties) cover 75%.34
  • Work requirements. The age range for able-bodied adults without dependents expands to 18 through 64, parents of children 14 and older are now included, and several exemptions end. The changes took effect on enactment, and errors in applying them count in quality control beginning November 1, 2025, so they will show up in FY 2026 error rates.3
  • Benefit calculation. Internet costs no longer count toward the excess shelter deduction, and energy assistance rules for the standard utility allowance narrow. Every rule change is a new chance for calculation errors.3
  • Corrective action. States at or above 6% must submit a corrective action plan to USDA addressing the root causes of their errors.2
  • Budget impact. CBO estimates the cost-share provision alone reduces federal spending by about $41 billion from 2028 through 2034, about $35 billion of it through state payments.7
Where States Stand

Most States Are Above the 6% Line

USDA released FY 2025 SNAP payment error rates on June 24, 2026. These are the first rates that can be used to set the new cost share.2

States and DC by FY 2025 cost-share tier

Below 6%
9
6% to 8%
6
8% to 10%
16
10% or higher
20

Calculated from USDA FNS FY 2025 state payment error rates for the 50 states and the District of Columbia. Seven of the 20 in the top tier are at or above 13.33% and would qualify for a delayed start. Tiers shown are for illustration; a state may instead use its FY 2026 rate.2

What the FY 2025 data shows

  • Rates ranged from 2.47% to 23.15%, with a median of 9.44% across the 50 states and DC
  • 42 of the 50 states and DC were at or above 6%
  • Overpayments made up 9.28 points of the 10.62% national rate; underpayments made up 1.33 points
  • The national rate fell 0.31 points from FY 2024 (10.93%) and remains well above the 6% threshold set by Congress
  • The FY 2025 error tolerance threshold was $57, meaning smaller errors were not counted
Medicaid

Eligibility Errors Carry New Weight

Federal law has allowed a 3% Medicaid eligibility error rate since 1983, and states could avoid penalties by showing good-faith efforts. GAO found no recoupments under the related quality control program since 1992.13 H.R. 1 changes how errors are counted and removes the main path to waivers.5

6.12%
Medicaid improper payment rate, FY 2025
72%
Share of improper payments tied to eligibility ($27.0B)
77%
Share from insufficient documentation, which CMS says is generally not indicative of fraud9
12
States above the 3% eligibility threshold in their most recent PERM review8

What changes

  • Payments for people whose eligibility can't be confirmed because of missing documentation now count as erroneous
  • HHS must recover the federal share of erroneous payments above 3%
  • Waivers for states making good-faith efforts are eliminated
  • HHS can rely on state audits such as Medicaid Eligibility Quality Control reviews
  • Takes effect in fiscal year 2030, which begins October 1, 2029

Why it matters

  • CMS reviews about 17 states a year, so each state is measured about every three years, and the national rate combines three review cycles
  • The 12-state figure reflects reviews that overlapped with the pandemic and the unwinding, so it may not predict future rates
  • States must submit a corrective action plan within 90 days of receiving a PERM rate
  • Work requirements, six-month renewals, and new verification rules add more steps where documentation can fall short
  • CMS states that improper payment rates are not fraud rates; most reflect a missed administrative step
Medicaid Timeline

New Eligibility and Verification Requirements

Each of these provisions adds data, verification, or renewal work, and each is a place where documentation errors can occur.610

ProvisionEffectiveWhat states must doCBO 10-year federal impact
Community engagementJan 1, 2027Verify 80 hours a month of work or qualifying activity for expansion adults ages 19 to 64, using data matching where possible. Good-faith extensions possible to Dec 31, 2028$326B reduction
Six-month renewalsRenewals scheduled on or after Jan 1, 2027Redetermine eligibility for expansion adults every six months$63B reduction
Address verification and duplicate enrollmentJan 1, 2027; federal system by Oct 1, 2029Verify enrollee addresses and submit enrollee data monthly to a federal system that prevents enrollment in more than one state$17B reduction
Enrollee death checksJan 1, 2027Check the death master file at least quarterlyNo CBO effect
Provider death checksJan 1, 2028Check at enrollment, reenrollment, and quarterlyNot separately scored
Retroactive coverageJan 1, 2027Shorten retroactive coverage periods$4B reduction
Cost sharingOct 1, 2028Apply cost sharing for expansion adults above the poverty line$7B reduction
Eligibility error penaltyOct 1, 2029Keep eligibility-related improper payments at or below 3%About $8B reduction
Key Dates

The Window Is Already Open

July 4, 2025
H.R. 1 signed into law; SNAP work requirement changes take effect on enactment
November 1, 2025
Errors in applying the new SNAP work requirements begin to count in quality control
June 24, 2026
USDA releases FY 2025 SNAP payment error rates, the first eligible to set cost shares
October 1, 2026
States begin paying 75% of SNAP administrative costs
January 1, 2027
Medicaid community engagement requirements, six-month renewals, address verification, and quarterly enrollee death checks begin
October 1, 2027
FY 2028 begins; SNAP benefit cost sharing starts for most states at or above 6%
October 4, 2027
Deadline for all states to implement the National Accuracy Clearinghouse, which flags SNAP participation in more than one state11
October 1, 2029
Medicaid eligibility error penalties above 3% apply; federal duplicate enrollment system due
What States Can Do Now

Practical Steps Before the Deadlines

Find where errors start

Break recent quality control and PERM findings down by error type, office, and step in the process. Income, deductions, and documentation gaps usually account for most of the dollars.

Check before you pay

Add validation before benefits are issued. An error caught before issuance costs a few minutes of review; one caught after costs a recovery effort and counts against the rate.

Connect your records

Link records for the same person across programs and systems. Duplicate IDs and conflicting determinations are a common source of both errors and rejected claims.

Support caseworkers

Reduce manual keying, standardize rules across offices, and prioritize the cases with the highest error risk and the nearest deadlines.

Document everything

Under the new Medicaid rules, a payment that cannot be confirmed because documentation is missing counts toward the penalty, even if the person was eligible. Make sure verification is captured and retrievable.

Watch denials, not just payments

Monitor error indicators continuously, and track denial and termination accuracy alongside them, so lowering the error rate never comes at the cost of eligible people.12

See How Stellar ACCORD Helps

Sources

  1. One Big Beautiful Bill Act, Public Law 119-21, signed July 4, 2025. Summary of health provisions: KFF, "Health Provisions in the 2025 Federal Budget Reconciliation Law".
  2. U.S. Department of Agriculture, "USDA Announces FY 2025 State Payment Error Rates in SNAP," June 24, 2026, and the accompanying FY 2025 state payment error rate table.
  3. National Association of Counties, "H.R. 1 and the Supplemental Nutrition Assistance Program (SNAP): What Counties Should Know."
  4. Feeding America Action, "H.R. 1 'One Big Beautiful Bill Act' FAQ," updated June 24, 2026.
  5. The Commonwealth Fund, "What H.R. 1 Changes to Medicaid Payment Error Rules Mean for States," July 2026, citing CMS FY 2025 PERM results.
  6. KFF, "Health Provisions in the 2025 Federal Budget Reconciliation Law," citing Congressional Budget Office estimates.
  7. Congressional Budget Office, supplemental information on SNAP provisions of Public Law 119-21, August 11, 2025.
  8. Jessica Mathers, Elizabeth Hinton, and Robin Rudowitz, "A Look at the Medicaid Payment Error Rate Measurement (PERM) Program and Upcoming Changes and Impacts," KFF, February 13, 2026.
  9. Centers for Medicare & Medicaid Services, "Fiscal Year 2025 Improper Payments Fact Sheet."
  10. Centers for Medicare & Medicaid Services, summary of Medicaid provisions of Public Law 119-21.
  11. U.S. Department of Agriculture, "SNAP: Requirement for Interstate Data Matching to Prevent Duplicate Issuances," interim final rule, October 3, 2022, with a state compliance deadline of October 4, 2027.
  12. U.S. Department of Agriculture, Food and Nutrition Service, "SNAP Case and Procedural Error Rates (CAPER)."
  13. U.S. Government Accountability Office, GAO-20-157, Medicaid eligibility oversight.

This briefing is a general summary for informational purposes and is not legal advice. Agencies should confirm requirements against federal guidance from USDA and CMS as it is issued.

Turn the Deadlines Into a Plan

Talk with Stellar about where your programs stand and which steps will move your error rates first.

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