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Page 2 of 3 Questions Regarding the One Big Beautiful Bill Act 0f 2025 Section 10106, Administrative Cost Sharing 1. The information memorandum issued on September 4, 2025, indicates the provision amends and reduces the amount USDA “may pay” for administrative operation costs of SNAP to 25 percent. Does this mean the USDA cost sharing amount may remain at 50 percent? No. Beginning in fiscal year 2027, the Federal share of SNAP administrative costs will be reduced from 50 percent to 25 percent, following requirements in OBBB. 2. Does Section 10106 of OBBB impact SNAP activities on Tribal reservations? No. In accordance with Section 16(a) of the Act and 7 CFR 281.9, FNS may pay each agency of State government and Indian Tribal Organization acting as a State agency administering SNAP on a reservation 75 percent of all approved administrative costs. 3. Does Section 10106 of OBBB impact the SNAP Employment and Training (E&T) administrative cost share? No, Section 10106 of OBBB does not impact SNAP E&T funding. In accordance with Section 16(h) of the Act, which was not amended by OBBB, USDA will continue to pay or reimburse State agencies an amount equal to 50 percent for E&T administrative costs. 4. Is the change to the administrative cost reimbursement rate made by Section 10106 of OBBB waivable? No, the Act does not allow for the administrative cost reimbursement rate to be waived. 5. Does the new administrative cost share provision impact recently approved Advanced Planning Document Updates (APD(U)s)? Yes, APD(U)s will be impacted by the change in the SNAP reimbursement rate from 50 percent to 25 percent. State agencies may continue following their already approved APD(U) plans, with necessary adjustments to reflect the new 25 percent Federal reimbursement rates starting in fiscal year 2027. Applicable APD(U)s must be submitted to FNS for review and/or approval at least 90 days prior to the start of the 2027 fiscal year. Guidance documents lack the force and effect of law, unless expressly authorized by statute or incorporated into a contract. USDA may not cite, use, or rely on any guidance that is not available through their guidance portal, except to establish historical facts.