04SNAP integrity
SNAP OBBBA §10105 Cost-Share Obligation by State — FY2028 Projection
What OBBBA §10105 cost-sharing does to a state budget, and the projected annual obligation for all 53 reporting jurisdictions — ranked by FY2025 payment error rate, with the statutory tier mechanics and every caveat that belongs on the figures.
- Published
- September 1, 2026
- Coverage
- 53 jurisdictions
- Document
- 5-page PDF · 17 KB
What cost-sharing means for a state budget
States have not previously paid a share of SNAP benefit costs as a matter of course — but they have been liable for them. Under 7 U.S.C. § 2025(c), a state whose payment error rate exceeded 105% of the national performance measure for two or more consecutive years could be assessed a liability computed against its own benefit allotments, with a good-cause waiver available before an administrative law judge. That regime reached persistent outliers, measured against their peers.
OBBBA §10105 converts that exception into a rule. Beginning in FY2028, any state whose combined payment error rate exceeds 6% owes a fixed percentage of its own SNAP benefit allotments out of state funds — measured against an absolute threshold rather than against other states. No corrective-action-plan waiver exists anywhere in the provision.
That puts a recurring state budget line where the program design had none, scaled to two things a state controls unevenly: its caseload and its measured accuracy. The obligation is not a penalty assessed after a finding, and it is not discretionary — it is a share of benefits, owed annually, set by a number the state’s own quality-control process produced three years earlier.
- It is recurring, not one-time. The obligation repeats every year the error rate stays above the threshold.
- It scales with caseload. A state that grows its SNAP population grows its own liability at the same tier.
- There is no waiver. No corrective-action-plan exemption exists anywhere in §10105. The only way a tier goes down is for the measured error rate to go down.
- The measurement year precedes the payment year. FY2028 tiers are set by FY2025 or FY2026 performance — for most states, data that is already closed.
- A single tier boundary is worth real money. Moving from 10% to 5% halves the obligation; crossing below 6% eliminates it entirely.
How a jurisdiction’s tier is determined
PER < 6%
0%
6% – <8%
5%
8% – <10%
10%
PER 10% or higher
15%
State share of SNAP benefit allotments, by FY2025 combined payment error rate. Tier boundaries are exact statutory cutoffs.
Projected obligation, all 53 jurisdictions
Every reporting jurisdiction is listed. No state is singled out — find your own line, and see who else is in the same tier.
A table of 53 jurisdictions with six columns: rank by payment error rate, jurisdiction name, the FY2025 combined payment error rate as a percentage, the resulting statutory cost-share tier as a percentage, estimated annualized SNAP benefits issued in millions of dollars, and the projected annual cost-share obligation in millions of dollars. Seven jurisdictions are marked as deferred to FY2029; two are marked as using a substitute month for the issuance estimate.
| # | State / territory | FY2025 PER | Tier (FY2028) | Est. benefits issued | Projected obligation |
|---|---|---|---|---|---|
| 1 | South Dakota | 2.47% | 0% | $168.4M | $0.0M |
| 2 | Idaho | 3.85% | 0% | $265.3M | $0.0M |
| 3 | Wyoming | 3.96% | 0% | $53.9M | $0.0M |
| 4 | Kentucky | 4.70% | 0% | $1.15B | $0.0M |
| 5 | Iowa | 5.34% | 0% | $493.2M | $0.0M |
| 6 | Virgin Islands | 5.36% | 0% | $61.5M | $0.0M |
| 7 | Vermont | 5.38% | 0% | $138.0M | $0.0M |
| 8 | Utah | 5.54% | 0% | $343.8M | $0.0M |
| 9 | Wisconsin | 5.72% | 0% | $1.33B | $0.0M |
| 10 | Nebraska | 5.90% | 0% | $287.8M | $0.0M |
| 11 | Nevada ‡ | 6.22% | 5% | $860.1M | $43.0M |
| 12 | West Virginia | 6.69% | 5% | $518.6M | $25.9M |
| 13 | Ohio | 6.76% | 5% | $2.95B | $147.5M |
| 14 | New Jersey | 6.86% | 5% | $1.84B | $91.8M |
| 15 | Washington | 6.98% | 5% | $1.94B | $96.8M |
| 16 | North Carolina | 7.36% | 5% | $2.67B | $133.6M |
| 17 | Louisiana | 8.14% | 10% | $1.42B | $142.4M |
| 18 | Missouri | 8.67% | 10% | $1.46B | $146.0M |
| 19 | South Carolina | 8.80% | 10% | $1.10B | $110.1M |
| 20 | Arkansas | 8.81% | 10% | $461.8M | $46.2M |
| 21 | New Hampshire | 8.85% | 10% | $149.0M | $14.9M |
| 22 | Montana | 8.86% | 10% | $147.1M | $14.7M |
| 23 | Connecticut | 9.08% | 10% | $704.7M | $70.5M |
| 24 | Pennsylvania | 9.21% | 10% | $3.80B | $379.6M |
| 25 | Texas | 9.34% | 10% | $6.38B | $637.6M |
| 26 | Kansas | 9.44% | 10% | $353.2M | $35.3M |
| 27 | Tennessee | 9.44% | 10% | $1.48B | $147.5M |
| 28 | Mississippi | 9.51% | 10% | $674.4M | $67.4M |
| 29 | Alabama | 9.52% | 10% | $1.52B | $152.0M |
| 30 | Indiana | 9.77% | 10% | $1.20B | $120.1M |
| 31 | Michigan | 9.89% | 10% | $2.84B | $284.1M |
| 32 | North Dakota | 9.89% | 10% | $110.9M | $11.1M |
| 33 | Colorado | 10.09% | 15% | $1.36B | $204.0M |
| 34 | Arizona ‡ | 10.80% | 15% | $1.94B | $290.6M |
| 35 | Maine | 10.81% | 15% | $325.9M | $48.9M |
| 36 | Hawaii | 10.92% | 15% | $617.8M | $92.7M |
| 37 | California | 10.93% | 15% | $11.92B | $1.79B |
| 38 | Oklahoma | 11.04% | 15% | $1.24B | $185.4M |
| 39 | Guam | 11.70% | 15% | $231.2M | $34.7M |
| 40 | Virginia | 12.32% | 15% | $1.48B | $222.7M |
| 41 | Rhode Island | 12.42% | 15% | $294.2M | $44.1M |
| 42 | Massachusetts | 12.49% | 15% | $2.14B | $321.4M |
| 43 | Minnesota | 12.58% | 15% | $849.4M | $127.4M |
| 44 | Florida | 12.97% | 15% | $4.86B | $729.0M |
| 45 | Maryland | 13.08% | 15% | $1.38B | $207.0M |
| 46 | New York | 13.18% | 15% | $7.36B | $1.10B |
| 47 | Oregon | 14.14% | 15% | $1.53B | FY2029: $229.2M † |
| 48 | Illinois | 14.67% | 15% | $3.81B | FY2029: $571.1M † |
| 49 | Georgia | 15.21% | 15% | $3.01B | FY2029: $450.8M † |
| 50 | Delaware | 16.00% | 15% | $217.6M | FY2029: $32.6M † |
| 51 | New Mexico | 16.81% | 15% | $934.4M | FY2029: $140.2M † |
| 52 | District of Columbia | 18.66% | 15% | $309.2M | FY2029: $46.4M † |
| 53 | Alaska | 23.15% | 15% | $263.0M | FY2029: $39.4M † |
Note on deferred jurisdictions: Seven jurisdictions trigger §10105's delayed-implementation clause (FY2025 PER × 1.5 of 20% or more). Their FY2028 obligation is deferred — not $0 and not exempt. The obligation column shows the FY2029 projection: what each would owe once the delay is assumed to lift, if its current error rate still stands then.
Note on substitute-month estimates: Nevada uses March 2026 preliminary × 12 (April 2026 initial is a partial-month reporting gap). Arizona uses April 2025 final × 12 (FY2026 monthly issuance runs ~46% of prior year across March and April 2026 — an unexplained level shift, not a confirmed caseload change).
A projection of statutory mechanics — not a USDA determination, an invoice, or a guaranteed liability. No implementing regulation for §10105 has been promulgated as of publication; figures reflect statutory text only. No corrective-action-plan waiver exists anywhere in §10105.
Sources
- SNAP Payment Error Rates (opens in a new tab)FY2025 combined rate by state, published 2026-06-24
- SNAP Data Tables (opens in a new tab)Persons participating and monthly benefit issuance
- P.L. 119-21 §10105 (opens in a new tab)Enrolled bill text
USDA's Food and Nutrition Service (FNS) became the Food and Nutrition Administration (FNA) on June 1, 2026. Releases cited here are attributed to the agency under its current name; some predate the change.