Track OBBBA "Heat and Eat" HCSUA eligibility change for FY2026

[hua7450]

Summary

The One Big Beautiful Bill Act (OBBBA / H.R. 1) restricts Heating/Cooling Standard Utility Allowance (HCSUA) eligibility for non-elderly/non-disabled LIHEAP-only households starting FY2026.

Impact

This affects the snap_utility_allowance_type formula logic — specifically which utility allowance type a household qualifies for. Households that previously qualified for the full HCSUA solely through a nominal LIHEAP payment ("Heat and Eat" strategy) may be downgraded to LUA or IUA if they are non-elderly and non-disabled.

Scope

• Variable affected: snap_utility_allowance_type (determines SUA vs LUA vs IUA vs phone-only)
• Not affected: Dollar amounts in the SUA/LUA/IUA parameter files (those are separate from eligibility)
• Effective: FY2026 (October 1, 2025)

Reference

• OBBBA / H.R. 1, SNAP utility allowance provisions
• USDA FNS implementation guidance (pending)

Found during PR #7726 review.