Department of Social Services

2025 Federal Legislation Changes and its Impact on DSS Service Delivery: H.R.1 / S.R.1 (One Big Beautiful Bill)

DSS Director Leon Henry, MSW, LCSW

And

DSS Director Mary Stebbins, PhD, LCSW

Agenda

• Overview of DSS
• SNAP
• Medicaid
• Energy Assistance
• DSS Impact
• Recommendations/ Request

Locally Administered Programs, State Oversight ��

120 Local Departments of Social Services (LDSS) overseen by 5 regional offices:

• Responsible for the administration of human services, child welfare, and eligibility for all benefit programs

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What We Do…

H.R. 1/S.R. 1 SNAP�"One Big Beautiful Bill"

Supplemental Nutrition Assistance Program (SNAP)

• Introduces a Matching Funds Requirement
• Changes Eligibility
• Repeal of National Education and Obesity Prevention Grant Program (SNAP-Ed)
• Changes Work Requirements for Able Bodied Adults
• Expands the National Accuracy Clearinghouse

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SNAP Costs Shifting to States

• Beginning in FFY2027, the state share of SNAP “Administrative” costs will increase from 50% to 75%, or ~ $90 million. **

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• A 25% increase shift locally would equate to an estimate 800k annually.

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• Beginning in October 1^st 2027, states will be required to contribute a state match for SNAP benefits. Currently, benefits are paid with 100% federal funds.

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• The state match will be calculated based on the states SNAP Error Rate with higher error rates resulting in a higher state match. If the error rate is below 6%, then a state is not required to match SNAP benefits.

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Details of SNAP Cost Shifting to States - VA

• Based on Virginia’s current PER of 11.5%, Virginia will have to match at 15% unless we can reduce our error rate under 6% during FFY 2026.
• The national error rate for FY 2024 is 10.93%

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CDSS and ACDSS SNAP Issuance for July 2025

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SNAP Policy/Eligibility Changes

Limits SNAP eligibility to those who reside in the United States and are:

• A citizen
• Lawfully admitted for permanent residence with no intention of abandoning their residence in a foreign country
• Cuban and Haitian entrants
• Allowed to live and work in the US under the Compacts of Free Association (COFA).

Removes eligibility for refugees and those granted asylum, as well as any others not explicitly included in the above.

Requires that all non-eligible, non-citizen financial resources in any SNAP household be included in eligibility and benefit determination, even for those who are not receiving benefits.

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Modifications to SNAP Work Requirements - SNAPET

• Changes the Able-Bodied Adults Without Dependents (ABAWD) work requirement age range to those 18-64, previously 18-54.
• Changes the exception for those with dependent children to only apply to children under 14, previously under 18.
• Limits ABAWD waivers to only be permissible if an area has an unemployment rate above 10% and removes the ability for waivers to be based on lack of sufficient jobs. This has been removed as a waiver for LDSS in these communities.
• Expands the National Accuracy Clearinghouse authority to prevent multiple issuances of other assistance program benefits through the integrated eligibility system (VACMS)

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8/13/2025

H.R. 1/ S.R.1- Medicaid�“Big Beautiful Bill”

• The bill contains key Medicaid provisions including provider tax restrictions, community engagement requirements, and changes to state- directed payment limits.
• Implementation of Medicaid provisions will be a collaboration with input from the Governor’s Office, the General Assembly, and federal partners.
• CMS implementation guidance will be forthcoming
• Most new Medicaid provisions will not take effect until 2026 or later, giving states time to develop their implementation plans.
• Current Medicaid eligibility rules remain unchanged at this time.
• Introduces New Medicaid Renewal Process
• Implements Community Engagement Experience Requirements

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Expected Changes – Medicaid

Immigrant Eligibility and Federal Match: Effective October 1, 2026

• Narrows the definition of qualified alien from current law
• Payments for services for an emergency medical condition furnished to an individual eligible for Expansion except for their citizenship status shall be limited to 50% federal match; currently 90%.

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Community Engagement- Work Requirement: Effective December 31,2026

• Requires individuals applying for or enrolled in Expansion (ABAWD) to participate in a qualifying activity at least 80 hours per month to be eligible
• Qualifying activities: work, community service, education, or combination of the above
• States must verify compliance at application for Medicaid and every six months thereafter

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Expected Changes – Medicaid

Retroactive Coverage for Medicaid Services: Effective January 1, 2027

• Limits retroactive coverage to one month for Expansion and two months for all other individuals; current limits are three months for all populations except for CHIP/FAMIS

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Frequency of Expansion Eligibility Redeterminations: Effective January 1, 2027

• Requires a redetermination for Expansion enrolled individuals to occur every six months; currently redeterminations occur on an annual basis

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Operational impacts to state and local DSS agencies to include systems, staffing and resources

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Expected Changes – Medicaid

Duplicate Enrollment & Deceased Individuals: Effective January 1, 2027/2028

• Requires states to obtain enrollee address information using reliable data sources
• Requires states to review the Death Master File quarterly to identify deceased individuals

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Cost Sharing for Recipients: Effective October 1, 2028

• Requires cost sharing greater than zero for Expansion members with incomes above 100% of the Federal Poverty Level up to $35 per service
• Exceptions for: primary care, substance use disorder and mental health, services provided by FQHCs, rural and behavioral health clinics
• Subset of entire Medicaid population, will have additional operational impact on recipients

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Expected Changes- Medicaid

Payment Error Rate: Effective October 1, 2029

• Pending CMS guidance, intent is to allow recoupment of erroneous payments beyond current Payment Error Rate Measure (PERM)
• Errors include payments made on behalf of ineligible individuals and when there is insufficient documentation to support eligibility
• The 3% error rate threshold applies to any audits conducted by the federal Secretary of Health and Human Services (HHS) and, at the Secretary’s option, audits conducted by the state.

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Low Income Home Energy Assistance Program –LIHEAP/Energy Assistance Program

• Funded through FFY 2025; future funding still under review.

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• Potential restructuring to combine Fuel, Cooling, and Crisis into a year-round program.

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• Currently processing Cooling assistance with reduced benefit amounts and limited eligibility with the application deadline: August 15, 2025.

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Child Care Subsidy Program

Federal budget cuts to offset fraud and waste: Effective 7/1/2025

• Job Search: Limited to 90 days in a 12 month period, if employment is not secured at the end of 90 days the child care case will close.
• Increase in Parent monthly copays per child, depending on the family’s income the copay could be from $0-$375/child/month, in addition to the over market rate most families pay when the child care provider charges more than child care subsidy covers.
• Waitlist: As of 7/30/25 there are 14,499 children on the waitlist across the state, Charlottesville has 28 families and 41 children on our waitlist. School age children make up 49% of our waitlist as Dept. of Education (DOE)’s priority is to serve children birth -5years (not yet in kindergarten)
• Not enough child care providers in Charlottesville for before/after school care for older children.

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Local Impact

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Organizational:

• Increased case management responsibilities
• Workforce Training and Education
• Systems changes and or updates needed to capture data required to monitor program compliance.

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Community:

• Increased paperwork and compliance mandates
• Increased demand for consistency and follow up.
• Increased need for supportive services to address/ decrease psychosocial barriers in accessing benefits.

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