As artificial intelligence (AI) has become an increasingly common presence in daily life, policymakers have been considering ways to ensure that the use of AI is not replacing human expertise and decision-making on complex topics. One of the areas of concern for both physicians and policymakers has been AI’s use in health insurance, particularly the ways in which insurance companies have begun utilizing AI to assess benefit coverage decisions.

How AI is Being Used in Health Insurance

Health Insurers

In 2025, the National Association of Insurance Commissioners published its Artificial Intelligence and Machine Learning (AI/ML) Survey Report, representing feedback from 93 insurance companies in 16 states. Of the companies surveyed, 84 percent indicated they use AI/ML across product lines. Companies selling individual major medical health insurance reported currently using or exploring the use of AI/ML for:

• Utilization management practices (71.0 percent);
• Disease management programs (61.0 percent);
• Prior authorization for approval processes (68.0 percent);
• Claims fraud detection (50.0 percent);
• Medical provider fraud detection (51.0 percent);
• Sales and marketing solutions (45.0 percent); and
• Denying prior authorizations (12.0 percent).

One of the key ways that insurers have begun using AI in their work is through prior authorization. Prior authorization requires health care providers to obtain approval from a patient’s health insurer before providing the prescribed item, service, or prescription.

A February 2025 study by the Medicaid and Children’s Health Insurance Plan (CHIP) Payment and Access Commission (MACPAC) notes that some studies suggest prior authorization can “reduce health care costs without negatively impacting care quality,” and it has been successfully used to reduce overutilization of some items, redirect care to less expensive treatments, and help ensure care aligns with accepted clinical standards by not covering experimental treatments or non-approved uses of medications. However, prior authorization can also cause necessary care to be delayed or denied, declines in health, and increased administrative burden and cost.

Physician Concerns

A survey conducted in 2024 by the American Medical Association found that 61.0 percent of physicians surveyed reported concern that the use of AI by health plans is increasing prior authorization denials. With these increased denials, surveyed physicians also reported poor clinical outcomes for patients (94 percent), delayed care (93 percent), and increased administrative burden for physicians and staff.

Class Action Lawsuit

A federal class action lawsuit filed in Minnesota against UnitedHealthcare in 2023 claims the company is “wrongfully denying elderly patients care owed to them under Medicare Advantage Plans by overriding their treating physicians’ determinations as to medically necessary care based on an AI model that Defendants know has a 90 percent error rate” (Estate of Gene B. Lokken et al. v. UnitedHealth Group, Inc.). In February 2025, the U.S. District Court for the District of Minnesota denied, in part, a request by UnitedHealthcare to dismiss the lawsuit. Portions of the lawsuit regarding breach of contract and breach of the implied covenant of faith and fair dealing were allowed to proceed. The Court also waived the requirement that plaintiffs must exhaust the Medicare appeals process prior to filing a lawsuit due to the potential for irreparable harm to many patients.

Policy Responses

Recent State Actions

Colorado. Colorado became the first state to implement regulations on AI and insurance on November 14, 2023. The regulations require life insurance companies to report how they review AI models and use External Consumer Data and Information Sources (ECDIS), which may include data like credit scores, social media habits, purchasing habits, home ownership, educational attainment, licensures, court records, and other information to supplement or supplant traditional underwriting factors. Life insurance companies are also required to develop a governance and risk management framework. Similar regulations are set to take effect for health and auto insurers in Colorado on October 15, 2025.

California. In 2024, the California Legislature passed SB 1120, the Physicians Make Decisions Act (Act), to restrict health insurers and disability insurers from using AI, algorithms, and similar tools as the sole means to deny, delay, or modify care based on medical necessity. The Act, enacted on January 1, 2025, provides that final medical necessity determinations may be made only by a licensed physician or licensed health care provider who is competent in the specific clinical issues and services requested by the provider.

The bill applies to prospective, retroactive, and concurrent utilization functions and creates requirements for AI, algorithms, and other tools used in health care. Under the bill, these tools must:

• Base decisions regarding medical necessity on the enrollee’s medical or clinical history and circumstances;
• Be applied fairly and equitably;
• Be available to inspection for audit and compliance reviews by specified state agencies; and
• Be reviewed periodically to assess outcomes and ensure accuracy, reliability, and compliance with the Act.

2025 State Legislative Actions

During the 2025 Legislative Session, four states passed bills to prohibit payors from using AI to deny medical necessity or prior authorization determinations.

Arizona. HB 2175 requires that health care providers independently review claims and prior authorization requests prior to an insurer denial. The sole use of any other source to deny a claim or prior authorization is prohibited.

Maryland. HB 820 requires carriers to ensure that if an AI tool is used for utilization review, it must include medical history, individual circumstances, and other clinical information in its determination. Such AI tools must be open for inspection and audit by the state, and patient data may not be used for any purpose beyond the intended utilization review.

Nebraska. LB 77 prohibits AI output from being the sole basis of evaluating medical necessity in order to deny, delay, or modify health care services. The use of AI in utilization review must be disclosed to health care providers and enrollees and communicated clearly on the payor’s public website.

Texas. SB 815 prohibits the use of AI to make adverse determinations regarding medical necessity of services. Payors may only use AI for administrative support or fraud detection. The bill also requires any AI tools in use by payors to be subject to inspection by the Commissioner of Insurance.

Federal Actions

The Centers for Medicare and Medicaid Services (CMS) issued a Final Rule, effective January 2024, stating that Medicare Advantage (MA) plans may use AI, algorithms, and related technologies to make coverage determinations, but medical necessity determinations must be “based on the circumstances of each specific individual” and determinations “must be reviewed by a physician or other appropriate health care professional with expertise in the field of medicine or health care that is appropriate for the services at issue.”

In November 2024, CMS released a Fact Sheet discussing proposed changes to the MA Program for Contract Year 2026, including requiring MA plans to “ensure services are provided equitably, irrespective of delivery method or origin, whether from humans or automated systems.” When the Final Rule for the 2026 MA Program was released in April 2025, the rule did not include these proposed guardrails on AI, but CMS noted broad interest in the regulation of AI and stated the agency would “continue to consider the extent to which it may be appropriate to engage in future rulemaking in this area.”

By Leighann Thone and Iraida Orr
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The federal 340B Drug Pricing Program (340B) allows certain eligible entities that serve low-income patients to purchase discounted outpatient drugs from manufacturers that participate in Medicaid and Medicare Part B. Manufacturers must sell covered outpatient drugs at 340B prices to these entities. The difference between the cost of the drugs and the amount paid by insurance enables covered entities to use federal resources to improve accessibility and provide more comprehensive services, particularly in rural, low-income, and medically underserved areas.

Program Overview

Section 602 of the Veterans Health Care Act of 1992 added Section 340B of the Public Health Service Act. Under 340B, entities receive a 20.0 to 50.0 percent discount on the average manufacturer price of outpatient prescription drugs.

The covered entities may generate revenue under 340B if patients’ insurance reimbursements exceed the 340B price. Federal statutes do not restrict how covered entities may use this revenue. A survey by the Medicare Payment Advisory Commission, a group representing safety-net hospitals, showed that covered entities use the revenue to reduce patients’ drug costs, provide uncompensated care, and maintain broader hospital operations, among other things. The Health Resources and Services Administration (HRSA) Bureau of Primary Health Care, however, requires a federally qualified health center (FQHC) to use 340B discounts for community benefits to fulfill grant requirements and remain a covered entity.

According to the Office of Pharmacy Affairs within the Health Resources and Services Administration (HRSA OPA), which administers the 340B Program on behalf of the U.S. Department of Health and Human Services (HHS), the discounts enable covered entities “to stretch scarce federal resources as far as possible” to fund safety-net care.

While both the 340B Program and the Medicaid Drug Rebate Program offer rebates to states, states cannot order “duplicate discounts” or stack rebates on prescription drugs.

Eligible Entities

Section 340B(a)(4) of the Public Health Service Act specifies the entities that are eligible to participate in 340B. These include qualifying hospitals, FQHCs, and specialized clinics. Entities are not allowed to divert drugs purchased at the 340B price to an individual who is not a patient of the entity.

Contract Pharmacies

Some covered entities enter into agreements with non-affiliated retail pharmacies, known as contract pharmacies, to provide services to patients. Contract pharmacies are not included in the federal 340B enacting statute. However, in 2001, HRSA created Alternative Methods Demonstration Projects (AMDP), which allow certain covered entities to contract with retail pharmacies. This allowed entities without in-house pharmacies to dispense medications under 340B. In 2010, HRSA expanded 340B to allow covered entities to contract with multiple pharmacies without going through the AMDP process.

Covered Entities in Kansas

As of September 2025, there are 565 unique covered entities in Kansas, according to HRSA’s 340B Office of Pharmacy Affairs Information System (340B OPAIS). These entities account for a total of 963 registered sites, including child sites such as affiliated clinics and outpatient facilities.

While Disproportionate Share Hospitals (DSH) make up less than 1.0 percent of all unique entities, they account for over 25.0 percent of all registered sites.

Disproportionate Share Hospital. DSH facilities are general acute care hospitals that serve a disproportionate number of low-income patients and automatically qualify for 340B annually if they provide enough inpatient services to Medicaid and low-income Medicare beneficiaries.

Critical Access Hospital (CAH). CAHs are designated by the Centers for Medicare and Medicaid Services (CMS). The CAH designation aims to reduce the financial vulnerability of rural hospitals and enhance health care access by maintaining essential services in rural communities.

Sexually Transmitted Disease Clinics. STD clinics are non-hospital facilities that diagnose and treat STDs. These clinics are supported by the STD Control Program overseen by the Centers for Disease Control and Prevention.

Updates and Developments

HRSA-funded Health Centers

On July 31, 2025, HRSA announced new award terms requiring health centers to offer insulin and injectable epinephrine to low-income patients at or below the centers’ 340B acquisition cost. The agency stated the change is aimed at lowering out-of-pocket costs for these medications. The change aligns with Executive Order 14273, Lowering Drug Prices by Once Again Putting Americans First. Health centers are expected to implement the new terms immediately.

340B Rebate Model Pilot Program

In August 2025, HRSA announced the launch of a voluntary 340B Rebate Model Pilot Program to test an alternative to the traditional upfront discount system under the 340B Drug Pricing Program. In this pilot, participating drug manufacturers will provide post-sale rebates to covered entities instead of upfront discounts.

The pilot targets drugs included on the Medicare Drug Price Negotiation Program’s Selected Drug List for the 2026 applicability year. Manufacturers with agreements under this program must submit plans to HRSA by September 15, 2025, with approvals expected by October 15, 2025. Implementation will begin January 1, 2026, and continue for at least one year.

Key requirements include:

• Manufacturers must bear all administrative and data submission costs;
• Covered entities must receive at least 60 days’ advance notice before implementation;
• Data on dispensed drugs can be submitted within 45 days of dispensing;
• Rebates must be paid within 10 days of data receipt; and
• Information technology (IT) systems used must be secure and comply with HIPAA privacy standards.

Limited to selected drugs and manufacturers initially, the pilot program will help HRSA evaluate the rebate model’s effectiveness and inform the development of a formal process for approving future 340B pricing models that comply with the 340B statute and the Administration’s goals.

Recent Kansas Legislation

2025 SB 284 was introduced by the Senate Committee on Federal and State Affairs. The bill would enact the Defense of Drug Delivery Act. Specifically, the bill would prohibit drug manufacturers; third-party logistics providers; repackagers; and an agents, contractors, or affiliates from limiting or interfering with the acquisition or delivery of 340B drugs to covered entities, unless required by federal or state law. It would also prohibit manufacturers from requesting health information or other data as a condition of access to 340B drugs, unless required by law.

The bill would authorize the Attorney General to adopt rules and regulations, administer the newly created Defense of Drug Delivery Fund, and impose civil penalties of up to $50,000 per violation, with each package of 340B drugs considered a separate violation. The State Board of Pharmacy would be authorized to investigate complaints and impose discipline, suspension, or revocation of the registration or permit of such person or entity.

The Senate Committee on Financial Institutions and Insurance amended the bill to clarify that wholesalers and virtual wholesalers are not among the entities prohibited from limiting 340B drug delivery but may be investigated if they possess evidence relevant to a complaint.

Active Covered Entities in Kansas

Source: HRSA 340B OPAIS data, accessed September 2025.

The bill passed the Senate on emergency final action on March 20, 2025. On March 24, 2025, the bill was referred separately to the House Committees on Interstate Cooperation and Insurance. As of the 2025 Interim, the bill remains in committee and has not yet been considered by the full House. Kansas’ two-year legislative cycle means SB 284 will remain active through the 2026 Session.

U.S. Supreme Court Case

On June 15, 2022, the U.S. Supreme Court ruled in American Hospital Association v. Becerra that the reimbursement payment rates set by HHS for drugs obtained under 340B in calendar years 2018 and 2019 were unlawful. The Court’s decision was based on HHS’s failure to conduct a required survey of hospitals’ acquisition costs before implementing the rates.

By Arianna Waddell and Leighann Thone.
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HB 2075 Implementation

The 2025 Legislature passed HB 2075, requiring the Secretary for Children and Families to respond within 24 hours of receipt of a referral from a law enforcement agency that a child may be a victim of abuse or neglect. This response includes contacting the persons who are subject to the report made by law enforcement and providing a status update to the referring law enforcement agency.

At the August 2025 meeting of the Joint Committee on Child Welfare System Oversight, the Department for Children and Families (DCF) regional directors and a representative of Kansas law enforcement agencies provided an update on the implementation of HB 2075.

DCF regional directors emphasized the benefits of enhanced communication and information sharing between law enforcement agencies and DCF regional offices. While some initial challenges emerged with implementing the new policy, particularly around ensuring weekend and holiday coverage, each region stated it is proactively developing solutions. Strategies include hiring part-time staff, using voluntary sign-ups, and scheduling rotations to ensure 24-hour follow-up coverage. Directors shared positive outcomes, such as children remaining safely at home with DCF-provided wraparound services, thereby avoiding unnecessary trauma from police protective custody. One director did note an instance where a regional office received a large backlog of police reports, some over a month old. The director commented that this would be an educational opportunity to resolve the issue.

The representative of law enforcement agencies expressed strong support for DCF’s implementation of HB 2075. The representative praised the agency’s collaborative efforts, including in-person and virtual town halls for law enforcement and community members. Based on a survey of chiefs of police and sheriffs, all but one gave positive feedback. This dissenter was personally encouraged to better engage with their DCF regional counterpart. Lastly, the representative expressed excitement for the new online training developed jointly by DCF and the Kansas Law Enforcement Training Center.

Executive Order No. 25-01

The federal Achieving a Better Life Experience (ABLE) Act of 2014 established tax-advantaged savings accounts designed to allow individuals with disabilities to save money without jeopardizing their eligibility for other benefit programs such as Medicaid. These ABLE accounts can hold various federal cash benefits including Supplemental Security Income (SSI), Social Security Administration (SSA) survivor benefits, and Veterans Affairs (VA) benefits.

Despite the intent of the ABLE Act to promote long-term financial security for individuals with disabilities, it remained a longstanding and widespread practice for states, including Kansas, to act as representative payees of children in foster care, and collect federal benefits on behalf of eligible children. These funds were then used to offset the cost of foster care—an approach that was historically accepted under the rationale that the benefits were being used for the immediate needs of the child.

However, this practice has come under increased scrutiny in recent years. Critics argue that these funds should be preserved for the child’s future needs and transition to adulthood, rather than used to reimburse the state for foster care costs.

In response, there has been growing national momentum for reform, including Kansas Executive Order 25-01, issued on January 10, 2025. Among other provisions, the order seeks to ensure that federal cash benefits received by children in foster care remain with the child, rather than being diverted to cover foster care maintenance payments.
However, implementing this policy change is projected to have significant fiscal implications to the state budget. Specifically, it is estimated that the shift will increase the State General Fund (SGF) share of foster care maintenance payments by approximately $8.0 to $9.0 million annually. This reflects the additional cost the state will bear by no longer using children’s federal benefits to offset foster care expenses.

Comprehensive Child Welfare Information System Update

In the 1990s, the federal government introduced SACWIS (Statewide Automated Child Welfare Information System). SACWIS is a federally funded framework designed to support child welfare case management services under Title IV-E of the Social Security Act. Kansas, however, did not receive federal certification for its case management system at the time and therefore was ineligible for the enhanced federal matching funds for system development. In 2016, the federal government published the final rule for CCWIS (Comprehensive Child Welfare Information System), a modernized version of SACWIS. This updated the federal regulation framework for the design, development, and operation of a child welfare information system eligible for Title IV-E funding. Since then, Kansas has been working toward compliance and participation in CCWIS.

The Kansas CCWIS aims to consolidate multiple legacy systems into a single, integrated platform that meets the CCWIS federal standards. The project is expected to cost a total of $100 million over the estimated four-year development period, with approximately 50 percent of the total cost coming from the SGF. Initially, the agency was allocated $2 million SGF annually for the project. Subsequently, as bids for the work were received, the 2024 Legislature approved an increase of $8.5 million SGF increase per year to the project’s base budget. As of state fiscal year (SFY) 2026, the agency receives $10.6 million SGF as a part of their base budget for the CCWIS project.

In July 2025, DCF announced the awarding of contracts for the CCWIS project. The largest of these is the Design, Development, and Implementation (DDI) contract, valued at $44 million, which was awarded to RedMane Technology, LLC., a Chicago-based firm selected through the competitive procurement process. DCF states this is a four-year contract with three 36-month optional renewals, if needed.

Two additional contracts were also awarded:

• Maximus US Services, Inc. received a $2.1 million contract to serve as the Independent Verification and Validation (IV&V) vendor. DCF states that this will expire at the end of SFY 2029; and
• CSG Government Solutions was awarded $4.7 million to provide quality assurance services throughout the duration of the project. DCF states this is a three-year contract with five one-year renewals, if needed.

The 2025 Legislature deleted approximately $26.8 million in reappropriated funds from DCF. According to the agency, these funds represented a savings accumulated over time across multiple programs and were intended to support the CCWIS contract. However, the agency was unable to encumber the funds prior to their deletion, as the final CCWIS contracts had not been signed. Now that the contracts have been finalized, the agency is advocating to reappropriate approximately $7.7 million SGF agency-wide savings from SFY 2025 to SFY 2027 to fulfill obligations under the signed contracts.

Foster Care, By the Numbers

DCF reports Kansas has had a 25 percent decline of children in foster care since 2019 (7,588 in SFY 2019 to 5,690 in SFY 2025). Additionally, fewer children entered foster care in SFY 2025, a total of 2,473 children in SFY 2025 versus a high of 4,212 children in SFY 2018. DCF credits the State’s investment in preventative efforts to keep families together.

When compared nationally, Kansas continues to be identified as a state with a high removal rate. In federal FY 2023, Kansas improved by three spots to rank 10th in the nation with 3.84 removals per 1,000 children compared with the national average of 2.22 removals per 1,000 children. Approximately 61 percent of children are removed from the home due to abuse or neglect and 39 percent are removed as the family undergoes an assessment to determine future outcomes. The percentage of children removed for abuse and neglect has decreased over time, and the percentage of children removed during a family needs assessment has increased as the State invests in prevention efforts aimed at keeping families together.

By Amanda Prosser and Elizabeth Cohn.
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Required Vaccinations for Students

KSA 72-6262 et seq. requires proof of certain vaccinations for all students enrolling for the first time in a school, preschool, day care program operated by a school, or as designated by the Secretary of Health and Environment (Secretary). Certification must be from a licensed physician or local health department and detail that the student has received all tests and vaccines as deemed necessary by the Secretary.

The vaccinations currently required for each susceptible child are the following: Diphtheria; Hepatitis A; Hepatitis B; Measles (Rubeola); Meningitis; Mumps; Pertussis (Whooping Cough); Poliomyelitis (Polio); Rubella (German Measles); Tetanus; and Varicella (Chickenpox). The vaccination list is set out in KAR 28-1-20, and any changes to the list are required to go through the rules and regulations process. KSA 76-761a requires each college and university to have policies and procedures, including a waiver procedure, for all incoming students who reside in student housing to be vaccinated for meningitis.

Click or tap on the following charts to see vaccination rates among kindergarteners for five different vaccines:

Alternatives to the Certification of Completion

A student, in accordance with KSA 72-6262, who has not completed the required vaccinations is required to present to the school one of the following:

• A written statement, signed by a licensed physician, stating the physical condition of the child is such that the tests or inoculations would seriously endanger the life or health of the child. This statement must also be submitted annually; or
• A written statement signed by one parent or guardian that the child is an adherent of a religious denomination whose religious teachings are opposed to such vaccinations. [Note: Kansas City, Kansas, Public Schools have a standardized form: Religious Exemption from Immunizations.]

2025 Measles Outbreak

In early 2025, the Kansas Department of Health and Environment (KDHE), Division of Public Health, recognized an outbreak of measles cases. As of August 13, 2025, the published data reflects there have been 90 total cases of measles in Kansas in 2025, and 87 of those cases are associated with the outbreak, with 12 counties having a case of measles. The ethnicity case rate reflects 7 cases in the Hispanic or Latino ethnicity and 81 in the Not Hispanic or Latino ethnicity.

Cases are split by age groups as follows:

KDHE states the routine recommendation is two doses of the Measles, Mumps, and Rubella (MMR) vaccine with the first dose at age 12-15 months and the second dose at age 4-6 years before school entry. KDHE notes that one dose is 93 percent effective against measles, and two doses are 97 percent effective. Updated maps are available on the KDHE Measles Outbreak Dashboard for community transmission as well as the location of publicly funded MMR vaccine clinics in Kansas.

Cost of the Measles Outbreak

KDHE presented on the estimated cost of a measles outbreak at the July 2025 Robert G. (Bob) Bethell Joint Committee on Home and Community Based Services and KanCare Oversight (Bethell Committee). KDHE estimated a cost of $2.6 million calculated as follows: KDHE used a review of the costs of measles outbreaks in the United States that was gathered by the Centers for Disease Control and Prevention (CDC) from 2001 to 2018 for the purpose of a simple estimate for the Bethell Committee. The review estimated the median cost per measles case at $32,805 and the median cost per contact at $223. Based on that information, KDHE estimated the cost of measles in Kansas from Jan. 1, 2025, to June 16, 2025, at a total of $2,665,432 (80 measles cases, 184 cases under public health monitoring).

Statewide Vaccine Coverage and Exemptions

The KDHE Kindergarten Immunization Dashboard reports on the following vaccines:

The statewide school entry vaccine coverage by academic year for all required vaccines and the statewide exemption rate were the following:

Source: KDHE Kindergarten Immunization Data [Note: The data also includes a breakdown by school district and certain private schools.]

By Elizabeth Cohn and Amanda Prosser.
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Background

The Food Stamp Act of 1964, which established the original federal framework for food assistance, did not include a formal or comprehensive quality control system. In the early 1980s, the current system for measuring Supplemental Nutrition Assistance Program (SNAP) payment errors was established, with the U.S. Department of Agriculture (USDA) issuing error rates annually.

Today, the USDA employs a two-tiered quality control system to monitor SNAP eligibility and benefit accuracy. Under this system, states and the federal government collaboratively review SNAP cases. In Kansas, the Department for Children and Families (DCF) conducts monthly reviews of a sample of cases. The USDA’s Food and Nutrition Service (FNS) then re-examines a subset of those cases to verify state accuracy by conducting interviews with selected participants and requesting additional documentation.

As a result of this quality control process, the USDA publishes four efficiency and effectiveness measures based on collected data.

Application Processing Timeliness Rate

The application processing timeliness (APT) rate measures how efficiently eligible applicants receive benefits on time. The Food and Nutrition Act of 2008 considers timeliness to be when all eligible households receive SNAP benefits within 30 days of application or within 7 days for those eligible for expedited service. The APT rate is calculated by dividing the number of SNAP applications timely approved by the total number of applications approved within that time frame.

Case and Procedural Error Rate

The case and procedural error rate (CAPER) reflects both the accuracy of the state agency’s determination and its compliance with federal procedural requirements around the determination. A case and procedural error occurs when a state takes one or more inaccurate or procedurally incorrect actions when denying, terminating, or suspending a household’s SNAP benefits. The rate indicates that a decision was inaccurate; the notice provided to the household was inaccurate, unclear, or insufficient; the notice provided to the household was untimely; and/or the procedures followed related to these decisions were inaccurate or untimely. The national rate is a weighted average of individual state rates, with the weighting based on a state’s proportion of total SNAP benefit issuance.

Program Access Index

The program access index (PAI) measure is designed to indicate the degree to which low-income people have access to SNAP benefits. It is not the participation rate, where the denominator is the number of people eligible. The PAI was designed to meet the federal requirements of the Farm Security and Rural Investment Act of 2002 (also known as the 2002 Farm Bill), which established performance bonus payments to states with the highest PAI and the states with the most improved performance for program participation. A precise participation rate cannot be used to evaluate performance because of timing. Part of the federal requirement was that an award must be paid by the end of the fiscal year following the calendar year of performance.

To calculate the calendar year participation rate, an accurate estimate of people eligible for SNAP benefits is needed. This number is calculated by the American Community Survey and is on a one–to-two-year delay. Therefore, a true participation rate cannot be calculated to meet the federal timing requirement. For this reason, the designed PAI uses the federal poverty line for the given performance year rather than the number of eligible people.

Payment Error Rate

The payment error rate measures how accurately a state agency determined SNAP eligibility and benefit amounts for those who participate in SNAP. This rate can be displayed to show overpayments, underpayments, and as an aggregate rate. A lower rate is preferred. The national payment error rate is calculated as a weighted average of all individual state payment error rates, with weighting determined by a state’s proportion of total SNAP benefit issuance.

Click or tap to enlarge the following charts to see data on SNAP applications and payments.

Impact of the One Big Beautiful Bill Act

Section 10105 of the One Big Beautiful Bill Act amends Section 4(a) of the Food and Nutrition Act of 2008 (FNA) to establish state cost-sharing requirements for the SNAP benefit issuance, beginning federal fiscal year (FFY) 2028. Beginning in FFY 2028, the state share of SNAP benefit costs will be based on the state’s SNAP payment error rate, which includes the following cost-sharing structure:

In FFY 2028, states may elect to use their payment error rate from FFY 2025 or FFY 2026 to determine their required cost-share. Beginning in FFY 2029, the applicable rate will be based on the state’s payment error rate from the three fiscal years prior.
States with very high error rates may have the cost-sharing requirement delayed. States may qualify for a delay if their error rate meets either of the following criteria:

• A fiscal year’s payment error rate is equal to or greater than 20.0 percent when multiplied by 1.5; or
• A two-year average of a state’s payment error rate is equal to or greater than 20.0 percent when multiplied by 1.5.

These provisions may affect Kansas, depending on the state’s SNAP payment error rate in the years used to calculate the required state match. The 2024 Kansas SNAP aggregate error rate is 9.98 percent as published by the USDA. DCF estimated the first quarter of 2025 error rate to be calculated at 9.47 percent. Based on the 2024 rate, Kansas would have been required to contribute a 10.0 percent state match under the proposed framework, equivalent to approximately $40.8 million in benefit costs.

By Amanda Prosser and Iraida Orr.
See Health and Social Services for more.