New SNAP Work Requirements: What Changed and Who May Be Affected
The 2025 expansion of SNAP work requirements has created real confusion for food-insecure households across the country — including in states like Minnesota, where advocates are documenting a measurable drop in participation among people who may still be eligible for the Supplemental Nutrition Assistance Program (SNAP). If you've heard about these rule changes and aren't sure whether they apply to you, this article walks through exactly what changed, who is and isn't covered, what exemptions exist, and what practical steps you can take to protect your household's access to food assistance.
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Data Snapshot
According to the USDA Food and Nutrition Service (FNS), SNAP served approximately 42.1 million people per month in fiscal year 2023, at a total program cost of roughly $112.8 billion (source: https://www.fns.usda.gov/snap/data-tables). The 2025 age-ceiling expansion under the Fiscal Responsibility Act of 2023 is estimated to bring hundreds of thousands of additional adults — those between ages 50 and 54 — under the ABAWD time-limit rules for the first time. State-level advocates, including those tracking enrollment in Minnesota, report that fear of the new rules — not actual ineligibility — appears to be driving some households away from benefits they may still be able to access. Benefit amounts vary by household size and income; the USDA does not publish a single national average that accounts for all household configurations.
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What Are SNAP Work Requirements?
SNAP has long included work-related rules for a specific group of recipients called Able-Bodied Adults Without Dependents (ABAWDs). These are generally adults who do not have children or other dependents living with them and who are not otherwise exempt due to a physical or mental health condition.
Under the rules in place before the 2023 legislative change, ABAWDs between the ages of 18 and 49 were limited to 3 months of SNAP benefits in any 36-month period unless they met one of the following conditions each month:
- Working at least 80 hours per month
- Participating in a qualifying job training or workforce development program for at least 80 hours per month
- Volunteering through a structured community service program for at least 80 hours per month
- Meeting an approved exemption (detailed below)
What Changed in 2025
The Fiscal Responsibility Act of 2023 included a phased expansion of ABAWD work requirements. As of October 1, 2025, the age ceiling for these rules rose to 54 years old. This means able-bodied adults without dependents between ages 18 and 54 are now subject to the 80-hour monthly participation requirement.
This is a meaningful shift. Adults in their early 50s who had been receiving SNAP without work-related conditions now need to either meet the participation threshold or qualify for an exemption. For people in physically demanding jobs, dealing with undiagnosed health conditions, or living in areas with limited employment opportunities, this change can feel abrupt and difficult to navigate.
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Who Is Exempt From SNAP Work Requirements?
This is where many people get confused — and where the documented "chilling effect" does the most harm. A substantial portion of people who technically fall within the ABAWD age range are exempt from these rules and may continue receiving SNAP without meeting the 80-hour monthly requirement.
You may be exempt if you:
- Are physically or mentally unfit for work (documentation from a medical provider or evidence of a disability may be required)
- Are pregnant
- Are responsible for the care of a child under age 18 or an incapacitated adult in your household
- Are already enrolled in a drug or alcohol treatment or rehabilitation program
- Are a veteran (exemption rules vary by state)
- Live in an area your state has designated as having insufficient job opportunities — states can request federal geographic waivers for high-unemployment counties or regions
- Are experiencing homelessness
- Are enrolled at least half-time in school or a vocational training program
States also have the authority to grant a limited number of categorical exemptions each year, allowing them to protect a percentage of their ABAWD caseload from the time limit regardless of work status. The availability and scope of these exemptions vary significantly from state to state.
If you are unsure whether you qualify for an exemption, do not simply stop participating in SNAP. Contact your local SNAP office or a benefits navigator to review your specific situation before making any decisions.
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The 'Chilling Effect': Why Eligible People Are Leaving SNAP
Advocates in Minnesota and other states have documented what researchers call a chilling effect — a pattern in which confusing or fear-inducing policy changes cause eligible people to disenroll from or avoid programs they could still access.
This happens for several interconnected reasons:
- People receive a notice about work requirements and assume they no longer qualify, even when they are exempt
- The language in official notices can be difficult to parse, especially for people with limited English proficiency or low literacy
- Fear of making a mistake or being accused of fraud leads some households to opt out preemptively
- Limited access to caseworkers or benefits navigators makes it harder to get clear, timely answers
If you or someone you know has stopped receiving SNAP — or decided not to apply — because of concerns about work requirements, it may be worth revisiting that decision with the help of a local food bank, legal aid organization, or benefits navigator. Many of these organizations offer free assistance and can help clarify whether the rules actually apply to your household.
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SNAP Income Eligibility: General Federal Thresholds
Regardless of work requirements, SNAP eligibility is also based on household income. The general federal thresholds are:
- Gross income limit: 130% of the Federal Poverty Level (FPL)
- Net income limit: 100% of the FPL (after allowable deductions for housing costs, childcare, medical expenses, and other factors)
- Asset limits: Vary by state; many states have eliminated or significantly raised asset tests in recent years
Benefit amounts vary by household size and income. Some states have expanded eligibility through broad-based categorical eligibility rules, which may allow households with gross incomes up to 200% of FPL to qualify under certain circumstances. Your state's specific rules may differ from the federal baseline.
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Documents You May Need to Apply or Respond to a Work Requirement Notice
Whether you are applying for SNAP for the first time or responding to a work requirement notice, gathering the right documents before contacting your local office can save significant time. You may need:
- Proof of identity (driver's license, state ID, or passport)
- Proof of residency (utility bill, lease agreement, or recent mail with your address)
- Proof of income (recent pay stubs, an employer letter, a Social Security award letter, or self-employment records)
- Proof of household expenses (rent or mortgage statements, utility bills, childcare costs, or medical expense documentation for elderly or disabled household members)
- Social Security numbers for all household members who are applying
- Documentation supporting an exemption claim, if applicable — this might include a letter from a physician, disability documentation, school enrollment verification, or proof of caregiving responsibilities
Not every document on this list will be required in every state or situation. Your local SNAP office can tell you exactly what is needed for your case.
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How to Respond If You Receive a Work Requirement Notice
Receiving an official notice about work requirements can feel alarming. Here is a practical, step-by-step approach:
- Read the notice carefully. Look for a response deadline, a contact phone number or address, and any case number associated with your household.
- Check whether you may be exempt. Review the exemption categories above and honestly assess your current situation — health, caregiving responsibilities, school enrollment, and local job market conditions all matter.
- Contact your local SNAP office. Ask specifically: "I received a work requirement notice — can you help me understand whether I qualify for an exemption?"
- Request a fair hearing if you disagree with a decision. Every SNAP recipient has the legal right to appeal. The notice you received should include instructions on how to request a hearing, including the deadline to do so.
- Reach out to a local legal aid organization or food bank. Many offer free benefits navigation services and can help you understand your rights and prepare for a hearing if needed.
You can find your state SNAP office through the USDA's official state directory at https://www.fns.usda.gov/snap/state-directory.
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What Counts as a Qualifying Work Activity?
If you are subject to work requirements and are not exempt, the following activities generally count toward the 80-hour monthly threshold:
- Paid employment (part-time or full-time, with documentation)
- Self-employment (with records of hours and income)
- Workfare (work assignments arranged through your SNAP office)
- Job search programs operated through your state workforce agency
- Vocational training or education programs approved by your state
- Structured community service or volunteer work (must be documented and organized through a recognized program)
Contact your state's SNAP Employment and Training (E&T) program to find approved activities in your area. Many states offer free job training, resume assistance, and job placement services specifically for SNAP recipients — at no cost to participants.
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A Note on State Waivers
Not all states enforce ABAWD work requirements uniformly. States with high unemployment rates or documented insufficient job opportunities can apply to the USDA for geographic waivers that exempt residents in specific counties or regions from the time limit. Whether your area is currently covered by a waiver depends on your state and county — and waiver status can change from year to year.
Check with your local SNAP office or visit your state's SNAP agency website for current waiver information. The USDA FNS also publishes waiver approval information at https://www.fns.usda.gov/snap/waivers.
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Program eligibility and availability vary by state. Not affiliated with any government agency.
Last reviewed: July 2025