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Supplemental Nutrition Assistance Program work requirements
Supplemental Nutrition Assistance Program (SNAP) work requirements are mandated work-related activities that SNAP recipients must complete in order to qualify for benefits, such as working at least 30 hours a week, participating in SNAP Employment and Training (E&T) programs, and taking a suitable job if it is offered. SNAP—formerly known as food stamps—has two types of work requirements: general work requirements and able-bodied adult without dependents (ABAWD) work requirements.[1]
The U.S. Department of Agriculture (USDA) promulgates rules and develops federal SNAP program guidelines. State-level agencies administer their SNAP programs following federal requirements, including work requirements.[2]
Background
- See also: U.S. Department of Agriculture
SNAP has two types of work requirements: general work requirements and able-bodied adult without dependents (ABAWD) work requirements. The following sections provide information about the two types of SNAP work requirements.
General SNAP work requirements
General SNAP work requirements mandate that individuals aged 16 to 59 who can work must complete the following work-related activities:
- Register for work
- Participate in SNAP Employment and Training (E&T) programs
- Take a suitable job if it is offered
- Not voluntarily quit a job or reduce work hours below 30 hours a week without cause.[3]
Individuals do not have to register for general work requirements if they already meet the following conditions when they apply for SNAP benefits:
- Work at least 30 hours a week
- Meet work requirements for another public benefits program
- Care for a child under six years old or an incapacitated person
- Are unable to work due to a physical or mental limitation
- Are participating in an alcohol or drug treatment program
- Are studying in school
- Are attending a training program[3]
Able-bodied adult without dependents (ABAWD) work requirements for SNAP
The ABAWD (Able-Bodied Adult Without Dependents) work requirement under SNAP applies to individuals aged 18 to 64 without children. To remain eligible for SNAP, ABAWDs must meet one of the following work-related activities:
- Work or Volunteer: At least 80 hours per month (about 20 hours per week).
- Participate in a Work Program: Participate in a federal, state, or local work program, such as SNAP Education and Training (E&T), for at least 80 hours per month.
Time Limit for ABAWDs
ABAWDs who do not meet the work requirement can only receive SNAP benefits for three months in a 36-month period. After reaching this time limit, they lose eligibility for benefits unless they start meeting the work requirement.[3][4]
Requalifying for SNAP Benefits
If an ABAWD loses eligibility due to failing to meet the work requirement, they can requalify for benefits by meeting the work requirement for 30 consecutive days. However, if they do not meet the work requirement within this 30-day period, they will be ineligible for SNAP for the next three years.
Time Limit Waivers
States can request temporary waivers for ABAWD work requirements in areas where jobs are scarce. These waivers apply in places with an unemployment rate above 10%, or in noncontiguous states (Alaska and Hawaii) if the unemployment rate is at or above 1.5 times the national unemployment rate.[5]
As of the third quarter of the 2025 fiscal year, three states had full ABAWD time limit waivers, and 25 states had waivers for specific counties with high unemployment.[6]
History of food stamp work requirements
This section includes information on the history of work requirements for the SNAP program, formerly known as food stamps.
States adopt food stamp work requirements
President John F. Kennedy (D) issued his first executive order, on February 2, 1961, calling for an expanded food distribution program and the initiation of food stamp pilot programs. The Food Stamp Act of 1964, signed by President Lyndon B. Johnson (D) on August 31, 1964, created the first pilot FSP under congressional control. The Food Stamp Act of 1964 allowed the U.S. Congress to enact food stamp regulations into law. The bill required state plans of eligibility standards and some states adopted work requirements as part of those state plans.[7]
Amendments to the Food Stamp Act establish national work registration requirements
The Food Stamp Act Amendment of 1970, signed by President Richard Nixon (R) on January 11, 1971, established national standards of eligibility and work registration requirements. It required ABAWDs to register for work at state or federal employment offices and accept suitable employment if offered in order to retain eligibility.[2][8]
The Food and Agriculture Act of 1977 creates uniform standards for work requirements
The Food and Agriculture Act of 1977, signed by President Jimmy Carter (D) on September 29, 1977, created uniform standards for food stamp eligibility, including work registration requirements. Work registration rules required ABAWDs between 18 and 65 years of age to register for employment at state employment offices and accept suitable employment if offered. Administration of work registration and eligibility was governed by state and local welfare departments under uniform rules promulgated by the U.S. Department of Agriculture.
The Food Stamp Act of 1985 creates employment and training programs
The Food Stamp Act of 1985, signed into law by President Ronald Reagan (R) on December 23, 1985, replaced the job search requirement with participation in Employment and Training (E&T) programs for food stamp recipients. It required all states to implement E&T programs for food stamp recipients by April 1, 1987. States were responsible for creating and administering E&T programs and the federal government created national standards for state programs. Federal requirements mandated that E&T programs contain a job search, job search training, workfare, or work experience training component. SNAP E&T services are offered by states or state partners such as colleges, American Job Centers, national Community-Based Organizations (CBOs), and state agencies. States must submit an annual SNAP E&T plan to the USDA each year and describe qualifying work activities.[9]
The Personal Responsibility and Work Opportunity Reconciliation Act creates new work requirements for food stamps
The Personal Responsibility and Work Opportunity Reconciliation Act (PRWORA), signed by President Bill Clinton (D) on August 22, 1996, created new work requirements for food stamp recipients. It required individuals ages 15 to 60 to register for employment programs and stipulated that they may not refuse employment or participation in training programs without good cause. It limited FSP participation to three out of 36 months for ABAWDs not working at least 20 hours a week or participating in a work program. The act required subsidized or unsubsidized employment, job training, work experience, community service, 12-month vocational training, and child care services for food stamp eligibility.[10]
The American Recovery and Reinvestment Act temporarily suspends work participation requirements
The American Recovery & Reinvestment Act of 2009 (ARRA), signed by President Barack Obama (D) on February 17, 2009, suspended the limitation that ABAWDs not working at least 20 hours a week only receive food SNAP benefits three out of 36 months from April 2009 through September 2010. The law stipulated that states could implement the time limit for ABAWDs who did not meet the work requirement if the state provided qualifying work activities to ensure that individuals could remain eligible for SNAP.[11]
Trump executive order calls for review and enforcement of work requirements
Executive Order 13828: Reducing Poverty in America by Promoting Opportunity and Economic Mobility, signed by President Donald Trump (R) on April 10, 2018, called for a review and enforcement of existing work requirements in SNAP and other public assistance programs. E.O. 13828 called for a review of federally funded workforce development programs and mandated that programs be consolidated if more than one executive department or entity administers similar programs. It mandated that state agencies enforce existing work requirements for public assistance programs, such as SNAP.[12]
The Food and Nutrition Service publishes rule on SNAP work requirements for ABAWDs
The Food and Nutrition Service (FNS) published a final rule on December 5, 2019, titled Supplemental Nutrition Assistance Program: Requirements for Able-Bodied Adults Without Dependents. The final rule limited the ability of U.S. Department of Agriculture to waive the time limit for ABAWDs when requested by states. On October 18, 2020, the rule was vacated by the U.S. District Court for the District of Columbia, which found that the final rule was arbitrary and capricious. [13][14]
The Families First Coronavirus Response Act, signed by President Donald Trump (R) on March 18, 2020, allowed states to use temporary SNAP flexibility to provide emergency benefit supplements. The Act prohibited states from removing ABAWDs from the SNAP program unless the individual refused to participate in state work programs or workfare programs. It suspended the participation time limit of three out of 36 months for ABAWDs who did not meet work requirements as long as those individuals did not refuse work opportunities provided by the state without good cause.[15]
The Fiscal Responsibility Act of 2023 changes SNAP work requirements
The Fiscal Responsibility Act of 2023, signed by President Joe Biden (D) on June 3, 2023, modified work requirements for SNAP benefits. Prior to the new law, able-bodied adults without dependents from ages 18 to 49 were required to complete 80 hours of work-related activities per month to receive SNAP benefits. The Fiscal Responsibility Act of 2023 implemented phased-in changes to SNAP work requirements and expanded the ages of work requirement participants to able-bodied adults without dependents between the ages of 18 to 54. The federal legislation also allowed new work exemptions for veterans, homeless individuals, and former foster children under age 25.[16][17]
The One Big Beautiful Bill Act changes SNAP work requirements
The 2025 budget reconciliation bill that was signed into law on July 4 changed the able-bodied adult without dependents (ABAWD) work requirement for SNAP. The age range for ABAWDs who are required to work was expanded from ages 18 to 54 to include adults up to age 64. Exemptions were removed for people who are currently homeless, who are veterans, who are responsible for a dependent child over the age of 13, and people who are 24 years old or younger and were in foster care when they became legal adults in their state. Exemptions were added for individuals who are defined as Indian, Urban Indian, or Californian Indian by the Indian Health Care Improvement Act.[18]
Under the new law, the following are exempt from the ABAWD work requirements for the SNAP program:
- People under 18 or over 65 years of age,
- Individuals who are medically certified as physically or mentally unfit for employment,
- Caregivers responsible for a dependent child under 14 years of age,
- People who are exempt from general SNAP work requirements,
- Individuals who are pregnant, and
- People defined as an Indian, Urban Indian, or Californian Indian by the Indian Health Care Improvement Act.
The bill also removed language allowing states to apply for time limit waivers to the ABAWD work requirements if there are insufficient jobs. States other than Alaska and Hawaii may only apply for these waivers if the unemployment rate is above 10%. The bill allows Alaska and Hawaii to acquire these time limit waivers if the unemployment rate is 1.5 times that of the national unemployment rate or more until the end of 2028.
Timeline of food stamp work requirements
The following timeline features noteworthy events related to the development and implementation of food stamp work requirements:
- January 31, 1964: The Food Stamp Act of 1964 allowed states to implement work requirements for food stamps.
- January 11, 1971: The Food Stamp Act Amendment of 1970 established national standards of eligibility and work registration requirements.
- September 29, 1977: The Food and Agriculture Act of 1977 established a national job search requirement for food stamp recipients.
- December 23, 1985: The Food Stamp Act of 1985 required all states to implement Employment and Training (E&T) programs for food stamp eligibility by April 1, 1987.
- August 22, 1996: The Personal Responsibility and Work Opportunity Reconciliation Act (PRWORA) required subsidized or unsubsidized employment, job training, work experience, community service, 12-month vocational training, and child care services for food stamp eligibility.
- February 17, 2009: The American Recovery and Reinvestment Act suspended the limitation that ABAWDs not working at least 20 hours a week only receive food SNAP benefits three out of 36 months from April 2009 through September 2010.
- April 10, 2018: Executive Order 13828 called for a review and enforcement of existing work requirements for SNAP.
- March 18, 2020: The Families First Coronavirus Response Act suspended the limitation that ABAWDs not working at least 20 hours a week only receive food SNAP benefits three out of 36 months.
- June 3, 2023: The Fiscal Responsibility Act of 2023 raised the age to meet work requirements for ABAWD over three phases.
- October 1, 2023: The age to meet work requirements for ABAWDs increased to 52, as outlined in the Fiscal Responsibility Act of 2023.
- October 1, 2024: The age to meet work requirements for ABAWDs increased to 54, as outlined in the Fiscal Responsibility Act of 2023.
- July 4, 2025: The age to meet work requirements for ABAWDs increased to 64, as outlined in the One Big Beautiful Bill Act of 2025.
The following selected court cases have affected the administration of food stamps work requirements:
Bread for the City v. USDA (2020)
The U.S. Department of Agriculture (USDA) , on February 23, 2018, proposed a rule that altered the criteria for approving state waivers for SNAP work requirements. The new criteria allowed the USDA to approve states' waivers removing work requirements and time limits for SNAP recipients only if the state satisfied one of two core standards: "(1)'a recent 12-month average unemployment rate over 10 percent;' or (2)a recent 24-month 'average unemployment rate 20 percent or more above the national rate.'" The final rule was published on December 5, 2019.[19]
On January 16, 2020, 14 states and the District of Columbia sued the USDA in the United States District Court for the District of Columbia. Plaintiffs argued that the final rule, by setting an unemployment rate floor for SNAP work requirement waivers and not removing that provision after public comments, was "arbitrary and capricious, contrary to law, and promulgated without observing procedural requirements." The plaintiffs asked for a preliminary injunction or a stay of the final rule until a final decision. Bread for the City, a nonprofit in Washington, D.C., filed a separate suit on January 16, 2020, making the same claims about the waiver portions of the final rule, and the cases were combined.[20]
The United States District Court for the District of Columbia granted a preliminary injunction on March 13, 2020. Justice Beryl A. Howell argued that an injunction was necessary because the rule would cause injuries amounting to nationwide impact: "The record in this case establishes that implementation of the waiver portions of the Final Rule would have 'nationwide impact' and would cause injuries of 'sufficient similarity to the plaintiff[s']' to other states and individuals throughout the country." The court vacated the rule on October 18, 2020, arguing in part that the rule was arbitrary and capricious.[21]
Noteworthy events
SNAP ABAWD work requirement changes included in budget reconciliation bill (2025)
The 2025 budget reconciliation bill that was signed into law on July 4 changed the able-bodied adult without dependents (ABAWD) work requirement for SNAP. The age range for ABAWDs who are required to work was expanded from ages 18 to 54 to include adults up to age 64. Exemptions were removed for people who are currently homeless, who are veterans, who are responsible for a dependent child over the age of 13, and people who are 24 years old or younger and were in foster care when they became legal adults in their state. Exemptions were added for individuals who are defined as Indian, Urban Indian, or Californian Indian by the Indian Health Care Improvement Act.[18]
Under the new law, the following are exempt from the ABAWD work requirements for the SNAP program:
- People under 18 or over 65 years of age,
- Individuals who are medically certified as physically or mentally unfit for employment,
- Caregivers responsible for a dependent child under 14 years of age,
- People who are exempt from general SNAP work requirements,
- Individuals who are pregnant, and
- People defined as an Indian, Urban Indian, or Californian Indian by the Indian Health Care Improvement Act.
The bill also removed language allowing states to apply for time limit waivers to the ABAWD work requirements if there are insufficient jobs. States other than Alaska and Hawaii may only apply for these waivers if the unemployment rate is above 10%. The bill allows Alaska and Hawaii to acquire these time limit waivers if the unemployment rate is 1.5 times that of the national unemployment rate or more until the end of 2028.
Robert F. Kennedy Jr., Mehmet Oz, Brooke Rollins, and Scott Turner on work requirements for public assistance programs
Secretary of Health and Human Services Robert F. Kennedy Jr., Administrator of the Centers for Medicare & Medicaid Services, Mehmet Oz, Secretary of Agriculture Brooke Rollins, and Secretary of Housing and Urban Development Scott Turner cowrote a New York Times opinion piece, that was published on May 14, 2025. The secretaries and administrator expressed their feelings on work requirements for public assistance and support for a 20 hour/week work requirement across programs.[22]
They wrote:
| “ |
Establishing universal work requirements for able-bodied adults across the welfare programs we manage will prioritize the vulnerable, empower able-bodied individuals, help rebuild thriving communities and protect the taxpayers.[23] |
” |
| “ |
Our agencies are united in a very straightforward policy approach: Able-bodied adults receiving benefits must work, participate in job training or volunteer in their communities at least 20 hours a week. Limited exceptions will be made for good cause, like caring for young children and health issues, but the principle is clear — those who can work, should.[23] |
” |
USDA press release states: Those who can work should (2025)
On April 17, the U.S. Department of Agriculture (USDA) published a press release and a memorandum concerning the able-bodied adult without dependents (ABAWD) time limit waivers for the SNAP work requirement. The USDA statements argued that those who can work should work. Both documents mentioned that the Fiscal Responsibility Act of 2023 amended SNAP's purpose statement to include assisting low-income adults in obtaining employment and increasing their earnings as one of the program's goals.[24][25]
Secretary of agriculture Brooke Rollins stated:
| “ | It is important to remind states that Congress conditioned the receipt of benefits by able-bodied adults without dependents on satisfying work requirements. Many states have abused the system by requesting work requirement waivers. Today marks the start of a new era for SNAP—prioritizing work, career and technical education, and volunteering rather than idleness, excess spending, and misapplication of the law.[23] | ” |
Secretary Rollins was appointed by President Donald Trump (R) in his second administration.
New federal SNAP work requirements take effect (2023-2024)
Starting September 1, 2023, new Supplemental Nutrition Assistance Program (SNAP) rules took effect requiring some older Americans to work to qualify for food assistance, while also exempting other groups from working.
These SNAP work requirement modifications were included in the Fiscal Responsibility Act enacted on June 3, 2023, as part of the negotiations between President Joe Biden (D) and House Speaker Kevin McCarthy (R) to raise the debt ceiling.
Prior to the change, SNAP rules required able-bodied adults from ages 18 to 49 to work or attend job training for at least 80 hours a month. The Fiscal Responsibility Act gradually increases the age limit for work requirements for individuals to be eligible for the food assistance program. The timeline for the modified age-based work requirements occurs in three phases:
- September 1, 2023: The age to meet work requirements increased to 50.
- October 1, 2023: The age to meet work requirements increased to 52.
- October 1, 2024: The age to meet work requirements increased to 54.[26]
The federal legislation also added new exemptions for work requirements for some people. Those who no longer have to submit proof of work are veterans, homeless individuals, and former foster children under age 25. All of the new SNAP rules will expire on October 1, 2030.
The Center on Budget and Policy Priorities, a nonpartisan fiscal policy research group, argued in a report that the new work requirements “would put almost 750,000 older adults aged 50-54 at risk of losing food assistance … including many who have serious barriers to employment as well as others who are working or should be exempt but are caught up in red tape.”[27]
Following the passage of the Fiscal Responsibility Act, McCarthy argued in remarks on the House floor, “Work-capable adults without dependents will get a job, learn new skills, and earn a paycheck because of this bill’s new welfare reforms. These reforms are going to change people’s lives. Families will be stronger and more self-sufficient.”[28]
Legal challenges to Food and Nutrition Service rule (2019-2020)
The Food and Nutrition Service (FNS) of the U.S. Department of Agriculture (USDA) published a final rule in December 2019 that limited states' abilities to request time waivers for able-bodied adults without dependents (ABAWD) if the unemployment rate was over 10% or if there was a lack of sufficient jobs. Under normal conditions, ABAWDs can receive benefits for 3 months without meeting work requirements, but states can waive these time limits under certain conditions.[29]
December 2019: States sue Trump administration over food stamp rule
At least 14 states, the District of Columbia, and New York City sued the USDA for limiting their ability to waive work requirements during periods of high unemployment or in areas without sufficient jobs.[30]
October 2020: Judge strikes down USDA rule over SNAP beneifts
The U.S. District Court for the District of Columbia vacated the 2019 final rule in the October 18, 2020, decision in District of Columbia, et al., v. United States Department of Agriculture, et al., consolidated with Bread for the City v. USDA. The court found that "the final rule’s redefinition of waiver area is likely arbitrary and capricious."[31][32]
See also
- Arguments about work requirements for public assistance programs
- Court cases related to work requirements for public assistance programs
- Scholarly work related to work requirements for public assistance programs
External links
Footnotes
- ↑ USDA, "SNAP Work Requirements," accessed September 17, 2025
- ↑ 2.0 2.1 Every CRS Report, A concise history of the Food Stamp Program, accessed May 25, 2023
- ↑ 3.0 3.1 3.2 USDA, "SNAP Work Requirements," accessed May 16, 2023
- ↑ HHS, "SNAP ABAWD work requirements," accessed June 2, 2023
- ↑ Congress.gov, "H.R.1 - 119th Congress (2025 - 2026)," July 4, 2025
- ↑ USDA Food and Nutrition Service, "ABAWD Waivers," accessed July 1, 2025
- ↑ Gov Info, Food Stamp Act of 1963, accessed June 1, 2023
- ↑ FNS, Amendments to The Food Stamp Act of 1964, accessed May 30, 2023
- ↑ SNAP to Skills, USDA, accessed June 2, 2023
- ↑ ASPE, Personal Responsibility Work Opportunity Reconciliation Act, accessed May 30, 2023
- ↑ CBPP, SNAP Benefit Boost 2009, accessed June 1, 2023
- ↑ Gov Info, Executive Order 13828, accessed June 1, 2023
- ↑ "Justia," "District of Columbia, et al, v. U.S. Department of Agriculture, et al," accessed October 25, 2023.
- ↑ "Food and Nutrition Service," "Final Rule: SNAP Rescission of Requirements for ABAWDS: Notice of Vacatur, " accessed October 25, 2023.
- ↑ CBPP, Temporary Flexibility in SNAP, accessed May 16, 2023
- ↑ CNN, Here’s who would have to work for government benefits – and who wouldn’t – under the debt ceiling package, accessed June 22, 2023
- ↑ White House, HR 346, accessed June 22, 2023
- ↑ 18.0 18.1 Congress.gov, "H.R.1 - 119th Congress (2025 - 2026)," accessed July 10, 2025
- ↑ Federal Register, SNAP ABAWDs work requirement rule, accessed May 30, 2023
- ↑ Justia, District of Columbia et al v. U.S. Department of Agriculture, accessed May 30, 2023
- ↑ Justia, District of Columbia et al v. U.S. Department of Agriculture, accessed May 30, 2023
- ↑ New York Times, "Trump Leadership: If You Want Welfare and Can Work, You Must," May 14, 2025
- ↑ 23.0 23.1 23.2 Note: This text is quoted verbatim from the original source. Any inconsistencies are attributable to the original source.
- ↑ USDA, "USDA Reiterates Importance of Those Who Can Work, Should Work While Receiving SNAP," accessed April 28, 2025
- ↑ USDA FNS, "The Secretary’s Authority on Able-Bodied Adults Without Dependents (ABAWD) Waivers," accessed April 28, 2025
- ↑ USDA.gov, "Policy Memo: Fiscal Responsibility Act of 2023," accessed August 18, 2023
- ↑ CBPP.org, "Debt Ceiling Agreement’s SNAP Changes Would Increase Hunger and Poverty for Many Older Low-Income People; New Exemptions Would Help Some Others," accessed August 18, 2023
- ↑ Speaker.gov, "Speaker McCarthy’s Floor Speech on the Fiscal Responsibility Act," accessed August 18, 2023
- ↑ "Federal Register," "Supplemental Nutrition Assistance Program: Requirements for Able-Bodied Adults Without Dependents," accessed October 28, 2023
- ↑ "Politico," "14 states sue Trump administration over food stamp rule," accessed October 28, 2023
- ↑ "Food and Nutrition Service," "Final Rule: SNAP Rescission of Requirements for ABAWDS: Notice of Vacatur," accessed October 28, 2023
- ↑ "Justia," "District of Columbia, et al., v. United States Department of Agriculture, et al.," accessed October 28, 2023
