Have any states recently changed SNAP disability exemption rules or waivers as of 2025?

Checked on January 20, 2026
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Executive summary

Federal law in 2025 overhauled SNAP work rules and narrowed the circumstances under which states may suspend time limits and apply area waivers—changes that forced state agencies to update how they screen for and apply exemptions, but reporting does not show a wave of state laws redefining “disability” for SNAP; rather, states are changing implementation and waiver use consistent with new USDA/FNS guidance [1] [2] [3].

1. What Congress and USDA changed, and why it matters

The One Big Beautiful Bill Act of 2025 (often called H.R. 1 or OBBB) tightened SNAP work and time-limit rules and directed the USDA to limit geographic waivers, creating a federal baseline that reduces previous flexibility for states to suspend the ABAWD time limit where jobs were scarce [4] [1] [3].

2. USDA/FNS implementation: states must apply updated exemptions

USDA’s Food and Nutrition Service issued implementation guidance telling state agencies to apply updated exceptions to new and ongoing participants after screening and warned it would follow up with states operating waivers that are no longer eligible under the revised rules, effectively making states change administrative practice even where no state statute was passed [1].

3. How states have actually responded — administrative changes, not wholesale redefinition of disability

Several state agencies and local partners have posted notices explaining that formerly available waivers and exemptions will end and that additional recipients will now be screened against work rules, with Pennsylvania explicitly telling residents that some people who had been exempt will now face work requirements starting late 2025 [5] [6]; reporting emphasizes state-level implementation of federal direction rather than states individually rewriting disability definitions [7] [8].

4. What changed for disability exemptions and households with disabled members

Federal materials and FNS webpages continue to recognize special rules for elderly and disabled households (such as different income deductions and medical expense treatments), and they note ongoing exemptions for individuals medically unfit for work, but the new law’s broader application to caregivers and household-level effects means a household with no certified disabled member may lose prior protections—so disability as a protected individual status remains, while household-level exposure to work rules has expanded [9] [10] [4].

5. Waivers narrowed and the practical consequences on the ground

The new federal framework sharply limits area waivers — for example, permitting them only in areas with unemployment above about 10%, a threshold rarely met — which ends many state or county-level blanket suspensions of ABAWD limits and forces people previously exempt because of local waivers to either meet work/training requirements or qualify for an individual exemption [3] [2] [7].

6. Advocacy, uncertainty and what reporting does not show

Disability advocates and legal services groups warn the changes will increase paperwork, appeals, and coverage losses and note that states have differing timelines for implementation (some checking compliance starting Dec. 1, 2025), but the sources provided do not document a mass of state laws that redefined SNAP disability eligibility itself; instead they document federal law and FNS direction driving state administrative changes and the winding down of area waivers [4] [8] [11].

7. Bottom line

As of 2025, states have changed how they apply disability-related exemptions and waivers mainly through administrative implementation of federal reforms—USDA/FNS told states to apply updated exceptions and to narrow waivers, and at least some states (e.g., Pennsylvania) publicly adjusted rules and notices accordingly—yet evidence in the reporting shows implementation changes rather than widespread state-level redefinition of who counts as “disabled” for SNAP purposes [1] [5] [3].

Want to dive deeper?
Which states announced specific implementation timelines for SNAP work-rule enforcement in late 2025?
How do SNAP disability certifications and medical verifications differ across states under FNS guidance?
What legal challenges or lawsuits have been filed against the 2025 SNAP work-rule and waiver changes?