Fact check: What was the old SNAP work requirements

1. How the Rule Worked — A Simple Cap with a Big Catch

The policy applied specifically to ABAWDs, limiting their SNAP receipt to three cumulative months in any 36-month window unless they worked, participated in a work program, or engaged in training for at least 80 hours per month; otherwise, the time limit enforced benefit termination. This restriction is described as a longstanding provision in federal law, designed to tie benefits to work activity for a defined subset of recipients, and it functioned as a categorical eligibility limiter rather than a broad change to overall SNAP rules ^{[1] [5]}. Waivers could be granted by states under certain conditions, and those waivers were central to how many people remained eligible despite the federal cap ^[4].

2. What Enforcement Looked Like in Practice — Waivers and the Pandemic Break

In practice, the three-in-36 rule was often softened by state waivers and exemptions, which allowed many ABAWDs to continue receiving benefits; during the COVID-19 pandemic, federal and state actions waived those time limits broadly, effectively pausing enforcement and expanding access for affected adults. When waivers were in place, the 80-hour participation threshold remained on the books but was not enforced for many individuals, and returning to strict enforcement required states to rescind or lose waiver authority. The post-pandemic shift back to enforcement is described as a reinstatement of existing law, not a creation of new requirements ^{[2] [5]}.

3. Evidence of Impact — Hundreds of Thousands Affected

Empirical analyses of the period when work requirements were pushed more aggressively show substantial declines in SNAP caseloads and issued benefits tied to enforcement of ABAWD rules. One research summary estimates about 600,000 adults lost SNAP benefits between 2013 and 2017, after controlling for factors like unemployment, poverty, and Medicaid expansion, indicating the policy directly affected participation independent of broader economic trends. That research signals that enforcement of the three-in-36 rule had measurable, population-level effects on program access ^[3].

4. Policy Moves and Administrative Proposals — Narrowing Waivers

Policy documents and a USDA proposed rule in early 2019 indicated an administrative intent to limit or tighten waiver use, explicitly aiming to reduce the number of nondisabled childless adults receiving SNAP by narrowing the circumstances under which states could waive the ABAWD time limit. The proposed administrative change reiterated the core framework—three months in 36, 80 hours per month—while seeking to constrain exemptions and thereby increase enforcement; proponents framed this as restoring statutory intent, while critics warned of increased hunger and instability for vulnerable adults ^{[4] [1]}.

5. The Historical Context and Legal Roots — A Longstanding Federal Choice

These ABAWD work rules are part of a broader history of federal welfare policy that ties benefits to work expectations, tracing through legislative and programmatic changes over decades; descriptions of SNAP’s evolution and other welfare reforms highlight that the three-in-36 rule is embedded in long-standing statutory frameworks that govern program eligibility and the use of work-based conditions. While the Food Stamp Program’s origins and later transformations established the mechanics of eligibility, the specific ABAWD rule has persisted as a targeted mechanism within SNAP policy for decades ^{[6] [7]}.

Overall, the authoritative picture from the compiled analyses is clear: the “old” SNAP work requirement for ABAWDs was a defined, statutory rule—three months of benefits in any 36-month period absent 80 hours per month of work or equivalent participation—that has produced large, measurable effects when enforced and has been subject to periodic administrative tightening and pandemic-era waivers ^{[1] [3] [4] [2]}.