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Fact check: How does the SNAP work program vary by state?
Executive Summary
The SNAP work program varies substantially across states in three main dimensions: which adults are subject to work rules and exemptions, how states use ABAWD time‑limit waivers and discretionary exemptions, and how states run Employment & Training and administrative policies — all within a federal framework that allows broad state discretion. Recent federal and state actions in 2024–2025, including updated FNS guidance and new state laws, have tightened and in some cases expanded work checks and state cost responsibilities, producing sharply different impacts by jurisdiction [1] [2] [3] [4] [5].
1. Why ABAWDs Become the Focal Point of State Variation
States diverge most visibly on Able‑Bodied Adults Without Dependents (ABAWD) policy because federal rules set a uniform baseline but allow waivers and discretionary exemptions that states allocate differently. Federal law requires ABAWDs ages 18–54 to work or participate at least 80 hours per month or face a three‑month time limit, but states may request area‑level waivers in high‑unemployment zones or use monthly discretionary exemptions to shield people from time limits; usage and allocation differ widely across the 50 states, D.C., Guam and the Virgin Islands [2] [3]. Some states pursue broad statewide waivers or allocate many discretionary exemptions, while others apply few or none, creating large differences in who actually loses benefits. This variation also reflects differing state assessments of local labor markets and administrative capacities, and is documented in the 2025 State Options Report showing 37 jurisdictions using exemptions and a patchwork of waiver practices [1].
2. How General Work Requirements Leave Room for State Choices
Beyond ABAWD rules, there is a general work requirement for adults 16–59 that sets baseline expectations — registration, acceptance of suitable jobs, restrictions on voluntary quitting, and exemptions for students, caregivers, disability, pregnancy, veterans and homelessness — but states have discretion in enforcement, sanction length, and household disqualification policies. Certifications, sanction durations, and whether a non‑compliant head of household can disqualify an entire household vary: certification periods range from 4 to 24 months, and sanction periods follow either minimum schedules (1–3–6 months) or allow extended and permanent disqualifications in some states [1] [2]. These administrative choices change how burdensome the program feels to recipients and how aggressively states enforce federal standards, producing uneven effects on caseloads and local program costs [1].
3. Administrative Tools — Employment & Training and Categorical Eligibility — Drive Outcomes
States also differ in whether SNAP Employment & Training (E&T) programs are mandatory or optional and in adoption of Broad‑Based Categorical Eligibility (BBCE). BBCE adoption expands eligibility and simplifies administration, and it is in use in most states but rejected by several; E&T program design affects whether recipients can meet work requirements through training rather than immediate employment [1]. These choices change both the composition of caseloads and the administrative cost structure: states that expand BBCE generally see broader eligibility pools, while states that make E&T optional or underfunded place larger burdens on job search and immediate work compliance, shifting costs between state agencies and federal benefits [1] [2].
4. New Federal and State Developments Since 2024 That Shift the Landscape
Recent developments in 2024–2025 have accelerated state variation by altering both federal guidance and state law. The USDA Food and Nutrition Service updated ABAWD guidance and discretionary exemption allocations for FY2025, shifting how many exemptions states receive and prompting re‑allocations across states [3]. Separately, legislative changes dubbed in reporting as the “Big Beautiful Bill” expanded work requirement checks and broadened which recipients are subject to work rules, with most states beginning compliance checks on November 1, 2025, thereby raising immediate implementation and fiscal questions for states [4]. These federal and legislative moves force states to revisit waiver requests, staffing for compliance checks, and potential cost‑sharing, as Maryland’s February 2025 analysis showed an expected increase in state fiscal responsibility and tens of thousands of residents newly subject to work checks [5].
5. What the Patchwork Means for Families and Policy Choices
The resulting patchwork means a SNAP recipient’s obligations and risks depend heavily on state residence: in some states recipients face aggressive work verification and limited exemptions, increasing risk of benefit loss, while in others waivers and exemptions provide robust protections. This spatial variation affects economic stability, labor supply responses, and state budgets differently; states expanding checks must budget for increased administrative work and potentially higher state cost‑sharing, while states using waivers often cite elevated local unemployment or rural access barriers as justification [1] [5]. Policymakers, advocates and researchers must therefore evaluate not just federal rules but the full set of state choices — waivers, discretionary exemption allocations, certification practices, E&T design, and recent statutory changes — to understand the real‑world operation of SNAP work requirements across the country [1] [2] [3] [4].