How do individual states differ in the medical documentation they require for SNAP work‑rule exemptions?
Executive summary
States vary widely in what medical proof they demand to exempt SNAP recipients from work rules: federal guidance requires verification and permits documentary evidence, but implementation ranges from accepting a brief physician note or verbal confirmation to requiring state‑specific medical forms and formal Medical Exemption applications [1] [2] [3]. That divergence shows up in differences in timing, format, and administrative burden—some states ask for documentation only at recertification or after outreach, while others proactively require completed medical statement forms and mailed proofs [4] [5] [6].
1. Federal baseline, state discretion
The USDA’s Food and Nutrition Service and its OBBB implementation memo set a verification floor—state agencies must verify questionable information with reviewable documentary evidence under federal regulation—but they give states discretion about how that verification is collected and recorded, which is why practices differ state to state [1] [7].
2. Paperwork intensity: state forms vs. simple notes
Some states mandate a formal state medical exemption form or a completed medical statement submitted to an office or PO box, turning a medical claim into a mini‑application process (New York’s guidance and Legal Services NYC highlight completed medical statement forms and mailing instructions) [6] [8]. By contrast, other state and local offices will accept a physician’s note, a caseworker’s interview confirmation, or even a verbal statement in an eligibility interview to establish a disability or caregiving exemption (AARP reporting) [2].
3. Timing and triggers: recertification, outreach, or immediate proof
How often and when states ask for proof differs: many will wait until the next recertification to demand documentation, but some may require updated medical or caregiving documentation during interim reviews or after targeted outreach—states must notify beneficiaries if they apply new checks before a certification cycle ends (Propel; state guidance and local reporting) [4] [5].
4. Who collects and how: interviews, phone calls, digital portals
States vary in the administrative path: some jurisdictions rely on in‑person or phone interviews by benefits specialists to document exemptions and allow quick verbal confirmations, while others are pushing documents through mail or online uploads as they update systems for the 2026 rule changes (AARP; Propel) [2] [4].
5. Burden and access: uneven effects on recipients
The practical impact differs depending on state capacity—requiring mailed forms or multiple physician signatures creates extra hurdles for recipients with limited transportation, unstable housing, or sporadic medical care; advocates and legal services in New York already recommend completing and submitting medical statement forms to avoid interruptions (Legal Services NYC; AARP) [6] [2].
6. Enforcement and appeals: documentation can determine benefits quickly
States that demand documentary proof at specific cutoffs or that treat “questionable information” as trigger points can move faster to reduce benefits unless recipients promptly supply evidence; federal rules require opportunities to submit additional information, but enforcement cadence varies across jurisdictions (FNS OBBB memo; Propel) [1] [4].
7. Political and administrative drivers behind variation
Variation reflects both policy choices—some states prioritize strict verification to reduce noncompliance, others prioritize access and low administrative friction—and logistical realities: many states are still updating systems after the 2025–2026 federal changes, producing uneven practices and outreach (Propel; PCSNW analysis) [4] [9].
8. What reporting does not show
Available reporting documents procedures in several states and federal guidance but does not provide a comprehensive, state‑by‑state catalog of exact forms, acceptable wording, or processing times for medical exemptions; in many cases, only local agency notices or legal‑aid advisories reveal the granular steps recipients must take [3] [6] [5].