Who was affected by the old SNAP work requirements and exemptions?
Executive summary
Before the 2025 changes, SNAP work rules primarily targeted able-bodied adults without dependents (ABAWDs) aged roughly 18–49 (and in some guidance up to 59), limiting nonworking ABAWDs to three months of benefits in a 36‑month period unless they met work, training, volunteer or waiver conditions [1] [2]. States historically used area waivers for counties with high unemployment to exempt large groups; the 2025 federal changes narrowed those waivers and expanded who must meet an 80‑hour‑per‑month (20 hours/week) standard, putting many previously exempt people back under scrutiny [3] [4] [5].
1. Who the old ABAWD rules targeted — the policy and the people
Federal ABAWD (able‑bodied adults without dependents) rules applied time limits that restricted receipt of SNAP beyond three months in three years unless recipients worked, trained, volunteered, or qualified for an exemption; historically that applied mainly to adults without dependent children and typically in age bands around 18–49 or 18–59 depending on guidance [1] [2]. States tracked participation hours or granted work program placements; failure to meet those rules could mean losing benefits after three months [1].
2. Common exemptions under the prior framework — who did not have to meet the ABAWD clock
Under earlier practice many groups were excluded from the ABAWD time limit: people who were pregnant, medically unfit for work, primary caregivers of young children, elderly adults (thresholds evolved), people in substance‑use treatment, veterans and some foster care participants — and places with high local unemployment could receive area waivers that exempted whole counties or Tribal Nations [6] [7] [8] [2] [9].
3. The role of waivers — geography as safety valve
Area waivers let state or federal authorities suspend the ABAWD time limit where labor markets were weak; those waivers covered all or parts of several states and even U.S. territories and were an important reason many recipients did not face the three‑month clock [10] [11] [9]. State guidance shows waivers historically depended on local unemployment metrics and were a central mechanism to avoid cutting benefits in places lacking sufficient jobs [3].
4. How many people were effectively affected under the old system
Available sources explain who the rules covered and who could be exempt but do not provide a single nationwide pre‑2025 headcount in these materials; reporting and agency pages indicate the rules applied to a subset of working‑age adults without dependents and that states used waivers to substantially reduce the pool subject to time limits [1] [9]. Analyses cited later estimate expansions would double the number subject to the mandate, implying the pre‑change group was substantially smaller [12].
5. Shifts in 2025 that narrowed exemptions and expanded coverage
Congress and the USDA tightened exemptions and waiver criteria in 2025, raising the participation expectation to about 80 hours per month (20 hours/week) for many and removing some categorical exemptions (for example homelessness, veterans, certain foster‑care age rules) that had shielded people before; states began re‑screening recipients starting November 1, 2025, with full implementation differences by state [4] [13] [8] [3]. Federal guidance and state pages document that previously waived counties lost exemption status under the new law [3] [5].
6. How states and advocates described the transition — implementation and contention
State agencies warned the change increases administrative workload and that some counties or Tribal Nations that once had waivers would no longer be exempt, forcing recipients to report hours or claim exemptions at recertification [3] [7]. Coverage from national outlets said the rollout was chaotic, that waivers were being narrowed, and that legal challenges or temporary court orders affected timing in some places [12] [10] [11].
7. Competing perspectives and the political stakes
Proponents in federal agencies framed the tightening as restoring work expectations and preventing waste (quoted defenders in reporting), while researchers and advocates warned the expanded mandate would roughly double the number of people subject to work rules and could cut millions from benefits over time — the Congressional Budget Office projection cited projected declines and analysts such as Brookings’ Lauren Bauer estimated the subject population would grow substantially [12] [11]. Sources document both the administration’s claim of strengthening work requirements and independent estimates of large coverage increases [4] [11].
8. Limits of available reporting and what’s not said
Available sources describe which groups were covered and which exemptions existed, and they report broad estimates of expansion, but they do not provide a comprehensive pre‑2025 national tally of exactly how many SNAP recipients were exempt versus subject under older rules; nor do these sources provide granular, nationwide counts by exemption category in the pre‑change period [1] [9]. If you need precise historic headcounts by exemption type, that is not found in current reporting.
Bottom line: historically, ABAWD rules focused on working‑age adults without dependents and relied on medical, caregiving, age, and geographic waivers to spare many people; the 2025 changes narrowed waivers, tightened hour thresholds to roughly 80 per month, and brought substantial numbers who had been exempt back under time limits and reporting requirements [1] [3] [4].