Which specific SNAP work requirement exemptions apply to seniors in 2025 and what proof is needed?
Executive summary
Federal rules in 2025 keep people age 60 and older exempt from SNAP’s general work and ABAWD rules; states must screen applicants and may require proof of exemptions or participation at application/recertification (FNS implementation memo and FNS eligibility pages) [1] [2] [3]. New federal law (the One Big Beautiful Bill Act of 2025) expanded work requirements to older cohorts (up to age 64 in many accounts) and pushed states to begin enforcement around Nov. 1, 2025, but state practice and paperwork vary — some states say exemptions narrowed or ended for groups like homeless people and veterans and instruct recipients to return exemption forms and supporting documents to local agencies [1] [4] [5].
1. Who is explicitly exempt among seniors under federal guidance
The USDA’s FNS implementation memorandum says individuals aged 60 or older remain exempt from the general SNAP work requirements, including mandatory participation in SNAP Employment & Training (E&T) [1]. The FNS “Special Rules for the Elderly or Disabled” page also treats 60+ as the program’s senior threshold for special rules such as different income deductions and eligibility tests [2].
2. Where headlines and state materials appear to diverge
Multiple news and state pages report that the One Big Beautiful Bill Act expanded work rules up the age ladder and that many states began enforcing broader proof requirements starting November 1, 2025 [4] [6]. Some state pages and local guidance (for example, Virginia and Delaware notices) signal that rules about exemptions changed — saying certain formerly automatic exemptions (homelessness, veteran status, foster care aging-out) were eliminated or narrowed and instructing recipients to indicate exemptions and submit documentation to local offices [5] [7]. FNS guidance, however, reiterates that 60+ remain exempt from mandatory E&T and the general work rules [1]. Available sources do not mention an FNS directive that raises the senior exemption above age 60 to 65 or 66; state notices may reflect their operational interpretation or timing of implementation [1] [7].
3. Which seniors might still need to prove something and why
Even though 60+ are federally exempt from work and mandatory E&T, state agencies must “screen for and apply” exemption criteria on each initial or recertification application and may request proof when a household claims an exemption [1] [3]. States told recipients to check exemption boxes on consolidated notices and to return supporting documents; some states are implementing the OBBB changes more aggressively and notifying households they must show either exemption status or evidence of meeting 80 hours/ month (or 20 hours/week equivalents under local conversions) to avoid time limits [8] [5] [9].
4. What types of proof states and FNS say recipients should be ready to provide
FNS and state SNAP pages say applicants must complete an eligibility interview and give verification of the information provided; states will advise what specific documents they need [3]. For medical or disability exemptions, states commonly require a Medical Exemption Form or medical documentation such as a doctor’s note, diagnosis, or other provider attestation [10] [11]. For work/participation verification, states and advocacy guides recommend pay stubs, employer statements, volunteer program letters, training attendance records, or E&T enrollment confirmations [8] [9]. State pages also tell people to return the consolidated notice with exemption selections to local departments for evaluation [5].
5. Where the confusion and risk come from — policy changes and staggered state rollouts
The One Big Beautiful Bill Act took effect on enactment (July 4, 2025) and FNS issued implementing memoranda, but states control day‑to‑day screening, discretionary exemptions, and notices to recipients [1] [12]. That split explains why national guidance (60+ exemptions preserved) can coexist with state notices saying older cohorts now face work checks or that certain exemptions ended [1] [5]. Advocacy groups warn these changes could rapidly reduce enrollments and leave older adults vulnerable if they lack medical proof or if state screening is inconsistent [13].
6. Practical next steps for seniors and caregivers
If you’re 60 or older, cite the FNS memo that individuals aged 60+ are exempt from general work requirements and ask your caseworker to confirm that status in writing; keep a copy of any consolidated notice and any medical or caregiver documentation you have [1] [3]. If a state asks for proof, be prepared to submit doctor’s notes, Medical Exemption Forms, pay stubs or volunteer/training attendance records, and return exemption-selection forms as instructed [10] [11] [5]. If your state claims rules that conflict with the FNS memo, request a written explanation and appeal instructions from your local agency; available sources describe USDA waiver and discretionary-exemption processes but show states vary in implementation [1] [12].
Limitations: this account draws only on the cited federal FNS documents, state guidance, and reporting in the provided sources; available sources do not list a single exhaustive checklist of every document each state will accept, and state practices are changing rapidly [1] [5] [4].