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How do SNAP eligibility rule changes in 2025 alter work requirements and enrollment rates?
Executive summary
The 2025 rule changes reinstate and tighten ABAWD (able‑bodied adults without dependents) time‑limit enforcement nationwide, requiring 80 hours per month (about 20 hours per week) of work, training, volunteering, or a combination to receive SNAP beyond three months in a 36‑month period; states were directed to begin full enforcement on or about Nov. 1, 2025 [1] [2]. The Congressional Budget Office and multiple outlets estimate the policy will lower participation — roughly a 2.4 million average monthly reduction over 10 years per CBO projections cited in contemporary reporting — and administrative burdens, waivers and exemptions are being narrowed [3] [4].
1. What changed: nationwide re‑imposition of ABAWD hours and the “three‑month clock”
Federal guidance as of late 2025 ends the pandemic‑era nationwide pause and directs states to fully apply the long‑standing ABAWD time limits: able‑bodied adults ages roughly 18–64 without dependent children again face a three‑month limit of SNAP benefits in any 36‑month span unless they meet work‑or‑training thresholds [1] [5]. The operational requirement most repeatedly cited is 80 hours per month — typically described as 20 hours per week or 80 hours a month — via work, approved training, verified volunteering or SNAP Employment & Training participation [2] [4] [6].
2. How states must act: tighter waiver rules and verification duties
USDA memoranda instruct states to end broad geographic and unemployment waivers that previously exempted many areas, to tighten discretionary exemptions, and to verify ongoing compliance and report participation — meaning more applicants and recipients will be subject to casework, reporting and potential benefit terminations if they do not document meeting requirements or qualifying for exemptions [4] [6]. Several state agencies (for example Georgia, Minnesota, New York, Pennsylvania and Tennessee) have already posted guidance instructing clients that they will need to document hours and exemptions at recertification or face loss of benefits after three noncompliant months [2] [6] [5] [7] [8].
3. Expected enrollment impacts and fiscal estimates
Reporting cites the Congressional Budget Office estimate that the changes will reduce average monthly SNAP caseloads by about 2.4 million people over the next decade — a projection packaged in national stories about the rule change [3] [9]. Other media and state notices also cite CBO and federal analyses indicating that hundreds of thousands to more than a million able‑bodied adults could lose benefits under the new law, and that some parents and noncitizen applicant rules were tightened in ways that shrink eligibility [10] [3].
4. Who is exempt or still protected — and where sources disagree or limit detail
Multiple sources stress that many groups remain exempt: people who are elderly or disabled, pregnant, primary caregivers of young children under new age cutoffs, certified unfit for work, or otherwise qualifying for statutory exemptions [11] [12] [5]. But state notices warn that exemptions were narrowed in the 2025 Congressional bill — for example parental‑care exemptions that formerly covered parents of children under 18 were changed in some reporting to a younger age threshold — and the specifics of exemptions and which populations newly fall under ABAWD rules vary by state guidance [10] [13] [6]. Available sources do not mention exhaustive lists of every newly covered subgroup; states are instructing recipients to await local notices [5] [2].
5. Administrative and implementation friction: real‑world hurdles flagged by states
State agencies and news outlets emphasize administrative burdens: beneficiaries must report participation, upload verification, and attend recertification interviews; states must re‑establish tracking systems and communicate case actions — actions that advocates warn could create claim losses from paperwork failures as much as from people truly not meeting the hours test [2] [7] [14]. Some jurisdictions briefly waived enforcement in November 2025 because of a federal shutdown and funding uncertainty, showing implementation can be uneven in practice [15] [3].
6. Competing policy framings: work incentives vs. hunger and access concerns
Federal and some state framing presents the change as restoring work expectations and program integrity [11] [4]. Opponents and many local agencies and news reports emphasize potential harm: reduced food access, higher administrative churn, and notable projected caseload declines (CBO’s ~2.4 million figure is widely cited) [3] [10]. Both lines appear across the files: policymakers argue for responsibility and labor force attachment [11], while reporting and state advisories document likely enrollment drops and operational risks [3] [6].
7. Bottom line and what recipients should do now
If you or someone you serve is an ABAWD or newly subject adult on SNAP, expect states to check for 80 monthly hours (20/week) or approved activities at recertification and to require documentation; read notices from your state agency and submit requested verification promptly to avoid three‑month disqualification [2] [6] [5]. For aggregate effects, current reporting and CBO estimates point to multi‑hundred‑thousand to multi‑million declines in participation over years, but the precise impacts will depend on state waiver usage, outreach, and implementation [3] [4].
Limitations: this summary draws only on the supplied reporting and state guidance; available sources do not include full statutory text comparisons, granular state‑by‑state waiver decisions, or post‑implementation enrollment data (not found in current reporting).