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How many SNAP recipients were exempt from work requirements in 2022 and 2023?

Checked on November 25, 2025
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Executive summary

Available reporting and federal documents do not give a single nationwide headcount of how many SNAP recipients were formally “exempt” from work requirements in 2022 or 2023; instead, they describe categories of exemptions, state waiver practices, and program changes that affect counts (for example, FNS guidance and waivers for areas with high unemployment and the end of the pandemic-era suspension) [1] [2] [3].

1. What “exempt” means in SNAP reporting — different buckets, different data

SNAP uses several distinct concepts that are often collapsed in news coverage: general work-rule exemptions (age, disability, caregiving, pregnancy, etc.), the ABAWD (able-bodied adults without dependents) time-limit exemptions, discretionary exemptions allocated to states, and geographic waivers that suspend ABAWD rules in high‑unemployment areas [4] [2] [5]. Federal materials and state guidance explain these legal categories but do not present a single line that sums “all exempt people” across every state and exemption type [4] [1].

2. Why you won’t find a single 2022 or 2023 national exemption count in these sources

The USDA/FNS and states publish rules, waiver lists, and allocations of discretionary exemptions — and some analyses (e.g., CBPP used FY2022 quality‑control data to estimate people at risk) — but the provided sources show that exemption accounting is fragmented: states report discretionary exemption use separately and waivers are approved on a county/area basis, and many documents note that final state usage figures must be reported by states on forms due after the fiscal year [3] [4] [5]. Thus the available documents describe mechanisms and allocations, not a consolidated national tally for 2022 or 2023 [3].

3. Key program events in 2022–2023 that affect exemption counts

Two events changed how many people were subject to — or could be exempted from — ABAWD rules: the pandemic-era suspension of ABAWD time limits ended mid‑2023, and states could again begin assigning “countable months” starting July 1, 2023; FNS advised states to prepare and reminded them many states didn’t need to use discretionary exemptions in FY2023 [3]. Meanwhile, the Fiscal Responsibility Act of 2023 amended rules and exception definitions and required more transparency about waivers and exemptions [4] [5].

4. Examples of how state practice changed counts (waivers and statewide exceptions)

States can request temporary ABAWD waivers for areas with unemployment above statutory thresholds; some states maintained statewide waivers (for example, Illinois’ FNS waiver through October 2025 was cited by the Illinois DHS), which effectively exempt entire populations from ABAWD time limits in those jurisdictions and therefore reduce the number of people who must be counted as “subject to” the work clock [6] [7] [2]. FNS materials emphasize that waiver usage and discretionary exemptions are tracked at the state level and reported after the fiscal year closes [3].

5. Independent estimates and “at‑risk” counts, not simple exemption tallies

Research organizations and news outlets produced estimates of how many people could be affected when rules changed (e.g., CBPP used FY2022 QC data to model impacts; the Congressional Budget Office and media reported projections that millions could be at risk under new rules), but those are projections of people who could lose benefits or be newly subject to requirements — not retrospective counts of formally recorded exemptions in 2022 or 2023 [8] [9] [10]. The distinction matters: “at risk” ≠ “officially exempted and recorded as such” [8].

6. What the available sources do provide if you want to build a number

To approximate 2022–2023 exemption counts from primary sources you would need to (a) collect each state’s FNS-583 or final FY reports (states report discretionary exemption usage and waiver status), (b) aggregate counts of people who meet statutory exemption categories from state administrative data, and (c) account for areas under waiver where ABAWD limits were suspended [3] [2] [4]. The federal materials note that many states did not use discretionary exemptions in FY2023, but they do not translate that into a national headcount [3].

7. Bottom line and recommended next steps

Available sources do not mention a single national count of SNAP recipients formally exempt from work requirements in 2022 or 2023; they instead document legal categories, state waiver mechanisms, discretionary exemption allocations, and analyses estimating people at risk when rules changed [3] [4] [8]. If you want a concrete number, the next step is to request state‑level final FY2022 and FY2023 reports (FNS‑583 and state administrative reports) and add counts for general exemptions reported in state SNAP caseload files — because the federal pages and press reports in the supplied material stop short of producing a consolidated national tally [3] [5].

Want to dive deeper?
How did SNAP work requirement exemptions change between 2020 and 2024?
What criteria qualify SNAP recipients for work requirement exemptions in 2023?
How many able-bodied adults without dependents (ABAWDs) were exempt from SNAP work rules in each state in 2022–2023?
What impact did pandemic-era waivers have on SNAP work requirement exemption numbers in 2022 and 2023?
Which demographic groups made up the largest share of SNAP work requirement exemptions in 2022–2023?