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Have recent state or federal policy changes affected SNAP work requirements for individuals with disabilities (as of 2025)?
Executive summary
Federal law changed in mid‑2025: the “One Big Beautiful Bill Act” (H.R. 1) tightened SNAP work rules and prompted USDA guidance and state action to re‑enforce ABAWD time limits beginning Nov. 1, 2025; many states are notifying that able‑bodied adults without dependents must meet a 20‑hour/week participation test or face a three‑month limit [1] [2] [3]. Available sources say people with disabilities and households composed entirely of elderly or disabled members remain generally exempt, but households that include non‑disabled adults can be affected if those adults cannot document an exemption [4] [5] [6].
1. What changed at the federal level: the new law and USDA action
Congress passed and the President signed a major budget/omnibus package in mid‑2025 often referenced as H.R. 1 / the One Big Beautiful Bill Act; that law restores and expands enforcement of SNAP work rules for able‑bodied adults without dependents (ABAWDs) and directs USDA to provide guidance to states on ABAWD exceptions and waivers [7] [1]. USDA announced it would resume full enforcement of longstanding ABAWD time limits and work rules, instructing states to apply those limits more broadly and indicating guidance was forthcoming [3] [1].
2. Who is targeted by the revived rules — and how disability fits in
The rule changes mainly target ABAWDs — generally adults 18–64 without dependents — who must either work/participate in approved employment or training 20 hours per week (80 hours per month) or qualify for an exemption to receive SNAP for more than three months in any 36‑month period [2] [8]. Federal and state materials repeatedly note that households composed entirely of elderly or disabled members are not subject to work requirements [4]. However, policy changes expand documentation and reporting expectations, and households with a disabled member can still lose benefits if other adults in the household do not meet work rules or cannot prove an exemption [5] [6].
3. How states are implementing the federal direction
States moved quickly to operationalize the changes: New York, Georgia, Tennessee, Pennsylvania, Colorado, Washington and others published notices telling ABAWDs their waivers will end and that Nov. 1, 2025 (or similar dates) marks the start of renewed enforcement or expanded reporting [9] [2] [10] [11] [8] [12]. Local agencies are scheduling appointments, requiring work‑activity reporting, and warning clients that failing to meet three months of required activity will lead to benefit cuts [13] [14] [2].
4. Practical rules states are enforcing — hours, reporting, and time limits
States and guidance referenced in reporting set the participation threshold around 20 hours per week (80 hours per month) for ABAWDs to avoid exhausting the three‑month limit within a 36‑month window [2] [8]. Agencies are asking beneficiaries to document activities, attend career services appointments, and in some cases begin formal reporting cycles (e.g., New York City scheduling notices Oct/Nov 2025 and March 2026 as a reporting start) [13] [9].
5. How these changes affect people with disabilities — key caveats
Available sources consistently state that people with disabilities and households consisting entirely of elderly or disabled members are generally exempt from work requirements [4]. At the same time, reporting and advocacy outlets warn that expanded documentation rules and state discretion mean disabled individuals could be indirectly affected if another adult in their household is newly subject to ABAWD rules; disability advocates also flagged cuts to related programs like SNAP‑Ed that could harm people with disabilities [6] [5].
6. Competing perspectives and potential hidden agendas
Federal and state materials frame the move as restoring long‑standing law and encouraging work or training [3] [2]. Advocacy groups and policy analysts argue the changes will cut benefits for many and shift administrative burdens to states and counties; Disability Belongs and CBPP emphasize that households with disabled members may still face risk if other adults cannot document exemptions and that program supports (like SNAP‑Ed) may be reduced [6] [5]. Some state communications emphasize implementation logistics and client notices, suggesting an administrative priority to document compliance rather than a focus primarily on disability protections [9] [10].
7. Where reporting is thin or absent
Available sources do not mention detailed federal criteria or a new, uniform process for disability determinations under the 2025 law beyond stating exemptions exist; specific federal guidance text on how agencies should evaluate disability exemptions “is in the process of being provided” according to USDA pages [1] [4]. Also, the sources provided do not include the final USDA guidance documents or full legal text laying out every new exemption nuance — those materials are described as forthcoming [1].
Bottom line: policy changes in 2025 re‑activated and broadened enforcement of SNAP work requirements for ABAWDs; people with disabilities remain generally exempt on paper, but practical risk to households with disabled members increased because other adults may now be newly subject to strict work, reporting, and documentation rules [1] [4] [2] [5].