Proposed Rule: Modification to Work Requirements for Able-Bodied Adults

Summary

The proposed rule would codify USDA's regulatory implementation of provisions of the One Big Beautiful Bill Act of 2025 (OBBB) changing the three-month time limit for certain participants subject to work requirements in the Supplemental Nutrition Assistance Program (SNAP). These changes include modifying the list of exceptions from the time limit for certain populations; updating requirements for areas to qualify for waivers of the time limit; and adding the temporary good faith exemptions in Alaska and Hawaii. Additionally, this rule proposes to strengthen requirements for requesting waivers of the time limit and revise the SNAP definition of a homeless individual.

Request for Comments

Written comments must be received on or before Dec. 10, 2026.

The Food and Nutrition Administration, USDA, invites interested persons to submit written comments on this proposed rule. Comments may be submitted in writing by one of the following methods:

• Federal eRulemaking Portal: Go to regulations.gov. Follow the online instructions for submitting comments.
• Mail: Send comments to SNAP Program Development Division, Food and Nutrition Administration, 5601 Sunnyside Ave., Beltsville, MD 20705. Phone: (703) 305-2022.
• Email: Send comments to [email protected]. Include "Docket ID Number FNA-2025-0368, Modification to Work Requirements for Able-Bodied Adults" in the subject line of the message.

All written comments submitted in response to this proposed rule will be included in the record and will be made available to the public. Please be advised that the substance of the comments and the identity of the individuals or entities submitting the comments will be subject to public disclosure. FNA will make the written comments publicly available on the internet via regulations.gov.

Supplementary Information

Background

Implementation of the One Big Beautiful Bill Act of 2025

On July 4, 2025, President Trump signed Public Law 119-21, the One Big Beautiful Bill Act of 2025 (OBBB). Section 10102 of the OBBB makes significant changes to the time limit (also known as a work requirement) for certain Supplemental Nutrition Assistance Program (SNAP) participants. These changes require more SNAP participants to work as a condition of eligibility. The Department is issuing this proposed rule to implement those OBBB provisions, as well as strengthen standards for requests for waivers of the time limit and set clear expectations that those who can work, do.

The OBBB provisions build on a longstanding and evolving Congressional directive that SNAP must support work. Work requirements were first implemented as a condition of SNAP eligibility in 1971 (PL 91-671). In 1985, Congress required state agencies to operate an employment and training program (SNAP E&T) which helps SNAP participants gain skills that increase their employability and help meet employers' skilled workforce needs. In 1996, the Personal Responsibility and Work Opportunity Reconciliation Act (PRWORA, PL 104-193) made pivotal changes, creating a time limit for certain individuals not engaged in work. The Fiscal Responsibility Act of 2023 (FRA, PL 118-5) explicitly established that the purpose of SNAP includes assisting low-income adults in obtaining employment and increasing their earnings. This history, though not inclusive of all changes to SNAP work requirements, demonstrates the long-standing imperative that SNAP's purpose includes supporting participants in finding employment and increasing earnings, and mitigating reliance on the program.

SNAP work requirements include both general work requirements and the time limit, formerly known as the able-bodied adults without dependents (ABAWD) time limit. Under the general work requirements at Section 6(d)(1) of the Food and Nutrition Act of 2008 (the Act) (7 USC 2015(d)(1)), individuals must register for work; accept offers of suitable employment; not voluntarily quit or reduce hours of employment below 30 hours per week without good cause; and participate in workfare or SNAP E&T if required by the state agency. SNAP participants subject to these requirements that do not comply are disqualified from receiving SNAP benefits for periods ranging from one month to permanent disqualifications, depending on the number of violations and state options. The general work requirements apply to SNAP participants aged 16 through 59, unless they meet specific exemptions such as being unable to work due to physical or mental limitations.

In addition to the general work requirements, SNAP has a time limit and associated work requirements for certain individuals. Under the time limit, per Section 6(o) of the Act (7 USC 2015(o)), individuals must work and/or participate in a qualifying work program for at least 20 hours per week (averaged to 80 hours per month) or participate in workfare as assigned. Time-limited participants may only receive SNAP for three months in a 36-month period in which they do not comply with this requirement.

The OBBB changed who is subject to the time limit to now apply to SNAP participants aged 18 through 64 who do not meet an exception such as being physically or mentally unfit for employment, responsible for a child under 14, pregnant, or an "Indian", "Urban Indian" or "California Indian". These changes are explained in the discussion of proposed changes below.

Section 6(o)(4) of the Act (7 USC 2015(o)(4)) also allows the Department to approve state requests to waive the time limit in areas in certain circumstances. Waivers of the time limit allow for individuals residing in waived areas to continue participating in SNAP even if they do not meet the work requirement associated with the time limit, given they are otherwise eligible. Waivers of the time limit do not absolve state agencies of their responsibility to support participants in finding employment. State agencies must continue to track time-limited participants in waived areas to ensure program integrity when the waiver expires.

Prior to the OBBB, time limit waiver criteria included areas with unemployment rates over 10 percent or areas without a sufficient number of jobs to provide employment. The OBBB removed the ability for areas to qualify based on a lack of a sufficient number of jobs. Now, state agencies, except for Alaska and Hawaii, may only qualify for waivers for areas with unemployment rates of over 10 percent. The OBBB allows waivers for areas in Alaska and Hawaii with unemployment rates at least 1.5 times the national average.

Read the Full Proposed Rule