Across the country, states are racing to implement new federal work requirements for the Supplemental Nutrition Assistance Program (SNAP). These changes—part of the “Big Beautiful Bill” (H.R. 1), passed earlier this year—expand who is subject to time limits and narrow who qualifies for exemptions. While the federal government frames these shifts as a way to encourage employment, research and experience tell a different story. Work requirements don’t help people find or keep good jobs. They simply cut people off from the food assistance they need while adding red tape for states and local agencies.
Under the new federal guidance issued by the U.S. Department of Agriculture’s Food and Nutrition Service (FNS), states must now apply stricter work requirements to more adults classified as “Able-Bodied Adults Without Dependents” (ABAWDs).
The policy expands the affected age range from 18–54 to 18–64, meaning adults up to age 64 must now meet work requirements or face time limits on benefits. It also narrows child care exemptions. Only adults caring for children under 14 now qualify, down from 18. Temporary exemptions (which were added in 2023), for veterans, homeless individuals, and youth aging out of foster care, have been removed.
States are required to implement these new criteria immediately, with a short period of time to come into compliance with the new rules before they’re fully enforced on November 1, 2025. FNS guidance also specifies how states should apply limited exceptions for certain tribal communities, but those flexibilities are narrow and require case-by-case coordination.
While supporters of the policy claim it will motivate employment, the reality is that most SNAP participants who can work already do, often in unstable or low-wage jobs without benefits or predictable schedules. Many others face significant barriers to employment, like lack of transportation, child care, or access to training, that rigid work requirements fail to address.
Decades of research have shown that work requirements don’t improve employment outcomes. As National Skills Coalition has written before, these policies do little to help workers get ahead and instead punish them for systemic barriers outside their control.
When SNAP participants lose food assistance, they’re not suddenly more employable, they’re simply hungrier. Losing SNAP can make it harder to focus on training, show up for work, or care for one’s family. In states that have implemented strict work rules, thousands of adults have been cut off from benefits, yet employment rates remain flat.
Losing SNAP can make it harder to focus on training, show up for work, or care for one’s family.
Moreover, enforcing work requirements places a heavy administrative burden on states and workers. Human services agencies must notify recipients of the new requirements, verify work hours, track compliance, and process exemptions. In each of these activities there is room for error that can have devastating consequences for workers. These activities also divert resources from programs that actually help people build skills and find stable jobs.
For states, the new rules present a significant operational and policy challenge. Many are already stretched thin managing workforce and safety-net systems. As the new federal memo takes effect, state agencies must:
These new layers of bureaucracy risk pushing eligible individuals off SNAP simply because they can’t navigate complex reporting requirements. The result could be fewer people accessing food assistance, greater administrative costs, and less time for agencies to connect participants with meaningful education or training opportunities.
For workers, the stakes are higher still. Many adults newly subject to work requirements are on the edge of self-sufficiency; working part-time, juggling caregiving responsibilities, or their participation in a training program doesn’t meet the strict definitions of “work activity.” Losing SNAP support can derail that progress entirely.
National Skills Coalition has always maintained that Basic needs are workforce needs. Slashing safety net programs like SNAP (and Medicaid) makes it harder for students to get ahead. It makes it harder for people to train for a new career or succeed in the workforce if they’re struggling to put food on the table, see a doctor when sick, or afford basic necessities.
Instead of enforcing punitive work rules, states can expand access to skill-building programs that connect SNAP participants with training and supportive services. That’s where SNAP Employment & Training (SNAP E&T) comes in. SNAP E&T lets states fund supports like transportation, child care, and other supports like covering the cost of uniforms that help people complete their training programs and move toward stable employment and self-sufficiency.
National Skills Coalition has long advocated for coordinating (SNAP E&T) with state workforce systems. States that integrate E&T with workforce development can help participants earn credentials; complete training aligned with in-demand jobs; and move into sustainable careers.
The federal guidance leaves little flexibility, but states still have important choices to make. Policymakers and advocates should:
Most importantly, advocates must keep pushing for policies that recognize skill-building—not sanctions—as the foundation of an inclusive economy.
As the new SNAP rules take effect, states face a choice: comply narrowly and risk pushing workers out of both assistance and opportunity or use this moment to strengthen the bridge between safety net programs and skill development.
As the new SNAP rules take effect, states face a choice: comply narrowly and risk pushing workers out of both assistance and opportunity or use this moment to strengthen the bridge between safety net programs and skill development.
National Skills Coalition will continue working with state partners to elevate what’s working, share implementation challenges, and advocate for policies that help workers build skills and stability.
For more on NSC’s stance on SNAP, skills training, and workforce development, see our previous blogs: “Focus on Skill-Building, Not Work Requirements” and “Why the Farm Bill Matters to Skills Advocates”.
