Worsening SNAP’s Harsh Work Requirement Would Take Food Assistance Away From Millions of Low-Income People
Families With Children, Older Adults, Veterans Among Those Who Would Be Harmed
As Republican lawmakers draft legislation to enact the deep cuts called for in their budget resolution, it appears increasingly likely that proposals to make SNAP’s existing harsh work requirement broader and more punitive will be included.[1] This could take food away from millions of people in low-income households who are struggling to find steady work or who face substantial barriers to employment, including families with children — despite some lawmakers falsely claiming this policy would not cut food assistance benefits.
Under one proposal from House Agriculture Committee member Dusty Johnson, we estimate about 6 million people would be at risk of losing their food assistance. In total, nearly 11 million people — about 1 in 4 SNAP participants, including more than 4 million children and more than half a million adults aged 65 or older and adults with disabilities — live in households that would be at risk of losing at least some of their food assistance if Rep. Johnson’s proposal were enacted.[2]
Estimates for how many people in each state and congressional district would be at risk of losing some or all of their food assistance under two of the policies included in this proposal — expanding SNAP’s work requirement to older adults up to age 65 and adults living with school-aged children — are included in the map and table below. (See Figure B and Table 1.[3])
The Congressional Budget Office (CBO) projected that many of those who would be at risk of losing their food assistance due to the Johnson proposal would indeed be cut off SNAP, estimating that 3 to 3.5 million fewer people would participate in SNAP in a typical month.[4] Because research consistently shows that SNAP’s work requirement does not increase employment or earnings, the vast majority of those losing SNAP due to the expansion of the work requirement — including older adults, parents, veterans, people experiencing homelessness, and young people who have aged out of foster care — would lose the assistance they need to afford groceries with no improvement in their job prospects or income.[5] Ending SNAP eligibility for these individuals would harm not only the adults subject to the requirement, but also the people they live with, including children and people with disabilities, by reducing food benefits for the entire household.
As damaging as these cuts would be, this proposal would yield less than half of the $230 billion in cuts the House Agriculture Committee has been instructed to make, according to CBO’s projection. That means to meet its instructions, the committee would have to combine the harsher work requirements with other harmful policies that would take food assistance away from even more people.[6]
With the risk of a recession rising and the Trump Administration’s tariff policies likely to increase the cost of groceries and other essentials, SNAP’s role in supporting people who are temporarily out of work or don’t earn enough to afford basic needs is especially critical. Taking food away from more people who don’t meet a harsh, red tape-laden work requirement or are unable to prove they qualify for an exemption would worsen food insecurity and hardship while undermining SNAP’s vital role as an economic stimulus.
SNAP’s Harsh Work Requirement Takes Food Assistance Away, Does Not Improve Employment Outcomes
Under current SNAP rules, most adults aged 18 through 54 without children in their household can receive food benefits for just three months in a three-year period unless they show compliance with a 20-hour-per-week work requirement or prove they qualify for an exemption, such as having a disability.[7]
Most SNAP participants who can work already do so or are temporarily between jobs. Among households who reported receiving SNAP at some point in 2023, included a non-disabled working-age adult, and did not include minor children, 82 percent had earnings in that year, Census data show.8] Work rates among SNAP households with working-age non-disabled adults and children are typically even higher; 91 percent of such households had earnings at some point during 2023.
Given these data, most working-age adults who receive SNAP are workers who supplement their low wages with SNAP or receive SNAP when they are temporarily out of work. Many SNAP participants work in low-paid jobs that have unpredictable hours, don’t offer benefits like paid sick leave, and are volatile, resulting in more frequent periods of joblessness.[9] (See Figure A). But finding a new job may take longer than SNAP’s three-month time limit allows, particularly in areas where jobs are scarce or during times of elevated unemployment. Looking for work does not count toward the 20-hour requirement.
Taking away food assistance through SNAP — which averages only $6.20 per person per day — when someone can’t document compliance with a work requirement will hurt workers who are between jobs, have employers who do not provide a consistent number of hours of work, or get caught up in the red tape of documenting their work hours, an inefficient and burdensome process.
FIGURE A
Most Working-Age SNAP Participants Work, but Instability Overstates Joblessness
Work status of 100 simulated SNAP participants
In a typical month of SNAP participation, about half of non-disabled adults under 60 are working.
But many SNAP participants move in and out of work frequently.
Most will have worked at some point over the course of a year.
Has worked
Has not worked
Note: Individual dots are for illustrative purposes and do not correspond to real survey participants. Simulation is based on CBPP analysis of longitudinal 2014 Survey of Income and Program Participation (SIPP) panel data and is not directly comparable to the more recent Census data due to differences in survey methodology.
Work requirements also take away food assistance from many people with disabilities because state eligibility workers without medical training don’t sufficiently screen participants for exemptions or because people are challenged by the red tape required to adequately document their health conditions. People who reported having a disability — who likely should have been exempt from the three-month time limit — lost SNAP at the same rate as people without a disability, one study found.[10]
Research using high-quality data and rigorous methodologies to isolate the causal effects of this policy consistently shows it does not increase employment or earnings.[11] Instead, its primary impact is taking food assistance away from people who are already struggling to meet their basic needs. One study found that this policy cut off more than half — 53 percent — of the people subject to it.[12]
Millions of Older Adults, Families With Children, Veterans, and Others at Risk of Losing Benefits
The Johnson proposal would dramatically expand SNAP’s punitive and ineffective three-month time limit by applying it to additional groups of people and essentially eliminating states’ long-standing ability to temporarily waive the time limit in areas with higher unemployment or insufficient jobs.
Not all people who would be newly at risk of losing food assistance would be cut off SNAP. Some would successfully document enough work hours to comply with the requirement or would be excused by their state because of a disability, pregnancy, or another exemption. But as CBO’s estimate suggests, millions of people would lose the food assistance they need to afford groceries.
Based on our analysis, the people who would be newly at risk of losing food assistance under the Johnson proposal include:
1.4 million older adults aged 55 through 64 without children in their homes. These older adults often face additional barriers to employment, such as age-related hiring discrimination, which may heighten their risk of being cut off SNAP. Additionally, more than half of low-income adults in this age range report a health barrier to work. (See Figure 1.) Estimates of how many of these 1.4 million older adults without children live in each state and congressional district are included in the map and table below. (See Figure B and Table 1).
The House Agriculture Committee Chair, Glenn “GT” Thompson, has indicated that he doesn’t support expanding the age range to “anything over 61.”[13] However, even this more limited policy would still put 1.1 million adults aged 55 through 61 at risk of being cut off SNAP.
More than 3 million adults who live with school-aged children. In addition to expanding the three-month time limit to adults up to age 65, the Johnson proposal would also impose this policy on more than 3 million adults, primarily parents and grandparents, who live with children aged 7 or older. Estimates of how many of these more than 3 million adults live in each state and congressional district are included in the map below. (See Figure B and Table 1.)
If an adult is cut off SNAP, food benefits are decreased for their entire household. As a result, the more than 4 million children aged 7 through 17 who live in these households would be at risk of living in a household without enough food assistance to feed the family.
For example, a household with a recently unemployed single parent and two school-aged children who has no current income and receives the maximum SNAP benefit would lose $232 per month in food assistance if the parent isn’t able to document steady work. After three months, the household’s benefits would drop from $768 per month to only $536, a 30 percent decrease.
Because the three-month time limit would apply to all adults in the household unless they are otherwise exempt, this proposal could harm two-parent households even more. If the family in the example above had two parents struggling to find work instead of one, the household’s benefits would drop from $975 per month to $536, a 45 percent decrease.
Veterans, people experiencing homelessness, and young people who have aged out of foster care. This proposal would impose the work requirement on veterans, people experiencing homelessness, and former foster youth by removing the current exemptions from the three-month time limit put in place until 2030 on a bipartisan basis in the Fiscal Responsibility Act of 2023. About 400,000 people in these populations are eligible for SNAP because of these exemptions, the Department of Agriculture (USDA) estimated.[14] Among the 1.2 million veterans who live in households that participate in SNAP, most do not report having a disability, are younger than 65, and do not live with children. Thus, a relatively large share could be subject to the three-month time limit under this proposal.[15]
About 1.6 million people living in areas without enough jobs. Since the creation of SNAP’s work requirement nearly 30 years ago, states have had the ability to temporarily waive the three-month time limit in areas with relatively high rates of unemployment or insufficient jobs. Over the decades, every state has used this flexibility at some point to respond to local labor market conditions.
The Johnson proposal would virtually eliminate this option, restricting waivers to individual counties where unemployment rates exceed 10 percent. Currently, only ten counties in the entire country would qualify for a waiver under this proposal. (See Figure 2.) Currently waived areas that are facing economic challenges, such as counties in eastern Kentucky hit by severe flooding or rural communities in Maine hit hard by the loss of major employers, would no longer qualify for waivers. Similarly, areas that tend to have relatively high unemployment rates but are not counties or county-equivalents, such as the currently waived areas of the Navajo Nation in Arizona and New Mexico, would no longer qualify for waivers.
Based on the share of people who are subject to the three-month time limit but live in a waived area in a typical year, about 1.6 million people would be at risk of losing food assistance due to this limit. These 18- through 54-year-olds without children in their homes would be cut off SNAP if they can’t find reliable employment after three months or secure an exemption, even though they live in an area that lacks sufficient jobs based on long-standing USDA criteria.
Substantially restricting waivers means that many people would lose food assistance for failing to comply with the work requirement even if jobs are scarce where they live. As noted above, looking for work does not count toward SNAP’s 20-hour work requirement, and many unemployed workers need more than three months to find a job even when unemployment rates are relatively low.[16]
When unemployment is under 5 percent, nearly one-third of unemployed workers are out of work for 15 weeks or longer. When unemployment is above 7 percent, more than half of unemployed workers are out of work for 15 weeks or longer. (See Figure 3.) While these data represent all unemployed workers, people subject to SNAP’s harsh work requirement often face additional barriers to employment.
Economic Uncertainty Could Significantly Worsen the Impact of Expanded Work Requirement
Dramatically expanding the population subject to SNAP’s three-month time limit and curtailing states’ ability to temporarily waive this harsh policy would substantially worsen hunger and hardship even in times of relatively low unemployment. But with economic uncertainty and the risk of recession rising, now is a particularly bad time for Congress to pursue these harmful changes.
SNAP is a highly efficient and effective economic stimulus during economic downturns because low-income households quickly spend their SNAP dollars at stores in their community, bolstering local businesses and supporting jobs throughout the food supply chain. In fact, the Department of Agriculture’s Economic Research Service estimates that every $1 spent on SNAP food benefits generates $1.54 in economic activity in a weak economy.[17]
Cutting off food assistance to millions of SNAP participants if they can’t document compliance with a work requirement would increase food insecurity and hinder SNAP’s ability to stimulate the economy, particularly during recessions. Congress must reject these cuts and harmful changes to SNAP.
FIGURE B
Millions At Risk of Losing Food Assistance Under Proposed Expansion of SNAP’s Work Requirement
by 119th congressional district
Note: “With school-age children” refers to households with children where all children are 7 or older. These estimates do not incorporate other proposals in H.R. 1528 that would significantly restrict states’ ability to request waivers of SNAP’s work requirement for areas with insufficient jobs and eliminate current exemptions for veterans, people experiencing homelessness, or youth who have aged out of foster care. Due to rounding, the sum of congressional district estimates in a given state may differ from state estimates.
Source: State estimates based on CBPP analysis of SNAP quality control data for fiscal year 2022. State estimates were allocated to districts of the 119th Congress based on special tabulations from the American Community Survey for 2019-2023 using each district's share of the state's population of adults age 55 to 64 with no disability in SNAP households and no children under 18, and each district's share of the state's population of adults age 18 to 64 in SNAP households with school-age children.
Center on Budget and Policy Priorities | CBPP.org
TABLE 1
Millions At Risk of Losing Food Assistance Under Proposed Expansion of SNAP’s Work Requirement Estimated average monthly number of:
Adults at Risk of Losing SNAP:
Total People at Risk of Losing Some Amount of SNAP:
Ages 55 to 64 with no children, no disability
Ages 18 to 64 with school-age children, no disability
In households with adults ages 55 to 64 with no children, no disability
In households with adults ages 18 to 64 with school-age children, no disability
Alabama
22,000
54,000
28,000
137,000
Alaska
2,000
6,000
3,000
14,000
Arizona
37,000
62,000
44,000
147,000
Arkansas
8,000
19,000
11,000
49,000
California
201,000
286,000
243,000
645,000
Colorado
23,000
57,000
28,000
131,000
Connecticut
12,000
36,000
14,000
81,000
Delaware
5,000
11,000
6,000
31,000
District of Columbia
7,000
8,000
7,000
17,000
Florida
113,000
174,000
151,000
423,000
Georgia
50,000
156,000
58,000
382,000
Guam
2,000
3,000
2,000
8,000
Hawai‘i
7,000
11,000
8,000
22,000
Idaho
2,000
8,000
3,000
21,000
Illinois
65,000
164,000
75,000
397,000
Indiana
18,000
53,000
23,000
128,000
Iowa
10,000
19,000
11,000
47,000
Kansas
5,000
14,000
7,000
36,000
Kentucky
19,000
46,000
24,000
111,000
Louisiana
23,000
71,000
28,000
178,000
Maine
4,000
12,000
4,000
27,000
Maryland
26,000
45,000
29,000
100,000
Massachusetts
42,000
76,000
57,000
179,000
Michigan
39,000
113,000
52,000
252,000
Minnesota
11,000
34,000
14,000
92,000
Mississippi
8,000
35,000
10,000
91,000
Missouri
14,000
54,000
18,000
132,000
Montana
3,000
8,000
3,000
19,000
Nebraska
3,000
10,000
3,000
25,000
Nevada
19,000
38,000
22,000
87,000
New Hampshire
1,000
5,000
1,000
14,000
New Jersey
22,000
82,000
29,000
185,000
New Mexico
23,000
52,000
28,000
120,000
New York
125,000
221,000
158,000
512,000
North Carolina
47,000
127,000
58,000
317,000
North Dakota
1,000
4,000
1,000
11,000
Ohio
42,000
102,000
53,000
263,000
Oklahoma
18,000
54,000
25,000
131,000
Oregon
27,000
52,000
31,000
114,000
Pennsylvania
58,000
135,000
84,000
317,000
Rhode Island
4,000
8,000
4,000
17,000
South Carolina
17,000
44,000
22,000
121,000
South Dakota
less than 1000
5,000
1,000
13,000
Tennessee
21,000
57,000
26,000
134,000
Texas
107,000
285,000
123,000
683,000
Utah
4,000
13,000
5,000
31,000
Vermont
2,000
6,000
3,000
13,000
Virgin Islands
1,000
3,000
1,000
6,000
Virginia
22,000
76,000
28,000
176,000
Washington
26,000
53,000
29,000
120,000
West Virginia
13,000
28,000
18,000
66,000
Wisconsin
26,000
45,000
30,000
114,000
Wyoming
less than 1000
3,000
less than 1000
7,000
Total
1,400,000
3,100,000
1,700,000
7,500,000
Note: “With school-age children” refers to households with children where all children are 7 or older. These estimates do not incorporate other proposals in H.R. 1528 that would significantly restrict states’ ability to request waivers of SNAP’s work requirement for areas with insufficient jobs and eliminate current exemptions for veterans, people experiencing homelessness, or youth who have aged out of foster care. The District of Columbia, Guam, and the Virgin Islands are considered states in SNAP. Puerto Rico, American Samoa, and the Commonwealth of the Northern Mariana Islands are not included in this table because they receive a nutrition assistance block grant in lieu of participating in SNAP.
Source: State estimates based on CBPP analysis of SNAP quality control data for fiscal year 2022.
[2] Figures here and below for the number of people at risk of losing SNAP food assistance under the bill are based on CBPP analysis of 1) the number of participants meeting the age and other characteristics of the populations that would be newly subject to the work requirement under U.S. Department of Agriculture 2022 SNAP Household Characteristics data, and 2) the number of participants potentially subject to the work requirement in areas with waivers under 7 C.F.R. 273.24(f) in a typical year. All figures are estimates of the average monthly number of participants. The number newly at risk of losing SNAP over the course of a year would be larger.
[6] In 2023, CBO estimated that a nearly identical policy would save $90 billion to $120 billion over ten years, though H.R. 1528, the version introduced in 2025, could result in deeper cuts because it more significantly curtails states’ ability to waive the three-month time limit. Because any policy changes enacted in reconciliation legislation are unlikely to be implemented during the current fiscal year, we assume that House Agriculture Committee would need to meet the $230 billion target by making cuts over only nine years (2026-2034). As a result, this policy would likely result in less than half of the targeted $230 billion in savings.
[7] This policy has historically applied to adults aged 18 through 49; the age range was temporarily expanded to include adults aged 50 through 54 in the Fiscal Responsibility Act of 2023. Under current law, the expansion of the age range will end on October 1, 2030.
[8] CBPP Analysis of 2023 American Community Survey data.
[10] Erin Brantley, Drishti Pillai, and Leighton Ku, “Association of Work Requirements With Supplemental Nutrition Assistance Program Participation by Race/Ethnicity and Disability Status, 2013-2017,” JAMA Network Open, Vol. 3, No. 6, June 2020, https://jamanetwork.com/journals/jamanetworkopen/fullarticle/2767673.
[12] Colin Gray et al., “Employed in a SNAP: The Impact of Work Requirements on Program Participation and Labor Supply,” American Economic Association Journal, Vol. 15, No. 1, February 2023, https://www.aeaweb.org/articles?id=10.1257/pol.20200561.
[14] Food and Nutrition Service, U.S. Department of Agriculture, “Supplemental Nutrition Assistance Program: Program Purpose and Work Requirement Provisions of the Fiscal Responsibility Act of 2023.” April 30, 2024, Federal Register Vol. 90, No. 84, p. 34372, https://www.govinfo.gov/content/pkg/FR-2024-04-30/pdf/2024-08338.pdf.
[15] Luiz Nuñez, “SNAP Helps 1.2 Million Veterans With Low Incomes, Including Thousands in Every State,” CBPP, updated April 2, 2025, https://www.cbpp.org/research/food-assistance/snap-helps-12-million-veterans-with-low-incomes-including-thousands-in.