Food stamp recipients are presently getting their allocations for November, yet a significant contingent of enrollees face the prospect of soon forfeiting their essential food aid altogether.
Coinciding with the government shutdown causing disruptions to the Supplemental Nutrition Assistance Program, or SNAP, jurisdictions simultaneously began putting into effect an expansion of the program’s mandatory work rules, as stipulated in the Republicans’ “big, beautiful bill,” which gained the assent of President Donald Trump this past summer.
Under the framework established by the GOP, a greater number of food stamp participants will be obligated to engage in employment, volunteer activities, or job training for a minimum of 80 hours monthly, or else their allotments will be capped at three months of receipt within any three-year period.
The broadened stipulations regarding work are projected to lead to 2.4 million fewer Americans receiving food stamp benefits on an average month over the upcoming decade, according to an evaluation conducted by the Congressional Budget Office. This demographic reduction includes 300,000 households that have children.
Those beneficiaries who fail to satisfy the participation criteria are likely to begin having their assistance terminated starting in March, though the precise timing will be contingent upon their location and the schedule for their eligibility recertification for food stamps.
Republicans have held a long-standing desire to strengthen the existing SNAP work prerequisite, which previously governed beneficiaries between the ages of 18 and 49 who did not have documented disabilities or dependents. As part of the 2023 debt ceiling accord, the GOP raised this age limit to 54.
Furthermore, the Republican spending measure extended the work mandate to encompass participants up to the age of 64, and parents of children aged 14 through 17. Individuals who are veterans, those experiencing homelessness, and former youth from the foster care system are now also included under this directive.
In addition, the legislation imposed greater difficulty on states when attempting to secure waivers during periods of economic hardship. Formerly, territories could obtain exemptions in locales where they identified a shortage of available employment opportunities. Now, only regions reporting unemployment rates exceeding 10% qualify for such relief.
A federal judge in Rhode Island has issued a temporary injunction preventing the US Department of Agriculture from prematurely ending waivers that are currently active before their designated expiration dates, although the agency has yet to issue formal clarification regarding this ruling, stated Chloe Green, the assistant director of policy at the American Public Human Services Association.
When questioned about the ongoing legal matter, the USDA responded that it is approving waivers “within its statutory authority under the One Big Beautiful Bill Act of 2025, on an individual basis.”
Overall, approximately double the quantity of SNAP participants will now fall under the scope of this mandate, observed Lauren Bauer, an economic studies fellow at the Brookings Institution.
However, the execution of these expanded work mandates has been disorganized, a situation made worse by the unprecedentedly long government shutdown, according to state administrators and other experts.
“There is both a tremendous amount of confusion and, strangely, a wide array of differences across states and how they are implementing it,” Bauer remarked.
A ‘We Accept Food Stamps’ sign hangs in the window of a grocery store on October 31, 2025 in Miami, Florida.
A ‘We Accept Food Stamps’ sign hangs in the window of a grocery store on October 31, 2025 in Miami, Florida. Joe Raedle/Getty Images
Rushed timetable
The commencement dates for the SNAP work requirement provisions were among the few measures from the GOP agenda bill that lacked a firmly established implementation deadline. In the autumn season, the US Department of Agriculture released guidance indicating that the new regulations became effective on July 4, the date the official document was signed into law, but effectively granted states until November 1 to establish their operational programs.
Subsequently, earlier this month, the USDA advised that states should disregard November when tallying whether enrollees were fulfilling their work obligations, owing to the benefit interruptions precipitated by the shutdown.
The majority of states selected November 1 as their launch date for implementation, although some initiated the process sooner, according to Green. Yet, other jurisdictions indicate that their internal systems might not be prepared to monitor the expanded requirements until the spring, even though this delay could expose them to potential punitive action from the USDA.
“One worry we have is that when you make systems changes this fast, there’s a risk for unintended impacts somewhere else in the system,” she cautioned, pointing out that such technological overhauls typically necessitate 12 to 18 months for proper completion.
Jurisdictions are particularly wary of making errors related to payments at this juncture because another stipulation within the Republican agenda bill mandates that they absorb a larger portion of the program’s operational expenditures if they exhibit high rates of inaccuracy.
Individuals newly subject to the work requirements must receive formal notification and undergo vetting to confirm they do not qualify for other exclusions, such as having physical or cognitive limitations.
“A lot of people who are calling in are worried that now they’re being assigned work requirements without them even knowing,” Green stated. “That should not happen.”
Numerous states are initiating the three-month compliance countdown when residents initially apply for food stamps or when they submit their forms for benefit renewal, which generally occurs every six to twelve months depending on the state and involves an interview. However, certain states are reviewing all of their enrolled population simultaneously, without awaiting the scheduled recertification dates.
An aerial view shows lines of vehicles as people arrive to receive food assistance at a turkey distribution intended for federal workers and Supplemental Nutrition Assistance Program (SNAP) recipients organized by the Houston Food Bank in Houston, Texas, on November 22, 2025.
An aerial view shows lines of vehicles as people arrive to receive food assistance at a turkey distribution intended for federal workers and Supplemental Nutrition Assistance Program (SNAP) recipients organized by the Houston Food Bank in Houston, Texas, on November 22, 2025. Mark Felix/AFP/Getty Images
Updating systems
Connecticut has confronted considerable “difficulty” in enacting the expanded work mandates, shared Dan Giacomi, director of program oversight and grants administration at the state’s Department of Social Services. An estimated 36,000 residents—representing 10% of the state’s SNAP enrollment—may face the threat of losing their benefits in the coming months due to the legislative changes.
“You can’t just flip a switch in your eligibility system and have it do all of these new categories or new processes you have,” he explained.
To ensure adherence to the Republican agenda bill, the state has had to deploy temporary remedial measures—which involve case workers manually documenting whether recipients are now subject to the requirement—while simultaneously rushing to upgrade its IT infrastructure. Giacomi also expresses apprehension about the proper integration of these cases into the system once it is modernized, as well as any payment inaccuracies that could result in financial penalties for the state.
An additional factor contributing to the delay is that the state was compelled to await directives from the USDA so that personnel understood how to address all potential situations, he mentioned. While several unanswered questions persist, they possess sufficient information to commence operations.
States frequently prefer to hold off until clear guidance is provided by the USDA to avoid implementing actions that the agency might later deem non-compliant with the codified regulations, noted Ed Bolen, director of state SNAP strategies for the Center on Budget and Policy Priorities, which leans left.
In Pennsylvania, the timeline initiated even sooner because its economic waivers, which covered numerous counties and localities, lapsed in September. The commonwealth undertook “substantial efforts” to reach out to all SNAP participants within these jurisdictions to ascertain if they met the criteria for any alternative exemptions from the work requirements, reported Hoa Pham, a deputy secretary within the Department of Human Services. If they do not qualify for exemptions, they risk losing their assistance beginning as early as January 1 unless they comply with the employment directive.
Pennsylvania utilizes several methods for verifying participant income, including state and federal data sources and a pilot program where enrollees authorize a third-party service to extract and report their wage data. However, these sources do not uniformly capture all the labor participants undertake, meaning they might also be required to submit physical pay stubs.
Before the enactment of the GOP agenda bill, fewer than 25,000 of Pennsylvania’s approximately 1 million SNAP participants were subject to the work requirement rules applicable to those aged 18 through 54. The new legislation increased that figure to just under 248,000 individuals.
The department currently forecasts that a total of 144,000 recipients may see their benefits discontinued over the next year when they undergo their eligibility renewal process.
Jurisdictions are also actively engaged in informing SNAP beneficiaries who may now be subject to the work requirements to guarantee they either meet the obligations or submit applications for exemptions.
Connecticut is utilizing text messages, dispatching official notices, and holding sessions with community organizations. It has also established an online questionnaire designed to guide those potentially impacted toward the requisite subsequent steps. Pennsylvania has launched a dedicated website—featuring an explanatory video and a screening tool—to communicate the changes to its residents.
Nevertheless, Pham remains concerned that some individuals who would otherwise continue to qualify might have their benefits revoked solely due to procedural errors involving paperwork.
“It is all too easy for someone to miss an action step, and for that reason alone, that opens up the risk for people to lose their SNAP eligibility — for just missing an administrative process, and not because they are not otherwise eligible,” she concluded.
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