some students attending college more than half time,
6
certain immigrants who are lawfully present,
7
and certain people with drug-related felony convictions in some states. Many adults aged 18 to 52
who do not have children in the home and who do not have disabilities are limited to three months
of SNAP benefits every three years in many areas of the country, and states have broad authority to
extend work requirements to many other SNAP households. (See box, “The Three-Month Time
Limit.”)
The Three-Month Time Limit
Many adults without dependents need to meet additional requirements to remain
eligible for SNAP.
Since the Personal Responsibility and Work Opportunity Act of 1996, individuals aged 18 or over
and under 50 have been limited to three months of SNAP benefits every three years unless they
are working or in a work or training program at least 20 hours a week. Some individuals are
exempt from this work-reporting requirement (sometimes referred to as a time limit), such as
those who live with children in the household, those determined to be physically or mentally unfit
for work, pregnant people, and others.
In response to the pandemic, Congress suspended the work-reporting requirement until the month
after the federal public health emergency (PHE) ended.
a
The PHE ended on May 11, 2023, and the
first countable month toward the time limit was July 2023. Many participants unable to work or
train 20 hours a week will lose their SNAP benefits beginning in October 2023.
The Fiscal Responsibility Act of 2023, which was enacted in June, phases in an expansion of this
work-reporting requirement to adults up to age 54.
b
As of September 2023, the requirement was
extended to 50-year-olds. It will go into effect October 2023 for 51- and 52-year-olds and October
2024 for 53- and 54-year-olds. The agreement also provides temporary exemptions from the work-
reporting requirement for veterans, people experiencing homelessness, and former foster youth
up to age 24. States will need to identify these individuals for them to be exempt.
The law allows states to temporarily waive the work-reporting requirement in areas with relatively
high and sustained unemployment. Individuals subject to the time limit can continue to receive
SNAP benefits if they live in a state that has waived it in the area in which they reside.
More general information on the work-reporting requirement is available at
https://www.fns.usda.gov/snap/work-requirements. For detailed eligibility requirements in a given
state, consult the state SNAP agency.
a
The time limit was not suspended in the few states that pledged to provide 20 hours of qualifying work activity for every
adult subject to this rule.
b
Ed Bolen, “About 500,000 Adults Will Soon Lose SNAP Due to Return of Work-Reporting Requirements; Another
750,000 Older Adults Newly at Risk,” July 12, 2023, CBPP, https://www.cbpp.org/blog/about-500000-adults-will-soon-
lose-snap-due-to-return-of-work-reporting-requirements-another.
6
In response to the pandemic, Congress temporarily created new exemptions to the general rule that makes many
college students ineligible for SNAP. These remained in place for 30 days after the end of the PHE (through June 2023)
for new SNAP applicants. Since then, participating students are in the process of being reassessed at the household’s
next SNAP recertification, which will likely occur by May 2024.
7
In general, lawfully present immigrant children, refugees, and asylees, and qualified immigrant adults who have been in
the U.S. for at least five years, are eligible for SNAP. In some cases, the income and resources of the immigrant’s
sponsor count toward the immigrant’s eligibility. For detailed information on non-citizens’ eligibility for SNAP, see
http://www.fns.usda.gov/snap/snap-policy-non-citizen-eligibility
.