By Tami Luhby, CNN
Sun November 30, 2025
Food stamp recipients are now receiving their
November benefits, but a growing swath of enrollees may soon lose their vital food assistance completely.
At the same time as the government shutdown
disrupted the Supplemental Nutrition Assistance Program, or SNAP, states began implementing an expansion of the program’s work requirements as mandated in the
Republicans’ “big, beautiful bill,” which was signed into law by President Donald Trump this summer.
Under the GOP package, more food stamp enrollees will have to work, volunteer or participate in job training for at least 80 hours a month or they will only be able to receive benefits for three months out of every three years.
The expanded work requirements will result in 2.4 million fewer Americans receiving food stamps benefits in an average month over the next decade, according to a Congressional Budget Office analysis. This includes 300,000 families with children.
Recipients who don’t meet the requirement will likely start losing their benefits in March, but the timing will depend on where they live and when they must recertify their eligibility for food stamps.
Republicans have long wanted to beef up SNAP’s existing work requirement, which used to apply to beneficiaries ages 18 to 49 who did not have disabilities or dependent children. The GOP increased the age threshold to 54 as part of the 2023 debt ceiling agreement.
The GOP spending bill further broadened the work requirement to include recipients through age 64 and parents of children ages 14 through 17. Veterans, people experiencing homelessness and former foster youth are now also subject to the mandate.
Plus, the legislation made it harder for states to seek waivers during poor economic conditions. Previously, states could obtain waivers in areas they identify as having a lack of sufficient jobs. Now, only areas with unemployment rates over 10% qualify.
A federal judge in Rhode Island has temporarily barred the US Department of Agriculture from terminating existing waivers before their expiration dates, but the agency has yet to release guidance on the decision, said Chloe Green, assistant director of policy at the American Public Human Services Association.
Asked about the case, the USDA said it is approving waivers “within its statutory authority under the One Big Beautiful Bill Act of 2025, on an individual basis.”
Overall, roughly double the number of SNAP recipients will be subject to the mandate, said Lauren Bauer, a fellow in economic studies at the Brookings Institution.
The rollout of the expanded work requirements, however, has been chaotic, which was exacerbated by the record-long government shutdown, states officials and experts say.
“There is both a tremendous amount of confusion and, strangely, a wide array of differences across states and how they are implementing it,” Bauer said.
Rushed timetable
The SNAP work requirement provisions were among the few GOP agenda bill measures that did not have a set implementation date. In the fall, the US Department of Agriculture published guidance that said the new rules took effect on July 4, when the bill was
signed into law, but effectively gave states until November 1 to stand up their programs.
Then, earlier this month, the USDA said that states should not count November when calculating whether enrollees are meeting their work requirements because of the
shutdown-spurred benefit disruptions.
Most states set November 1 as their implementation date, though some started earlier, Green said. But other states say their systems may not be ready to track the expanded requirement until the spring, even though that could put them at risk for being penalized by 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 said, noting that such updates usually take 12 to 18 months to do properly.
States are particularly sensitive to making payment mistakes now because another provision of the Republican agenda bill requires that they shoulder a larger share of the program’s administrative costs if they have high error rates.
Beneficiaries who may be newly subject to the work requirements need to be notified and screened to make sure they don’t qualify for other exemptions, such as having physical or mental limitations.
“A lot of people who are calling in are worried that now they’re being assigned work requirements without them even knowing,” Green said. “That should not happen.”
Many states are starting the three-month clock when residents first apply for food stamps or when they file their recertification forms, which generally happens every six to 12 months depending on the state and entails an interview. But some states are checking all their enrollees at once, without waiting for their recertification dates.
Updating systems
Connecticut has found it “very challenging” to implement the expanded work requirements, said Dan Giacomi, director of program oversight and grants administration at the state’s Department of Social Services. An estimated 36,000 residents — or 10% of the state’s SNAP enrollees — could be at risk of losing their benefits in coming months because of the law’s 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 said.
To ensure it is complying with the Republican agenda bill the state has had to implement temporary workarounds — which involve case workers manually inputting whether recipients are newly subject to the requirement — while it races to update its technology. Giacomi is also concerned about these cases being integrated properly into the system once it is updated, as well as any payment errors that may result in penalties for the state.
Another reason for the delay is that the state had to wait for guidance from the USDA so staffers knew how to handle all scenarios, he said. Though it still has several outstanding questions, it has enough information to get started.
States often want to wait for clear USDA guidance so they don’t take steps that the agency might later say don’t comply with the regulations, said Ed Bolen, director of state SNAP strategies for the left-leaning Center on Budget and Policy Priorities.
In Pennsylvania, the timetable began even earlier because its economic waivers, which covered many counties and localities, expired in September. The commonwealth took “substantial steps” to connect with all the SNAP recipients in these areas to determine if they could qualify for another exemption from the work requirements, Hoa Pham, a deputy secretary in the Department of Human Services, said. If they don’t qualify, they could start losing their benefits as soon as January 1 unless they meet the work mandate.
Pennsylvania has several ways of verifying recipients’ income, including state and federal data and a pilot program in which enrollees allow a third-party platform to pull and report their payroll information. But these sources don’t necessarily cover all the work that recipients perform so they may also have to submit pay stubs.
Prior to the GOP agenda bill, fewer than 25,000 of Pennsylvania’s roughly 1 million SNAP enrollees were subject to the work requirement rules that applied to those ages 18 to 54. The legislation expanded that number to just under 248,000 people.
The department projects that a total of 144,000 recipients could lose their benefits over the next year when they renew their eligibility.
States are also racing to inform SNAP beneficiaries who may now be subject to the work requirements to make sure they meet the mandate or file for exemptions.
Connecticut is sending text messages, mailing notices and meeting with community groups. It has also set up an online questionnaire that will direct those potentially affected to the next steps they have to take. Pennsylvania has launched a website — with a video and a screener — to explain the changes to residents.
Still, Pham is worried that some people who would continue to qualify could lose their benefits because of the 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 said.
