Project 2025 Tracker / What’s done, what’s next

10. Department of Agriculture · Major

Reinstate SNAP work requirements for able-bodied adults

Done

299 10. Department of Agriculture

“Re-implement work requirements. The statutory language covering food stamps allows states to waive work requirements that otherwise apply to work-capable individuals—that is, adult beneficiaries between the ages 18 and 50 who are not disabled and do not have any children or other dependents in the home.”

What has happened

  1. Done

    Section 10102 of the reconciliation act (P.L. 119-21) rewrote the SNAP time-limit exceptions in 7 U.S.C. 2015(o): the work requirement now runs to age 65 (previously 55 under the 2023 debt-ceiling law), the dependent-child exception is narrowed to children under 14, and the state waiver criterion the Mandate objects to ("lack of sufficient jobs") is struck, leaving only areas with unemployment above 10 percent, plus a temporary exemption for Alaska and Hawaii. Enacted by Congress rather than by the executive action the Mandate contemplated.

Research log

What was searched, and what didn’t count as evidence

Research notes

  • The Food and Nutrition Service (renamed the Food and Nutrition Administration on 2026-06-01) published implementation memoranda for Sec. 10102 — an information memorandum on the SNAP provisions of the act (a search snippet dates it 2025-09-04 and says FNS would terminate remaining “lack of sufficient jobs” waivers 30 days after issuance), an “ABAWD Waivers – Implementation Memorandum” (https://www.fna.usda.gov/snap/obbb-abawd-waivers-implementation) and an “ABAWD Exceptions – Implementation Memorandum” (https://fns.usda.gov/snap/obbb-ABAWD-exemptions-implementation-memo). The pages open with the right titles but their bodies load by script and could not be read, so the memo dates and the waiver-termination date are unconfirmed; recorded as leads. The memo index is https://www.fna.usda.gov/obbb.
  • No Federal Register rule implementing Sec. 10102 was found (the statute is self-executing); the only OBBBA SNAP rulemaking in the federal records we keep and search is the 2026-06-24 proposed rule on federal–state administrative cost sharing (Sec. 10106).
  • This Recommendation is not marked as needing an act of Congress, because the Mandate frames the ask as USDA tightening waiver approvals; what actually happened was a statutory change, which achieves the ask more durably.
Action
reinstate
Object
SNAP ABAWD work requirements
ID
775