Sec. 10102. Modifications to SNAP work requirements for able-bodied adults | Impact

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Legislative and Policy Analysis

Section 10102: Modifications to SNAP work requirements for able-bodied adults

Executive Summary

Section 10102 narrows access to Supplemental Nutrition Assistance Program benefits by expanding the population subject to the able-bodied adult work requirement and by limiting state waiver flexibility. It amends Section 6(o) of the Food and Nutrition Act of 2008, the provision that limits SNAP eligibility to 3 months in a 36-month period unless a covered adult works, participates in qualifying work activities, or qualifies for an exception.[1]

The practical effect is that more adults ages 18 through 64 must document at least 80 hours per month of work, workfare, volunteering, or approved employment and training activity to keep SNAP beyond the time limit.[2] CBO estimates that Section 10102 will reduce SNAP participation by roughly 2.4 million people in an average month over the 2025-2034 period.[3] CBO’s supplemental budget crosswalk reports an estimated federal spending reduction of about $68.6 billion over the 2025-2034 period for Section 10102.[4]

What Section 10102 Actually Does

Section 10102 does not create a new grant, appropriation, loan authority, or direct payment stream. Instead, it changes eligibility rules for an existing mandatory benefit program. The fiscal effect comes from reduced SNAP participation and lower federal benefit outlays.

Program or activity	Amount	What the money supports or changes
SNAP federal benefit outlays affected by Section 10102	About $68.6 billion reduction over 2025-2034	CBO’s supplemental budget crosswalk identifies this as the estimated federal spending reduction associated with the section’s work-requirement changes.[4]
Estimated SNAP participation change	Roughly 2.4 million fewer participants in an average month over 2025-2034	CBO estimates this reduction from expanded work requirements, narrowed waivers, and changed exception categories.[3]
Adults through age 64 without dependent children	About 800,000 fewer participants in an average month	CBO attributes part of the participation decline to applying the requirement to able-bodied adults through age 64 who do not live with dependent children.[3]
Adults ages 18 to 64 living with children age 14 or older	About 300,000 fewer participants in an average month	CBO attributes part of the participation decline to newly covered adults living with children age 14 or older.[3]
Adults who would previously have benefited from geographic waivers	Roughly 1 million fewer participants in an average month	CBO attributes this to restricted state waiver authority.[3]
Veterans, people experiencing homelessness, and former foster youth, partially offset by American Indian exclusions	Net reduction of about 300,000 participants in an average month	CBO estimates participation losses from removing several prior exceptions, partly offset by new American Indian-related exceptions.[3]

Substantively, Section 10102 makes four major changes.

First, it revises the list of exceptions from the ABAWD time limit. The new statutory exception applies to individuals who are under 18 or over 65, medically certified as physically or mentally unfit for employment, responsible for a dependent child under 14, otherwise exempt under the general work-requirement provision, pregnant, an Indian or Urban Indian as defined in the Indian Health Care Improvement Act, or a California Indian described in that Act.[1]

Second, it effectively extends the age range affected by the ABAWD work requirement. Before enactment, USDA described the ABAWD rule as applying to certain adults ages 18-54 without dependents, with a requirement to work or participate in qualifying activities for at least 80 hours per month to receive SNAP for more than 3 months in 3 years.[2] CBO explains that Section 10102 expands the requirement to able-bodied adults through age 64 who do not live with dependent children and to adults ages 18 to 64 who live with children age 14 or older.[3]

Third, it removes several prior exceptions. CBO states that Section 10102 eliminates exclusions from work requirements for veterans, people experiencing homelessness, and people ages 18 to 24 who were in foster care when they turned 18.[3]

Fourth, it limits waiver authority. Before the law, states could seek waivers for areas with unemployment above 10 percent or areas without a sufficient number of jobs. Section 10102 restricts waiver flexibility and creates special rules for noncontiguous states, with Alaska and Hawaii able to seek limited exemptions tied to good-faith compliance efforts and subject to expiration no later than December 31, 2028.[1]

Legislative Mechanism

Section 10102 amends 7 U.S.C. 2015(o), the Food and Nutrition Act provision governing the ABAWD time limit. It does not operate by annual appropriations language. It changes the underlying eligibility statute for SNAP, which means state SNAP agencies must apply the revised federal eligibility rules in certification, recertification, case maintenance, notices, compliance tracking, and fair-hearing processes.

The section uses three mechanisms:

It replaces the statutory exception list for the ABAWD time limit.
It modifies waiver rules, including special treatment for noncontiguous states.
It requires quarterly progress reports from noncontiguous states that receive temporary exemptions while moving toward compliance.[1]

Because SNAP benefits are mandatory spending, changing eligibility rules changes federal outlays without Congress separately appropriating or rescinding a Section 10102 funding line.

Expenditure Tracking and Reporting Protocol

Section 10102 affects federal financial flows by reducing SNAP benefits paid through the existing SNAP issuance system. The relevant administering agency is USDA’s Food and Nutrition Service, while state agencies determine eligibility, track compliance, issue notices, and administer case actions. Benefits are federally funded and issued through state-administered Electronic Benefit Transfer systems.

Likely tracking sources include USDA-FNS SNAP participation and benefit data, state SNAP eligibility systems, state quality-control systems, Treasury and OMB budget execution data, CBO estimates, and oversight by USDA’s Office of Inspector General, GAO, and congressional committees. Public tracking will be partly clear at the aggregate SNAP level but difficult to isolate precisely for Section 10102 because benefit reductions will appear as lower participation or lower outlays inside the broader SNAP account rather than as a separately labeled public expenditure line.

Reporting is likely to follow existing SNAP protocols: states report participation, issuance, administrative, and quality-control data to USDA-FNS; USDA publishes national and state-level SNAP data; CBO estimates federal budget effects; and oversight bodies may review implementation. For the special noncontiguous-state exemption, Section 10102 specifically requires quarterly progress reports to the Secretary of Agriculture on milestones, risks, barriers, and mitigation plans.[1]

Section 10102 statutory eligibility change
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USDA Food and Nutrition Service guidance
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State SNAP agencies update eligibility systems
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Caseworkers verify exception status and work activity
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EBT benefit issuance continues for eligible households
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Lower participation and lower federal benefit outlays
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Tracking through USDA SNAP data, state reports, CBO estimates,
Treasury and OMB budget execution, IG and GAO oversight
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        v
Public visibility is partly clear in aggregate SNAP data
but difficult to isolate as Section 10102-only savings

The biggest tracking limitation is attribution. A person may lose or avoid SNAP participation because of work requirements, documentation burdens, state waiver changes, immigration rules, benefit calculation changes, or household changes. Public data may show total participation declines, but not always the exact statutory reason for each case closure.

Day-to-Day Government Process Changes

For USDA, Section 10102 requires guidance, policy memoranda, model notices, waiver review standards, and technical assistance to states. USDA’s OBBB implementation page lists Section 10102 work-requirement guidance, including ABAWD exceptions and ABAWD waiver implementation materials.[5]

For state SNAP agencies, the section increases operational complexity. Eligibility systems must identify adults ages 18 through 64, household child ages, exception status, work activity hours, waiver status, and time-limit months. States must also train eligibility workers and call-center staff, revise notices, update online applications, coordinate with employment and training providers, and prepare for more fair-hearing disputes.

For applicants and recipients, the change turns more routine SNAP interactions into documentation-heavy compliance events. A covered adult may need to prove hours worked, volunteer hours, work-program participation, medical unfitness, pregnancy, responsibility for a child under 14, Tribal or Indian Health Care Improvement Act status, or another exception.

For noncontiguous states, especially Alaska and Hawaii, the law creates a separate temporary compliance pathway. A state may request an exemption based on good-faith efforts, but that exemption can expire, cannot be renewed beyond December 31, 2028, and requires quarterly progress reporting.[1]

Effects on Consumers

The primary consumer impact is reduced access to food assistance for adults who cannot document qualifying work or an exception. CBO estimates a roughly 2.4 million-person average monthly participation reduction over 2025-2034 from Section 10102.[3]

The people most exposed are adults ages 55 through 64 without dependent children, adults in households with children age 14 or older, people in unstable work with fluctuating hours, people whose work is informal or difficult to document, people in areas that previously qualified for waivers, and people who face transportation, caregiving, disability, housing instability, or paperwork barriers.

Consumers may experience:

Consumer group	Likely effect
Adults ages 55-64 without dependent children	Newly exposed to time-limit compliance if not otherwise excepted.
Parents or household members responsible for children age 14 or older	May lose the prior practical protection tied to older dependent children.
Veterans, people experiencing homelessness, and former foster youth	Increased risk of losing SNAP if they cannot meet another exception or document qualifying activity.
American Indians, Urban Indians, and certain California Indians	Newly protected by statutory exceptions.
Households with mixed eligibility status	Benefit amounts may fall if one adult is removed from the SNAP household’s eligible members.

The policy may also increase churn: people may lose benefits for noncompliance, later regain eligibility, and then cycle through documentation and recertification again. That churn can reduce food security even when a person is legally eligible.

Effects on Businesses

Retail food businesses may see reduced SNAP purchasing power in communities with high numbers of affected adults. SNAP dollars are spent quickly and locally, so benefit reductions can affect grocery stores, corner stores, farmers markets, discount retailers, and food delivery or transportation patterns.

Employers may see some workers seeking more scheduled hours to meet the 80-hour monthly threshold. However, the effect depends on whether employers can offer stable hours, whether workers can document those hours, and whether local job availability matches recipients’ transportation, health, caregiving, and schedule constraints.

Businesses that contract with states for eligibility systems, call centers, document management, employment and training, or compliance analytics may see increased demand. States will need system modifications, worker training, reporting tools, and interfaces with employment and training providers.

Environmental and Climate Impact

Section 10102 has no direct environmental permitting, emissions, land-use, energy, or climate provision. Its environmental effects are indirect and likely small relative to the SNAP program as a whole.

Possible indirect effects include shifts in household food purchasing, increased reliance on emergency food networks, and additional administrative activity by state agencies and nonprofit partners. If households lose benefits, they may make fewer grocery trips or purchase lower-cost foods; food banks may see increased demand and distribution activity. These effects are real for communities but are not the central statutory purpose of the section and are unlikely to be separately measured in federal climate or environmental reporting.

Impact Summary

Section 10102 is a major SNAP eligibility tightening provision. It does not appropriate money; it reduces federal spending by narrowing who can remain eligible for food assistance unless they document work or qualifying activity. CBO estimates about $68.6 billion in federal savings over 2025-2034 and roughly 2.4 million fewer SNAP participants in an average month.[3][4]

The section’s most important practical impact is administrative. It pushes more eligibility decisions onto documentation, state tracking systems, work-hour verification, exception screening, waiver determinations, and case closures. The public will likely see aggregate changes in SNAP participation and federal outlays, but section-specific effects may be difficult to isolate because the reductions will flow through ordinary SNAP eligibility and benefit systems rather than a separately labeled spending account.

Key References and Sourcing

Source	Relevance
Public Law 119-21, Section 10102	Primary statutory text for the Section 10102 amendments to the Food and Nutrition Act of 2008.
USDA-FNS SNAP Work Requirements	USDA explanation of SNAP general work requirements and ABAWD work requirements.
CBO, Estimated Effects of Public Law 119-21 on Participation and Benefits Under SNAP	CBO participation and benefit-impact estimates for SNAP provisions, including Section 10102.
CBO, Supplemental Budget Crosswalk for Public Law 119-21	CBO section-level budgetary crosswalk identifying estimated Section 10102 budget effects.
USDA-FNS One Big Beautiful Bill Act of 2025 Implementation Page	USDA implementation hub listing Section 10102 work-requirement guidance resources.
USDA-FNS ABAWD Exceptions Implementation Memorandum	USDA policy memo page for Section 10102 ABAWD exception implementation.
USDA-FNS ABAWD Waivers Implementation Memorandum	USDA policy memo page for Section 10102 ABAWD waiver implementation.

[1] GovInfo, “Public Law 119-21,” Section 10102, https://www.govinfo.gov/content/pkg/PLAW-119publ21/html/PLAW-119publ21.htm.

[2] USDA Food and Nutrition Service, “SNAP Work Requirements,” updated August 29, 2025, https://www.fns.usda.gov/snap/work-requirements.

[3] Congressional Budget Office, “Estimated Effects of Public Law 119-21 on Participation and Benefits Under the Supplemental Nutrition Assistance Program,” August 11, 2025, https://www.cbo.gov/system/files/2025-08/61367-SNAP.pdf.

[4] Congressional Budget Office, “Supplemental Budget Crosswalk for Public Law 119-21,” August 2025, https://www.cbo.gov/system/files/2025-08/61452-Supplemental-Info.xlsx.

[5] USDA Food and Nutrition Service, “One Big Beautiful Bill Act of 2025,” updated February 24, 2026, https://www.fns.usda.gov/obbb.

[6] USDA Food and Nutrition Service, “SNAP Provisions of the One Big Beautiful Bill Act of 2025: ABAWD Exceptions - Implementation Memorandum,” updated February 25, 2026, https://www.fns.usda.gov/snap/obbb-abawd-exemptions-implementation.

[7] USDA Food and Nutrition Service, “SNAP Provisions of the One Big Beautiful Bill Act of 2025: ABAWD Waivers - Implementation Memorandum,” updated February 25, 2026, https://www.fns.usda.gov/snap/obbb-abawd-waivers-implementation.