June 8, 2023

Changes are happening in Supplemental Nutrition Assistance Program (SNAP) eligibility and operations in summer 2023, both because SNAP temporary policies during the pandemic are “unwinding” and because the recently enacted debt ceiling law amends the population groups subject to SNAP time limit rules.[i] Communicating with SNAP participants and applicants will be even more important in the weeks and months ahead to ensure that eligible people do not miss out on benefits.

Pandemic-Era Relief Ending
In March 2020, Congress authorized SNAP Emergency Allotments (EAs) and suspended SNAP time limits for the duration of the U.S. Department of Health and Human Services (HHS) COVID-19 Public Health Emergency (PHE) declaration. Similarly, in December 2020, Congress eased some barriers to college student SNAP access for the duration of the PHE.[ii]  The U.S. Department of Agriculture (USDA) also approved numerous pandemic-era waivers of SNAP procedural rules to help agencies and clients.[iii] In December 2022, Congress prematurely terminated SNAP EAs,[iv] resulting in  SNAP benefits that average a mere $6 a person a day. Now that the  HHS pandemic PHE declaration ended on May 11, 2023, USDA is “unwinding” other temporary SNAP policies.[v]

Persons With Limited English Proficiency and People With Disabilities

By memorandum dated May 30, 2023, USDA’s Food and Nutrition Service (FNS) has reminded SNAP state agencies to pay particular attention to their civil rights law responsibilities to serve persons with limited English proficiency (LEP) and those with disabilities.[vi] FNS explained, “According to recent census data, approximately 68 million people in the United States speak a language other than English at home, and up to 1 in 4 adults have some type of disability [1]  Notably, those impacted by the unwinding of EA allotments and upcoming unwinding of COVID-19 program flexibilities include individuals who belong to undeserved communities, such as individuals with disabilities and LEP individuals. Therefore, it is imperative that states carefully consider their obligations toward these vulnerable communities.” The FNS memorandum lists “best practices” on communicating with these population groups, as well as encourages SNAP state agencies to make cross referrals to other programs for which SNAP applicants may qualify.

Additional Outreach to Target Populations

FRAC and allies are encouraging special outreach to SNAP eligible people who are ages 18 to 55 without dependents, college students, people who are homeless, military veterans, and young adults aging out of foster care.  At the same time, it has added exemptions to the time limits for people who are homeless, military veterans and young adults aging out of foster care.

Even before the new changes to the time limits, FNS had provided guidance to state SNAP agencies about the steps they would have to take when the temporary suspension of the time limits ended. [vii] By memorandum dated September 20, 2021, FNS had advised, “Administering the time limit incorrectly can result in individuals losing SNAP benefits for which they are eligible, cause payment errors, and negatively impact quality control (QC) error rates. As a fundamental first step, state eligibility workers must determine whether each work registrant meets an exemption from the ABAWD work requirements.”

Anecdotal evidence from community groups and research from the Urban Institute confirm that states have challenges in properly identifying those who are subject to the time limits, particularly with regard to whether they are “fit for work.”[viii] The Century Foundation has pointed out that the “rigid three-month (out of thirty-six months) time limit on SNAP receipt for so-called ‘able-bodied adults without dependents’ has put SNAP out of reach for an unknown number of disabled people over the years due to improper eligibility screening and barriers in fully completing the documentation required to sufficient hours of work activities.”[ix]

Proper screening for SNAP eligibility is crucial, including for people with disabilities as well as for those newly exempt population groups. In a June 5 letter to four cabinet secretaries, Sens. Debbie Stabenow (D-MI), Ron Wyden (D-OR), Sherrod Brown (D-OH), and Jon Tester (D-MT) wrote, “Guidance issued to states from your agencies should ensure related policies are implemented consistently across all states to equitably reach the highest number of eligible participants, reduce administrative and paperwork burdens on both state agencies and SNAP participants, and to ensure participants are adequately screened for exemptions prior to losing access to benefits. This is particularly timely as states work to reinstate the ‘able-bodied’ time limits following the end of the Public Health Emergency.”[x]

End SNAP Time Limits

Even the best implementation of SNAP’s three-month time limits will take food away from many people who are unemployed or underemployed unless they are documenting 80 hours of work activities each month. The meaningful, effective, and equitable remedy for the arbitrary, punitive SNAP time limits is to end them permanently for all groups. H.R. 1510, introduced by Rep. Barbara Lee (D-CA) and cosponsored by 73 House members, would do just that[xi].


[i] See Luis Guardia, “Expansion of Harsh Time Limits on SNAP in Debt Ceiling Agreement Will Fuel Rates of Hunger and Poverty,”Food Research & Action Center (FRAC), 5/29/23  https://frac.org/news/debtceilingbillmay2023

[ii] See Andrew Cheyne and Ellen Vollinger, “A Strengthen SNAP Agenda to Address the Hunger Cliff–Part 1,” FRAC Chat, FRAC, Feb. 3, 2022,  https://frac.org/blog/strengthen-snap-agenda-part-1

[iii] See Andrew Cheyne and Ellen Vollinger, “A Strengthen SNAP Agenda to Address the Hunger Cliff–Part 1=2,” FRAC Chat, FRAC,Mar. 15, 2022, https://frac.org/blog/strengthen-snap-agenda-part-2

[iv]See Luis Guardia, “Offset in Omnibus Would Cut SNAP and Hasten Hunger Cliff for Millions,” FRAC, Dec. 20, 2022,  https://frac.org/news/omnibuscutsnaphungercliffdecember2022

[v]See “FNS Response to COVID-19 Public Health Emergency,” USDA Food and Nutrition Service, accessed June 6, 2023,  https://www.fns.usda.gov/coronavirus

[vi]See Sasha Gersten-Paal, “Supplemental Nutrition Assistance Program (SNAP) Preparing for Reinstatement of the Time Limit for Able-Bodied Adults without Dependents (ABAWDs)”, FNS, Sept. 20, 2021,  https://fns-prod.azureedge.us/sites/default/files/resource-files/SNAP%20Preparing%20for%20Reinstatement%20of%20Time%20Limit%20for%20ABAWDs.pdf

[vii]See Roberto Contreras, “Ensuring Language Access for Limited English Proficient (LEP) Individuals and Effective Communication for Individuals with Disabilities In Consideration of the Recent Unwinding of the Supplemental Nutrition Assistance Program (SNAP) Emergency Allotments (EA) and Upcoming Unwinding of COVID-19- Program Flexibilities,” USDA, May 30, 2023, https://www.fns.usda.gov/snap/snap-preparing-reinstatement-time-limit-abawds

[viii]See Laura Wheaton, “The Impact of SNAP Able-bodies Adults Without Dependents (ABAWD) Time Limits REiinstatrions in Nine States,” The Urban Institute, June 2021,   https://www.urban.org/sites/default/files/publication/104451/the-impact-of-snap-able-bodied-adults-without-dependents-abawd-time-limit-reinstatement-in-nin_0.pdf

[ix]See Rebecca Vallas et al, “Economic Justice Is Disability Justice,” The Century Foundation, Apr. 21, 2022, https://tcf.org/content/report/economic-justice-disability-justice/

[x] See Senators Debbie Stabenow, Ron Wyden, Sherrod Brown and Jon Tester, Letter to Secretaries of USDA, VA, HUD, and HHS, June 5, 2023,   https://www.agriculture.senate.gov/imo/media/doc/letter_to_usda_va_hud_and_hhs_re_debt_limit_abawd_exemption_6523.pdf

[xi]See Ellen Vollinger, “History Shows Congress Should End SNAP Time Limits,” FRAC Chat, FRAC, May 1, 2023,  https://frac.org/blog/history-shows-congress-should-end-snap-time-limits