Published October 10, 2025

Q&A: How Does the New SNAP Time Limits Policy Affect You? What States and Families Need to Know 

The U.S. Department of Agriculture (USDA) has announced the end of remaining Supplemental Nutrition Assistance Program (SNAP) time limit waivers and new guidance that will result in major changes nationwide. Starting this winter, millions of adults — including caregivers, veterans, older workers, and people experiencing homelessness — could lose food assistance under expanded time limits passed in the 2025 budget reconciliation law (H.R. 1). 

The Q&A below explains what is changing, when the new guidance takes effect, and what states and advocates need to know. 

Q: What are the current SNAP time limits — and what’s changing? 

SNAP time limits were first introduced in 1996 through the Personal Responsibility and Work Opportunity Reconciliation Act (PRWORA). Under this law, certain adults ages 18–49 without dependents were limited to three months of SNAP benefits every three years unless they met a 20-hour-per-week work requirement or qualified for an exemption.  

In 2023, the Fiscal Responsibility Act (FRA) expanded the age range to include adults 50–54 and added temporary exemptions for veterans, individuals experiencing homelessness, and former foster youth under 24. These changes were set to expire in 2030.  

President Trump, signed H.R. 1 into law on July 4 of this year. The legislation dismantles SNAP and significantly expands time limits. The new policy includes:  

  • adults up to age 65  
  • parents, grandparents, or caregivers of children ages 14 or older  
  • veterans  
  • adults experiencing homelessness, including homeless families with teenage children  
  • youth aging out of foster care  

The law does provide an exemption from time limits for certain Native American adults. See here how the USDA is deciding who qualifies as eligible for an exemption.  

Q: How did H.R. 1 change the criteria for states to apply SNAP time limit waivers? 

H.R. 1 also eliminates the long-standing option for states to receive waivers based on a “lack of sufficient jobs,” a provision that many states relied on for nearly three decades to protect residents in areas with limited employment opportunities. Under the new law, an area now qualifies for a waiver only if its unemployment rate exceeds 10 percent. Alaska and Hawaii were granted separate provisions allowing them greater flexibility in applying for waivers. 

Q: When do SNAP time limit waivers on “lack of sufficient jobs” end? 

Many states had waivers in place because certain areas lacked sufficient jobs, and they sought to protect vulnerable residents from losing essential food assistance. States planned their operations and budgets around these waivers. However, USDA is now abruptly rescinding even those waivers that were approved through next year. As a result, the remaining waivers in about 20 states will end on November 2, 2025. 

Under the “for the full benefit month” rule in 7 CFR 273.24(b)(1), the time clock for the three-month limit does not begin until the first full month after the waiver ends. This means the countable months will be December, January, and February, with affected individuals potentially losing benefits in March. 

Q: What about the new provisions for adults ages 55–64, caregivers of children over 14, veterans, youth aging out of foster care, and people experiencing homelessness? 

USDA has clarified that the effective date for these changes was July 4, 2025, the day the law was enacted. The agency also announced that the 120-day “quality control (QC) hold harmless” period will end on November 1, 2025. During this period, states will not be penalized for administrative errors as they adjust to new regulations and update their systems. This is separate from the start of implementation.  

The hold harmless period is critical because, under H.R. 1’s new cost-share rules, states will soon have to share SNAP benefit costs based on their payment error rates. By rushing states, the administration is setting states up for higher error rates and potential financial penalties once the grace period ends. 

USDA’s compressed timeline has left states scrambling to update systems, train staff, and issue new guidance. Meanwhile, USDA is planning to consolidate seven regional offices into five, further reducing oversight and technical support. These sweeping program changes require at least 12 to 18 months for proper implementation, yet states are being forced to act without adequate time, staffing, or information. The result will be confusion, administrative errors, and disruption amid inflation, uncertainty, and a government shutdown. 

In contrast, during the rollout of the 2023 Fiscal Responsibility Act, USDA provided a clear timeline, multiple rounds of technical guidance, and flexibility that allowed states to prepare and protect vulnerable residents — support that is conspicuously absent now. 

Q: How does implementation vary across states? 

Implementation will not be uniform across states. Some states have already begun applying the new rules, while others plan to phase them in at each household’s next certification or recertification period. Because of these differences, advocates and SNAP participants should check with their state SNAP office to confirm specific timelines and procedures. 

In most cases, households will encounter these changes during an initial application or at their next recertification, which typically occurs every six or 12 months for ongoing cases. If a state applies the new rules before a household’s next recertification, it must follow the verification requirements in 7 CFR 273.2(f) and 7 CFR 273.24(l), including providing written notice and allowing the household an opportunity to submit additional information or verify exemptions before benefits are reduced or terminated. 

Q: Why is this expansion concerning? 

These changes will remove vital food support from caregivers, veterans, older adults, and people already struggling to find stable work. Research consistently shows that time limits do not increase employment, but they do increase administrative burdens and food insecurity, especially when states are forced to rush implementation. 

The consequences will be particularly severe in rural areas, where poverty rates are already high, especially among part-time workers. In 2023, rural part-time workers were more likely than their urban counterparts to be among the working poor — often due to caregiving responsibilities, not economic conditions. At the same time, access to child care continues to decline: Between 2017 and 2022, rural areas saw a steady drop in private child care providers, especially in small cities and rural-adjacent communities. Without accessible child care, meeting work requirements becomes even harder, putting rural families at greater risk of losing essential food support.  

Q: What is the impact on states and local economies? 

Every $1 in SNAP benefits generates up to $1.80 in economic activity, meaning these cuts will ripple through local economies — particularly in rural areas, where one in seven households relies on SNAP. 

Starting in fiscal year 2028, states will also be required to share the cost of SNAP benefits, facing penalties up to 15 percent for higher error rates — even if those errors stem from unclear guidance.  

Q: What can advocates and policymakers do? 

Programs like SNAP embody our nation’s core values of fairness, compassion, and opportunity. Most people who rely on SNAP are already working, often in low-wage or gig jobs with unpredictable hours, few benefits, and limited opportunities to advance. H.R. 1’s expanded time limits will not create jobs or raise wages; they will only deepen hardship and hunger. As these new rules take effect, continued vigilance and advocacy will be essential to protect those most at risk.  

Advocates and state leaders should: 

  • Monitor implementation closely and report harmful impacts. 
  • Educate participants about exemptions and rights. 
  • Track wrongful terminations or administrative errors, and assist participants in appealing those denials or wrongful terminations. 
  • Engage federal policymakers to restore the historical cuts made to SNAP and support. The Restoring Food Security for American Families and Farmers Act of 2025 would repeal the damaging Budget Reconciliation Law (H.R. 1) SNAP cuts. You can contact your member of congress with FRAC Action Network (FAN). 
  • Engage state and local policymakers to create coordinated, community-based solutions that reduce barriers to work and food access by:
     
  • Partnering with workforce boards, community colleges, and chambers of commerce to expand apprenticeships, job training, and career pathways in industries offering living wages and long-term stability. 
  • Addressing systemic barriers such as limited transportation, child care shortages, lack of internet or computer access, and inadequate language services that prevent full participation in employment and training programs. 
  • Challenging harmful narratives that blame individuals instead of recognizing labor market instability as the real driver of hardship. 
  • Encouraging employers to offer fair wages, training, and advancement opportunities that reduce turnover and strengthen local economies. 

The H.R. 1 changes to SNAP, including time limit expansion, will increase hardship for families, strain state agencies, and weaken local economies. Advocates and states should prepare to support and guide participants and applicants in navigating the new policies and connect them to other resources to fill the gap left by the policies — because food for the hungry should not have a time limit.