Published August 8, 2025

Time limits are a cut to SNAP and ignore the structural and personal barriers that many SNAP recipients face — including unstable job markets, part-time work with insufficient hours, unpaid caregiving, and jobs that do not provide documentation needed to prove work activity. The reality is that many people affected by these policies are already working or trying to work but cannot meet the rigid requirements.  

Millions of individuals with low incomes, including caregivers, veterans, older adults, and those experiencing homelessness will now face more hardship. It will increase administrative burdens on already strained state agencies and deepen food insecurity and poverty. Proponents claim that people can simply volunteer to maintain their benefits, but this “work-for-food” alternative is difficult to implement in practice. Outlined below are the significant barriers that make mandated volunteering a deeply flawed and burdensome policy, not only for participants but for the states and nonprofits expected to support it. 

The U.S. Job Market
The U.S. job market remains challenging, with the unemployment rate holding steady at 4.2 percent as of July 2024, affecting 7.2 million people. Disparities persist among different groups: Unemployment for adult men is 4.0 percent, women 3.7 percent, teenagers, those 16-19, are a high 15.2 percent, Blacks 7.2 percent, Hispanics (Latine) 5.0 percent, Asians 3.9 percent, and Whites 3.7 percent. Additionally, 4.7 million workers are employed part-time for economic reasons. They would have preferred full-time employment but were working part-time because their hours had been reduced or they were unable to find full-time jobs — highlighting the difficulties in securing stable, well-paying jobs. 

What Are the Current SNAP Time Limits, and What Has Changed? 

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. 

More recently, congressional Republicans, with support from President Trump, passed H.R. 1 — legislation that 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 
  • Some Native American adults, with only limited exemptions 

Why is this expansion concerning? 

Food for the hungry shouldn’t have a time limit. 

This sweeping expansion dramatically increases the number of people at risk of losing food assistance, many of whom are already facing barriers to paid work or are serving as unpaid caregivers. Removing food assistance does not reduce the need for food; it simply increases hardship. 

Research consistently shows that SNAP time limits do not increase long-term employment. Instead, they create administrative burdens and result in eligible people losing benefits due to paperwork errors, lack of child care, and limited access to qualifying work or training. These burdens fall heavily on state agencies and on nonprofit or public organizations expected to absorb the impact. 

What Is the Community Service or Volunteer Option?
Federal regulations allow individuals subject to the time limit to “work-for-food” by volunteering at a state-approved nonprofit or public agency. However, this is not as simple as it may sound. 

States are not required to run volunteer programs, and these placements are not typically part of the SNAP Employment and Training (E&T) program. This means: 

  • There is no additional federal funding or dedicated staff to recruit or oversee volunteer sites. 
  • Depending on the structure of the state’s workfare program, individuals may be required to secure their own volunteer placement that meets state agency requirements. In states that allocate funding for workfare, the agency may instead take responsibility for recruiting and approving qualified nonprofit sites. 
  • Participants must track and document their volunteer hours, which are calculated based on their monthly SNAP benefit amount divided by the higher of the state minimum wage or the federal minimum wage ($7.25/hour). 
    • Example: A person receiving $194/month in SNAP must volunteer 26 hours per month (~6–7 hours/week). 

What burden does this place on state agencies?
State agencies are already stretched thin, particularly in the wake of HR. 1. The expansion of time limits increases the number of individuals subject to complex eligibility rules and ongoing tracking, without any additional funding or staff capacity. 

Separately, agencies are expected to coordinate with nonprofit organizations to support program implementation. Recruiting, supervising, and engaging nonprofits as volunteer host sites adds administrative demands, yet none of these activities come with additional federal funding. 

Additionally, caseworkers must review the files of individuals subject to time limits or reapplying after benefit termination multiple times. This process significantly increases administrative costs, primarily due to additional staff time. These costs are further compounded by high churn rates, as time-limited participants frequently exit and re-enter the program due to challenges in meeting continuous eligibility requirements. 

What burden does this place on nonprofits?
Nonprofits asked to host time-limited SNAP participants may have to complete official documentation, track volunteer hours, and report absences or early terminations to the state. These responsibilities are especially burdensome for small, community-based organizations that were never designed to function as workfare supervisors. 

Hosting volunteers requires time and resources. Organizations must provide appropriate training, supplies, supervision, and ongoing support. Yet most nonprofits lack the funding or infrastructure to manage these responsibilities effectively. Youth-serving organizations, in particular, face higher costs due to the intensive recruitment and training required, including background checks and other screening procedures. 

Additionally, many nonprofits already rely on high school and college students to fulfill internship or service requirements. Even when volunteer sites are available, they may not have the capacity to onboard and train additional individuals, especially those who may lack the skills or readiness needed to contribute meaningfully. 

Do participants get help finding a volunteer site or getting there?
Generally, no assistance is provided to help participants find a volunteer site or cover transportation costs. This disproportionately harms rural residents, who may live far from approved volunteer sites. 

For example, consider a retired grandmother living on Social Security in a small rural town. She may rely on SNAP to afford food after covering rent, utilities, and medication. If subject to time limits, she may be forced to drive an hour each way just to volunteer and maintain benefits, despite the lack of compensation or support. 

Why Not Use Employment & Training Funding to Cover These Activities? 

Using SNAP Employment and Training (E&T) funding to support volunteer placement not only misaligns with program goals but also risks reducing the quality and impact of services available to SNAP participants seeking education, training, and employment support. States may technically use E&T funding to support volunteer activities, but doing so undermines the core purpose of the E&T program. Designed to help SNAP participants build skills, gain work experience, and move toward self-sufficiency, SNAP E&T offers training, education, and supportive services such as transportation and child care to reduce barriers to employment. 

In contrast, volunteer programs — whether operated within SNAP E&T or as comparable programs — typically require participants to perform unpaid labor in exchange for their benefits, without any guarantee of skills development, career advancement, or transition into stable employment. Volunteer sites used in workfare rarely offer structured training or pathways to long-term work, meaning they fail to meet E&T’s intent to promote upward mobility. 

Additionally, implementing volunteer programs within SNAP E&T requires states to fund, contract with, and monitor volunteer sites — an expensive and administratively burdensome task. Given that E&T funds are limited and meant to support evidence-based employment and training strategies, diverting these resources to unpaid work requirements does not represent an effective or efficient use of funds. 

What is SNAP E&T and how is it used?
SNAP Employment & Training (E&T) is designed to help participants gain skills, education, or work experience. States must operate an E&T program but have wide flexibility in who they serve, what services they offer, and how they deliver them. These services range from job search and resume help to vocational training and education. However, quality and availability vary greatly. 

Are E&T programs effective?
Outcomes are mixed. While well-designed programs can help people access better jobs, many states emphasize quick job placement (“work-first”) over education or long-term skill-building. Some programs require participants to conduct job searches or participate in workfare — unpaid labor that rarely leads to lasting employment. 

A U.S. Census Bureau study found that individuals subject to time limit work requirements often remained stuck in low-wage, entry-level jobs, even after years of participation. The few programs that showed real success provided robust training, supports, and encouraged participants to seek higher-quality jobs. 

What barriers do E&T participants face?
According to a USDA national survey: 

  • 80 percent reported at least one barrier to employment (health, transportation, caregiving, education). 
  • 28 percent reported three or more barriers. 
  • 32 percent experienced job search discrimination, often based on age, race, or gender. 

Lack of child care, mental health services, and transportation — especially in rural areas —limits participation and effectiveness. Many participants never receive support services, despite identifying them as critical to success. 

Why is participation in E&T so low?
Low engagement reflects systemic gaps: 

  • Many participants are unaware of services due to transiency or poor outreach. 
  • Supports like child care and transportation are underfunded or unavailable. 
  • Rural residents face long travel times with few accessible training options. 
  • Formerly incarcerated individuals may be discouraged from participating due to limited job prospects. 

Can individuals enroll in a training program instead of volunteering?
Technically, yes — but training programs often run in cycles and may not accept new participants year-round. If someone is cut off from SNAP and the next training session doesn’t start for weeks or months, they may remain ineligible for benefits in the meantime, further deepening their hardship. 

Can E&T support time-limit compliance?
Not reliably. E&T participation may fulfill the work requirement, but the program is often under-resourced and inconsistent. It cannot substitute for food assistance, especially when people face real barriers that training alone cannot resolve. Even the best-designed E&T programs cannot create jobs where none exist or eliminate longstanding employment inequities. 

SNAP Time Limits Do Not Work 

Time limits impose unnecessary burdens on vulnerable populations, increasing food insecurity and poverty. These policies fail to address the structural barriers to employment and lack adequate support systems, leaving state agencies and nonprofits to manage additional responsibilities without funding. Volunteers face the challenge of contributing unpaid hours with no assistance for transportation or child care. Instead of creating opportunities for economic mobility, these measures perpetuate hardship and complicate an already flawed system. To effectively address hunger, we need policies that focus on lowering food costs, skills development, sustainable jobs, and access to essential services, not punitive restrictions.