USDA’s SNAP work-requirements page, last updated July 16, 2026, lists seven exemptions from the program’s three-month time limit, including veterans and people experiencing homelessness. A USDA memo dated September 4, 2025 says the 2025 law removed both of those exceptions, along with one for young adults who aged out of foster care. The agency also says on the same page that guidance on how the law changes the work rules is still being prepared, so the printed list and the memo point in different directions.
The exemption list USDA’s page prints is not the whole story. The SNAP & Medicaid Renewal Organizer lays out the SNAP work-rule time limit and who is exempt, next to a renewal and reporting calendar.
Open the SNAP time-limit and exemption layout with its reporting calendar →
Three months in three years, then 80 hours a month
The rule applies to what USDA calls able-bodied adults without dependents. On its work-requirements page, USDA describes them as people ages 18 to 54 who are able to work and have no dependents. Such an adult can receive SNAP for only three months in three years unless working at least 80 hours a month, whether through a job, a work program or a combination of the two.
USDA’s separate eligibility page, which covers October 1, 2026 through September 30, 2027, states the same test as 20 hours a week. That page, updated October 1, says the 2025 law changes certain SNAP eligibility factors and that USDA is still updating it with the changes.
The seven exemptions as the page prints them
The work-requirements page counts seven exceptions to the time limit:
- Unable to work due to a physical or mental limitation.
- Pregnant.
- Have someone under 18 in the SNAP household.
- Excused from the general work requirements, which the page describes separately and which include working 30 hours a week or studying at least half-time.
- A veteran.
- Experiencing homelessness.
- Age 24 or younger and in foster care on the 18th birthday.
The page does not mark any of the seven as removed. What it does say is that USDA is “in the process of providing guidance on how The One Big Beautiful Bill Act of 2025 changes the work requirements for SNAP able-bodied adults without dependents.”
What the September 2025 memo changed
The change is spelled out in the SNAP provisions implementation memo issued under the name of Ronald Ward, Acting Associate Administrator for SNAP. It removes the exceptions for homeless individuals, for veterans and for people 24 and younger who aged out of foster care, which are three of the seven on the page. It raises the age exception so the requirement reaches adults up to 64, where the page says 54. It narrows the dependents exception to a child under 14, where the page says under 18. And it adds exceptions for people defined as an Indian, Urban Indian or California Indian under the Indian Health Care Improvement Act.
The memo states that “these changes were effective upon enactment.” It also narrows work-rule waivers: states other than Alaska and Hawaii may now request them only where an area’s unemployment rate is at least 10 percent. Alaska and Hawaii have a separate good-faith provision that expires no later than December 31, 2028.
Where the page and the memo stop matching
Read side by side, the two documents disagree on four points: who is too old for the rule, which dependents count, whether veterans are exempt and whether homelessness is. The work-requirements page, last updated July 16, 2026, still carries the earlier list, and the eligibility page dated October 1 describes itself as unfinished.
A printed exemption list the memo has overtaken
The difficulty for an adult in SNAP is that the most visible USDA list is the one the memo changed. A veteran or a person experiencing homelessness who reads only the work-requirements page would find an exemption that the implementation memo says no longer exists, and a 60-year-old who reads the same page would see an age ceiling of 54 that the memo moves to 64. A household whose youngest child is 15 sits inside the page’s “under 18” exemption and outside the memo’s “under 14.”
The clock is the other half. Three months in three years is counted whether or not anyone has read the guidance, and the 80 hours a month, or 20 a week on the eligibility page, is the standard an adult without an exemption has to meet. USDA says guidance is coming, and nothing on the pages read for this piece gives a date for it.
The official route is USDA’s own Food and Nutrition Administration pages, which publish the rule, the memo and the eligibility tables free of charge, with the memo as the document that spells out what changed.
Reading a work rule that changed on paper first
The three-month limit and the seven printed exemptions are the part of SNAP that now depends on which USDA document a household reads. The memo moved the age ceiling, the dependents threshold and three exemptions, and the work-requirements page still waits on guidance. Sorting out which exceptions survive is the unfinished job.
The SNAP & Medicaid Renewal Organizer includes 51 state packs and a renewal document checklist for assembling a household’s SNAP paperwork.
Read how the 2025 law changed SNAP’s three-month limit and its exemptions →
This piece was drafted with AI assistance; the exemptions and memo terms were checked against USDA’s work-requirements page, its eligibility page and the September 2025 implementation memo.
