A single Supplemental Nutrition Assistance Program overhaul now tells state caseworkers two things about the same person at the same time. Someone who turns 60 is still shielded from being ordered into a mandatory employment and training slot, a protection built into food stamp law for decades. But that same 62-year-old, under the One Big Beautiful Bill Act signed July 4, 2025, is no longer automatically exempt from the three-month benefit clock that applies to able-bodied adults without dependents. The U.S. Department of Agriculture’s October 3 implementation memo lays out both rules without reconciling the contradiction for the people caught between them.
The General Work Requirement Exemption Holds at 60
Section 6(d)(3) of the Food and Nutrition Act sets the general work requirement that applies to most working-age SNAP applicants, and the One Big Beautiful Bill Act left its upper boundary untouched. Individuals 60 or older remain outside that requirement entirely, which means state agencies cannot refer them to Employment and Training on a mandatory basis regardless of how the rest of their case looks. Employment and Training programs exist to help work registrants build skills or search for jobs, and mandatory referral has always been the tool a state uses to enforce the general work requirement, not the separate time limit that applies to a narrower group.
The law also left the SNAP definition of “elderly” untouched at age 60, a status that carries weight well beyond the work rules. Households with a member 60 or older continue to qualify for the uncapped excess shelter deduction and the excess medical expense deduction, calculations that can meaningfully raise a monthly benefit for someone with high rent or ongoing prescription costs. The September 4, 2025 information memorandum describing the law’s SNAP provisions section by section treats that continuity as a deliberate choice, not a detail state agencies need to guess about.
Keeping the 60-and-older group outside mandatory Employment and Training while still subjecting some of that same group to a separate time limit means the time limit now functions as a freestanding eligibility rule for this age band, disconnected from any state-run work program at all. A caseworker cannot resolve a 62-year-old’s case by pointing to the work-program exemption, because the exemption answers a different question than the one the time limit asks.
Free download: The recertification document list, how to handle a missing benefit or skimmed card, and when to ask for a fair hearing. Download the free SNAP checklist.
The ABAWD Time Limit Now Runs Through Age 64
Running alongside the general work requirement is a narrower rule: the time limit on able-bodied adults without dependents, detailed in USDA’s October 3, 2025 implementation memorandum, which cuts off benefits after three months in a 36-month period unless the person works or trains 20 hours a week. Before the new law, that time limit stopped applying once someone turned 55. The One Big Beautiful Bill Act pushed the cutoff to 65, meaning anyone aged 55 through 64 who previously aged out of the time limit is now inside it, with no work-program referral required to trigger the clock.
That distinction is the source of the contradiction the memo leaves unresolved. A 62-year-old cannot be mandated into an Employment and Training slot, because the general work requirement exempts them outright, but the same person can still lose benefits after three countable months if they do not independently meet the 20-hour activity standard or live in an area covered by an active waiver. State agencies are told to screen for both statuses in the same interview, and the two screens can produce opposite answers for people who are, in every other respect, identical.
The jump did not happen gradually. Before this law, the age threshold had already been rising in stages: the Fiscal Responsibility Act of 2023 was gradually moving the upper edge of the time limit from 49 to 54 through fiscal year 2030, a multi-year phase-in state agencies had years to plan around. The One Big Beautiful Bill Act discarded that runway and moved straight to 65 the moment it took effect, compressing what had been a seven-year adjustment into a single implementation memo issued more than a year ahead of the schedule the 2023 law had set.
State agencies retain narrower tools to soften the transition for individuals who briefly fall out of compliance. A single discretionary exemption can extend eligibility by one month, and a finding of good cause can excuse a temporary lapse in the 20-hour requirement, but neither tool changes the underlying determination that a 60-to-64-year-old is now inside the time-limited population in the first place.
A Notice Duty With No Grace Period Left
USDA’s memo does not treat the age change as a future concern. State agencies were told to apply the modified age bands immediately to every initial application and every recertification, and to update the consolidated work-requirement notice so it reflects both the unchanged 60-and-older exemption from mandatory Employment and Training and the new time limit reaching to 64. The guidance remains the department’s current word on the subject; its public landing page shows a September 15, 2026 update, more than eleven months after the rule took effect.
That timeline means the guidance functions less as a warning and more as a description of enforcement already underway. A caseworker evaluating a 63-year-old’s case today is meant to check the general work requirement box, the time-limit box, and the notice-history box in the same sitting, and separating the three incorrectly risks either cutting off an exempt person’s mandatory-program status by mistake or leaving countable months untracked for someone who is not exempt from the time limit at all.
USDA’s tribal consultation materials, issued three weeks after the implementation memo, flagged the same age band as one of the changes most likely to catch existing participants off guard, listing “individuals age 55 to 64” among the groups newly required to meet ABAWD work requirements even as the general work exemption for the same ages held firm. The line between who a state can order into a program and who a state must still time-limit is not a drafting error; it is how the statute was written, and it now governs every SNAP case file for someone in their early 60s.
Tracking the SNAP Reporting a Time Limit Requires
The general work requirement exemption and the ABAWD time limit run on separate tracks inside the same SNAP case file, and neither one pauses the paperwork a household still owes at its next recertification. A birthday that lifts someone out of mandatory Employment and Training does nothing to the renewal calendar SNAP and Medicaid both keep running in the background, and the two programs rarely share a single deadline sheet. Households juggling both often end up tracking each one separately, with no document that lines the dates up.
The SNAP & Medicaid Renewal Organizer is a 13-page organizer built around 51 state packs, a renewal document checklist, and a renewal and reporting calendar, including guidance on the 90-day window after coverage is dropped.
See the 51 state packs and the renewal and reporting calendar in The SNAP & Medicaid Renewal Organizer.
This article was researched and drafted with the assistance of AI and reviewed by The Money Overview editorial team.
