People experiencing homelessness once had one less hurdle to clear to keep their food assistance: a blanket exemption from SNAP’s work-hour rule that Congress built specifically for them in 2023. A 2025 law rewriting the same section of federal food-assistance law took that protection away. Anyone without stable housing who applies for or renews SNAP now faces the same 80-hour-a-month work-or-training standard as a housed adult in the same age range, unless they qualify for one of the program’s other, non-housing-related exceptions.
The Homelessness Exemption Congress Created In 2023
The exemption traces to the Fiscal Responsibility Act of 2023, the same debt-ceiling law that also created carve-outs for veterans and youth aging out of foster care. It added a categorical exemption from the ABAWD time limit for people experiencing homelessness, using SNAP’s existing definition of the term — someone lacking a fixed, regular nighttime residence, including people staying in shelters, transitional housing, cars, or other places not meant for regular sleeping.
USDA finalized the exemption through a rule published in the Federal Register in December 2024, writing the homelessness carve-out into the agency’s SNAP work-requirement regulations. The reasoning mirrored the logic behind the other two 2023 exemptions: documenting 80 hours of work a month is harder without an address, a phone number, transportation, or the paperwork most jobs and training programs expect. Lawmakers who backed the original exemption argued that penalizing someone for a housing crisis, on top of the crisis itself, ran counter to the purpose of a nutrition program in the first place.
Unlike an age-based cutoff, the homelessness exemption could apply to an adult of any age inside the ABAWD range, and it didn’t require a medical finding or a specific household makeup — only a housing situation that met the program’s definition. That made it one of the more frequently used categorical exemptions among the three the 2023 law created.
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How The 2025 Law Ended It
The One Big Beautiful Bill Act, signed into law July 4, 2025, includes Section 10102(a), which eliminated all three exemptions the 2023 law had created — for veterans, homeless individuals, and youth aging out of foster care — in a single provision. USDA’s Food and Nutrition Administration confirmed the removal in an implementation memorandum for state SNAP agencies, most recently updated in mid-September 2026, directing caseworkers to stop applying the homelessness exemption at screening and recertification.
Because the categorical exemption is gone rather than narrowed, an unhoused adult’s housing situation alone no longer determines their status under the time limit. A person sleeping in a shelter or a vehicle is now screened for the ABAWD rule the same way a housed adult in the same age range would be, with the outcome resting on documented work hours or one of the surviving exceptions rather than on a housing circumstance.
The removal took legal effect on the law’s enactment date, though USDA’s guidance portal lists the formal implementation memorandum as issued Oct. 3, 2025 — about three months later — giving states time to update eligibility systems and retrain staff before applying the change to live cases at local offices.
A short list of exceptions still stands regardless of housing status: people medically certified as unable to work, those caring for a child under 14, people who are pregnant, and a handful of others written into the statute. None of those exceptions is tied to homelessness itself, so an unhoused adult who doesn’t fit one of them now has to meet the 80-hour standard directly.
Meeting A Work Requirement Without A Fixed Address
The practical mechanics of the 80-hour rule assume a level of stability that homelessness often removes: a mailing address to receive a recertification notice, a phone number a caseworker can reach, transportation to a job site or training program, and copies of pay stubs or attendance logs kept somewhere safe. None of those logistics changes because the categorical exemption is gone — they simply now determine whether someone keeps SNAP benefits rather than being beside the point.
Some accommodations remain available case by case rather than automatically. A state agency can, in some circumstances, work with homeless-services providers, shelters or outreach workers to help verify hours or relay notices, and SNAP’s general good-cause provisions can excuse a missed reporting deadline tied to circumstances outside someone’s control. None of that restores the blanket exemption; it only softens the edges of a rule that now applies by default.
The population affected by this specific change often overlaps with the population most likely to fall through the cracks of a paperwork-heavy system, since a returned-mail notice or an unanswered phone call can result in a case closure the person never sees coming until benefits stop arriving. A shelter address or a case manager’s office can sometimes stand in for a permanent mailing address on a SNAP file, but that workaround depends on a caseworker or outreach worker setting it up in advance, not on anything that happens automatically once the exemption ends.
Local SNAP offices vary in how proactively they flag a case that’s about to lose eligibility over unverified hours, and an unhoused applicant without an advocate or a shelter caseworker walking them through the process is more likely to find out about a denial after the fact than before it. That gap in practice, rather than any single provision of the law, is where advocates say the greatest risk to this group now sits.
USDA’s own Q&A on the law’s time-limit provisions, updated as recently as June 2026, treats the end of the homelessness exemption as a permanent feature of the current rule rather than a temporary policy choice. That means an unhoused adult applying for SNAP today enters the system under the new standard immediately, with no separate transition period tied to their housing situation.
When A Renewal Notice Can’t Reach Someone Without An Address
What happens when a renewal notice is mailed to an address that no longer exists, or a work-hour log needs to be rebuilt from memory because the original paperwork was lost along with stable housing, is exactly where a SNAP or Medicaid case can quietly close without anyone intending it to.
The SNAP & Medicaid Renewal Organizer is a 13-page organizer with a renewal and reporting calendar and the 90-day window after coverage is dropped, covering what to do once a notice is missed.
Read the 90-day window rules 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.
