Non-disabled adults as old as 64 now face federal time limits on food assistance, a shift that could push more than a million older Americans off the Supplemental Nutrition Assistance Program. The expansion, signed into law as part of P.L. 119-21, extends so-called ABAWD (able-bodied adults without dependents) work requirements a full decade beyond the previous cutoff of age 54. Federal agencies have already directed states to update their eligibility notices, but no public data yet shows how many affected recipients have actually received those letters.
How the age threshold jumped from 54 to 64
Until 2023, ABAWD time limits applied only to adults aged 18 through 49. The Fiscal Responsibility Act of 2023 raised the ceiling to age 54, a change the USDA codified through a final rule that also spelled out exemption categories. P.L. 119-21, formally titled the One Big Beautiful Bill Act, pushed the boundary again, this time covering non-disabled adults under 65. That means adults aged 55 through 64 who do not meet work, training, or volunteer requirements now face a three-month benefit limit within a 36-month window, the same constraint that younger recipients have dealt with for years.
The latest expansion builds on earlier debates over tightening food aid rules. During consideration of the House energy package H.R. 1, lawmakers folded in SNAP-related provisions that the Congressional Budget Office later evaluated as part of its broader cost estimate. A Brookings Institution analysis identifies non-disabled adults ages 55 through 64 without dependent children as one of the newly affected groups and cites CBO estimates that work-requirement provisions in H.R. 1 reduce SNAP participation by roughly 2.4 million people in an average month over the coming decade. That aggregate figure covers all age cohorts subject to the expanded rules, not just the 55-to-64 group, but the older cohort represents a significant share of the newly covered population.
Policy specialists note that this layer of work rules lands on adults who already face steeper labor-market barriers. Research synthesized in a Congressional Research Service discussion of older workers points to higher rates of long-term unemployment among people in their late fifties and early sixties, particularly those with limited education or health challenges that fall short of federal disability standards. Many in this age band cycle between short-term jobs, caregiving responsibilities, and periods of joblessness, making it harder to sustain the steady 80 hours of work or qualifying activities per month that ABAWD rules typically require.
State notice gaps could widen participation drops
The USDA Food and Nutrition Service has instructed states to update their notices so individuals aged 55 through 64 learn they are now subject to the ABAWD time limit, according to the agency’s implementation memorandum. But no state-level data has surfaced showing how many of those letters have gone out or how many recipients have responded. That information gap matters because states with weaker outreach systems and higher concentrations of residents in the 55-to-64 range are likely to see sharper drops in enrollment. If administrative notices fail to reach eligible adults before their benefits lapse, people who could qualify through exemptions or by meeting work-hour thresholds may lose coverage by default rather than by choice.
Implementation also depends on how aggressively states use waivers. Under long-standing law, states can request relief from ABAWD time limits in areas with elevated unemployment or insufficient jobs, a flexibility described in a Congressional Research Service review of SNAP work requirements. The new statute does not eliminate those waivers, but it does narrow the pool of counties that qualify, and some governors have signaled reluctance to seek broad exemptions. That means older adults in economically weak regions could still find themselves subject to strict time limits if state officials decline to pursue available flexibilities.
The law also narrows caregiver protections. Under the new rules, parents or guardians of children aged 14 through 17 may no longer automatically qualify for an exemption from the time limit, a change that Brookings flags as a constraint on the program’s ability to respond to downturns. Adults in their late fifties and early sixties who are helping raise grandchildren or teenage relatives could be forced to juggle caregiving with additional work hours simply to keep food benefits, even in households already living close to the poverty line.
Advocates warn that the combination of higher age thresholds, tighter exemptions, and uncertain state outreach will fall hardest on people with unstable health who do not meet the strict criteria for disability benefits. Many older SNAP recipients report chronic conditions that limit the types of jobs they can do, but they may lack formal medical documentation or struggle to navigate the paperwork required to secure an exemption. Without legal aid or caseworker support, those adults are more likely to time out of the program after three months.
For now, the full impact of the new ABAWD rules remains unclear. Federal officials have not released comprehensive figures on how many 55-to-64-year-olds have already lost benefits, and state agencies are still revising their systems to track the expanded age band. What is clear is that SNAP, long treated as an automatic stabilizer during economic downturns, will offer less secure support to older adults in the next recession. As implementation moves forward, the key questions will be whether states invest in clear communication, whether they fully use remaining waiver authority, and whether Congress revisits the balance between encouraging work and protecting food access for people nearing retirement age.
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