Alaska and Hawaii are the only two states with a second route around SNAP’s tightened work-time limit, and the route has nothing to do with the over-10-percent unemployment test now required everywhere else. Under Section 10102 of the One Big Beautiful Bill Act, the two states can still waive the limit for an area at 1.5 times the national unemployment rate, and either state can separately request a good-faith exemption while it builds the capacity to enforce the work rule at all. USDA’s implementation memo says any such exemption expires no later than December 31, 2028, whichever state uses it and however far its enforcement has progressed by then.
A different math for two states
Most states need an area’s unemployment rate over 10 percent to waive the work-time limit for able-bodied adults without dependents, with no alternative test available anywhere else in the country. Alaska and Hawaii instead qualify under a separate formula written into the same law, one pegged to the national rate rather than to a fixed percentage.
USDA’s implementation memo describes the standard as “unemployment rates 150 percent above the national unemployment rate,” language the agency’s own question-and-answer guidance restates more plainly as areas at 1.5 times the national average. Under either phrasing, an area in Alaska or Hawaii can qualify for a waiver at a lower unemployment rate than an equivalent area anywhere else, since the trigger moves with the national number instead of sitting fixed at 10 percent.
The distinction exists because the statute names the two states directly, in Section 10102(b) of the One Big Beautiful Bill Act, rather than leaving USDA to define a general geographic exception on its own. Neither the memo nor the Q&A document explains why Alaska and Hawaii specifically were written into that section rather than any other high-cost or geographically isolated state, and USDA has not published data showing how many areas in either state currently clear the 1.5-times threshold.
The 2028 date attached to two states: Alaska and Hawaii’s good-faith exemptions run only until December 31, 2028, and which of the state’s own routes applies before then is not something the federal memo tracks by household. See the state packs in The SNAP & Medicaid Renewal Organizer.
A second path that is not about unemployment at all
Section 10102(c) gives Alaska and Hawaii a separate option that does not depend on a jobs number. USDA’s implementation memo says a good-faith exemption is available if the state agency demonstrates it is making a genuine effort to comply with the ABAWD work requirement, even where it cannot yet enforce that requirement fully or accurately.
To get one, a state has to submit a description of the actions it has taken to administer the work requirement and time limit, an account of the significant barriers or challenges standing in the way, and a plan and timeline for reaching full and accurate implementation. The Q&A document frames the same tool slightly differently at the individual level, describing it as available when the state agency is making a good-faith effort to move a specific person into compliance with the work requirement rather than exempting an entire area’s unemployment status.
Either version of the exemption is temporary by design. USDA’s memo states plainly that “exemptions issued under this authority expire no later than December 31, 2028,” and neither document explains why that date, rather than an earlier or later one, marks the cutoff. What is clear is that the exemption buys Alaska or Hawaii time to build enforcement capacity, not a permanent alternative to the work-time limit itself.
What Alaska tells its own SNAP recipients
Alaska’s Department of Health describes the same law to residents in narrower terms than the federal memo does. Its own summary of the law’s impacts tells recipients that the state may request a temporary delay in putting the new rules in place if the state’s unemployment rate stays above a certain level and it can show progress toward meeting the new requirements, without naming the 1.5-times figure or the December 2028 cutoff spelled out in USDA’s own guidance.
The same state page lists exemptions that apply to individuals regardless of any area-wide waiver or good-faith exemption, including for Alaska Native or American Indian people, pregnant women, people medically unable to work, and adults who live with or care for a child under 14. Those are separate from Section 10102’s area-level and state-level tools; a person can fall under one of the individual exemptions even in an area with no waiver or good-faith exemption in effect at all, and an area’s waiver status has no bearing on whether an individual exemption applies to a given recipient.
Neither USDA nor the state has published how many Alaska or Hawaii recipients currently rely on the good-faith exemption rather than an area-wide waiver or one of the individual categories, and the federal memo sets no interim reporting requirement before the December 2028 deadline arrives. A recipient in either state is left checking three separate criteria rather than a single unemployment figure, and the plainest public description of any of them, Alaska’s own summary for residents, is also the one that names none of the specific numbers or dates USDA’s guidance spells out.
Two different safety valves, one state to track
Alaska and Hawaii have three separate ways a SNAP recipient there might avoid the work-time limit: an area-wide waiver at 1.5 times the national unemployment rate, a state-level good-faith exemption tied to enforcement capacity, and individual exemptions such as the ones Alaska lists for caregivers and people unable to work. Which one, if any, applies to a given household depends on details a federal memo does not track at the household level.
The SNAP & Medicaid Renewal Organizer includes a renewal document checklist and a renewal and reporting calendar for keeping that kind of state-specific status straight across a certification cycle.
Read the renewal document checklist 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.
