USDA’s SNAP work-requirement page still tells food stamp recipients that the three-month time limit applies to adults ages 18 to 54, even though the law signed on July 4, 2025 raised the top age to 64. The page carries a July 16, 2026 update date and says the Department of Agriculture is still working on guidance about how that law changes the rules. The agency’s written instructions to state offices went out more than a year ago. For an adult in the late 50s or early 60s with no children at home, the gap between the public page and those instructions can decide whether SNAP stops after three months.
What USDA’s public work-rule page lists
The Food and Nutrition Service, the USDA agency that runs SNAP, describes the rule for what it calls able-bodied adults without dependents. A person who is 18 to 54, able to work and has no dependents must work at least 80 hours a month, take part in a work program, combine the two or do workfare for the assigned hours. Without that, SNAP lasts no more than three months in three years, and benefits can be regained by meeting the rule for a 30-day period or becoming excused. Among those excused, the page lists people unable to work because of a physical or mental limitation, pregnant people, households with someone under 18, veterans, people experiencing homelessness and people 24 or younger who were in foster care on their 18th birthday.
The same work-requirements page carries the notice about the new law. It says, “We are in the process of providing guidance on how” the One Big Beautiful Bill Act of 2025 changes the work rules for these adults, including the exception and waiver criteria, and that USDA will update the page once the guidance is released. On October 15 the page still showed the 18-to-54 range, the under-18 household exception and all three of the excused groups above. It points readers to a separate USDA page for the law.
USDA told states something different in writing. A memo dated October 3, 2025, signed by Ronald Ward, acting associate administrator of SNAP at the Food and Nutrition Service, says individuals aged 18 to 64 are now subject to the time limit, unless they meet another exception. The memo says the changes took effect on enactment, July 4, 2025, and that state agencies must apply the modified criteria immediately. Adults ages 55 to 64 with no dependents are therefore inside the three-month limit under USDA’s instructions to states, and each of them needs to know which exception, if any, a state office will honor.
Adults 55 to 64 are the group the public page’s 18-to-54 range leaves out, and the memo puts them under the three-month limit. The SNAP & Medicaid Renewal Organizer lays out the SNAP work-rule time limit and who is exempt, with 51 state packs for the dates each state sets.
Look up who is exempt from SNAP’s three-month limit in the SNAP & Medicaid Renewal Organizer →
The memo also changes who counts as excused. It says the caregiver exception now covers only children under 14, down from under 18. It removes the temporary exceptions for homeless people, veterans and adults 24 or younger who were in foster care on their 18th birthday. It adds exceptions for a person who is an Indian, an Urban Indian or a California Indian, as those terms are defined in the Indian Health Care Improvement Act. Three of the groups the public page still lists as excused are the ones the memo says no longer qualify, and the page’s household-with-someone-under-18 exception becomes a child-under-14 exception in the memo.
How state offices are applying the limit
States are already counting months. Illinois Department of Human Services Secretary Dulce M. Quintero signed a January 15, 2026 information memo saying the start of the SNAP work requirement moved to February 1, 2026, because of a court ruling. February 2026 is the first month that counts toward the three-month limit in Illinois. The memo says countable months before then, including December 2025 and January 2026, will be removed, and affected households will receive a notice. The memo does not spell out the age range, so a household learns where it falls from the state’s notice or a caseworker.
USDA’s own One Big Beautiful Bill implementation page shows that the federal guidance exists in pieces. Updated June 11, 2026, it lists the exceptions memo, a memo on waivers, questions and answers on time-limit changes and a note on quality-control variance exclusion, all under Section 10102, the part of the law on SNAP work requirements. It says USDA will keep adding implementation resources. The work-requirements page has not been updated to carry those details, and USDA’s notice says only that the page will change once the remaining guidance is out.
Where the unemployment waivers fit
A time limit does not apply everywhere. USDA’s time-limit waiver page, updated October 5, 2026, says states can request temporary waivers for areas where unemployment is above 10 percent, and that Alaska and Hawaii can ask for areas where it is 1.5 times the national average. A waiver suspends the three-month limit for the area, so adults there can stay on SNAP without meeting the 80-hour test. The page links to waiver status tables by state, the latest covering the first quarter of fiscal 2027.
The waiver page does not mention the 2025 law, and the work-requirements page says waiver criteria are part of the guidance still being written. Two USDA pages updated 11 weeks apart, on July 16 and October 5, therefore describe different parts of the same rule without saying how they fit together. For a household, the questions are local: whether the county sits in a waived area, whether the member’s age and family make-up fit an exception, and which month the state began counting.
Confirming age and exceptions with the state SNAP office
The state SNAP notice is the first document to read, because it names the month counting began, the hours required and any exception on file. USDA’s work-requirement policy resources page says the 2025 law changed who must follow the time limit as of July 4, 2025, and that federal materials published before that date “may be out of date.” That includes the 18-to-54 language that appears on the public page.
For an adult between 55 and 64, the exceptions the memo leaves in place decide the outcome: a physical or mental limitation that prevents work, pregnancy, a child under 14 in the household, or membership in one of the Indian categories the memo adds. A veteran, a person without a home or a former foster youth 24 or younger who relied on the older list is the person most likely to find a notice that no longer matches what USDA’s website says.
Ronald Ward’s October 3, 2025 memo, not the 18-to-54 range on USDA’s website, is the clearest federal statement of who is under the limit, and it says the change dates from July 4, 2025. USDA has said it will revise the work-requirements page when the guidance is released, which leaves a state’s own notice as the document that fixes any one household’s months.
The age line moved from 54 to 64
The detail that gets missed is that three exceptions still printed on USDA’s public page, for veterans, homeless adults and former foster youth, no longer apply under the October 2025 memo. The SNAP & Medicaid Renewal Organizer covers the SNAP work-rule time limit and who is exempt, and its 51 state packs carry each state’s renewal and reporting dates.
Get the work-rule time limit and exempt groups for ages 55 to 64 in the Renewal Organizer →
This article was prepared with AI assistance from cited public sources and reviewed before publication.
