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A USDA waiver exempting food stamp recipients in Detroit, Flint and Saginaw from the three-month time limit expires October 31

A USDA waiver that exempts food stamp recipients in Detroit, Flint and Saginaw from the three-month time limit expires October 31, 2026. The Food and Nutrition Service approved it on November 20, 2025 for six Michigan cities: Detroit, Flint, Saginaw, Jackson, Bay City and Eastpointe. When it ends, the limit that allows only three months of benefits in three years can apply there again.

What the October 31 date ends

The date marks the end of an exemption, not the start of a benefit. Food stamps, formally the Supplemental Nutrition Assistance Program or SNAP, normally limit adults who are not working or in a work program to three months of benefits in a three-year period. The waiver response suspended that limit in the listed places for a year, effective November 1, 2025.

Ronald Ward, acting associate administrator for SNAP at USDA’s Food and Nutrition Service, signed the approval letter to Shelly Walker, Michigan’s SNAP state administrator. Michigan had asked for November 3, 2025 through November 2, 2026. USDA approved November 1 through October 31 instead.

The waived rule is Section 6(o) of the Food and Nutrition Act of 2008, carried out through 7 CFR 273.24. USDA’s letter says Michigan’s request met the approval requirements at 7 CFR 273.24(f), the provision that allows an unemployment-based waiver. The letter lists the request as initial, so any extension would be a new filing.

The limit reaches a specific group, called able-bodied adults without dependents. USDA’s eligibility page says they must work or take part in a work program at least 20 hours a week to get benefits for more than 3 months in a 36-month period. The waiver document states the same test as 80 hours a month.

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Not everyone in a covered city is subject to the limit. The eligibility page lists groups that may not be subject to the work requirements, including children, seniors, veterans, pregnant women, people experiencing homelessness and people exempt for physical or mental health reasons. It adds that the page is being updated for changes in the 2025 One Big Beautiful Bill Act.

Six cities cleared the 10 percent unemployment bar

The waiver rests on the federal standard of an unemployment rate above 10 percent. USDA’s table gives Flint the highest rate at 14.3 percent. Saginaw is at 11.8, Eastpointe 11.4, Detroit 10.9, Jackson 10.5 and Bay City 10.1.

USDA’s first data period is the 12-month average from September 2024 to August 2025. Bay City is also named under a February-to-April 2025 three-month average, and Detroit under a January-to-March 2025 average. Those are the data windows USDA accepted.

Flint’s 14.3 percent is the highest of the six and well above the 10 percent line. Bay City, at 10.1 percent, clears it by a tenth of a point. That margin matters because a renewal request has to show unemployment still above 10 percent, with data attached.

The cities are only part of the document. The same waiver covers 15 counties and eight tribal reservation areas, all under the same October 31 expiration. A recipient outside the six named cities may still be in a covered place.

What happens when the waiver lapses

USDA’s document does not say whether Michigan has asked for a renewal. It says any extension or replacement waiver needs a formal request with supporting data, including spreadsheets for requests based on unemployment. No replacement is mentioned.

The approval also requires Michigan to keep measuring the three-year period and tracking these adults continuously. The reason given is that the state must be able to reinstate the time limit when the waiver ends.

Adults can meet the requirement with a work program of at least 80 hours a month, the document says. It encourages the state to connect participants to FAE&T, the employment and training program named in the letter. Meeting that bar keeps benefits going past three months.

Income is a separate test from the time limit. For fiscal 2027, which began October 1, USDA’s benefit tables put the gross monthly income limit for a one-person household at $1,729 and the net limit at $1,330. A person under those limits can still lose benefits to the time limit.

Those income limits are set at 130 percent of the poverty level for gross income and 100 percent for net income. A household can sit well under both and still reach the end of the three-month count. The work test, not the income test, is what the expiring waiver suspended.

Questions to settle before November 1

The answer for any one recipient depends on three facts. Is the person an able-bodied adult without dependents, does an exemption category apply, and do work hours reach 80 a month? The state’s records, which USDA requires it to keep, decide the rest.

USDA’s SNAP site links to a state directory for finding Michigan’s office. Until a replacement waiver is posted or announced, October 31 is the date printed on the approval.

Will a Detroit recipient still be exempt after October 31?

Michigan has to keep tracking these adults so it can bring the limit back, which leaves little room to sort out an exemption after the fact. A recipient in Detroit, Flint or Saginaw who does not know which category applies could face the three-month cutoff.

The SNAP & Medicaid Renewal Organizer covers the SNAP work-rule time limit and who is exempt, with 51 state packs and a renewal and reporting calendar. Its Part 4 is titled The 2025 Work-Rule Change, the rule behind this expiry.

Get the SNAP time-limit exemption guide and renewal calendar →


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This article was produced with AI assistance and edited for accuracy against the sources linked above.

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Daniel Harper

Daniel is a finance writer covering personal finance topics including budgeting, credit, and beginner investing. He began his career contributing to his Substack, where he covered consumer finance trends and practical money topics for everyday readers. Since then, he has written for a range of personal finance blogs and fintech platforms, focusing on clear, straightforward content that helps readers make more informed financial decisions.​