Adults who live on six Wisconsin tribal reservations will not lose FoodShare, the state’s name for SNAP, for missing the work requirement through September 30, 2027, after USDA approved a waiver of the three-month time limit. The approval letter is dated August 24, and the waiver took effect October 1. Everywhere else in Wisconsin, adults 18 to 64 without a young child at home still face the limit.
The six reservations and their jobless rates
USDA’s approval letter covers six areas, each with a 12-month unemployment rate above the 10% bar: the Forest County Potawatomi Community at 18.5%, the Red Cliff Reservation at 15.5%, the Ho-Chunk Nation at 14.8%, the Sokaogon Chippewa Community at 12.6%, the St. Croix Reservation at 11.2% and the Lac du Flambeau Reservation at 10.3%.
The rates cover June 2025 through May 2026. Ronald Ward, acting associate administrator for SNAP, signed the letter, and it was addressed to Autumn Arnold, who directs the Bureau of Eligibility and Enrollment Policy at Wisconsin’s Department of Health Services. The waiver runs October 1, 2026, to September 30, 2027.
Federal law now sets a high bar. A waiver may be granted only where unemployment is over 10%, the letter says, citing the Food and Nutrition Act. USDA’s waiver page adds that a time limit waiver does not waive the general SNAP work requirements, so the rest of the program’s rules still apply to people in these areas.
The list matters most for adults living inside those boundaries who are not tribal members. Tribal members are already exempt from the FoodShare work requirement, the state says, so the waiver extends the same protection to their non-member neighbors.
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Six more areas on the state’s list
Wisconsin’s Division of Medicaid Services went further in an operations memo dated September 16. It lists a second group of six tribal areas where the time limit is suspended under what it calls additional federal flexibilities: Bad River, Fond du Lac, Lac Courte Oreilles, Menominee, Oneida and Stockbridge-Munsee.
The USDA letter covers only the first six areas, so the second group rests on the state’s memo. In both groups the memo says adults living there will not lose FoodShare for missing the work requirement while the suspension lasts, which it dates from October 1, 2026, through September 30, 2027.
Caseworkers still have a job in the suspended areas. The memo tells them to keep screening every applicant and member aged 18 to 64 for exemptions at application and renewal, including people who live in a qualifying reservation area.
Native Americans have a separate exemption. The memo says tribal members, Urban Indians and California Indians remain exempt from the work requirement, whether or not their area appears on a suspension list. For them the lists change nothing; for non-member adults living in the areas, they decide whether the clock runs.
What the time limit means everywhere else
Outside those areas, the state’s FoodShare work page spells out the rule. It applies to members 18 to 64 with no child 13 or under living at home, and it requires 80 hours a month of work, volunteering or an approved training program, or any combination of the three.
Miss the requirement without an exemption and benefits stop after three months in a three-year period. The current period runs from January 2025 through December 2027, the Department of Health Services says.
Exemptions are broad. They include being pregnant, being unable to work for physical or mental health reasons, living with a child 13 or younger, caring for a child under 6 who lives elsewhere or for someone who cannot care for themselves, receiving or applying for unemployment compensation, attending school at least half-time, and tribal membership.
Benefits can restart. A member who loses FoodShare can regain it by meeting the requirement for 30 days, showing the requirement will be met within 30 days, having an exemption, or showing good cause for missed hours, such as illness, bad weather or a lack of transportation.
Where the reservation waiver ends
The reservation waiver is not permanent. USDA’s page lists the August 24 letter as Wisconsin’s most recent response, and the waiver expires September 30, 2027. The letter also requires the state to keep tracking the three-year period for time-limited participants during the waiver, so the limit can be reinstated when it ends.
Residence decides coverage. The state’s memo applies the suspension to members living in the listed areas, and the letter describes areas by reservation and, for most, off-reservation trust land. A Wisconsin adult 18 to 64 whose address falls outside those lines is under the three-in-36 clock.
Renewal of the waiver will turn on the same test. USDA approved these areas because unemployment ran above 10% over the 12 months ending in May 2026, and a request for a later year would have to show the same thing for a new 12-month window.
The open question for adults on and near these reservations is which list their address is on and what happens on October 1, 2027, if the rates fall.
Living on one of the six reservations?
A Wisconsin adult who is not on a waived reservation and not exempt loses FoodShare after three months of missed work hours within a three-year period that runs through December 2027.
The SNAP & Medicaid Renewal Organizer includes the SNAP work-rule time limit and who is exempt, plus a renewal document checklist, a renewal and reporting calendar and a state pack for each of the 51 states, so exemptions and dates sit in one place.
Track the SNAP time limit and exemptions with this renewal organizer →
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This article was produced with AI assistance and edited for accuracy against the sources linked above.
