SNAP and Medicaid work requirements, side by side

Able-bodied adults without dependents, ages 18 to 64.1

H.R. 1 widened the band from 18–54 and removed the veteran, homeless, and former-foster-youth exemptions.1△ statute governs

Unchanged. §10102 does not rewrite SNAP’s activity list or hour rules — those remain in pre-existing 7 U.S.C. 2015(o)(1)–(2).8 This section touches only exceptions, waiver triggers, and noncontiguous handling.

• Paid work
• Work program
• Workfare

Defined at 273.24(a)(1)2.

Yes — in the regulation rather than in §10102.

7 CFR 273.24(a)(1)(iii) allows any combination of work and work-program participation totalling 20 hours.2

And (a)(2) defines working itself as three things that also combine, per (a)(2)(iv): work for money, work for goods or services (“in kind”), and unpaid work, verified under standards established by the State agency.2

Volunteer hours already count here, and Hawaiʻi Department of Human Services (DHS) sets what proof looks like.

Yes, but as an exemption rather than a way to count hours.

Federal minimum wage × 30 hours. A person employed or self-employed at 30+ hours a week, or earning that much regardless of hours, is exempt from SNAP work requirements 7 CFR 273.7(b)(1)(vii).3

That exemption reaches the time limit too: 273.24(c)(5) excepts anyone otherwise exempt under 273.7(b).2

Do not set this against Medicaid’s $580 as if they were the same test: this one is a weekly wage test on the individual, and it removes the requirement instead of satisfying it. The regulation states the SNAP figure weekly and gives no monthly equivalent — converting it invites exactly that false comparison.

• Under 18, or over 65 — a person who is exactly 65 is still subject
• Medically certified unfit for employment
• Parent or household member responsible for a dependent child under 14
• Otherwise exempt under subsection (d)(2)
• Pregnant
• Indian or Urban Indian; California Indian

§6(o)(3) — seven subparagraphs, as amended (Indian/Urban Indian and California Indian are separate subparagraphs, listed together above).1△ statute governs

Data the State already holds, first. Where an exception is questionable the agency must try its own records and other public-assistance data sharing before asking the person for documents 7 CFR 273.24(l)2 — the same instinct as Medicaid’s ex parte rule.

Hours are verified under 273.2(f)(1) and (f)(8) 273.24(a)(6).4 A drop below 20 hours is a reportable change 273.12(a)(1)(viii).5

For unpaid work the regulation names no format: it is verified “under standards established by the State agency” 273.24(a)(2)(iii).2 Like Medicaid, the question of what a volunteer-hour record must look like is decided below the statute — here by the State, not HHS.

Three months of benefits within a 36-month window, then the time limit applies.

The current window closes 2026-09-30; the next begins 2026-10-01.

There is a way back. Someone denied eligibility “shall regain eligibility … if, during a 30-day period, the individual works 80 or more hours” or completes 80 hours in a work program.8 The 36 months is the window the three-month limit is measured across, not a bar on reapplying.2 Told as a lockout, it persuades people not to try.

Two geographic paths.

A waiver the State may request where unemployment is at or above 1.5× the national rate §6(o)(4)(A)(ii). The Secretary may grant it on the request of the State agency; nothing triggers automatically.

Plus a noncontiguous-state good-faith exemption on petition to United States Department of Agriculture (USDA) §6(o)(7). Hawaiʻi and Alaska qualify; Guam and the USVI are excluded. Sunsets 2028-12-31, non-renewable.1