A 2025 federal law, Public Law 119-21, changed the rules for two big benefit programs: SNAP (food assistance, once called food stamps) and Medicaid (health coverage). Some changes already apply, others start in 2027. This guide explains them as of October 14, 2026, using the law's text and official agency pages. Rules vary by state and are still being put into practice, so treat it as a map, not an answer about your own case.
SNAP: who is affected now
The work rule applies to "able-bodied adults without dependents" (ABAWDs). Under the time limit, they can get SNAP for only 3 months in 3 years unless they work, join a work program, or both, for at least 80 hours a month (USDA). The 2025 law changed who counts, effective July 4, 2025 (USDA memo page).
- Ages 18 to 64. The limit used to stop at 54.
- Parents. The exception now covers only a parent or household member responsible for a child under 14 (it was 18).
- Removed. Veterans, people experiencing homelessness, and young adults who aged out of foster care are no longer exempt for that reason alone.
- Still exempt. People medically certified as unfit for work, pregnant women, and American Indians, Urban Indians and California Indians, plus people exempt from general SNAP work rules (Public Law 119-21, section 10102).
SNAP: immigrants and state costs
Federal law now lists these groups as eligible: U.S. citizens and nationals, green card holders, Cuban and Haitian entrants, and people lawfully living here under a Compact of Free Association. Refugees, asylees and some other groups are no longer eligible based on that status alone (section 10108). This is contested: states sued USDA over how it treated people who entered as refugees or asylees and later got a green card, and a federal court in Oregon ruled for the states on September 17, 2026 (Oregon DOJ case tracker). Ask your state SNAP office how it applies. Most adult green card holders still face the 5-year waiting period or other conditions that applied before the 2025 law (children and some others are exempt); the state office decides.
States face new costs too. From October 1, 2026, the federal share of state SNAP administrative costs falls from 50% to 25% (section 10106). From federal fiscal year 2028 (October 1, 2027), states with payment error rates of 6% or more pay 5%, 10% or 15% of benefit costs, rising with the error rate; some states with very high rates start later (section 10105). Your benefit amount does not change directly, but state budgets and processing may feel the pressure.
Medicaid: the work (community engagement) requirement
States must start by January 1, 2027, and may start earlier. It applies to adults 19 to 64 in the Medicaid expansion group who are not pregnant and do not have Medicare, in 43 states and Washington, D.C. (CMS fact sheet). CMS's rule is an interim final rule issued June 1, 2026, so details can still change (Federal Register).
- What counts. 80 hours a month of work, community service, a work program, or half-time school, alone or combined. Monthly income of at least $580 (the federal minimum wage times 80 hours) counts instead (section 71119).
- Who is exempt. Former foster youth, American Indians and Alaska Natives, parents or caregivers of a child 13 or younger or of a person with a disability, veterans rated totally disabled, people who are medically frail or have special medical needs, people in drug or alcohol treatment, people in jail or prison, pregnant and postpartum women, and people who meet certain TANF or SNAP work rules.
- Proof. Applicants must show at least one month of compliance before applying; enrollees are checked at renewal. If the state cannot verify it, you get a notice and 30 days to respond.
- Hardship and delays. States may excuse months with a hospital stay, a county disaster or high local unemployment, and can ask for more time by showing good-faith effort, but never beyond December 31, 2028.
Expansion adults must also renew every 6 months for renewals scheduled from January 1, 2027 (section 71107).
Key dates
| Date | What happens |
|---|---|
| July 4, 2025 | Law signed; SNAP time-limit and immigrant eligibility changes took effect |
| October 1, 2026 | Federal share of state SNAP administrative costs drops to 25% |
| January 1, 2027 | Latest start for the Medicaid work requirement; 6-month renewals begin for expansion adults (renewals scheduled from this date) |
| October 1, 2027 | States begin sharing SNAP benefit costs based on error rates (some later) |
| December 31, 2028 | Latest end of any state's Medicaid good-faith delay |
A simple self-check (not an eligibility decision)
Only your state agency decides eligibility. These questions help you prepare to talk to them.
- Are you 18 to 64, with no child under 14 in your care?
- Do you work or join a program 80 hours a month, or earn at least $580 a month?
- Might you be exempt (medical letter, pregnancy, tribal membership, caregiving)?
- Do you know your immigration category and what your state office says about it?
- On Medicaid at 19 to 64 in an expansion state: do you know your renewal date?
- Do you keep pay stubs or school records, and is your address current with the agency?
What to do
Find your state's SNAP office in the USDA SNAP state directory, and your state Medicaid office on Medicaid.gov. The USAGov Benefit Finder lists other programs. Open every agency letter, answer by its deadline, and ask for a fair hearing if you disagree with a decision (the notice explains how). To plan for a change, try the budget tracker or the 50/30/20 budget calculator.
Immigration and public charge
Under a Department of Homeland Security rule in effect since September 18, 2026, USCIS may consider means-tested benefits received on or after that date when it decides green card (adjustment of status) applications; some groups are exempt. We cannot answer that legal question. Read the USCIS public charge guidance and talk to a licensed immigration attorney or accredited representative before you sign up for, or drop, any benefit.
Frequently asked questions
Does the Medicaid work requirement apply to everyone on Medicaid?
No. It applies to expansion-group adults 19 to 64 who are not pregnant and do not have Medicare. Children, people 65 and older, and exempt groups are not required to meet it.
What counts toward the 80 hours?
Work, community service, a work program or half-time school, in any combination, or monthly income of at least $580. Keep records; states verify at application and renewal.
I have a green card. Can I still get SNAP?
Green card holders are a listed eligible group, but income rules still apply, most adult green card holders still face the 5-year waiting period or other conditions that applied before the 2025 law (children and some others are exempt), and the treatment of people who entered as refugees or asylees is being decided in court. Ask your state SNAP office. For how benefits can affect a green card application, see the public charge section above.
This is general information, not legal, immigration, tax or benefits advice. Rules vary by state and are changing; check your state agency and the official sources above. Information as of October 14, 2026.
Written by the CentDaily editorial team with AI assistance; facts checked against the official sources listed in this guide and in the Sources box below. General information, not legal, tax or financial advice.