Veterans, people experiencing homelessness and young adults aging out of foster care have lost a food-stamp protection that Congress wrote into law just two years earlier. A U.S. Department of Agriculture memorandum confirms that the One Big Beautiful Bill Act, signed July 4, 2025, struck out three exceptions the Fiscal Responsibility Act of 2023 had carved into the Supplemental Nutrition Assistance Program’s work-time limit. State SNAP agencies were ordered to apply the change immediately upon enactment, and the memo remains the agency’s live guidance today. For older readers who served in the military, are sheltering a homeless relative, or are raising a grandchild about to age out of foster care, the change decides whether SNAP benefits keep flowing after just a few months without documented work hours.
The Three FRA-2023 Exceptions Congress Wrote In
The Fiscal Responsibility Act of 2023 amended Section 6(o)(3) of the Food and Nutrition Act to add three temporary exceptions to the SNAP work-time limit for able-bodied adults without dependents, according to USDA’s implementation memorandum on the change. Those exceptions covered homeless individuals, veterans, and individuals aged 24 or younger who were in foster care on their 18th birthday, or a higher age in states that offered extended foster care. The same 2023 law also began raising the age at which adults face the time limit, moving it from 49 to 54 gradually through fiscal year 2030.
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USDA’s October 2025 Memo Ends Them
The One Big Beautiful Bill Act, which President Trump signed on July 4, 2025, rewrote that FRA-2023 language through Section 10102(a). USDA’s Food and Nutrition Service first described the change in a September 5, 2025 information memorandum, then issued a more detailed implementation memo on October 3, 2025 spelling out exactly what disappeared. Its language is direct: the law “removes the temporary exceptions for the following populations, which were added by the Fiscal Responsibility Act of 2023.” Once removed, the memo states, “these individuals are once again subject to the time limit, as they were prior to the 2023 FRA, unless they meet another exception.” The change took effect on enactment, and state agencies were told to apply it to all initial and recertification applications right away.
Homeless SNAP Recipients Return to the Work-Hours Clock
For people experiencing homelessness, the practical effect is that a caseworker screening a SNAP application can no longer check a box that exempted them from the time limit. Unless a homeless applicant separately qualifies through another category, such as caring for a child under 14 or a documented disability, the clock the 2023 exception had paused starts running again: adults without dependents can draw SNAP for only three countable months in a rolling 36-month period without 80 hours of monthly work, training or workfare activity, per USDA’s ABAWD policy guidance. The October memo places the burden on state agencies, not on the recipient, to identify who no longer qualifies under the old exception and reclassify them under what the agency calls the “modified exception criteria.”
Veterans Face the Same Three-Month Limit They Had Before 2023
The 2023 exception for veterans applied regardless of discharge status, era of service or disability rating, so long as the individual identified as a veteran to the SNAP agency. That blanket exception disappeared along with the other two FRA-2023 exceptions the OBBB struck. A veteran now qualifies for a pass on the time limit only by meeting one of the law’s other remaining categories, the same standard that applies to any other applicant. Absent one of those categories, a veteran who cannot document qualifying work hours returns to the same pre-2023 three-month standard the USDA memo describes.
Former Foster Youth Lose Their Exception as a New Category Arrives
The third population affected is young adults aged 24 or younger who were in foster care on their 18th birthday, or later if a state’s extended foster care program covered them past that age. Like the homeless and veteran exceptions, this carve-out was added by the 2023 law and removed by the OBBB’s Section 10102(a), effective the same July 4, 2025 date. USDA’s memo pairs the removal with something new: exceptions added for enrolled members of federally recognized tribes, “Urban Indians” and “California Indians” as defined under the Indian Health Care Improvement Act. The agency, renamed the Food and Nutrition Administration on June 1, 2026, still lists the October 2025 memo as its live implementation guidance on the exceptions change, with that page last updated February 25, 2026. Grandparents and other relatives who took in a grandchild after that child aged out of the foster system, and who may themselves be applying for SNAP as older adults, are affected the same way: the exception that once covered the young adult in their household is gone unless another category applies.
What USDA Told State Agencies to Do Next
USDA gave state SNAP agencies a limited grace period rather than an open-ended one. A 120-day quality-control variance exclusion covered agencies that misapplied the new exception criteria, but that exclusion period ended November 1, 2025, meaning agencies are now expected to apply the rule correctly on every application. The memo instructs agencies to update their written and oral notices so households understand which work requirements now apply to them, and to keep following the same federal verification rules, at 7 CFR 273.2(f) and 273.24(l), that applied before the 2023 exceptions existed. The memo is signed by Ronald Ward, USDA’s acting associate administrator for SNAP, and remains posted on the department’s One Big Beautiful Bill Act implementation page, updated as recently as June 11, 2026.
This article was produced with the assistance of AI and reviewed by The Financial Wire editorial team.
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David M. Keller is a finance writer based in Columbus, Ohio, covering personal finance and consumer-focused economic topics. He earned his degree in journalism from Ohio University and began his career reporting on local business and economic trends for a regional media outlet. Since then, he has contributed to a variety of online publications, focusing on clear, practical coverage of topics such as cost of living, debt, and everyday financial decision-making.
