States must warn everyone aged 55 to 64 that food stamps now stop after three months without work

Image Credit: USDAgov - CC BY 2.0/Wiki Commons

The age band of adults subject to the food-stamp work-time limit jumped by a decade under a 2025 law, and USDA is now requiring every state to tell the newly covered group directly. Individuals aged 55 to 64 who once sat safely above the cutoff are, as of the law’s enactment, subject to the same three-month time limit that has applied to younger able-bodied adults for years. A U.S. Department of Agriculture memorandum instructs state agencies that this is not optional background knowledge for caseworkers: it must be put in writing and explained out loud to every household affected. For someone in their late fifties or early sixties who assumed the age exemption still protected them, the notice requirement is the mechanism meant to prevent that assumption from costing them benefits.

Why the Age Cutoff Jumped by a Decade

Before the One Big Beautiful Bill Act, individuals aged 18 to 54 were subject to the Able-Bodied Adults Without Dependents time limit, a ceiling that had itself been rising gradually from 49 under a 2023 law. The 2025 law reset that trajectory in one step rather than continuing a phase-in: it raised the upper age to 64, meaning anyone 18 through 64 is now covered unless another exception applies.

USDA’s implementation memorandum states the change without qualification: “The OBBB increases the age of those subject to the time limit to age 64. Therefore, individuals aged 18 to 64 are now subject to the time limit,” according to the agency’s October 2025 guidance. The memo is explicit that this is a different provision from the general work requirements that separately exempt people 60 and older, a distinction addressed later in the same document.


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The Notice States Are Required to Send

USDA did not leave the noticing duty to state discretion. The memo instructs that “State agencies must update their notices to ensure individuals aged 55 to 64 are properly notified that they are now subject to the ABAWD time limit,” on top of the consolidated written notice and oral explanation already required for every work registrant. The instruction targets the 55-to-64 band specifically because that group crossed from being categorically exempt to being covered in a single step, unlike younger age bands that had already absorbed years of gradual increases and prior notices.

A household that has not received an updated notice is not automatically excused from the time limit; the requirement obligates the state agency to notify, but the time limit itself took effect the day the law was signed, regardless of when any individual notice goes out.

What Happens After Three Months Without 80 Hours

The consequence behind the notice is unchanged from the rule that has applied to younger adults for years: someone covered by the time limit can receive benefits for only three months within a three-year period unless working, training or volunteering at least 80 hours a month, according to USDA’s Food and Nutrition Administration. Participating in an approved work program, or a combination of paid work and program hours, satisfies the same threshold. Missing it means benefits stop until the requirement is met for 30 days or the three-year clock resets.

Who in This Age Band Might Still Be Excused

Reaching 55 does not by itself remove every path to an exception. A person in this age range who is pregnant, has a documented physical or mental limitation, or is caring for a child under 14 in the household still qualifies for a separate exception. The same 2025 law eliminated exceptions that had covered veterans, people experiencing homelessness and young adults aging out of foster care, so a 58-year-old veteran can no longer rely on veteran status alone the way an earlier version of the rule allowed.

Turning 60 changes the calculation again, though not by removing the time limit. Once someone in this band reaches 60, a state agency can no longer require them to participate in mandatory Employment and Training, even though the time limit itself still applies through age 64. That distinction, drawn from a separate section of the same law, means a 61-year-old faces the three-month clock but cannot be compelled into a training program as the way to meet it, while a 56-year-old faces the identical clock with no such protection from mandatory training.

The Deadline Behind the Notice Requirement

USDA gave state agencies a limited grace period to get the notice right, not an indefinite one. A 120-day quality-control variance covering the noticing change and the age increase closed November 1, 2025, meaning state agencies are now expected to have updated notice language in place for every application and recertification. The memorandum, signed by Ronald Ward, USDA’s acting associate administrator for the food-stamp program, remains the agency’s live guidance on the requirement, and the page hosting it shows no update since February 25, 2026 that would suggest the notice duty has changed.

This article was produced with the assistance of AI and reviewed by The Financial Wire editorial team.

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