A 2025 law pulled 60-to-64-year-olds into the food-stamp work-time limit for the first time in years, then stopped states from treating them like every other adult now subject to it. State agencies are barred from requiring anyone in that five-year age band to participate in mandatory job training, even though the same rule change makes that group’s benefits contingent on meeting a work standard. The tension is written directly into a U.S. Department of Agriculture memorandum implementing the law, and it turns on a distinction between two separate sets of SNAP work rules that apply different ages to different requirements.
Two Different Rules, Two Different Age Tests
The Supplemental Nutrition Assistance Program runs two work-rule systems side by side. General work requirements, set out in Section 6(d)(3) of the Food and Nutrition Act, apply a broader standard: registering for work, accepting a suitable job and not voluntarily quitting one, with an exemption for anyone 60 or older. Separately, the Able-Bodied Adults Without Dependents time limit, at Section 6(o)(3), caps benefits at three months in three years for a narrower group unless they meet a work threshold.
The One Big Beautiful Bill Act raised the ABAWD time-limit age ceiling to 64, but left the general work-requirement exemption for people 60 and older untouched. According to USDA’s implementation memorandum, “the OBBB does not change the upper age limit for the general work requirements at Section 6(d)(3) of the Act. Individuals aged 60 or older remain exempt from the general work requirements, including mandatory participation in SNAP Employment and Training.” The result is a five-year band, ages 60 through 64, governed by two rules that point in different directions at once: one treats the group as fully covered by the time limit, and the other treats the same group as too old to compel into mandatory training. Both readings come from the same memorandum and are meant to be applied simultaneously, not as competing interpretations a caseworker must choose between.
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Why Mandatory Employment and Training Doesn’t Apply
Because people 60 and older stay exempt from the general work requirements, and because SNAP Employment and Training participation falls under those general requirements, USDA’s memo draws the line explicitly: “State agencies are prohibited from requiring individuals aged 60 through 64 to participate in E&T (mandatory E&T).” A caseworker screening a 62-year-old applicant can still refer that person to a voluntary work program, but cannot make participation in mandatory E&T a condition of keeping benefits, the way it can for a 45-year-old covered by the same general requirements.
Elderly Status Still Protects Other Benefits
The age-64 change to the time limit did not touch a separate, older line in the law: SNAP’s definition of “elderly,” which stays fixed at 60 and older. Individuals in that group keep access to the excess medical expense deduction and face no cap on the shelter deduction, benefits calculations that can matter as much to a household’s monthly allotment as the work rules themselves. USDA’s memo notes that state agencies “must continue to apply other policies for elderly individuals to those aged 60 or older,” meaning a 63-year-old subject to the new time limit does not lose the deduction protections tied to elderly status.
The Same Group Still Faces the Time Limit
The E&T prohibition is not a broader exemption from the time limit itself. A 61-year-old who cannot document 80 hours a month of work, training or volunteering still loses benefits after three months in a three-year period, exactly like a younger adult covered by the same provision, according to USDA’s Food and Nutrition Administration. The only difference is that a state cannot compel that 61-year-old into a mandatory training program as the way to meet the hours; the person must find qualifying work, a voluntary program or another exception on their own.
A voluntary work program remains available even where mandatory E&T does not. A state agency can still offer, and a 60-to-64-year-old can still choose, to enroll in Employment and Training on a voluntary basis, and hours completed that way count toward the 80-hour monthly threshold the same as paid work would. The prohibition is narrower than it might first appear: it bars compulsion, not access.
A Rule Implemented Without a Phase-In
USDA’s memorandum, signed October 3, 2025 by Ronald Ward, the agency’s acting associate administrator for the food-stamp program, states the changes took effect “upon enactment, July 4, 2025,” with no transition period for the 60-to-64 group caught between the two rules. A 120-day quality-control variance tied to the broader age increase closed November 1, 2025. The USDA page hosting the memo lists a last update of February 25, 2026, with the E&T prohibition for this age band still standing as written.
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.
