A federal law signed a little over a year ago has quietly pulled more than a million older Americans into a work-hours test that never used to apply to them. Adults age 55 through 64 who receive Supplemental Nutrition Assistance Program benefits are now subject to the same 80-hour-a-month work rule long faced only by younger recipients, and the accounting period that determines who has already run out of time closes at the end of September.
The One Big Beautiful Bill Act Raised SNAP’s Work-Rule Age Ceiling
The One Big Beautiful Bill Act, also known as H.R. 1, was signed into law on July 4, 2025, and it rewrote eligibility rules for the SNAP category known as Able-Bodied Adults Without Dependents, or ABAWD. Before the law took effect, the ABAWD work-hours requirement applied only to adults age 18 through 54. The new law raised that ceiling to 64, meaning adults age 55 through 64 who were previously excused from the requirement solely because of their age are now covered unless another exemption applies.
The change did not arrive with a grace period. The U.S. Department of Agriculture’s Food and Nutrition Service says the requirement applies from the date of enactment, and the agency’s implementation guidance for states set November 1, 2025, as the date it would begin holding state SNAP agencies accountable for errors in applying the expanded age band during its quality-control reviews. That date effectively marked when the new rule moved from a paper change to active enforcement in caseloads nationwide, according to the Food and Nutrition Service’s work-requirements guidance.
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Why September 30 Is the First Real Deadline
SNAP does not track ABAWD compliance month to month in isolation; it tracks it in fixed 36-month blocks. The current nationwide ABAWD accounting period runs from October 1, 2023, through September 30, 2026, and a new three-year period opens the next day. A non-exempt adult who does not document at least 80 hours a month of work, qualifying job training, or approved volunteer service can receive only three countable months of benefits within that 36-month window before the time limit cuts off further payments.
Because states were told to begin applying the 55-to-64 age expansion in caseloads no later than early November 2025, adults newly swept into the ABAWD category who did not immediately meet the work test started using up their three countable months last fall and winter. September 30 is the date the current accounting period closes, which is why it functions as the first hard deadline for this age group: anyone in that band who has already exhausted the three countable months without meeting the requirement loses benefits as the period ends, rather than being carried into the next three-year cycle, according to USDA’s implementation memorandum summarized by the National Association of Counties.
The Three-Month Limit and How to Reset It
The underlying mechanic predates the age expansion and has not changed: a covered adult who fails to meet the 80-hour standard can receive a maximum of three months of SNAP benefits in a 36-month period. Once those three countable months are used, benefits stop until the next accounting cycle begins or until the recipient documents at least 80 hours of qualifying activity within a 30-day span, which restores eligibility going forward. Paid work, unpaid work for goods or services, approved volunteer positions, and participation in a SNAP Employment and Training program all count toward the 80-hour threshold.
Exemptions still apply regardless of age. Adults who are physically or mentally unable to work, pregnant, caring for a child under 14, already working close to full time, or receiving unemployment compensation, among other categories, are excused from the time limit. Adults age 55 to 64 who believe an exemption applies to them should confirm that status with their state SNAP agency directly rather than assume it carries over automatically, since the expanded age band removed the blanket age-based exemption that many in this group previously relied on.
What a State SNAP Case File Shows Right Now
Caseworkers determine countable months from the record already on file, not from a recipient’s own estimate of hours worked. A person who has picked up part-time work, started a training program, or begun volunteering since last fall should verify that the hours were actually logged and credited in the case file well before September 30, since a documentation gap, not a lack of hours, is often what triggers a cutoff. State SNAP offices and connected advocacy resources can walk an applicant through which activities qualify and how to submit proof before the deadline. The AARP’s guidance on meeting SNAP work requirements outlines the documentation states typically accept, including pay stubs, timesheets from volunteer coordinators, and enrollment records from approved training programs.
For adults nearing or past their three countable months, the practical path back onto benefits is the same 80-hours-in-30-days rule that applies to any ABAWD case: once a state confirms the hours, coverage resumes the following month rather than requiring a fresh application from scratch.
This article was produced with AI assistance 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.
