Recent proposals to expand the work requirement in the Supplemental Nutrition Assistance Program (SNAP) have been almost universally portrayed as a punitive effort to push low-income recipients off the program. Indeed, the Congressional Budget Office (CBO) estimated that over 3 million people will leave SNAP due to the work requirement expansions. However, it is important to understand that there are many possible reasons for these estimated reductions in the caseload.

The CBO estimated that the House-passed bill would reduce overall SNAP spending by $285.7 billion over the 2025-2034 period or $28.6 billion per year. Approximately 30 percent of the SNAP’s spending cuts result from changes to SNAP’s work requirements, according to the CBO. Currently, able-bodied adults age 18-54 without dependents (ABAWDs) can only receive SNAP for three months in a three-year period unless they work, volunteer, or participate in a work program for 80 hours per month. States can waive this requirement when local labor market conditions are unfavorable.

The House-passed reconciliation bill makes three key changes to these work requirements: (1) it increases the age that defines an able-bodied adult subject to SNAP’s work requirement to age 64 (from 54), (2) it expands the work requirement to able-bodied parents whose youngest child is age 7 or older (currently parents are exempt), and (3) it narrows the criteria by which states can waive the work requirement. CBO estimates that these provisions alone will reduce spending by $94.3 billion over the 10-year period.

Notably, the Senate Agriculture Committee’s version of the reconciliation bill retains the same work requirement provisions, with a few exceptions—most importantly, raising the age threshold for the youngest child from seven to 10. The Senate bill also moves up by five years the sunset date for current exemption for veterans, homeless, and young adults aging out of foster care. These changes would alter CBO’s cost estimates of the House-passed version to some extent.

CBO’s letter explained the estimated impact of the House-passed changes to SNAP’s work requirement on participation. They wrote:

“Enacting those combined sections would reduce participation in SNAP by roughly 3.2 million people in an average month over the 2025–2034 period, CBO estimates. Of those people, about 1 million people losing benefits in an average month would be able-bodied adults through age 64 who do not live with dependent children, another 0.8 million would be able-bodied adults age 18 to 64 who live with children who are age 7 or older, and the remaining 1.4 million would be able‑bodied adults aged 18 to 54 (or 18 to 49, starting in 2031) who do not live with dependents but who receive a waiver or exemption from the requirements under current law.”

It is useful to consider how these numbers fit into overall SNAP participation. According to our analysis of SNAP’s quality control (QC) data, there were 7.5 million ABAWDs age 18-64 (i.e., without dependents) receiving SNAP in the average month in FY 2023 (the most recent year of data), of which 6.5 million were not compliant with the 80 hour per month work requirement at the time of eligibility determination (although we could not assess volunteer hours in the data). For context, there were 24.5 million total adults receiving SNAP in the average month in FY 2023.

In addition to SNAP adults without dependents, there were also 3.7 million SNAP parents age 18-64 with a youngest child age seven or older, of which 2.3 million were not complying with the work requirement at the time of their eligibility determination in FY 2023. These 2.3 million parents would be newly subject to SNAP’s work requirement under the House-passed bill. (For comparison, 1.4 million would be newly subject to the work requirement under the Senate’s bill requiring parents with a youngest child age 10 or older). This suggests that almost all of the 2.3 million parents whose youngest child is age seven or older would be newly required to work or volunteer to maintain SNAP eligibility in economic conditions similar to 2023.  

In sum, under the House-passed bill, approximately 6.5 million non-compliant ABAWDs would be subject to work requirements and 2.3 million non-compliant parents with a youngest child age seven or older – for a total of 8.8 million SNAP adults. The CBO estimate of a 3.2 million reduction in SNAP adults due to the House-passed work requirements suggests a relatively large share of these 8.8 million SNAP adults would disenroll due to work requirements. The uncertainty around the effects of work requirements on different groups makes it difficult to evaluate the accuracy of CBO’s estimates. Still, even if their estimates are correct, there are several possible reasons why a given SNAP recipient might disenroll in response to work requirements.

One reason SNAP participation might decline in response to a work requirement is that some recipients gain employment and leave SNAP. To be fair, studies of SNAP’s existing work requirements generally show weak employment responses, although methodological challenges make the results difficult to interpret. Research that exists is mixed on whether the existing ABAWD work requirements increases employment. Nonetheless, plenty of evidence suggests work requirements can increase employment among certain populations and in certain contexts.

SNAP participation could also decline because work requirements prompt recipients to disclose employment earlier, leading some to leave the program sooner than they otherwise would. For example, an ABAWD might qualify for SNAP initially due to a lack of employment. If they begin working the following month, they typically wouldn’t need to report their new income until their next recertification—often six months or longer, depending on the state. However, if they are newly subject to a work requirement, they would be required to report employment sooner. More commonly, they may not respond to a notice requesting employment verification to meet the work requirement. In either case, the individual is likely to exit SNAP earlier than they otherwise would, contributing to a decline in the overall caseload.

Furthermore, some adults may choose not to apply for SNAP at all if doing so requires compliance with a work requirement, opting instead to seek or maintain employment. These dynamics are likely to reduce SNAP participation while potentially increasing employment.

Of course, it is also possible that individuals may leave SNAP because they are either unaware of the work requirements or unable to comply with them. While states are responsible for communicating and enforcing SNAP’s work requirements—and typically offer multiple opportunities for participants to verify compliance—they must also ensure that eligible individuals are not improperly losing access to benefits. To do so, state agencies need a strong understanding of their caseloads and must follow up with participants who exit the program without securing employment.

Changes to SNAP’s work requirements are expected to reduce the caseload. Even though the exact magnitude of the reduction remains uncertain, CBO estimates it could be nearly 3.2 million adults. While work requirements can promote employment and improve outcomes for families, caseload declines may also stem from breakdowns in communication or enforcement by state agencies. To ensure SNAP’s work requirements are effective—and that eligible individuals are not improperly removed—states must closely monitor their caseloads and follow up with individuals who lose SNAP eligibility but remain unemployed.