SNAP’s New Work Rules Are Here: What’s Changing and Who’s Impacted
Reprinted from Arizona Public Health Association (AzPHA) blog post “Public Health Policy Update” by Will Humble. [Editor’s note: Will Humble will be the featured speaker at Lutheran Day at the Legislature on February 23, 2026.]
About 900K of Arizonans currently get SNAP food aid (about 12% of the population) but SNAP participation isn’t uniform.
Dark-red rural counties like Mohave and Gila counties have much higher SNAP participation rates than urban areas. About 30% of people in rural areas get SNAP aid. Urban places like the Phoenix and Tucson are closer to 10%.
This week new federal SNAP rules from H.R. 1 took effect, expanding work requirements and restricting exemptions. For the most part, HR1 didn’t change the actual requirements – rather it mostly affects who are subject to the requirements.
Changes Implemented this Week
The biggest change is the expanded work requirements by age. Previously, federal (and state) SNAP work rules applied only to “able-bodied” adults without dependents between 18–54. Under H.R. 1, that upper age limit increased to 64.
From now on, adults ages 55–64 who meet the technical definition of “able-bodied” need to meet the requirements or lose their benefits after a few months.
Under SNAP law, “able-bodied” means being physically and mentally capable of working and not qualifying for a specific exemption. Exceptions include having a verified disability, being pregnant, or caring for a child under age 14 (but these must be proven). Many people with chronic health conditions may still be classified as able-bodied without formal documentation.
For those subject to it, the work requirement stays at least 80 hours per month of work, volunteering, or approved training, or about 20 hours a week.
H.R. 1 also ended several exemptions from the work requirements that used to exist. Veterans, people experiencing homelessness, and young adults who aged out of foster care aren’t automatically exempt from work rules. Also, parents with children age 14–17 now need to meet work requirements (previously any parent with a child under 18 was exempt).
t’s also harder for states to ask for waivers from the work requirements for areas that have very few jobs. States can only get a geographic waiver if the area has an unemployment above 10%.
Who are Most Affected by the New SNAP Rules?
Adults ages 55–64 w/o dependents. This age group is newly subject to SNAP work requirements. Many are close to retirement age but may still be classified as “able-bodied” under the law.
Rural Arizonans. SNAP participation is highest in rural counties that vote reliably Republican, where job availability and transportation are often limited. Tighter waiver rules (for high local unemployment rates) make it harder to waive ‘work’ requirements in these areas.
Veterans, people experiencing homelessness, former foster youth. These groups lost exemptions and must now meet work requirements unless they qualify for another documented exemption.
Parents of teenagers (ages 14–17). Parents are no longer automatically exempt once their youngest child turns 14. Caregiving alone no longer protects eligibility.
Older adults with chronic conditions. People with health issues may still be considered able-bodied if they lack formal disability documentation, increasing the risk of losing benefits.
What Counts as ‘Work’?
Work Requirements for Able-Bodied Adult Without Dependents | Arizona Department of Economic Security
Paid work: Normal job for at least 20 hours per week;
Volunteer work: Unpaid work (including “work-for-food” or service in exchange for goods/services);
Self-employment: Subsistence or informal work can sometimes count depending on the kind and what documentation they have;
Participation in a qualifying work program: Enrollment in programs like Employment & Training, Workforce Innovation and Opportunity Act programs
Example: A 63-year-old woman volunteers at her church 20 hours per week. She is now subject to the work requirements to get her benefits. She counts the money from the collection plates and works in the kitchen to prepare meals on Sunday mornings.
If the church can verify her hours and they are documented – they probably would satisfy the ‘work’ requirement. Simply attending church services or taking part in activities without a clear volunteer work part doesn’t count.
Note: This person still needs to document and prove she’s doing the work. For example, she’ll need a written statement from her church showing she does 20 hours of work per week. She must make sure ADES gets the information. A self-attestation that she’s doing the volunteer work isn’t enough.
To review Request to Speak (RTS) Action Alerts on SNAP for the week of February 9, click here.