As expanded SNAP work requirements take effect under the One Big Beautiful Bill Act, policy analysts warn that uneven state and local enforcement could encourage recipients to move to areas with less stringent rules.
By yourNEWS Media Newsroom
New federal work requirements for the Supplemental Nutrition Assistance Program are taking effect across the country, raising concerns that differences in state and local enforcement could make some jurisdictions more attractive to recipients who do not comply with stricter employment rules elsewhere.
The federal government spent more than $100 billion on SNAP in fiscal year 2025. The program remains federally funded and governed by core eligibility standards, but states administer benefits and retain some flexibility over implementation, creating a patchwork of rules, timelines and enforcement practices.
The latest changes stem from the One Big Beautiful Bill Act, signed 13 months ago, which expanded SNAP work requirements for able-bodied adults without dependents, or ABAWDs. The new rules apply to adults ages 18 to 64, broadening the previous range of 18 to 54, according to federal SNAP eligibility guidance.
The law also narrowed several exemptions. Caregivers of children age 14 and older, some veterans, homeless individuals and former foster youth must generally comply with the work rules. Those subject to the requirements must complete 80 hours per month of work, volunteering or training. Individuals who do not comply are limited to three months of benefits within a 36-month period.
The law also restricted eligibility for some noncitizens and added state cost-sharing requirements based on error rates.
Most states began implementing the new requirements in late 2025, with states such as Maryland, Pennsylvania and Kansas applying the rules to new applicants and recertifications between September and November, according to the National Conference of State Legislatures. By early 2026, 49 states had largely complied, though implementation schedules varied.
Several jurisdictions faced delays due to waivers or litigation, including California, Illinois, Washington, D.C., Nevada and others. Some delays extended into February or later, with parts of Pennsylvania delayed until September 2026. Grace periods also applied in some places, including through May 1. Noncitizen eligibility changes received a hold-harmless extension until April 9, 2026, for 21 states.
The varying timelines have prompted concerns that less stringent jurisdictions could become informal “SNAP havens,” according to a Just the News report. The concern is that recipients affected by stricter work requirements may choose to relocate to states or localities where enforcement is delayed, weaker or more flexible.
Analysts have pointed to earlier welfare migration patterns as a possible warning sign. A 2000 analysis using 1980 and 1990 Census data found that single mothers and low-education individuals were more likely to move to states with more generous general welfare benefits. Similar patterns were observed in immigrant welfare use, with higher concentrations in high-benefit states.
SNAP’s federal structure limits how far states can diverge from national rules. Income limits, citizenship requirements, work requirements and benefit calculations remain core federal standards. However, states can use options such as broader categorical eligibility, which can ease income or asset limits, and they can design their own employment and training programs.
Administrative differences can also emerge below the state level. In about 10 states, counties handle day-to-day SNAP operations, including processing, local support and some implementation functions. That structure can produce differences in how quickly new work rules are applied, how recipients are notified and how waivers or grace periods are managed.
Fraud, waste and improper payments remain a major concern for the program. In fiscal year 2023, the U.S. Department of Agriculture estimated SNAP’s improper payment rate at 11.7%, totaling about $10.5 billion in erroneous benefits.
Benefit trafficking, the illegal exchange of SNAP benefits for cash, diverted an estimated 1.6% of benefits, or about $1 billion annually, according to the most recent USDA study covering 2015 to 2017.
Federal watchdogs have also found vulnerabilities through data matching, which compares SNAP records with other databases involving income, death records, prison rolls and interstate enrollment. Those reviews have identified billions in potential overpayments to ineligible recipients.
Supporters of stricter enforcement argue that expanded work requirements are intended to reduce long-term dependency, improve program integrity and ensure benefits are targeted toward eligible households. Critics of uneven implementation say the state-by-state rollout could undercut those goals if some areas enforce the new rules more slowly or less aggressively than others.
The new SNAP rules now place greater pressure on state agencies to apply federal requirements consistently while managing legal challenges, administrative deadlines and local capacity. As the rollout continues, the central question is whether the expanded work rules will produce uniform enforcement nationwide or create incentives for recipients to seek out jurisdictions with softer requirements.
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