This document lays out, for each of the 50 states plus D.C., when people become subject to the ABAWD three-month time limit, when eliminations occur, and why the jurisdiction is classed cliff, rolling, hybrid, or not published. Guam is excluded because it has no wave-shape record in the source data; the Virgin Islands is excluded because it has no row in the signed-off first-elimination table this page is checked against.
Rolling
| First countable month — people newly subject under the 2025 law | Dec 2025 (federal default) |
|---|---|
| First elimination month | Mar 2026 |
| Rolling closures | Mar 2026 onward |
December 2025 — People ages 55 to 64, parents whose youngest child is 14 to 17, veterans, homeless people, and former foster youth became newly subject to the three-month limit under the 2025 federal law. Alabama has not published how it finds people already enrolled who became newly subject to this limit. Alabama's caseload fell in January, March, April and May 2026 with no single-month drop, which fits renewal-by-renewal closures rather than a single wave. Because November 2025 does not count anywhere in the country, December 2025 is the first month that can count against them; new applicants are checked when they apply. Alabama DHR POE Manual, Chapter 7, Section 710A
March 2026 onward — Starting in March 2026 and continuing for as long as the rule is in force, Alabama picks up newly subject people one at a time, at their next renewal. Alabama DHR POE Manual, Chapter 7, Section 710A
The state has published no instrument for finding people already enrolled who became newly subject; the federal default applies them at renewal, so closures arrive a few at a time from March 2026 onward (inferred from the caseload). Alabama DHR POE Manual, Chapter 7, §710A (live capture 2026-05-29)
Cliff
| Waiver end(s) | Oct 2026 |
|---|---|
| First countable month — people newly subject under the 2025 law | Nov 2026 |
| First elimination month | Feb 2027 |
| 36-month reset | Jan 2028 |
October 2026 — People ages 55 to 64, parents whose youngest child is 14 to 17, veterans, homeless people, and former foster youth have been exempt from the three-month limit under a statewide exemption. The same exemption keeps adults without children at home exempt everywhere in Alaska except the Municipality of Anchorage. Both parts of the exemption end October 31, 2026, so months start counting toward the limit for everyone they had covered. Alaska's SNAP manual says caseworkers check this status only when someone applies, renews their benefits, or reports a change affecting their case. Alaska Dept. of Health, H.R.1 AK Impacts FAQ
November 2026 — November 2026 is the first month that can count against the three-month limit for people newly subject under the 2025 law, because Alaska's statewide good-faith exemption, which covers all areas except the Municipality of Anchorage, ends October 31, 2026. Alaska Dept. of Health, H.R.1 AK Impacts FAQ
February 2027 — By February 2027, people ages 55 to 64, parents whose youngest child is 14 to 17, veterans, homeless people, and former foster youth, along with adults without children at home outside Anchorage, reach the three-month limit together and lose benefits unless they are working, in a training program, or otherwise excused. Alaska SNAP Manual 602-1(L), Able-Bodied Adults Without Dependents
January 2028 — In January 2028, Alaska's three-year count starts over statewide, giving everyone three fresh months again. Alaska SNAP Manual 602-1(L), part 2 (36 Month Period)
People newly subject under the 2025 law reach the three-month limit together in February 2027. Alaska SNAP Manual 602-1(L), Able-Bodied Adults Without Dependents, part 4 (Identifying an ABAWD) (live capture 2026-09-02)
Cliff
| Waiver end(s) | Sep 2025 and Feb 2027 |
|---|---|
| First countable month — people newly subject under the 2025 law | Dec 2025 |
| First elimination month | Mar 2026 |
| 36-month reset | Jan 2028 |
August 2025 — For people already enrolled who had been exempt as veterans, former foster youth, homeless people, or parents of a child 14 or older, Arizona counts August, September and October 2025 against the three-month limit once their case is next reviewed, so August 2025 is their first counted month (shown as a dashed chip). Arizona FAA Policy Manual, ABAWD Exemptions
October 2025 — Adults without children at home in every county except Maricopa started counting in October 2025, because the county exemption that had paused work requirements there ended September 30, 2025. FNS Arizona ABAWD Waiver Response, FY2025
November 2025 to February 2026 — People who had been exempt from the three-month limit as veterans, former foster youth, homeless people, or parents of a child 14 or older could lose benefits at their next interview during this span, because Arizona counts August 2025 through October 2025 against them. Arizona FAA Policy Manual, ABAWD Exemptions
December 2025 — For other people newly subject under the 2025 law, ages 55 to 64 among them, December 2025 is the first month that can count; they are found at their next renewal interview. November 2025 never counts. Arizona FAA Policy Manual, ABAWD Time Limits and Work Requirements
February 2026 — By February 2026, adults without children at home in every Arizona county except Maricopa reach the three-month limit together and lose benefits, because the county exemption that had paused work requirements there ended September 30, 2025. FNS Arizona ABAWD Waiver Response, FY2025
March 2026 onward — Starting in March 2026 and continuing for as long as the rule is in force, other Arizona adults who are newly subject to the limit are found one at a time, when they go in for their renewal interview. Arizona FAA Policy Manual, ABAWD Time Limits and Work Requirements
January 2028 — In January 2028, Arizona's three-year count starts over statewide, giving everyone three fresh months again. Arizona FAA Policy Manual, ABAWD Time Limits and Work Requirements
Arizona says its staff searched case records for people affected by the new rules, applied another exemption where the data showed one, and sent everyone else a notice; it gives no date for the notices. This timeline draws the newly subject group starting to count together in December 2025, so by our count those who did not meet the work rule lost benefits together in March 2026, outside Yuma County and the six reservation areas that a new waiver covered from that month. Arizona has not published this month. Arizona DES blog, "Standing Strong: Navigating H.R. 1's Impact", February 10, 2026
Rolling
| First countable month — people newly subject under the 2025 law | Dec 2025 (federal default) |
|---|---|
| First elimination month | Mar 2026 |
| 36-month reset | Jan 2028 |
| Rolling closures | Mar 2026–Jun 2027 |
December 2025 — People ages 55 to 64, parents whose youngest child is 14 to 17, veterans, homeless people, and former foster youth became newly subject to the three-month limit under the 2025 federal law. Arkansas's SNAP Certification Manual directs staff to check this status only when someone applies, renews their benefits, or reports a change, not through a one-time review of existing cases. Arkansas's caseload fell from March through May 2026 at about a third of its earlier pace, which fits renewal-by-renewal closures. Because November 2025 does not count anywhere in the country, December 2025 is the first month that can count against them in Arkansas. Arkansas SNAP Certification Manual, SNAP 3530
March 2026 onward — Starting in March 2026 and continuing for as long as the rule is in force, Arkansas picks up newly subject people one at a time, at their application, renewal, or a reported change. Arkansas SNAP Certification Manual, SNAP 3530
January 2028 — In January 2028, Arkansas's three-year count starts over, giving everyone subject to the limit three fresh months again. Arkansas SNAP Certification Manual, SNAP 3511
The state has published no instrument for finding people already enrolled who became newly subject; the federal default applies them at renewal, so closures arrive a few at a time from March 2026 onward (inferred from the caseload). AR SNAP Certification Manual (04/02/2026) SNAP 3530, Disqualifying Individuals Who Fail to Comply
Rolling
| Waiver end(s) | Jan 2026 |
|---|---|
| First countable month — people newly subject under the 2025 law | Jun 2026 |
| First elimination month | Sep 2026 |
| 36-month reset | Jan 2029 |
| Rolling closures | Sep 2026–Jun 2027 |
January 2026 — California's three-year count runs January 1, 2026 through December 31, 2028 for everyone subject to the three-month limit. California CDSS All-County Letter 25-93
July 2026 — Starting June 2026, California only checks whether someone already getting benefits falls under the three-month limit when that person renews their benefits. This applies both to people newly subject to the limit (ages 55 to 64, parents whose youngest child is 14 to 17, veterans, homeless people, and former foster youth) and to adults without children at home who were already subject. Because of how the count works, the earliest month that can count against anyone is July 2026. California CDSS All-County Letter 25-93
October 2026 onward — From October 2026 onward, Californians newly subject to the limit lose benefits a few at a time, as each renews their benefits and is checked. California CDSS All-County Letter 25-93
January 2029 — In January 2029, California's three-year count starts over statewide, giving everyone three fresh months again. California CDSS All-County Letter 25-93
People already enrolled who became newly subject under the 2025 law are picked up at their next recertification, so closures arrive a few at a time from September 2026 onward. CDSS ACL 25-93 (Dec 31 2025), New Applicants
Rolling
| Waiver end(s) | Sep 2025 |
|---|---|
| First countable month — people newly subject under the 2025 law | Dec 2025 (federal default) |
| First elimination month | Mar 2026 |
| 36-month reset | Jul 2026 |
| Pause and resume | Jul 2026–Sep 2026 → resumes Oct 2026 |
| Rolling closures | Mar 2026–Jun 2026 |
December 2025 — People ages 55 to 64, parents whose youngest child is 14 to 17, veterans, homeless people, and former foster youth became newly subject to the three-month limit under the 2025 federal law. Colorado's Operational Memo OM-FEA-2025-0011 says the state applies the new rules to new and ongoing participants after they are screened, so people already enrolled are picked up at their next renewal. Colorado has not published a start date, letter, or batch for that screening, so the federal default applies. Because November 2025 does not count anywhere in the country, December 2025 is the earliest month that can count against them. Colorado CDHS Operational Memo OM-FEA-2025-0011
March 2026 to June 2026 — Closures under the three-month limit arrive a few at a time from March through June 2026, as Colorado screens newly subject people at their renewals. These closures are too small a number to show up in Colorado's monthly caseload totals. Colorado CDHS Operational Memo OM-FEA-2025-0011
May 2026 — Colorado's caseload did fall sharply in May 2026, but not because of the three-month limit. A separate part of the 2025 federal law ended SNAP benefits for most non-citizens, effective with benefits issued starting May 1, 2026. Colorado's own caseload fell by 8,144 people from April to May 2026, and Arapahoe County alone reported just over 2,900 residents losing benefits. Rep. Diana DeGette press release, May 1, 2026
October 2025 — A county exemption that had paused work requirements in 18 Colorado counties, Alamosa, Baca, Bent, Conejos, Costilla, Crowley, Custer, Fremont, Hinsdale, Huerfano, Kiowa, Las Animas, Lincoln, Mineral, Otero, Pueblo, Rio Grande, and Saguache, ended September 30, 2025. Adults without children at home in those counties are also picked up at their next renewal, the same as people newly subject under the 2025 federal law. Colorado has never announced a shared start date for them, so no single closure month is shown. FNS Colorado ABAWD Waiver Approval, FY2025
July 2026 — In July 2026, Colorado's three-year count starts over statewide, giving everyone three fresh months again. Colorado Code of Regulations 2506-1, Section 4.311.3, ABAWD Time Limits
October 2026 — After the reset, the three months July, August, and September 2026 are a pause in which no one can reach the limit. In October 2026 everyone still subject to the limit reaches it together, three counted months after the reset. Renewal-by-renewal closures then continue from October 2026 onward. Colorado Code of Regulations 2506-1, Section 4.311.3, ABAWD Time Limits
People already enrolled who became newly subject under the 2025 law are picked up at their next recertification, so closures arrive a few at a time from March 2026 through June 2026. The state's three-year clock resets in July 2026. After the reset, everyone still subject to the limit gets three fresh months, so anyone not meeting the work requirement through the pause reaches the limit together in October 2026. Renewal-by-renewal closures resume from October 2026. CDHS OM-FEA-2025-0011 (Oct 1 2025), attaching FNS Sept 4 2025 OBBB Information Memorandum
Rolling
| Waiver end(s) | Nov 2025 |
|---|---|
| First countable month — people newly subject under the 2025 law | Dec 2025 |
| First elimination month | Mar 2026 |
| Rolling closures | Mar 2026 onward |
December 2025 — People ages 55 to 64, parents whose youngest child is 14 to 17, veterans, homeless people, and former foster youth became newly subject to the three-month limit under the 2025 federal law. Connecticut identifies people already enrolled who became newly subject from its own case data. DSS officials told reporters the department mailed or texted them a notice ahead of time. December 2025 is the first month that counts toward the limit for them, since November 2025 doesn't count anywhere in the country. Inside Investigator, quoting Connecticut DSS official Barton Reeves
March 2026 — Adults without children at home in parts of Connecticut whose town exemption from the three-month limit ended November 30, 2025, reach the limit together in March 2026 and lose benefits. Connecticut DSS SNAP Policy Manual, ABAWD Tracking
Connecticut's social services commissioner said notices would go out on November 3, 2025 and the three-month limit would begin December 1 for remaining recipients without another exemption. Read plainly, that timing gives one start for everyone remaining, but the report does not say which group the notices went to, and Connecticut has not published how it timed the newly subject group's losses, so this timeline draws them arriving a few at a time from March 2026, the first month anyone in the group could lose benefits by our count. Inside Investigator, quoting DSS official Barton Reeves (operational fact, agency-attributed)
Cliff
| Waiver end(s) | Sep 2025 |
|---|---|
| First countable month — people newly subject under the 2025 law | Dec 2025 (federal default) |
| First elimination month | Mar 2026 |
December 2025 — People ages 55 to 64, parents whose youngest child is 14 to 17, veterans, homeless people, and former foster youth became newly subject to the three-month limit under the 2025 federal law. Delaware finds people already enrolled who became newly subject from its own case data and mails each one an official notice, rather than waiting for their next renewal. December 2025 is the first month that counts toward the limit for them, since November 2025 doesn't count anywhere in the country. Delaware DHSS, SNAP Alert FAQ
October 2025 — Delaware's exemption from the three-month limit, which had covered Wilmington and Kent and Sussex Counties, expired September 30, 2025. October 2025 is the first month that counts toward the limit for adults without children at home there. FNS Delaware ABAWD Waiver Response, FY2025
February 2026 to March 2026 — By February 2026 and March 2026, people the state had already identified as newly subject to the limit, and people from the ended Wilmington, Kent, and Sussex county exemption, reached it and lost benefits. Delaware mails a notice directly to each person rather than waiting for their next renewal. Delaware DHSS, SNAP Alert FAQ
Adults 18 to 54 without children at home in Wilmington plus Kent and Sussex counties whose exemption ended September 30, 2025 reached the three-month limit together in February 2026 and March 2026. Delaware DHSS, SNAP Alert FAQ (live capture 2026-09-02)
Rolling
| Waiver end(s) | Dec 2025 |
|---|---|
| First countable month — people newly subject under the 2025 law | Jun 2026 |
| First elimination month | Sep 2026 |
| Rolling closures | Sep 2026 onward |
June 2026 — The District's fixed three-year count for the three-month limit began June 1, 2026, the first time DC has enforced the time limit. DC DHS, SNAP Work Requirements FAQ
July 2026 — Starting June 1, 2026, the District only checks whether someone already getting benefits falls under the three-month limit when that person applies or renews their benefits. This applies both to people newly subject to the limit (ages 55 to 64, parents whose youngest child is 14 to 17, veterans, homeless people, and former foster youth) and to adults without children at home who were already subject. Because of how the count works, the earliest month that can count against anyone is July 2026. DC DHS, SNAP Work Requirements FAQ
October 2026 onward — From October 2026 onward, DC residents newly subject to the limit lose benefits a few at a time, as each applies or renews and is checked. DC DHS, SNAP Work Requirements FAQ
People already enrolled who became newly subject under the 2025 law are picked up at their next recertification, so closures arrive a few at a time from September 2026 onward. DC DHS, SNAP Work Requirements FAQ (captured 2026-08)
Rolling
| First countable month — people newly subject under the 2025 law | Dec 2025 (federal default) |
|---|---|
| First elimination month | Mar 2026 |
| 36-month reset | Jan 2028 (not confirmed) |
| Rolling closures | Mar 2026–Jun 2027 |
December 2025 — People ages 55 to 64, parents whose youngest child is 14 to 17, veterans, homeless people, and former foster youth became newly subject to the three-month limit under the 2025 federal law. Florida's FY2026 SNAP E&T State Plan says these customers will be rescreened and reevaluated at their next recertification, or sooner if requested. Because November 2025 does not count anywhere in the country, December 2025 is the first month that can count against them. Florida FY2026 SNAP E&T State Plan (DCF, live-fetched 2026-09-04)
March 2026 onward — Starting in March 2026 and continuing for as long as the rule is in force, Florida picks up newly subject people one at a time, at their recertification. Florida FY2026 SNAP E&T State Plan (DCF, live-fetched 2026-09-04)
People already enrolled who became newly subject under the 2025 law are picked up at their next recertification, so closures arrive a few at a time from March 2026 onward. Florida ESS Program Policy Manual §1410.1800 (live-fetched 2026-09-02; PDF metadata dated 2025-08-04)
Rolling
| First countable month — people newly subject under the 2025 law | Dec 2025 (federal default) |
|---|---|
| First elimination month | Mar 2026 |
| 36-month reset | Dec 2026 |
| Pause and resume | Dec 2026–Feb 2027 → resumes Mar 2027 |
| Rolling closures | Mar 2026–Nov 2026 |
December 2025 — People ages 55 to 64, parents whose youngest child is 14 to 17, veterans, homeless people, and former foster youth became newly subject to the three-month limit under the 2025 federal law. Georgia applies the new rules only when someone applies or renews their benefits on or after November 1, 2025. Because November 2025 does not count anywhere in the country, December 2025 is the first month that can count against anyone in Georgia. Georgia DHS Press Release, October 31, 2025
March 2026 to November 2026 — From March 2026 through November 2026, Georgians newly subject to the limit lose benefits a few at a time, as each applies or renews and is checked. Georgia DFCS, Able-Bodied Adults without Dependents FAQ
December 2026 — In December 2026, Georgia's three-year count starts over statewide, giving everyone three fresh months again. Georgia DFCS SNAP Manual (PAMMS), Section 3355
March 2027 — After the reset, the three months December 2026, January 2027, and February 2027 are a pause in which no one can reach the limit. In March 2027 everyone still subject to the limit reaches it together, three counted months after the reset. Renewal-by-renewal closures then continue from March 2027 onward. Georgia DFCS SNAP Manual (PAMMS), Section 3355
People already enrolled who became newly subject under the 2025 law are picked up at their next recertification, so closures arrive a few at a time from March 2026 through November 2026. The state's three-year clock resets in December 2026. After the reset, everyone still subject to the limit gets three fresh months, so anyone not meeting the work requirement through the pause reaches the limit together in March 2027. Renewal-by-renewal closures resume from March 2027. GA DHS/DFCS — Able-Bodied Adults without Dependents (FAQ page)
Rolling
| First countable month — people newly subject under the 2025 law | Dec 2025 (federal default) |
|---|---|
| First elimination month | Mar 2026 |
| Rolling closures | Mar 2026 onward |
December 2025 — Hawaii's Department of Human Services says its wider definition of who must meet the three-month work limit took effect November 1, 2025, covering people ages 55 to 64, parents whose only children at home are 14 or older, veterans, homeless people, and former foster youth. No month before December 2025 counts anywhere in the country, so December 2025 is the earliest month that can count for them. Hawaii has not named this as its own official starting month, so it follows the federal default. Hawaii DHS press release (Oct. 17, 2025)
March 2026 onward — Hawaii's Department of Human Services says it asks about the new work rules only at a person's next application or recertification interview, not through a separate review or mailing. Because of that, people newly covered by the 2025 federal law lose benefits a few at a time, as their individual cases come up from March 2026 onward. Hawaii DHS, Changes to Able-Bodied Adult Work Requirements FAQ
People already enrolled who became newly subject under the 2025 law are picked up at their next recertification, so closures arrive a few at a time from March 2026 onward. Hawaii DHS — Changes to Able-Bodied Adult Work Requirements for SNAP FAQs
Rolling
| First countable month — people newly subject under the 2025 law | Apr 2026 |
|---|---|
| First elimination month | Jul 2026 |
| Rolling closures | Jul 2026 onward |
April 2026 — Idaho has not updated its own written rule for the people the 2025 federal law newly covers: those ages 55 to 64, parents whose only children at home are 14 or older, veterans, homeless people, and former foster youth. Idaho has not published a way to identify people already enrolled who became newly covered. An Idaho Health and Welfare spokesperson said the state's new rule took effect in April 2026, and new applicants and people renewing benefits are checked under the ordinary rule. Idaho Capital Sun via Spokane Public Radio, Laura Guido (2026-07-06), quoting IDHW spokesman AJ McWhorter
July 2026 onward — Rolling closures for people newly subject to the limit begin in July 2026 and continue for as long as the rule is in force, one at a time at renewal. The first of these exits have not yet appeared in Idaho's caseload data. Idaho Capital Sun via Spokane Public Radio, Laura Guido (2026-07-06), quoting IDHW spokesman AJ McWhorter
The state has published no instrument for finding people already enrolled who became newly subject; the federal default applies them at renewal, so closures arrive a few at a time from July 2026 onward (inferred from the caseload). IDAPA 16.03.04.251 (live-fetched 2026-09-02; PDF metadata modified 2026-06-25)
Cliff
| Waiver end(s) | Jan 2026 |
|---|---|
| First countable month — people newly subject under the 2025 law | Feb 2026 |
| First elimination month | May 2026 |
| 36-month reset | Jan 2027 |
February 2026 — Illinois's human services agency updated every active SNAP case's status in its system on September 26, 2025, ahead of the exemption that had paused the work requirement statewide. The update covered both people newly covered by the 2025 federal law — those ages 55 to 64, parents whose only children at home are 14 or older, veterans, homeless people, and former foster youth — and adults without children at home who were already covered before the law. A federal court kept that exemption in place through its original end date, January 31, 2026. February 2026 is the first month that can count toward the three-month limit statewide. IDHS Manual Release #26.03 (Feb. 4, 2026)
April 2026 — A separate part of the 2025 federal law ended SNAP eligibility for most non-citizens. Illinois applied that change at redeterminations with certification periods beginning on or after April 1, 2026. Illinois's manual says these redeterminations "will be subject to the new requirements." Because of that timing, the May 2026 caseload drop blends those closures with the work-rule removals. Illinois DHS Manual Release #26.19
May 2026 — Adults without children at home in every Illinois county, whose exemption from the work requirement ended January 31, 2026 after that court order, reached the three-month limit together and lost benefits. Illinois's human services agency told reporters it removed about 100,000 people that month. WBEZ, "Illinois sees 16% drop in SNAP enrollment" (July 27, 2026), citing IDHS
January 2027 — Illinois runs the time limit on a statewide count that ends December 31, 2026. A new three-year count begins for everyone on January 1, 2027. IDHS Policy Manual PM/WAG 03-16-04-a: ABAWD Time Limit Clock
April 2027 — This second wave is smaller than the first. It includes only people who had used some but not all of their three months when the count returned to zero, plus people who joined or came back onto the program in the months around the reset. IDHS Policy Manual PM/WAG 03-16-04-a: ABAWD Time Limit Clock
People newly subject under the 2025 law reached the three-month limit together in May 2026. The state's three-year clock resets in January 2027. After the reset, people who had used some but not all of their three months, plus anyone who joined shortly before the reset, reach the limit together in April 2027. IDHS Policy Memo, End of Waiver for Time-Limited SNAP Benefits and Changes to Exemptions for SNAP Work Requirements (10/16/2025)
Rolling
| First countable month — people newly subject under the 2025 law | Jan 2026 |
|---|---|
| First elimination month | Apr 2026 |
| 36-month reset | Jul 2027 |
| Rolling closures | Apr 2026–Jun 2027 |
December 2025 — Indiana's SNAP/TANF Program Policy Manual, §2438.17.05, says work-limit status is decided only at initial application, at redetermination, or when someone is added to the case. Indiana has not published a single date for checking people already enrolled against the wider 2025 federal law, which added people ages 55 to 64, parents whose only children at home are 14 or older, veterans, homeless people, and former foster youth. No month before December 2025 counts anywhere in the country, so December 2025 is the earliest month that can count for them, under the federal default. Indiana's caseload declined gradually from March through May 2026 with no single-month spike, which fits renewal-by-renewal closures. Indiana SNAP/TANF Program Policy Manual, Ch. 2400 §2438.17.05
March 2026 onward — Starting in March 2026 and continuing for as long as the rule is in force, Indiana picks up newly subject people one at a time, at their redetermination. Indiana SNAP/TANF Program Policy Manual, Ch. 2400 §2438.17.05
July 2027 — Indiana runs the time limit on a statewide count that ends June 30, 2027. A new three-year count begins for everyone on July 1, 2027. Indiana SNAP/TANF Program Policy Manual, Ch. 2400 §2438.17.00
The state has published no instrument for finding people already enrolled who became newly subject; the federal default applies them at renewal, so closures arrive a few at a time from April 2026 onward (inferred from the caseload). Indiana SNAP/TANF Program Policy Manual, Ch. 2400 §2438.17.05 ([LEGACY edition], in.gov/fssa/dfr/forms-documents-and-tools/policy-manual)
Cliff
| First countable month — people newly subject under the 2025 law | Dec 2025 (federal default) |
|---|---|
| First elimination month | Mar 2026 |
| 36-month reset | Dec 2026 |
December 2025 — Iowa has not published a single date for checking people already enrolled against the wider 2025 federal law, which added people ages 55 to 64, parents whose only children at home are 14 or older, veterans, homeless people, and former foster youth. No month before December 2025 counts anywhere in the country, so December 2025 is the earliest month that can count for them, under the federal default. Iowa runs one shared three-year count for everyone rather than a separate clock per person: the manual says "This period is the same for all ABAWDs in Iowa" and names the current period as December 1, 2023 through November 30, 2026. A shared count is what makes people reach the limit in the same month. Iowa HHS Employees' Manual, Title 7: SNAP, Chapter I — Tracking / Time Limit for ABAWDs
March 2026 — In March 2026 the people newly covered by the 2025 federal law reach the three-month limit together, three counted months after December 2025. Iowa's caseload fell by about 4,900 people that month, roughly five times a normal month for Iowa, and then held flat through June 2026. Iowa published no list or notice date for this group, so the timing here is read from the shared three-year count and from the caseload, not from an Iowa announcement. Iowa HHS Employees' Manual, Title 7: SNAP, Chapter I — Tracking / Time Limit for ABAWDs
December 2026 — Iowa's three-year count resets to zero for everyone on December 1, 2026. December 2026, January 2027, and February 2027 are a pause, in which no one can reach the limit. Iowa HHS Employees' Manual, Title 7: SNAP, Chapter I — Changes in ABAWD Status (worked example)
March 2027 — In March 2027 everyone still subject to the limit reaches it again together, three counted months after the reset. This second group is smaller than the first: it is the people who had used some but not all of their three months before the reset, plus people who joined or came back onto the program around the reset. Iowa HHS Employees' Manual, Title 7: SNAP, Chapter I — Changes in ABAWD Status (worked example)
The state has published no instrument for finding people already enrolled who became newly subject; the caseload shows most of the newly subject group leaving together in March 2026 (inferred from the caseload). The state's three-year clock resets in December 2026. After the reset, people who had used some but not all of their three months, plus anyone who joined shortly before the reset, reach the limit together in March 2027. Iowa HHS Employees' Manual, Title 7: SNAP, Chapter I — ABAWD Status Notifications (Revised Feb 13, 2026)
Rolling
| First countable month — people newly subject under the 2025 law | Dec 2025 |
|---|---|
| First elimination month | Mar 2026 |
| 36-month reset | Oct 2025 |
| Rolling closures | Mar 2026–Jun 2027 |
December 2025 — Kansas's DCF Policy Memo 25-10-08 tells workers to identify people newly covered by the 2025 federal law — those ages 55 to 64, parents whose only children at home are 14 or older, veterans, homeless people, and former foster youth — only at an application, a review, an interim report, a 12-month report, or a reported change. The memo's own worked example sets December 2025 as the first month that can count toward their three-month limit. Kansas DCF EES Policy Memo 25-10-08 (Oct. 22, 2025), Example 1
March 2026 onward — People already enrolled who became newly covered by the 2025 federal law are found one at a time, when their case comes up for an application, review, interim report or a reported change; December 2025 is the earliest month that can count for them. The earliest of them reach the three-month limit in March 2026, and closures continue a few at a time from then on. Kansas DCF EES Policy Memo 25-10-08 (Oct. 22, 2025), Implementation Instructions
October 2025 — Kansas's own three-year count for adults without children at home restarted at zero for everyone covered by the limit in October 2025, on the state's regular schedule and separate from the 2025 federal law. Kansas KEESM 2520 (Economic and Employment Services Manual)
October 2025 — Adults without children at home who were already covered by the three-month limit before the 2025 federal law resumed building up months toward the limit starting with that October 2025 restart. Kansas DCF EES Policy Memo 25-10-08 (Oct. 22, 2025), Notification
February 2026 — Adults without children at home who were already covered by the three-month limit before the 2025 federal law reached the limit together and lost benefits. Kansas DCF EES Policy Memo 25-10-08 (Oct. 22, 2025)
Adults 18 to 54 without children at home statewide whose count restarted when Kansas opened a new three-year window on October 1, 2025 reached the three-month limit together in February 2026. People already enrolled who became newly subject under the 2025 law are picked up at their next recertification, so closures arrive a few at a time from March 2026 onward. Kansas DCF EES Policy Memo 25-10-08 (Oct 22, 2025), Implementation Instructions
Hybrid: a cliff plus rolling closures
| Waiver end(s) | Nov 2025 |
|---|---|
| First countable month — people newly subject under the 2025 law | Dec 2025 (federal default) |
| First elimination month | Mar 2026 |
| Rolling closures | Mar 2026 onward |
December 2025 — Kentucky assigns a work-requirement tracking code to every SNAP case each time it is recalculated, which is how it finds people newly covered by the 2025 federal law — those ages 55 to 64, parents whose only children at home are 14 or older, veterans, homeless people, and former foster youth. Households that already had an exemption for a child under 18 keep that exemption until their next renewal. No month before December 2025 counts anywhere in the country, so December 2025 is the earliest month that can count for them, under the federal default. KY DFS Operations Manual Vol. IIA, MS 2300 (ABAWD Tracking)
March 2026 onward — Because Kentucky picks up already-enrolled households at their next renewal, people newly covered by the 2025 federal law lose benefits a few at a time throughout this period, as their individual cases come up for review. KY DFS Operations Manual Vol. IIA, MS 2300 (ABAWD Tracking)
December 2025 — Adults without children at home in the 117 Kentucky counties covered by the county exemption that had paused the work requirement started building up months toward the three-month limit after that exemption ended November 30, 2025. FNS/FNA, SNAP Waiver of the Time Limit – Status Update (Feb. 26, 2026), Appendix A
March 2026 — Adults without children at home in those 117 counties reached the three-month limit together and lost benefits. KY DFS Operations Manual Vol. IIA, MS 2700 (ABAWD Noncompliance)
People newly subject under the 2025 law reached the three-month limit together in March 2026. People already enrolled who became newly subject under the 2025 law are picked up at their next recertification, so closures arrive a few at a time from March 2026 onward. KY DFS Operations Manual Vol. IIA, MS 2300 ABAWD Tracking (OMTL-683, R. 10/25/25)
Cliff
| First countable month — people newly subject under the 2025 law | Dec 2025 (federal default) |
|---|---|
| First elimination month | Mar 2026 |
| 36-month reset | Apr 2026 |
December 2025 — Louisiana's health department told all recipients directly that its wider definition, covering people ages 55 to 64, parents whose only children at home are 14 or older, veterans, homeless people, and former foster youth, took effect November 1, 2025. Because no month before December 2025 counts anywhere in the country, December 2025 is the first month that counted against the three-month limit for them. Louisiana LDH, ABAWD page (FAQ)
March 2026 — People newly subject under the 2025 federal law had December, January, and February count against the three-month limit and reached it together in March 2026. Louisiana LDH, ABAWD page (FAQ)
April 2026 — Louisiana runs the time limit on a statewide count that ends March 31, 2026. A new three-year count begins for everyone on April 1, 2026. Louisiana LDH, ABAWD page (FAQ)
July 2026 — This second wave is smaller than the first. It includes only people who had used some but not all of their three months when the count returned to zero, plus people who joined or came back onto the program in the months around the reset. Louisiana LDH, ABAWD page (FAQ)
People newly subject under the 2025 law reached the three-month limit together in March 2026. The state's three-year clock resets in April 2026. After the reset, people who had used some but not all of their three months, plus anyone who joined shortly before the reset, reach the limit together in July 2026. LDH ABAWD page, Age Requirement Chart (Wayback capture 2026-02-10; "Novemebr" is LDH's own typo)
Hybrid: a cliff plus rolling closures
| Waiver end(s) | Sep 2025 |
|---|---|
| First countable month — people newly subject under the 2025 law | Dec 2025 (federal default) |
| First elimination month | Feb 2026 |
| 36-month reset | Oct 2026 |
| Pause and resume | Oct 2026–Dec 2026 → resumes Jan 2027 |
| Rolling closures | Mar 2026–Sep 2026 |
December 2025 — Adults newly required to meet Maine's work rule under the 2025 federal law, meaning people ages 55 to 64, parents whose youngest child is 14 to 17, veterans, homeless people, and former foster youth, could start counting toward the three-month limit as early as December 2025, the federal default since Maine has not named its own date. Maine has not published how it identifies people already enrolled who became newly subject to the rule; the state's only documented trigger is its general work registration, which recurs at application and every twelve months. 10-144 CMR ch. 301, FS 111-5 (current rule, filing 2026-115, amended May 17 2026)
March 2026 to September 2026 — Adults newly required to meet Maine's work rule under the 2025 federal law who live outside the 213 towns and townships are found one at a time, when their case comes up for renewal, starting in March 2026. Maine has not published an instrument for finding them; this reading is inferred, because the state's caseload from March through May 2026 shows no single-month drop, only the same pace as before. 10-144 CMR ch. 301, FS 111-5 (current rule, filing 2026-115, amended May 17 2026)
October 2025 — Maine's county exemption, which had paused work requirements in 213 Maine towns and townships, ended September 30, 2025. Adults without children at home in those towns began counting toward the three-month limit statewide starting that October, under Maine's fixed three-year count. 10-144 CMR ch. 301, FS 111-7(2)(B) (Maine SNAP rule)
February 2026 — Adults without children at home in the 213 Maine towns and townships whose county exemption ended September 30, 2025 reached the three-month limit together and lost benefits in February 2026. 10-144 CMR ch. 301, FS 111-7(2)(B) (Maine SNAP rule)
October 2026 — Maine's three-year count restarts at zero in October 2026 for everyone subject to the work rule. 10-144 CMR ch. 301, FS 111-7(2)(B) (Maine SNAP rule)
January 2027 — Closures pause for three months, October, November and December 2026, right after Maine's three-year count resets October 1, 2026. This second wave is smaller than the first. It includes only people who had used some but not all of their three months when the count returned to zero, plus people who joined or came back onto the program in the months around the reset. Renewal-by-renewal closures for adults newly required to meet the work rule continue from January 2027 onward. 10-144 CMR ch. 301, FS 111-7(2)(B) (Maine SNAP rule)
Adults 18 to 54 without children at home in 213 towns whose exemption ended September 30, 2025 reached the three-month limit together in February 2026. People already enrolled who became newly subject under the 2025 law are picked up at their next recertification, so closures arrive a few at a time from March 2026 through September 2026. The state's three-year clock resets in October 2026. After the reset, people who had used some but not all of their three months, plus anyone who joined shortly before the reset, reach the limit together in January 2027. Renewal-by-renewal closures resume from January 2027. 10-144 CMR ch. 301, FS 111-5 (current rule, filing 2026-115, amended May 17 2026)
Rolling
| First countable month — people newly subject under the 2025 law | Dec 2025 (federal default) |
|---|---|
| First elimination month | Mar 2026 |
| 36-month reset | Jul 2026 |
| Pause and resume | Jul 2026–Sep 2026 → resumes Oct 2026 |
| Rolling closures | Mar 2026–Jun 2026 |
December 2025 — Maryland's Action Transmittal 26-09 says the updated screening applies to active cases beginning November 1, 2025, the next time a person is screened. This wider definition covers people ages 55 to 64, parents whose only children at home are 14 or older, veterans, homeless people, and former foster youth. No month before December 2025 counts anywhere in the country, so December 2025 is the earliest month that can count for them, under the federal default. Maryland FIA Action Transmittal 26-09 (issued Oct. 16, 2025)
March 2026 to June 2026 — Maryland screens for the work rules only at certification, at redetermination, or when a household reports a change, including at a Maryland Benefit Review. Because of that, people newly covered by the 2025 federal law lose benefits a few at a time throughout this period, as their individual cases come up for review between March 2026 and June 2026. Maryland SNAP Manual, Section 106.3 (Screening)
July 2026 — Maryland runs the time limit on a statewide count that ends June 30, 2026. A new three-year count begins for everyone on July 1, 2026. Maryland SNAP Manual, Section 106.2 (General Requirements)
October 2026 — After the reset, the three months July, August, and September 2026 are a pause in which no one can reach the limit. In October 2026 everyone still subject to the limit reaches it together, three counted months after the reset. Renewal-by-renewal closures then continue from October 2026 onward. Maryland SNAP Manual, Section 106.2 (General Requirements)
People already enrolled who became newly subject under the 2025 law are picked up at their next recertification, so closures arrive a few at a time from March 2026 through June 2026. The state's three-year clock resets in July 2026. After the reset, everyone still subject to the limit gets three fresh months, so anyone not meeting the work requirement through the pause reaches the limit together in October 2026. Renewal-by-renewal closures resume from October 2026. Maryland FIA Action Transmittal 26-09 (issued Oct 16 2025, effective Nov 1 2025)
Rolling
| First countable month — people newly subject under the 2025 law | Dec 2025 (federal default) |
|---|---|
| First elimination month | Mar 2026 |
| 36-month reset | Jan 2027 |
| Pause and resume | Jan 2027–Mar 2027 → resumes Apr 2027 |
| Rolling closures | Mar 2026–Dec 2026 |
December 2025 — Massachusetts's Department of Transitional Assistance says its wider definition of who must meet the three-month work limit took effect November 1, 2025, covering people ages 55 to 64, parents whose only children at home are 14 or older, veterans, homeless people, and former foster youth. No month before December 2025 counts anywhere in the country, so December 2025 is the earliest month that can count for them, under the federal default. Mass.gov DTA, November 2025 SNAP Updates
March 2026 to December 2026 — Massachusetts's Department of Transitional Assistance checks people against the new work rules only at their next application or annual renewal, and tells clients not to contact the agency about the rules before then. Because of that, people newly covered by the 2025 federal law lose benefits a few at a time throughout this period, as their individual cases come up between March 2026 and December 2026. Mass.gov DTA, November 2025 SNAP Updates
January 2027 — Massachusetts runs the time limit on a statewide count that ends December 31, 2026. A new three-year count begins for everyone on January 1, 2027. Massachusetts DTA Online Guide (BEACON), ABAWD Clock page
April 2027 — After the reset, the three months January, February, and March 2027 are a pause in which no one can reach the limit. In April 2027 everyone still subject to the limit reaches it together, three counted months after the reset. Renewal-by-renewal closures then continue from April 2027 onward. Massachusetts DTA Online Guide (BEACON), ABAWD Clock page
People already enrolled who became newly subject under the 2025 law are picked up at their next recertification, so closures arrive a few at a time from March 2026 through December 2026. The state's three-year clock resets in January 2027. After the reset, everyone still subject to the limit gets three fresh months, so anyone not meeting the work requirement through the pause reaches the limit together in April 2027. Renewal-by-renewal closures resume from April 2027. Mass.gov DTA, November 2025 SNAP Updates
Cliff
| Waiver end(s) | Feb 2026 |
|---|---|
| First countable month — people newly subject under the 2025 law | Dec 2025 |
| First elimination month | Mar 2026 |
| 36-month reset | Jan 2028 |
December 2025 — Adults newly required to meet Michigan's work rule under the 2025 federal law, meaning people ages 55 to 64, parents whose youngest child is 14 to 17, veterans, homeless people, and former foster youth, could start counting toward the three-month limit as early as December 2025. The same date applies to adults without children at home in the near-statewide area whose county exemption, which had paused work requirements, ended February 28, 2026, because Michigan's worker manual sets December 1, 2025 as when nearly the whole state became subject to the rule, well before the exemption's stated end date. Michigan has not resolved the conflict between these two dates in its own documents. Michigan's manual says people are screened for exceptions at application, at renewal, when someone joins the household, or when they newly become subject to the rule, and are re-screened before a month counts against them. MDHHS BEM 620, Time Limited Food Assistance (eff. 4-1-2026)
March 2026 — Adults newly required to meet the work rule under the 2025 federal law, and adults without children at home in the near-statewide area whose county exemption ended February 28, 2026, who had not met the work rule reached the three-month limit together and lost benefits in March 2026. MDHHS BEM 620, Time Limited Food Assistance (eff. 4-1-2026)
January 2028 — Michigan's three-year count restarts at zero in January 2028 for everyone subject to the work rule. MDHHS BEM 620, Time Limited Food Assistance (eff. 4-1-2026)
People newly subject under the 2025 law reached the three-month limit together in March 2026. MDHHS BEM 620, Time Limited Food Assistance (BPB 2026-008, eff. 4-1-2026), Screening
Hybrid: a cliff plus rolling closures
| Waiver end(s) | Jun 2026 |
|---|---|
| First countable month — people newly subject under the 2025 law | Jan 2026 |
| First elimination month | Jun 2026 |
| 36-month reset | Jan 2029 |
| Rolling closures | Jun 2026–Jun 2027 |
August 2025 — Minnesota estimated that the 2025 federal law would make about 27,000 more Minnesotans, meaning people ages 55 to 64, parents whose youngest child is 14 to 17, veterans, homeless people, and former foster youth, newly subject to the three-month limit. Minnesota DCYF, Federal SNAP Provisions Impact Factsheet (Aug. 2025)
January 2026 — Minnesota's fixed three-year count reset January 1, 2026 statewide, wiping every prior countable month for adults subject to the three-month limit, including adults newly required to meet the work rule under the 2025 federal law. Minnesota's clock reset January 1, 2026, but counting for the newly subject began March 2026, the month that makes the state's announced June 1, 2026 first terminations add up. Minnesota did not explain the gap. MN DHS Combined Manual 0011.24 (The 36-Month Fixed Clock)
March 2026 — Minnesota rescreens all SNAP unit members age 16 and older for every exemption at recertification, which is how it identifies adults already enrolled who become newly required to meet the work rule under the 2025 federal law. Minnesota announced that adults would first lose benefits under the three-month limit starting June 1, 2026, which under the three-month rule means their counting began in March 2026. Minnesota has not explained the two-month gap between the January 2026 clock reset and this March 2026 start. Minnesota DCYF, "SNAP work rules 'time limit' reset Jan. 1, 2026" (news release)
June 2026 — Adults newly required to meet the work rule under the 2025 federal law who had been counting since March 2026 reached the three-month limit together and lost benefits starting June 2026. Minnesota DCYF, "SNAP work rules 'time limit' reset Jan. 1, 2026" (news release)
June 2026 onward — Because Minnesota checks whether someone newly falls under the three-month limit only at recertification, adults newly required to meet the work rule lose benefits a few at a time from June 2026 onward, as their individual cases come up for review. MN DHS Combined Manual 0028.06.15 (Redetermination of an Exemption)
June 2026 — The county exemption that had paused work requirements in 17 counties and 9 reservations does not end until June 30, 2026, later than Minnesota's own January 2026 clock reset. Adults without children at home there start building up months toward the three-month limit after that date, and no closure month is shown for them because Minnesota has not published one. FNS/FNA, SNAP Waiver of the Time Limit – Status Update (Feb. 26, 2026), Appendix A
January 2029 — Minnesota's three-year count restarts at zero in January 2029 for everyone subject to the work rule. MN DHS Combined Manual 0011.24 (The 36-Month Fixed Clock)
People newly subject under the 2025 law reached the three-month limit together in June 2026. People already enrolled who became newly subject under the 2025 law are picked up at their next recertification, so closures arrive a few at a time from June 2026 onward. MN DHS Combined Manual 0011.24 (Time-limited SNAP Recipients)
Rolling
| First countable month — people newly subject under the 2025 law | Dec 2025 (federal default) |
|---|---|
| First elimination month | Mar 2026 |
| Rolling closures | Mar 2026 onward |
December 2025 — Adults newly required to meet Mississippi's work rule under the 2025 federal law, meaning people ages 55 to 64, parents whose youngest child is 14 to 17, veterans, homeless people, and former foster youth, could start counting toward the three-month limit as early as December 2025, the federal default since Mississippi has not named its own date. Mississippi's rules say a person who loses an exemption for a reason they do not have to report right away, such as turning 55, must complete the work rule requirement at their next scheduled recertification. MDHS SNAP Policy Manual, Rule 12.5(B) (Losing Exemption Status Due to Change in Circumstances)
March 2026 onward — Mississippi measures the three-year count from each person's own first application date, and checks exemption status for changes like this only at recertification, so adults newly required to meet the work rule lose benefits a few at a time from March 2026 onward, as their individual cases come up for review. MDHS SNAP Policy Manual, Rule 13.5 (Measuring the Three-Year Period)
People already enrolled who became newly subject under the 2025 law are picked up at their next recertification, so closures arrive a few at a time from March 2026 onward. MDHS SNAP Policy Manual, Rule 13.1 General Rule (Revised: May 2026)
Rolling
| First countable month — people newly subject under the 2025 law | Dec 2025 (federal default) |
|---|---|
| First elimination month | Mar 2026 |
| 36-month reset | Jul 2026 |
| Pause and resume | Jul 2026–Sep 2026 → resumes Oct 2026 |
| Rolling closures | Mar 2026–Jun 2026 |
December 2025 — Adults newly required to meet Missouri's work rule under the 2025 federal law, meaning people ages 55 to 64, parents whose youngest child is 14 to 17, veterans, homeless people, and former foster youth, could start counting toward the three-month limit as early as December 2025, the federal default since Missouri's rule changes took effect November 1, 2025. Missouri reevaluates a person's exemption status at their next scheduled recertification rather than all at once. Missouri DSS HR1 Participant FAQ
March 2026 to June 2026 — Because Missouri checks exemption status only at recertification, adults newly required to meet the work rule lose benefits a few at a time from March 2026 through June 2026, as their individual cases come up for review. Missouri DSS HR1 Participant FAQ
July 2026 — Missouri's three-year count restarts at zero in July 2026 for everyone subject to the work rule. Missouri DSS SNAP Manual 1105.035.00 (ABAWD Work Requirements)
October 2026 — After the reset, the three months July, August, and September 2026 are a pause in which no one can reach the limit. In October 2026 everyone still subject to the limit reaches it together, three counted months after the reset. Renewal-by-renewal closures then continue from October 2026 onward. Missouri DSS SNAP Manual 1105.035.00 (ABAWD Work Requirements)
People already enrolled who became newly subject under the 2025 law are picked up at their next recertification, so closures arrive a few at a time from March 2026 through June 2026. The state's three-year clock resets in July 2026. After the reset, everyone still subject to the limit gets three fresh months, so anyone not meeting the work requirement through the pause reaches the limit together in October 2026. Renewal-by-renewal closures resume from October 2026. Missouri DSS HR1 Participant FAQ (mydss.mo.gov, captured via Wayback 2026-05-21; page since retired)
Rolling
| Waiver end(s) | Jun 2026 |
|---|---|
| First countable month — people newly subject under the 2025 law | Dec 2025 (federal default) |
| First elimination month | Mar 2026 |
| 36-month reset | Jul 2026 |
| Pause and resume | Jul 2026–Sep 2026 → resumes Oct 2026 |
| Rolling closures | Mar 2026–Jun 2026 |
December 2025 — Adults newly required to meet Montana's work rule under the 2025 federal law, meaning people ages 55 to 64, parents whose youngest child is 14 to 17, veterans, homeless people, and former foster youth, could start counting toward the three-month limit as early as December 2025, the federal default since Montana's exemption rules narrowed effective November 1, 2025. Montana evaluates a person's work registration and exemptions at their simplified report or recertification, and does not apply the three-month limit to anyone until their next certification action. Montana DPHHS SNAP Manual 801-1 (ABAWD Countable Months/Exemptions)
March 2026 to June 2026 — Because Montana checks exemption status only at simplified report or recertification, adults newly required to meet the work rule lose benefits a few at a time from March 2026 through June 2026, as their individual cases come up for review. Montana DPHHS SNAP Manual 803-1 (ABAWD Disqualification/Regaining Eligibility)
July 2026 — Montana's three-year count restarts at zero in July 2026 for everyone subject to the work rule. Montana DPHHS SNAP Manual 803-1 (ABAWD Disqualification/Regaining Eligibility)
October 2026 to June 2027 — After the reset, the three months July, August, and September 2026 are a pause in which no one can reach the limit, though a county exemption that had paused work requirements in the six reservation areas also ended June 30, 2026. In October 2026 everyone still subject to the limit reaches it together, three counted months after the reset. Renewal-by-renewal closures for adults newly required to meet the work rule then continue from October 2026 onward, as more of their cases come up for review. Montana DPHHS SNAP Manual 803-1 (ABAWD Disqualification/Regaining Eligibility)
People already enrolled who became newly subject under the 2025 law are picked up at their next recertification, so closures arrive a few at a time from March 2026 through June 2026. The state's three-year clock resets in July 2026. After the reset, everyone still subject to the limit gets three fresh months, so anyone not meeting the work requirement through the pause reaches the limit together in October 2026. Renewal-by-renewal closures resume from October 2026. Montana DPHHS SNAP Manual 802-1, ABAWD Geographic Waiver (live, 2026-09-02)
Rolling
| First countable month — people newly subject under the 2025 law | Dec 2025 (federal default) |
|---|---|
| First elimination month | Mar 2026 |
| Rolling closures | Mar 2026 onward |
December 2025 — Adults newly required to meet Nebraska's work rule under the 2025 federal law, meaning people ages 55 to 64, parents whose youngest child is 14 to 17, veterans, homeless people, and former foster youth, could start counting toward the three-month limit as early as December 2025, the federal default since Nebraska's rule changes took effect October 20, 2025. Nebraska's own news release says active cases are reviewed for these changes at their next recertification, when a household member is added, or when other updates are addressed. Nebraska DHHS news release (Oct. 17, 2025)
March 2026 onward — Because Nebraska reviews these changes only at case events like recertification, adults newly required to meet the work rule lose benefits a few at a time from March 2026 onward, as their individual cases come up for review. Nebraska DHHS news release (Oct. 17, 2025)
People already enrolled who became newly subject under the 2025 law are picked up at their next recertification, so closures arrive a few at a time from March 2026 onward. Nebraska DHHS news release, Oct 17 2025
Cliff
| Waiver end(s) | Jan 2026 |
|---|---|
| First countable month — people newly subject under the 2025 law | Feb 2026 |
| First elimination month | May 2026 |
February 2026 — The 2025 federal law added people ages 55 to 64, veterans, homeless people, and former foster youth to the three-month limit for adults without children at home. Nevada checked its whole caseload against the new rules and sent notices in mid-November 2025 to people who no longer qualified for an exemption. A lawsuit delayed the change, so February 2026 was the first month that counted against the limit for people newly subject. Nevada DHS press release, 'New Federal Work Requirements Affect Certain SNAP Recipients'
February 2026 — Adults without children at home statewide, whose exemption that had paused work requirements ended January 31, 2026, also started having February 2026 count against the three-month limit. FNS/FNA waiver status update, Feb 26 2026, Appendix A
May 2026 — People newly subject and people affected by the statewide exemption's end used up their three months that count against the limit and lost benefits together on May 1, 2026, after a lawsuit had briefly pushed the deadline back from an earlier date. NV DSS official announcement, reproduced by the Nevada Registry (Mar 3, 2026)
People newly subject under the 2025 law reached the three-month limit together in May 2026. Nevada DHS press release, 'New Federal Work Requirements Affect Certain SNAP Recipients'
Cliff
| First countable month — people newly subject under the 2025 law | Dec 2025 (federal default) |
|---|---|
| First elimination month | Mar 2026 |
December 2025 — Adults newly required to meet New Hampshire's work rule under the 2025 federal law, meaning people ages 55 to 64, parents whose youngest child is 14 to 17, veterans, homeless people, and former foster youth, could start counting toward the three-month limit as early as December 2025. New Hampshire built a clock for this group effective November 1, 2025, and the state screens people for exceptions at application, at recertification, and whenever someone's status changes from exempt to required. NH DHHS Bureau of Family Assistance, SR 25-37 (signed Nov. 17, 2025)
March 2026 — New Hampshire removed the exceptions for homeless people, veterans, and former foster youth from its eligibility system for everyone at once on January 1, 2026, rather than case by case. Adults newly required to meet the work rule under the 2025 federal law who had not met it reached the three-month limit together and lost benefits in March 2026. NH DHHS Bureau of Family Assistance, SR 25-37 (signed Nov. 17, 2025), New HEIGHTS & NH EASY Systems Procedures
People newly subject under the 2025 law reached the three-month limit together in March 2026. NH DHHS Bureau of Family Assistance, SR 25-37 (signed 11/17/2025)
Cliff
| Waiver end(s) | Jan 2026 |
|---|---|
| First countable month — people newly subject under the 2025 law | Feb 2026 |
| First elimination month | May 2026 |
| 36-month reset | Feb 2027 (not confirmed) |
February 2026 — New Jersey's Division of Family Development identifies people already enrolled who are newly required to meet the work rule under the 2025 federal law, meaning people ages 55 to 64, parents whose youngest child is 14 to 17, veterans, homeless people, and former foster youth, and sends them an automatic notice rather than waiting for a renewal. February 2026 is the earliest month that could count toward the three-month limit for adults newly required to meet the work rule, the same month New Jersey's county exemption, which had paused work requirements statewide outside Camden City and Cape May County, ended January 31, 2026. NJ DFD, Federal Changes to SNAP
May 2026 — Adults newly required to meet the work rule under the 2025 federal law, and adults without children at home statewide outside Camden City and Cape May County whose county exemption ended January 31, 2026, who had not met the work rule reached the three-month limit together and lost benefits in May 2026. NJ SNAP ABAWD FAQ
February 2027 — New Jersey's own guidance describes benefits resuming for adults covered by the work rule around February 2027, though the state has not fully confirmed the exact restart date for everyone in that situation. NJ SNAP ABAWD FAQ
May 2027 — This second wave is smaller than the first. It includes only people who had used some but not all of their three months when the count returned to zero, plus people who joined or came back onto the program in the months around the reset. N.J.A.C. 10:87-10.20(b)
People newly subject under the 2025 law reached the three-month limit together in May 2026. The state's three-year clock resets in February 2027. After the reset, people who had used some but not all of their three months, plus anyone who joined shortly before the reset, reach the limit together in May 2027. NJ DFD, Federal Changes to SNAP — 'How is DFD helping SNAP recipients affected by federal changes to work requirements?'
Two cliffs
| Waiver end(s) | Dec 2025 and Dec 2026 |
|---|---|
| First countable month — people newly subject under the 2025 law | Feb 2026 |
| First elimination month | May 2026 |
| 36-month reset | Jun 2026 |
February 2026 — The 2025 federal law added people ages 55 to 64, parents whose youngest child is 14 to 17, veterans, homeless people, and former foster youth to the three-month limit for adults without children at home. New Mexico applies the change the next time each person applies for or renews SNAP on or after January 1, 2026. February 2026 was the earliest month that could count against the limit for people newly subject. NM HCA press release, Dec 17 2025
February 2026 — A separate part of the 2025 federal law ended federal SNAP eligibility for most non-citizens. New Mexico's Health Care Authority said about 19,485 lawfully present immigrants would lose that eligibility over the course of the year as they came up for renewal. New shelter, utility, and dependent-care documentation rules also took effect May 1, 2026. Because of both changes, New Mexico's spring 2026 decline blends them with the work rule. New Mexico HCA release, Feb 4 2026
May 2026 — People newly subject whose renewal fell in that first window used up their three months that count against the limit and lost benefits together in May 2026. People with later renewals reach the limit case by case as their own renewals come due. NM HCA press release, Dec 17 2025
January 2026 — Adults without children at home in the 29 counties and 18 reservations whose county exemption that had paused work requirements ended December 31, 2025, started having January 2026 count against the three-month limit. NM HCA ABAWD Q&A v3.2 (Apr 21 2026)
April 2026 — Adults in those areas used up their three months that count against the limit and lost benefits together in April 2026. NM HCA ABAWD Q&A v3.2 (Apr 21 2026)
June 2026 — New Mexico's three-year count reset to zero for everyone on June 1, 2026, starting a new three-year period that runs through May 2029. NM HCA ABAWD Q&A v3.2 (Apr 21 2026)
September 2026 to June 2027 — June, July, and August 2026 were a pause. No one could reach the limit again during those months. This second wave is smaller than the first. It includes only people who had used some but not all of their three months when the count returned to zero, plus people who joined or came back onto the program in the months around the reset. In New Mexico, this happened in September 2026. From then onward, people newly subject continued to reach the limit one renewal at a time as additional households were reviewed. NM HCA ABAWD Q&A v3.2 (Apr 21 2026)
New Mexico applies the new rules at each person's renewal or application from January 1, 2026. People whose count started in February 2026, the earliest possible month, used up their three months before the state's three-year period closed on May 31, 2026, and those who did not meet the work rule lost benefits together in May 2026. The new period opened June 1, 2026 with three fresh months for everyone, so those counted from the restart who do not meet the work rule lose benefits together in September 2026. NM HCA press release, Dec 17 2025 -- "New federal rules may affect your SNAP food benefits"
Hybrid: a cliff plus rolling closures
| Waiver end(s) | Feb 2026 |
|---|---|
| First countable month — people newly subject under the 2025 law | Mar 2026 |
| First elimination month | Jun 2026 |
| 36-month reset | Oct 2026 |
| Pause and resume | Oct 2026–Dec 2026 → resumes Jan 2027 |
| Rolling closures | Jun 2026–Sep 2026 |
March 2026 — The 2025 federal law added people ages 55 to 64, parents whose youngest child is 14 to 17, veterans, homeless people, and former foster youth to the three-month limit for adults without children at home. New York has rescreened them for exemptions at every application and renewal since November 1, 2025. March 2026 was also the first month that counted against the limit for adults without children at home in the 61 counties, including New York City, whose exemption that had paused work requirements ended February 28, 2026. OTDA 25-ADM-03-P, Background
June 2026 — People newly subject and people in those 61 counties used up their three months that count against the limit and lost benefits starting June 2026. OTDA 25-ADM-03-P, Program Implications
June 2026 — New York City's own count found that 22,200 people there lost benefits that month, about 1.3 percent of the city's SNAP caseload. City Limits, reporting NYC DSS's June 2026 count (published Jul 20 2026)
June 2026 to September 2026 — From June 2026 through September 2026, people newly subject and people from those 61 counties reached the limit one at a time as they came up for their own renewal, so closures continued a few at a time. OTDA 25-ADM-03-P, Required Action A
October 2026 — New York's three-year count reset to zero for everyone on October 1, 2026, starting a new three-year period. OTDA 25-ADM-03-P, Background
January 2027 to June 2027 — October, November, and December 2026 were a pause. No one could reach the limit again during those months. This second wave is smaller than the first. It includes only people who had used some but not all of their three months when the count returned to zero, plus people who joined or came back onto the program in the months around the reset. In New York, this started in January 2027. From then onward, people newly subject continued to reach the limit one renewal at a time as additional households were reviewed. OTDA 25-ADM-03-P, Background
People newly subject under the 2025 law reached the three-month limit together in June 2026. People already enrolled who became newly subject under the 2025 law are picked up at their next recertification, so closures arrive a few at a time from June 2026 through September 2026. The state's three-year clock resets in October 2026. After the reset, people who had used some but not all of their three months, plus anyone who joined shortly before the reset, reach the limit together in January 2027. Renewal-by-renewal closures resume from January 2027. OTDA 25-ADM-03-P (Rev 10/2025), Required Action
Rolling
| First countable month — people newly subject under the 2025 law | Dec 2025 (federal default) |
|---|---|
| First elimination month | Mar 2026 |
| 36-month reset | Jan 2028 |
| Rolling closures | Mar 2026–Jun 2027 |
December 2025 — Adults newly required to meet North Carolina's work rule under the 2025 federal law, meaning people ages 55 to 64, parents whose youngest child is 14 to 17, veterans, homeless people, and former foster youth, could start counting toward the three-month limit as early as December 2025, the federal default since the state's rule changes took effect that same month. North Carolina's own guidance tells recipients their county department of social services will screen them for exemptions at their next recertification, and the state does not assign a month against the limit until someone has been screened at application or recertification. NC DHHS FNS-260 ABAWD, Change #02-2025 (issued Nov. 26, 2025)
March 2026 onward — Because North Carolina screens for exemptions only at application or recertification, adults newly required to meet the work rule lose benefits a few at a time from March 2026 onward, as their individual cases come up for review. NCDHHS, Able-Bodied Adults Without Dependents (ABAWDs) consumer page
January 2028 — North Carolina's three-year count restarts at zero in January 2028 for everyone subject to the work rule. NC DHHS FNS-260 ABAWD, Change #02-2025, Section 260.03
People already enrolled who became newly subject under the 2025 law are picked up at their next recertification, so closures arrive a few at a time from March 2026 onward. NCDHHS ABAWD consumer page (current)
Rolling
| Waiver end(s) | Jun 2026 |
|---|---|
| First countable month — people newly subject under the 2025 law | Dec 2025 (federal default) |
| First elimination month | Mar 2026 |
| Rolling closures | Mar 2026 onward |
December 2025 — People ages 55 to 64, parents whose youngest child is 14 to 17, veterans, homeless people, and former foster youth became newly subject to North Dakota's three-month limit under the 2025 federal law. December 2025 is the first month that can count against the limit for them, the federal default because North Dakota has not named its own date. North Dakota has not published an instrument for finding people already enrolled who became newly subject to the limit, so the federal default applies them at their next standard renewal review. North Dakota's caseload held roughly flat in March and April 2026, the months closures were expected to begin, which fits a pattern of people losing benefits one at a time at renewal rather than all at once; this reading is inferred from the caseload. ND SNAP Policy Manual, Section 401 Overview
March 2026 onward — Closures for people newly subject to North Dakota's three-month limit arrive a few at a time as households come up for their standard renewal review, starting in March 2026 and continuing for as long as the rule is in force. ND SNAP Policy Manual, Section 1005 Recertification (Standard Renewals)
June 2026 — Rolette County and the Turtle Mountain Reservation have a county exemption that had paused work requirements there; it is scheduled to end June 30, 2026. This is a fact about the exemption's end date, not a predicted wave of closures. FNS/FNA, SNAP Waiver of the Time Limit — Status Update (Feb. 26, 2026), Appendix A
The state has published no instrument for finding people already enrolled who became newly subject; the federal default applies them at renewal, so closures arrive a few at a time from March 2026 onward (inferred from the caseload). ND SNAP Policy Manual, Section 401 Overview (Screening of ABAWD Status)
Cliff
| First countable month — people newly subject under the 2025 law | Mar 2026 |
|---|---|
| First elimination month | Jun 2026 |
February 2026 — The 2025 federal law added people ages 55 to 64, parents whose youngest child is 14 to 17, veterans, homeless people, and former foster youth to the three-month limit for adults without children at home. Starting November 1, 2025, Ohio checked its entire caseload against the new rules through its Ohio Benefits Worker Portal, then applied the changes to everyone at once when the portal updated on February 1, 2026. February 2026 was the first month that counted against the limit for people newly subject. ODJFS Food Assistance Change Transmittal No. 107 (Oct 16, 2025)
May 2026 — People newly subject used up their three months that count against the limit and lost benefits together in May 2026. Ohio Administrative Code 5101:4-3-13(C)(1)
People newly subject under the 2025 law reached the three-month limit together in June 2026. ODJFS Food Assistance Change Transmittal No. 107 (Oct 16, 2025), Ohio Benefits Implementation
Rolling
| First countable month — people newly subject under the 2025 law | Dec 2025 (federal default) |
|---|---|
| First elimination month | Mar 2026 |
| Rolling closures | Mar 2026 onward |
December 2025 — People ages 55 to 64, parents whose youngest child is 14 to 17, veterans, homeless people, and former foster youth became newly subject to the three-month limit under the 2025 federal law. Oklahoma's Rule Impact Statement 25-08 says agency staff must re-screen these members for eligibility at their next certification or certification renewal. Because November 2025 does not count anywhere in the country, December 2025 is the first month that can count against them. OKDHS Rule Impact Statement 25-08 (live-fetched 2026-09-04)
March 2026 onward — Starting in March 2026 and continuing for as long as the rule is in force, Oklahoma picks up newly subject people one at a time, at their certification renewal. OKDHS Rule Impact Statement 25-08 (live-fetched 2026-09-04)
People already enrolled who became newly subject under the 2025 law are picked up at their next recertification, so closures arrive a few at a time from March 2026 onward. OAC 340:50-5-100(d), retrieved live 2026-09-02
Rolling
| Waiver end(s) | Dec 2025 |
|---|---|
| First countable month — people newly subject under the 2025 law | Oct 2025 |
| First elimination month | Feb 2026 |
| 36-month reset | Jan 2028 |
| Rolling closures | Feb 2026–Jun 2027 |
October 2025 — The 2025 federal law added people ages 55 to 64, parents whose youngest child is 14 to 17, veterans, homeless people, and former foster youth to the three-month limit for adults without children at home. In the six counties that had never had a county exemption pausing work requirements, Oregon mass-notified people newly subject who had applied or renewed between July 4 and October 1, 2025, around October 15, 2025. October 2025 was the first month that counted against the limit for them. Oregon ODHS Federal Updates page
February 2026 — The cliff in February 2026 is people newly subject under the 2025 law in the six counties Oregon began enforcing October 1, 2025 (they were notified in October). They used up their three counted months, October, December and January, and lost benefits together in February 2026. Oregon Administrative Rule 461-135-0520(2)
February 2026 onward — People already enrolled elsewhere in Oregon who became newly subject under the 2025 law are picked up only when their case comes up for a regular renewal, so closures arrive a few at a time from February 2026 onward. Adults without children at home in the 30 counties whose exemption that had paused work requirements ended December 31, 2025 join this pattern starting April 2026, as their own renewals come up. Oregon Administrative Rule 461-135-0520(9)(b)
January 2028 — Oregon's three-year count will reset to zero for everyone on January 1, 2028. Oregon Administrative Rule 461-135-0520(3)
Oregon reviews people at application or renewal, so closures arrive a few at a time: from February 2026 in the six never-waived counties and from April 2026 in the 30 formerly waived counties. OAR 461-135-0520(3), Time Limit and Special Requirements for ABAWD; SNAP
Rolling
| Waiver end(s) | Aug 2025 |
|---|---|
| First countable month — people newly subject under the 2025 law | Dec 2025 (federal default) |
| First elimination month | Mar 2026 |
| 36-month reset | Jan 2027 |
| Pause and resume | Jan 2027–Mar 2027 → resumes Apr 2027 |
| Rolling closures | Mar 2026–Dec 2026 |
December 2025 — The 2025 federal law added people ages 55 to 64, parents whose youngest child is 14 to 17, veterans, homeless people, and former foster youth to the three-month limit for adults without children at home. Pennsylvania's Ops Memo 25-10-02 lets people who already held an exemption for being a veteran, being homeless, or having aged out of foster care keep that exemption until their next full renewal, when the office screens them again. The memo does not say whether people already enrolled who are age 55 to 64 get the same treatment; new applicants in that age group are screened right away. December 2025 was the earliest month that could count against the limit for people newly subject. PA DHS OIM Ops Memo #25-10-02 (Oct 27 2025)
March 2026 to December 2026 — From March 2026 through December 2026, people newly subject reached the limit one at a time as they came up for their own renewal, so closures continued a few at a time. PA DHS OIM Ops Memo #25-10-02 (Oct 27 2025)
September 2025 — Adults without children at home statewide, whose exemption that had paused work requirements ended August 31, 2025, started having September 2025 count against the limit. Pennsylvania mailed them a screening form to check for other exemptions. PA DHS OIM Ops Memo #25-08-03 (Aug 19 2025)
January 2026 — Adults whose exemption had ended used up their three months that count against the limit and lost benefits together in January 2026. Pennsylvania has not published this date; it comes from this project's own count of Pennsylvania's countable months. PA SNAP Handbook 536.11
January 2027 — Pennsylvania's three-year count reset to zero for everyone on January 1, 2027, starting a new three-year period that runs through December 31, 2029. PA SNAP Handbook 536.11
April 2027 to June 2027 — January, February, and March 2027 were a pause. No one could reach the limit again during those months. This second wave is smaller than the first. It includes only people who had used some but not all of their three months when the count returned to zero, plus people who joined or came back onto the program in the months around the reset. In Pennsylvania, this is expected in April 2027. Renewal-by-renewal closures continue from April 2027 onward, as more of their cases come up for review. PA SNAP Handbook 536.3
Adults 18 to 54 without children at home statewide whose exemption ended August 31, 2025 reached the three-month limit together in January 2026. People already enrolled who became newly subject under the 2025 law are picked up at their next recertification, so closures arrive a few at a time from March 2026 through December 2026. The state's three-year clock resets in January 2027. After the reset, people who had used some but not all of their three months, plus anyone who joined shortly before the reset, reach the limit together in April 2027. Renewal-by-renewal closures resume from April 2027. PA DHS OIM Ops Memo #25-08-03 (Aug 19 2025), CM 558 Mass Mailing
Cliff
| Waiver end(s) | Feb 2026 |
|---|---|
| First countable month — people newly subject under the 2025 law | Mar 2026 |
| First elimination month | Jun 2026 |
| 36-month reset | Sep 2026 |
March 2026 — The 2025 federal law added people ages 55 to 64, parents whose youngest child is 14 to 17, veterans, homeless people, and former foster youth to the three-month limit for adults without children at home. Rhode Island delayed the start of this change to March 1, 2026 statewide, and told people affected they would get additional notices. RI DHS 'Stay Covered' SNAP Updates, Jan 9 2026 entry
March 2026 — March 2026 was also the first month that counted against the limit for adults without children at home in New Shoreham and eight other cities and towns, including Providence and Pawtucket, whose exemption that had paused work requirements ended February 28, 2026. FNS/FNA 'SNAP Waiver of the Time Limit - Status Update' (Feb 26 2026), Appendix A
June 2026 — People newly subject and people in those cities and towns used up their three months that count against the limit and lost benefits together in June 2026. RI SNAP Rules and Regulations, 218-RICR-20-00-1 Section 1.11.9(A)(3)
September 2026 — Rhode Island's three-year count reset to zero for everyone on September 1, 2026, starting a new three-year period that runs through August 31, 2029. RI DHS clock-reset notice, 'Attention SNAP Customers' (Jul 29 2026)
December 2026 — This second wave is smaller than the first. It includes only people who had used some but not all of their three months when the count returned to zero, plus people who joined or came back onto the program in the months around the reset. In Rhode Island, this happened in December 2026. RI DHS clock-reset notice, 'Attention SNAP Customers' (Jul 29 2026)
People newly subject under the 2025 law reached the three-month limit together in June 2026. The state's three-year clock resets in September 2026. After the reset, people who had used some but not all of their three months, plus anyone who joined shortly before the reset, reach the limit together in December 2026. RI DHS 'Stay Covered' - SNAP Updates, 1/9/2026 SNAP ABAWD Update
Rolling
| First countable month — people newly subject under the 2025 law | Dec 2025 (federal default) |
|---|---|
| First elimination month | Mar 2026 |
| 36-month reset | Apr 2028 |
| Rolling closures | Mar 2026–Jun 2027 |
March 2026 — The 2025 federal law added people ages 55 to 64, parents whose youngest child is 14 to 17, veterans, homeless people, and former foster youth to the three-month limit for adults without children at home. South Carolina's new rules took effect February 2, 2026, and the state finds people newly subject only at their next application, renewal, or reported change. Because that effective date fell in the middle of the month, March 2026 is the first full month that counts toward the limit. SCDSS news release, 'New Federal SNAP Work Requirements Take Effect in South Carolina' (Feb 2, 2026)
June 2026 onward — Because South Carolina finds people newly subject case by case, closures arrive a few at a time, from June 2026 onward, as households come up for their own renewal. SCDSS SNAP Manual Volume 69, Section 8.13
April 2028 — South Carolina's three-year count will reset to zero for everyone on April 1, 2028. Adults without children at home ages 18 to 54 have had no county exemption pausing work requirements since September 2023, so they were already enforced under the ordinary three-month limit before the 2025 law. SCDSS SNAP Manual Volume 69, Section 8.18
People already enrolled who became newly subject under the 2025 law are picked up at their next recertification, so closures arrive a few at a time from March 2026 onward. SCDSS SNAP Manual Volume 69, Section 8.13 ABAWD Determination
Rolling
| Waiver end(s) | Sep 2025 |
|---|---|
| First countable month — people newly subject under the 2025 law | Dec 2025 (federal default) |
| First elimination month | Mar 2026 |
| 36-month reset | Dec 2026 |
| Pause and resume | Dec 2026–Feb 2027 → resumes Mar 2027 |
| Rolling closures | Mar 2026–Nov 2026 |
December 2025 — The 2025 federal law added people ages 55 to 64, parents whose youngest child is 14 to 17, veterans, homeless people, and former foster youth to the three-month limit for adults without children at home. South Dakota finds people newly subject at their next application, renewal, or six-month report. December 2025 was the earliest month that could count against the limit for them. South Dakota SNAP Manual, Section 13241
March 2026 to November 2026 — From March 2026 through November 2026, people newly subject reached the limit one at a time as they came up for their own renewal or report, so closures continued a few at a time. South Dakota SNAP Manual, Section 13240
October 2025 — Adults without children at home in the 7 counties and 6 reservations whose exemption that had paused work requirements ended September 30, 2025, started having October 2025 count against the limit. FNS South Dakota ABAWD Waiver Response (Aug 12, 2024)
February 2026 — Adults in those counties and reservations used up their three months that count against the limit and lost benefits together in February 2026. South Dakota SNAP Manual, Section 13210
December 2026 — South Dakota's three-year count resets to zero for everyone every December, starting a new three-year period at that time. South Dakota SNAP Manual, Section 13241
March 2027 to June 2027 — December 2026, January 2027, and February 2027 were a pause. No one could reach the limit again during those months. This second wave is smaller than the first. It includes only people who had used some but not all of their three months when the count returned to zero, plus people who joined or came back onto the program in the months around the reset. In South Dakota, this is expected in March 2027. Renewal-by-renewal closures continue from March 2027 onward, as more of their cases come up for review. South Dakota SNAP Manual, Section 13241
Adults 18 to 54 without children at home in 7 counties and 6 reservations whose exemption ended September 30, 2025 reached the three-month limit together in February 2026. People already enrolled who became newly subject under the 2025 law are picked up at their next recertification, so closures arrive a few at a time from March 2026 through November 2026. The state's three-year clock resets in December 2026. After the reset, people who had used some but not all of their three months, plus anyone who joined shortly before the reset, reach the limit together in March 2027. Renewal-by-renewal closures resume from March 2027. South Dakota SNAP Manual, section 13240 Time Limits (ABAWD)
Cliff
| First countable month — people newly subject under the 2025 law | Dec 2025 (federal default) |
|---|---|
| First elimination month | Mar 2026 |
| 36-month reset | Jan 2028 |
December 2025 — People ages 55 to 64, parents whose youngest child is 14 to 17, veterans, homeless people, and former foster youth became newly subject to Tennessee's three-month limit under the 2025 federal law. December 2025 is the first month that can count against the limit for them, the federal default because Tennessee has not named its own date. The Tennessee Department of Human Services handles this by mailing each person a letter about their own case, rather than screening everyone already enrolled at once. Tennessee's caseload stayed flat and then rose from March through July 2026, which fits a letter-by-letter approach rather than a single wave of closures; this reading is inferred from the caseload. Tennessee DHS SNAP ABAWD Information page
March 2026 onward — Closures for people newly subject to Tennessee's three-month limit arrive a few at a time as households come up for renewal, starting in March 2026 and continuing for as long as the rule is in force. FNS OBBB ABAWD Exceptions Implementation Memorandum (Oct. 3, 2025)
January 2028 — Tennessee's three-year count will reset to zero for everyone on January 1, 2028. Tennessee DHS SNAP ABAWD Information page
Tennessee set one deadline, October 31, 2025, for everyone who thought they were exempt to upload proof, so the newly subject group started counting together in December 2025. By our count, anyone in it who did not meet the work rule lost benefits together in March 2026. Tennessee has not published this month. Tennessee DHS news release, "New Federal Law Updates SNAP Work Requirements for ABAWDs in Tennessee", September 22, 2025
Rolling
| First countable month — people newly subject under the 2025 law | Dec 2025 (federal default) |
|---|---|
| First elimination month | Mar 2026 |
| Rolling closures | Mar 2026 onward |
December 2025 — The 2025 federal law expanded the three-month limit for adults without children at home to include people ages 55 to 64, parents whose youngest child is 14 to 17, veterans, homeless people, and former foster youth. Texas has not named the month this starts counting for people already receiving benefits. This page uses the federal default rule that the shutdown month, November 2025, does not count, so December 2025 is the earliest month that could count against them. Texas identifies these people when they apply for benefits, recertify, or report a change such as their work hours falling below an average of 20 hours a week. USDA FNS ABAWD Exceptions Implementation Memorandum (Oct. 3, 2025)
March 2026 onward — Texas checks whether a person newly covered by the wider rules is subject to the limit only when they apply for benefits, renew their benefits, or report a change, not all at once. Because of that, people newly subject to the limit lose benefits a few at a time throughout this period, as their individual cases come up for review. Texas HHSC Bulletin 25-16 (Oct. 1, 2025)
People already enrolled who became newly subject under the 2025 law are picked up at their next recertification, so closures arrive a few at a time from March 2026 onward. Texas Works Handbook A-1910, General Policy, retrieved live 2026-09-02
Rolling
| First countable month — people newly subject under the 2025 law | Dec 2025 (federal default) |
|---|---|
| First elimination month | Mar 2026 |
| Rolling closures | Mar 2026 onward |
December 2025 — People ages 55 to 64, parents whose youngest child is 14 to 17, veterans, homeless people, and former foster youth became newly subject to Utah's three-month limit under the 2025 federal law. December 2025 is the first month that can count against the limit for them, because November 2025, the shutdown month, does not count. Utah has not published an instrument for finding people already enrolled who became newly subject to the limit, so the federal default applies them at their next renewal. Utah's caseload declined smoothly from March 2026 onward, only slightly faster than its prior pace, which fits people losing benefits one at a time at renewal rather than in one large wave; this reading is inferred from the caseload. Utah DWS Eligibility Manual 341, ABAWD Time Limits
March 2026 onward — Closures for people newly subject to Utah's three-month limit arrive a few at a time as households come up for renewal or report a change in status, starting in March 2026 and continuing for as long as the rule is in force. Utah gives a 10-day advance notice before ending benefits once a status change is processed. Utah DWS Eligibility Manual 341-7, ABAWD - Change in Status
The state has published no instrument for finding people already enrolled who became newly subject; the federal default applies them at renewal, so closures arrive a few at a time from March 2026 onward (inferred from the caseload). UT DWS Eligibility Manual 341-7 (ABAWD - Change in Status)
Cliff
| First countable month — people newly subject under the 2025 law | Dec 2025 (federal default) |
|---|---|
| First elimination month | Mar 2026 |
| 36-month reset | Nov 2025 |
November 2025 — Vermont runs the three-month limit for adults without children at home on a statewide three-year clock. That clock reset on this date, giving everyone with a work requirement a fresh count of three allowed months. Vermont AHS/DCF legislative report, 'Changes to the Administration of the SNAP Program' (Sept. 15, 2025)
December 2025 — Vermont's human services agency used case data to identify about 4,000 people who either lost an exemption or became newly subject to the three-month limit under the 2025 federal law, rather than waiting for each person's application or renewal. Using the federal default rule that the shutdown month, November 2025, does not count, December 2025 is the earliest month that could count against them. Vermont DCF news release (Oct. 7, 2025)
March 2026 — The people Vermont identified through case data who had not met the work requirement reached the three-month limit together and lost benefits. USDA FNS memo, SNAP Benefit Issuance and the FY26 Appropriations Act (Nov. 13, 2025)
People newly subject under the 2025 law reached the three-month limit together in March 2026. VT DCF news release, Oct 7, 2025
Rolling
| First countable month — people newly subject under the 2025 law | Dec 2025 (federal default) |
|---|---|
| First elimination month | Mar 2026 |
| Rolling closures | Mar 2026 onward |
December 2025 — People ages 55 to 64, parents whose youngest child is 14 to 17, veterans, homeless people, and former foster youth became newly subject to Virginia's three-month limit under the 2025 federal law. December 2025 is the first month that can count against the limit for them, the federal default because Virginia has not named its own date. Virginia has not published an instrument for finding people already enrolled who became newly subject to the limit; its FAQ mentions a mailed notice about the new work requirement but does not say when it was sent or who received it. Virginia's caseload swung up and down from November 2025 through February 2026, which the state attributes to the federal shutdown and to the timing of benefit issuance, not to closures under this rule; this reading is inferred from the caseload. VDSS SNAP Requirements FAQ
March 2026 onward — Closures for people newly subject to Virginia's three-month limit arrive a few at a time as households come up for renewal, starting in March 2026 at the earliest. This date is stated here only as a floor, not a confirmed wave. VDSS SNAP Manual, Part XV.B (Transmittal #36, Oct. 2025)
June 2025 — Adults without children at home in Brunswick, Buchanan, Danville, Dickenson, Dinwiddie, Emporia, Greensville, Hopewell, Martinsville, Petersburg, Surry, and Sussex had a county exemption that had paused work requirements end June 30, 2025, before the 2025 federal law was signed, so this change is not part of the law and is not shown as a wave on this timeline. VDSS SNAP Manual Transmittal #36, Part XV Appendix I (Oct. 2025)
The state has published no instrument for finding people already enrolled who became newly subject; the federal default applies them at renewal, so closures arrive a few at a time from March 2026 onward (inferred from the caseload). VDSS SNAP Requirements FAQ
Rolling
| Waiver end(s) | Jan 2026 |
|---|---|
| First countable month — people newly subject under the 2025 law | Feb 2026 |
| First elimination month | May 2026 |
| 36-month reset | Jan 2027 |
| Pause and resume | Jan 2027–Mar 2027 → resumes Apr 2027 |
| Rolling closures | May 2026–Dec 2026 |
February 2026 — A statewide exemption that had paused Washington's three-month limit for adults without children at home ended January 31, 2026. The 2025 federal law also newly covered people ages 55 to 64, parents whose youngest child is 14 to 17, veterans, homeless people, and former foster youth. Washington checks a person's status only when they apply, renew benefits, or report a change. February 2026 is the earliest month that could count toward the limit for anyone screened after that date. Washington DSHS EA-Z Manual, ABAWD chapter
May 2026 to December 2026 — Because Washington checks each person's status only at their own application or renewal, people newly subject to the limit and people whose statewide exemption ended lose benefits a few at a time throughout this period, as their individual cases come up for review. Washington DSHS EA-Z Manual, ABAWD chapter
January 2027 — Washington's statewide three-year clock resets, and everyone's count of months toward the limit returns to zero. Washington DSHS EA-Z Manual, ABAWD chapter
April 2027 to June 2027 — After the reset, the three months January, February, and March 2027 are a pause in which no one can reach the limit. In April 2027 everyone still subject to the limit reaches it together, three counted months after the reset. Renewal-by-renewal closures then continue from April 2027 onward, as individual cases come up for review. Washington DSHS EA-Z Manual, ABAWD chapter
People already enrolled who became newly subject under the 2025 law are picked up at their next recertification, so closures arrive a few at a time from May 2026 through December 2026. The state's three-year clock resets in January 2027. After the reset, everyone still subject to the limit gets three fresh months, so anyone not meeting the work requirement through the pause reaches the limit together in April 2027. Renewal-by-renewal closures resume from April 2027. WA DSHS EA-Z Manual, ABAWD chapter — Screening for exceptions
Rolling
| First countable month — people newly subject under the 2025 law | Dec 2025 (federal default) |
|---|---|
| First elimination month | Mar 2026 |
| 36-month reset | Jan 2028 |
| Rolling closures | Mar 2026–Jun 2027 |
December 2025 — People ages 55 to 64, parents whose youngest child is 14 to 17, veterans, homeless people, and former foster youth became newly subject to West Virginia's three-month limit under the 2025 federal law, effective November 1, 2025. December 2025 is the first month that can count against the limit for them, because November 2025, the shutdown month, does not count. West Virginia has not published an instrument for finding people already enrolled who became newly subject to the limit beyond the general screening required at application and at redetermination. West Virginia's caseload rose in March 2026, the month closures were expected to begin, so no single wave is visible there; this reading is inferred from the caseload. West Virginia Income Maintenance Manual, Chapter 3, Section 3.2.1.D.1.a
March 2026 onward — Closures for people newly subject to West Virginia's three-month limit arrive a few at a time as households come up for redetermination, starting in March 2026 and continuing for as long as the rule is in force. West Virginia Income Maintenance Manual, Chapter 1, Section 1.2.3.A, Worker Responsibilities
November 2025 — West Virginia itself said it expected these changes to affect approximately 36,000 SNAP recipients in the state. West Virginia DoHS/BFA news release (Nov. 3, 2025; live page now 404s, archived copy shown)
January 2028 — West Virginia runs the limit on a statewide count that ends December 31, 2027, so a new three-year count begins for everyone on this date. West Virginia DoHS/BFA, ABAWD Requirements fact sheet
The state has published no instrument for finding people already enrolled who became newly subject; the federal default applies them at renewal, so closures arrive a few at a time from March 2026 onward (inferred from the caseload). WV Income Maintenance Manual, Chapter 1, §1.2.3.A Worker Responsibilities
Rolling
| Waiver end(s) | Sep 2025 |
|---|---|
| First countable month — people newly subject under the 2025 law | Dec 2025 (federal default) |
| First elimination month | Mar 2026 |
| 36-month reset | Jan 2028 |
| Rolling closures | Mar 2026–Jun 2027 |
October 2025 — The Wisconsin exemption that had paused the three-month limit ended October 1, 2025 in the City of Racine and eight counties: Adams, Bayfield, Douglas, Florence, Forest, Iron, Marquette, and Menominee. Adults without children at home there who were not working started building up months toward the limit. Wisconsin DHS DMS Operations Memo 25-14 (Sept. 16, 2025)
December 2025 — The 2025 federal law newly covers people ages 55 to 59 and parents whose only children at home are 14 to 17. Wisconsin's Operations Memo 26-04 says this applies to new applicants right away and to people already enrolled at their application or next renewal, starting December 1, 2025. December 2025 is the earliest month that could count against them. Wisconsin DHS DMS Operations Memo 26-04 (Feb. 6, 2026)
February 2026 — People in the City of Racine and the eight counties whose exemption had ended who had not met the work requirement reached the three-month limit together and lost benefits. Wisconsin FoodShare Handbook 3.17.1, Work Requirements for ABAWDs
March 2026 onward — Starting March 1, 2026, the same 2025 federal law newly covers people ages 60 to 64, veterans, homeless people, and former foster youth, at their application or next renewal. Wisconsin checks everyone newly covered by these wider rules only when they apply or renew, so people in these groups lose benefits a few at a time from March 2026 onward. Wisconsin DHS DMS Operations Memo 26-04 (Feb. 6, 2026)
January 2028 — Wisconsin's statewide three-year clock ends December 31, 2027, so a new count of allowed months begins for everyone on this date. Wisconsin DHS DMS Operations Memo 25-14 (Sept. 16, 2025)
Adults 18 to 54 without children at home in the City of Racine and 8 counties whose exemption ended September 30, 2025 reached the three-month limit together in February 2026. People already enrolled who became newly subject under the 2025 law are picked up at their next recertification, so closures arrive a few at a time from March 2026 onward. WI DHS DMS Operations Memo 26-04 (Feb 6, 2026), Background
Rolling
| First countable month — people newly subject under the 2025 law | Oct 2025 |
|---|---|
| First elimination month | Feb 2026 |
| 36-month reset | Oct 2027 |
| Rolling closures | Feb 2026–Jun 2027 |
December 2025 — People ages 55 to 64, parents whose youngest child is 14 to 17, veterans, homeless people, and former foster youth became newly subject to Wyoming's three-month limit under the 2025 federal law. December 2025 is the first month that can count against the limit for them, because November 2025, the shutdown month, does not count. Wyoming has not published an instrument for finding people already enrolled who became newly subject to the limit; it checks a person's status only when they apply for benefits or report a change. Wyoming's caseload rose in March, April, and May 2026, so there was no single month of closures; its November 2025 dip matches Utah's and reflects the federal shutdown, not this rule; this reading is inferred from the caseload. Wyoming SNAP and POWER Policy Manual, Section 708, part E
March 2026 onward — Closures for people newly subject to Wyoming's three-month limit arrive a few at a time as households come up for application or a status change, starting in March 2026 and continuing for as long as the rule is in force. FNS memo, Nov. 13, 2025 — Time Limited Participants, Countable Months
July 2025 — Wyoming's policy manual dates this wider coverage to July 4, 2025, the day the 2025 federal law was enacted. Wyoming checks a person's status only when they apply for benefits or have a status change, not on any other schedule. Wyoming SNAP and POWER Policy Manual, Section 708, part A
October 2027 — Wyoming runs the limit on a statewide count that ends September 30, 2027, so a new three-year count begins for everyone on this date. Wyoming SNAP and POWER Policy Manual, Section 708, General Rule
The state has published no instrument for finding people already enrolled who became newly subject; the federal default applies them at renewal, so closures arrive a few at a time from February 2026 onward (inferred from the caseload). WY SNAP and POWER Policy Manual, Section 708 ABAWD Requirements, part E