Currently, able-bodied adults without dependents (ABAWDs) between the ages of 18 and 54 must meet work requirements to receive Supplemental Nutrition Assistance Program (SNAP) benefits. Failure to meet these requirements for three consecutive months results in ineligibility for benefits until the end of a three-year period, earning this rule the name “the time limit.” States can apply for waivers to exempt ABAWDs living in areas with struggling labor markets from this time limit. When a waiver is in place, ABAWDs unable to find work are not penalized for failing to meet the work requirement.
The One Big Beautiful Bill Act (OBBBA) introduces significant changes to SNAP work requirements. It exposes additional SNAP participants to these time limit work requirements and radically alters the criteria for SNAP work requirement waivers.
Under OBBBA, states can only request waivers for areas with an unemployment rate above 10 percent, calculated as a three-month average, 12-month average, or an as-yet-undefined seasonal average. This shift aims to understand how these changes impact SNAP’s ability to function as a countercyclical program during economic contractions.
To analyze the impact of these changes, the proposed three-month 10 percent unemployment rate cutoff was applied to individual counties during the Great Recession. An interactive map illustrates how long after the start of the recession (December 2007) it took for each county in the U.S. to hit the three-month 10 percent unemployment rate threshold by state. This interactive tool allows users to zoom into the map to see how counties within each state would have fared under the new OBBBA rules. For a selected state, users can hover over individual counties to see how long they remained below the threshold and their 2008 population.
Data and Methodology
Below the map, a bar chart highlights the distribution of each state’s population among counties based on how long it took their county to reach the three-month 10 percent unemployment rate threshold. The categories include:
- Above 10% unemployment rate (three-month average) for December 2007-February 2008
- Less than 1 year
- 1-2 years
- 2-3 years
- 3-12 years
- Never (Did not reach 10 percent unemployment rate (three-month average) during the Great Recession business cycle)
Data sources include the Bureau of Labor Statistics and the Census Bureau. Unemployment data are from the Local Area Unemployment Statistics. Counties that underwent boundary changes between 2007 and 2020 are excluded from this map. The 3-12 years category includes counties that hit a three-month average unemployment rate of 10 percent by January 2020, marking the end of the Great Recession business cycle.
In the first three months of the Great Recession, which began in December 2007, only 122 counties (where 5.4 million people live) had a three-month average unemployment rate of 10 percent or higher. Within the first year, only an additional 126 counties (7.9 million people) hit a three-month average unemployment rate of 10 percent. Between the first and second years of the recession, 1,154 additional counties (126.4 million people) hit 10 percent unemployment with a three-month average. An additional 338 counties (28.2 million people) reached this threshold between years two and three, and 28 counties (1.8 million people) between years three and four. Between the fourth year and the end of the business cycle, 17 additional counties (1.0 million people) reached a three-month average unemployment rate of 10 percent or above.
Previous Waiver Criteria
Before OBBBA, states could submit SNAP work requirement waiver requests to the U.S. Department of Agriculture. These requests identified places with documented evidence of a weak labor market. The criteria included:
- A recent 12-month average unemployment rate over 10 percent
- A recent three-month average unemployment rate over 10 percent
- A historical seasonal unemployment rate over 10 percent
- Designation by the U.S. Department of Labor as a Labor Surplus Area (LSA)
- Qualification for Extended Benefits to Unemployment Insurance (EB)
- A low and declining employment-to-population ratio
- A lack of jobs in declining occupations or industries
- Description in a study or other publication as an area with a lack of jobs
- A 24-month average unemployment rate 20 percent above the national average for the same period, starting no earlier than the start of the LSA designation period for the current fiscal year
States could request waivers for the entire state, specific entities such as cities, towns, counties, Indian Reservations, or Labor Surplus Areas, or state-defined contiguous labor market areas. If approved, these waivers exempted all ABAWDs in that area from time limit work requirement-related rules and penalties.
The One Big Beautiful Bill Act (OBBBA) Changes
The One Big Beautiful Bill Act (OBBBA) makes it nearly impossible to waive work requirements by place. It radically changes the waiver criteria, allowing only places with an unemployment rate above 10 percent (as a three-month average, 12-month average, or as yet undefined “historical seasonal unemployment rate over 10 percent”) to be eligible for a waiver. Alaska and Hawaii can receive a waiver if their unemployment rate is 150 percent of the national average; these states may also temporarily exempt individuals from work requirements if they show a good faith effort toward implementation.
OBBBA also limits place-based waivers to one year; during the Great Recession, waivers could apply for up to three years. This change significantly impacts the flexibility and effectiveness of SNAP in responding to economic downturns.
