For many Supplemental Nutrition Assistance Program (SNAP) participants, receiving food assistance now depends on meeting documentation deadlines, fulfilling new work or volunteer requirements, or qualifying for an exemption. A year after implementing H.R.1, SNAP enrollment has dropped by more than 13% over the past 12 months.
The law requires most individuals previously exempt to work or volunteer at least 80 hours per month, or complete specific training and education programs, to remain eligible for benefits. Additionally, these rules have been extended to include adults up to the age of 64. Those who cannot show they work at least 20 hours a week or are exempt are limited to three months of food assistance every three years.
Where Implementation Is Breaking Down: Paperwork and Procedural Denials
Enrollment counts show how many people left but not why. The current administration points to fraud enforcement, abuse of federal programs, and the removal of ineligible people, while researchers and advocates point to the added administrative burden of new rules and verification steps. Research suggests that procedural denials, where people are turned away for not completing the process rather than for being ineligible, rather than ineligibility explain why fewer people remain enrolled in government benefit programs after work requirements are enacted. In one state’s data, nearly two in three new SNAP applications were denied, and over half of those denials were procedural. Denial rates were higher when work requirements were in effect than when they were waived.
The timeline to implement HR-1 makes this harder. The same analysis warns that the tight federal timeline for shifting costs to states makes it more likely they will try to lower error rates by restricting access and adding procedural hurdles. Wrongful denials for procedural reasons are not counted in those error rates, so tighter verification can protect payment accuracy while making it harder for eligible households to stay enrolled.
USDA’s guidance said the new rules took effect July 4, 2025, but effectively gave states until November 1, 2025, to stand up their programs. The Food Research Action Center has noted that systems changes like these typically take 12 to 18 months to do properly, and warned that moving this fast risks unintended effects elsewhere in the system. Some states reported that their systems might not be able to track the expanded requirement until spring.
Current States Facing Trouble:
Arizona: Saw the nation’s largest drop, with enrollment falling 55% from April 2025 to April 2026, totaling more than 400,000 people. The state said the decline was driven largely by its own struggles to implement the new federal requirements.
Connecticut: Relied on temporary workarounds in which caseworkers manually entered who was newly subject to the requirement while the state updated its technology. A state official said you cannot simply flip a switch in an eligibility system, and worried about integrating those manual cases once the system is updated.
Illinois: Enrollment among adults ages 18-64 fell 24.8% from October 2025 through June 2026, with declines of roughly 21% for ages 55-59 and 20% for ages 60-64. Nearly 100,000 fewer children were also enrolled.
Designing for Access: Screening for Exemptions
If the main failure is that eligible people cannot navigate the process, design is a lever states control. Code for America found that many people who should qualify for exemptions fall through the cracks because they do not know they are eligible or how to claim these exemptions. Their screener, tested with SNAP clients and community organizations, offers three design principles:
Use plain language instead of policy jargon. Clients found terms like “chronically homeless” confusing, so the screener asks whether a person has a regular place to sleep or shower, and uses concrete examples to define caregiving.
Ask sensitive questions with care. Place questions about difficult circumstances in their own section, and people who select one see an acknowledgment of their situation and a resource.
Make next steps clear. The design explains what proof is likely needed, and only for the exemptions where workers typically ask for it, reducing unnecessary paperwork.