Why Food Stamp Work Requirements Should Include More Able-Bodied Adults
Key Findings
- The number of able-bodied adults on food stamps has skyrocketed, reaching 18.5 million in 2023.
- Most able-bodied adults on food stamps are exempt from work requirements.
- States are abusing gimmicks and loopholes to waive work requirements for millions of able-bodied adults.
- Work requirements have a proven track record of success, but are currently too limited in scope, leaving millions of able-bodied adults behind.
- Expanded work requirements would save taxpayers more than $175 billion.
Overview
The food stamp program was created more than 60 years ago with the goal of helping low-income families obtain a nutritionally adequate diet.1-2 By the mid-1990s, food stamp enrollment had spiked to more than 27 million enrollees, costing taxpayers $25 billion per year.3 In announcing his candidacy for the 1992 presidential election, Bill Clinton responded to growing welfare rolls by promising to “insist that people move off welfare rolls and onto work rolls” and “demand that everybody who can work and become a productive member of society.”4
But efforts to address the growing problems plaguing food stamps and other welfare programs stalled until Newt Gingrich’s 1994 Contract with America swept Republicans into the majority for the first time in more than 40 years.5-6 After the 1994 landslide, Republicans quickly began work on major welfare reform legislation, with Speaker Gingrich shepherding the Personal Responsibility Act of 1995 through the House in just 84 days.7
Although President Clinton vetoed the legislation, many of its provisions were signed into law as part of the landmark welfare reform law the following year.8-9 Those changes include requiring some able-bodied adults to work, train, or volunteer as a condition of eligibility and requiring others to participate in training programs if assigned.10
But despite this statutory connection to work, the number of able-bodied adults on the program has exploded in recent years. Since 2000, the number of able-bodied adults on food stamps has nearly tripled—reaching 18.5 million in 2023.11-13
Most able-bodied adults on the program are exempt from work requirements and bureaucratic loopholes have allowed states to skirt them even further—waiving them for as many able-adults as possible.14 Even worse, the Obama and Biden administrations actively pressured states to continue this trend, leaving millions of able-bodied adults trapped in a cycle of dependency.15
With millions of open jobs nationwide and labor force participation rates behind pre-pandemic levels, it is more critical than ever to move able-bodied adults from welfare to work.16-17
Most able-bodied adults on food stamps are exempt from work requirements
Federal law requires some able-bodied adults to work, train, or volunteer at least part time to qualify for benefits.18 But these requirements apply only to able-bodied adults without dependents (ABAWDs), childless adults on food stamps who are under the age of 55.19-20
Separate “work registration” requirements exist for a broader population of able-bodied adults—those under the age of 60 who have no children under age six—but the requirement to engage in work activities only applies if states assign them to Employment and Training (E&T) programs—which few states ever do.21-22 In 2025, more than 93 percent of work registrants were exempt from mandatory E&T requirements.23
States have also used discretionary exemptions and waivers to bypass the ABAWD work requirement even for those who are statutorily subject to it.24 In 2023, more than 80 percent of ABAWDs were exempt from work requirements due to either waivers or discretionary exemptions.25 Additional exemptions added during the final years of the Biden administration weakened these work requirements even further.26
With work requirements applying to so few able-bodied adults, it should come as no surprise that few are meaningfully engaged in the workforce. Today, just five percent of able-bodied adults without young children work full time, while more than 70 percent do not work at all.27
Waiving work requirements and feeding dependency
Federal law generally requires ABAWDs to work, train, or volunteer on a part-time basis to remain eligible for benefits.28 Congress provided the U.S. Department of Agriculture (USDA) with limited discretion to waive work requirements in areas that lack suitable job opportunities for able-bodied adults and have unemployment rates above 10 percent.29 However, bureaucratic loopholes and gimmicks have allowed states to game the system to waive work requirements for as many able-bodied adults as possible.30
Despite clear statutory guidelines, federal regulations have expanded the criteria for approvable waivers far beyond these statutory limits.31-32 USDA developed “alternative procedures” that allow states to waive work requirements in areas with record-low unemployment and record-high job openings.33-35
Many areas with low unemployment rates consistently qualify for waivers, even during periods of economic growth and increased job availability. In 2019, out of 1,100 jurisdictions granted waivers, only 23 had unemployment rates above 10 percent, while nearly 1,000 had rates at or below six percent.36 Nearly half of those jurisdictions had unemployment rates below four percent, including some with literally zero unemployment.37
This abuse has continued in recent years. In October 2024, of the 835 counties nationwide where work requirements were either fully or partially waived, only seven counties had unemployment rates above the 10 percent statutory threshold.38 More than two-thirds of these counties had unemployment rates below the average rate that the U.S. Department of Labor has classified as “full employment” over the last 40 years, meaning areas where virtually everyone able and willing to work can easily find employment.39
As a result, less than 19 percent of ABAWDs are now subject to work requirements.40 To achieve this, states abuse a variety of gimmicks and loopholes.
Gerrymandering
Federal law permits states to request waivers from work requirements in “areas” that meet statutory thresholds.41 But rather than defining what constitutes an area for waiver purposes, federal regulations provide that states “may define areas to be covered by waivers.”42
Subregulatory guidance from USDA indicates that it believes “areas” under the statute to roughly mean jurisdictions, such as counties. For example, USDA guidance provides that “data from individual areas can be combined to waive a larger group of areas.”43-44 USDA further provides that “areas must be contiguous or considered parts of the same economic region” in order to be combined into a “larger group of areas.”45 The guidance acknowledges states “discretion to define the group of areas to be combined” and requires states to “thoroughly document” its “rationale for the boundaries of the group.”46 USDA guidance then provides examples of allowable groupings, including “economic regions based upon shared industries.”47
There is no statutory basis for USDA to approve waivers for groups of areas or for any area that does not independently meet statutory requirements. But that is exactly what USDA regulations have allowed.
States have combined jurisdictions into a “group of areas” to qualify for waivers, even when many of those jurisdictions do not meet the criteria.48 In Illinois, officials combined 101 of the state’s 102 counties into a single “area” for waiver purposes, even as many waived counties did not independently qualify.49 Some waived counties even had lower unemployment rates than the single county where the work requirement was not waived.50 This logic assumes that there are only two economic “areas” in Illinois: DuPage County—a single county in the Chicago metropolitan area—and the rest of the state.51 The waiver treats cities like Belleville and Bolingbroke, Chicago and Cairo, and Marion and Moline as if they are all part of the same economic region, despite the fact that these cities are hundreds of miles apart.52
Officials from several states have acknowledged that they pursued “waivers in as many parts of the state as possible” to “minimize the areas” where the requirements would apply—often guided by left-wing advocacy groups, such as the Center on Budget and Policy Priorities (CBPP).53 Groups like these provide tools and analyses aimed at maximizing the number of able-bodied adults that can be exempted.54 Indeed, CBPP staff have told public officials that they “prepare waivers for the majority of waived states,” are in “constant communication” with USDA about the status of those waivers, and even suggest states let USDA know that the waivers were prepared by CBPP to help expedite their approval.55 A review of more than 13,000 pages of correspondence between state officials and CBPP revealed at least a dozen waiver requests written by CBPP that were either identical—or nearly identical—to the waiver requests actually submitted by state officials.56
Manipulating old data
Federal law restricts the use of waivers to areas that USDA determines “has an unemployment rate” exceeding 10 percent, or “does not have a sufficient number of jobs” for able-bodied adults subject to the work requirement.57 This language, stated in present tense, requires USDA to evaluate waivers based on current economic conditions.
However, Clinton-era regulations and Obama-era guidance introduced an extended “lookback” period that allows states to continue receiving waivers long after economic downturns have passed.58 Under these rules, states can rely on unemployment data that dates back to the period used for determining labor surplus areas.59 For fiscal year 2025, the lookback period could date as far back as January 2022, allowing states to use data from three years ago to support waiver requests, even when that data has no connection to current economic conditions.60
These regulations also allow states to game the timeline based on when the waiver it files was submitted. If a state begins a waiver in the last month of a fiscal year, rather than the first month of the next fiscal year, it is able to use an entire year’s worth of even older data.61 This gaming has led to absurd results, where states use data from distant temporary economic conditions to justify current waivers.
In October 2024, for example, California was operating under a waiver based on data dating back to before COVID when government-imposed lockdowns spiked the state’s unemployment rate to more than 16 percent—despite those conditions no longer reflecting the current labor market.62 States also use multiple different lookback periods for different areas in the same waiver request to maximize the number of able-bodied adults waived from work requirements.63
Proven impact of work requirements undermined by limited reach
Work requirements became a standard feature of the food stamp program following the welfare reforms of the 1990s.64 Since their adoption, millions of able-bodied adults have transitioned from welfare to work—contributing to broader economic growth.65 State-level studies have consistently found positive outcomes following the implementation of work requirements.66
When states implemented food stamp work requirements, thousands of able-bodied adults transitioned from welfare to work.67 These individuals found employment across 1,000 diverse industries.68 Within one year, their incomes more than doubled, and within two years they had tripled.69 The increased earnings more than offset welfare benefits that were lost, putting many on the path to independence and self-sufficiency.70
Despite the proven track record of work requirements, state waiver abuse and statutory limitations have led most able-bodied adults on food stamps to be exempt from work requirements altogether. Today, just five percent of the 18.5 million able-bodied adults on the program are actually subject to a work requirement.71
Currently, the ABAWD work requirement applies to able-bodied adults up to the age of 54.72 However, this work requirement only applies to a portion of able-bodied adults on food stamps, leaving millions without a work requirement. Although work requirements currently apply for individuals under the age of 55, many Americans continue working well beyond that age.
In 2024, the average retirement age was 64.73 Individuals cannot qualify for Medicare until 65 and cannot draw full Social Security benefits until 67.74-75 Not only are older Americans still actively participating in the workforce, but they also tend to earn larger incomes than their younger counterparts.76 Yet the current ABAWD work requirement only applies to a fraction of the able-bodied adult population.
Another segment of able-bodied adults that lacks a real work requirement is able-bodied parents. Federal law states that work registrants—able-bodied adults under 60 without young children—must register for work, take a suitable job if offered, and participate in state E&T programs if assigned.77
However, most states make participation in E&T programs completely voluntary.78 Despite able-bodied parents being categorized as work registrants, most have no work requirement unless the state can prove a suitable job offer was refused.
These examples highlight a significant issue within the food stamp program. Although federal law intends for most able-bodied adults to be subject to a work requirement, many states have opted to waive work requirements or sidestep enforcement.79 Compounding the problem, there is no explicit work requirement for able-bodied parents receiving benefits.
As a result, some families remain stuck in long-term dependency, often spanning generations. Introducing work requirements for more able-bodied adults on food stamps would be a meaningful step toward breaking this cycle and jumpstarting America’s economic comeback.
Expanded work requirements would save taxpayers more than $175 billion
Congress should consider a number of reforms to move more able-bodied adults from welfare to work. First, Congress should crack down on the waiver abuse perpetuated by states and encouraged by federal bureaucrats. Waivers should be limited to counties with unemployment rates above 10 percent—as originally intended. This would block states from gerrymandering areas together for waiver purposes, using old data, or gaming alternative procedures to waive work requirements in areas with low unemployment and plenty of open jobs.
Second, Congress should repeal the new exemptions added during the final years of the Biden administration that exempted more than one million new able-bodied adults from work.
Third, Congress should extend the work requirement to able-bodied adults up to age 64, creating consistency with other welfare programs and recognizing actual retirement patterns. Finally, Congress should extend the work requirement to able-bodied parents of school-aged children.
These simple reforms would save taxpayers more than $175 billion over the next decade, moving millions of able-bodied adults back to work and providing a much-needed boost to the economy.80-91
The Bottom Line: It is time for Congress to restore accountability and promote self-sufficiency within the food stamp program.
Although federal law includes work requirements for able-bodied adults on food stamps, work requirements are too often limited in scope or are waived altogether. Even worse, some states make participation completely voluntary.93 Under the status quo, millions of able-bodied adults are being left behind.
It is time for Congress to restore accountability and promote self-sufficiency within the food stamp program. Work requirements have consistently delivered results when implemented, helping millions of able-bodied adults transition from welfare to work.94 By cracking down on states’ waiver abuse, ending Biden-era exemptions, expanding the age range for the ABAWD work requirement, and establishing a real work requirement for able-bodied parents of school-aged kids, Congress can take a meaningful step toward breaking the cycle of long-term dependency.
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