In 2024, 15% of Michiganders (about 1.47 million residents) received Supplemental Nutrition Assistance Program (SNAP) benefits. SNAP, or Food Assistance Program (FAP) is a crucial resource for low-income households: research has shown that by preventing food access being limited by income, low-income SNAP participants are less likely to experience food insecurity, are able to increase their monthly income, and have better mental and physical health outcomes. Research also suggests that SNAP mitigates racial disparities in food insecurity and poverty, addressing systemic barriers that disproportionately impact people of color.
In most of the country, SNAP recipients have had to meet work requirements to receive benefits. Michiganders have been insulated from these requirements for most of the past 20 years because our state was granted waivers based on our high unemployment rates. Because of falling unemployment rates in some parts of the state and changes made in the One Big Beautiful Bill Act of 2025, this is changing. This post explains these changes and steps recipients and advocates can take now to prepare.
New SNAP Work Requirements
First, because of falling unemployment rates, as of October 1, 2025, able-bodied adults without dependents (ABAWD) in Washtenaw County, Kent County (except for within the City of Grand Rapids), and Oakland County (except for the cities of Oak Park and Pontiac) are subject to work requirements and adults 18-54 without a child under 18 may need to comply.
Second, with the passage of the One Big Beautiful Bill Act of 2025, there are various additional changes to SNAP’s work requirements coming. Under the most recent USDA guidance, these changes will be enforced against states beginning November 1, 2025. These changes include:
- A stricter waiver requirement will only allow Michigan to obtain a waiver for areas with unemployment rates of at least 10%. This will dramatically expand work requirements in Michigan. For example, as of this posting, only Oscoda County would qualify for a waiver.
- Work requirements have been expanded to cover adults 18-65. They previously only covered adults 18-54.
- Caregivers for children 14 and older, veterans, adults experiencing homelessness, and former foster youth are no longer exempt from the requirements. (See below for remaining options for seeking deferrals.)
As a result, as of November 2, 2025, time limits and work requirements are expected to apply across Michigan to anyone 18-64 who is not exempt or a caretaker for someone under 14.
The stated goal of SNAP work requirements is to increase employment and work effort, but evidence shows that the work requirements do not lead to a meaningful increase in employment. Most SNAP participants who are able to work already do so or are experiencing temporary periods of unemployment. Rather, SNAP work requirements have been noted to reduce participation by 53% and increase program exits by 64% due to the influence of factors such as general administrative barriers, job market difficulties, unpredictable employment schedules, and obstacles like access to the internet, transportation, childcare, and healthcare. Furthermore, SNAP work requirements perpetuate racial disparities as they are found to lead to more black individuals losing eligibility compared to white individuals.
Suggestions in light of these changes:
- Be aware of clients’ rights and responsibilities and inform them of such. Be on the lookout for notice from MDHHS regarding work requirements and help clients ensure they receive both oral and written explanations if they are subject to work requirements.
- Be informed about ways to meet the work requirements and applicable exemptions. Check if the client is eligible for an exemption and obtain necessary documents to establish such eligibility.
- Assist with income verification documents and monthly Community Service Activity Reports, ensuring the client is informed about the reporting requirements, documentation of hours, and recurring deadlines. Some groups fall under the simplified reporting category: those who are under the time limited food assistance policy that work 20 hours or more can fall under this category until they no longer meet the 20 hour requirement.
- Inform clients about what to do in the case of their employment status changing. There are different responses and penalties depending on the change in circumstances/failure to comply with the requirements. There are consequences for knowingly quitting or reducing their work hours, but in some cases, reasons for change may be considered for “good cause,” in which the action will not be determined as a voluntary quit. Ensure proper documentation is provided when changes in employment and circumstances occur, and provide information that supports a showing of good cause.
- Inform clients about seeking deferrals. Deferrals could be available currently if there is a child in the food assistance group who is under the age of 18 (14 when the OBBBA changes go into effect), during every stage of pregnancy, where a person is medically certified mentally or physically unfit to work (can be met by receiving most available public benefits connected to a disabling condition, or if a person appears mentally or physically unfit to work to the MDHHS specialist–including if struggling with domestic violence or addiction), or an Unaccompanied Refugee Minor, and individuals participating in a local refugee program.
- The deferral applicant should be able to demonstrate their eligibility for a deferral through their own statement so long as it is not considered questionable. The deferral applicant could also use a statement from a doctor, domestic violence provider, or other treatment or services provider to support their deferral application.
- Additional resources: USDA website; MDHHS FAP; Bridges Eligibility Manual; MI Bridges application, case management, and resources.