The budget bill introduces significant changes to the federal food assistance program, also known as the Supplemental Nutrition Assistance Program (SNAP).
Section 10001
Summary
Section 10001: Thrifty food plan.
This section would limit how much food assistance (SNAP) benefits can go up each year.
Explainer
Section 10001: Thrifty food plan.
The federal government uses the Thrifty Food Plan to decide how much food assistance people can get for buying approved foods. This plan is based on what it costs to buy healthy food for a household, and it’s reviewed every few years to keep up with real food prices.
Right now, SNAP benefits can go up when food prices go up. But this new rule would change that. It says SNAP benefits can only go up as much as the general inflation rate. Inflation is based on the cost of many things, not just food. Since food prices often rise faster than inflation,[1] SNAP benefits would not keep up with the real cost of groceries.
Starting in 2027, people will get less in food assistance each month than they would under the current rules. Right now, the average food assistance benefit is only $6.31 per person per day, which is not enough for a basic meal in many states.[2] By 2034, the average monthly benefit is expected to be 6.6% lower than under the current law. This change will reduce overall food assistance benefits by $37 billion between 2027 and 2034.[3]
Likely Impact on Disability Community
Increased Food Insecurity: Research shows that people with disabilities are more likely to live in poverty, often due to barriers to employment, education, and healthcare. For example, ten years after the onset of a chronic and severe disability, average earnings drop by 76% and family income declines by 28%.[4]
Households that include adults with disabilities experience significantly higher rates of food insecurity. In fact, about 38% of households with very low food security include an adult with a disability. [5]
Program Participation: Participation in food assistance programs, such as the School-Based ACCESS Program (SBAP), makes a measurable difference. Multiple studies have found that participants receiving SNAP food assistance are 5–20 percentage points less likely to experience food insecurity compared to those who are eligible but not enrolled in the program.[6]
Therefore, reducing the amount of food assistance across the board is likely to have a disproportionate impact on people with disabilities and their ability to access adequate nutrition. This is particularly important given that people with disabilities make up a significant portion of food assistance recipients. More than one in four individuals receiving food assistance report having a disability or a work limitation.[7]
Worsening Health and Increased Healthcare Costs: Reduced access to nutritious food will also lead to poorer health and higher healthcare costs for persons with disabilities. Research shows that children with intellectual and developmental disabilities who face food insecurity are more likely to have worse overall health, behavioral challenges, and functional limitations, especially when food insecurity is moderate to severe.[8] Another study found that people experiencing food insecurity had significantly higher healthcare costs, spending an estimated additional $1,863 annually.[9]
Disproportionate Impact for Persons with Disabilities: Many people with disabilities also spend more on food because they may need special diets, such as allergy-friendly or medical diets, that cost more.[10]
For instance, a report found that medically necessary diets, such as the Dietary Approaches to Stop Hypertension (DASH) diet, cost approximately 41% more than the food assistance benefit at the time of the study. Additionally, the report noted that individuals with conditions such as malabsorption may require a higher caloric intake, leading to increased food expenses.[11]
Despite these needs, SNAP does not provide additional support for people who require more expensive food diets due to a disability or illness. Across-the-board benefit reductions would worsen this gap, making it harder for people with disabilities to access the food they need to stay healthy. This, in turn, is likely to lead to worsening health outcomes and increased healthcare costs.
Gaps or Concerns
The Cost of Inflation Is Not Sufficiently Considered
Slowing the annual increase in food assistance benefits will make it harder for people with disabilities and other vulnerable groups to afford enough food, especially given the already high rates of food insecurity and the higher food costs some face due to medical or dietary needs.
The proposed rule also fails to reflect the reality of grocery prices, which have risen significantly in recent years. In 2025, for example, egg prices increased by 49.3 percent.[12]
Given these realities, food assistance benefits should be adjusted based on real food price trends, not reduced or limited by broader inflation measures that don’t reflect the true cost of eating well.
Recommendations
- Remove Section 10001 as currently written. The proposed cap on SNAP benefit increases does not reflect the real cost of food and would disproportionately harm people with disabilities.
- Allow SNAP benefits to increase annually based on actual food costs and levels of need. Adjustments should reflect the resources required to effectively reduce food insecurity, not just general inflation.
- Ensure that benefit levels are sufficient for individuals with higher food costs resulting from disability or chronic illness. This includes accounting for medically necessary diets and other nutrition-related needs that are not currently addressed in benefit calculations.
Section 10002 and Section 10003
Summary
Section 10002: Work requirements for able-bodied adults without dependents.
This section expands work requirements for individuals classified as able-bodied adults without dependents (ABAWDs) who receive SNAP benefits. Under the proposed changes, these individuals must work—either in paid employment or approved unpaid activities—for at least 80 hours per month to remain eligible for food assistance.
The new rules would broaden the group of people subject to these requirements, meaning more individuals would need to meet work thresholds to continue receiving SNAP benefits.
Section 10003: Able-bodied adults without dependents waivers.
This section restricts states’ ability to waive SNAP work requirements for able-bodied adults without dependents (ABAWDs). Under current law, states can request waivers in areas where there are not enough jobs available.
However, Section 10003 would significantly narrow this flexibility. States would only be allowed to apply for a waiver if the unemployment rate in a given area exceeds 10%—a much higher threshold than current standards. This change would make it significantly more difficult for states to exempt individuals from work requirements, even in areas with limited job opportunities.
Explainer
Section 10003: Able-bodied adults without dependents waivers.
Work Requirements for Older Adults Without Children
This section says that more adults without children will have to work to get food assistance (right now, people age 54 and older don’t have to work to get SNAP (food assistance). This bill would change that. People up to age 65 would have to work at least 80 hours a month to keep getting SNAP. This work could be a job, job training, or volunteering.
Work Requirements for Parents and Caregivers
Today, parents and caregivers of children under 18 don’t have to meet work rules to get SNAP. This bill would change that. Parents would have to work 80 hours a month, unless their child is 6 years old or younger. If two parents live together, only one of them would need to meet the work rule.
Work Requirements for Vulnerable Populations
Right now, some people don’t have to meet work rules, like:
- Veterans
- People experiencing homelessness
- Young adults leaving foster care
This bill would remove those exceptions. These groups would now have to work 80 hours a month to keep getting SNAP.
Work Requirements Despite Insufficient Jobs
Right now, states can ask to skip the work rule if there aren’t enough jobs in an area. This bill makes that harder. States could only ask for a waiver if the unemployment rate is over 10%.
Likely Impact on Disability Community
Unfit For Work Certifications: To be exempt from SNAP work requirements due to disability, a person must be certified by a doctor as “unfit for work.” However, many low-income individuals with disabilities may not have access to the healthcare needed to obtain this certification. Even when they do, the term “unfit for work” often fails to reflect the real challenges people with disabilities face in the job market.
Research shows that people with disabilities often face serious barriers to employment[13]—not because they are incapable of working, but because of barriers including discrimination, bias, and stigmatization due to disability, limited workplace accommodations, and inaccessible job settings.
For example, some studies show that job seekers with mental health disabilities who request a modification or accommodation during the hiring process are less likely to be hired than those who do not.[14] Additionally, people with disabilities are more likely to experience long-term unemployment once they lose a job.[15]
Many people with disabilities may be able to work in theory but are not given the opportunity in practice. As a result, they may not qualify for the “unfit for work” exemption, even though their disability prevents them from obtaining paid employment.
Hourly Requirements: Requiring people to complete 80 hours per month of unpaid work or job training may:
- Reduce the time and flexibility they need to search for meaningful, paid employment
- Fail to address the real reasons why people with disabilities struggle to find or keep jobs
- Place additional burdens on individuals already navigating complex health and accessibility challenges
In some cases, these mandatory activities may do more harm than good, making it harder for people with disabilities to pursue long-term employment opportunities that match their skills and needs.
Older Adults and Disability: Under the proposed bill, adults without children would be required to work 80 hours per month to receive SNAP benefits until they reach the age of 65. This change would affect many middle-aged and older adults, even though disability becomes more common after age 50.[16] Another study analyzing cross-country data also found that individuals aged 55–65 exhibit higher rates of disability compared to younger age groups.[17]
Non-Identification of Disability in Adults Aged 55+: Despite the increasing prevalence of disability, many adults aged 55 do not identify themselves as having a disability. Various factors, including societal perceptions and personal beliefs about disability and aging, can influence this underreporting.
For instance, a study published in Disability Studies Quarterly found that older adults often perceive disability as a label for severe limitations, leading them to dismiss their functional difficulties as a regular part of aging rather than a disability.[18]
Those over 55 are therefore likely to associate the certification of “unfit for work” with severe impairment, leading them to dismiss their difficulties in meeting work requirements.
The process of applying for the “unfit to work” certification through a physician can also be complex, which is likely to discourage many individuals with disabilities from applying for a work requirement exemption.
Difficulties Finding Employment in Later Life: Older adults also commonly face greater challenges finding employment than younger workers, often due to ageism in hiring practices and other factors. A 2025 report from the Government Accountability Office found that 41% of displaced workers aged 55 and older had not returned to work three years after job loss, nearly double the rate for workers aged 25–54.[19] Many adults over age 55 who need food assistance are willing to work, but may face challenges finding employment because of discrimination based on age or disability. Requiring them to perform 80 hours of unpaid work each month does not address these underlying barriers.
Lack of Exemptions for Disabled People in Vulnerable Populations: Although the bill allows exemptions for people who are medically certified as “unfit for work,” many people with disabilities may face challenges providing the required documentation. This is especially true for individuals who are unhoused or for young adults transitioning out of foster care. These obstacles will likely result in the most vulnerable people with disabilities, who are eligible for food assistance, losing access due to barriers in completing and submitting the supporting documentation.
Furthermore, approximately 1.2 million low-income veterans receive SNAP.[20] Many of those face unique barriers to employment, including service-connected disabilities, mental health disabilities such as post-traumatic stress disorder (PTSD), and other challenges transitioning to civilian jobs. Requiring 80 hours of work per month does not address these barriers and may lead to loss of benefits for those who need them most.
Lack of Exemptions for Children with Disabilities: Under the bill, parents of children over 6 years old would be required to meet the 80-hour-per-month work requirements, even if they can’t afford childcare.[21] For many low-income families that rely on food assistance, particularly single-parent households, childcare is unaffordable and difficult to find. In many states, it is illegal or unsafe to leave a 7-year-old home alone, yet parents will be required to work 20 hours a week to maintain access to food assistance.[22] While parents of children with disabilities are exempt if they are caring for a person who is “incapacitated,” this definition does not cover all children with disabilities. As a result, some families may lose food assistance if they can’t find or afford childcare to cover 80 hours a month.
Grandparents Caring for Grandchildren: Many grandparents provide unpaid childcare for their families. Under the bill, grandparents under age 65 would still be required to meet the 80-hour-per-month work rule—even if they are caring for grandchildren. This could especially hurt families of children with disabilities who rely on grandparents (who receive food assistance) for support.
People with Disabilities Encounter Extra Challenges When Seeking Employment: Currently, states can ask for a waiver if there aren’t enough jobs in an area. Under the new rule, they could only do this if the unemployment rate is over 10%, which is rare.[23] This change would make it harder for people with disabilities—who already face discrimination, lack of accommodations, and inaccessible workplaces—to meet work requirements, especially in areas with few job opportunities.
Gaps or Concerns
Disability Misclassification and Documentation Barriers
Many individuals with disabilities do not qualify for the “unfit for work” exemption due to:
- Stigma and self-perception, especially among older adults
- The narrow definition of disability and complex medical certification process
- Inability to obtain certification documentation from a doctor due to inaccessible or unaffordable healthcare
Older Adults Facing Structural Employment Barriers
Adults ages 55–64 are:
- More likely to experience disability
- Less likely to self-identify as disabled
- Disproportionately affected by ageism and unable to find work[24]
No Consideration for Caregivers of Children with Disabilities
- Parents of children over 6 years old must meet work requirements regardless of caregiving responsibilities.
- The definition of “incapacitated” does not cover all children with disabilities, excluding many families from exemptions.
Negative Impact on Vulnerable Subpopulations with Disabilities
- Veterans, unhoused individuals, and youth aging out of foster care with disabilities may face added barriers to obtaining exemptions due to documentation difficulties[25].
- These groups already face compounded barriers to employment.
Undermining Job Search and Economic Advancement
Requiring 80 hours a month of unpaid work or training may:
- Interfere with real job search efforts and distract from long-term employment goals; and
- Fail to address underlying discriminatory or structural barriers to employment faced by people with disabilities.
Grandparent Caregivers Penalized
- Grandparents under 65 who care for grandchildren (including children with disabilities) may lose access to food assistance despite fulfilling a critical family support role.
Disabled Job Seekers Penalized
- When jobs are scarce, persons with disabilities who do not certify as “unfit for work” will be forced to meet work requirements, putting their access to food assistance at risk and reducing the time and flexibility they may need to search for work.
Recommendations
- Remove Sections 10002 and 10003 as currently written. These provisions would impose rigid work requirements that fail to account for the realities faced by older adults, people with disabilities, and caregivers.
- Eliminate work requirements for individuals with disabilities, regardless of whether they are officially certified as “unfit for work.” Many people with disabilities face real barriers to employment but may not meet narrow medical exemption criteria.
- Remove work requirements for households that include:
- A person with a disability
- A child under 18
- An adult aged 50 or older
These groups face unique challenges that make rigid work requirements especially harmful.
- Allow a set of more flexible work requirement waiver criteria that considers not just county-wide unemployment, but also local economic conditions, job availability, and the employment barriers faced by households that include persons with disabilities and other vulnerable populations.
Section 10006, Section 10007, and Section 10010
Summary
Section 10006: Matching funds requirements.
Imposes a 5% state match for food assistance benefit costs starting in FY 2028, with penalties for high payment error rates.
Section 10007: Administrative cost sharing.
Reduces the federal share of administrative food assistance benefits costs from 50% to 25%, shifting the costs to the states.
Section 10010: Quality control zero tolerance.
Sets food assistance benefit payment accuracy incentive funding to $0 starting in FY 2026.
Explainer
Section 10006: Matching funds requirements.
Starting in 2028, states will have to pay for 5% of the cost of SNAP (food assistance) benefits. Right now, the federal government pays for all SNAP benefits. This change means states will have to start sharing the cost. If a state makes too many mistakes in how it gives out SNAP benefits—called payment errors—it could face penalties. That means the state might have to pay even more money.
Section 10007: Administrative cost sharing.
The federal government pays for half (50%) of the cost to run the SNAP (food assistance) program—things like staff, computers, and paperwork. This section would cut that support in half.
Starting soon, the federal government would only pay 25%, and states would have to pay the rest. This means states would have to spend more of their own money to keep SNAP running.
Section 10010: Quality control zero tolerance.
States can get extra funding if they do a good job of making sure SNAP benefits go to the right people and in the right amounts.
This section would end that. Starting in 2026, the federal government will stop giving money to states as a reward for accurately processing food assistance cases. This is known as quality control incentive funding. This could make it harder for states to invest in systems that prevent mistakes and improve service.
Likely Impact on Disability Community
Increased Financial Pressure on States: These provisions shift significant costs from the federal government to the states. Many states may not have the resources to absorb these new expenses, which could lead to cuts in food assistance programs. This would disproportionately affect people with disabilities who rely on SNAP to meet basic nutritional needs.
Reduced Support During Economic Downturns: SNAP plays a crucial role in supporting families during recessions and periods of economic hardship. Reducing federal funding and administrative support could weaken the program’s ability to respond to future crises. This would have broad economic consequences, especially for people with disabilities and their families, who are often among the most economically vulnerable.
Gaps or Concerns
Impact on Low-Income States
The shift in SNAP costs from the federal government to the states will disproportionately impact low-income states and those with larger food assistance caseloads.
These states may already struggle with limited budgets and high demand for services. Without additional federal support, they may be forced to reduce benefits, restrict eligibility, or cut administrative resources, placing vulnerable populations, including people with disabilities, at even greater risk of food insecurity.
Recommendations
- Remove this provision as written. Shifting the financial burden of SNAP to states threatens the stability and accessibility of food assistance programs, especially in states with limited resources.
- Maintain a strong federal cost share for both benefit and administrative expenses. This is essential to ensure that SNAP remains equally accessible across all states, particularly during times of economic downturn or public health emergencies when demand for assistance increases.
References
[1] U.S. Government Accountability Office. (2023, January 19). Inflation and rising food prices: How does federal food assistance change? WatchBlog. GAO explains that SNAP benefits are tied to general inflation but notes that “food prices often rise faster than inflation,” meaning benefit increases may lag behind actual grocery costs.
[2] Grocery prices by state 2025. (n.d.). worldpopulationreview.com. https://worldpopulationreview.com/state-rankings/grocery-prices-by-state
[3] Swagel, P. (2025, May 22). Re: Potential Effects on the Supplemental Nutrition Assistance Program of Reconciliation Recommendations Pursuant to H. Con. Res. 14, as Ordered Reported by the House Committee on Agriculture on May 12, 2025. Congressional Budget Office. https://www.cbo.gov/system/files/2025-05/Klobuchar-Craig-Letter-SNAP_5-22-25.pdf
[4] Carlson, S., Keith-Jennings, B., Chaudhry, R. (2017, June 14). SNAP Provides Needed Food Assistance to Millions of People with Disabilities. Center on Budget and Policy Priorities. https://www.cbpp.org/research/snap-provides-needed-food-assistance-to-millions-of-people-with-disabilities
[5] Coleman-Jensen, A. & Nord, M. (2013, May 6). Disability Is an Important Risk Factor for Food Insecurity. US Department of Agriculture. https://www.ers.usda.gov/amber-waves/2013/may/disability-is-an-important-risk-factor-for-food-insecurity
[6] Engelhard, E., & Hake, M. (2020). Food Security Evidence Review [Report]. https://www.feedingamerica.org/sites/default/files/2020-12/Food%20Security%20Evidence%20Review%20August%202020.pdf
[7] Carlson, S., Keith-Jennings, B., Chaudhry, R. (2017, June 14). SNAP Provides Needed Food Assistance to Millions of People with Disabilities. Center on Budget and Policy Priorities. https://www.cbpp.org/research/snap-provides-needed-food-assistance-to-millions-of-people-with-disabilities
[8] Dhuliawala, S., Payakachat, N., Painter, J., Swindle, T., Chenghui, L. Food Insecurity and Health Outcomes of Children with Intellectual and Developmental Disabilities. American Journal on Intellectual and Developmental Disabilities. https://www.aaidd.org/docs/default-source/prepressarticles/food-insecurity-and-health-outcomes-of-children-with-intellectual-and-developmental-disabilities.pdf
[9] Berkowitz, S. A., Basu, S., Meigs, J. B., & Seligman, H. K. (2018). Food Insecurity and Health Care Expenditures in the United States, 2011-2013. Health services research, 53(3), 1600–1620. https://doi.org/10.1111/1475-6773.12730
[10] Mont D., Cote A., Hanass-Hancock J., Banks L.M., Grigorus V., Carraro L., Morris Z. and Pinilla-Roncancio M., “Estimating the extra costs for disability for social protection programs,” UNPRPD. (2022):1–47. https://www.social-protection.org/gimi/RessourcePDF.action?id=57850
[11] U.S. Government Accountability Office. (2000, May 8). Food Stamp Program: Information on the costs of special diets (Report No. GAO/RCED‑00‑144R). ([GAO] 2000, p. B‑285079) https://www.gao.gov/products/gao-23-105450
[12] Consumer prices up 2.3% from April 2024 to April 2025. (2025, May 19). Bureau of Labor Statistics. https://www.bls.gov/opub/ted/2025/consumer-prices-up-2-3-percent-from-april-2024-to-april-2025.htm
[13] U.S. Bureau of Labor Statistics. (2024). Persons with a Disability: Labor Force Characteristics—2023. https://www.bls.gov/news.release/pdf/disabl.pdf
[14] Sundara, V., O’Neill, J., Houtenvillec, A., Phillips, K., Keirns, T., Smith, A., & Katz, E. (2018). Striving to work and overcoming barriers: Employment strategies and successes of people with disabilities. Journal of Vocational Rehabilitation, 48, 93-109. https://kesslerfoundation.org/sites/default/files/2019-07/Striving%20to%20Work%20JVR.pdf
[15] Sundara, V., O’Neill, J., Houtenvillec, A., Phillips, K., Keirns, T., Smith, A., & Katz, E. (2018). Striving to work and overcoming barriers: Employment strategies and successes of people with disabilities. Journal of Vocational Rehabilitation, 48, 93-109. https://kesslerfoundation.org/sites/default/files/2019-07/Striving%20to%20Work%20JVR.pdf
[16] Heimbuch, H., Rhee, Y., Douglas, M., Juhl, K., Knoll, K., Stastny, S., & McGrath, R. (2023). Prevalence and Trends of Basic Activities of Daily Living Limitations in Middle-Aged and Older Adults in the United States. Epidemiologia (Basel, Switzerland), 4(4), 483–491. https://doi.org/10.3390/epidemiologia4040040
[17] Wang, S., Phillips, D., & Lee, J. (2021). Disability prevalence in midlife (aged 55-65 years): Cross-Country comparisons of gender differences and time trends. Women’s midlife health, 7(1), 1. https://doi.org/10.1186/s40695-020-00061-0
[18] Leahy, A. Disability Identity in Older Age? – Exploring Social Processes that Influence Disability Identification with Ageing. (2023). Disability Studies Quarterly, 42 (3-4). https://dsq-sds.org/index.php/dsq/article/view/7780/7872
[19] US Government Accountability Office. (2025, May). Older Workers: Employment Rates Rebounded and Personal Finances Remained Steady Following Pandemic. GAO. https://www.gao.gov/assets/gao-25-106962.pdf
[20] Hall, L. (2021, November 9). SNAP Helps 1.2 Million Low-Income Veterans, Including Thousands in Every State. Center on Budget and Policy Priorities. https://www.cbpp.org/research/food-assistance/snap-helps-12-million-low-income-veterans-including-thousands-in-every
[21] U.S. Department of Health and Human Services, Office of the Assistant Secretary for Planning and Evaluation. (2020). Child care affordability and access in the United States. https://aspe.hhs.gov/reports/child-care-affordability-access-us
[22] Child Welfare Information Gateway. (2019). Leaving children home alone: What the law says. U.S. Department of Health and Human Services, Children’s Bureau. https://www.childwelfare.gov/pubPDFs/alone.pdf
[23] Center on Budget and Policy Priorities. (2025, April). Worsening SNAP’s harsh work requirement would take food assistance away [Analysis]. https://www.cbpp.org/research/food-assistance/worsening-snaps-harsh-work-requirement-would-take-food-assistance-away
[24] AARP Research. (2024, October 18; updated January 15, 2025). Age Discrimination Persists Among Older Workers. https://www.aarp.org/pri/topics/work-finances-retirement/employers-workforce/age-discrimination-workplace
[25] Arkansas Advocates for Children and Families. (2025, June 20). Veterans, Unhoused People, and Youth Aging Out of Foster Care Lose Out in Senate Bill [Advocacy report]. https://www.aradvocates.org/veterans-unhoused-people-and-youth-aging-out-of-foster-care-lose-out-in-senate-bill/
