Approximately 1,200 DC residents could lose critical Supplemental Nutrition Assistance Program (SNAP) benefits by October because of a harmful time limit that federal lawmakers imposed on states and enrollees last year, according to data shared by the DC Department of Human Services (DHS).
SNAP is the nation’s largest anti-hunger program, serving about 1 in 4 households in the District and disproportionately serving more Black households than white households. Many DC residents face barriers to food security and rely on SNAP due to systemic and racial inequalities, including the high cost of living, wage disparities, and limited access to grocery stores East of the River. SNAP plays a vital role in reducing hunger by helping residents with low incomes afford the food they need, directly improving their health, productivity, and quality of life.
Despite SNAP’s critical role in improving food access, federal changes enacted under the One Big Beautiful Bill Act (OBBBA) require DC to impose ineffective and burdensome work requirements on SNAP enrollees. Those who cannot meet these requirements are facing a strict three-month time limit on benefit receipt over a three-year period. Other states are already seeing the deep harm of the time limit, and DC will be no different. Over 19,700 District residents are subject to these new requirements, with many at immediate risk of losing SNAP and even more at risk in the months ahead.
OBBBA Expanded Work Requirements, Restricting Access to Vital Food Assistance
Before OBBBA, federal law limited Able-Bodied Adult Without Dependents (ABAWDs) to three months of SNAP benefits in a three-year period unless they met specific work requirements or qualified for an exemption. This included adults ages 18 to 54 who did not live with a child under age 18, did not have a medical or physical barrier to employment, and were not pregnant. Since the late 1990s, the US Department of Agriculture (USDA) has allowed DC to waive these requirements because of high local unemployment and limited job availability. As a result, ABAWDs in DC have not been subject to these rules for nearly three decades.
OBBBA upended this policy by restricting waivers to areas with unemployment rates above 10 percent. Because DC did not meet this new threshold, its long-standing waiver expired in December 2025. The law also raised the work requirement age threshold for older adults from 54 to 64 and decreased the maximum age for a dependent from 18 to 14, meaning the time limit is now harming households with children in the home.
These changes represent a fundamental shift in SNAP eligibility rules that will harm thousands of District residents and children. Approximately 62,000 SNAP enrollees—or 51 percent of all SNAP enrollees in DC—now meet the definition of an ABAWD, according to DC DHS data. These individuals must work, participate in the SNAP Employment and Training program, or volunteer for at least 20 hours per week to maintain their benefits, unless they qualify for an exemption. DHS estimates that about one-third of these adults (19,715 people) are non-exempt and therefore subject to work requirements and the three-month time limit.
Work requirements do nothing to increase employment. Instead, they take food off the tables of people who are already struggling to make ends meet, worsening poverty, according to decades of research. That harm is especially concerning in DC, where many residents already struggle to afford basic necessities. On average from 2020 to 2024, nearly 61 percent of Black households in DC had incomes below the amount needed for an adequate standard of living.
Thousands of Vulnerable Residents at Risk of Losing SNAP
DC DHS began implementing the new SNAP time limit rules on June 1, 2026. Under the new process, DHS reviews SNAP applicants and enrollees to determine whether they meet the definition of an ABAWD and, if so, whether they qualify for an exemption or must meet work requirements. Importantly, the three-month time limit does not begin for these adults until DHS screens them. People who apply for SNAP on or after June 1 are screened as part of the application process, while current enrollees are screened at their next recertification.
As of July 5, DHS had screened 4,827 SNAP applicants and recipients to determine their ABAWD status and whether they qualified for an exemption. Of the 1,371 ABAWDs who did not receive an exemption, 1,210 were not meeting work requirements and had therefore started their three-month time limit; thirty-five percent (418) were in their second month, and 65 percent (788) were in their first month (Figure 1). If they continue to not meet work requirements, these individuals will lose their SNAP benefits on September 1 or October 1, respectively.
Figure 1.
1,210 SNAP Recipients are at Risk of Losing SNAP Benefits this Fall
Number of ABAWDs screened by DHS (as of July 5), not eligible for an exemption and not meeting work requirements
Source: DC Department of Human Services, “ESA Advocate Meeting,” August 3, 2026.
Note: ABAWDs refers to able-bodied adults without dependents.
DHS Should Strengthen Transparency as Implementation Continues
DHS should commit to data transparency by establishing a system to track and publicly report monthly SNAP caseload data on ABAWDs so that the community can property track OBBBA’s harm. The Council should also convene a public roundtable or hearing to examine implementation challenges and lessons learned, which can inform the District’s approach to limiting harm in the upcoming implementation of Temporary Assistance for Needy Families (TANF) and Medicaid work requirements.
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