HomeMy WebLinkAboutAgenda 10-07-2025; 12-5 - Information Item - Memorandum - HR 1 Food and Nutrition Services Expanded Work Requirements 1
J
o"NGE COUNTY
DEPARTMENT OF
SOCIAL SERVICES
113 Mayo Street, Hillsborough, NC 27278 1 919.245.2800
MEMORANDUM
TO: Orange County Board of County Commissioners
FROM: Lindsey Shewmaker, Social Services Director
DATE: October 7,2025
SUBJECT: HR 1 Food and Nutrition Services Expanded Work Requirements
Summary of Changes
HR 1 made significant changes to the Federal Supplemental Nutrition Program(SNAP). The first of the major changes,
expanded work requirements,will take affect this year and could cause many Food and Nutrition Services (FNS)
recipients to lose benefits. The Orange County Department of Social Services will be working with other County
departments and community partners to educate and inform individuals in those targeted populations about upcoming
changes and will work with the same groups to try to mitigate the impact and keep people connected to benefits.
It is unclear how many people in Orange County will be impacted by the changes,but we do know there are currently 868
older adults, age 55-64, currently receiving benefits. Statewide, 1 in 8 people receive FNS benefits, according to the North
Carolina Department of Health and Human Services. Of those 1.4 million beneficiaries,46,000 are Veterans who may
face eligibility changes depending on additional income and disability factors, 66%are members of families with
children,many of whom will face eligibility changes depending on the age of children in the household, and 20% are
members of families without children who are also likely to face eligibility or work requirement changes.
To stay eligible after the changes are implemented,recipients will need to:
• Work or volunteer at least 20 hours a week,
• Participate in a training program,
• Or be declared medically exempt by a doctor.
Even if a recipient is already meeting these rules,they will now need to submit documentation or risk losing benefits.
Background
On July 4,2025,President Trump signed into law new rules that expand work requirements for the federal SNAP
program,which in North Carolina we call the Food and Nutrition Services Program(FNS).
Orange County Government I www.orangecountync.gov 1 919.732.8181
2
J
o"NGE COUNTY
DEPARTMENT OF
SOCIAL SERVICES
113 Mayo Street, Hillsborough, NC 27278 1 919.245.2800
The FNS program has long had work requirements for a group identified as Able-Bodied Adults Without Dependents
(ABAWDs). HR 1 expanded those requirements and removed several previous exemptions.
General work requirements include:
• Registering for work, or
• Not voluntarily quitting a job or reducing your work hours below 30 a week without a good reason, or
• Voluntarily participating in FNS Employment and Training(More than a Job,NC) and taking a suitable job if
offered.
Recipients can be exempt for these general work requirements if they are:
• Already working at least 30 hours a week or earning at least$217.50 in pre-tax income per week, or
• Taking care of a child under age 6 or an incapacitated person, or
• Receiving TANF, or
• Receiving or applied for unemployment, or
• Studying in school or a training program at least half-time(but college students are subject to other eligibility
rules), or
• Have a physical or mental disability that prevents you from working(including pregnancy), or
• Participating regularly in an alcohol or drug treatment program.
If an individual is not working 30 hours per week and falls under the category for an ABAWD,they must meet the
following work requirements to continue receiving FNS benefits:
• Work at least 80 hours a month(work can be paid or unpaid,volunteer, or for goods or services (something other
than money), or
• Participate in a work program at least 80 hours a month, or
• Participate in a combination of work and work program hours for a total of at least 80 hours a month.
A work program includes FNS Employment&Training(More than a Job,NC),the TANF work program, and the
Workforce Innovation and Opportunity Act(WIOA)work program, all of which Orange County Department of Social
Services currently runs.
Prior to the new legislation,the category for ABAWDs included adults age 18-54. Exempt populations included persons
experiencing homelessness,veterans,those living with children under age 18, and young adults who had aged out of
foster care.
The changes to the law will go into effect in the next two months. States must begin tracking this three-month time limit
for people newly subject to this requirement when they are approved or recertified for benefits. The USDA guidance is not
Orange County Government I www.orangecountync.gov 1 919.732.8181
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J
o"NGE COUNTY
DEPARTMENT OF
SOCIAL SERVICES
113 Mayo Street, Hillsborough, NC 27278 1 919.245.2800
detailed,but this means that people who apply or are recertified beginning in October 2025 (or earlier depending on start
date)will exhaust their three months of benefits as soon as January 1 and states will, at that time,begin cutting people off
FNS who cannot document that they qualify for an exemption or are meeting the 20-hours per-week work requirement.
Who is Impacted?
The work requirements changes will impact FNS recipients who were previously exempt based on one or more qualifying
factors.The law expands the existing work requirements to include:
• Older adults aged 55 through 64; and
• Parents/caretakers with children aged 14 and older; and
• Veterans; and
• People experiencing homelessness; and
• Young people who recently aged out of foster care.
Unless they can document 20 hours per week of work or participation in a narrow set of work activities or prove they
qualify for an exemption,these individuals now can only receive FNS for three months in a three-year period. If these
adults are cut off,benefits will be reduced significantly for their remaining household members, including children in
school.
When will these changes take effect?
These changes were signed into law on July 4, 2025, and must take effect soon. On Friday, September 19th, 2025,North
Carolina counties received guidance from the North Carolina Department of Health and Human Services stating that
counties should"continue using current procedures and await further instruction from DHHS."
States have 120 days from the date a law is signed before they are held accountable for program changes. This hold-
harmless period for quality control(QC)purposes will expire on November 1,2025.We currently expect the State to have
the new rules in place by mid-October or earlier.
Once the policy changes are rolled out in North Carolina, staff will have to evaluate new applications and recertifications
based on the policy changes. For the below examples, assume the policy changes are effective October 15th,2025.
Example 1:
Carl is a 55-year-old man who is currently not working. He applies for FNS benefits on October 16th,2025.He will be
informed at application that he is subject to work requirement rules and will need to show that he is working in a paid or
unpaid job, seeking employment, or participating in a training or jobs program for 20 hours per week to continue
Orange County Government I www.orangecountync.gov 1 919.732.8181
4
J
o"Nce COUNTY
DEPARTMENT OF
SOCIAL SERVICES
113 Mayo Street, Hillsborough, NC 27278 1 919.245.2800
receiving benefits. His work hours will need to be reported monthly. If he fails to meet these requirements for three
months,he will lose benefits and be unable to receive FNS for three years unless he begins meeting work requirements.
Carl will also be asked if he meets any exemptions, including being medically unable to work. If his doctor provides
verification that he is medically unable to work, or if he meets any other exemption, Carl will be exempt for the new
requirements.
Example 2:
Lucy is a 60-year-old woman who has been receiving FNS benefits for several years. She must recertify her eligibility
every six months.When Lucy comes to recertify her benefits after October 15`h, she will be informed that she is now
subject to the new work requirements.
Communication Strategies and Plans
Orange County Social Services is working with the State to identify a list of current recipients likely to be impacted by
these changes. In the meantime, data shows there are 868 individuals who are age 55-64 currently receiving benefits.
Some of this group is likely to meet another exemption but staff are working with community partners to help educate the
target populations. (older adults,persons experiencing homelessness, and veterans)
Strategies include:
• Providing notice in advance of these changes through advertising and partnerships with the Orange County
Department on Aging,the Orange County Housing Department,the Orange County Criminal Justice Resource
Department,the Orange County Office of Civil Rights& Civic Life, churches, and other community partners.
(early communication materials are included as an attachment)
• Holding a targeted job fair in partnership with the Department on Aging for seniors.
• Working with the Chapel Hill/Carrboro Chamber of Commerce and Hillsborough Chamber of Commerce to
identify local employers committed to an age-diverse workforce.
• Identifying volunteer opportunities for adults who are not seeking paid employment that can meet work
requirements.
• Attending community outreach events and provide information on program changes and opportunities for
employment activities.
Orange County Government I www.orangecountync.gov 1 919.732.8181
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• • • Even if you are already meeting these rules, you may now need to submit
documentation or risk losing your benefits. Please respond to phone calls or
letters you receive from your caseworker to keep Your benefits.
ORANGE COUNTY
DEPARTMENT OF Call 919-245-2800 for more information.
SOCIAL SERVICES
Changes to FNS
r
On July 4, 2025, President Trump signed into law `
new rules that expand work requirements for Food
and Nutrition Services (FNS). Persons experiencing
homelessness will now be subject to work requirements --
unless they are able to meet another exception to the ,
rules.These rules will take effect soon in North Carolina. _ , �►
To stay eligible you may need to: H
• Work or volunteer at least 20 hours a week, "
• Participate in a training program, -
'4
• Or be declared medically exempt by a doctor.
000 Even if you are already meeting these rules, you may now1 1submit
Changes to FNS
On July 4, 2025, President Trump signed into law
new rules that expand work requirements for Food
and Nutrition Services (FNS).Veterans will now be
subject to work requirements unless they are able `
to meet another exception to the rules.These rules
will take effect soon in North Carolina.
To stay eligible you may need to:
• Work or volunteer at least 20 hours a week,
• Participate in atraining program,
• Or be declared medically exempt by a doctor.
000 Even if you are already meeting these rules, you may now need to submit
Y)t documentation or risk losing your benefits. Please respond to phone calls or
ORANGE COUNTY letters you receive from your caseworker to keep your benefits.
D� 919-245-2800