End of Waiver for Time-Limited SNAP Benefits and Changes to Exemptions for SNAP Work Requirements

Illinois Department of Human Services Logo

10/16/25

This Policy Memo updates the following Manual Release:

Summary:

  • This Policy Memo introduces changes to the SNAP Work Requirement exemptions as set forth in Public Law No: 119-21. The changes introduced in this Policy Memo were implemented in IES effective 09/26/2025 for all active SNAP cases and applications. Changes in IES were implemented in preparation for the end of the Work Requirement waiver.
  • Illinois' Work Requirement waiver is ending in November 2025. The first potential countable month for Able Bodied Adults Without Dependents (ABAWD) who are not exempt or meeting the SNAP Work Requirement is December 2025.
  • This Policy Memo also provides updated guidance on implementing the SNAP Work Requirement. A Manual Release will also be published in the coming weeks to provide Policy Manual updates and additional information regarding the SNAP Work Requirements.
  • Active cases who have an exemption that is being discontinued or who are gaining an exemption due to the changes will go through a batch update process in IES to update the information on the case without worker intervention. If the case is not updated systematically, Family Community Resource Center (FCRC) workers must review the case for accuracy, run eligibility and certify the case to complete the update process.

Exemptions that Ended

The following categories of people will no longer be exempt from the SNAP Work Requirement unless they qualify for another exemption:

  • Veterans as defined in WAG 03-25-01;
  • Homeless as defined in PM 06-04-02; and
  • Individuals age 24 and younger and were in a foster care program at the time of their 18th birthday as defined in WAG 03-25-01.

Change to Age Related Exemption

People who are between the ages of 18-64 and do not meet a Work Requirement exemption found in PM 03-25-01 are considered ABAWDs and must comply with the SNAP Work Requirement.

A customer will become exempt in the month of their 65th birthday.

Note: People exempt from the SNAP Work Provisions continue to be exempt from the SNAP Work Requirement, except those who are exempt due to their age being 60 or older, see PM 03-15-02.

Change to Age of Dependent Child Exemption

All people living in a SNAP household (purchase and prepare food together) with a child age 13 or younger, even if the child is ineligible for SNAP, are exempt from meeting the SNAP Work Requirement.

Change to Medical Exemption - Chronic Homelessness

A person experiencing chronic homelessness is exempt from meeting the SNAP Work Requirement.

To be considered chronically homeless, a person must meet the definition of homeless in PM 06-04-02 for at least 1 year, or have met the definition on at least four separate occurrences in the last 3 years and the person must have a diagnosable substance use disorder, serious mental illness, developmental disability, post traumatic stress disorder, cognitive impairments resulting from a brain injury, or chronic physical illness or disability.

Being chronically homeless does not exempt a person from the Work Provisions in PM 03-15-02.

Workers must apply the chronic homelessness exemption manually on the Exemptions - Details page in IES for the exemption to be applied. Workers should only require verification if there is a direct contradiction between the information provided by the household and other information provided or found through clearances.

New Native American Exemption

People with the following status will be exempt from the SNAP Work Requirement: Alaska Native, American Indian, American Urban Indian, or California Indian (as defined in the Indian Health Care Improvement Act).

SNAP Work Rules and Exemptions

SNAP Work Rules are 2 sets of rules that together promote self sufficiency in SNAP households and require SNAP customers to find work or otherwise volunteer in their communities or, if available in their area, enter into a SNAP Employment and Training (E&T) program to increase their employability, see PM 21-06-00.

The sets of rules that make up the "SNAP Work Rules" are: SNAP Work Provisions and SNAP Work Requirement.

Note: SNAP Work Provision exemptions have not changed, see PM 03-15-02.

A person is exempt from the SNAP Work Requirement if they:

  • Are age 17 or younger or age 65 or older
  • Have a physical or mental condition that prevents them from working or makes it difficult to maintain work
  • Are experiencing chronic homelessness
  • Are pregnant
  • Live in a SNAP household with a child under age 14 that purchase and prepare food together
  • Are an Alaska Native, American Indian, American Urban Indian, or California Indian (as defined in the Indian Health Care Improvement Act)

A person is exempt from the SNAP Work Requirement and SNAP Work Provisions if they:

  • Are attending a school, college, or training program at least half-time
  • Have applied for or are receiving unemployment benefits
  • Are in a drug or alcohol addiction treatment program or suffering from substance addiction
  • Are currently receiving TANF and are participating and complying with the TANF work and training requirements
  • Are providing care for another person who needs help caring for themselves (this person does not have to be living in your home)
  • Are responsible for the care of a child under the age of 6 (does not have to be your child or living in your home)
  • Are an AmeriCorps VISTA volunteer working 30 or more hours a week paid, unpaid, or paid in-kind (living stipend)
  • Are a migrant or seasonal farm worker under contract with an employer to begin employment within 30 days for an average of 30 hours per week or earning wages at least equal to $217.50 per week before taxes and other deductions (federal minimum wage $7.25 multiplied by 30 hours)
  • Are working an average of 30 hours per week or earning wages at least equal to $217.50 per week before taxes and other deductions (federal minimum wage $7.25 multiplied by 30 hours)

A person is exempt from the SNAP Work Provisions if they:

  • Are age 15 or younger or age 60 or older
    • Note: A person exempt from the Work Provisions for being age 60 or older does not automatically exempt them from the Work Requirement.

Screening for Work Requirement Exemptions

FCRC workers must thoroughly screen customers for all potential exemptions during SNAP interviews at both initial application and redetermination. FCRC workers must also screen for all potential exemptions when a customer loses a Work Requirement exemption during the certification period. Countable months should not be assigned until the customer is screened to determine whether any other Work Requirement exemptions exist.

An FCRC worker's observation is sufficient to determine if a customer is physically unable to work.

An observation can be based on the customer's statement, for example:

  • the customer says they are pregnant
  • the customer says they are suffering from substance abuse addiction
  • the customer says they have a walking boot on an ankle

Allow the exemption and do not request verification unless the information provided by the household directly contradicts with other information provided or found through clearances.

The observation can also be visual, for example, if the worker observes:

  • a cast on a broken leg or arm
  • a person walking on crutches
  • a person wearing a neck brace

Visual observations of an exemption due to being physically unable to work are not limited to the above conditions.

Workers must still ask the relevant questions regarding the details of the customer's condition, document the responses, and document ALL of the exemptions that the customer qualifies for.

New SNAP Work Requirement Screener in ABE

A new SNAP Work Requirement Screener is now available on the Application for Benefits Eligibility (ABE) website. Customers can use this tool to find out if they might be exempt or subject to the SNAP Work Requirement.

To access the SNAP Work Requirement Screener, a button called, "Check if I Meet SNAP Work Requirements", has been added to the ABE homepage. Clicking this button will take customers to the mobile-friendly screener that helps them figure out if they need to meet the SNAP Work Requirement. Customers are not required to have an ABE account or IES case to use the SNAP Work Requirement Screener.

Customers answer a series of screener questions to find out if they are likely exempt from or subject to the SNAP Work Requirement. The screener will provide additional information including how to submit a request for exemption.

Granting Work Requirement Exemptions

When a customer qualifies for more than one exemption, the FCRC worker must update Data Collection in IES for each exemption and document all the Work Requirement exemptions in IES Case Comments that each household member qualifies for. IES will prioritize them and then apply the exemption that will be in effect the longest amount of time. 

If during the certification period, an ABAWD subject to the SNAP Work Requirement has a change in circumstance that results in the customer now meeting an exemption, the FCRC must act promptly to apply the exemption. The FCRC worker should not assign a countable month once information is received that is not questionable and indicates an ABAWD subject to the SNAP Work Requirement now qualifies for an exemption, see PM 03-25-06.

To grant the exemption, FCRC workers must update Data Collection in IES and/or enter a manual exemption on the Exemptions - Details page in IES. After updating the case and running eligibility, workers must review eligibility results on the Eligibility Summary page in IES to make sure customers are given the correct SNAP Work Requirement exemptions if they qualify for one.

Verification of Work Requirement Exemptions - Only When Questionable

Verification of a SNAP Work Requirement exemption is not needed from the customer. Client statement is an acceptable verification to allow a SNAP Work Requirement exemption.

However, if there is a direct contradiction between the information provided by the household and other information provided to the FCRC or available in clearances, the customer may be asked to verify their exemption(s).

Note: A customer may be eligible for more than one exemption. Questionable information provided for one exemption may not need verified if eligibility for a different exemption exists.

Before requesting verifications from the customer, the FCRC worker must first attempt to verify the exemption using clearances and any other information available to them.

If verification is still required after reviewing clearances and other available information, the FCRC worker should:

  • Not pend the case;
  • Manually issue a Verification Checklist (IL444-0267) or a SNAP Work Requirement Request - Medical Service Provider Unable to Work Determination (IL444-2340) for medical related exemptions;
    • Note: The IL444-2340 is an optional form. A medical related SNAP Work Requirement exemption can also be verified by a healthcare professional's written statement, collateral contact or other verification from a healthcare professional.
  • Certify the case without the exemption; and
  • Document the actions taken on the case.

Meeting the SNAP Work Requirement

To meet the Work Requirement a person must:

  • Work (paid or unpaid) an average of 20 hours per week (80 hours per month), see PM 03-25-05 for the ABAWD definition of work; or
  • Volunteer to take part and comply with a work program an average of 20 hours per week (80 hours per month). A work program could be a federal, state, or local work program, or one of the following SNAP Employment and Training (E&T) activities, if available: Basic Education, Vocational Training, Work Experience, Community Workfare, Earnfare; or
  • Do self-initiated Community Service with a community-based organization for an average of 20 hours per week (80 hours per month); or
  • Do any combination of the above.

Note: Participation in SNAP E&T is voluntary, but the individual must still perform the activity for the required number of hours to meet the Work Requirement. Community Workfare is based on the household's SNAP benefit amount divided by the State minimum wage. Community Workfare placement can only be done through a SNAP E&T Provider.

The number of hours a customer is expected to work or participate in an activity to meet the SNAP Work Requirement must be verified at the time of initial application, redetermination, or whenever an exempt customer becomes nonexempt. Once it is verified, do not require the customer to provide verifications monthly.

Good Cause - Not Meeting Work Rules

A customer who is meeting the Work Requirement by working an average of 20 hours per week but misses some work for good cause can still be considered as having met the Work Requirement, if it is temporary and the job is still retained. Good cause includes circumstances beyond the customer's control, such as an illness, a household emergency, or lack of transportation.

Eligibility Limits - Three Countable Months of SNAP Benefits

A person who is required to comply with the SNAP Work Requirement is limited to 3 months of SNAP benefits in a fixed 3-year period if the Work Requirement is not met and does not qualify for an exemption. The current fixed 3-year period started January 1, 2024, and ends December 31, 2026.

The 3 countable months do not have to be consecutive. A SNAP application prorated benefit month does not count toward the 3 months.

Once 3 countable months have been received, a nonexempt customer remains ineligible for the remainder of the 3-year period, unless he or she regains eligibility or becomes exempt.

Countable Months Received in Another State

Countable months of SNAP benefits received in another state by nonexempt customers who were not meeting the SNAP Work Requirement is verified by the other state's verbal or written attestation, an IL444-0267 to the household is not needed. The verified countable months of SNAP benefits received by nonexempt ABAWDs who were not meeting the Work Requirement will count towards the 3 months of time-limited SNAP.

FCRC workers must screen households for any out of state SNAP benefits received in the last 12 months at both initial application and redetermination interviews.

If during the interview or on the application the household indicates that out of state SNAP benefits were received in the last 12 months by an ABAWD in the SNAP household, the FCRC worker must verify if any of the months in which benefits were received were countable months in that state. The FCRC worker must also verify if any of the additional 3 consecutive months were used, see the "Additional 3 Consecutive Months of SNAP Benefits" section below. 

FCRC workers are instructed to contact the other state to determine if any countable months of SNAP benefits were received by a nonexempt ABAWD who was not meeting the SNAP Work Requirement. Only the out of state benefits received during Illinois' current 3-year fixed period should be considered when determining if the benefits received in the other state count towards the customer's 3-month time limit.

The FCRC worker can access the National Directory of SNAP Contacts for the state's contact information. The other state's verbal attestation is all that is needed to verify the countable months.

If the other state cannot be reached at the time the case is being processed, workers should pend the case in IES using the "Program Verification" feature on the Eligibility Summary page to allow 10 days for the other state to respond. If an IL444-0267 is being issued for other necessary verifications, it does not need to include the verification of countable months received in another state, the worker may delete the notice if no other verifications are being requested.

Note: Expedited SNAP benefits should not be pended for countable months of SNAP received in another state, see the Expedited SNAP Application Guide. If verification is required for Countable Months of SNAP received in another state, only pend non-expedited months.

Do not delay processing of SNAP benefits after the 10 days have passed. If the other state has not responded, no negative action is taken, process the case without including any countable months for the household.

ABAWDs who are being added to an active SNAP case should also be screened for out of state SNAP benefits received in the last 12 months. FCRC workers should follow the same procedure that is described above for initial applications and redeterminations.

Note: A written request is not necessary to add a customer to an active SNAP case. But if one is received, workers must screen it for any indication of out of state SNAP benefits having been received. If the request to add an ABAWD is received by telephone/in-person, the FCRC worker must screen at that time for SNAP benefits received in another state in the last 12 months.

Regaining Eligibility

Customers who use their 3 months of time-limited SNAP and lose SNAP benefits due to not meeting the SNAP Work Requirement can regain eligibility at anytime in any of the 3 following ways:

  1. Qualify for an exemption and request or reapply, if necessary, for SNAP benefits; or
  2. Request SNAP benefits or reapply, if necessary, when their time-limited SNAP clock is reset in the next 3-year period; or
  3. By showing proof that they have done one or a combination of the following in a 30 consecutive day period prior to the date of application or request for SNAP benefits:
    • Worked (paid or unpaid) an average of 20 hours per week (80 hours per month); or
    • Volunteered and complied with one of the following SNAP E&T activities an average of 20 hours per week (80 hours per month), if available: Basic Education, Vocational Training, Work Experience, Community Workfare, Earnfare; or
    • Self-initiated in Community Service with a community-based organization for an average of 20 hours per week (80 hours per month).
      • Note: Proof must be shown that eligibility can be maintained in order to regain eligibility.

Proof may be check stubs showing the hours worked or an applicable activity form signed by the service provider that verifies the weekly or monthly hours the individual is expected to work or has worked. Once it is verified, do not require the person to provide verifications monthly, see PM/WAG 03-25-03. There is no limit on the number of times a person may regain eligibility.

At reapplication, an individual who has received 3 months of SNAP benefits and who is not exempt or has not met one of the Work Requirements in a 30 consecutive day period prior to the date of application is ineligible for SNAP.

Additional Three Consecutive Months of SNAP Benefits

There are two scenarios in which a customer who has used their 3 allowable months, but is no longer meeting the Work Requirement, may be eligible for 3 additional months.

  1. The customer regains and maintains eligibility to be approved for SNAP ongoing and then later stops meeting the Work Requirement; or
  2. The customer has met the criteria to regain eligibility for at least one month, but has not been receiving benefits.
    • Example: A customer lost benefits after not meeting the Work Requirement for the allowable 3 months. The customer later found work, but chose not to reapply because they felt their income was sufficient. The customer then lost their job through no fault of their own, and decides to apply for benefits.

The additional 3 consecutive months begin:

  • On the date the customer who had regained and been maintaining benefits first notifies the FCRC that they are no longer meeting the requirement; or
  • On the date a customer who had not been receiving benefits reapplies or requests SNAP benefits.

An application prorated month does not count as one of the 3 months. The additional 3-month benefit period runs for 3 consecutive countable months, regardless of whether the person receives benefits in all 3 months. The additional 3 consecutive months is issued only one time in any 3-year period.

Forms Updates

The following forms have been updated with this Policy Memo:

  • SNAP Work Requirement Notice (IL444-2293)
  • SNAP Work Rules - Unable to Work Determination (IL444-2340)
  • SNAP Work Rules - Request for Exemption (IL444-2341)
  • SNAP Work Requirement - Community Workfare Verification (IL444-3673) - (IES version only)
  • SNAP Work Rules (IL444-5175)

Customer Notification

Active customers determined to potentially be an ABAWD who are not meeting or exempt from the SNAP Work Requirement will receive CN 25.10/25.10S Notice of SNAP Work Requirement Changes informing them of their potential non-exempt status. The mailing will also include the SNAP Work Rules - Request for Exemption (IL444-2341) form which includes the list of exemptions for the Work Requirement. The customer can complete and submit the form to request an exemption.

A list of Frequently Asked Questions (FAQs) regarding the SNAP Work Requirement will also be posted to the Illinois Department of Human Services (IDHS) homepage for customers to refer to in the upcoming weeks.

FCRC Action

FCRCs must:

  • Explain to SNAP households what the SNAP Work Requirement is, how to meet it, who is exempt, what happens if they do not meet it, and screen them to see if they are eligible for any exemptions. Also inform them about the SNAP Work Requirement screener in ABE.
  • Not request verification of an exemption unless there is a direct contradiction between the information provided by the household and other information provided to the FCRC or available in clearances.
  • Review eligibility results in IES to make sure customers are given the correct SNAP Work Requirement exemptions if they qualify for one.
  • Screen households for SNAP benefits received in other states in the prior 12 months of application. If out of state benefits have been received, contact the other state using the National Directory of SNAP Contacts to verify countable months.
  • Review eligibility, run eligibility and certify cases that did not get updated in the automatic batch update process.

[signed copy on file]

Dulce M. Quintero

Secretary, Illinois Department of Human Services

Forms referenced:

CN 25.10/25.10S

IL444-0267

IL444-2293

IL444-2340

IL444-2341

IL444-3673

IL444-5175