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Page 2 of 7 Guidance documents lack the force and effect of law, unless expressly authorized by statute or incorporated into a contract. USDA may not cite, use, or rely on any guidance that is not available through their guidance portal, except to establish historical facts. Supplemental Nutrition Assistance Program (SNAP) Time Limit Provisions of the One Big Beautiful Bill Act of 2025 (OBBB) Question and Answer #1

A. Changes to Exception Criteria A.1 Increase in Upper Age Limit 1. Did the OBBB change the definition of “elderly”? No. The OBBB increases the age of those subject to the time limit from those aged 18 through 54 to those aged 18 through 64. However, the OBBB did not amend the definition of “elderly” at Section 3(j) of the Food and Nutrition Act (“the Act”), defined as “60 years of age or older.” Therefore, State agencies must continue to apply other policies for elderly individuals to those aged 60 or older, such as the availability of excess medical deduction and the lack of a cap on excess shelter deduction.

2. Are individuals aged 60 to 64 subject to the general work requirements? No. The OBBB did not change who is subject to the general work requirements. Individuals aged 60 to 64 are not subject to the general work requirements, per section 6(d)(1)(A) of the Act. While FNA has historically referred to time-limited participants as a subset of the individuals subject to the general work requirements, now there is a group of individuals who are subject to the time limit even though they are not subject to the general work requirements.

3. Can State agencies require time-limited participants aged 60 to 64 to participate in mandatory employment and training? No. State agencies may not require individuals aged 60 to 64 to participate in mandatory employment and training (E&T). These individuals may voluntarily participate in E&T.

4. Are individuals aged 60 to 64 subject to the time limit even though they are exempt from the general work requirements based on age? Yes. Individuals aged 60 to 64 are subject to the time limit, unless they meet another exception.