80 Hours a Month: The Work Requirement Expansion That Will Reshape Every CBO's Caseload by 2027

The One Big Beautiful Bill Act, signed July 4, 2025, set in motion the largest simultaneous expansion of work requirements across federal safety net programs in history. SNAP requirements are already in effect. Medicaid “community engagement” requirements must be implemented by January 1, 2027. For the families you serve, these aren't separate policy changes. They're one converging reality—and the organizations that help them navigate it need infrastructure that most communities haven't built yet.

What Changed

SNAP's Able-Bodied Adults Without Dependents (ABAWD) age range expanded from 18–54 to 18–64, and the requirement now applies to adults with dependents aged 14 and older. Previous exemptions for veterans, individuals experiencing homelessness, and former foster youth have been narrowed or eliminated. The magic number across both SNAP and Medicaid is 80 hours per month—work, job training, education, or community service that must be documented and reported monthly.

The Congressional Budget Office estimates $187 billion in SNAP cuts over the next decade—the largest cut to the program ever enacted. Roughly 800,000 to 1 million older adults ages 55–64 and 700,000 young adults are projected to lose some or all SNAP benefits in a typical month. An additional 5.2 million people are projected to lose Medicaid coverage by 2034, with 4.8 million becoming uninsured.

We Already Know What Happens Without Infrastructure

When Arkansas implemented Medicaid work reporting requirements, 18,000 adults—one in four of those subject to the requirement—lost coverage within seven months. A peer-reviewed study found the requirement did not increase employment. People didn't lose coverage because they weren't working. They lost it because they couldn't navigate the reporting.

That's the pattern we're about to see at national scale. The individuals who lose benefits won't primarily be people who refuse to work. They'll be people whose caseworker at the workforce board doesn't know what their SNAP eligibility specialist requires, whose training hours counted for one program but weren't reported to another, whose 50-cent raise simultaneously triggered a benefits cliff and a compliance requirement that no one in the system saw coming.

The Infrastructure Question

States can only waive SNAP ABAWD requirements in areas where unemployment exceeds 10%, making relief nearly impossible in rural regions with limited job opportunities. The compliance burden falls directly on the organizations closest to the families. And those organizations are being asked to do something most weren't designed for: coordinate across programs simultaneously for the same individual.

When a single person must document 80 hours per month of qualifying activity for SNAP and Medicaid and potentially TANF, the agencies helping them need shared case management infrastructure—not three separate intake forms. They need warm handoffs between benefits enrollment and workforce teams. They need a single view of each family's full picture.

Requirements Without Systems Just Produce Disenrollment

The Arkansas data is the clearest evidence we have: work requirements without coordinated support infrastructure don't increase employment. They increase disenrollment. The distinction between outcomes and outputs has never mattered more. A disenrolled client is an output. A family that maintains benefits while building toward lasting economic stability is an outcome.

Community Action Agencies and Workforce Development Boards are about to become the coordination backbone for millions of families navigating simultaneous requirements. The question isn't whether this is your responsibility. It is. The question is whether your systems are ready.