More than 5 million Californians rely on monthly benefits from CalFresh—the state’s version of the Supplemental Nutrition Assistance Program (SNAP)—to meet their basic food needs. It has been the state’s most universally available social safety net program and plays a large role in reducing poverty. Federal legislation signed into law in July (known as HR1) made several significant changes to nutrition assistance that are likely to substantially narrow CalFresh’s reach. How many Californians will be affected by one key element of the legislation—new rules regarding work requirements?

First, the changes: The new law requires all adults ages 18–64 to maintain adequate hours of work or training—or qualify for an exemption—in order to maintain CalFresh eligibility. Otherwise, participation will be limited to three months out of three years. In the past, California qualified for a statewide waiver for work-based time limits because the state’s unemployment rate was 20% higher than the national rate (this applied to adults ages 18–54 without dependents). As of this month, only three counties retain waivers (Colusa, Tulare, and Imperial) because their average unemployment rates are above 10%. With broader work requirements newly in place across most of the state, many CalFresh participants will soon have three months to document employment, training, volunteering, or an exemption—or lose benefits.

Next, the numbers: Of the 2.5 million adults ages 18–64 who receive CalFresh in a typical month, about 1.1 million (46%) could see their benefits time-limited if they do not meet or qualify for an exemption from work requirements, according to our calculations. (The remaining 54% are exempted because they have children younger than 14 or a documented disability.) Most of those affected by time limits are in single-person households (74%), and 3 in 10 are ages 55–64.

About 21% of the 1.1 million adults facing time limits are currently meeting work requirements based on their earnings, hours of employment, or receipt of unemployment insurance benefits. However, because CalFresh participants who are working often have volatile earnings and employment, many may move in and out of compliance with work requirements. For example, we estimate that 12% of those not meeting the work requirement (and not otherwise excused) are working but have insufficient hours to meet the requirement. Others may qualify for additional types of exemptions, including being enrolled in school for more than half time, being physically or mentally unfit for employment, or caring for an incapacitated person—available data indicate that 25% could qualify.

Among the remaining 620,000, at least 6 in 10 could lose benefits, since they have had CalFresh for at least three months. (It is typical to be enrolled for longer than three months: More than half of those who are employed even before seeking assistance are still enrolled more than 6 months later.)  The impact of losing benefits will be large: On average CalFresh makes up 73% of household resources for those not currently exempted or meeting work requirements, and 56% of this group of adults have no recorded income apart from CalFresh.

Screening participants for exemptions for which they are eligible is particularly important, as HR1 rescinded exemptions added in 2023 for those experiencing homelessness, veterans, and former foster youth. While existing data are insufficient to count veterans and foster youth, we estimate that 200,000 of the 370,000 adults flagged as experiencing homelessness in CalFresh records are likely now subject to and not meeting, or excused from, work requirements. This group amounts to nearly a third of the adults now facing time-limited assistance. States do have discretion to exempt an additional share of adults subject to work requirements, creating an additional need to prioritize adults who do not qualify for an exemption.

If work requirements went unmet or participants were not exempted from them, adults facing time limits would not be the only ones impacted. About 160,000 people—mainly teens (47%) and adults age 65+ (32%)—live with someone now facing time limits. These CalFresh participants would keep their portion of the household benefit, but the household’s resources would be lower.

As counties seek to ensure that participants will receive CalFresh for the entire time they are income eligible, they will need to thoroughly screen for exemptions and document activities that meet work requirements on a monthly basis. Identifying ways to streamline processes will be key to success, since these expanded duties will substantially increase the workload of county employees. Ensuring accuracy is also particularly pressing in light of another change from HR1: For the first time ever, the state and counties will be responsible for part of the cost of benefits if the payment error rate exceeds a predetermined threshold.

As the state responds to a shifting federal landscape, PPIC will continue to track the impacts of these changes.