According to the US Department of Housing and Urban Development’s (HUD’s) 2024 Annual Homelessness Assessment Report, nearly 770,000 people experienced homelessness on a single night in January 2024, an 18% increase from the prior year and the highest total since point-in-time counts began in 2007. Family homelessness surged by almost 40%, and unsheltered homelessness grew in parallel, with more than one-third of all unhoused individuals living in tents, vehicles, encampments, or other places not meant for human habitation. Chronic homelessness also reached a record high, with over 152,000 people experiencing long-term or repeated episodes of homelessness; nearly two-thirds were unsheltered.
The Supplemental Nutrition Assistance Program (SNAP) is one of the most effective stabilizers for extremely low-income households, reducing food insecurity by up to 30% and lowering downstream healthcare costs, according to research from the University of Pennsylvania Leonard Davis Institute of Health Economics and Harvard Public Health scholars. For people experiencing homelessness, particularly those who are unsheltered, SNAP access often determines whether limited resources can be redirected toward transportation, medical care, or pathways into housing.
The H.R. 1 One Big Beautiful Bill Act (OBBBA) marks a critical turning point. By expanding Able Bodied Adults Without Dependents (ABAWD) requirements and tightening SNAP and Medicaid eligibility, the bill reshapes access to public assistance programs that help prevent people from falling deeper into homelessness. New compliance hurdles threaten food security for many unsheltered individuals who cannot realistically meet the documentation and work requirements. The OBBBA ABAWD expansion points to the need for a new statewide approach to unsheltered homelessness that better supports the safety and health of unsheltered families.
Why unsheltered adults are most at risk under ABAWD rules
Under OBBBA, SNAP eligibility and participation rules are significantly tightened through an expansion of ABAWD requirements. The law extends SNAP time limits to all adults ages 18-64 and eliminates the longstanding exemption for people experiencing homelessness. Individuals subject to ABAWD rules must now document at least 80 hours per month of work, job training, or qualifying volunteer activities to maintain benefits. OBBBA also narrows overall SNAP eligibility, resulting in benefit losses for additional groups, including certain immigrants, such as asylees and parolees, individuals with deportation withheld, and individuals exiting the foster care system.
These changes have particular implications for people experiencing homelessness, for whom meeting work and reporting requirements is often far more difficult. Unhoused individuals frequently lack a permanent address, reliable transportation, or consistent access to phones, internet, or mail. Lost identification documents, irregular schedules, and high rates of chronic physical and behavioral health conditions further limit their ability to document hours or navigate verification systems. Older unhoused adults, now newly subject to ABAWD rules, often face compounded barriers due to health conditions or unstable work histories.
At the same time, OBBBA increases administrative and reporting demands across SNAP. For individuals without stable housing, these added requirements raise the risk of procedural disenrollment even when eligibility criteria are technically met. As SNAP access declines, food insecurity among people experiencing homelessness is expected to increase, shifting greater demand onto food pantries, shelters, and other emergency food providers. Estimates from the Urban Institute suggest that nearly 700,000 young adults could lose some or all SNAP benefits each month under expanded work‑reporting rules, underscoring the scale of potential impact.
SNAP ABAWD requirements: Before and after OBBBA

OBBBA significantly expands SNAP ABAWD requirements, removing the longstanding homelessness exemption and increasing documentation and work reporting expectations.
What states can expect
States must now implement expanded ABAWD rules under far tighter federal expectations. OBBBA increases state administrative cost‑sharing for SNAP and adds new sanctions, reporting mandates, and verification requirements, creating significant fiscal and operational strain for human services agencies already managing complex caseloads.
OBBBA’s SNAP changes result in:
- Increased administrative costs and cost-sharing
- Need to modify systems and technologies
- Close workforce and provider capacity gaps, such as workforce training slots, subsidized employment programs
- Documentation bottlenecks and backlog due to increased reporting and verification requirements
- Concerns over equity impact, including older adults, individuals with disabilities, and vulnerable populations
- Increased pressure on emergency services
- Additional pressure on community partners and systems as more people lose benefits
Collectively, states face greater fiscal pressure: increased responsibility for SNAP administration and rising demand from individuals who have become newly food‑insecure.
What can states do?
States can consider the following strategies across eligibility, workforce, and employment programs to mitigate these risks.
- Strengthen ABAWD Screening and Exemption Identification
With the elimination of the homelessness exemption, states must ensure all remaining exemptions are identified early and accurately, particularly physical or mental unfitness for work, which is highly prevalent among unsheltered adults. States can:
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Train eligibility workers, outreach teams, shelter staff, and case managers to flag individuals likely to qualify for exemptions
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Build Direct Pathways into SNAP Employment & Training (E&T)
For individuals unable to secure consistent work hours, E&T will become a primary compliance pathway. States can:
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Co-locate Eligibility Services in Homelessness Settings
Preventing procedural terminations will require bringing eligibility services directly to people experiencing homelessness. States can:
- Deploy mobile eligibility teams to shelters, encampments, day centers, meal sites, and transitional housing
- Embed SNAP, Medicaid, and workforce eligibility staff in high-volume service providers, including behavioral health clinics and social service providers
- Establish rapid recertification stations to assist with reporting, documentation, and renewals
- Partner with libraries and community centers to provide digital access, printing, and identity verification support
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Coordinate SNAP, Medicaid, and housing systems
Because OBBBA also imposes Medicaid cuts and work requirements, cross-program coordination is essential to maintain stability. States can:
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Strengthen housing placement infrastructure
Loss of nutrition and health benefits increases the risk of prolonged homelessness, making housing exits more urgent. States can:
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Reduce administrative burden
Expanded ABAWD rules significantly increase administrative demands. To reduce churn and unnecessary benefit loss, states can:
- Automate work hour reporting and simplify notices.
- Implement presumptive eligibility for high-risk populations while documentation is gathered.
- Expedite renewals and recertifications for individuals facing termination due to administrative barriers.
State strategies to mitigate ABAWD-related risk
States can mitigate the impact of expanded ABAWD requirements through coordinated eligibility, workforce, housing, and administrative strategies.
OBBBA’s expanded ABAWD time limits and massive cuts to SNAP arrive at a moment of rising unsheltered homelessness, shrinking safety nets, and deepening public health risks. The combination threatens to push thousands of adults into homelessness while overwhelming state systems. By recognizing the convergence of ABAWD rules and unsheltered homelessness and responding proactively, states can prevent avoidable harm, reduce long-term costs, and stabilize residents on the brink. 
BerryDunn can help
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