Where SNAP time limit waivers ended: the areas that lost their ABAWD waiver after H.R. 1

Key findings

1. Waivers went from 30 states and territories to 12. On July 1, 2025, days before H.R. 1 became law, USDA listed 6 statewide waivers (California, District of Columbia, Guam, Illinois, Nevada and U.S. Virgin Islands) and 24 states with some areas waived. On October 1, 2026, it listed no statewide waivers and 12 states with some areas waived. 18 of the 30 lost every waived area: Colorado, Connecticut, Delaware, District of Columbia, Guam, Hawaii, Illinois, Maine, Massachusetts, Montana, New Hampshire, North Dakota, Pennsylvania, Rhode Island, South Dakota, U.S. Virgin Islands, Virginia and Washington.
2. 522 of 531 counties and all 299 cities and towns named in the July 2025 approvals are no longer waived. The 21 partial-waiver letters we could read named 914 areas: 531 counties, 299 cities and towns and 84 tribal areas. On USDA approvals for November 1, 2026, only 9 of those counties and none of those cities and towns are still named. In the same states, tribal areas went from 84 on those letters to 27 on approvals for November 1, 2026. These counts leave out the 6 statewide waivers and 3 states whose letters are not posted (Hawaii, Massachusetts and Virginia).
3. Large cities that were waived no longer are. All five New York City boroughs were on New York’s approval through February 28, 2026. Philadelphia, Pittsburgh, Louisville, Tucson, Buffalo, Rochester, Syracuse, Newark and Jersey City were in waived areas on July 1, 2025, and Los Angeles, Chicago, Las Vegas and Washington, D.C. were covered by statewide waivers. None of them is waived now. In Michigan, Bay City, Detroit, Eastpointe, Flint, Jackson and Saginaw kept a waiver as cities under an approval that ends October 31, 2026.
4. 6 more states’ waivers end between October 31 and December 31, 2026. Alaska, Michigan, Kentucky, Minnesota, New Mexico and Oregon have 69 waived areas between them, and as of October 31, 2026 USDA had posted no renewal request or approval for any of them. If none is approved, only 6 states will have any waived area on January 1, 2027: Arizona, California, Nevada, New Jersey, New York and Wisconsin.
5. What is left is mostly tribal land and a few rural counties. Of the 57 areas approved for November 1, 2026, 39 are reservations, colonies, pueblos or trust land and 17 are counties. Every one met H.R. 1’s new test: unemployment over 10%, or 1.5 times the national rate in Alaska and Hawaii.
6. CBO expects about 1 million fewer people on SNAP in an average month because of the waiver change. The Congressional Budget Office estimated that Section 10102 as a whole would reduce SNAP participation by roughly 2.4 million people in an average month over 2025 to 2034. About 1 million of them are adults 18 to 54 without dependents who, before the law, would have been covered by a waiver. We found no state-by-state official count.

How the number of waivers fell

Waivers approved under the old rules ran to their end dates, so states dropped off USDA’s list one by one. As each approval ended, a state could renew only areas that met the new test.

Results for every state and territory

All 30 states and territories on USDA’s July 1, 2025 list. Click a column heading to sort. “Areas named” counts the counties, cities, towns and tribal areas in the approval letter in effect that day; each date links to that letter. “Areas waived Nov 1, 2026” counts the areas on USDA approvals covering that date.

Large cities in areas that lost their waiver

Each city is named by the waived area it sits in. Where a county is listed, the city is that county’s largest city or county seat.

• Brooklyn (New York City) (New York, Kings County): the approval in effect July 1, 2025 ran to February 28, 2026.
• Queens (New York City) (New York, Queens County): the approval in effect July 1, 2025 ran to February 28, 2026.
• Manhattan (New York City) (New York, New York County): the approval in effect July 1, 2025 ran to February 28, 2026.
• The Bronx (New York City) (New York, Bronx County): the approval in effect July 1, 2025 ran to February 28, 2026.
• Staten Island (New York City) (New York, Richmond County): the approval in effect July 1, 2025 ran to February 28, 2026.
• Los Angeles, San Diego, San Jose, San Francisco and every other California city (California, statewide waiver): the approval in effect July 1, 2025 ran to January 31, 2026.
• Chicago and every other Illinois city (Illinois, statewide waiver): the approval in effect July 1, 2025 ran to January 31, 2026.
• Philadelphia (Pennsylvania, Philadelphia County): the approval in effect July 1, 2025 ran to August 31, 2025.
• Pittsburgh (Pennsylvania, Allegheny County): the approval in effect July 1, 2025 ran to August 31, 2025.
• Las Vegas, Henderson and Reno (Nevada, statewide waiver): the approval in effect July 1, 2025 ran to January 31, 2026.
• Washington, D.C. (District of Columbia, statewide waiver): the approval in effect July 1, 2025 ran to December 31, 2025.
• Louisville (Kentucky, Jefferson County): the approval in effect July 1, 2025 ran to November 30, 2025.
• Tucson (Arizona, Pima County): the approval in effect July 1, 2025 ran to September 30, 2025.
• Buffalo (New York, Erie County): the approval in effect July 1, 2025 ran to February 28, 2026.
• Rochester (New York, Monroe County): the approval in effect July 1, 2025 ran to February 28, 2026.
• Syracuse (New York, Onondaga County): the approval in effect July 1, 2025 ran to February 28, 2026.
• Newark (New Jersey, Essex County): the approval in effect July 1, 2025 ran to January 31, 2026.
• Jersey City (New Jersey, Hudson County): the approval in effect July 1, 2025 ran to January 31, 2026.
• Spokane (Washington, Spokane County): the approval in effect July 1, 2025 ran to January 31, 2026.
• Tacoma (Washington, Pierce County): the approval in effect July 1, 2025 ran to January 31, 2026.
• Vancouver, Wash. (Washington, Clark County): the approval in effect July 1, 2025 ran to January 31, 2026.
• Grand Rapids (Michigan, Grand Rapids city): the approval in effect July 1, 2025 ran to February 28, 2026.
• Lansing (Michigan, Ingham County): the approval in effect July 1, 2025 ran to February 28, 2026.
• Ann Arbor (Michigan, Washtenaw County): the approval in effect July 1, 2025 ran to February 28, 2026.
• Eugene (Oregon, Lane County): the approval in effect July 1, 2025 ran to December 31, 2025.
• Salem, Ore. (Oregon, Marion County): the approval in effect July 1, 2025 ran to December 31, 2025.
• Providence (Rhode Island, Providence city): the approval in effect July 1, 2025 ran to February 28, 2026.
• Bridgeport (Connecticut, Bridgeport city/town): the approval in effect July 1, 2025 ran to November 30, 2025.
• New Haven (Connecticut, New Haven city/town): the approval in effect July 1, 2025 ran to November 30, 2025.
• Hartford (Connecticut, Hartford city/town): the approval in effect July 1, 2025 ran to November 30, 2025.
• Las Cruces (New Mexico, Dona Ana County): the approval in effect July 1, 2025 ran to December 31, 2025.
• Fairbanks (Alaska, Fairbanks North Star Borough): the approval in effect July 1, 2025 ran to October 31, 2025.
• Juneau (Alaska, Juneau Borough/city): the approval in effect July 1, 2025 ran to October 31, 2025.
• Wilmington, Del. (Delaware, Wilmington city): the approval in effect July 1, 2025 ran to September 30, 2025.
• Racine (Wisconsin, Racine City): the approval in effect July 1, 2025 ran to September 30, 2025.
• Pueblo (Colorado, Pueblo County): the approval in effect July 1, 2025 ran to September 30, 2025.

Waivers ending October 31 to December 31, 2026

• Oct 31, 2026: Alaska, 20 areas (20 counties)
• Oct 31, 2026: Michigan, 29 areas (15 counties, 6 cities, 8 tribal areas)
• Nov 30, 2026: Kentucky, 5 areas (5 counties)
• Nov 30, 2026: Minnesota, 5 areas (1 county, 4 tribal areas)
• Dec 31, 2026: New Mexico, 5 areas (1 county, 4 tribal areas)
• Dec 31, 2026: Oregon, 5 areas (5 tribal areas)

When a waiver ends, the time limit can apply from the next month to adults 18 to 64 who are not exempt. Months spent in a waived area never count toward the 3 months. See every waived area for the current lists. California’s 2025-2026 list also ends October 31, 2026, but a new approval starts November 1 (Alpine County drops off and Kings County is added).

Methodology

• Before: USDA FNS’s quarterly list of waivers in effect on July 1, 2025, the last list before H.R. 1 was signed on July 4, 2025. For each state on it, we used the FNS approval letter covering July 1, 2025, from FNS’s waiver pages, and copied every area named in the letter’s tables.
• Now: FNS’s list of waivers in effect October 1, 2026, and the FNS approval letters for waivers starting since, as listed on our waived areas page. “Areas waived Nov 1, 2026” means areas on an approval that covers that date, as posted on October 31, 2026.
• Counting areas: counties include boroughs, census areas and two Pennsylvania “balance of county” areas. Cities and towns include townships, plantations and unorganized territories. Tribal areas include reservations, pueblos, colonies and trust land. A county, city or town counts as still waived only if the same name is on a current approval, so a county is “not waived” even if one city inside it is (for example Wayne County, Michigan, and Detroit). Tribal area names differ from letter to letter, so we compare tribal areas only as totals.
• Gaps: Hawaii, Massachusetts and Virginia are on the July 1, 2025 list, but the only letters FNS posted for them ended June 30, 2025, so their areas are not counted. Connecticut’s letter says 68 towns but names 67, and New Mexico’s says 18 reservations but names 14; we count the names. We did not check whether any state ended a waiver early, which states may do.
• No estimates: we do not estimate how many people live in each area or lost benefits. The only official figure of people affected we found is CBO’s national estimate.

Use and cite this study

Journalists, researchers and advocates may quote or republish these figures and the table with a link to this page. Suggested citation:

SNAP Work Requirements, “Where SNAP Time Limit Waivers Ended: The Areas That Lost Their ABAWD Waiver After H.R. 1,” October 2026, https://snapworkrequirements.com/waiver-study/

For a state’s full list of areas, or questions about the data, contact us. People on SNAP can check whether the time limit applies to them with the free SNAP work requirement checker.