By GARRY RAYNO, InDepthNH.org

CONCORD — Some people on the Supplemental Nutrition Assistance Program may find their food benefits this Thanksgiving are at risk due to a new federal work requirement law.

The new work requirement law eliminated exemptions for veterans, the homeless, parents with children 15 to 18 years old, and former foster youths to the age of 24 years old.

The change to eligibility is expected to mean thousands of state residents who were exempt until the rules changed Nov. 1 will now have to meet the federal work requirements of at least 80 hours a month of work, volunteer time, or participation in a training program to receive benefits for longer than three months during a three-year period.

For most of those affected by the changes, the impact will not be immediate, but occur when they have to be recertified, according to Laura Milliken, executive director of NH Hunger Solutions, and many that lose their group exemptions will still qualify under individual categories.

“You will not see a work surge,” she said, “because most people on SNAP who can work, are working.”

What work requirements do is create a lot of red tape that serves as a barrier and throws people off the program, Milliken said.

“For someone with two or three part-time jobs, (meeting the new work requirements) is like another part-time job,” she said, “just to get the signatures and paperwork needed to hand in.”

If a person’s hours fall below 80 hours in a month, he or she must inform the Department of Health and Human Services within 10 days and they will only be given benefits for three months in a three-year period, but can resume the program if the work requirement is met in the future.

The work requirements apply to recipients between the ages of 18 and 64 years old, parents who do not have a child younger than 14 years old in their home, and those physically and mentally able to work.

Until the new law that was included in the “one big beautiful bill” that contained President Trump’s priorities for his second term, passed, the work requirements applied to people between 18 and 54 years old.

She said the bill expanded those who would have to work, but many will be able to assert an individual exemption.

The recent government shutdown when people went four or five days without SNAP benefits at the beginning of the month makes people anxious if they can feed themselves, Milliken said.

She noted the charitable food system is overwhelmed today even with the restoration of SNAP benefits, and they are afraid they will not be able to sustain services at that level going forward.

The NH Food Bank wants its outreach contract with the state renewed because they are still seeing a surge of people, Milliken noted.

When it appeared New Hampshire SNAP beneficiaries would not receive SNAP benefits beginning Nov. 1 due to the federal government shutdown, the state contracted with the NH Food Bank to provide additional mobile sites to help those on the program.

Under the new regulations, in order to receive SNAP benefits for more than three months, a recipient must be working for pay, working for goods and services, in an approved training program, or volunteering for at least 80 hours a month.

You do not need to work if you are:

Younger than 18 years old;

You have someone younger than 14 years old in your household;

You have a mental or physical condition that prevents you from working;

You are pregnant;

You provide care for someone who cannot care for themselves;

You work 30 hours a week or earn at least $217.50 a week;

You receive or are applying for unemployment benefits;

You are a student enrolled at least half time in any recognized school, training program or institution of higher learning.

You are already meeting the work requirements in the Financial Assistance for Needy Families Program;

Or you are in a drug or alcohol treatment program.

While the federal changes impact needy individuals it will also impact state government finances.

Beginning in October 2026, the state will have to pick up an additional 25 percent of the costs of administering the program. Currently the state and federal government have split the cost of administering the program, but next year the split will be 75 percent for the state and 25 percent for the federal government.

Milliken said that is an additional $5.75 million added on top to the state’s $11 million appropriation for administering SNAP.

The following year, the state will have to reduce its error rate which occurs when a mistake in the benefit amount is made either by the state or if a person makes a mistake on an application, but is not fraud.

The national average for the error rate is 6 percent and states with rates above that level will be penalized beginning in 2027.

Currently the state’s error rate is 7.57 percent for last year.

Milliken said the state penalty if it does not improve its error rate will be between $8 million and $23 million based on the level of the error.

She said the staff determining the benefit level at HHS has not not grown bigger because of the changes the federal government made, making it almost impossible for the state to significantly reduce its error rate fast enough to avoid penalties.

“This mess was not created by the state,” Milliken said, “it was the federal government.”

The SNAP program is good for the state, she said, bringing in millions of dollars for people to spend on food, which benefits grocery stores and their employees, as well food producers and farmers.

She said last year the program spent $154 million in direct benefits to people, with a ripple effect of $234 million across the economy.

And she said there is very little fraud in the program. 

“The notion that someone is getting away with anything,” Milliken said, “is absolutely false.”

Garry Rayno may be reached at garry.rayno@yahoo.com.