Enacted July 4, 2025, the FY2025 budget reconciliation law (P.L. 119-21) included significant changes to the means-tested programs Medicaid and the Supplemental Nutrition Assistance Program (SNAP). The law created new Medicaid community engagement requirements for specified individuals (Section 71119) and expanded work requirements for SNAP (Section 10102). The Congressional Budget Office (CBO) estimated that the provision establishing the Medicaid community engagement requirements will reduce federal Medicaid outlays by $325.6 billion from FY2025 to FY2034, and the SNAP provision will reduce federal SNAP outlays by $69 billion over the same 10-year period. Policymakers may be interested in how the enacted policies compare and contrast as states and households face changes in both programs. P.L. 119-21 establishes a new community engagement requirement as a condition of Medicaid eligibility or continued enrollment for specified individuals who are eligible for (or enrolled under) the Affordable Care Act (ACA) Medicaid expansion pathway or who are eligible for (or enrolled under) a waiver that provides minimum essential health coverage. This group is technically known as “applicable individuals.” Prior to the enactment of P.L. 119-21, there was no statutory requirement for Medicaid enrollees comparable to the new community engagement requirement, although the new statutory provision builds on the first Trump Administration’s Medicaid Section 1115 demonstration waiver initiative that allowed states to implement Medicaid community engagement requirements. P.L. 119-21 built on an existing SNAP requirement for Able-Bodied Adults Without Dependents (ABAWDs). The ABAWD rule was enacted in the Personal Responsibility and Work Opportunity Reconciliation Act of 1996 (P.L. 104-193). P.L. 119-21 both expands the population subject to the ABAWD rule and shrinks available waivers and exemptions. The Medicaid community engagement requirement, once effective, and the expanded SNAP ABAWD rule both apply to Medicaid applicants and enrollees and SNAP participants within the same general population: (1) nondisabled adults between the ages of 18 and 64 for SNAP and the ages of 19 and 64 for Medicaid, without dependents, and (2) parents (and others who are caring for children) between the ages of 18 and 64 (19 and 64 for Medicaid) whose youngest child is aged 14 or older. Some individuals in these populations may be exempted, and some of the exemptions differ between Medicaid and SNAP. Both Medicaid and SNAP requirements can be met with 80 hours per month of employment, and both allow a combination of employment, participation in a work program, and participation in other activities to count toward the 80-hours-per-month requirement (though the other activities differ). Key differences include Medicaid’s special provisions for counting the earnings of seasonal workers toward meeting the community engagement requirement, a provision not available under SNAP; Medicaid’s exemption for individuals receiving SNAP who are already subject to SNAP’s work rules; and differing effective dates (December 31, 2026, or earlier at state option under Medicaid; July 4, 2025 for SNAP). Some individuals affected by the new and revised work requirements may be both Medicaid enrollees and SNAP participants. However, though both the new Medicaid and the revised SNAP requirements apply broadly to similar populations, there are differences in the eligibility rules between the two programs that mean some individuals may receive benefits under one program but not the other. CRS estimates that in 2025, out of 24.7 million persons who were either ACA Medicaid expansion adults without children under the age of 14 (i.e., persons included among the group of “applicable individuals” who are subject to the Medicaid community engagement requirement) or SNAP participants who were non-aged (under the age of 65), nondisabled adults without a child under the age of 14, an estimated 6.2 million were enrolled in both programs. Federal and state guidance and rulemaking are likely to influence how households, states, and other stakeholders experience the new law.
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