When Will Changes to SNAP and Medicaid Take Effect?

As additional work and reporting requirements roll out, older adults may struggle to retain benefits

Molly Snow,

AARP

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En español

Published July 11, 2025

red potatoes, green beans and yellow squash at a farmers market

Jeffrey Greenberg/Getty Images

In this story

New work requirements • Paperwork hurdles • Medicaid coverage changes • SNAP funding cuts • Medicaid funding changes

Extra reporting paperwork. New work requirements. Funding shifts. These changes will soon trickle down to millions of low-income adults who rely on federal nutrition assistance and health care.

The new federal spending law signed by President Trump July 4 will bring big changes to the Supplemental Nutritional Assistance Program (SNAP) and Medicaid — two programs that are lifelines for people with disabilities and limited resources. More than 11 million adults 50 and older use SNAP to keep food on the table, while more than 17 million adults 50 and older rely on Medicaid for essential health care services.

The changes on the horizon are expected to impact many of these people who struggle to afford nutritious food, prescription medications, long-term care and routine doctor visits. Adding further complexity, the changes roll out at different times and affect different people in different ways, creating potential for some to fall through the cracks.

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For example, some of the changes to Medicaid — including more frequent eligibility determinations and individual service charges — affect enrollees in the Medicaid Expansion program, or those under 65 residing in states where you can qualify by income alone if your earnings fall below 138 percent of the poverty level. All but 10 states have adopted Medicaid Expansion.

Roughly 3 million people could lose SNAP benefits due to expanded work requirements, according to initial estimates from the nonpartisan Congressional Budget Office. Up to 9 million Medicaid enrollees ages 50 to 64 may be at risk of losing health care coverage if they can’t meet — or be exempted from — Medicaid work requirements, according to AARP research.

These new burdens could “cost people their health care coverage, not because they are ineligible, but because they missed a deadline or could not navigate a complex system,” wrote Nancy LeaMond, AARP’s chief advocacy and engagement officer, in a letter to the House on May 21 urging lawmakers to protect access to Medicaid.

So, what can adults 50-plus expect to see as the legislation once known as the Big Beautiful Bill takes effect, and when will changes occur?

New and expanded work requirements

The first major changes will be the introduction of work requirements for older adults enrolled in Medicaid and the expansion of work requirements for SNAP.

Medicaid enrollees were not subject to federal work requirements previously, but going forward, nondisabled adults ages 18 to 64 without dependents will have to work, volunteer or be enrolled in school for 80 hours a month to get and maintain coverage. Parents of dependent children age 13 and under and those who are medically frail are exempt, among others.

By early 2027, work requirements for Medicaid enrollees will take effect.
Some states may institute work requirements sooner if they obtain a waiver that permits them to deviate from the statute to “test new approaches” to Medicaid.

The new law also expands work requirements for SNAP beneficiaries. Currently, adults up to age 54 without disabilities and dependents are required to work, volunteer or attend training for 80 hours a month to apply for and keep food assistance. Under the new law, adults ages 55 through 64 will also have to comply.

It’s still unclear when this will take effect.
The Food and Nutrition Service within the U.S. Department of Agriculture will likely issue guidance on how states should enforce these changes.

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Even then, it will take time for states to update their systems and figure out how to carry out the federal rules. Currently, SNAP applicants submit pay stubs or employment verification as proof of income; these documents can show hours worked. In various states, case managers might ask for verification of volunteer or educational training hours, and other eligibility documentation is typically submitted online, in person or by mail.

The frequency of eligibility checks for SNAP varies, depending on the household.

Eligibility changes spell more paperwork

Other provisions in the legislation complicate Medicaid enrollment, putting the onus on applicants to meet new standards or risk missing the window for coverage.

The process for how states will track and certify newly mandated work hours is not clear, as states are awaiting Medicaid implementation guidance from the Department of Health and Human Services. That is expected to come next summer.

“Some will find it easy to demonstrate their compliance with the new rules, many others will not, particularly family caregivers and people whose work is unstable or irregular,” according to recent analysis by AARP’s Public Policy Institute.

Beginning in late 2026, Medicaid Expansion enrollees will be subject to eligibility checks twice a year, instead of the current schedule of once annually.

But the short rollout timeline means states will have to move quickly to prevent delays in determining eligibility and exemptions. Some states may have to update computer systems to be able to track whether people are meeting the requirements.

“There’s a number of different ways that the implications of the provisions could vary across states,” said Robin Rudowitz, director of KFF’s program on Medicaid and the uninsured, in a briefing on July 9. States are waiting for guidance on many of those questions. “But beyond that, there’s likely to be variation across states in terms of their system capacity and how well they do data matching,” she said.

Medicaid coverage changes

Before the new law passed, retroactive coverage allowed people to get coverage for medical and long-term care expenses incurred three months before they applied for Medicaid. Under the new law, this timing would narrow — to one month prior to application for Medicaid Expansion enrollees and two months prior for traditional enrollees.

Certain individuals will also see new charges for some services that had been free. Medicaid beneficiaries with incomes 100 to 138 percent above the federal poverty level may be charged up to $35.

In early 2027, retroactive coverage changes take effect.
In October 2028, cost-sharing for Medicaid Expansion enrollees begins.

SNAP costs to shift onto states

Since the program’s inception in the 1930s, SNAP benefits have been entirely funded by the federal government. Administrative costs are split equally with states.

That is set to change dramatically in the next few years as the new law shifts costs from the federal government to state governments.

In fiscal year 2027, states’ shares of administrative costs for SNAP will increase from 50 percent to 75 percent.
In fiscal year 2028, states will begin paying for SNAP benefits depending on their “error rate,” or how much they over- or underpaid on benefits in previous years.

For the first round of payments, states can choose to use error-rate data from fiscal years 2025 or 2026 to determine their share. But from 2029 onward, states will use data from three years prior to calculate their annual cost-sharing amount.

There is another wrinkle to this timeline.

Certain states may be allowed to postpone payments until 2029 or 2030 under this new model if their error rates are especially high, to buy them a little more time.

Medicaid funding changes

Similar to changes in SNAP, federal cost-cutting will put more funding responsibility of Medicaid onto states, which may not be immediately prepared to cover the difference.

Broadly speaking, Medicaid is a jointly funded program, whereby the federal government matches payments for services. The amount varies among states.

States also have their own ways of paying for Medicaid, including through their general funds and by levying a tax on hospitals and other providers.

Fiscal year 2028 kicks off a series of annual reductions in how much Medicaid Expansion states can tax providers to help pay Medicaid costs.
By fiscal year 2032, that rate will fall to 3.5 percent — roughly half of what it is now.

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Molly Snow is a writer for AARP covering advocacy issues and state news. She also writes AARP's Today's Tips podcast. She previously worked at other news outlets, including Federal Times, McClatchy and Gannett.