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The Issues · Food security · The SNAP rewrite, part 4

Who we call homeless

Congress put many adults without a home back under SNAP's work rule in 2025. On paper, North Carolina's rules leave more room than "work requirement" suggests. Here is what the rule says, what it lets a person without an address do, what it leaves to a caseworker's judgment, and what the public data cannot yet tell us.

The change

Say "homeless" and one picture shows up. A man on a sidewalk, a cardboard sign, nowhere to be. That picture is real, and it is a small part of the whole. Many people without a permanent home are on a friend's couch, in a weekly motel, in a shelter bed, or in a car. A lot of them work.

In July 2025 Congress removed the SNAP exemption that had shielded homeless adults from the work rule. So homeless adults in the covered age range now have to meet it, qualify for another exemption, or lose their benefits. What most of the argument skips is the fine print North Carolina wrote. This page is not a report on how the rule is being applied in Buncombe County, because the public record does not yet support one. There is a second reason: North Carolina's reading of the federal exemption for people unfit to work is a recent state interpretation rather than settled ground.

The word

One word, hiding two very different situations

Homelessness takes many forms, and the word flattens them. In January 2025, about 745,000 people were counted as homeless in HUD's yearly one-night count. It counts those in a shelter or a place not meant for sleeping, like a car or a tent. It does not count two large groups without a home of their own: families doubled up with relatives, and people paying by the week at a motel. The real number is far higher. A second federal count reaches the people HUD's does not. It answers a different question, though. Public schools identified about 1.55 million students without stable housing across the whole 2023 to 2024 school year. About three in four were doubled up, exactly the group HUD's one-night count leaves out. One is a single night, all ages, narrowly defined; the other is a full year, students only, defined more broadly. Put side by side they do not tell you the size of the gap. What they do show is that a large population without a home of their own sits outside what the headline number was built to measure.

Much of homelessness is also brief. A job ends, a car breaks down, a lease is not renewed, and someone loses their home for weeks or months. That kind of homelessness looks nothing like the picture the word brings to mind.

The part people miss

More than half in shelters had earnings

A national study out of the University of Chicago linked the records of people counted as homeless to federal earnings data. In the year they were counted, 52.8 percent of the people in shelters had formal, tax-reported earnings. That is more than half. Among those counted unsheltered, 40.4 percent did. (The data is from 2010 and counts only income reported to the IRS, so it misses cash work. The percentages mean these people earned something that year, not every month.)

But the work is thin. Among sheltered people who worked, the average was about $14,200 in 2018 dollars. The work came in stretches: roughly 30 weeks of the year, at something near full-time hours in the weeks they worked. Those last figures come from survey answers people gave about themselves, over a later stretch of years, not from the tax records behind the 52.8 percent. The study's authors caution that self-reported work often does not match the earnings records. That makes the shape of the work the finding here, not the exact numbers. The work rule requires 80 hours a month, and it is applied one month at a time. So someone working steadily for part of the year clears it in those months and falls short in the empty ones. The work is real. It is not enough to pay for a home, and it does not line up with a monthly rule.

52.8%
People in shelters with formal earnings the same year they were counted homeless (2010 data).
U. of Chicago, NBER w28861
40.4%
Unsheltered people with formal earnings that year.
Same study
~$14,200
Mean yearly earnings of the sheltered homeless who worked (2018 dollars).
Same study
The other group

The smaller group with the hardest barriers

A smaller group is counted differently again. HUD's chronic homelessness means having a disability and living in an emergency shelter, a place not meant for people to live, or a safe haven, which is a small residence for people with severe mental illness. The person must have been homeless that way for at least 12 months, in one stretch or in four or more stretches in the last three years. The disability can be physical, mental, or emotional, including addiction, if it is long-lasting, makes it hard to live independently, and could be improved by more suitable housing. A developmental disability or HIV also counts. HUD counted about 150,000, most living outside. These are not separate populations from the people just described. Someone in this group may have earnings; someone with no earnings this year may not be in it. For many, though, steady work is not on the table, because the same things that keep them on the street keep them out of a job. SNAP has never applied its work rule to a person found unfit to work, and the 2025 law kept that exemption. But being chronically homeless is not an automatic pass. The person has to be screened, and a caseworker has to find them exempt. Whether that happens depends on what North Carolina tells its caseworkers, and how a caseworker reads it.

How the rule works

The rule, in brief

The rule in question is SNAP's three-month time limit for adults it labels able-bodied and without dependents, ages 18 through 64. SNAP has other work rules that reach a different set of people; this is the one the 2025 change altered for homeless adults. Behind the label "without dependents" is one exemption worth knowing, and one trap inside it. If you are in a SNAP household with a child under 14, the rule does not apply to you. You do not have to be the child's parent, you do not have to be responsible for them, and the child does not have to be eligible for benefits. But it has to be the same SNAP household. That usually means the people you buy and prepare food with rather than everyone under the same roof. Spouses and most children under 22 living with a parent are the exception: they count as one household whether they share food or not. The same goes for a child under 18 who lives with and depends on someone other than a parent, such as a grandparent. Foster children are not part of that rule. Someone sleeping on a friend's couch and buying their own groceries is a household of one, and the friend's children do not give them this exemption.

Set against the counts above, the under-14 exemption cuts less cleanly than it first looks. A parent doubled up with relatives and sharing food with them is likely exempt. The other adult on the same couch, buying their own groceries, is not. Neither is a doubled-up parent whose children are 14 or older. Either one can still be exempt for another reason. One is a separate exemption for someone responsible for the care of a child under 6, or of a person of any age who needs help caring for themselves. North Carolina's guidance says the person being cared for does not have to live with the caregiver or be in the same SNAP household. So the rule does reach into the doubled-up population, just unevenly. None of the public counts can tell us how many people land on each side of that line. One word covers all of them; the rule sorts them by arrangements no count records.

If the rule covers you and you are not exempt, you have to spend 80 hours a month in paid or unpaid work, in an approved work program, or volunteering. Any combination of these counts. Three months without the hours and your benefit ends. The three months do not have to be back to back. A month counts toward the three only if you got a full month of benefits.

A missed month does not count automatically, either. If something outside your control got in the way, that can be good cause, and the month is not supposed to count against you. Good cause is for someone who would have met the hours but missed some. The absence also has to be temporary. North Carolina's manual describes good cause as circumstances beyond your control. The manual gives examples rather than a closed list: your own illness, an illness in the household that affects your ability to work, a household emergency, or no transportation. NCDHHS also names child care falling through. Tell the caseworker as soon as it happens rather than after the fact, and be ready to explain what happened. Someone who misses hours is supposed to get the benefit of the doubt.

North Carolina counts the months that do stick inside a fixed three-year window. The current one runs from January 1, 2025 through December 31, 2027. Someone who used three months in 2025 is locked out until the next window opens on January 1, 2028, unless they meet the hours or qualify for an exemption first. Getting back on takes 80 hours in any 30-day period, from paid or unpaid work, an approved work program, or a combination of the two. The 30 days do not have to line up with a calendar month. Taking part in a workfare program and doing what it requires over a 30-day period would also count, but no North Carolina county runs one. Becoming exempt does it too, and so does the three-year window running out. And once someone is back on, they can get three more months in a row even if they stop meeting the hours again. Those are sometimes called bonus months, and they are available once per three-year window. They start on the date you tell the agency you are no longer meeting the hours. If you had been in a work or workfare program, they start instead when the agency tells you.

The rules

What the rules actually let you do

Some of this is federal law every state follows. Some is North Carolina's own call.

Two things are firm, and no caseworker can waive them. You cannot be required to have a permanent home or a fixed mailing address to get food help. And when you claim an exemption, your own word must be accepted unless there is a specific, case-by-case reason to question it. A county cannot decide in advance that everyone in your situation has to prove it; federal rule forbids exactly that. Your word alone is not always enough. Receiving disability benefits has to be verified another way. So does being unfit to work, when that is not obvious to the caseworker. The two firm rules are the floor for every state. Being believed is not the same as being found exempt, though. The worker still decides whether what you describe meets the standard.

The "obviously unfit" finding, and the option to take a short statement from someone other than a doctor, are in the federal rules every state works from. What North Carolina added is the part that matters most here. The state told its caseworkers that chronic homelessness itself can be the thing that makes a person obviously unfit, when their housing situation is what keeps them from working 20 hours a week. That is the worker's judgment. The manual does not use the term chronic homelessness the way HUD does. HUD's chronic homelessness requires a disability and at least 12 months of homelessness. North Carolina's manual means something else: lacking a fixed and regular place to sleep at night. Its examples include shelters, outdoor and makeshift spots, vehicles, RVs without working utilities or sewer or septic hookups, and other places not built or ordinarily used for sleeping. It also counts places without access to a toilet, or where a person cannot keep clean or sleep in a stable way. So the exemption reaches the street, the shelter, and the car most clearly. A couch in someone else's home or a paid motel room is a harder case under that wording. Those are exactly the situations of the two large groups the opening described.

When someone is obviously unfit for work, no doctor's note is required. When the barrier is not obvious, a short statement is enough, but it has to come from someone on the state's list. That list is wider than a doctor's office. Federal rules accept a physician, a physician's assistant, a nurse, a nurse practitioner, a licensed or certified psychologist, a social worker, or a staff member a doctor's office authorizes to give the statement. North Carolina added physical and occupational therapists, speech-language pathologists, licensed counselors and therapists, and a Certified Addiction and Drug Counselor. The state also added the two a person without a home is most likely to already know: a Certified Substance Abuse Counselor and a Certified Community Health Worker. Being on the list is what matters. A shelter staffer or outreach worker who is not on it cannot write the statement, so ask about that first. The statement itself is easy. It can be given by phone, and it needs no letterhead and no particular wording. It only has to identify who is writing it and say the person cannot work 20 hours a week, or describe the condition that stops them. And no month can be counted against anyone until the county has screened them for every exemption.

Volunteering toward the 80 hours can be done at a nonprofit, a church or other religious group, a community organization, or a government agency. Community service ordered by a court counts too. For self-employment or contract work, the county is told to accept the person's own statement of hours instead of a pay stub, because that kind of work does not produce one. That applies to the hours. Income and the rest of eligibility are still checked the usual way, so this is not a matter of saying a number and being done. Read together, the rules describe more than one path for a person without an address. But a category in a manual is not the same as a volunteer placement that will take you and vouch for your hours. The state's own manual notes that its work program is optional for counties.

The judgment

Who makes the judgment call

Parts of the rules are firm, and parts turn on a caseworker's judgment. The no-address rule and the required screening are requirements a county must follow. So is taking you at your word when you claim an exemption, except where proof is required. The part left to judgment is smaller, but the hardest cases turn on it. Is the homelessness enough to make someone "obviously unfit"? Does a housing situation really prevent 20 hours of work? Those are calls a worker makes. The same discretion can protect one person and exclude another, depending on who is deciding and how much time they have.

Some of the counties making these calls are stretched thin. North Carolina's own auditor looked at 2021 through 2024. From 2022 through 2024, about 9 percent of applications and recertifications missed the federal deadline. In a handful of the worst counties, a larger share was late. That report is about how fast paperwork moves. It does not cover who gets an exemption, and it does not show anyone being wrongly denied. It is a reason to pay attention.

The gap

What the public data can't show

So does the fine print hold up once a real case reaches a caseworker? We cannot yet say, and neither can anyone working only from what is public. When a SNAP case closes in North Carolina, the county records a reason code. It shows, roughly, whether the household earned too much or missed a required step like an interview or a form. A statewide count of how often cases are closed because of a missed step would at least show how large a role paperwork plays. But no public source we searched breaks it out. Even that count would not say which closures involved a homeless person or a mishandled exemption. The next step for this reporting is to request the deidentified data from the agencies that hold it.

Economists who studied an earlier round of SNAP work requirements found the requirements pushed people off the program without moving them into work. The economists also found that homeless adults were among those most likely to be screened out. Another study, in a single state, found that dropping a work requirement reduced the denials that come from procedure rather than from income. Neither study is about North Carolina, and neither tested the more forgiving rules the state just wrote. So they do not predict what happens here. What they show is the risk worth watching: a work requirement can screen out homeless adults, and a share of the people it screens out are turned away over paperwork rather than over money.

If this is you

You do not have to do this alone

If you are trying to keep your SNAP, get free help before you take no for an answer. Pisgah Legal Services helps with SNAP denials, terminations, and appeals at no cost. The Food Helpline at MANNA FoodBank helps you apply for SNAP and keep it. Your county Department of Social Services runs your case.

If you are cut off, two dates on the letter matter. You have 90 calendar days to ask for a hearing. There is also a shorter window, the 10 working days of advance notice. Asking inside it can keep your benefits coming at the old amount while you wait. That second option does not apply to every case. It is also not free: if you lose, you have to pay back what you received in the meantime. So keep the letter, note both dates, and call Pisgah Legal before you decide which one you are working toward. This is a page about what the rule says, not a substitute for someone who can look at your notice.

Where this sits in the series

One part of a larger rewrite

For the wider toll across the state, see who loses SNAP now. For who absorbs the added cost of all this verification, see who pays for SNAP now. For what the work does and does not pay for, see that wouldn't be me. For what an Asheville day center does for someone with no mailbox, see what the belt measures.

The takeaway

The rules on paper are real. Whether they hold up in practice, the public record doesn't show.

North Carolina told its counties several things. A homeless person's own word can start an exemption claim. Homelessness can support a finding that someone is unfit to work. The manual's test for homelessness here is having no fixed and regular place to sleep at night. The finding only follows when the housing situation is what keeps the person from working 20 hours a week, and a caseworker still has to make the call. When the barrier is obvious, no doctor's note is needed; when it is not, a short statement is required from someone on the state's list. Volunteering counts, though the organization has to verify the hours. But the hardest cases come down to a caseworker's judgment, one case at a time.

On paper, the rules leave room for people without a home. Two things should keep that from sounding like a promise. The first is that the room comes from a reading, not from a settled rule. Congress deliberately removed the homelessness exemption in July 2025. What North Carolina is using instead is a different federal exemption, the one for people unfit to work, plus its own instruction that homelessness itself can support that finding. The state can narrow that reading, and Washington can challenge it. The second is that we have not reported whether the paths exist on the ground here. County caseworkers, legal aid attorneys, and people who have been through it may already know things the public record does not show.

Sources & notes

The rules. The work rule and its exemptions come from federal law (the ABAWD provisions) and North Carolina's Food and Nutrition Services Manual, Section 260, Change #02-2025, effective December 1, 2025. Benefit rules change; this page describes the rules as they stood on July 19, 2026, and existing participants are generally screened at their next recertification. If you are reading this much later, check with your county or Pisgah Legal before relying on it. The One Big Beautiful Bill Act, signed July 4, 2025, removed the exemptions for homeless adults, veterans, and former foster youth. The residency floor (no fixed address may be required), the acceptance of a person's own word to claim an exemption, the "obviously unfit" standard, the acceptance of a short medical statement that need not come from a doctor, and the screening-before-any-month-counts rule are all in the manual and the federal regulations it restates. The "obviously unfit" standard and the medical statement come from the federal rules (7 CFR 273.24) rather than from a North Carolina choice; what the state added is the instruction that chronic homelessness itself can support that finding. Also from the manual (FNS 260, Change #02-2025) and NCDHHS guidance: the time limit reaches adults ages 18 through 64, since the exemption now starts at 65 rather than 55; residing in an FNS (SNAP) household with a child under 14 is an exemption, where the threshold used to be 18, and the manual is explicit that the individual need not be the parent, need not be responsible for the child, and the child may be an ineligible member (FNS 260.01.C), which reads the responsibility as belonging to the household rather than to each member (the statute's words are "a parent or other member of a household with responsibility for a dependent child under 14 years of age," 7 U.S.C. 2015(o)(3)(C); USDA's implementation memo speaks of "a parent or other household member with responsibility for a dependent child"; the eCFR text of 7 CFR 273.24(c)(4), as fetched in October 2026, still frames the older under-18 version as "residing in a household where a household member is under age 18"); the statement of unfitness, when the barrier is not obvious, must come from a source on the federal list at FNS 260.01.F.3.a or on the nine North Carolina added at 260.01.F.3.b (physical therapist, occupational therapist, speech language pathologist, LPC, LMFT, LCMHC, CADC, CSAC and Certified Community Health Worker), and the statement may be taken verbally and telephonically attested but must be documented in NC FAST; good cause applies when someone who would have met the requirement misses some hours and the absence is temporary (260.04.D.1), and it includes circumstances beyond the individual's control, with illness, illness of another household member affecting the ability to work, a household emergency, and unavailability of transportation given as examples and not as a closed list; a countable month requires a full benefit month while not meeting the requirement, without good cause and without another exemption; and NC FAST tracks three bonus months on top of the three countable ones, which under FNS 260 sec. 260.05.B go only to someone who regained eligibility and then stopped meeting the requirement, and must be consecutive. Note the manual's definition of chronic homelessness is not HUD's: it means lacking a fixed and regular nighttime residence (its examples, introduced with "including locations such as," are a homeless or domestic violence shelter, outdoor or makeshift locations, vehicles, RV-type structures without active utilities or sewer or septic hookups, and other places not designed for, or ordinarily used as, regular sleeping accommodations, and it "includes environments without access to toilets or where basic hygiene or stable sleep cannot be maintained," FNS 260.01.F.2.c), with no long-duration or disability test, and the unfitness finding follows only when that situation prevents twenty hours of work a week, at the eligibility worker's discretion. Appeals: NC FNS Manual Section 705 (Hearings, Change #2-2021), the version we hold. NCDHHS's list of FNS manuals, as fetched in October 2026, now shows hearings as FNS 700 and uses 705 for Administrative Disqualification Hearings. A fair hearing must be requested within 90 calendar days of the action (705.09); benefits continue at the prior amount if the request comes within the ten-day advance notice period on the Notice of Adverse Action (ten working days, not counting weekends and holidays, under FNS 170.04, Change #21-2021), unless the certification period has ended or the household waives continuation (705.11); and a request is "any clear expression, oral or written," which a representative or other person may make on the household's behalf (705.08). Continuation does not apply when the hearing request results from recertification, or once the certification period ends (705.11 E and F). Under 7 CFR 273.15(k)(1), if the agency's action is upheld, "a claim against the household shall be established for all overissuances," so benefits continued during an appeal are repayable if the appeal is lost. Hearings policy cited here is the Change #2-2021 revision of what was then Section 705; it has not been checked against the current FNS 700 text, so confirm before relying on it. Household rules (who counts as one household whether or not they buy and cook together: spouses; a person under 22 living with a parent; and a child under 18, other than a foster child, who lives with and is under the parental control of a household member other than a parent): 7 CFR 273.1(b)(1). County timeliness: N.C. Office of the State Auditor, performance audit PER-2024-4435 (October 2025), covering January 1, 2021 through December 31, 2024; 91 percent of SNAP benefit payments, counting initial applications, expedited applications and recertifications, were timely from January 1, 2022 through December 31, 2024, and several counties issued as many as 20 to 25 percent late.

The population and the work. HUD Point-in-Time count: about 745,000 people on a single night in January 2025, a universe that excludes people doubled up or in self-paid motels. A broader federal count reaches part of that excluded group, though it answers a different question and cannot be differenced against the HUD figure: U.S. Department of Education / National Center for Homeless Education (EHCY), 1,548,191 public-school students identified in the 2023-2024 school year, a 12.6 percent rise in a single year and 28.4 percent above the 2021-2022 count. The source expresses that one-year change as an increase over two reporting years, which counts data points rather than elapsed years; elsewhere it gives the annual increase from 2022-2023 to 2023-2024 as 12.63 percent. About three in four of them, 1,150,630, were doubled up. It is a full-year count under a wider definition, not comparable one-to-one with HUD's one-night tally. Chronic homelessness: about 150,000 individuals, most unsheltered; HUD's count does not include people in families with children. HUD's definition (24 CFR 578.3) requires a "homeless individual with a disability" who lives in a place not meant for human habitation, a safe haven, or an emergency shelter, and has lived that way continuously for at least 12 months or on at least four separate occasions in the last three years that add up to at least 12 months, with each break between the occasions including at least seven consecutive nights of not living that way; it also reaches someone in an institution for fewer than 90 days who met that test before entering, and a family whose head of household meets it. The disability test comes from the McKinney-Vento Act (42 U.S.C. 11360(9)). HUD's 2025 Annual Homeless Assessment Report, which gives the count, defines that disability as one of three things: a physical, mental, or emotional impairment, including one caused by alcohol or drug abuse, post-traumatic stress disorder, or brain injury, that is expected to be long-continuing or of indefinite duration, substantially impedes independent living, and could be improved by more suitable housing; a developmental disability; or AIDS or any condition arising from its infectious agent. HUD's rule of December 5, 2011, which wrote the same test into the Shelter Plus Care and Supportive Housing rules, adds that this includes infection with HIV. Employment: Meyer et al., "Learning about Homelessness Using Linked Survey and Administrative Data," NBER Working Paper 28861 (University of Chicago, 2021). Two different measures inside one paper, and they should not be read as a single finding. From 2010 records linking the homeless count to IRS earnings data: 52.8 percent of the sheltered and 40.4 percent of the unsheltered had formal, tax-reported earnings at some point that year. Separately, from American Community Survey responses over 2011 to 2018, in which people describe their own work: mean earnings among sheltered workers of about $14,200 in 2018 dollars, across roughly 30 weeks. The authors caution that self-reports like these are frequently unreliable, and that the administrative records often conflict with them.

The wider research (context, not North Carolina). Gray et al., "Employed in a SNAP?" (AEJ: Economic Policy, 2023): work requirements raised program exits and cut participation with no measurable rise in employment, and homeless adults were disproportionately screened out. Cook, Cox & East (AEA Papers and Proceedings, 2026): eliminating work requirements reduced procedural denials. Neither study is North Carolina or about the 2025 change.

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