Who we call homeless

Homelessness takes many forms, and the word flattens them. HUD's yearly one-night count found about 745,000 people in January 2025. 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, though it answers a different question and cannot be subtracted from the first. Public schools identified about 1.55 million students without stable housing across the whole 2023 to 2024 school year, and 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 see. 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.

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, and it means 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, and 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 does not always match the earnings records, so treat the shape of the work as the finding here, not the exact numbers. The rule's 80-hour test 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.

A smaller group is counted differently again. HUD's chronic homelessness means a long or repeated stretch without a home together with a disabling condition, which may be a physical disability, a serious illness, a mental illness, or a substance use disorder. HUD counted about 150,000, most living outside. These are not separate populations from the people just described, and the line between them is not a line at all. 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.

The rule this piece is about 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. That label hides 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, though spouses and most children under 22 living with a parent count as one household whether they share food or not. Someone sleeping on a friend's couch and buying their own groceries is a household of one, and the friend's children do not exempt them. For everyone else covered, you have to spend 80 hours a month working, in an approved work program, or volunteering. Three months without the hours and your benefit ends.

That exemption is worth holding against the counts above, though it 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. So the rule does reach into the doubled-up population, just unevenly, and 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.

They do not have to be back to back. 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. The manual calls it circumstances beyond your control, and 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. North Carolina counts the months that do stick inside a fixed three-year window, and 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 during any 30-day period. That period does not have to line up with a calendar month. 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.

The 2025 change sends a person without a home straight to that same fine print: they now have to meet the hours or qualify under one of the exemptions that remain.

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. The one carve-out is disability benefits, which need verification beyond your word. Being believed is not the same as being found exempt, though. The worker still decides whether what you describe meets the standard. Those are the floor for every state.

Some of what follows is federal, not North Carolina's doing. 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: it 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 twenty hours a week. That is the worker's judgment. Read the term carefully, because the manual does not use it the way HUD does. HUD's chronic homelessness means a long or repeated stretch without a home plus a disabling condition. North Carolina's manual means something else: lacking a fixed and regular place to sleep at night, and it lists shelters, outdoor and makeshift spots, vehicles, RVs without utilities, and other places not built or ordinarily used for sleeping. 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, and those are exactly the situations the opening counts are full of. When someone is obviously unfit for work, no doctor's note is required. When they are not, 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. Besides physicians, nurses, and social workers, North Carolina added physical and occupational therapists, licensed counselors and therapists, and the two a person without a home is most likely to already know: a Certified Substance Abuse Counselor and a Certified Community Health Worker. The credential is what matters. A shelter staffer or outreach worker without one cannot write it, so ask before you go get it. The statement itself is easy: it can be given by phone, needs no letterhead and no particular wording, and only has to identify who is writing it and say the person cannot work twenty hours a week, or describe the condition that stops them. Someone who misses hours is supposed to get the benefit of the doubt. And no month can be counted against anyone until the county has screened them for every exemption.

The 80 hours can be met more than one way: paid or unpaid work, an approved work program, or volunteering at a nonprofit, church, or government agency. 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. Whether those paths exist in practice is a separate question this piece cannot answer: a category in a manual is not the same as a volunteer placement that will take you and vouch for your hours, and the state's own manual notes that its work program is optional for counties.

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

It is worth knowing that some of the counties making these calls are stretched thin. North Carolina's own auditor looked at 2022 through 2024. About 9 percent of applications and recertifications were not processed inside the federal time limits, and a handful of the worst counties were slower still. That report is about how fast paperwork moves, not who gets an exemption, and it does not show anyone being wrongly denied. It is a reason to pay attention, not proof the doors are being held shut.

So does the fine print hold up once a real case reaches a caseworker? Honestly, 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, and even that would not say which closures involved a homeless person or a mishandled exemption. The honest next step is to request the deidentified data from the agencies that hold it. That is where this reporting goes next.

What the wider research shows is that this friction is real, and it can hit exactly these people hardest. Economists who studied an earlier round of SNAP work requirements found they pushed people off the program without moving them into work, and that homeless adults were among those most likely to be screened out. Another study, in one state that was not North Carolina, found that dropping a work requirement reduced the denials that come from procedure rather than from income. Neither study is 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 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 that letter matter. You have 90 calendar days to ask for a hearing. There is also a shorter window, the ten days of advance notice, and asking inside it can keep your benefits coming at the old amount while you wait. That second option is not free: if you lose, you have to pay back what you received in the meantime, and it does not apply to every case. 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.

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