In July 2025, the U.S. Congress passed H.R. 1, titled the “One Big Beautiful Bill Act,” which included significant cuts to Medicaid financing as well as changes to Medicaid and Supplemental Nutrition Assistance (SNAP) eligibility for certain immigrant populations. H.R. 1 also added work-reporting requirements for states that have adopted Medicaid expansion, requiring that individuals aged 19–64 enrolled in Medicaid — with certain exemptions — work 80 hours per month to remain eligible for Medicaid. Additionally, H.R. 1 imposed new SNAP time limits onto vulnerable people who are not working at least 20 hours a week, such as older participants, as well as parents or other members of a household with responsibility for a dependent child under 14 years of age. It also shifted extensive costs from the federal government to states participating in SNAP by increasing each state’s share of administrative expenses and forcing states with SNAP error rates of 6 percent or higher to pay a percentage of the grocery benefits provided to eligible families.1
Florida has proposed SB 1758/HB 1453 to align with some of the provisions of H.R. 1; however, this bill goes beyond what is required in H.R. 1 by imposing new, onerous standards on Medicaid and SNAP that would cause undue harm to Florida’s families. These provisions would exacerbate food insecurity, disproportionately increase red tape for individuals who receive these services, and stray from the federal law in imposing work requirements on non-expansion adults.
The new federal law prohibits states from submitting waivers that institute work-reporting requirements for non-expansion adults who receive Medicaid.2 SB 1758/HB 1453 specifies that any implementation of these requirements would need to be approved by a state waiver, which would ultimately not be approved at the federal level because it is illegal to create a new Medicaid work requirement for individuals who would already be exempt otherwise. The bill should be amended to eliminate these requirements entirely.
Florida does not have a Medicaid Expansion population; therefore, it is not beholden to the work-reporting requirements for adults passed under H.R. 1. SB 1758/HB 1453 would impose stringent work-reporting requirements for parents on Medicaid, while limiting the hours available to work towards these requirements. These bills propose that able-bodied parents of children aged 14–18 (SB 1758) or aged 6–18 (HB 1453) report working or attending educational programs for 80 hours per month. They also would require that these hours only be met during the standard school day. Most able-bodied adults who receive Medicaid already work.3 Data collected in states that impose these requirements shows that adding these barriers causes bureaucratic hurdles and undue coverage loss, while also creating a financial burden on the state.4, 5
If somehow enacted, this bill would force Florida’s working parents into a coverage gap, since the state has not expanded Medicaid — and Florida’s eligibility limit is currently 26 percent of the Federal Poverty Level for parents.6This means that in order for a family of three to qualify, parents would need to make about $8,000 annually. With Florida’s minimum wage moving to $15 per hour in September, working 80 hours per month would increase the family's income to $14,000 annually, effectively disqualifying them from Medicaid coverage. In turn, this would leave them too poor to access Marketplace Insurance, which they would need $27,320 to qualify for.
Florida imposes federal SNAP work requirements in two different ways on two different sets of SNAP participants: through its mandatory SNAP Employment and Training program (SNAP E&T), and through time limits imposed on people called “Able-Bodied Adults Without Dependents (ABAWDs).” H.R. 1 changed the federal law that governs ABAWDs to expand time limit work requirements to, among others, people up to age 65 and parents or other members of a household with responsibility for a dependent child 14 years of age or older. However, H.R. 1 did not change the federal law that governs mandatory SNAP E&T work requirements.7 Still, SB 1758 improperly attempts to impose mandatory SNAP E&T work requirements not only onto people up to age 65 — which violates federal law — but also onto people with children 14 and older in their household. This is contrary to how Florida has previously chosen to run its SNAP E&T program.8
SB 1758 also aims to reduce DCF’s error rate (i.e., non-fraud mistakes)9 in the SNAP program by mandating that DCF develop and implement a food assistance payment accuracy improvement plan to reduce Florida’s SNAP error rates to below 6 percent. Many of the required components for the plan in the bill reflect a common-sense approach to lowering those rates (e.g., improved training and data sourcing). However, technological upgrades — which will require funding from lawmakers to address — will also be critical to reducing errors.
In addition, SB 1758 would tighten verification of shelter and utility costs — which DCF says10 are a source of errors made in SNAP — by prohibiting self-attestation and, instead, requiring documentation.11 Although SB 1758 would require DCF to adopt policies that accommodate participants who are unable to provide documentation of shelter or utilities because they have only recently moved to their new residence, the bill neglects to address the other barriers that some participants may have that make it difficult for them to provide this documentation. Both federal and state law require that state agencies assist households in obtaining required verification when they need help, so long as the household is cooperating with the state agency.12 The bill should be amended to also reflect that duty.
Finally, SB 1758 would also require that a family’s EBT card includes a photo of the cardholder, even though that mandate is not contained in H.R. 1. Proponents of photo IDs claim that this would allow check-out clerks at grocery stores to combat SNAP theft. However, not only has this option been shown to increase stigma and hinder the ability of people with disabilities and family members to use their benefits,13 studies also suggest that it is neither cost-efficient nor necessary.14
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1 Cindy Huddleston, “How Historic Cuts to SNAP Enacted by Congress Jeopardize the Food Security of Floridians in Need and the State’s Entire Program, "Florida Policy Institute, August 12, 2025,
2 42 U.S Code 1396(a) Sec. 7119(a)(10) https://www.law.cornell.edu/uscode/text/42/1396a.
3 Anne Swerlick, "Medicaid Work Requirements Don’t Work For Florida,” February 2020, https://www.floridapolicy.org/posts/medicaid-work-requirements-dont-work-for-florida.
4 Commonwealth Fund, “Few Georgians are Enrolled in the State’s Medicaid Work-Requirement Program,” September 2024, https://www.commonwealthfund.org/blog/2024/few-georgians-are-enrolled-states-medicaid-work-requirement-program.
5 Georgia Budget and Policy Institute “Pathways to Coverage: Looking Back Two Years and Into the Future” October 2025,https://gbpi.org/wp-content/uploads/2025/10/PathwaystoCoverage_TwoYearsinReviewBrief_202510.pdf.
6 KFF, "Medicaid Income Eligibility Levels for Parents, 2002-2025" https://www.kff.org/medicaid/state-indicator/medicaid-income-eligibility-limits-for-parents/?currentTimeframe=0&sortModel=%7B%22colId%22:%22Location%22,%22sort%22:%22asc%22%7D.
7 Under SNAP E&T requirements, mandatory participants and their families face losing their SNAP as a sanction if the participant does not work or take part in a qualifying E&T program for at least 120 hours a month. Under SNAP time limit requirements, people up to age 65 can only get SNAP for three months in a three-year period if they are not working an average of 20 hours per week. Department of Children and Families, “Able-Bodied Adults Without Dependents and Mandatory Work Participants FAQ: What does it mean to be an ABAWD or mandatory work participants for food assistance?” https://www.myflfamilies.com/services/public-assistance/abawd.
8 Florida Department of Children and Families,” Able-Bodied Adults Without Dependents and Mandatory Work Participants FAQ: How do I know if I am an ABAWD or mandatory work participant who is subject to work requirements?,” 2026, https://www.myflfamilies.com/services/public-assistance/abawd.
9 U.S. Department of Agriculture, “Ensuring Eligible SNAP Households Get the Right Benefits: Are the error rates the same thing as fraud?,” https://www.fns.usda.gov/snap/qc.
10 Florida House of Representatives, “Human Services Subcommittee: Meeting Packet: ONE BIG BEAUTIFUL BILL ACT:
CHANGES TO THE SUPPLEMENTAL NUTRITION ASSISTANCE PROGRAM,” October 8, 2025, https://www.flhouse.gov/Sections/Documents/loaddoc.aspx?MeetingId=14829&PublicationType=Committees&DocumentType=Meeting%20Packets.
11 DCF must also verify things such as earned and unearned income, identity, and immigration status.
12 7 C.F.R. § 273.2 (f)(5), https://www.ecfr.gov/current/title-7/subtitle-B/chapter-II/subchapter-C/part-273/subpart-A/section-273.2#p-273.2%28c%29%285%29. See also Fla. Admin. Code R. 65A-1.204 (1), https://flrules.org/gateway/readFile.asp?sid=0&tid=0&cno=65A-1&caid=1678311&type=4&file=65A-1.doc; Center on Budget and Policy Priorities, “How to Streamline Verification of Eligibility for Medicaid and SNAP,” July 18, 2024, https://www.cbpp.org/research/health/how-to-streamline-verification-of-eligibility-for-medicaid-and-snap#_ftn21.
13 Office of Greg Casar, “NEWS: Congressman Greg Casar Introduces the No Photo for Food Act,” September 26, 2023, https://casar.house.gov/media/press-releases/news-congressman-greg-casar-introduces-no-photo-food-act;
Stacy Dean, “SNAP: Combating Fraud and Improving Program Integrity Without Weakening Success,” Center on Budget and Policy Priorities, June 9, 2016, https://www.cbpp.org/research/food-assistance/snap-combating-fraud-and-improving-program-integrity-without-weakening.
14 Gregory Mills and Christopher Lowenstein, “Assessing the Merits of Photo EBT Cards in SNAP,” Urban Institute March 2015, https://www.urban.org/sites/default/files/publication/44641/2000159-Assessing-the-Merits-of-Photo-EBT-Cards-in-the-Supplemental-Nutritional-Assistance-Program.pdf.
American Rescue Plan Act Changes. The American Rescue Plan Act of 2021 extended PEUC and PUA benefits through the week ending September 6, 2021. It also increased the maximum duration of PEUC benefits ($300 a week) to 53 weeks and the maximum duration of PUA to 79 weeks. Although PEUC and PUA did not end until September 6, 2021, Florida withdrew from the Federal Pandemic Unemployment Compensation Program (FPUC) effective June 26, 2021. FPUC provided persons who were out of work due to COVID-19 with an additional $300 a week in unemployment insurance.
Reemployment Assistance weeks reverted to 12 effective January 1, 2022. DEO determines the maximum number of weeks available to RA claimants based on a statutory formula that looks at the average unemployment rate for the most recent third calendar year quarter (i.e., July, August, and September). Based on the downturn in unemployment, the maximum number of weeks for RA reverted to 12 effective January 1, 2022.
RA work-search and work registration requirements reinstated on May 30, 2021. Persons filing an application for RA benefits beginning March 15, 2020, are not required to complete work registration in Employ Florida through May 29, 2021. In addition, work search requirements for individuals requesting benefits for the weeks beginning March 15, 2020, were also reinstated on May 30, 2021.
RA biweekly reporting requirements reinstated. Although previously waived, biweekly reporting was reinstated effective May 10, 2020. DEO’s guide to claiming weeks is here.
Mobile app deployed. DEO has deployed a mobile app for RA applications.
DEO announces extended benefits. DEO announced implementation of Extended Benefits (EB).
Resources and guidance. For a list of resources and guidance from the United States Department of Labor on unemployment insurance and COVID-19, go here.
For DEO’s “Reemployment Assistance Frequently Asked Questions and Additional Resources,” updated 12/30/2020, go here.
For DEO’s latest claims data, go here.
DCF opens offices. DCF has reopened its brick-and-mortar storefronts, which were previously closed due to coronavirus.
DCF adds call center numbers. DCF has added a call center number for Monday through Friday, from 7 a.m. to 6 p.m. Call center numbers now include 850-300-4323, 866-762-2237, or TTY 1-800-955-8771.
Certification periods extended by 6 months only through August 2020. Certification periods for cash, food and medical assistance were extended by 6 months for individuals and families scheduled to recertify in April through August 2020. FNS’ approval of the SNAP extension for August is here. However, effective September 1, 2020, SNAP, TANF and Medicaid recertifications have been reinstated, although DCF says that no one will lose Medicaid due to recertification.
DCF allows phone interviews. Phone interviews are now being used for TANF cash and SNAP food assistance.
Mandatory work requirements suspended only through May 2021. Under a directive from Governor DeSantis to waive work requirements for safety net programs, DCF waived work requirements for individuals participating in the Supplemental Nutrition Assistance Program (SNAP) and Temporary Assistance for Needy Families (TANF) through May 2021. To do this, DCF explains that it partnered with the Department of Economic Opportunity to apply “good cause” statewide for TANF and SNAP recipients who would otherwise be subject to participation in mandatory work requirements as a condition of receiving those benefits. Through May 2021, persons who were sanctioned in the past due to work requirements will be able to reapply and participate in SNAP or TANF again.
Work requirements were reinstated effective June 1, 2021.
Emergency allotments (EA) ended. DCF automatically supplemented SNAP allotments of current recipients up to the maximum for a household’s size for July 2021. However, EA was discontinued beginning August 1, 2021.
The SNAP benefits increase by 15 percent ended in October 2021. Floridians who participate in SNAP to put food on the table will receive a temporary 15 percent supplement to SNAP under COVID relief passed by Congress and extended by the American Rescue Plan Act through September 2021.
FNS permanently increases SNAP through revamp of the Thrifty Food Plan. Effective October 2021, FNS has mandated a permanent increase to SNAP through a revamp of the Thrifty Food Plan. DCF says that the increase amounts to about 6% for Floridians.
Time limits suspended. SNAP time limits are suspended during the COVID-19 public health emergency. No one in Florida should be barred from SNAP due to time limits, even if they exhausted their time limit in the past.
Florida granted waiver to allow families to purchase groceries online. DCF has been granted a federal waiver to permit the State of Florida to launch a pilot project statewide effective April 21, 2020, that allows families to purchase groceries online with their Electronic Benefit Transfer (EBT) card instead of going into stores.
No Medicaid terminations from March 2020 through the end of the federal public health emergency. The national public health emergency has existed since January 27, 2020 and has been renewed by the Secretary of the U.S. Department of Health & Human Services in 90-day increments since that time. The most recent renewal is effective January 16, 2022.
On March 31, 2020, AHCA alerted providers and DCF posted on the ACCESS website that:
Redetermination/recertification times are reinstated. As of October 1, 2020 AHCA's website is alerting recipients that the Department of Children and Families is now mailing letters for case reviews to check if a household is still eligible for Medicaid and/or Medically Needy. AHCA is urging people receiving these letters to take steps now to re-apply. But note, Medicaid coverage will not end during the COVID-19 Public Health Emergency. In January 2021 DCF conducted one-year “automated renewals” for people whose sole income is social security and SSI and are enrolled in an SSI-related Medicaid program (e.g., MEDS/AD, Medically Needy and Medicare Savings Programs). People getting VA income were not included in the automated renewal.
Extended application time. Effective with applications filed in February 2020, the time for submitting documentation required to process an application is extended for 120 days from the date of the application and eligibility will still be effective the first day of the month the application was received. Effective July 1, 2021, this policy has been rescinded. Medicaid applications submitted on or after July 1, 2021 may be denied on the 30th day after application or the day after verification information is due. Applications filed prior to July 1, will be allowed 120 days to provide requested verification to establish Medicaid eligibility.
Exclusion of additional unemployment payments in determining eligibility. The $600/week of additional unemployment insurance payments under the CARES Act will not be counted as income in determining Medicaid eligibility. (However, these payments will be counted as income in determining marketplace subsidy calculations.)
Coverage of Medicaid services during the state of emergency
COVID-19 Vaccines for Medicaid Enrollees. In an executive order published March 16, 2021 Governor DeSantis revised the vaccine distribution plan, which applies to the general public including Medicaid enrollees, to lower the age requirement to 40 effective March 29, 2021 and then effective April 5, 2021 all Floridians are eligible to receive any COVID-19 vaccination approved by the Food and Drug Administration.
Medicaid enrollees eligible to receive the vaccine may visit myvaccine.fl.gov to find a location distributing the vaccine and to schedule an appointment.
On March 12, 2021, AHCA published instructions for Medicaid enrollees on how to obtain Medicaid transportation once they have scheduled an appointment for a vaccine. AHCA states: "Florida Medicaid will take you to get the COVID-19 vaccine at no cost. All you need to do is set up a time to get your vaccine. Next, let your Medicaid plan know you need a ride and they will take care of the rest. If you are not enrolled in a plan, call the Medicaid Helpline at 1-877-254-1055 to find out the name and phone number for a transportation service."
The state has also recently launched a new email system to help bring COVID-19 vaccines to homebound seniors. Seniors will be able to sign up to have the vaccine come to them by emailing a request to HomeboundVaccine@em.myflorida.com.
AHCA has posted Medicaid Alerts and FAQs providing more detail on Medicaid service changes in response to COVID-19. They address a wide range of topics including, but not limited to: telemedicine guidance for medical, behavioral health, and early intervention services providers; long-term care provider network flexibilities allowing more types of providers to deliver specified long term care services; and continuity of care for adult day care center enrollees during the time these centers are closed.
AHCA is loosening coverage restrictions for behavioral health services. Effective May 5, 2020, all prior authorization requirements for mental health or substance use disorder treatment are waived and service limitations (frequency and duration) are lifted. For behavioral analysis services, current authorizations will be extended through an "administrative approval process" which does not require providers to reassess beneficiaries currently getting services. Effective July 1, 2021 service limits will be reinstated for behavioral health services and effective July 15, 2021 Medicaid prior authorization requirements will be reinstated for behavioral health services.
Per a May 29, 2020 provider alert, during the state of emergency AHCA will be reimbursing providers for telemedicine well-child visits provided to children older than 24 months through age 20. Providers are directed to actively work to schedule follow-up in-person visits to administer immunizations and other physical components of the exam which cannot be accomplished through telemedicine.
Coverage of home and community-based waiver services (HCBS) - In response to the public emergency, Florida obtained approval from the federal government to make changes in HCBS waiver programs, including the Long Term Care and Developmental Disabilities programs. The changes are effective retroactively from January 27, 2020 to January 26, 2021. Details can be found here. They include, but are not limited to:
Note on COVID-19 testing, treatment, and vaccines for the uninsured. Florida has not opted to receive 100 percent federal Medicaid funding for COVID-19 testing of people without health insurance. Under the 2021 American Rescue Plan Act this option has been expanded to cover COVID-19 treatment and vaccines for the uninsured as well. Since the state has not taken up this option Floridians must look to an uneven patchwork of free testing, treatment, and vaccine resources scattered around the state. AHCA advises that uninsured people may receive free testing from their county health department or a federally qualified health center and that “many communities provide testing for free for individuals who do not have insurance. Please [click here] to find a test site in your area. Uninsured individuals should ask before the test whether testing is free of charge." There are no state agency instructions on where uninsured people can receive free treatment. However, more information on possible sources for free treatment is available here.
Residency proof no longer required at some vaccine sites, “paving the way for migrants.” - On April 29, 2021 Surgeon General Rivkees issued a new public health advisory specifying that COVID-19 vaccines are available to “a Florida resident” or someone “who is present in Florida for the purpose of providing goods or services for the benefits of residents and visitors of the State of Florida.” This new policy applies to all state-run and federally supported vaccination sites. It rescinds an advisory issued in January that had restricted vaccinations to people who could show proof of Florida residency
2021 unemployment compensation claimants can access free or reduced cost health insurance through the ACA marketplace. The Affordable Care Act (ACA) Marketplace was re-opened in February 2021 to give people who need health insurance a new “special enrollment" opportunity to get covered. The 2021 American Rescue Plan eliminated or vastly reduced premiums for many people with low or moderate incomes.
Starting July 1, 2021, people who received or have been approved for unemployment compensation for any week beginning in 2021 can access free or reduced cost comprehensive health insurance plans through the ACA marketplace. This benefit is available regardless of someone's current income. To get this benefit, people must enroll in the marketplace no later than August 15, 2021. For help with enrollment, contact Covering Florida at 877-813-9115.
School children in distance learning still eligible for free or reduced cost meals. Students in distance learning for 2020-21 can still receive school meals through the National School Lunch Program if they are eligible. The student or parent/guardian may pick up meals at the school but should contact their school for more information.
For a list of current child nutrition program waivers for Florida from USDA, go here.
Congress allows increased fruit and vegetable benefits. At present, WIC provides $9 for children and $11 for women monthly for fruits and vegetables. The American Rescue Plan Act makes funding available for a four-month increase in the benefit of up to $35 monthly, if a state chooses to do so.
DOH attains waiver allowing remote issuance: Department of Health (DOH) obtained a waiver of the requirement that participants pick up their EBT cards in person at recertification or during nutritional education appointments.
WIC participants allowed to substitute certain food. Under a waiver from USDA, WIC participants in Florida are allowed to substitute milk of any available fat content and whole wheat or whole grain bread in package sizes up to 24 oz. when 16 oz. packages are unavailable.
USDA waived physical presence requirements: Although the scope and logistics are unclear at this time, USDA has given DOH permission to waive the requirement that persons be physically present at each certification or recertification determination in order to determine eligibility under the program through May 31, 2020.
USDA extends certification periods through May 31, 2020, for some participants.
For a list of current WIC waivers for Florida from USDA, go here.
HHS provides guidance. HHS has issued guidance on the flexibilities in TANF to respond to COVID-19.