90-Day WOTC Watch Series (Part 2): How 2025 SNAP Program Changes Could Impact WOTC for Employers
This is the second article in our 90-Day WOTC Watch Series of articles, exploring the impact of how the SNAP changes affect WOTC activity and whether Congress moves to extend the credit into 2026. Click here for the first article in the series.
Summary
- SNAP eligibility updates effective November 1, 2025, could directly affect how employers qualify for the Work Opportunity Tax Credit (WOTC).
- WOTC is set to expire on December 31, 2025. There is a current Bipartisan movement on renewing the tax credit before the expiration date.
SNAP Program Changes & Their Impact on hiring in the last 30 days
Our internal data shows a 7.75% increase in the number of WOTC applications received for the SNAP category in November 2025 compared with November 2024. During this same period, overall hiring growth has slowed while layoffs have increased. Despite these trends, our data shows a rise in the number of SNAP recipients being hired, which may be a benefit to employers who participate in the WOTC program. As the available labor pool expands and SNAP work requirements increase, employers may see an increase in the amount of the credit employers receive for hiring qualified SNAP recipients.
More data and insight will be available after the November Jobs Report is released in mid-December.
Read more here about hiring trends: US layoffs for October surge to two-decade high, Challenger data shows | Reuters
WOTC Reauthorization Status
There is active legislation aimed at not only extending but also expanding WOTC. For example, the Improve and Enhance the Work Opportunity Tax Credit Act (H.R. 1177) was introduced in the House on Feb. 10, 2025. One of the legislation sponsors is Senator Bill Cassidy (R-LA). He, along with Representative Lloyd Smucker (R-PA), is introducing legislation to extend WOTC for five years. These lawmakers are currently working on legislation that combines uncoordinated efforts to expand and enhance WOTC for employers who hire people who usually have a difficult time finding employment.
House Bill H.R. 1177 proposes:
- Increasing the WOTC claimable wage percentage (for many hires) from the current 40% to 50%.
- Removing the maximum age limit for SNAP benefit recipients in order to qualify.
Read the complete Bill and recent updates here:
- All Info – H.R.1177 – 119th Congress (2025-2026): Improve and Enhance the Work Opportunity Tax Credit Act | Congress.gov | Library of Congress
- Bipartisan Momentum Grows for Employement Tax Break Expansion
What Employers Should Continue Doing
1. Continue WOTC as part of your onboarding process
2. Monitor SNAP eligibility changes: Track state-level updates that could affect applicant status.
3. Stay connected with experts: Work with your WOTC consultant or contact McMillian & Associates for program updates and impact analysis.
Discover Georgia and National SNAP Updates
- https://dhs.georgia.gov/snap-work-requirement-change-effective-nov-1-2025-abawds
- https://www.fns.usda.gov/obbb
- https://www.fns.usda.gov/snap/recipient/eligibility
Key Takeaways
- SNAP changes effective November 1, 2025, may reduce WOTC-eligible hires.
- WOTC expires December 31, 2025. There is current Bipartisan movement on renewing the tax credit before the expiration date.
- Employers should stay proactive: continue submitting applications, track eligibility updates, and lean on trusted WOTC experts for guidance.
Stay Tuned
Stay tuned for our next episode in our 90-Day WOTC Watch Series as we dig into the impact of the second 30 days of SNAP Changes on WOTC for employers, and share if there have been any movements in getting the WOTC program reauthorized for 2026 and beyond.
Stay connected with us on LinkedIn or reach out to David McMillian at dmcmillian@mcataxcredits.com for more insights.
For real-world examples of how McMillian & Associates helps employers capture WOTC credits, explore our Success Stories.