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90-Day WOTC Watch Series (Part 1): How 2025 SNAP Program Changes Could Impact WOTC for Employers

WOTC

This article kicks off our 90-Day WOTC Watch Series of articles, exploring the impact of how the first 30 days of SNAP changes affect WOTC activity and whether Congress moves to extend the credit into 2026.

Summary 

What’s Changing and Why It Matters

The Supplemental Nutrition Assistance Program (SNAP) is updating its work requirements for adults without dependents starting November 1, 2025. These adjustments are anticipated to have a substantial effect on employers’ ability to claim WOTC for their employees who are SNAP recipients.  

Data from Fiscal Year 2024 reveals a significant correlation: 68% of all WOTC certifications were granted for individuals receiving SNAP benefits. Any changes to SNAP will potentially affect an employer’s hiring needs and retention rates.

How WOTC Works and What’s at Risk

The Work Opportunity Tax Credit, a pivotal federal initiative, was established in 1996 under the Small Business Job Protection Act to encourage inclusive hiring. Since its inception, the program has undergone a series of significant transformations, adapting to evolving economic landscapes and policy objectives. These changes have included the expansion and addition of eligible target groups and efforts to streamline the new hire certification administrative operation process.

Here’s how it works:

  1. Employers hire eligible individuals from target groups such as veterans, long-term unemployed, or SNAP recipients.
  2. Employers submit applications (request for certification for WOTC) to their state workforce agency within 28-days of the new hire’s start date.
  3. Employers receive the WOTC credit for certified employees based on wages paid to the qualifying employees.

However, because the program is statutory, it depends on Congressional reauthorization. The WOTC is currently scheduled to expire on December 31, 2025, and has experienced six lapses since 1998, creating “hiatus” periods where submissions are accepted but certifications are paused. A failure to renew the WOTC program eliminates employer access to this valuable tax credit.

Recent SNAP Changes and Their WOTC Impact

The most significant SNAP adjustment centers on work-hour requirements for adults without dependents. These updates could limit SNAP eligibility and reduce the number of employees who qualify under the WOTC’s SNAP Target Group.

From 2020 to 2024, more than 60% of all WOTC certifications came from this group, making SNAP changes especially impactful for employers.  WOTC and SNAP are deeply connected, and employers may see fewer qualifying candidates if eligibility is tightened.

To learn more about how WOTC certification works, visit McMillian & Associates’ WOTC Program page or review guidance from the U.S. Department of Labor’s WOTC overview. 

How Employers Can Prepare

Here’s what employers can do before the end of 2025:

  1. Review your hiring process: Confirm your WOTC submission workflow is timely and compliant.
  2. Monitor SNAP eligibility changes: Track state-level updates after Nov. 1 that could affect applicant status.
  3. Plan for a possible WOTC hiatus: If the program lapses after Dec. 31, you can still submit applications, but certifications will pause until renewal.
  4. Stay connected with experts: Work with your WOTC consultant or contact McMillian & Associates for program updates and impact analysis.

Key Takeaways

Stay Tuned

Stay tuned for our next episode in our 90-Day WOTC Watch Series as we dig into the impact of the first 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.