How New Work Requirements in SNAP and Medicaid Could Impact Class C/D Multifamily Investors

How New Work Requirements in SNAP and Medicaid Could Impact Class C/D Multifamily Investors

July 21, 20252 min read

How New Work Requirements in SNAP and Medicaid Could Impact Class C/D Multifamily Investors

As a real estate investor or fund manager, you’re likely focused on interest rates, cap rate spreads, and local comps.

But if you own or underwrite Class C or D multifamily assets, you also need to pay attention to what’s happening with social programs—especially SNAP (food stamps) and Medicaid.

The OBBBA just introduced major reforms that could shift your tenant base’s ability to pay rent. And very few investors are talking about it.


What Changed Under OBBBA

SNAP (Supplemental Nutrition Assistance Program):

  • $150 billion in funding cuts over 10 years

  • New 20-hour weekly work requirements for able-bodied adults without dependents

  • Estimated 2 million fewer participants nationwide

Medicaid:

  • $800 billion in funding reductions

  • Work requirement of 20 hours/week for childless, non-disabled adults

  • Biannual eligibility verification

  • Estimated 10 million enrollees affected

On paper, these are framed as “cost-saving” or “pro-work” provisions. But from an operator’s perspective, they signal a shift that impacts rent collections and stability.


Why This Matters to Class C and D Operators

If you operate in areas where your tenants rely on SNAP or Medicaid, their discretionary income just changed.

These programs often act as indirect rent subsidies. If those benefits shrink—or require more hoops to maintain—you could see:

  • Delayed or partial rent payments

  • Higher turnover and vacancy

  • Increased reliance on flexible payment plans

  • More demand for cash-based work, which doesn’t show up on screenings

Even a $200/month reduction in household support can be the difference between paying rent on time and falling behind.


What You Should Be Asking Right Now

  1. Who is your actual renter base?
    Do they depend on social benefits for food, healthcare, or housing supplements?

  2. What’s your exposure by property class?
    You may need to underwrite differently for C/D properties in lower-income census tracts.

  3. What assumptions are baked into your renewal models?
    If you're planning 5–7% annual rent bumps without factoring in reduced benefit eligibility, you're setting yourself up for friction.

  4. Are you building more flexible leasing models?
    Monthly, bi-weekly, or variable rent options may be worth testing in certain markets.


Not a Political Debate—A Portfolio Reality

This isn’t about whether the work requirements are good or bad. That’s not my job.

My job is to help investors see around the corner—and this policy shift is a signal.

If you're underwriting workforce housing, especially in blue-collar markets or lower-income areas, this matters.

And if you're not updating your economic models to reflect it, you're flying blind.

James Bohan is a CPA, fourth-generation real estate developer, and founder of Stonehan Accountancy. He advises fund managers, syndicators, and high-net-worth investors on tax-efficient strategies to grow and preserve wealth.

James Bohan

James Bohan is a CPA, fourth-generation real estate developer, and founder of Stonehan Accountancy. He advises fund managers, syndicators, and high-net-worth investors on tax-efficient strategies to grow and preserve wealth.

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