SNAP – Noticing Able-Bodied Adults without Dependents before Reinstating the Time Limit

In response to the COVID-19 Federal public health emergency, the Families First Coronavirus Response Act (FFCRA) suspended the time limit and work requirement for able-bodied adults without dependents (ABAWDs) unless the individual is not complying with a work program or workfare program offered by the state that meets standards of section 6(o)(2)(B) or (C). FFCRA also requires state agencies to reset all ABAWD countable months to zero effective June 1, 2023, and lifts the suspension effective July 1, 2023. State agencies that have approved waivers of the time limit may continue to implement them. In addition, state agencies may continue to exempt individuals using their available discretionary exemptions.

FNS strongly encourages state agencies to inform all ABAWDs of their time-limited status and what actions they can take to remain eligible for Supplemental Nutrition Assistance Program (SNAP) benefits as soon as possible.

Notice Requirements

State agencies must provide households with a consolidated written notice and an oral explanation of all applicable work requirements, including the general work requirements, ABAWD requirements and mandatory SNAP Employment and Training (E&T), if assigned. The state agency must provide this consolidated written notice and oral explanation at certification, recertification and whenever a previously exempt household member or new household member becomes subject to work requirements (see 7 CFR 273.7(c)(1)(ii)).

State agencies that did not notify households about the ABAWD time limit and work requirement while it was suspended under FFCRA are required to do so before ABAWDs become subject to the time limit again.

State agencies that notified households about the ABAWD time limit and work requirement despite the time limit being suspended are not required to provide additional notice. However, FNS strongly encourages state agencies to do so as it is a best practice and good customer service.

In preparation for re-implementing the time limit, state agencies should review the memorandum “Preparing for Reinstatement of the Time Limit for Able-Bodied Adults without Dependents” to confirm their readiness.

Screening for Exemptions

FNS would like to remind state agencies of the importance of screening work registrants to determine if they are exempt from the ABAWD time limit and work requirement. FNS would also like to remind states that require ABAWDs to participate in SNAP E&T as a condition of SNAP eligibility that individuals cannot be required to participate in E&T unless they have been properly screened and referred to the program. Proper screening includes applying the ABAWD exceptions when screening for referral to E&T. State agencies who apply the time limit and work requirements, including SNAP E&T, to individuals who should be exempt may put individuals’ nutrition and health at risk.

The recently enacted Fiscal Responsibility Act (FRA) of 2023 signed by President Biden on June 3, 2023 amends Section 6(o)(3) of the Food and Nutrition Act of 2008. The FRA phases in an increase in the age of those subject to the ABAWD time limit to age 54. It also provides new exceptions for veterans, homeless individuals and individuals who are 24 years of age or younger and in foster care on their 18th birthday (or higher age if the state offers extended foster care to a higher age). These new exceptions must be applied at application and recertifications received on or after Sept. 1, 2023. FNS strongly encourages state agencies to notify SNAP households of the current exceptions and the new exceptions so they understand the importance of sharing their information.

Ensuring Access for Limited English Proficient (LEP) Individuals and Individuals with Disabilities

FNS reminds state agencies of their obligations under federal civil rights laws to ensure individuals and families have equal access to SNAP benefits as states resume normal operating procedures. State agencies, their subrecipients and program operators must provide language access for LEP individuals and effective communication for individuals with disabilities. For more information, please see the memorandum, "Ensuring Language Access for LEP) Individuals and Effective Communication for Individuals with Disabilities In Consideration of the Recent Unwinding of the SNAP Emergency Allotments and Upcoming Unwinding of COVID- 19 Program Flexibilities."

Please contact your respective FNS regional office representatives with any questions.

Moira Johnston
Acting Director
Program Development Division