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Which specific medical conditions or disability determinations make someone ABAWD-exempt?

Checked on November 19, 2025
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Executive summary

Federal and state guidance say ABAWD exemptions center on being physically or mentally unfit for work (including pregnancy and substance use treatment), certain caregiving or veteran statuses, homelessness, and limited discretionary or area waivers; states implement and document those exemptions and may apply additional categories [1] [2] [3]. The USDA’s OBBB/2025 implementation clarified exception rules and tightened waivers effective July 2025 with full nationwide enforcement of ABAWD work rules on November 1, 2025 [4] [5].

1. What the statute and USDA guidance actually cover: “unable to work” is a core exemption

USDA policy and the SNAP ABAWD guidance make clear that the primary exemption for the ABAWD time limit is when a person is physically or mentally unfit for employment; that determination can be based on an obvious condition observed by agency staff or on medical certification from a health professional [1]. The SNAP policy guide stresses a person does not have to meet the SNAP definition of “disabled” or be on SSD/SSI to qualify as physically or mentally unfit for purposes of the ABAWD rule — states may certify temporary or permanent conditions that limit the ability to work the required hours [1].

2. Plain-language categories many state sites list: pregnancy, medical conditions, substance use treatment, homelessness, veterans, caregivers

Multiple state and explanatory sites list specific categories routinely treated as exemptions: pregnant people, those medically unfit for work (whether physical or mental conditions), participants currently in substance use treatment, people experiencing homelessness, veterans, and some caregivers [2] [6] [5]. State pages mirror federal materials by describing pregnancy and medical incapacity as common grounds for an exemption and adding homelessness or veteran status in their local exemption lists [2] [6] [7].

3. How proof and process work: medical statements, worker discretion, and administrative determinations

Agencies use a mix of documentary proof and staff observation: if a participant is “obviously” unfit for work, workers may exempt them without medical documentation; if not obvious, the state may request a medical professional’s statement and use designated processing centers or disability-review mechanisms to confirm inability to meet the work requirement [8] [9] [1]. State forms such as an “ABAWD Medical Statement” are commonly used to document exemptions for physical or mental health reasons or for participation in substance use treatment [2].

4. Waivers and discretionary exemptions: geographic and caseload limits

Beyond individual exemptions, the Food and Nutrition Act and USDA materials allow temporary area waivers where local unemployment or job shortages exist and permit states a limited number of discretionary exemptions tied to caseload numbers; recent law changes tightened and clarified these waiver and discretionary-exemption rules [10] [3] [11]. The USDA has signaled states must apply modified exception criteria immediately after the OBBB enactment and that waivers do not erase other general SNAP work requirements [4] [3].

5. State-level variation matters — state pages show different phrasing and procedures

State human services sites (e.g., New York, Arizona, Colorado, Maryland, Washington) echo federal categories but differ in administrative detail: how they define “homeless,” what forms they use, how they code temporary incapacity, and how they award discretionary exemptions [2] [6] [12] [13] [14]. For example, Arizona explicitly notes “medically certified as mentally or physically unfit for work” as an exemption and instructs use of medical certification procedures [6]. California materials also describe an “obviously physically unfit” pathway that may not require a written medical statement [8].

6. Points of debate and practical gaps in coverage in reporting

Reporting and state guidance emphasize medical and pregnancy exemptions, but news outlets and advocates also note practical risk: not all people with limiting conditions have formal disability determinations or quick access to medical certifications; delays in benefit appeals or disability decisions can create gaps [15] [1]. Available sources do not comprehensively list an exhaustive, uniform catalog of every medical diagnosis that qualifies — states apply the “unfit for employment” standard case by case, and that discretion creates uneven outcomes [1] [9].

7. What to do if you think you qualify for an exemption

Federal and state guidance instruct applicants to provide available medical documentation or use state medical statement forms; if a condition is obvious, caseworkers can make determinations without paperwork, and states offer processes (medical statement, MRT processing, or other reviews) to formalize exemptions [2] [8] [9]. The USDA memo on OBBB implementation told states to screen all applications and recertifications under the revised exception criteria immediately, so affected recipients should expect written notices and avenues to submit documentation [4] [5].

Limitations: This analysis is drawn from USDA guidance, the 2023 SNAP policy guide, state SNAP pages and explanatory reporting in the provided results; none of the linked materials offers a single, exhaustive list of specific diagnoses that automatically qualify — rather, the functional standard “physically or mentally unfit for work” governs determinations and is implemented differently by states [1] [9].

Want to dive deeper?
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