How do state agencies document and approve medical exemptions for ABAWDs?
Executive summary
States accept medical exemptions to ABAWD (able‑bodied adults without dependents) rules largely through clinician‑filled medical statement forms plus state medical verification processes; New York, Washington, California guidance and federal FNS waiver rules show states require documentation, screening, and reporting while maintaining discretion on forms and processes (examples: NY’s ABAWD Medical Statement; WA’s DSHS Form 10‑353/14‑541; counties must screen and track even under waivers) [1] [2] [3] [4].
1. How federal rules set the frame: waivers vs. medical exemptions
The USDA’s Food and Nutrition Service (FNS) distinguishes two mechanisms that affect ABAWDs: area‑level ABAWD waivers (triggered by high local unemployment or lack of jobs) and individual exemptions such as medical incapacity. Waivers suspend the three‑month time limit in whole counties/areas but do not eliminate the general SNAP work requirements or the need for states to screen and document exemptions for individuals; states may request temporary waivers from FNS when an area’s unemployment exceeds 10% or jobs are insufficient [4] [5].
2. Typical on‑the‑ground workflow: screening, provider form, and state review
State and local agencies first identify who is an ABAWD and then screen for exemptions; if a client reports a physical or mental barrier to working the required hours, agencies ask for a completed medical statement from a healthcare provider. New York’s SNAP guidance directs recipients to submit an “ABAWD Medical Statement” completed by a clinician to document exemptions for physical/mental health, pregnancy, or substance‑use treatment [1]. Washington’s DSHS lists specific medical verification forms (Form 10‑353 or 14‑541) used to document medical condition and residual functional capacity for ABAWD determinations [2] [6].
3. What providers are asked to certify
Available state guidance emphasizes function over diagnostic labels: New York and NYC say clinicians should attest that a condition prevents meeting the work standard (20 hours/week or participation in qualifying activities), and that a specific diagnosis or SSDI status is not required [1] [7]. Washington’s medical verification forms explicitly collect information on functional capacity, implying agencies base exemptions on documented limitations rather than formal disability determinations [2].
4. Recordkeeping, reporting, and administrative consequences
Even where statewide waivers exist or existed, counties must still “identify ABAWDs, screen for exemptions, inform participants, and track and report work registrant and E&T data,” per California guidance; that means documentation from clinicians becomes part of case files and is used for monthly eligibility checks and counting months toward the three‑month limit [3]. Federal FNS materials reinforce that waivers don’t replace recordkeeping and that states must track participation and report waiver periods [4] [5].
5. Timing, implementation and why this matters now
Multiple sources note a renewed, nationwide emphasis on enforcing ABAWD rules starting Nov. 1, 2025, which increases the administrative importance of clear medical documentation and screening so states can determine exemption status and avoid improper benefit terminations [8] [9] [10]. Washington and other states explicitly updated guidance in late‑2025 to reflect renewed enforcement, and some states report that previously waived areas are no longer exempt, creating more cases requiring documentation [6] [11].
6. Where states have discretion — and where tensions arise
States choose the exact forms, evidentiary standards, and workflows: some use standardized state forms (WA’s 10‑353/14‑541), others provide an “ABAWD Medical Statement” for clinicians (NY/NYC), and counties can be responsible for initial screening [2] [1] [3]. This discretion creates potential inconsistencies in who receives exemptions, and the increased enforcement directive raises the risk that administrative gaps or slow provider responses could produce benefit loss for eligible clients — a dynamic visible in state notices telling recipients to promptly submit medical statements or risk losing benefits [7] [10].
7. Limitations in the available reporting and open questions
Available sources document forms and general procedures but do not provide national standardized timelines for processing medical statements, uniform evidentiary thresholds across all states, or comprehensive audit results on error rates. They also do not quantify how many ABAWD exemption claims are approved or denied nationally. For those operational details, available sources do not mention national processing‑time data, denial rates, or examples of appeals outcomes [4] [5] [3].
8. Bottom line for clinicians, clients, and advocates
Clinicians should complete the specific state medical statement requested, focusing on functional limits and expected duration; clients must submit the completed form to the local SNAP office promptly to preserve benefits; advocates should monitor state forms and reporting requirements because documentation standards and the administrative burden vary by state and have practical consequences amid renewed enforcement [1] [2] [7].