Fact check: Which states had waivers to SNAP ABAWD time limit and why?

1. What proponents claimed — Waivers applied widely where jobs were scarce

Federal guidance under the Food and Nutrition Act authorizes states to request temporary ABAWD waivers when an area has an unemployment rate above 10 percent or lacks a sufficient number of jobs, and multiple states used that authority in recent fiscal years to avoid closing off SNAP to ABAWD populations ^{[4] [1]}. The U.S. Department of Agriculture’s Food and Nutrition Service (FNS) posted lists of state waiver submissions and FNS responses for FY2020–2024 and updated materials for FY2025–29, documenting which states submitted waivers and whether those waivers were approved or denied; the FY2025 list of approved waivers named the states cited in federal postings ^{[4] [1]}. The legal basis and public posting of waiver materials were also shaped by the Fiscal Responsibility Act’s transparency requirements ^[4].

2. Which states actually had approved waivers in FY2025 — the documented list

FNS published an FY2025 roster of states with approved temporary ABAWD waivers that, according to federal materials, included Alaska, Arizona, California, Colorado, Connecticut, Delaware, District of Columbia, Illinois, Kentucky, Maine, Michigan, New Hampshire, New Jersey, New Mexico, New York, Oregon, South Dakota, Virgin Islands, Washington, and Wisconsin ^[1]. Earlier FY2020–2024 filings show a broader set of submissions, including additional jurisdictions such as Georgia, Guam, and Hawaii, but those lists covered different years and responses varied by state, with some approvals and some denials ^[4]. The FY2025 approvals reflect the federal assessment of local labor-market conditions as of the review period and the application of the statutory waiver criteria ^[1].

3. Why waivers were granted — the statutory and allocation mechanics

Waivers were granted primarily because areas met the statutory criteria of high unemployment or insufficient jobs, which is the explicit trigger in the Food and Nutrition Act for temporary ABAWD relief; FNS reviews state evidence and issues approvals or denials accordingly ^[4]. For FY2025, FNS also allocated a finite number of monthly discretionary exemptions to each state—calculated as 8 percent of the state’s estimated covered individuals—creating a quantitative cap and an administrative accounting system for exemptions that states must track and report quarterly ^[3]. The Fiscal Responsibility Act introduced limits on carryover of discretionary exemptions and increased public transparency for waiver materials, altering administrability and future state planning ^{[4] [3]}.

4. Recent policy shifts that narrowed waivers — H.R. 1 and the November 2025 deadline

Legislative changes embodied in H.R. 1 revised the waiver eligibility criteria and required FNS to make waiver materials public, significantly tightening the conditions under which waivers can be granted and signaling the end of many longstanding waivers; reporting indicates that roughly 20 states had waivers in effect but many of those waivers will end on November 2, 2025, under the new policy ^[2]. The new threshold returning to a strict 10 percent unemployment trigger reduces the number of qualifying areas compared with broader interpretations or discretionary exemption use in prior years, reshaping which communities remain exempt from the ABAWD time limit ^[2].

5. What advocates and critics emphasized — competing priorities and data gaps

Advocates for stricter work-accountability emphasize the need to encourage employment among able-bodied adults, while critics and many states emphasize that waivers reflect real local labor shortages and prevent disruptive loss of food assistance; think-tank analysis highlights systemic concerns about how work requirements are implemented without penalizing those unable to find work ^[5]. FNS administrative materials and the Fiscal Responsibility Act aim to increase transparency and standardize discretionary exemption tracking, but remaining uncertainties include how states will allocate limited new exemptions, how carryover limits will affect FY2026 planning, and which substate areas meet the tightened unemployment threshold ^{[3] [4]}.