How do SNAP disability exemptions vary between states for work requirement waivers?

1. How federal action changed the landscape overnight

The USDA’s guidance put every state on notice to fully apply long-standing ABAWD time limits and tighter work-participation rules beginning November 1, 2025, which reduces the latitude states previously used to suspend those rules during the pandemic; the federal memo also affirms specific exemption categories — including those who are pregnant or “medically unfit” — but requires states to verify status and track compliance ^{[1] [5]}.

2. What “disabled” or “medically unfit” means in practice — state role, not a single federal checklist

Federal pages and federal enforcement memos describe medical exemptions (medical expenses and special rules for elderly/disabled households) and note special SNAP rules for elderly or disabled members, but implementation depends on state determinations and documentation requirements; states are responsible for applying medical deductions and processing disability-related exemptions during eligibility or recertification ^{[6] [1]}.

3. Concrete state-level shifts: examples from New York and Delaware

New York’s SNAP office told recipients that its prior waiver of ABAWD work requirements will end as of November 2025 and that newly enforced work/time-limit rules mean formerly waived adults will need to meet participation or claim an exemption with documentation ^[3]. Delaware explicitly announced the end of certain exemptions — for example, the foster-care–on–18 exemption — and urged clients to notify caseworkers about health changes that could qualify for exemptions ^[4].

4. What remains the same: categories still exempted under federal instruction

The USDA guidance continues to exempt people who are pregnant, medically unfit (i.e., disabled), homeless, veterans, or caregivers from the ABAWD minimum-work clock, and it preserves case-by-case “discretionary exemptions” though it significantly limits blanket area waivers previously used by some states ^{[2] [1]}.

5. Where states still vary — verification, discretionary caps, and administrative practice

Even under nationwide enforcement, states retain discretion over how they verify disability and administer exemptions: they control documentation processes, the timing of recertification, and any remaining discretionary exemptions subject to federal caps; some states began applying checks earlier or will stagger verification at recertification, so the on‑the‑ground experience differs ^{[7] [2]}.

6. Practical implications for beneficiaries with disabilities

People with disabilities should expect to submit medical documentation to their state SNAP office to prove exemption status, and they may need to confirm eligibility at recertification; federal rules allow medical expense deductions for elderly/disabled members and special handling of disabled households, but the operational step — who collects and accepts what evidence — is a state responsibility ^{[6] [8]}.

7. Conflicting signals and political context to watch

Coverage and state advisories show disagreement about scope and timing: some local authorities and reporting stress immediate, stringent statewide enforcement (New York, Delaware notices), while advocacy groups warn of administrative delays and risks during transitions such as shutdowns; courts and state responses have at times produced different implementation timelines, so beneficiaries may see uneven applications across states ^{[3] [9] [10]}.

8. What to do now — actionable steps for people who may qualify as disabled

Check your state SNAP portal or contact your case manager to learn what medical documentation they require; submit proof early, monitor recertification notices, and use your state’s fair‑hearing/appeal process if benefits are reduced while you’re compiling documentation — states have been told to provide notice and opportunities to verify before terminating benefits ^{[8] [7]}.

Limitations: reporting in these sources focuses on federal enforcement and a few state notices (New York, Delaware) and on general USDA guidance; available sources do not provide a comprehensive, state‑by‑state list of exactly how each state defines or verifies “medically unfit” or disability exemptions, nor do they include sample state forms or uniform verification criteria (not found in current reporting).