What exemptions exist for ABAWDs under SNAP and how do states verify them?
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Executive summary
Able‑Bodied Adults Without Dependents (ABAWDs) face a federal three‑month time limit unless they meet specified exemptions or a state obtains a waiver; exemptions cover age, disability/medical inability, caregiving or household composition, students and certain training participants, homelessness and other categories, and states verify claims through a mix of self‑attestation, documentation from other public programs, medical statements, employer/paystub records, and administrative codes or case notes [1] [2] [3]. States also have limited discretionary exemptions and can seek area‑level waivers based on labor market conditions, while federal guidance requires continuation of verification standards under regulation [4] [5] [6].
1. Who counts as an ABAWD and why exemptions matter
ABAWDs are SNAP recipients who are able‑bodied, aged between discrete statutory limits, and have no dependents; if they do not meet ABAWD work requirements they are subject to receiving SNAP for only three months in a 36‑month period unless exempted or covered by a waiver [1] [4]. Exemptions and waivers are the primary tools states use to preserve benefits for people who cannot meet or are excused from the 80‑hour per month (or 20 hours per week) work/training standard that satisfies the ABAWD requirement [1] [7].
2. The principal exemption categories under federal policy
Federal guidance lists multiple exemption classes: people under minimum or over maximum age cutoffs, those with a physical or mental barrier to work (including disability), individuals participating in qualifying education, training, or SNAP Employment & Training (E&T) at sufficient hours, caregivers or household members with children, and people who meet other statutory exceptions such as SSI recipients or those jointly applying with SSI — states also treat homelessness and certain medically unable individuals as exempt in practice [2] [1] [8] [3]. State manuals and webpages echo these categories and add operational definitions (for example, the 80 hours/month standard and volunteer work as acceptable activity) used to determine exemption status [7] [8].
3. Waivers and discretionary exemptions: area‑level and case‑by‑case relief
Beyond individual exemptions, the Food and Nutrition Act allows states to request temporary area‑level ABAWD waivers where local unemployment exceeds specified thresholds or job availability is insufficient, which suspends the three‑month limit for residents of the waived area; separately, FNS allocates a limited number of discretionary (case‑by‑case) exemptions that state offices may request for individual ABAWDs [4] [9] [5]. States must follow federal waiver transparency processes and FNS publishes waiver materials and quarterly status, while discretionary exemptions require state unit approval and tracking for FNS reporting [9] [5].
4. Federal verification framework and regulatory baseline
Federal memoranda emphasize that states must follow the verification requirements in 7 CFR 273.2(f) and 273.24(l), and that screening for exemptions is required at application and recertification with consolidated notices explaining work rules and E&T obligations [6] [2]. The national policy guide states that a state agency is not automatically required to verify self‑reported exemptions unless information is questionable, and that verified data from other public assistance programs or administrative records can be used as verification [2] [3].
5. How states actually verify: practices and paperwork
State practice is a patchwork: many states accept self‑statements unless questionable, ask for paystubs, employer letters, E&T participation records, medical professional statements, or documentation from other state programs as verification, and assign eligibility codes in case management systems to reflect exemption status; specific forms and portals (online upload systems, questionnaires, medical exemption forms, volunteer verification forms) are commonly used by states like Pennsylvania, Tennessee, Colorado, Texas and Rhode Island [10] [11] [12] [7] [13]. Some states operate a formal review path for medical determinations (e.g., referral to a Medical Review Team) while others use community partner forms or agency matches to confirm homelessness or caregiving status [3] [14] [5].
6. Recent statutory changes and the verification impact
The One Big Beautiful Bill Act of 2025 altered who is subject to the ABAWD time limit (raising the upper age subject to the limit and changing exception criteria) and FNS has instructed states to update notices and continue following established verification regulations while offering limited QC hold‑harmless periods during implementation; practitioners warn these changes expand the number of people who must be screened and verified [6] [1] [15]. State websites and guides reflect active implementation steps — new uploads deadlines and revised questionnaires — underscoring operational strain and the uneven timing of state checks [11] [15].
Conclusion: a rules‑heavy system that blends trust, documentation and local discretion
The ABAWD exemption regime is governed by clear federal categories and regulatory verification standards, but implementation relies heavily on state screening, administrative matches, and a mix of documentary and attestation evidence; waivers and discretionary exemptions add geographic and case‑level flexibility, and recent federal legislative changes have widened the pool subject to screening while keeping verification anchored to 7 CFR standards [1] [6] [4] [5]. Where reporting is silent, no claim is made about state practices beyond the sources cited.