Able-Bodied Adults without Dependents (ABAWDs)

General Work Requirement Sect. 6(d) of Food and Nutrition Act and 7 CFR vs. ABAWD Work Requirement and Time Limit Sect. 6(o) and

People exempt from general work requirement (273.7) and the ABAWD work requirement/time limit (273.24) 80-85% People subject to general work requirement 15-20% People subject to BOTH general and ABAWD work requirement / time limit 5-10% The SNAP Population

General SNAP Work Requirement Applies to people who are: Age Fit for work Working under 30 hrs per week Not already complying with work requirements of another program Not students Not responsible for a child under (b) Requires: Register for work Participate in an E&T or workfare program if assigned by State Accept suitable employment if offered No voluntarily quit or reduction in work hours under 30 per week 273.7(a)

Failure to Comply with the General Work Requirement Ineligible for benefits (sanctioned) from 1 month to indefinitely, depending on the number of occurrences and the State’s chosen option Sanction periods:  1 st strike: months  2 nd strike: months  3 rd strike: 6 months to permanent 273.7(f)(2)

ABAWD Work Requirement & Time Limit Applies to people who are: Age Fit for employment Do not live in a SNAP household with a minor Not pregnant Not already exempt from general work requirement Not covered by time limit waiver or 15 percent exemption (c) Requires that ABAWDs: Work or participate in a work program (e.g. E&T) at least 20 hours per week, averaged monthly Participate in and comply with a workfare program (a)

Failure to Fulfill the ABAWD Work Requirement and the Time Limit ABAWDs are limited to 3 months of SNAP eligibility in any 3-year period while not fulfilling the ABAWD work requirement or otherwise exempt The time limit is the teeth behind the ABAWD work requirement

Countable Months A “countable month” is any month in which an ABAWD receives a FULL month of benefits while not fulfilling the ABAWD work requirement or otherwise exempt (b)(1)

15 Percent Exemptions Each 15 percent exemption can exempt 1 ABAWD from the time limit for 1 month FNS provides a new allotment each fall, and unused exemptions carry-over States can use 15 percent exemptions as they see fit (g) Time Limit Waivers States can request to waive the time limit in areas with high unemployment or lack of sufficient jobs If, when, and where to request a waiver is a State decision, but any request must be supported with evidence (f)

Regaining Eligibility ABAWDs who have exhausted their 3 countable months can regain eligibility: –Meet an exemption from ABAWD work requirements –Fulfill the ABAWD work requirement for 30 consecutive days ABAWDs who regain eligibility by working get an additional 3 consecutive countable months (d) and (e)

Options for measuring the 36-month time period: Rolling Clock: looks back 36 months from any point in time Fixed Clock: Starts on a certain day and runs for 36 months with a set start/stop date. –States can choose to have – Same period for everyone Individual period No matter what, it’s always 36 months (b)(3)

Fixed Clock Same period for everyone Every ABAWD in the State is on the same 36-month timeline Oct 1, 2013 Start of 36 mo period Sept 30, 2016 End of 36 mo period

Fixed Clock Individual periods Each ABAWD has their own 36-month period, based on the time they were certified for benefits or became an ABAWD. July 1, 2015 Start of 36 mo period June 30, 2018 End of 36 mo period

Rolling Clock Looks back 36 months from any point in time, and clicks forward as months pass August 2012 July 2015 Sept 2012 August month later, the clock rolls forward and August 2012 falls off...

What needs to be tracked each month for each individual ABAWD?  Participation status  Countable months  Fulfillment of the work requirement  Exemption status  15 percent exemption  Good cause  Additional 3-month eligibility

Effectively Identifying ABAWDs Screen at certification and determine ABAWD status Set certification periods consistent with household circumstances Review the case file and household circumstances at periodic report and recertification

States are responsible for notifying ABAWDs  Explain the work requirement, time limit, and exemption criteria at certification, periodic report, and recertification  Provide an adequate NOAA prior to enforcing the time limit  Provide an additional notice prior to waiver expiration

Final Thoughts Inaccurate application of the time limit can significantly impact State error rates States can still request to waive the time limit States are not required to assign E&T for all ABAWDs; States can run voluntary or mandatory E&T programs for ABAWDs

Resources Guide to Serving ABAWDs Subject to Time Limited Participation June 2015 ABAWD Questions and Answers memo March 2015 Expiration of ABAWD Time Limit Waivers memo December 2013 ABAWD Questions and Answers memo Partnerweb adults-without-dependents-abawdshttp:// adults-without-dependents-abawds