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SNAP - ABAWD Discretionary Exemptions Totals for FY 2022

Resource type
Policy Memos
Guidance Documents
Resource Materials
DATE: April 14, 2022
SUBJECT: Supplemental Nutrition Assistance Program (SNAP) – Fiscal Year 2022 Allocations of Discretionary Exemptions for Able-Bodied Adults Without Dependents
TO: All SNAP State Agencies
All Regions

Section 6(o) of the Food and Nutrition Act of 2008 (the Act) limits the amount of time able-bodied adults without dependents (ABAWDs) may participate in the Supplemental Nutrition Assistance Program (SNAP) to three months in any 36-month period, unless an individual fulfills certain work requirements or is otherwise exempt from the time limit. However, the Act allocates a number of monthly discretionary exemptions to the ABAWD time limit each fiscal year (FY), based on 12 percent of a state’s estimated number of covered individuals, as defined in section 6(o)(6)(A)(ii) of the Act.

This memorandum adjusts the total number of exemptions available to each state for FY 2022, as shown in the table on the next page. This includes increases in the number of exemptions available to states in which caseloads increased by more than 10 percent, as described in section 6(o)(6)(F) of the Act.

Please note that the totals do not account for any exemption usage in FY 2022 (those figures must be reported in final by states on the form FNS-583, due 45-days after the end of the FY). While states have great flexibility in applying discretionary exemptions, states must track and report the number of discretionary exemptions used each month on a quarterly basis to their respective FNS regional office via the FNS-583 form. In addition, discretionary exemptions must be properly documented in the case file prior to monthly quality control sample selections.

Special Considerations

As a reminder, the Families First Coronavirus Response Act (FFCRA) temporarily and partially suspends the time limit for ABAWDs’ participation in SNAP from April 1, 2020, through the end of the month subsequent to the month in which the public health emergency declaration by the Secretary of Health and Human Services based on an outbreak of COVID-19 is lifted. If a state offers an ABAWD a slot in a work or workfare program that would allow the person to meet the ABAWD work requirement for a given month, including a SNAP Employment and Training (E&T) program under section 6(d)(4), the individual is still subject to the time-limit.

Therefore, many states did not need to use any discretionary exemptions in FY 2022. For more information, please see the memo SNAP – Families First Coronavirus Response Act and Impact on Time Limit for Able-Bodied Adults Without Dependents (ABAWDs).

State agencies with questions should contact their respective regional office representatives.

J. David Noble
Acting Chief
Certification Policy Branch
Program Development Division


Page updated: September 28, 2022