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Implementing SNAP Provisions in the Fiscal Responsibility Act of 2023

DATE:June 30, 2023
SUBJECT:Implementing SNAP Provisions in the Fiscal Responsibility Act of 2023
TO:All State Directors
Supplemental Nutrition Assistance Program

On June 3, 2023, the President signed into law the Fiscal Responsibility Act of 2023 (the FRA).

On June 9, 2023, the Food and Nutrition Service (FNS) published a memorandum, “SNAP Provisions in the Fiscal Responsibility Act of 2023,” describing the Supplemental Nutrition Assistance Program (SNAP) provisions of the FRA. Attached is a memorandum with additional information for state agencies implementing the FRA provisions.

The FRA changes the SNAP work requirement policy, including the exceptions from the able-bodied adults without dependents (ABAWD) time limit, and reduces the number of discretionary exemptions state agencies will earn and carry over annually. Implementing these provisions will require state agencies to make extensive changes in a short period of time. FNS encourages state agencies to take necessary steps, such as updating policy manuals, training workers, modifying systems, revising notices using plain language and locally and culturally appropriate messaging, collaborating with partners, and meeting directly with individuals and families who will be impacted by these changes to successfully implement the provisions of the FRA, including other government agencies and community partners that have relationships with the individuals state agencies are attempting to reach.

FNS recognizes it will be challenging for state agencies to implement the provisions of the FRA simultaneously with ongoing efforts to reinstate the ABAWD time limit after the expiration of the partial suspension under the Families First Coronavirus Response Act (FFCRA). The FRA does not impact the timeline for reinstating the ABAWD time limit after the end of the FFCRA partial suspension. Please see the memorandum, “Preparing for Reinstatement of the Time Limit for Able-Bodied Adults without Dependents (ABAWDs),” which provides important reminders and best practices for state agencies reinstating the ABAWD time limit. In addition, FNS encourages state agencies to partner with their state and local workforce agencies and boards to help connect ABAWDs to employment and training opportunities at American Job Centers, as outlined in the joint letter from FNS and the Department of Labor (DOL) Employment and Training Administration.

FNS reminds state agencies that quality control active case reviews that identify an error resulting from the application of a mandatory change in Federal law that occurs during the first 120 days from the required implementation date are excluded from error analysis, per 7 CFR 275.12(d)(2)(vii).

FNS is committed to providing ongoing technical assistance to state agencies on issues related to the requirements of the FRA. State agencies with questions regarding these adjustments should contact their respective Regional Office representatives.

The contents of this document do not have the force and effect of law and are not meant to bind the public in any way. This document is intended only to provide clarity to state agencies and the public regarding existing requirements under the law or agency policies.

Catherine Buhrig
Associate Administrator
Supplemental Nutrition Assistance Program


Page updated: December 15, 2023