Able-Bodied Adults Without Dependents (ABAWDs)

Current status of the ABAWD rule

California’s statewide waiver of the ABAWD (time limit) rules was terminated effective November 1, 2025.  California will implement the time limit rules effective June 1, 2026.  [ACL 25-93.]

Regardless of the status of the waiver, counties must: identify ABAWDs, screen for exemptions, inform participants of the ABAWD and work rules, and track and report work registrant, ABAWD, and Employment and Training data.  [Ibid; ACL 25-14.]  Counties must provide written notice and oral explanation of the applicable CalFresh work rules to all households where at least one member is subject to a CalFresh work rule.  [Ibid.]  CDSS has created a script for counties to use to inform applicants and recipients of the ABAWD rules.  [ACL 24-42.] Counties must also track and report data about work registration, ABAWDs, and Employment and Training. [ACL 22-40.]

Individuals who were previously discontinued from CalFresh for failure to meet ABAWD requirements and reapply to CalFresh may be approved for benefits if otherwise eligible. CalFresh Employment and Training and voluntary quit sanctions do not stop when the individual moves to a county with an ABAWD time limit waiver.  [ACL 22-40; ACL 21-67.]

What are ABAWDs?

“ABAWD” refers to Able-Bodied Adults Without Dependents. The ABAWD change was the first time in federal legislation that a time limit was imposed on receiving SNAP benefits. Congress singled out for a three-month time limit, in any three year period, all those “able-bodied” recipients who are not working or in an acceptable work program. [7 U.S.C. § 2015(o)).]

What this means in practice is that anyone between the ages of 18 and 64 with no children under age 14 and who is not disabled, might only be able to get three months of CalFresh benefits every three years.

ABAWDs get three full months of benefits, even if — due to prorating in the month of application — the ABAWD ends up receiving a partial fourth month of benefits as well. An ABAWD could also receive a partial fourth month if she became exempt or covered by a waiver part way through a month. [MPP §§ 63-410.35, 63-410.1, 63-410.3; 7 C.F.R. §§ 273.24(b), 273.24(c).] This cut-off applies if the person is not working, or in workfare at least 20 hours a week, or otherwise participating in an approved work/training activity. [MPP § 63-410; 7 C.F.R. § 273.24(b).] The work and training activities are defined in MPP § 63-407.8; 7 C.F.R. § 273.7(a)(1) and (2).

CDSS has decided to implement the 36 month period using a fixed statewide clock.  This means all ABAWDs will have the same time 36 month time period, and when the clock starts it will continue uninterrupted.  The clock will begin on January 1, 2026 and will reset on January 1, 2029.  When the statewide clock ends, all ABAWDs will have their clock restart and can again receive their 3 months of CalFresh.  [ACIN I-88-16.]

Exceptions to the ABAWD work rules and cut-off

The three-month cut-off does not apply if the person is:

  • Under age 18 or over age 64. [MPP § 63-410.321; 7 C.F.R. § 273.24(c )(1).]
    • Recipients who are age 60 through 64 are exempt from work registration, but are still subject to the time limit unless they qualify for another work registration exemption or a time limit exemption.  [ACL 25-93.]
  • Mentally or physically unfit for work. [MPP § 63-322; 7 C.F.R. § 273.24(c)(2).]
    • Recipients can now use the CF 887 form to verify physical unfitness.  [ACL 25-34.]  That form is optional.
  • Pregnant. [7 C.F.R. § 273.24(c)(6).]
  • Working 20 hours per week or 80 hours a month (including work in exchange for “in-kind income”). MPP § 63-410.221; 7 C.F.R. § 273.24(a)(3)(iii)]
  • Participating in an employment and training program 20 hours a week (if job search activities are less than half the hours). [MPP § 63-410.212-213; 7 C.F.R. § 273.24(a)(1)(iii).]
  • Participating in a workfare program for the required number of hours (determined by dividing the person’s CalFresh benefit by the minimum wage). [MPP § 63-410.212; 7 C.F.R. § 273.24(a)(1)(iv).]
  • The parent or stepparent, or otherwise responsible for the care of, a dependent child under age 14, even if that person is not eligible for CalFresh benefits, and even if the child is not living in the same household. [ACL 25-93; MPP § 63-410.323; 7 C.F.R. § 273.24(c)(3).]
  • Living with a household member who is under age 14, even if that person is not eligible for CalFresh benefits. [MPP § 63-410.323; 7 C.F.R. § 273.24(c)(4).]
  • Living in a geographic area that has an ABAWD “waiver.” [MPP § 63-410.33; 7 C.F.R. § 273.24(b)(1)(ii); see ACL ACL 25-79 (counties that currently have waivers are Colusa, Imperial and Tulare).]
  • Individuals who meet the definition of Indian, Urban Indian, or California Indian in the Indian Health Care Improvement Act.  [ACL 25-93.] Self-attestation is sufficient to grant the exemption. [Id.]
  • Exempt from the CalFresh work registration requirements. (For example, the recipient is receiving unemployment benefits, has a pending unemployment insurance application, is a student in an education or training program at least half-time, or in a drug treatment program.) [MPP § 63-410.31, MPP § 63-407.21.]).

[7 C.F.R. § 273.24(c)(5).]

California is required to screen for ABAWDs exceptions.  [ACL 24-06.]  The new semi-annual reporting form SAR 7 includes questions to screen for ABAWD exceptions.  [Id.]  CDSS also has a screening form to help determine eligibility for exemptions from the ABAWD rules.  [CF 377.11E.]  The screening form does not eliminate the need for obtaining verification of exemptions.  [ACL 20-19.] Counties cannot take any negative action related to the time limit or work requirements on a case until an individual who is subject to the time limit has been rescreened for exemptions and has been informed of the time limit and work requirements. [ACL 25-93.] Counties must complete or voluntarily offer exemption screening if an individual discloses that they may meet the criteria for an exemption. [Id.] Counties must screen each household member individually. [Id.]

Beginning on June 1, 2026, counties must screen all recipient households at their next recertification an every subsequent recertification. [Id.] Counties cannot assign a countable month until exemption screening is completed. [Id.] Beginning June 1, 2026, new applicants must complete exemption screening at initial certification. [Id.]

If an individual loses an exemption, the county cannot assign countable months until the individual is rescreened for exemptions.  [ACL 25-93.] Recipients must report mid-period if their income is over the Income Reporting Threshold, or their work hours drop below 20 hours per week or 80 hours per month.  [Id.] If an individual reports a drop in work hours, the county must assess whether there is good cause or another exemption. [Id.] If an individual’s circumstances change mid-period to make them eligible for an exemption, the county must apply the new exemption within 10 days. [Id.]

In addition, federal law allows discretionary exemptions for 12 percent of the state annual CalFresh caseload. The Fiscal Responsibility Act of 2023 reduces the number of discretionary from 12 percent of the caseload, to eight percent of the caseload. California does not currently have any discretionary exemptions.  [ACL 25-93.] CDSS will release a letter with instructions when California is allocated new discretionary exemptions.  [Id.] Counties must continue to evaluate recipients for exemptions or good cause not meeting the work requirement. [Id.]  For more information about discretionary waivers, go to Waiver of the ABAWD work requirements in this guide.

Good cause for missing work

If the person would have worked an average of 20 hours per week but missed some work for “good cause,” and if the absence from work is temporary, and they keep their job, the CalFresh office must find there was compliance with the work requirement. [MPP § 63-410.221; 7 C.F.R. § 273.24(a)(2).] Good cause includes circumstance beyond a person’s control, such as illness, illness of another household member requiring the recipient’s presence, a household emergency, or the lack of transportation. [MPP § 63-407.5; 7 C.F.R. § 273.24(b)(2).]

Extended benefits for job loss

If the person gets three months of benefits while not working or not exempt, and then gets a job, but later loses that job, they can get three more months of benefits. [MPP § 63-410.52; 7 C.F.R. § 273.24(e).] This extra three months of benefits is allowed only one time in three years, and the three months have to be in a row. [MPP § 63-410.521; 7 C.F.R. § 273.24(e).]

Regaining eligibility after three-month cut-off

One will be eligible for CalFresh benefits if the person:

  • Works at least 20 hours per week or 80 hours in a 30-day period in paid or volunteer employment;
  • Complies with the requirements of a work program for at least 20 hours per week or 80 hours in a 30-day period;
  • Performs any combination of work and training or education for at least 20 hours per week or 80 hours in a 30 day period (WIOA or CalFresh Employment and Training programs count toward the 20 hours per week);
  • Complies with a workfare program for the number of hours needed for one month’s worth of benefits; or
  • Becomes exempt.

[MPP § 63-407.5; 7 C.F.R. § 273.24(d)(1).]

ABAWDs who lose their benefits, then become exempt, can regain CalFresh benefits by reapplying. [MPP § 63-407.53; 7 C.F.R. § 273.24(d)(v) and 7 C.F.R. § 273.7(g).]

If an ABAWD has regained eligibility after losing the time-limited benefits, and then stops doing the work requirement during the 36 months of the time-limit bar, she can get CalFresh benefits for three consecutive months, beginning on the first month the county learns that the individual is not satisfying the ABAWD work requirement. [MPP § 63-407.52; 7 C.F.R. § 273.24(e).] In other words, successfully regaining CalFresh benefits, and then losing them, starts a new 3-month time-limited benefit.

“Notice of Action” of ABAWD status

A county must give a Notice of Action (NOA) in the person’s third month of benefits that a person’s CalFresh benefits will be cut off due to ABAWD rules. [MPP § 63-410.41.] The notice must state that the person may demonstrate that he was (or is) exempt from the work requirement, has good cause for non-compliance (per MPP § 63-410.221), or that he actually met the work requirements. [MPP § 63-410.413.] The notice must also tell him what months are at issue. [MPP § 63-410.412.] The person can always request a fair hearing on these issues if he cannot convince the county he should not be cut off.

For more details about the ABAWD rules, see the CalFresh Able-Bodied Adults Without Dependents Time Limit Handbook attached to ACL 18-08.