AFS Special Procedures: ABAWD Eligibility Requirements

ABAWD Eligibility Requirements are temporarily set aside

The Families First Coronavirus Response Act (FFCRA) temporarily sets aside the time limit for Able-Bodied Adults Without Dependents (ABAWD) participation in the Supplemental Nutrition Assistance Program (SNAP). This is to be  applied during the period of 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.

Unless an individual meets another ABAWD exemption, ABAWDs applying for SNAP on or after April 1st should be coded Work Registration ‘Registered’ and ABAWD Exempt- Physically or Mentally Incapacitated.  

Note: Case notes MUST be made explaining the exemption was given due to the COVID-19 crisis.

With these ABAWDs being coded for this exemption, they will be certified as a normal semi-annual reporter. This means that they do not have to report when the exemption is lost. This also means at their MCR, the appropriate ABAWD ‘look back’ will need to be done. Initial ABAWD K months will need to be issued using the ABWU screen as appropriate and proper case notes made.


Mr. Smith applied for SNAP on 4/10/2020. He was not meeting any other work registration exemptions therefore subject to ABAWD. Due to the COVID-19 virus, the ABAWD time limit has been temporarily waived making Mr. Smith eligible for SNAP. He is coded Work Registration ‘Registered’ and ABAWD exempt, physically/mentally incapacitated and certified for 12 months. At his MCR for 10/1/2020, the worker completes the look back and finds the temporary suspension was lifted 6/1/2020 making Mr. Smith subject to ABAWD for 6/1/20. You contact Mr. Smith and verify he wasn’t meeting another exemption. You check ABAWI and he also hasn’t used his K months. You will use the ABWU screen to update June, July, and Aug for K months. Case note his exemption was lost and he didn’t meet another exemption. For September, the code should be left as a 2 as we do not want ABWI to show an excessive amount of K months. No overpayment is needed for September.

Also, please note, student policy has not changed, students must be working 20 hours a week to be eligible for SNAP if not meeting a student exemption.

Use of the medical exemption for people impacted by COVID-19 in not intended to replace other ABAWD coding. If an individual is meeting another exemption, use the code appropriate for that exemption. If an individual is meeting the work rule, you will use the appropriate code of M or W.

These changes went into effect 4/1/2020 and apply to benefits to be issued for April. This includes MCRs, initial and re-cert applications for April.  If you have an application from March where the client was not eligible due to ABAWD, please deny the March application on reason ’80-ABAWD without required work history’  and certify for 4/1/2020 using he COVID-19 exemption.

Please remember that Work Registration still needs to be addressed prior to ABAWD. If the client meets a work registration exemption, the client should be coded for that exemption. If no exemption is met, the client must ‘agree to register to work’ and be coded ‘R’ for work registration. Then ABAWD will need to be addressed.

Additional examples

Example 1
John applied for SNAP 3/25/2020. He lost his job 3/22/2020 when his employer closed as a result of COVID-19. He says it was a small business and he has not applied for unemployment yet. He is 52 and not sure how soon he’ll be able to find another job. He provided his income verification at the time of interview. You have determined he is not eligible for March benefits but will be eligible for April. While his employment termination is a result of COVID-19, he is exempt from ABAWD due to being age 50+. You will not need to use the medical exemption since he meets an age exemption.
Example 2
Stacy completed an application 4/1/2020. She received K months in September, October, and November 2019. She last received SNAP for the month of November 2019. She started a job at Sonic on 2/25/2020. She provides check stubs verifying that her hours average 24/wk. She has regained eligibility by working 80 hours in a 30 day period. Since she has regained and is still working 20 or more hours per week, she will be code with an M.
Example 3
Mike received his initial countable K months in July, August, & September 2019. He applied for SNAP on 4/2/2020. He is not currently working and meets no other ABAWD exemption. He would be coded ABAWD exempt reason ‘2-physically/medically unfit/homeless’. He would have a normal 12 month certification with a 6 month MCR. Case notes MUST be made explaining the exemption was given due to the COVID-19 crisis.

If you have any questions please email

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