If a person is not meeting the ABAWD work rule or requirement, working a minimum of 20 hours per week and is not otherwise exempt for the ABAWD policy, then they are considered to be “Countable ABAWD’s”. They are limited to receiving 3 full months of benefits. If the initial cert month is not a full certification month, it is not considered to their 3-month limit. The prorated benefit is not counted against an ABAWD’s initial three months of eligibility. The individual receives the prorated month and then the three full months of benefits. The worker codes countable months in the FACS ABAWD tab as ‘K’ months. The computer changes the code to a ‘P’ when the month is a partial month.

Refer to article SNAP: ABAWD Coding

If a person uses their 3 Countable Months and loses their SNAP eligibility, they can regain eligibility if they work at least 80 hours in any 30-day period following the expiration of the SNAP benefits.

Frequently Asked Questions are listed below by section:

Not Meeting ABAWD Work Requirement / Countable ABAWD’s / ‘K’ Months

Q1. At what point does the 36-month period begin?

ABAWD 36-month period begins with the FIRST month of certification, regardless if it is a full month or a partial month. For example, a customer was certified with his countable ABAWD months starting 06/15/2023 for 4 months. June is a P month, and July is a K month. It is later found out that the customer worked 80 hours in August 2023 and September 2023. We change August and September from K to W. Regardless of when the customer receives the other K months, the 36-month clock starts with June 2023, which is the first month of the certification for countable K months.

Q2. A customer who is an ABAWD and has been certified for the first 3 free “K” months of SNAP, reports in the second month of certification that he is now employed full time and reports his income. If he remains otherwise eligible, how many free months does he have left?

If customer is either meeting the work rule (working at least 20 hours per week averaged 80 per month) or meeting the exemption #9 (working at least 30 hours per week) for the second and third months, he still has 2 free “K” months left. These months do not have to be used consecutively. The 2nd and 3rd month coding needs to be adjusted to reflect the appropriate code, too.

Q3. A household member, age 18, graduates from high school in May. When would we begin counting the first 3 free “K” months for ABAWD compliance?

When an ABAWD task in Current^TM alerting that the 3^rd K month has been received, and no verification has been provided by the household, an ADM-92 requesting verification of ABAWD eligibility is no longer required. Depending on the deadlines, actions can be taken immediately. Our customers are still required to receive the correct closure/removal notice and to receive these notices timely.

Worker received the ABAWD task before the negative action deadline. As the example is for a single household member case, the case is closed effective next month for reason ABAWD WITHOUT REQUIRED WORK HISTORY (80).

Q4. A customer moved here from another state. We verified the customer received benefits from the other state. Do we check the number of countable ABAWD months a customer has received in the other state to see if he/she has used the first three free “K” months?

It depends on when the clock starts in Oklahoma. If the customer has never received benefits in Oklahoma, then we would only check the month of application. If the customer received benefits in Oklahoma and their 36-month clock has already started, we would check from when the clock started.

Q5. A customer was employed meeting the work rule (working 20 hours per week averaged to 80 a month) and lost his job in the first week of July.  He was certified for SNAP beginning 07/01/2023 with terminated income, and worker used ‘unfinished issuance’ to issue August 2023 benefits with zero income.  What months are countable “K” ABAWD months for this customer?

Because the customer did not meet the work rule of working at least 20 hours per week averaged to 80 per month in July due to losing his job, the first free countable ‘K’ month is July, with August and September coded as the 2^nd and 3^rd free ‘K’ months.  The customer is eligible for a three month certification.

Q6. My customer’s 21-year-old son received his first 3 free “K” months in July, August and September 2023. The customer reapplied for 11/01/2023 on 09/23/2023. The customer’s son is not working and does not meet an exemption. How should he be coded on the case for the certification renewal?

Since the son is not currently working and does not meet any exemptions, he is now ineligible for SNAP benefits, effective 11/01/2023. He is ineligible for SNAP due to not meeting the work requirements and will need to be coded “S/O” (income resources considered for SNAP—individual not included). If shelter is paid by or billed to him, then you would need to prorate his share of the shelter costs. If the shelter is not paid by or billed to him, then you would not need to prorate.

Q7. Applicant was exempt at certification and lost the exemption in the second month. Do we start considering countable months the next effective month or at MCR?

No. When the customer is meeting an ABAWD exemption, they are exempt through the entire certification period. They would be screened for ABAWD exemptions again at the certification renewal.

Q8. Benefit worker receives ABAWD task outside of the renewal time for Michael’s SNAP case. He has already received three free K months. Worker cannot reach the client to inquire about exemption status.

When an ABAWD task in Current^TM alerting that the 3^rd K month has been received, and no verification has been provided by the household, an ADM-92 requesting verification of ABAWD eligibility is no longer required. Depending on the deadlines, actions can be taken immediately. Our customers are still required to receive the correct closure/removal notice and to receive these notices timely.
Worker received the ABAWD task before the negative action deadline. As the example is for a single household member case, the case is closed effective next month for reason ABAWD WITHOUT REQUIRED WORK HISTORY (80).

Regaining Eligibility / ‘Y’ Months

Q9. An ABAWD client received her first 3 free “K” months of benefits. Several months later she reapplies and has worked 80 hours in a 30-day period while not receiving benefits, but is no longer employed. Has she regained eligibility for the 3 additional consecutive months?

Yes. The criterion for regaining eligibility is to have worked at least 80 hours in ANY 30-day period following the expiration of SNAP benefits.

Q10. My customer initially applied for SNAP benefits in the month of May. He was coded as “K” (initial ABAWD not meeting the work rule” for June, July, and August. The customer regained eligibility by working 80 hours in the month of September. The customer has continued that employment and is currently working an average of 20 hours per week at the time of his SNAP application. I have certified him, and have coded him “regained eligibility—maintaining 20 hour per week employment” (M).  What happens if the customer loses this job? 

The customer would be eligible for Y months if they have not yet received them. If only one Y month is used, the other 2 Y months are lost if there is a break. Y months have to be consecutive. After the Y months, the case would be closed on reason 80, for not meeting the work rule or an exemption.

Q11. We received an application on October 15^th and recognized that the customer had already used “K” months in the months of June, July and August. The customer was interviewed on October 19^th and showed proof that he had worked 80 hours between September 18^th– October 18^th. He is no longer employed as of October 18^th. He declares he is not ABAWD exempt upon review of the ABAWD exemptions with him in interview. Do I deny the 10/15 app date and give the app date of 18^th?

Yes. The customer can only regain eligibility while not receiving benefits. Deny the 10/15 application with reason “80-ABAWD without required work history.” Certify the benefits beginning, 10/18, the date the customer completed 80 hours of work. Please be sure to case note clearly why you have denied the initial application and had to change the application date.

Q12. What about expedited eligibility and during the interview the client claims that he/she does not meet any of the exemptions; has not worked at least 80 hours in any 30-day period since the receipt of initial K ABAWD months to meet criteria for regained eligibility (Y months)?

The application is denied using reason ABAWD WITHOUT REQUIRED WORK HISTORY (80).

Q13. What about expedited eligibility and if the client claims that he/she regained eligibility AND does not have the verification with them?

The worker should try to make contact with the appropriate person / agency/ etc. via phone during the interview. In other words, do their due diligence in attempting to verify. If they are unsuccessful (no answer, number disconnected, refusal to provide, etc.) the worker may utilize “best available” and complete a “01 EO” certification for 3 consecutive Y months. The worker MUST case note their attempts thoroughly including name and number of contact person, the number of attempts that they made and state that “in the best interest of the client and due to the inability to verify information, worker is using client’s declaration as best information available.”