SNAP FY 2025 Allocations of Discretionary Exemptions for Able-Bodied Adults Without Dependents

Section 6(o) of the Food and Nutrition Act of 2008 (the Act) limits the time able-bodied adults without dependents (ABAWDs) may participate in the Supplemental Nutrition Assistance Program (SNAP) to 3 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 each state a number of monthly discretionary exemptions from the ABAWD time limit for each fiscal year (FY) based on eight 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 2025, as shown in the following table. This includes adjustments in the number of exemptions for states with caseloads changes of more than 10 percent, per section 6(o)(6)(F) of the Act.

Please note, the totals do not account for exemption usage in FY 2025 (state agencies must report those figures in final on the FNS-583, due 45-days after the end of the FY). While state agencies have great flexibility in applying discretionary exemptions, they must track and report the number of discretionary exemptions on a quarterly basis to their respective regional office via the FNS-583 form. In addition, state agencies must properly document discretionary exemptions in the case file prior to monthly quality control sample selections.

As a reminder, the Fiscal Responsibility Act of 2023 limits the carryover of discretionary exemptions. Starting in FY 2026, states' carryover will be limited to unused exemptions earned in the previous fiscal year.

State agencies with questions should contact their regional office representatives.

Sasha Gersten-Paal
Director
Program Development Division
Supplemental Nutrition Assistance Program