ABAWD Exemptions
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This subject includes information about NA Able Bodied Adult Without Dependents (ABAWD) exemptions.
This subject also includes ABAWD exemption tracking requirements.
This policy is effective for all eligibility determinations completed on or after 08/30/2024. For eligibility determinations completed on or after 08/30/2024 follow the information on the Urgent Bulletin emailed 08/29/2024 until further notice.
Policy
When an NA participant meets an Able Bodied Adult Without Dependents(g) exemption, the participant is exempt from the work requirement. When exempt, the Able Bodied Adult Without Dependents (ABAWD) participant is not limited to a three-month time limit.
The entire month is exempt when an exemption occurs any time during the benefit month.
An ABAWD participant could qualify for more than one ABAWD exemption. The worker uses the ABAWD exemption that exempts the participant for the longest time. For exemptions that require verification, the participant is exempt once the proof is received.
The following participants are exempt from the ABAWD work requirement. FAA applies the exemptions in the following order:
1) Age
Participants are exempt from ABAWD work requirements when they meet one of the following:
●Under 18 years of age
The participant is exempt through the month in which they turn 18.
●Age 55 and over
The participant becomes exempt the month in which they turn 55.
2) Residing with a Minor Child (Under Age 18)
When a participant resides with a minor child, the minor is not required to be eligible for NA benefits but is required to be included in the same budgetary unit. This exemption applies through the month in which the minor turns 18.
3) Mentally or Physically Unfit for Work
Participants who are medically certified as mentally or physically unfit for work are exempt from the ABAWD time limit and work requirements. Unfit for work can include anything that affects the ability to work, maintain employment, or restricts the range of employment opportunities including, and not limited to, any of the following:
●Mental conditions
Learning disability
Emotional challenge
Difficulty handling stressful situations, or being around people
Victim of domestic violence, sexual harassment, sexual assault, or stalking
●Physical condition
Recovering from surgery
Physical limitations due to a disability
Receipt of temporary or permanent disability benefits from a governmental or private source
A participant does not need to have a disability to be unfit for work. Unfitness for work may not always be visible. Unfitness for work may be temporary or permanent.
When the participant claims they are unfit for work, additional verification is not required when the unfitness can be verified through one or more of the following:
●AZTECS interface
●HEAplus hubs
●Worker observation when the unfitness for work is obvious
When the participant claims they are unfit for work, and the unfitness is not obvious, the participant is required to provide verification of unfitness from a medically qualified source(g).
Participants considered temporarily unfit for work are exempt until renewal unless verification is received that specifies an expected end date for the exemption reason.
Participants with a long-term or permanent disability are exempt from the ABAWD work requirements and the ABAWD three-month time limit.
4) Pregnancy Exemption
Participants who are pregnant in any trimester are exempt from ABAWD work requirements.
5) Homeless(g)
6) Veterans
Participants who served in the United States Armed Forces and who were discharged or released, regardless of the conditions of the discharge or release. The United States Armed Forces includes all of the following branches:
●Air Force
●Army
●Coast Guard
●Marine Corps
●National Guard
●Navy
●Space Force
NOTE This includes participants who served in a reserve component of the Armed Forces.
7) Former Foster Care Youth Aged 24 or Under
A participant age 24 or under who was in the custody of foster care(g) when the participant turned age 18, or a higher age when the maximum age for foster care is higher than 18.
8) Exempt from the NA Work Requirements
See NA Work Requirement Exemptions for exemptions that can be used for ABAWD.
9) Geographical Exemption
Participants who reside in a geographically exempt area are exempt from the ABAWD work requirements.
The Geographic Exemption is applied when an ABAWD does not meet any other exemption and is living in an area that is exempt from the ABAWD time limit.
Beginning 10/01/2023, the Geographical Exemption is active for all areas of the state except Maricopa County.
NOTE When an ABAWD participant lives on American Indian Tribal Land in Maricopa County, the participant is geographically exempt.
Procedures
An obvious determination of unfit for work may be made during a face-to-face or telephone interview. When unfitness for work is obvious, documentation must include one or more of the following:
●Details of the interview with the participant that support unfitness for work.
●The reason a participant statement was accepted.
●Observations made during the interview such as cast, sling, wheelchair, or behavioral health issues.
●Why further verification was not requested.
When the participant claims they are unfit for work, and the unfitness is not obvious complete all of the following:
●Advise the participant of verification that is required
●Send the Information Needed (F011) notice requesting the participant to provide verification of unfitness from a medically qualified source(g).
Tracking ABAWD Countable Months
A countable month is any month in which an ABAWD participant receives a full month of NA benefits while not meeting an exemption or the ABAWD work requirement. AZTECS tracks months over a three-year period even while NA benefits have stopped.
Months from other states that have implemented ABAWD time limits are countable when received during Arizona’s current three-year period which started 01/2022.
NOTE All months before 07/2023 are not countable due to the federal suspension of the ABAWD time limits due to the Families First Coronavirus Response Act.
Contact the state agency that provided NA benefits when the budgetary unit includes an ABAWD participant who received NA in another state. The Verification of Out-of-State Benefits (FAA-1475A) form is sent to the state agency to verify any countable ABAWD months in another state. (See Duplicate Participation for state contact information.)
NOTE When an ABAWD participant has received countable months in another state, contact FAA Systems Help Desk to request the months be added to CODF. Do not include months before 07/2023.
Complete all of the following at each interview or reported change to determine whether the participant received three countable months of NA:
●Enter a Y in the TIME LIMIT DISPL FS column on WERE.
●Press ENTER to access CODF. Review CODF to determine the countable months.
●Begin reviewing the month before the NA benefit month to be determined. Review months included in Arizona’s current three-year period, which started on 01/01/2022.
NOTE NA benefits received in Arizona during the statewide ABAWD time limit waiver are not countable toward the three-month limit. The waiver was in effect from 10/01/2022 to 09/30/2023.
AZTECS displays the benefit indicators on CODF depending on the ABAWD Exemption Code keyed in the EXPT RSN field on WERE. CODF summarizes the months of benefits received by each participant as follows:
●X displays when the month is countable toward the three-month limit.
●E displays when the ABAWD participant has received an ABAWD extension month.
●F displays when the ABAWD discretionary exemption is applied.
●O displays when the month is not countable toward the three-month limit due to one of the following:
The participant received prorated benefits
The participant qualified for an exemption
The participant met the ABAWD work requirement
The month was received during the statewide ABAWD time limit waiver
The month was received during the Families First Coronavirus Response Act
Discretionary Exemption Requirements
Federal regulations allocate the number of available discretionary exemptions. FAA uses the discretionary exemption when a participant reaches the ABAWD time limit or when more than three countable months are received.
Arizona implements the ABAWD discretionary exemption in one of the following ways:
●Some ABAWD participants who have received three countable months and meet the ABAWD discretionary exemption requirements can continue receiving NA benefits when eligible. See Discretionary Exemption for ABAWD Participants Aged 50 Through 54 for more information.
●Other ABAWD participants may receive a discretionary exemption for NA benefit months that have exceeded the three countable month limit. These participants are not eligible to continue receiving benefits unless they regain eligibility. See Discretionary Exemption for ABAWD Participants Under Age 50 for more information.
Discretionary Exemption for ABAWD Participants Aged 50 Through 54
To qualify for this exemption, ABAWD participants aged 50 through 54 must meet all of the following requirements:
●Three countable months of NA benefits have been received in Arizona or another state implementing the ABAWD time limit.
●Does not meet an ABAWD or NA work requirement exemption.
●Does not meet an ABAWD work requirement.
●Does not qualify for an extension period. (See Extension Period for more information.)
●Volunteered to be referred to SNAP CAN. (See SNAP CAN Screening and Referral for more information.)
When a participant aged 50 through 54 qualifies for the discretionary exemption, an automated AZTECS procedure assigns the DE Discretionary Exemption Code on WERE, and all of the following apply:
●The ABAWD participant is eligible to continue receiving NA benefits.
●AZTECS updates CODF with the F indicator for each month the participant receives NA benefits after three countable months.
●The discretionary exemption code remains on WERE until the next renewal or reported change.
NOTE Update the ABAWD exemption when necessary.
Discretionary Exemption for ABAWD Participants Under Age 50
FAA also uses the discretionary exemption for a participant under the age of 50 for months in which all of the following apply:
●The participant received more than three countable months of NA benefits.
●Does not meet an ABAWD or NA work requirement exemption.
●Does not meet an ABAWD work requirement.
●Does not qualify for an extension period.
NOTE The Employee Benefits Unit (EBU) updates CODF as needed using an FAA Systems Report. The report includes ABAWD participants who have received more than three countable months and do not meet an exemption or the ABAWD work requirement.
An ABAWD participant who has received three countable months of NA benefits may regain eligibility or be eligible for an extension period. See ABAWD Continued Eligibility for more information.
ABAWD benefit months that are classified as discretionary exemptions are not overpayments.
Verification
System interfaces and the case file(g) must be reviewed before verification is requested. No additional verification is needed when AZTECS interface or HEAplus hubs have verified the information.
The participant has the primary responsibility for providing verification. (See Participant Responsibilities – Providing Verification for additional policy.)
Participant statement verification can be used, unless questionable.
When the exemption is questionable, examples of acceptable verification that can be used include, and are not limited to, any of the following:
●ABAWD Homeless
Proof of homelessness includes, and is not limited to, a written statement or collateral contact completed by a person aware of the participant’s circumstances.
●ABAWD Veteran
Proof of veteran status includes, and is not limited to, any of the following:
●Service department records, such as a DD Form 214.
●Certificate of Release or Discharge from Active Duty, original Certificate of Discharge.
●Report of Transfer or Discharge, Military ID Card indicating service in the armed forces.
●Correspondence or contact from the Department of Veteran Affairs, including a benefit payment or award letter.
●Veteran Affairs ID Card.
●Correspondence or contact from the Department of Veteran Affairs indicating service in the Armed Forces.
●Driver's license indicating veteran status.
●Foster Care Youth
Proof of foster care youth includes, and is not limited to, any of the following:
●Data sharing with other state or federal agencies.
●Collateral contact to other social service workers or agencies, such as the agency administering the foster care program or Medicaid.
●A written statement from or collateral contact completed with a person aware of the participant’s circumstances.
●ABAWD Exemption for Pregnancy or Unfit for Work
Proof of pregnancy or unfitness for work includes, and is not limited to, any of the following:
●Insurance or police reports supporting the claim.
●The Verification of Unfitness for Work for Adults (FAA-1533A) form.
●The Verify Unfit for Work for Adults (A024) notice.
NOTE When a completed A024 notice is in a case file(g), FAA may use the A024 notice as verification when FAA received the completed notice no more than 30 calendar days before an NA application.
●A written statement from, or collateral contact completed with a person aware of the participant’s circumstances.
●A written statement or collateral contact completed by a medically qualified source(g) . The statement is required to include all of the following:
The condition, circumstance, illness or disability that impedes the participant’s ability to participate in employment or work.
The projected duration of the condition, circumstance, illness or disability.
When the duration for the condition, circumstance, illness, or disability cannot be determined at the present time, it needs to include an indication of re-examination and reevaluation.
●Proof of receipt of temporary or permanent disability benefits from governmental or private sources, including, and not limited to, one of the following:
VA disability benefits
Workers Compensation
SSI (or pending application for SSI)
State-issued temporary or permanent disability benefits
Participation in a Vocational Rehabilitation program
Social Security Disability benefits
Maternity leave or disability leave pay from an employer
AZTECS Keying Procedures
ABAWD Time Limit Tracking on CODF
Before determining an ABAWD exemption, complete all of the following at each interview or reported change:
●Check to ensure that a month and year after 01/2022 is in the TI-Begin date field on CODF for each participant 18 years of age or older.
NOTE An asterisk displays on WERE, next to the participant’s name, when the TI-BEGIN date field is blank on CODF.
●When there is not a date displayed in the TI-BEGIN field on CODF, complete all of the following for each participant, one participant at a time:
Key Y next to a participant on WERE, under the column, FED LIMIT DISPL in the FS field. Then press ENTER to access CODF.
In the TI BEGIN field, key the month and year (MMYYYY) of the first whole month of NA benefits issued on or after 01/01/2022.
NOTE When no date is in the TI-BEGIN field, AZTECS does not allow the authorization of NA benefits. The following message displays on FSAD: *ERROR* INVALID TIME-LIMITED REQUIREMENTS (CHECK WERE/CODF). Once keyed, AZTECS updates the TIME-LTD MONTHS USED field and updates the Xs and Os.
Keying ABAWD Exemptions on WERE
The ABAWD exemptions must be assigned in the following order:
1) Age
Keying an Exemption Reason Code on WERE is not required. AZTECS allows the age exemption based on the participant's identified age keyed on SSDO.
2) Residing with a Minor Child (Under Age 18)
Key CH in the EXPT RSN FS field on WERE.
3) Mentally or Physically Unfit for Work
Key UF in the EXPT RSN FS field on WERE.
AZTECS auto populates the UF Exemption Reason Code in the EXPT RSN FS field on WERE and the PAR/EXEM field on WORW when the AZTECS screens include one or more of the following:
●Y in the DS/FS field on SSDO
●SI or SS DS income is keyed on UNIN
When verification of the unfit for work is requested for regular and expedited applications, do not key the UF Exemption Reason Code until verification is received. Leave the field as auto populated by AZTECS.
4) Pregnant
Key PG in the EXPT RSN FS field on WERE.
5) Homeless
Key LO in the EXPT RSN FS field on WERE.
AZTECS auto populates the LO Exemption Reason Code in the EXPT RSN FS field on WERE when a Y is keyed on the HOMELESS field on INDA.
6) Veteran
Key VA in the EXPT RSN FS field on WERE.
Key FC in the EXPT RSN FS field on WERE.
8) Exempt from NA Work Requirements
See NA Work Requirement Exemptions for keying of the exemptions which can be used for ABAWD.
9) Geographical Exemption
Key GE in the EXPT RSN FS field on WERE for an ABAWD participant who lives outside of Maricopa County or on American Indian Tribal Land inside Arizona.
NOTE Use the Geographical Exemption when an ABAWD participant does not meet any other ABAWD exemption during the ABAWD time limit waiver.
10) Discretionary Exemption
When the participant qualifies for the discretionary exemption AZTECS auto populates WERE.
Key DE in the EXPT RSN FS field on WERE, when needed.
NOTE Ensure an ABAWD participant meets all the eligibility requirements for the discretionary exemption. (See Discretionary Exemption Requirements.)
Referring an ABAWD to the Supplemental Nutrition Assistance Program Career Advancement Network (SNAP CAN) Program
An ABAWD participant who is exempt or meets the ABAWD work requirements can still participate in the SNAP CAN program.
Determine whether the ABAWD is appropriate to refer to SNAP CAN. (See SNAP CAN for more information.)
When appropriate, key the Y indicator in the REF field on WORW.
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Legal Authorities
7 CFR 273.24(b)(1)
7 CFR 273.24(b)(2)
7 CFR 273.24(b)(3)
7 CFR 273.24(c)
7 CFR 273.24(g)
FNS Waiver
last revised 10/01/2024