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All County Letter No. 25-93 Page Two 7 CFR 271.2; 7 CFR 273.24(l); USDA FNS SNAP MEMO – USE OF INFORMATION RECEIVED FROM OTHER PUBLIC ASSISTANCE PROGRAMS; 7 CFR 273.24(k); 7 CFR 273.24(k)(1)(i); 7 CFR 273.24(k)(1)(ii); ALL COUNTY INFORMATION NOTICE (ACIN) NO. I-88-16; 7 CFR 273.24(b) (2); ACL No. 23-30; 7 USC 2015(o)(3); ACL NO. 21-101; ACL NO. 21-101E The purpose of this All County Letter (ACL) is to provide County Welfare Departments (CWDs) with guidance on significant changes to policy related to the CalFresh time limit for Able-Bodied Adults Without Dependents (ABAWD) set forth in House of Representatives 1, an Act to provide for reconciliation pursuant to title II of H. Con. Res. 14. (HR1) (Public Law 119-21), signed into law on July 4, 2025. Due to the complexity of these policy changes and other factors beyond CDSS’s control, the guidance provided via this letter is effective June 1, 2026. This is the earliest possible implementation date that reflects the time required to design and implement the necessary automation changes within the California Statewide Automated Welfare System (CalSAWS) and to train county staff to ensure consistent and accurate application of the guidance statewide. Counties must not attempt to implement HR 1 related policy changes through manual processes or system workarounds. Relying on manual processes at this scale would create a high risk of inconsistent data entry, incorrect case actions, and data tracking gaps the system would not be able to reconcile. These errors could lead to systemic and long-term inaccurate eligibility outcomes and disruptions in benefits. That said, until the required CalSAWS automation changes are implemented, counties must continue to enter information to assist with future exemption screening using current system functionality. BACKGROUND Under Title 7 of the United States Code Section 2015(o)(2) and Title 7 Code of Federal Regulations (CFR) 273.24, the receipt of Supplemental Nutrition Assistance Program (SNAP) benefits, known as CalFresh in California, is limited to three full months in a 36- month period for people that meet the definition of an ABAWD. This is commonly referred to as the “ABAWD time limit.” On July 4, 2025, President Trump signed HR1 into law, which includes significant changes to CalFresh. Specifically, HR1 makes changes to the definition of an ABAWD, including increased age requirements, and narrows exemption criteria. Additionally, HR1 limits eligibility for state and county waivers of the time limit. A forthcoming ACL will provide more information on federal changes to the criteria for requesting a waiver of the time limit. Changes to CalFresh time limit policy will result in more people subject to