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All County Letter No. 25-93 Page Three the time limit and at risk of losing CalFresh eligibility, unless they are determined exempt or meet the work requirements. For additional information regarding HR1 and its impact to CalFresh, reference ACL 25- 50 and ACL 25-50E issued July 14, 2025, and August 26, 2025, respectively. OVERVIEW OF CALFRESH TIME LIMIT POLICY For CalFresh recipients deemed to be an ABAWD, eligibility for CalFresh is limited to three full countable months of benefits in a fixed 36-month period unless the individual: • Is exempt from the ABAWD time limit; • Satisfies the ABAWD work requirement; • Lives in a county or area with a waiver of the ABAWD time limit; • Qualifies for an additional three consecutive month period of eligibility; or • Receives a discretionary exemption. If an individual is exempt, they are not subject to the ABAWD time limit. If an individual is not exempt, they are subject to the ABAWD time limit and must work or participate in a qualifying work activity in order to receive benefits beyond the three countable months granted within a fixed 36-month period. HR1 does not change the general parameters of the time limit rules but significantly changes who is subject to the time limit and who qualifies for an exemption. NEW ABAWD TIME LIMIT AGE REQUIREMENTS Under prior federal law, ABAWDs were defined as CalFresh recipients aged 18 through 49 who are able‑bodied, do not have dependents, and do not meet any exemption criteria. As announced in ACL No. 23-80, issued on September 21, 2023, the Fiscal Responsibility Act of 2023 (FRA) gradually increased the upper age limit of those subject to the time limit from 49 to 54, effective October 1, 2024. HR1 changes the definition of an ABAWD to include individuals between the ages of 18 through 64, unless exempt. Prior to HR1, the definition of an ABAWD included individuals between the ages of 18 through 54. Per the USDA FNS SNAP Provisions of the One Big Beautiful Bill Act of 2025 ABAWD Exceptions Implementation Memorandum released October 3, 2025, HR1 does not change general SNAP work requirements, also known as work registration. Individuals aged 60 or older remain exempt from work registration. However, due to amendments at 7 USC 2015(o)(3) that raise the ABAWD age threshold to 64, individuals aged 60 through 64 who are exempt from work registration solely due to age, are still subject to