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○ Workforce Innovation & Opportunity Act (WIOA) ○ Trade Adjustment Assistance (TAA) ○ Veteran Programs ● Unpaid Work: When your client works for an individual without the exchange of a wage, salary, goods, or services. An example of unpaid work is an unpaid internship or apprenticeship that is not associated with the EF program.

11/9 Rule. All EF activities count toward the SNAP ABAWD Work Requirement. Supervised Job Search (SJS) may be included as part of those hours, as long as it makes up less than half of the 80 required hours in a month. This is known as the 11/9 Rule.

What to Do When SNAP ABAWD Work Requirement Hours are Incomplete. At times, an ABAWD client may be unable to meet their 80-hour work requirement, whether it is from an extenuating circumstance or the client failed to complete or submit hours to their EF PO worker during the month. EF POs must notify the client and document this in a CBMS case comment. An example of an appropriate CBMS case comment is: “Client was unable to meet their 80-hour SNAP ABAWD Work Requirement for the month of February due to losing access to transportation. Notified the client via email that these hours are incomplete for the month.”

Notice of Action (NOA). NOA is the cutoff date (approximately the 18th of the month) in CBMS to notify a household of a loss or reduction of SNAP benefits due to three countable months. This is important for the EF program because if an ABAWD does not meet the SNAP ABAWD work requirement, they can receive a countable month. After three countable months, the ABAWD may lose SNAP benefits.

Accurate and timely data entry by EF POs is crucial and can prevent an ABAWD from receiving a NOA and a countable month.

Starting April 2026, to the best of their ability, EF POs must enter ABAWD activity participation hours by the 18th of the current month to reduce the chance that an ABAWD will receive a countable month. If hours are entered after the 18th of the month, the EF PO must contact the SNAP eligibility office where the client receives benefits to ensure the ABAWD does not accrue a countable month. A SNAP eligibility technician can reverse a countable month when appropriate.

Why It Is Important to Report Work Requirement Hours. Failure to enter hours in a timely manner can put an ABAWD client at risk of losing their SNAP benefits. If any extenuating circumstances prevent activity hour entry, EF POs must communicate with the appropriate county’s SNAP eligibility team immediately and then document in CBMS case comments. EF POs must document any late data entry or when a client does not report activity hours in a timely manner.

Employment First Activities

Last updated: July 9, 2026

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