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Food and Nutrition Service, Braddock Metro Center, 1320 Braddock Place, Alexandria, VA 22314 USDA is an equal opportunity provider, employer, and lender. DATE: October 3, 2025 SUBJECT: Supplemental Nutrition Assistance Program (SNAP) Provisions of the One Big Beautiful Bill Act of 2025 - ABAWD Exceptions - Implementation Memorandum TO:

All SNAP State Agencies All Regions On July 4, 2025, President Donald J. Trump signed into law the historic One Big Beautiful Bill Act of 2025 (OBBB). On September 5, 2025, the Food and Nutrition Service (FNS) published a memorandum describing the SNAP provisions of the OBBB, Supplemental Nutrition Assistance Program Provisions of the One Big Beautiful Bill Act of 2025 – Information Memorandum. This memorandum provides State agencies additional information on implementing Section 10102(a) of the OBBB, which changes exceptions from the Able-Bodied Adults Without Dependents (ABAWD) time limit. Modification of ABAWD Time Limit Exceptions The OBBB modifies the ABAWD time limit exceptions at Section 6(o)(3) of the Food and Nutrition Act of 2008 (the Act). Throughout this document, “modified exception criteria” refers to the ABAWD exception criteria, as amended by the OBBB. Increase of the Upper Age Limit Prior to passage of OBBB, individuals aged 18 to 54 were subject to the ABAWD time limit.1 The OBBB increases the age of those subject to the time limit to age 64. Therefore, individuals aged 18 to 64 are now subject to the time limit, unless they meet another exception. The OBBB does not change the upper age limit for the general work requirements at Section 6(d)(3) of the Act. Individuals aged 60 or older remain exempt from the general work requirements, including mandatory participation in SNAP Employment and Training (E&T). The OBBB also does not impact the definition of “elderly” in Section 3(j) of the Act. Individuals age 60 or older continue to be defined as “elderly” for SNAP purposes. Therefore, State agencies must continue to apply other policies for elderly individuals to those aged 60 or

1 The Fiscal Responsibility Act of 2023 gradually increased the age of those subject to the ABAWD time limit from 49 to 54 through fiscal year 2030.