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7 CFR 273.7(c)(1)(ii). State agencies must update their notices to ensure individuals aged 55 to 64 are properly notified that they are now subject to the ABAWD time limit. Verification Requirements State agencies must continue to follow verification requirements at 7 CFR 273.2(f) and 273.24(l). Quality Control and Technical Assistance FNS will, as appropriate, hold States harmless for Quality Control (QC) purposes for 120 days from the required implementation date. The 120-day variance exclusion period cannot apply if the State agency does not implement the new provision in accordance with 7 CFR 275.12(d)(2)(vii). State agencies that implement a provision later than the required implementation date, but before the end date of the exclusionary period, will only be allowed a variance exclusion for the time remaining. State agencies that implement after the exclusionary period end date do not get a variance exclusion. A 120-day variance exclusion is permitted for the misapplication of the below OBBB changes, as discussed in this memo: • The revision of the exception for a parent or other household member with responsibility for a dependent child from a child under 18 years old to a child under 14 years old; • The removal of the three temporary exceptions added by the FRA, including homeless individuals, veterans, and individuals aging out of foster care; • The addition of exceptions for Indians, Urban Indians, and California Indians; and • The increase in the age-based exception to subject individuals to the time limit through age 64. None of the above provisions are subject to early implementation rules at 7 CFR 275.12(d)(2)(vii)(A) since the enactment date of all provisions began on July 4, 2025. The exclusionary period end date for all the above provisions is November 1, 2025.