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DATE: October 3, 2025 SUBJECT: Supplemental Nutrition Assistance Program Provisions of the One Big Beautiful Bill Act of 2025 – ABAWD Waivers - Implementation Memorandum TO: All SNAP State Agencies All Regions On July 4, 2025, President Donald J. Trump signed into law Public Law 119-21, One Big Beautiful Bill Act of 2025 (OBBB). On September 4, 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 with additional information on implementing Section 10102(b) and (c) of the OBBB, which changes criteria for waivers of the Able-Bodied Adults Without Dependents (ABAWD) time limit with special provisions for Alaska and Hawaii. Please note, FNS is reviewing SNAP regulations pertaining to ABAWD waiver requirements following enactment of the OBBB to determine changes necessary to comply with the changes. Changes to ABAWD Time Limit Waiver Criteria The OBBB amends the criteria under which the Secretary may approve a State agency request to waive the ABAWD time limit per section 6(o)(4) of the Food and Nutrition Act of 2008 (the Act). The statute, as amended, requires that areas have unemployment rates of over 10 percent to qualify for ABAWD time limit waivers, known as ABAWD waivers. The OBBB removed the criterion allowing for approval of waivers for areas where States identify that there is a lack of sufficient jobs and establishes new ABAWD provisions for Alaska and Hawaii, as detailed below. The statutory changes to ABAWD waiver criteria, as well as the provisions for Alaska and Hawaii, were effective upon enactment. FNS will also determine the need for any associated rulemaking. Requesting New Waivers of the ABAWD Time Limit FNS will review all future waiver requests under the statute, as amended by the OBBB. State agencies requesting waivers of the ABAWD time limit must provide data that the requested areas have unemployment rates over 10 percent. Food and Nutrition Service, Braddock Metro Center, 1320 Braddock Place, Alexandria, VA 22314 USDA is an equal opportunity provider, employer, and lender. Guidance documents lack the force and effect of law, unless expressly authorized by statute or incorporated into a contract. USDA may not cite, use, or rely on any guidance that is not available through their guidance portal, except to establish historical facts.