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Page 2 of 2 Attachment Questions Regarding Sections 10102 and 10103 of H.R. 1, the One Big Beautiful Bill Act of 2025 (OBBB) 1. What is the required implementation date for OBBB provisions in Sections 10102 and 10103 regarding the able-bodied adults without dependents (ABAWDs) and the treatment of energy assistance payments? Is the required date the enactment of OBBB (July 4, 2025) or the date the State can implement the provisions and notify staff? The required implementation date is the enactment of OBBB, July 4, 2025. 2. When does the variance exclusion period apply? The variance exclusion period ended November 1, 2025, which is 120 days from July 4, 2025. 3. If a State implemented Sections 10102 and 10103, including informing staff of the policy change, after August 29, 2025, but before November 1, 2025, on what date would the hold harmless variance exclusion period begin? Regardless of the implementation date chosen by the State, the variance exclusion period for implementing ABAWD exemption changes in Section 10102 and all provisions in Section 10103 of the OBBB ended November 1, 2025. 4. Can FNS extend the 120-day variance exclusion period? No, the law limits the variance exclusion period to 120 days. Per Section 16(c)(3)(A) of the Food and Nutrition Act of 2008, as amended, and 7 CFR 275.12(d)(2)(vii), certification errors resulting from the application of a new change in Federal law that occurs during the first 120 days from the required implementation date is excluded from the Quality Control (QC) error analysis. The OBBB did not address QC variance exclusions, therefore existing SNAP statutory and regulatory requirements apply. 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.