SNAP FY 2026 Discretionary Exemptions for ABAWDs - Not Adjusted for Carryover

Able-bodied adults without dependents (ABAWDs), referred to as time-limited participants, may only participate in SNAP for 3 months in any 36-month period, unless the individual fulfills certain work requirements or is otherwise exempt from the time limit. State agencies also receive a limited number of discretionary exemptions that they can use to extend eligibility for time-limited participants per section 6(o)(6) of the Food and Nutrition Act of 2008 (the Act). Each discretionary exemption extends eligibility to one time-limited participant for one month.

This memorandum provides estimates of the number of new discretionary exemptions each state agency has earned for FY 2026 (column 2 of the attached table). The number of discretionary exemptions each state agency earns is based on eight percent of the state's estimated number of covered individuals, per section 6(o)(6)(A)(ii)of the Act. State agencies do not earn discretionary exemptions for areas that operated under a waiver of the ABAWD time limit as of July 1, 2025.

Limitations on Carrying Over Unused Discretionary Exemptions

The Fiscal Responsibility Act of 2023 limits state agencies' ability to carry over of discretionary exemptions. Therefore, as of FY 2026 (beginning Oct. 1, 2025), state agencies may only carry over unused exemptions earned for the previous fiscal year (FY 2025).

To help estimate the maximum number of carryover exemptions, the attached table includes the number of new earned exemptions for FY 2025 (column 3).¹ These figures do not account for the number of discretionary exemptions each state agency used during FY 2025. This may help indicate the maximum number of exemptions available for carryover into FY 2026; the actual carryover for FY 2026 will depend on the number of discretionary exemptions the state agency used in FY 2025.

For FY 2026, a state agency may use the discretionary exemptions newly earned for FY 2026, as well as any unused discretionary exemptions earned for FY 2025. For example:

1. If the state agency did not use any discretionary exemptions in FY 2025, it would carry over all discretionary exemptions newly earned in FY 2025. The state agency would lose all other remaining discretionary exemptions earned in prior fiscal years.
2. If the state agency used its entire allotment of discretionary exemptions in FY 2025 (including those newly earned in FY 2025 and carried over from prior fiscal years), then it would have zero discretionary exemptions available for carryover into FY 2026.

State agencies must track their usage of discretionary exemptions on an ongoing basis and document their application in case records prior to monthly Quality Control sample selections. State agencies must report final figures for FY 2025 via the FNS-583 form by Nov. 15, 2025, 45 days after the end of the reporting period. Once required data on discretionary exemptions used in FY 2025 and changes in caseload size are available, FNS will issue updated discretionary exemptions totals for each state agency for FY 2026.

State agencies with questions should contact their respective regional office representatives.

Ronald Ward
Acting Associate Administrator
Supplemental Nutrition Assistance Program
Food and Nutrition Service
U.S. Department of Agriculture

Attachment

State Table