Satisfying the ABAWD Work Requirement

ABAWDs who do not qualify for an exemption or live in a waived area are subject to the time limit and must satisfy the work requirement to maintain CalFresh eligibility for more than three months within the 36-month period. There are multiple ways an ABAWD can satisfy the work requirement. Options include, but are not limited to:

Employment

Employment for at least 80 hours per month (20 hours per week, averaged monthly) satisfies the work requirement. 20 hours per week averaged monthly must total at least 80 hours per month. Allowable employment includes paid employment, self-employment, and in-kind work (i.e. work in exchange for goods and/or services). Employment may be combined with other allowable work activities described in this section to satisfy the work requirement for an average of 20 hours per week.

Note: Paid holiday, sick, or vacation hours do not count towards satisfying the work requirement. If a client received paid sick time, they may be eligible to receive a good cause determination.

Qualifying Work Activities

Participating at least 80 hours per month (an average of 20 hours per week) in an allowable work activity, or combination of allowable work activities, satisfies the work requirement. An allowable work activity includes one or more of the following:

CalFresh E&T

E&T components that satisfy the work requirement are referred to as qualifying activities. E&T components that do not satisfy the work requirement are referred to as non-qualifying activities. Qualifying E&T activities consist of workfare, work experience, self-initiated workfare, education, and vocational training. Except as specified below, non-qualifying E&T activities consist of stand-alone job club and job search components.

Hours spent in job search activities (including orientation, developing an employment plan, getting training and access to computers in resource room, basic skills testing, interest surveys) that are offered in combination with another E&T component are counted towards the ABAWD work requirement, provided time in job search constitutes less than half of the combined total (i.e. up to 9 hours per week, averaged monthly). An exception is E&T stand-alone job search activities of 20 hours per week, delivered through WIOA, which satisfies the 20-hour ABAWD work requirement.

CalFresh regulations allow the county to establish a job search period of up to 30 days following initial certification prior to making a workfare assignment. Since this job search activity is considered part of the workfare assignment, the hours can be used to meet the ABAWD work requirement.

Various E&T components may be combined to reach an average of 20 hour per week minimum along with any hours worked in paid employment or other qualifying work activities. For example, an individual could satisfy the work requirement by working 15 hours per week in paid employment and participating in a qualifying E&T activity five hours per week.

Workforce Innovation and Opportunity Act (WIOA)

WIOA programs (work2future or NOVA) include job search, occupational skills training, on-the-job training, job readiness training, and adult education and literacy activities.

Program under Section 236 of the Trade Act of 1974

The Trade Act applies to workers identified by the EDD as adversely affected by the U.S. trade agreements, e.g., the North American Free Trade Act. The Trade Act provides training services to adversely affected workers through participation in programs that are subject to approval by the Secretary of the U.S. Department of Labor. This program is administered by EDD and includes job search, job club, on-the-job training, WIOA training, or a program of remedial education.

Community Service or Volunteer Work

ABAWDs may volunteer with religious or community organizations to satisfy the ABAWD work requirement. The individual must complete 80 hours per month of community service or volunteer work and/or combine community service or volunteer work hours with another qualifying work activity to satisfy the work requirement. 

Note: Court-ordered community service hours can be used to satisfy the work requirement.

In order to verify community service or volunteer work, the ABAWD individual must complete a time-sheet which indicates the number of community service or volunteer hours completed. The form must be signed by an authorized representative of the organization for whom the ABAWD worked. If the ABAWD is unable to secure such a form, the county may also accept the verbal statement of an authorized representative of the organization for whom the ABAWD worked.

Important: Verification of community service hours follows the same process as verification of other types of work hours for ABAWDs. ABAWD individuals must provide verification of work hours at the initial application, recertification, at SAR 7 if their hours drop below 80 hours per month, and when regaining eligibility. If an ABAWD is using Community Service/Volunteer hours to satisfy
the work requirement, they would provide verification at these times. They may also choose to get the verification form completed as often as they wish to keep for their personal records, but are not required to submit to the county more frequently than as  described above.

Workfare

The work requirement may be satisfied through participation in various types of workfare. These may include CalFresh E&T workfare, self-initiated E&T workfare, E&T work experience components, as well as non-E&T workfare activities administered or overseen by the county. Non-E&T workfare programs include optional workfare, volunteer workfare, and comparable workfare. Comparable workfare programs include general assistance (GA) workfare components that are not part of CalFresh E&T.

Unpaid or volunteer work performed at a public or private non-profit institution as workfare or comparable workfare.

The requirement to work an average of 20 hours per week (80 hours per month) to satisfy the ABAWD work requirement does not apply to workfare. For any workfare option, the number of required hours is determined by dividing the household’s CalFresh allotment by the higher of the state, city, or county minimum wage. When determining workfare hours, the county may use the highest minimum wage associated with the individual’s residence address. Additionally, workfare cannot be combined with any other program to satisfy the average of 20 hours per week work requirement.

Note: In order for a program to be considered a workfare site, there must be a MOU or similar agreement between the county and the community partner or organization. This is because the workfare site must commit to tracking/reporting client attendance. The county must determine whether or not the client completed the required number of hours (based on CalFresh allotment divided by minimum wage) and can take action on the case accordingly. This is unique in comparison to other qualifying work activities where the client reports to the county whether or not they dropped below 80 hrs/month (20 hrs/week on average).

Community service or volunteer hours performed at any other non-workfare site can be used to satisfy the work requirement, but will be calculated based on the 80 hours per month requirement and require the client to report if not meeting the requirement.

 

ExampleExample

Paul is an ABAWD subject to the time limit. He is assigned to a workfare program through his county’s CalFresh E&T program. Paul’s monthly CalFresh allotment is $150. The current minimum wage in the county is $13.50 per hour. The county calculates Paul’s required number of workfare hours by dividing his CalFresh allotment of $150 by the county minimum wage of $13.50. The total number of required hours is equal to 11 hours per month ($150 CalFresh benefit ÷ $13.50/hour minimum wage = 11.11).

 

Note: When calculating workfare hours, the county must round down to the nearest hour.

As part of E&T workfare, counties may establish a job search period of up to 30 days prior to assigning an ABAWD to a workfare site. Participation in the 30-day job search activity is considered part of workfare and satisfies the ABAWD work requirement for that initial month.

ABAWDs placed in workfare or work experience may volunteer to participate for additional hours beyond those determined to be required using the minimum wage calculation, but they are not required to do so in order to maintain benefits.

Important: The number of workfare hours required to satisfy the work requirement applies to the entire CalFresh household.

If some of the ABAWD in the same household are exempt, the remaining ABAWDs who are not exempt are responsible for the total workfare hours that required for the entire household.

If more than one member of a CalFresh household participates in workfare, each participant shall participate for a portion of the number of workfare hours required for that household.

ABAWDs subject to the time limit who are members of the same household may split the required workfare hours in any combination or a single ABAWD subject to the time limit may complete the total required hours on behalf of the household. Regardless of the combination, by the end of the month, the household must complete the total number of required workfare hours.

Example 1Example 1 

Glen and Maggie are both ABAWDs subject to the time limit. They volunteer to participate in a workfare program through the county CalFresh E&T program. Glen and Maggie’s monthly CalFresh allotment is $180. The current minimum wage in the county is $13.50 per hour. The county calculates the household’s required number of workfare hours by dividing the household CalFresh allotment of $180 by the county minimum wage of $13.50. The total number of required workfare hours is equal to 13 hours per month ($180 CalFresh benefit ÷ $13.50/hour minimum wage = 13.3 rounded down to 13 hours of workfare per month). Glen and Maggie share the
responsibility of completing these hours. Glen participates in 8 hours of workfare and Maggie participates 5 hours of workfare; both satisfied the ABAWD work requirement for the month.

Example 2Example 2

A CalFresh household consists of an ABAWD couple. Their monthly allotment is $352 and the highest minimum wage is $13.50. The husband meets an exemption (e.g., disabled), but the wife is subject to the time limit. If the wife chooses to participate in workfare, the required workfare hours for the wife is 26 ($352/$13.50). 

Verification of Work Hours

ABAWDs who are subject to the time limit must provide verification of work hours at initial application, recertification, SAR 7 and when regaining eligibility. They must report to the county mid-period when their work hours drops below 20 hours per week on averaged monthly or 80 hours per month within 10 days of the date the drop in work hours became known to the household.

Related Topics

ABAWD Time Limit