CalFresh Update 2026-03: ABAWD Time Limit Implementation

CalFresh Handbook 

Date References Clerical Implementation
03/20/26 ACL 25-93, ACL 19-93 N/A 06/01/26

Background

On July 4, 2025, the House of Representatives 1 (H.R.1) was enacted into law, and it made changes to the definition of an ABAWD, including increased age requirements and narrowing exemption criteria.

Changes

Effective June 1, 2026, ABAWDs are defined as CalFresh recipients aged 18 through 64 who are able-bodied, do not have dependents, and do not meet any exemption criteria.

New Exemption

A new ABAWD Time Limit Exemption has been added for individuals who meet the definition of Indian, Urban Indian, or California Indian as defined under the Indian Health Care Improvement Act (IHCIA), also referred to as Native Americans, Alaska Natives, and Tribal Members.

Eliminated Exemptions

H.R.1 removes the temporary exemptions added by the Fiscal Responsibility Act (FRA) of 2023 for the following populations:

  • Veterans;
  • Individuals experiencing homelessness; and
  • Youth under age 25 who were in foster care on their 18th birthday.

Modified Exemption

The exemption criteria for individuals who were either the parent of a child under the age of 18 or those who reside with a household member under the age of 18, has been modified under H.R. 1 to limit the dependent child exemption to individuals who are either the parent of, or otherwise responsible for the care of, a dependent child under the age of 14. 

Individuals aged 60 or older

Individuals aged 60 through 64 who are exempt from work registration solely due to age, are still subject to the ABAWD time limit, unless they qualify for another work registration exemption or an ABAWD exemption. If an individual meets the criteria for an ABAWD time limit exemption or a work registration exemption other than age, then the individual is exempt from the ABAWD time limit.

Exemption Screening

A full screening must be completed to ensure that all available exemptions are reviewed and correctly entered into CalSAWS. An exemption from work registration or from the ABAWD time limit must be identified before any countable month can be applied. 

When an ABAWD qualified for more than one exemption, all applicable exemptions must be entered into CalSAWS and documented in the Journal Detail page.

Intake Applications

Effective June 1, 2026, SSBSs must begin to review new applications in CalSAWS using the updated policy. All applicants certified on or after this date must complete an H.R. 1 compliant exemption screening at initial certification. As previously noted, this screening must occur before imposing the ABAWD time limit or assigning any countable month. Individuals who are determined eligible prior to June 1, 2026, will not be subject to the ABAWD time limit until they complete an H.R. 1 compliant screening at recertification.

Reminder: A partial month of benefits does not count toward the 3 months in a 36-month limit. 

Continuing

Starting June 1, 2026, SSBSs must begin to review continuing cases in CalSAWS using the updated policy under H.R. 1. All CalFresh households must complete an H.R. 1 compliant exemption screening at their next recertification and every recertification thereafter. This requirement applies to all households with recertifications due in June 2026 and beyond. A countable month must not be assigned until the screening is completed, and only if the individual is neither exempt nor meeting ABAWD work requirements. Because screenings completed before June 1, 2026, do not reflect the updated H.R. 1 exemption criteria, counties must rescreen all continuing households with recertifications due on or after that date.  

Mid Period

During the certification period, when an individual loses an existing exemption due to a change in circumstances, no countable months may be applied until the individual is re‑screened to determine whether another exemption applies.

After an H.R. 1 compliant exemption screening is completed at recertification, mid‑period reporting rules for ABAWDs subject to the time limit apply. A re‑screening will occur at the household’s next scheduled recertification. 

When a change in circumstances results in newly qualifying for an exemption, the exemption must be applied within 10 days of receiving the information, provided it is not questionable. Once a new exemption is established, no countable month may be assigned. If the information appears questionable, verification must be requested, and the household must be given 10 days to provide.

Individuals subject to the time limit must report mid‑period when:

  • household gross monthly income exceeds the Income Reporting Threshold (IRT), or
  • work hours fall below 20 hours per week or 80 hours per month, unless living in a waived area.

After June 1, 2026, individuals who have completed an H.R. 1 compliant exemption screening and report reduced work hours must be evaluated for good cause or another exemption before a countable month is applied. No additional exemption screening is required during the certification period.

Individuals who have not yet completed an H.R. 1 compliant exemption screening are only required to report mid‑period when income exceeds the IRT. They are not required to report reduced work hours because they cannot be subject to the ABAWD time limit until the H.R. 1 screening occurs. Once screened at recertification and determined not exempt, the individual becomes subject to the time limit and the related work and mid‑period reporting requirements.

Elderly Simplified Application Project (ESAP)

Households certified under ESAP receive a 36‑month certification period, which cannot be shortened once assigned. ESAP households with individuals ages 60–64 cannot be subject to ABAWD rules until they have been screened using the updated H.R. 1 exemption criteria. Exemption screening is required at both initial certification and recertification.

Screening Requirements at Recertification for ESAP Participants Ages 60–64

  1. Screen for work registration exemptions first.
    1. If the individual qualifies for any work registration exemption other than age, they are not considered an ABAWD, and no further ABAWD screening is needed.
  2. If no work registration exemption applies, screen for ABAWD exemptions.
    1. Individuals who meet an ABAWD exemption are not subject to the time limit.
    2. Individuals who do not meet any exemption are subject to the time limit.


Recertification interviews for ESAP households are normally waived. However, contact must be attempted to complete the required screening.

  • When screening can be completed through contact, no interview is required solely for this purpose.
  • When contact cannot be made, all attempts must be documented, and an interview must be required before taking any negative action, including assigning countable months.
  • Failure to complete the required interview results in a denied recertification for the missed interview.

Important Reminders

  • An individual cannot be subject to the ABAWD time limit until they have been screened for exemptions and informed of the ABAWD work rules.
  • Individuals who have not been informed of the work rules are not required to report a drop in work hours.
  • After screening, an oral explanation of the work rules must be provided along with the CalFresh Notice of Work Rules (CF 886).
  • ESAP households with ABAWD or non‑ABAWD members ages 60–64 who otherwise meet ESAP eligibility criteria must continue to receive a 36‑month certification period.

Revised Topics

The following topics have been revised to reflect the updated policy:

Documentation

The case record must include enough detail to support the benefit determination. Documentation should be thorough enough that a reviewer with no prior knowledge of the case can clearly understand how the benefit allotment was calculated and verify its accuracy.

Data Systems

System Change Request (SCR) CA‑294575, included in CalSAWS Release 26.5, updates the ABAWD pages in CalSAWS to align with the new policy. The revised pages are reflected in the internal  ABAWD Guide.

 

Department of Employment & Benefits Services

Contact Person(s): Ana Guitron, SSA BPIS