3 Recommendations on Implementing ABAWD Requirements

Since ABAWD requirements are top of mind for many SNAP agencies across the country, we reached out to administrators in the state of Delaware to understand three best practices they have employed to promote compliance while supporting ABAWD clients through the enrollment process. Delaware has never had an ABAWD waiver, and therefore has extensive experience with implementing the ABAWD requirements.

1. Work with a SNAP Employment & Training (E&T) vendor.
   
   “Our E&T vendor, Career Team, tracks all the information for reporting requirements such as your normal 583. EDSI is another vendor that can help minimize the burden,” said Teresa Gallagher, Delaware SNAP Administrator. “If states have E&T vendors one thing they could do is communicate information with the state to minimize reporting requirements for the client.” In Delaware, as soon as a client participates in their training program Career Team staff notify Delaware Health and Social Services and an alert is put on a client’s case to stop the clock on the 3-month requirement.
   
   Delaware is a pledge state, which means that any at-risk ABAWD clients that participate in the SNAP E&T program can maintain their SNAP benefits. Delaware mails a letter with the E&T vendor contact information and the WIOA Delaware Jobs and Job link.

2. Work with the FNS contact in your region.
   
   Gallagher shared, “They have put out many publications and are the ones who can really help.” The USDA provides a contact list here to find the contact in your region.

3. Review all the policy requirements for ABAWD.
   
   “Review all the policy requirements for ABAWD to make sure you are fully complying.” While these reporting requirements can be complex, the USDA also has policy memos, as well as additional resources available on their website.

In addition to the information on the USDA website, here are three resources from think tanks that outline the impact of these policy changes -

• Mathematica has published extensively on this topic. They have provided a brief and visualization about the impact of both changes, respectively.
• The Urban Institute released a policy brief this month on the estimated effects of these changes.
• The Hamilton Project at Brookings issued a report on the differences between the original policy and the proposed rule.