Contract No.: 53-3198-7-025

MPR Reference No.: 8460-800

Imposing a Time Limit on 

Food Stamp Receipt: 

Implementation of the 

Provisions and Effects on 

Food Stamp Program 

Participation 

Volume I 

Final Report

September 4, 2001

John L. Czajka 

Sheena McConnell 

Scott Cody 

Nuria Rodriguez 

Submitted to: 

U.S. Department of Agriculture 

Food and Nutrition Service 

3101 Park Center Drive 

10th Floor 

Alexandria, VA 22302 

Project Officer: 

Carol Olander 

Submitted by: 

Mathematica Policy Research, Inc. 

600 Maryland Ave., S.W., Suite 550 

Washington, DC 20024-2512 

(202) 484-9220 

Project Director: 

John L. Czajka 
iii 

ACKNOWLEDGMENTS 

We would like to thank the many people whose efforts have made this report possible. 

Carol Olander, the project officer at the Food and Nutrition Service (FNS) of the U.S. 

Department of Agriculture, made extremely valuable contributions throughout the study. 

Michael Atwell, Bob Dalrymple, Michael DePiro, and Moira Johnson at FNS also helped greatly 

in the design of the study and interpretation of the findings. This report benefited greatly from 

the comments of FNS staff on two earlier drafts. 

Vivian Gabor and Christopher Botsko of Health Systems Research, Inc. (HSR) worked with 

staff from Mathematica Policy Research, Inc. (MPR) to design the study and provided helpful 

advice and guidance in analyzing the survey data. Susan Williams at HSR summarized the 

challenges faced by the local office managers in providing employment and training services to 

ABAWDs. James Ohls and Anu Rangarajan at MPR provided helpful comments on the content 

of this report. 

This study involved interviews with many managers of the Food Stamp Program in both 

state and local offices. At MPR, Jacquie Anderson, Scott Cody, Michelle Derr, Sidnee Paschal, 

and Paul Werner were tireless interviewers of staff at the state food stamp offices. At HSR, 

Christopher Botsko, Mary Harkins, Christopher Miller, and Susan Pachikara, led by Susan 

Williams conducted the interviews with employment and training managers in both the state and 

local food stamp offices. 

Laura Castner, Daisy Ewell, Lisa Fowler, Christopher Rankin, and Randy Rosso at MPR 

helped in analyzing the Food Stamp Program Quality Control data and Ama Takyi, Ram 

Krishnamoorthi, and Joseph Lucas provided expert research assistance. Daryl Hall and Elizabeth 

Hurley provided editorial assistance, and Alfreda Holmes prepared the manuscript. 

Finally, we would like to thank the many staff at the state and local food stamp agencies 

who responded to our surveys and provided us with data. Without their generosity, the study 

would not have been possible. 

 
 v 

CONTENTS 

Chapter Page 

 ACKNOWLEDGEMENTS ...........................................................................................iii 

 EXECUTIVE SUMMARY.........................................................................................xvii 

I. BACKGROUND AND OVERVIEW OF STUDY ........................................................ 1 

A. THE ABAWD PROVISIONS................................................................................. 2 

1. Definition of an ABAWD ............................................................................... 3 

2. Meeting the Work Requirement...................................................................... 4 

3. Waivers............................................................................................................ 5 

4. 15 Percent Exemption ..................................................................................... 5 

5. Final ABAWD Regulations ............................................................................ 6 

B. BBA PROVISIONS DESIGNED TO INCREASE THE AVAILABILITY 

OF QUALIFYING WORK ACTIVITIES .............................................................. 6 

C. OBJECTIVES OF THE STUDY ............................................................................ 7 

1. To Provide Estimates of the Number and Characteristics of People 

Affected by the ABAWD Provisions, Nationwide and by State..................... 7 

2. To Describe How the ABAWD Provisions Have Been Implemented............ 9 

D. SOURCES OF DATA........................................................................................... 11 

1. Data Sources for Determining the Number and Characteristics of 

ABAWDs ...................................................................................................... 11 

2. Data Sources for Understanding ABAWD Policies and Their 

Implementation.............................................................................................. 16 

E. ORGANIZATION OF THE REPORT ................................................................. 20 

II. ABAWD PARTICIPANTS IN THE FOOD STAMP PROGRAM: NUMBER 

AND CHARACTERISTICS......................................................................................... 23 

A. NATIONAL ESTIMATES OF THE NUMBER OF ABAWD 

PARTICIPANTS................................................................................................... 24 

1. Earlier Estimates ........................................................................................... 24 

2. ABAWD Participants as Defined Under PRWORA..................................... 26 

3. Exclusions from the ABAWD Population .................................................... 28 

4. Additional Participants at Risk of Using Time-limited Benefits .................. 32 
CONTENTS (continued)

Chapter Page 

 vi 

B. STATE ESTIMATES OF THE NUMBER OF ABAWD PARTICIPANTS ....... 35 

C. TRENDS IN PARTICIPATION OVER TIME .................................................... 41 

D. MEETING THE WORK REQUIREMENT ......................................................... 48 

1. Previous Research ......................................................................................... 48 

2. Number Meeting the Work Requirement...................................................... 50 

3. Ways of Meeting the Work Requirement ..................................................... 52 

E. CHARACTERISTICS OF PARTICIPANTS SUBJECT TO THE TIME 

LIMIT.................................................................................................................... 57 

1. ABAWD Participants Versus All Participants 18 to 50................................ 58 

2. Meeting the Work Requirement.................................................................... 62 

F. NUMBER REACHING THE TIME LIMIT......................................................... 68 

G. SUMMARY .......................................................................................................... 78 

III. WHO IS SUBJECT TO THE TIME LIMIT? VARIATION IN STATE POLICIES... 81 

A. STATE POLICIES ON EXEMPTIONS FROM THE TIME LIMIT................... 82 

1. Age at Which Adults Become Exempt ......................................................... 83 

2. Certified as Unfit for Employment................................................................ 83 

3. Exemptions Based on Dependent Children................................................... 90 

B. WAIVERS FOR AREAS WITH HIGH UNEMPLOYMENT AND 

INSUFFICIENT JOBS.......................................................................................... 92 

C. THE 15 PERCENT EXEMPTION ....................................................................... 93 

1. Reasons for Using the 15 Percent Exemption............................................... 94 

2. Eligibility Criteria for the 15 Percent Exemption ......................................... 95 

3. Extent to Which States Use the 15 Percent Exemption ................................ 97 

4. Reasons for Using Fewer Exemptions Than Allotted................................. 101 

D. SUMMARY OF STATE ABAWD POLICIES .................................................. 104 
CONTENTS (continued)

Chapter Page 

 vii 

IV. HELPING ABAWDS MEET THE WORK REQUIREMENT: POLICIES AND 

CHALLENGES........................................................................................................... 109 

A. MEETING THE WORK REQUIREMENT THROUGH WORK...................... 111 

1. State Policy on What Counts as Meeting the Requirement through Work. 111 

2. Job Search and Job Search Training............................................................ 113 

3. Work-Related Support Services .................................................................. 115 

B. AVAILABILITY OF QUALIFYING WORK ACTIVITIES............................. 117 

1. Number of States Offering Qualifying Work Activities ............................. 118 

2. Types of Qualifying Work Activities Offered ............................................ 118 

3. Availability of Activities In Nonwaived Areas of the State........................ 122 

4. Availability of Qualifying Work Activities for ABAWDs Who Wish to 

Participate in Them ..................................................................................... 123 

5. Work Activities Offered to ABAWDs Who Have Reached the Time 

Limit and Become Ineligible....................................................................... 124 

6. Use of Federal Food Stamp E&T Funds ..................................................... 125 

C. PERCEIVED EFFECTIVENESS OF EMPLOYMENT AND TRAINING 

SERVICES FOR ABAWDS ............................................................................... 128 

D. PARTICIPATION IN WORK ACTIVITIES BY ABAWDS............................. 130 

E. CHALLENGES OF PROVIDING E&T SERVICES TO ABAWDS ................ 132 

1. Low Rate of Participation in Work Activities............................................. 132 

2. Hard-to-Serve Population............................................................................ 134 

3. Lack of Funds for Support Services............................................................ 135 

4. The Structure of E&T Funding for ABAWDs ............................................ 135 

5. Complexity of the Policy............................................................................. 136 

6. Restrictions on the Types of Qualifying Activities..................................... 136 

7. Lack of Qualified Staff................................................................................ 136 

F. APPROACHES TO ADDRESSING THE CHALLENGES .............................. 137 

G. SUMMARY ........................................................................................................ 138 
CONTENTS (continued)

Chapter Page 

 viii 

V. ADMINISTERING ABAWD POLICY: TRACKING AND OTHER 

CHALLENGES........................................................................................................... 141 

A. POLICIES AND PROCEDURES TO TRACK RECEIPT OF TIMELIMITED BENEFITS......................................................................................... 141 

1. Defining the Three-Month Time Limit and the 36-Month Period .............. 141 

2. States’ Tracking Capabilities ...................................................................... 145 

3. Procedures for Tracking ABAWDs Who Move within and between 

States ........................................................................................................... 148 

B. CHALLENGES IN ADMINISTERING ABAWD POLICY ............................. 148 

1. Tracking ...................................................................................................... 149 

2. Ensuring That Eligibility Workers Implement the Policy Correctly........... 151 

3. Translating the Law into State Policy ......................................................... 152 

C. SUMMARY ........................................................................................................ 152 

VI. CONCLUSIONS......................................................................................................... 153 

A. THE ABAWD POPULATION IS SMALL........................................................ 153 

B. MANY ABAWDS WHO LEFT THE PROGRAM DID NOT RETURN.......... 154 

C. DIVERSE FACTORS AFFECT STATES’ POLICY CHOICES....................... 155 

D. STATE POLICIES AFFECT THE NUMBER OF PARTICIPANTS WHO 

ARE SUBJECT TO THE TIME LIMIT ............................................................. 156 

E. THE ABAWD PROVISIONS ARE COMPLEX AND DIFFICULT TO 

ADMINISTER .................................................................................................... 158 

F. HALF OF ALL PARTICIPANTS WHO WERE SUBJECT TO THE TIME 

LIMIT WERE MEETING THE WORK REQUIREMENT............................... 159 

G. WHILE SOME ABAWDS MAY BE UNWILLING TO MEET THE WORK 

REQUIREMENT, OTHERS ARE NOT ABLE TO MEET IT .......................... 159 

1. Despite Generous Federal Funding, Qualifying Work Activities Are Not 

Available For All ABAWDs....................................................................... 160 

2. Many ABAWDs Face Significant Barriers to Both Work and 

Participation in Qualifying Work Activities ............................................... 161 
CONTENTS (continued)

Chapter Page 

 ix 

H. THE ABAWD PROVISIONS: ASSESSING THEIR IMPACT ....................... 161 

 REFERENCES............................................................................................................ 165 

APPENDIX A: SUMMARY OF FINAL ABAWD REGULATIONS ...................A-1 

APPENDIX B: SOURCE OF QUANTITATIVE ESTIMATES OF 

ABAWDS....................................................................................... B-1 

APPENDIX C: STATE POLICIES ON DEFINING WHO IS SUBJECT TO 

THE ABAWD TIME LIMIT ......................................................... C-1 

APPENDIX D: STATE POLICIES ON MEETING THE WORK 

REQUIREMENT AND THE PROVISION OF 

QUALIFYING WORK ACTIVITIES...........................................D-1 

APPENDIX E: ADMINISTERING THE ABAWD POLICIES, STATE 

POLICIES AND PROCEDURES.................................................. E-1 

APPENDIX F: DETERMINANTS OF THE PROPORTION OF ADULT 

FSP PARTICIPANTS SUBJECT TO THE TIME LIMIT .............F-1 
 xi 

TABLES 

Table Page 

I.1 SOURCES OF DATA TO ADDRESS RESEARCH QUESTIONS ON 

THE NUMBER AND CHARACTERISTICS OF PERSONS AFFECTED 

BY THE ABAWD PROVISIONS.....................................................................13 

I.2 SOURCES OF DATA TO ADDRESS RESEARCH QUESTIONS ON 

THE IMPLEMENTATION OF ABAWD POLICIES ......................................17 

II.1 ESTIMATED NUMBER OF ABAWD PARTICIPANTS IN THE FSP, 

MARCH 2000 ....................................................................................................27 

II.2 FOOD STAMP PARTICIPANTS EXCLUDED FROM THE ABAWD 

POPULATION, BY REASON, MARCH 2000 ................................................28 

II.3 COMPARATIVE FREQUENCY OF ABAWD PARTICIPANTS IN 

WAIVED AND NONWAIVED AREAS, MARCH 2000 ................................32 

II.4 ABLE-BODIED PARTICIPANTS 18 TO 50 WITHOUT DEPENDENTS 

WHO ARE EXCLUDED FROM THE ABAWD POPULATION 

BECAUSE THEY ARE EXEMPT FROM WORK REGISTRATION, 

BY REASON .....................................................................................................34 

II.5 ESTIMATED NUMBER OF ABAWD PARTICIPANTS BY STATE, 

MARCH 2000 ....................................................................................................37 

II.6 ABAWD PARTICIPANTS SUBJECT TO THE TIME LIMIT AS A 

PERCENTAGE OF ALL PARTICIPANTS 18 TO 50, BY STATE, 

MARCH 2000 ....................................................................................................39 

II.7 COMPARATIVE FREQUENCY OF ABAWD PARTICIPANTS IN 

WAIVED AND NONWAIVED AREAS, BY STATE, MARCH 2000 ...........40 

II.8 STATE ESTIMATES OF ABAWD PARTICIPANTS SUBJECT TO 

THE TIME LIMIT AND MEETING THE WORK REQUIREMENT, 

MARCH 2000 ....................................................................................................51 

II.9 METHOD OF MEETING THE WORK REQUIREMENT: ABAWD 

PARTICIPANTS SUBJECT TO THE TIME LIMIT, MARCH 2000..............53 

II.10 STATE ESTIMATES OF ABAWD PARTICIPANTS MEETING THE 

WORK REQUIREMENT, BY METHOD, MARCH 2000 ..............................54 
TABLES (continued)

Tables Page 

 xii 

II.11 STATE EXTIMATES OF PERCENTAGE OF ABAWD 

PARTICIPANTS SUBJECT TO THE TIME LIMIT WHO WERE 

MEETING THE WORK REQUIREMENT, BY METHOD, MARCH 

2000....................................................................................................................55 

II.12 DEMOGRAPHIC CHARACTERISTICS OF PARTICIPANTS 

SUBJECT TO THE ABAWD TIME LIMIT AND ALL PARTICIPANTS 

18 TO 50, FY2000 .............................................................................................59 

II.13 NUMBER OF CONSECUTIVE MONTHS RECEIVING FOOD 

STAMPS BY PARTICIPANTS SUBJECT TO THE ABAWD TIME 

LIMIT AND ALL PARTICIPANTS 18 TO 50, FY 2000.................................60 

II.14 HOUSEHOLD SIZE DISTRIBUTION AND AVERAGE MONTHLY 

BENEFIT OF PARTICIPANTS SUBJECT TO THE TIME LIMIT AND 

ALL PARTICIPANTS 18 TO 50, FY 2000 ......................................................61 

II.15 INCOME OF FOOD STAMP PARTICIPANTS SUBJECT TO THE 

ABAWD TIME LIMIT AND ALL PARTICIPANTS 18 TO 50, FY 2000......63 

II.16 DEMOGRAPHIC CHARACTERISTICS OF PARTICIPANTS 

SUBJECT TO THE TIME LIMIT BY WHETHER OR NOT THEY 

WERE MEETING THE WORK REQUIREMENT, MARCH 2000 ................64 

II.17 LACK OF A STABLE OR PERMANENT RESIDENCE AMONG 

PARTICIPANTS SUBJECT TO THE ABAWD TIME LIMIT BY 

WHETHER OR NOT THEY WERE MEETING THE WORK 

REQUIREMENT, MARCH 2000 .....................................................................65 

II.18 NUMBER OF CONSECUTIVE MONTHS RECEIVING FOOD 

STAMPS: PARTICIPANTS SUBJECT TO THE ABAWD TIME LIMIT 

BY WHETHER OR NOT THEY WERE MEETING THE WORK 

REQUIREMENT, MARCH 2000 .....................................................................66 

II.19 HOULDHOLD SIZE DISTRIBUTION AND AVERAGE MONTHLY 

BENEFIT: PARTICIPANTS SUBJECT TO THE ABAWD TIME LIMIT 

BY WHETHER OR NOT THEY WERE MEETING THE WORK 

REQUIREMENT, MARCH 2000 .....................................................................67 

II.20 INCOME OF FOOD STAMP PARTICIPANTS SUBJECT TO THE 

ABAWD TIME LIMIT BY WHETHER OR NOT THEY WERE 

MEETING THE WORK REQUIRENT, MARCH 2000 ..................................68 
TABLES (continued)

Tables Page 

 xiii 

II.21 ESTIMATED NUMBER OF TERMINATIONS OF ABAWD 

PARTICIPANTS REACHING THE THREE-MONTH TIME LIMIT, 

SELECTED PERIODS ......................................................................................75 

III.1 AVERAGE MONTHLY ALLOTMENTS OF 15 PERCENT 

EXEMPTIONS AND THEIR USE ...................................................................95 

IV.1 STATE POLICIES TOWARD MEETING THE WORK 

REQUIREMENT BY WORKING ..................................................................112 

IV.2 STATES THAT REQUIRED JOB SEARCH AND/OR OFFERED JOB 

SEARCH TRAINING TO AT LEAST SOME ABAWDS IN 

NONWAIVED AREAS...................................................................................115 

IV.3 NUMBER OF STATES OFFERING QUALIFYING WORK 

ACTIVITIES TO ABAWDs............................................................................119 

IV.4 NUMBER OF STATES OFFERING DIFFERENT TYPES OF WORK 

PROGRAMS....................................................................................................121 

IV.5 NUMBER OF STATES OFFERING A SLOT IN A QUALIFYING 

WORK ACTIVITY TO ALL ABAWD PARTICIPANTS IN 

NONWAIVED AREAS WHO WANTED ONE.............................................124 

IV.6 PERCENTAGE OF RESPONDENTS WHO VIEWED E&T SERVICE 

AS HELPFUL FOR SOME ABAWDS...........................................................129 

IV.7 FACTORS THAT DISCOURAGE ABAWD PARTICIPANTS FROM 

PARTICIPATING IN E&T ACTIVITIES ......................................................134 

V.1 STATE POLICIES ON DEFINING THE THREE-MONTH TIME 

LIMIT...............................................................................................................143 

V.2 STATE POLICIES ON DEFINING THE 36-MONTH PERIOD...................145 
 xv 

FIGURES 

Figure Page 

II.1 ABAWD PARTICIPANTS IN RELATION TO THE ENTIRE FOOD 

STAMP CASELOAD, MARCH 2000 ..............................................................30 

II.2 NUMBER OF PARTICIPANTS IN THE FOOD STAMP PROGRAM, 

OCTOBER 1988 THROUGH SEPTEMBER 2000 ..........................................42 

II.3 ALTERNATIVE SIMULATIONS OF ABAWD PARTICIPANTS IN 

THE FOOD STAMP PROGRAM, OCTOBER 1994 THROUGH 

SEPTEMBER 2000............................................................................................44 

II.4 ALL PARTICIPANTS AND ABAWD PARTICIPANTS, OCTOBER 

1994 TO SEPTEMBER 2000, AS A PERCENTAGE OF OCTOBER 

1994 LEVEL ......................................................................................................47 

II.5 NUMBER OF ABAWD PARTICIPANTS REACHING THE THREE 

MONTH TIME LIMIT IN SIX STATES, FEBRUARY 1997 THROUGH 

MARCH 2000 ....................................................................................................70 

II.6 NATIONAL ESTIMATE OF ABAWD PARTICIPANTS REACHING 

THE 3-MONTH TIME LIMIT, BASED ON EXTRAPOLATION FROM 

12 STATES ........................................................................................................74 

III.1 DISTRIBUTION OF STATES BY THE AGE ADULTS BECOME 

EXEMPT FROM TIME LIMITS ......................................................................84 

III.2 DISTRIBUTION OF STATES BY THE DISABILITY BENEFITS 

THAT QUALIFY INDIVIDUALS AS UNFIT FOR EMPLOYMENT ..........86 

III.3 TYPES OF HEALTH PROFESSIONALS WHO CAN CERTIFY 

UNFITNESS FOR EMPLOYMENT.................................................................87 

III.4 NUMBER OF ADULTS EXEMPT IF DEPENDENT CHILD IS 

PRESENT ..........................................................................................................91 

III.5 REASONS FOR USING THE 15 PERCENT EXEMPTION...........................91 

III.6 15 PERCENT EXEMPTION ELIGIBILITY CRITERIA.................................96 

III.7 PERCENTAGE OF 15 PERCENT EXEMPTION ALLOCATIONS, 

USED BY THE STATES, FY99 .....................................................................100 

III.8 STATE ABAWD POLICY RANKINGS ........................................................106 
FIGURES (continued)

Figures Page 

 xvi 

IV.1 TYPES OF WORK-RELATED SUPPORT SERVICES OFFERED TO 

ABAWD PARTICIPANTS .............................................................................116 

IV.2 DISTRIBUTION OF STATES BY NUMBER OF DIFFERENT TYPES 

OF SUPPORT SERVICES OFFERED TO ABAWD PARTICIPANTS........117 

IV.3 DISTRIBUTION OF STATES BY NUMBER OF QUALIFYING WORK 

ACTIVITIES OFFERED ANYWHERE IN STATE, FY99 ...........................119 

IV.4 DISTRIBUTION OF STATES BY NUMBER OF QUALIFYING WORK 

ACTIVITIES OFFERED TO ABAWDS IN ALL NONWAIVED AREAS 

OF STATE .......................................................................................................123 

IV.5 DISTRIBUTION OF STATES BY NUMBER OF QUALIFYING WORK 

ACTIVITIES AVAILABLE TO ALL ABAWDS WHO WANTED TO 

PARTICIPATE ................................................................................................125 

IV.6 DISTRIBUTION OF STATES BY PERCENTAGE OF E&T FUNDS 

DRAWN IN FY99 ...........................................................................................127 

IV.7 PERCENTAGE OF FILLED AND OFFERED SLOTS IN QUALIFYING 

WORK ACTIVITIES THAT WERE FILLED BY ABAWD 

PARTICIPANTS, NONWAIVED AREAS, FY99 .........................................131 
xvii 

EXECUTIVE SUMMARY 

 The Personal Responsibility and Work Opportunity Reconciliation Act of 1996 (PRWORA), 

which reformed the welfare system, also introduced fundamental changes to the way that Food 

Stamp Program (FSP) eligibility is determined for a segment of the population. PRWORA 

imposed a work requirement and time limit on those viewed as fit to work—able-bodied adults 

without dependents (ABAWDs). ABAWD participants are limited to three months of benefits in 

a three-year period unless they meet a work requirement. 

 The ABAWD provisions have fundamentally changed the FSP in three ways. One, this is 

the first instance that a time limit has been placed on food stamp receipt and that a major group 

of persons have been made ineligible because of factors other than their income and assets.1

 

Two, the states were granted uncharacteristically broad latitude in implementing these 

provisions. Three, states are now required to track food stamp receipt, employment, and 

participation in other work activities over a period of 36 months, while previously eligibility 

depended for the most part on household circumstances in just one month. 

 The uniqueness of the ABAWD provisions has generated interest in the number and 

characteristics of participants affected by them. The flexibility under which states implemented 

the provisions has generated interest in states’ policy choices and in how the recent issuance of 

final regulations on the ABAWD provisions will affect those choices. To address these issues, 

Mathematica Policy Research, Inc. (MPR) and its subcontractor Health Systems Research, Inc. 

(HSR) have conducted a study of the ABAWD provisions for the Food and Nutrition Service 

(FNS) of the U.S. Department of Agriculture (USDA). This report presents the study findings. 

THE ABAWD PROVISIONS 

The time limit established by PRWORA does not apply to individuals who are: 

• Under 18 or over 50 years of age 

• Medically certified as physically or mentally unfit for employment 

• Responsible for a dependent child 

• Exempt from FSP work registration 

• Pregnant 

All other participants are considered ABAWDs. 

 The exclusion of participants who are exempt from work registration requires further 

explanation. Since the 1980s, the FSP has required certain adult participants to register for work. 

 

1

 PRWORA also made some resident aliens ineligible. 
xviii 

For consistency, PRWORA exempts from the ABAWD time limit all individuals who are 

exempt from work registration. The most significant exemptions from work registration are 

similar to the ABAWD exemptions. As a result, most participants who would be excluded 

because they are exempt from work registration are already excluded for another reason. 

Participants who are under 15 or over 60 years of age, physically or mentally unfit, or 

responsible for a dependent child under age 6 are exempt from both work registration and the 

ABAWD provisions. A smaller number of participants who might otherwise be identified as 

ABAWDs are exempt from work registration if they are complying with the work requirements 

for Social Security or Unemployment Compensation, responsible for the care of an incapacitated 

person, enrolled at least half time in a qualified educational institution or training program, 

participating in a drug addiction or alcohol treatment program, or working 30 hours a week or 

earning more than 30 times the minimum wage. 

The time limit applies to ABAWDs unless they satisfy a work requirement. ABAWDs can 

meet the work requirement by (1) working at least 20 hours per week (2) participating in a 

workfare or comparable program, or (3) participating in another qualifying work activity for at 

least 20 hours per week. Months in which they meet the work requirement do not count against 

the three-month limit. 

ABAWDs who exhaust their three months of benefits lose their eligibility to receive food 

stamps for the remainder of the 36-month period. They can regain eligibility during this time 

period by meeting the work requirement for 30 days, after which they remain eligible to receive 

food stamps for as long as they continue to meet the work requirement. If they fail to meet the 

work requirement a second time, they can receive food stamps for up to three additional months. 

These three months must be used consecutively. After that point and for the balance of the 36-

month period, they can receive food stamps only in those months in which they meet the work 

requirement. 

 States have two options for exempting participants from the time limit. At the request of a 

state agency, USDA may waive the time limit and the associated work requirement for people 

who live in an area where the unemployment rate is over 10 percent or where there is an 

insufficient number of jobs. In addition, the Balanced Budget Act of 1997 (BBA) allows states 

to exempt up to 15 percent of the number of persons who are currently FSP-ineligible because of 

the ABAWD provisions. 

SOURCES OF DATA 

 A comprehensive study such as this one requires multiple data sources to adequately address 

all of the research questions. Most of the data for this study were provided by staff at state, 

county, and local FSP agencies. Other important data were obtained from FNS databases, but 

their primary source was the states. 

Number and Characteristics of ABAWDs. Because of the flexibility that states had in 

defining ABAWDs, documenting the number and characteristics of ABAWD participants 

presents a considerable challenge. Ultimately, we require data in which the states have identified 

those participants whom they regard as ABAWDs. But state data systems differ not only in the 

degree to which they identify ABAWDs and document key characteristics but in the reliability 
xix 

with which they do so. To estimate the number and characteristics of ABAWDs, we relied 

primarily on tabulations that we requested from the states. To validate and supplement these 

numbers, which were often incomplete, we obtained information from three additional sources: 

micro caseload data from five states, FSP Quality Control (FSPQC) sample data, and 

information reported by the states to FNS. We also conducted follow-up interviews with the 

states after reviewing their submissions. 

ABAWD Policies and Their Implementation. We conducted five surveys to collect a 

broad range of information on state policy choices, their implementation, and their 

administration. These surveys are identified by their target populations: (1) state FSP directors 

and managers of local office operations, (2) county FSP administrators, (3) state employment 

and training (E&T) managers, (4) E&T managers in local offices, and (5) state data-processing 

managers. We also conducted interviews with representatives of advocacy groups at the state 

and national levels. 

NUMBER AND CHARACTERISTICS OF ABAWD PARTICIPANTS 

Number of Participants. In March 2000 there were 422,500 ABAWD participants in the 

FSP. Approximately 55 percent were living in nonwaived areas. Almost all (93 percent) 

ABAWD participants living in nonwaived areas were subject to the three-month time limit. The 

balance of ABAWD participants in nonwaived areas were covered by the 15 percent exemption. 

The remaining ABAWD participants in the FSP, or 45 percent of the total, were residents of 

areas that were waived from the time limit because of high unemployment or insufficient jobs. 

Share of the FSP Caseload. ABAWD participants represented about 2.5 percent of all FSP 

participants. The small size of this share can be explained by the reasons why participants were 

excluded from the ABAWD population. Nearly two-thirds of all participants were under 18 or 

over 50 and therefore excluded by age. Another 9 percent were certified as physically or 

mentally unfit for employment while 20 percent were responsible for dependent children. About 

0.5 percent were pregnant and 3 percent were exempt from FSP work registration for reasons 

other than those already listed. 

ABAWD participants in waived areas accounted for a greater share of all participants 18 to 

50—about 12 percent—than did ABAWD participants in nonwaived areas, who represented just 

6 percent of that age group. We attribute most of this difference to the absence of a time limit 

and work requirement, although other differences between waived and nonwaived areas may 

contribute. 

Trends. While the ABAWD provisions were expected to reduce the number of food stamp 

participants who are subject to them, they were implemented during a period of dramatic 

changes in participation. Along with the total caseload, the number of ABAWD participants 

started to decline more than two years before the ABAWD provisions were implemented in late 

1996. After implementation, the number of ABAWD participants began a steep decline that 

reduced the ABAWD caseload by more than 40 percent in less than a year. The rate of decline 

then slowed, and by late 1999 there was evidence that the ABAWD caseload had leveled off—

followed, at least a year later, by the total FSP caseload. We estimate that at least half of the 
xx 

first-year decline among ABAWD participants may have occurred even without the ABAWD 

provisions. Nevertheless, the provisions themselves had a direct and sizable impact. 

Meeting the Work Requirement. In March 2000, just over half of the ABAWD 

participants who were subject to the time limit were meeting the work requirement. Nearly all 

who met the work requirement did so by working 20 or more hours a week or participating in 

workfare. However, most of the workfare participants were in Los Angeles or New York state. 

Elsewhere, participants who met the work requirement did so, for the most part, by working. 

 These estimates do not include those participants who were exempt from the time limit 

solely because they were working 30 hours or more or earning more than 30 times the minimum 

wage. Because such persons are exempt from work registration, states defined them to be 

outside the ABAWD population. Counting them as ABAWDs subject to the time limit increases 

the percentage who are meeting the work requirement from 51 percent to 68 percent. 

Other Characteristics. Compared with all participants 18 to 50, who were predominantly 

female, those who were subject to the ABAWD time limit were much more likely to be male. 

Nevertheless, females still accounted for nearly half of this group. Participants subject to the 

time limit also had smaller household sizes and lower unearned income, and had been 

participating for a shorter period of time. They were just as likely to have earnings, however. 

ABAWD participants who were meeting the work requirement differed in some respects 

from those who were subject to the work requirement but were not meeting it. Participants who 

were meeting the work requirement had longer spells of participation and lived in somewhat 

larger households than participants who were not meeting the work requirement. They were also 

more likely to have earnings. Some participants who were not meeting the work requirement 

had earnings as well but did not work enough hours to meet the work requirement. 

 

Terminations. Nearly 200,000 ABAWD participants were terminated in the first few 

months that ABAWDs exhausted their time-limited benefits. By March 2000, the total number 

who had reached the three-month time limit and been terminated had grown to more than 

900,000. There is little indication, however, that very many of those who lost their benefits 

during the first 36 months that the time limit was in place returned to the FSP to receive 

additional benefits during the next 36-month period. 

WHO IS SUBJECT TO THE TIME LIMIT? VARIATION IN STATE POLICIES 

States have had broad authority to develop their own ABAWD policies. State authority 

extends to (1) who is exempted from the definition of an ABAWD, (2) the use of waivers, and 

(3) the use of the 15 percent exemption. Not surprisingly, states vary in each of these policy 

areas. The final regulations issued in January 2001 reduce the states’ latitude in defining an 

ABAWD, but they do not eliminate it entirely. 

In defining ABAWDs, states have the most latitude in defining who is fit for work and who 

is responsible for a dependent child. 
xxi 

Fitness for Work. Before the final regulations were issued, states had considerable 

flexibility in determining how to certify a person as unfit for employment. The most important 

areas of state-to-state variation were: 

• The types of benefits that, if received, automatically certify a person as unfit for 

work. All but three states gave automatic certification to persons receiving any of the 

five types of benefits that trigger special FSP eligibility rules for disabled persons, but 

fewer states recognized other disability benefits. 

• The types of health professionals who can certify unfitness. State policies varied 

widely on the types of health professionals other than MDs or psychologists who 

could certify clients as unfit, with only seven states accepting certification from “any”

health professional. 

• Whether a person can self-report a disability. In 16 states an eligibility worker can 

certify a client as unfit for employment based on the client’s self-report. 

• Whether an eligibility worker can certify based on observation. In 35 states, an 

eligibility worker is allowed to certify an individual from direct observation. 

The final regulations require certification from a health professional only when “the 

unfitness is not evident to the eligibility worker” but do not allow a client’s self-report to be the 

sole basis for a certification. The regulations consider the receipt of any disability benefits as 

indirect proof that certification has taken place. 

Responsibility for Dependent Children. Before the final regulations were issued, states 

could define the age at which children are considered dependent. All but two states considered a 

child under the age of 17 or 18 as dependent. States could also determine which adults in a 

household with a dependent child can be exempted. In 22 states, all adults in the household with 

a dependent child were exempt from the ABAWD provisions. Four states exempted only one 

adult per household, and the remaining 24 exempted more than one adult if the adult met certain 

qualifications. The final regulations remove this flexibility. Children are to be considered 

dependent until age 18, and the presence of a dependent child will exempt all adults in the 

household. 

Waivers. In March 2000, 37 states and the District of Columbia had waivers in effect but 

there was substantial cross-state variation in terms of how much of the state the waivers covered. 

The waiver in the District of Columbia was unique because it covered the entire area while three 

states had waivers only for Indian reservations. Of the 13 states with no waivers, 10 had 

multiple areas that would qualify. In addition, two states received approval for waivers that 

some local areas, most notably New York City, elected not to implement. 

15 Percent Exemption. As of March 2000, 35 states had elected to use the 15 percent 

exemption, and an additional six states planned to use it in the coming year. States have broad 

authority in determining who can receive benefits under the 15 percent exemption. Some states 

apply the exemption to all individuals in a geographic area. Others apply the exemption on the 

basis of personal characteristics such as homelessness, age, inadequate access to transportation, 
xxii 

and health problems that have not been certified but render the client unable to work. Two 

states—Arkansas and Illinois—apply the exemption to all persons in areas not covered by 

waivers, and two other states—Missouri and Tennessee—allow persons who exceed the threemonth time limit two additional months of benefits. 

States that do not use the 15 percent exemption cite various reasons. These include the 

difficulty of monitoring the policy, the influence of political considerations, the availability of a 

sufficient number of jobs, and a desire to be more consistent with their TANF work 

requirements. 

FNS provides states with an annual allotment of exemptions that can be used in that year or 

carried over to the next year. The allotment equals 15 percent of the estimated number of 

individuals denied benefits because of the ABAWD provisions—plus any unused allotments 

from earlier years. Nationally, states used only about 8 percent of the exemptions that were 

available to them in FY98 and FY99. (Among the states using any exemptions, 12 percent of 

their FY99 total allotment was used.) Factors contributing to this low usage included the large 

number of allotted exemptions compared to the actual number of ABAWDs denied benefits, a 

state’s reluctance to use all of its available exemptions, and the difficulty estimating the number 

of ABAWDs that would meet the criteria established. 

Factors Determining State Policy. Few states adopted policies that uniformly minimize or 

maximize the number of participants who are subject to the ABAWD time limit. Rather, most 

states have adopted a mix of policies, with some tending to increase the number subject to the 

time limit and some working in the opposite direction. We examined the use of four key 

ABAWD policies in each state (disability certification, dependent child exemption, waiver use, 

and 15 percent exemption use). Each policy was classified as strict, moderate, or lenient, where 

a strict policy refers to one that maximizes the number subject to the time limit. We then 

combined these ratings to create an ABAWD policy scale in which the lowest value (zero) 

represents the strictest policies, and the highest value (eight) represents the most lenient. Values 

for 32 states fell in the middle of the distribution, with 5 states at the strict end and 13 at the 

lenient end of the distribution. Despite the large number of states in the middle, however, very 

few states employed only moderate policies. 

These findings indicate that there are potentially multiple factors affecting each state’s 

ABAWD policies. Ease of implementation plays a role, and some states have strong advocacy 

groups that influence policy choices. States may also have competing ideologies at different 

levels of government. 

HELPING ABAWDS MEET THE WORK REQUIREMENT: POLICIES AND 

CHALLENGES 

State policies vary in the extent to which they assist ABAWDs in meeting the work 

requirement. In particular, states differ in the extent to which they support ABAWDs in finding 

and retaining employment, in the number and types of work activities they offer to ABAWDs, 

and in the extent to which these activities are available to all ABAWDs who need them to meet 

the work requirement. 
xxiii 

What Constitutes Work. State policies were divided almost equally between those that 

allowed volunteer work to meet the work requirement under all circumstances and those that did 

so only sometimes or never. But more than three-quarters of the states with policies agreed that 

work for less than 20 hours a week could count if it was combined with another qualifying work 

activity. The final regulations mandate that both volunteer work as well as a combination of 

work and another qualifying activity can meet the work requirement. 

Job Search. Generally, job search and job search training are not qualifying work activities, 

but they can be helpful in finding employment. Independent of the ABAWD provisions, most 

states required at least some ABAWDs to conduct a job search and most of these offered job 

search training. A majority of states provided some forms of job search training that met the 

work requirement. More than half the states required job search training as part of their workfare 

programs and about a quarter offered job search training through their Job Training Partnership 

Act (JTPA) or Trade Adjustment Assistance (TAA) programs. 

Support Services. Most states provided some support services, such as assistance with 

transportation or other job-related expenses. Support services were viewed as providing 

important assistance to ABAWDs who work and to those who participate in qualifying work 

activities. Many state and local E&T managers complained that the $12.50 per person per month 

assistance in federal matching funds was inadequate. 

Qualifying Work Activities. The increased funding for the food stamp E&T program in 

the BBA is intended to ensure that there are sufficient qualifying work activities for all 

ABAWDs who need them. In FY99, nearly all states offered ABAWDs some qualifying work 

activities, but states varied considerably in how many different activities they offered and the 

extent to which the activities were available to all ABAWDs subject to the time limit. Workfare 

was the most frequently offered work activity. Nearly half of all states reported that they had a 

prearranged slot in workfare available for every ABAWD who wanted one. However, 22 states 

could not offer any qualifying work activity to at least some ABAWDs who were subject to the 

time limit. 

Use of Federal E&T Funds. Despite the fact that there are states that have not provided 

qualifying work activities for all ABAWDs, more than half of the federal funding for E&T 

services for ABAWDs was unspent in FY99. According to state E&T managers, this results 

from the difficulties in serving such a small population. The number of ABAWDs is small to 

begin with, and many do not wish to participate in qualifying work activities. Some states have 

found that, because the fixed costs of developing and running E&T programs for ABAWDs can 

be spread over only a small number of people, the reimbursement amount per slot may not be 

large enough to cover the program costs. Advocates echo this concern. An increasing number of 

states have opted to be “alternative reimbursement” states. These states are not subject to the 

reimbursement caps but in return are required to offer a qualifying work activity slot to all 

ABAWDs in nonwaived areas. 

Perceived Effectiveness of E&T Services. Most local E&T managers interviewed viewed 

E&T services as helping at least some ABAWDs find employment. Different activities seem to 

be helpful for different ABAWDs. Workfare was viewed as helpful for ABAWDs who lack 

work experience or “soft skills,” (such as how to dress for work and communicate appropriately 

with coworkers). Education was helpful for ABAWDs who lack credentials. Vocational 
xxiv 

training was viewed as helpful for those who lack marketable skills, and job search training was 

helpful for the “job ready.” Support services were especially helpful for those with 

transportation difficulties. 

Low Participation. Both state and local E&T managers noted the low participation of 

ABAWDs in qualifying work activities—a finding that is broadly consistent with available data. 

Respondents reported that the lack of motivation of some ABAWDs is one reason for low 

participation. However, respondents also stated that many ABAWDs face serious barriers to 

both work and participation in qualifying work activities, including lack of transportation, 

disabilities that are not medically certified, substance abuse problems, and homelessness. 

ADMINISTERING ABAWD POLICY: TRACKING AND OTHER CHALLENGES 

The ABAWD provisions significantly increased the complexity of determining FSP 

eligibility. 

Tracking. Tracking refers to the procedures used to determine whether an ABAWD has 

received benefits during the past 36 months. The states vary widely in the extent to which 

tracking is both automated and statewide. While in March 2000 the majority of states operated 

computer systems that could track ABAWDs statewide, 17 states still had either a very limited 

tracking system or no automated statewide tracking system. Without a statewide, automated 

tracking system, the eligibility worker can check the client’s prior receipt of time-limited benefits 

only by contacting other local offices in the state. No automated procedures exist to track 

ABAWDs across states. 

Timing Issues. The law grants states some discretion in: 

• Defining the Three-Month Time Limit. Six states count the month of application 

toward the three-month time limit while 36 states count only full months of benefits. 

The other eight states have policies that fall between these two extremes. The final 

regulations allow states to count only full months of benefits. 

• Defining the 36-Month Period. Twenty-seven states use the most stringent policy to 

define the 36-month period, a rolling clock, where the 36-month period is always the 

preceding 36 months. The rest use a fixed clock, in which the beginning and ending 

dates of the 36-month period do not change. Under a rolling clock, an ABAWD 

cannot receive more than three months of time-limited benefits in a 36-month period 

unless they regain eligibility. They can, however, under a fixed clock if they receive 

time-limited benefits more than three months into the fixed period. The final 

regulations allow states to use either a rolling or fixed clock. 

Challenges. While some respondents viewed the ABAWD provisions as unfairly 

penalizing the targeted population, more disliked the provisions because of the difficulties they 

encountered in administering them. The policy is viewed as too burdensome, particularly in light 

of the small size of the ABAWD population. More than half the state respondents (30) identified 

tracking as one of the main administrative challenges. Difficulties included not only the effort 

required to develop and maintain an automated system but the burden that tracking placed upon 
xxv 

eligibility workers generally. Other major challenges included ensuring that eligibility workers 

implemented the policy correctly and translating the ABAWD provisions into state policy. 

Nearly half of the state respondents volunteered that they would like to have the ABAWD time 

limit and/or work requirement removed. 

CONCLUSIONS 

 We draw seven main conclusions from this study: 

1. The ABAWD population is small. It is small because the definition is quite 

restrictive and because the number of ABAWD participants has declined significantly 

since the ABAWD provisions went into effect. 

2. Many ABAWDs who left the program have not returned. ABAWDs who used up 

their time-limited benefits in 1997 became eligible again in 2000, creating the 

potential for a sharp upswing in participation, yet the trend in participation shows no 

such change. 

3. Diverse factors affect states’ policy choices. There was little correlation between the 

policy choices made by each state with respect to whether the policy would minimize 

or maximize the number of persons subject to the ABAWD time limit. Factors 

contributing to state decisions included administrative considerations, concurrent 

changes in cash assistance programs, divergent views among policymakers, and 

pressure from advocates. 

4. State policies affect the number of participants who are subject to the time limit. 

Waivers, the 15 percent exemption, and the creation of E&T slots have the most 

discernible and direct effects. Policy defining responsibility for a dependent child 

affects the number of ABAWD participants, but the final regulations eliminate state 

discretion. 

5. The ABAWD provisions are complex and difficult to administer. Tracking has been 

the most challenging aspect. In addition, the rules determining eligibility are difficult 

for state administrators and eligibility workers to understand and to explain to clients. 

6. Half of all participants subject to the time limit were meeting the work requirement. 

Of these, about half were working, and nearly all of the rest were participating in 

workfare. Participants who were exempt from the time limit because they were 

working 30 hours or more are not counted by states as ABAWDs. Doing so raises the 

proportion meeting the work requirement to 68 percent. 

7. While some ABAWDs may be unwilling to meet the work requirement, others are 

not able to meet it. Despite generous federal funding, qualifying work activities are 

not available for all ABAWDs. Many ABAWDs face significant barriers to both 

work and participation in qualifying work activities. 
 1 

I. BACKGROUND AND OVERVIEW OF STUDY 

The Personal Responsibility and Work Opportunity Reconciliation Act of 1996 (PRWORA), 

or welfare reform as it is more commonly known, made significant changes to the Food Stamp 

Program’s (FSP) eligibility rules. To encourage personal responsibility and self-sufficiency, the 

legislation placed a work requirement and a time limit on benefit receipt on persons viewed as fit 

to work—able-bodied adults without dependents (ABAWDs). ABAWD participants can meet 

the work requirement by working or participating in a qualifying work activity. Those who do 

not satisfy the work requirement are limited to three months of food stamp benefits in a threeyear period. 

This report presents the findings from a study of the ABAWD provisions conducted by 

Mathematica Policy Research, Inc. (MPR) and its subcontractor Health Systems Research, Inc. 

(HSR) for the Food and Nutrition Service (FNS) of the U.S. Department of Agriculture (USDA). 

The study has two primary objectives. The first objective is to provide national and state 

estimates of the number and characteristics of people affected by the ABAWD provisions. In 

particular, we estimate the number of FSP participants who are ABAWDs, the number who are 

subject to the time limit, the number who are satisfying the work requirement, and the number 

who receive time-limited benefits. We compare the characteristics of these groups with those of 

all adult participants, and show how the total number of ABAWD participants and the number 

who have been disqualified after reaching the time limit have changed over time. 

The second objective of the study is to describe how the ABAWD provisions have been 

implemented across states. Specifically, we describe state variation in policy related to defining 

ABAWDs and exempting them from the time limit. We also describe state variation in policies 

aimed at helping ABAWDs meet the work requirement and the challenges of providing 
 2 

employment and training services to ABAWDs. In addition, we discuss the issues and 

challenges faced by the states in administering ABAWD policy. 

Learning more about the number and characteristics of persons affected by the ABAWD 

provisions, and about the decisions that states have made in implementing the provisions is 

important for three reasons. One, this is the first instance that a time limit has been placed on 

food stamp receipt and that a major group of persons has been made ineligible because of factors 

other than their income and assets. Two, the states were granted broad latitude in implementing 

the ABAWD provisions, significantly more than in other areas of the FSP. States can decide, for 

example, whether to apply for waivers from the time limit for areas of high unemployment, and 

whether and how to use a “15 percent” exemption through which anyone can be exempted from 

the ABAWD provisions as long as the total exemptions do not exceed a given federal allotment. 

Three, to determine FSP eligibility for ABAWDs, states are now required to track food stamp 

receipt, employment, and participation in qualifying work activities over a period of up to 36 

months. Previously, eligibility depended for the most part on household circumstances in a onemonth period. 

This introductory chapter reviews the ABAWD provisions and discusses the changes to the 

Food Stamp Employment and Training (E&T) program introduced by the Balanced Budget Act 

of 1997 (BBA) to encourage states to provide more qualifying work activities for ABAWDs. It 

also outlines the final federal regulations on the ABAWD provisions, and details the study 

objectives and data sources. 

A. THE ABAWD PROVISIONS 

PRWORA states that an ABAWD participant who fails to meet the work requirement will 

become ineligible for food stamps after receiving three months of benefits in a 36-month period. 

ABAWDs can meet the work requirement by working, or by participating in a workfare program 
 3 

or another qualifying work activity. The three months of time-limited benefits need not be 

consecutive. 

ABAWDs who exhaust their three months of benefits lose their eligibility to receive food 

stamps. They can regain eligibility if during a 30-day period when they are not receiving food 

stamps they participate in a workfare program, or work or participate in a qualifying work 

activity for 80 or more hours. An ABAWD who regains eligibility in this way remains eligible 

as long as he or she continues to meet the work requirement. If, after regaining eligibility, an 

individual again fails to meet the work requirement, he or she can receive benefits for three 

additional months starting on the date the person notified the FSP agency that he or she was not 

meeting the work requirement. An ABAWD may receive these second three months of benefits 

only once in any 36-month period and must use these months consecutively. 

ABAWDs must satisfy the work requirement to avoid using up their time-limited benefits 

unless they live in an area that is waived from the ABAWD provisions or they are granted a 15 

percent exemption as provided by the BBA. 

1. Definition of an ABAWD 

Under PRWORA, individuals with the following characteristics are not considered 

ABAWDs: 

• Under age 18 or over age 50 

• Medically certified as physically or mentally unfit for employment 

• Responsible for a dependent child 

• Exempt from work registration 

• Pregnant 

Since the 1980s, the FSP has required at least some adult participants to register for work. 

The ABAWD time limit applies only to these adults; PRWORA explicitly exempts from the 
 4 

ABAWD restrictions all individuals who are exempt from work registration. Many of the 

exemptions from work registration overlap with the ABAWD exemptions. For example, FSP 

participants who are under 15 or over 60 years of age, or who are physically or mentally unfit are 

exempt from both work registration and the ABAWD provisions. However, the following 

persons are exempt from the ABAWD provisions only because they are exempt from work 

registration: 

• Persons working 30 hours a week or earning more than an amount equal to 30 hours 

times the minimum wage 

• Persons complying with the work registration requirements for Social Security or 

Unemployment Compensation 

• Persons responsible for the care of an incapacitated person 

• Students enrolled at least half time in a school, training program, or institution of 

higher education 

• Regular participants in a drug addiction or alcoholic treatment program 

2. Meeting the ABAWD Work Requirement 

To meet the work requirement, an individual must do one of the following: 

• Work. An ABAWD can meet the work requirement by working 20 or more hours per 

week, averaged monthly. (However, an ABAWD who works 30 or more hours per 

week is technically exempt from work registration and hence also exempt from the 

ABAWD provisions). 

• Participate in a Workfare or Comparable Program. An ABAWD can meet the work 

requirement by participating in a workfare or other work program. The Fair Labor 

Standards Act limits workfare participation to the number of hours necessary for the 

ABAWD to pay off his or her food stamp benefit at the minimum wage. 

• Participate in Another Qualifying Work Program. An ABAWD can meet the work 

requirement by participating in a qualifying work program for at least 20 hours per 

week. Qualifying work programs include education programs, vocational training, 

and self-employment programs. PRWORA explicitly states that, with some 

exceptions, job search and job search training are not approved work programs. The 
 5 

exceptions include job search and job search training that are part of a Workforce 

Investment Act (WIA) or Trade Adjustment Assistance (TAA) program.1

3. Waivers 

At the request of a state agency, USDA may waive the ABAWD time limit and associated 

work requirement for people who live in an area where the unemployment rate is over 10 percent 

or where there is an “insufficient number of jobs” to provide employment. Waivers, when 

approved, usually last for one year. An area can qualify as having an insufficient number of jobs 

if it: (1) is designated as a Labor Surplus Area by the U.S. Department of Labor, (2) qualifies for 

extended Unemployment Insurance benefits, (3) has a low and declining employment-topopulation ratio, (4) has a lack of jobs in declining occupations or industries, (5) has a 24-month 

average unemployment rate that is 20 percent above the national average for the same period, or 

(6) presents other compelling evidence of an insufficient number of jobs. The most common 

geographic unit for a waiver is the county, though several states have received waivers for cities, 

municipalities, Indian reservations, and census tracts. 

4. 15 Percent Exemption 

The BBA allows states to exempt from the time limit up to 15 percent of the estimated 

number of people in the state who would be denied eligibility for food stamp benefits because of 

the ABAWD provisions. Whether the exemption is used and the criteria for determining who 

qualifies for the exemption are matters of state discretion. 

As the number of persons currently ineligible for the FSP because of the ABAWD 

provisions is unknown, the BBA directs USDA to estimate the number and provide the states 

with an annual allotment of 15 percent exemptions. USDA estimates this number based on three 

 

1

 WIA replaced the Job Training Partnership Act (JTPA) on July 1, 2001. 
 6 

factors: the estimated number of persons in FY96 who would have been found ineligible if the 

ABAWD provisions had been in place, subsequent changes in the FSP caseloads, and estimates 

of the number of persons covered by waivers. Unused exemptions from each state’s allotment 

can be carried over to the next year while exemptions in excess of the allotment are subtracted 

from the next year’s allotment. 

5. Final ABAWD Regulations 

In December 1999, FNS published proposed regulations on the implementation of the 

ABAWD provisions (Federal Register, December 17, 1999). Final regulations, published in 

January 2001 (Federal Register, January 17, 2001), were effective August 1, 2001 and were 

required to be implemented by the state agencies no later than October 1, 2001. This report 

addresses the implications of these regulations for ABAWD policy. 

The regulations address eight topics: (1) meeting the work requirement, (2) implementing 

the time limit, (3) establishing verification and reporting requirements, (4) tracking the receipt of 

time-limited benefits, (5) determining eligibility for others in the household, (6) exempting 

individuals from the work requirement, (7) regaining eligibility, and (8) applying for waivers. 

Appendix A lists the main requirements of these regulations in each of these areas. 

B. BBA PROVISIONS DESIGNED TO INCREASE THE AVAILABILITY OF 

QUALIFYING WORK ACTIVITIES 

States can fund E&T services through either their Food Stamp E&T programs, which are 

100 percent federally funded, or through federal matching funds, which reimburse states for 50 

percent of the allowable costs expended. Prior to the BBA, states had considerable flexibility in 

how they used the E&T funds, including what services they funded and which populations were 

targeted. In response to concern about the lack of opportunities for ABAWDs to participate in 

qualifying work activities, the BBA significantly increased the funding for Food Stamp E&T 
 7 

programs but targeted the increased funding to qualifying work activities for ABAWDs. (It did 

not, however, place any restrictions on the use of the federal matching funds.) Specifically, the 

BBA: 

1. Substantially Increased Funding. Federal funding increased by $131 million in 

fiscal year 1998 (FY98), FY99, FY00, and FY01, and it will increase by $75 million 

in FY02. In FY98, the BBA increased the funding for Food Stamp E&T programs 

by over 60 percent.2

2. Concentrated the Funding on ABAWDs. The BBA requires 80 percent of a state’s 

allocation of federal funds be spent on qualifying work programs for ABAWDs. The 

remaining 20 percent of federal funds can be spent on activities for FSP participants 

who are not ABAWDs or on nonqualifying activities. 

3. Set Capped Reimbursement Rates. The BBA authorized FNS to set caps on the rate 

at which the state agency can be reimbursed with federal funding for providing 

qualifying work activities. Recognizing that some E&T slots are not filled, FNS set 

a monthly reimbursement rate of $175 for a filled slot and $30 for a slot that is 

offered but not filled. 

4. Introduced a Maintenance of Effort (MOE) Requirement. To receive the increased 

federal funding for E&T, the states must maintain or exceed the FY96 E&T 

expenditures they financed from nonfederal sources. 

C. OBJECTIVES OF THE STUDY 

The study has two broad objectives: to provide estimates of the number and characteristics 

of people affected by the ABAWD provisions and to describe how the ABAWD provisions have 

been implemented by the states. 

1. To Provide Estimates of the Number and Characteristics of People Affected by the 

ABAWD Provisions, Nationwide and by State 

For the most part, we provide a snapshot of the number and characteristics of ABAWDs in 

March 2000, before the final regulations were issued but shortly after the proposed regulations 

were published. We also examine how the number of ABAWDs participating in the FSP and the 

 

2

 The Agricultural Research, Extension, and Education Reform Act of 1998 subsequently reduced the 

authorization levels for the FSP E&T program by $100 million in FY99 and $45 million in FY00. 
 8 

number who lost eligibility because of the time limit have changed historically. We address 

seven more specific research questions: 

1. How Many FSP Participants Are ABAWDs? To what extent are persons exempted 

from the provisions because of their age, because they are “unfit for employment,”

because they have dependents, or because of other ways in which they do not meet 

the definition of an ABAWD?

2. How Many ABAWDs Are Subject to the Time Limit? To what extent are ABAWDs 

exempted from the work requirement by waivers or by the 15 percent exemption?

3. How Has the Number of ABAWDs Changed over Time? How does the trend 

compare with that of all FSP participants?

4. How Many ABAWDs Who Are Subject to the Time Limit Are Satisfying the Work 

Requirement? Of those who are satisfying the work requirement, how many are 

doing so by working, and how many are doing so by participating in workfare or 

other qualifying work activities? 

5. How Many ABAWDs Who Are Subject to the Time Limit Are Receiving TimeLimited Benefits? How many ABAWDs subject to the time limit are not satisfying 

the work requirement and are receiving one of their months of time-limited benefits? 

6. How Many ABAWDs Have Reached the Time Limit and Been Disqualified? How 

have the numbers changed over time? What is the cumulative number of 

terminations?

7. What Are the Characteristics of ABAWDs and Their Households? Do the 

characteristics of ABAWDs who meet the work requirement differ from the 

characteristics of ABAWDs who do not meet the work requirement?

Previous studies have addressed questions 1, 2, 3, 4, and 7 for earlier periods and with more 

limited data than this project. Stavrianos, Cody, and Lewis (1997) and Stavrianos and Nixon 

(1998) used Food Stamp Program Quality Control (FSPQC) sample data to estimate the number 

and characteristics of ABAWDs who would have been participating in the FSP in 1995 if the 

ABAWD provisions had been in place at that time. Cody and Castner (1999) used a similar 

methodology to estimate the average monthly number and characteristics of ABAWD 

participants for each fiscal year from 1994 through 1997, and Cody (1999) extended some of 

these estimates to 1998. The U.S. General Accounting Office (U.S. GAO 1998) obtained 

estimates of ABAWD participants by waiver status directly from 42 states for the middle of 1998 
 9 

but did not attempt to extrapolate the findings to the full nation. This report also presented FNS 

statistics on the number of participants who were meeting the work requirement through 

federally reimbursed workfare and other E&T activities, and most of the studies cited above 

provided estimates of both work and E&T participation among ABAWDs, but without 

information on whether these activities met the work requirement. The estimates presented in 

this report update and improve on these earlier estimates by supplementing state reports on 

ABAWD participants and their characteristics with FSPQC data, which we use to evaluate, 

refine, and extend the state numbers. In addition, we provide more complete answers to 

questions 3 and 4 and present the first estimates that address questions 5 and 6. 

While this study goes a long way in building an understanding of the implications of the 

ABAWD provisions, determining the full impact of the provisions means understanding what 

happens to ABAWDs after they leave the FSP. It is beyond the scope of this study to address 

this issue. However, four state-specific studies funded by the Economic Research Service (ERS) 

of USDA address how ABAWDs and other former food stamp participants fare after leaving the 

program (Garasky et al. 2000, Mills and Kornfeld 2000, and Rangarajan and Gleason 2001).3

2. To Describe How the ABAWD Provisions Have Been Implemented 

Given the discretion accorded to the states in implementing the ABAWD policy, different 

states have implemented the ABAWD provisions quite differently. It is important to understand 

how the policies have been implemented for four reasons. First, the information on 

implementation provides a first check on the statistics provided by the states. For example, we 

checked that the state-reported proportion of ABAWDs who live in waived areas is 

commensurate with the waivers that the state received. Second, an understanding of policy 

 

3

 The report on the fourth study is forthcoming. 
 10 

implementation will help us interpret differences between states in terms of the number of people 

both subject to and satisfying the work requirement. Third, it will help FNS predict the impact 

of the final ABAWD regulations on state policy and on the number of ABAWDs. Fourth, 

describing policies that have been used by some states may be helpful to other states in 

redesigning their ABAWD policy. 

To describe how the ABAWD provisions were implemented, we address three research 

questions: 

1. How Much Do State Policies Vary in Determining Who is Subject to the Time 

Limit? How do states vary in who is exempt from the ABAWD provisions? How 

many states applied for and implemented waivers? To what extent, and how, are the 

states using the 15 percent exemption? 

2. To What Extent Are States Helping ABAWDs Meet the Work Requirement? How 

do states vary in the extent to which they help ABAWDs find and retain 

employment? To what extent are the states offering ABAWDs qualifying work 

activities? Which services do states feel are most effective at helping ABAWDs find 

employment? What are the challenges of providing E&T services to ABAWDs and 

how have these challenges been addressed?

3. How Have the ABAWD Policies Been Administered? How have the states tracked 

the receipt of time-limited benefits by ABAWDs? What challenges have arisen in 

administering the policy? How have the states addressed those challenges?

We focus mainly on ABAWD policy as implemented in March 2000. However, some data on 

the qualifying work activities provided by state agencies refer to FY99. 

Previous studies have documented some state policy choices. In 1997, HSR conducted a 

survey of state FSP agencies to obtain information on state policy choices after welfare reform, 

including ABAWD policy choices (Gabor 1998). GAO (1997) first conducted a survey of state 

FSP agencies in 1997 to identify policies designed to assist people who lose FSP eligibility 

because they are ABAWDs or immigrants and then in 1998 conducted another survey on state 

E&T activities (GAO 1998). 
 11 

The study documented in this report adds to the information provided by these three earlier 

studies by focusing on a more recent period (March 2000) and by giving more details on a wider 

range of policies affecting ABAWDs. In summer 1999, HSR conducted a study for ERS 

(Botsko et al. 2000), which complements our study. The ERS study focused on the extent to 

which states use the new funds available from BBA to create workfare and other E&T slots for 

ABAWDs. As described below, the State E&T Managers Survey in our study was designed to 

serve our data needs and those of the ERS study. 

D. SOURCES OF DATA 

A comprehensive study such as this one requires multiple data sources to adequately address 

all the research questions. Most of the data for this study were provided by staff at state, county, 

and local FSP agencies.4

 Other important data were obtained from FNS databases. We describe 

below the data sources we used to address each of the two main research objectives. 

1. Data Sources for Determining the Number and Characteristics of ABAWDs 

An important strength of this study is its use of multiple data sources to assess the number 

and characteristics of FSP participants affected by the ABAWD provisions (Table I.1). Data 

collected through the states’ food stamp management information systems, enhanced in many 

cases to capture and store information on participation by ABAWDs, are the most authoritative 

source for determining how many participants have been classified as ABAWDs, how many of 

these individuals have become subject to the time limit, how many have satisfied the work 

requirement to retain their benefits, and how many have been terminated or disqualified from the 

program as a result of using up their time-limited benefits. The data that only the states can 

supply therefore become central to this study. 

 

4

 All the instruments used to collect these data are provided in Volume II of this report. 
 12 

While the primary data source for estimates of the ABAWD population is a set of stateproduced tabulations, information to validate and supplement these numbers come from a variety 

of other sources, including actual caseload data from five states, FSPQC data, and pertinent 

information reported by the states to FNS. By using multiple sources of data, this analysis 

addressed many of the limitations posed by states’ automated management information systems. 

The following sections of the report describe each of these sources in more detail. 

a. Tabulations Provided by the States 

States provided tabulations in response to a detailed set of worksheets and instructions. To 

provide a snapshot of the number and characteristics of ABAWDs at a point in time, most of the 

items were requested for March 2000. However, we asked for monthly counts of the number of 

participants terminated or disqualified because of the ABAWD provisions since the 

implementation of the policy. 

The states varied in the extent to which they were able to meet the full request. Appendix B 

provides a description of the data provided by each state. All but 10 states were able to supply 

basic counts of ABAWDs subject to the time limit. Most of these states also provided some 

other data, such as the number of ABAWDs who live in areas that were waived from the time 

limit, and several states were able to provide tabulations of ABAWDs subject to the time limit by 

age, sex, race, household size, benefit level, consecutive months of benefit receipt, and income. 

Only six states could provide data on the monthly number of ABAWDs who were terminated or 

disqualified since the ABAWD provisions went into effect, but another six states were able to 

produce monthly counts starting some time later. Generally, the larger states were the most 

responsive, and this accounts for much of the strength of the national estimates presented in this 
 13 

TABLE I.1 

SOURCES OF DATA TO ADDRESS RESEARCH QUESTIONS ON THE NUMBER AND 

CHARACTERISTICS OF PERSONS AFFECTED BY THE ABAWD PROVISIONS 

Research Question 

State 

Tabulations 

Caseload 

Data 

Food Stamp 

QC Data 

Form 

FNS-583 

How many FSP participants are ABAWDs?    

How many ABAWDs are subject to the time limit?   

How has the number of ABAWDs changed over 

time? 

 

How many ABAWDs who are subject to the time 

limit are satisfying the work requirement? 

   

How many ABAWDs who are subject to the time 

limit are receiving time-limited benefits? 

  

How many ABAWDs have reached the time limits 

and been disqualified? 

 

What are the characteristics of ABAWDs and their 

household? 

  

report. All of the states were given the opportunity to review the state-level statistics presented 

in this report and to revise their initial submissions. 

b. Caseload Data for Five States 

We requested and received caseload data from five states—four of them for the entire March 

2000 caseload and one for a sample of the FY00 caseload. The caseload micro data were used to 

describe in more detail the characteristics of ABAWDs and to examine relationships between 

selected characteristics. To reduce the burden on these five state agencies, we used their micro 

data to prepare the counts requested of all other states. 

c. FSPQC Data 

The FSPQC database is a nationally- and state-representative sample of about 60,000 food 

stamp households per year; the sample is drawn by the individual states in order to comply with 

food stamp quality control procedures. Samples of cases are drawn every month in each state, 

and a standard set of items is coded and transmitted to FNS. The data have been used to support 
 14 

many previous analyses of the food stamp caseload—including estimates of the size of the 

ABAWD population in FY96 (Stavrianos and Nixon 1998). In FY98, a code identifying 

ABAWD status was introduced. While some important limitations have been identified, this 

code nevertheless enhances the value of the FSPQC sample data for analysis of ABAWD issues. 

We used the FSPQC data in three ways: (1) to supplement the tabular data for states that 

were not able to complete the full data request, (2) to estimate trends in the number of ABAWD 

participants, and (3) to describe the number and characteristics of all adult participants. When a 

state was not able to supply a particular data item, we estimated the missing item from the state’s 

FY00 FSPQC data. When we needed an item to produce state-level estimates, we adjusted the 

FSPQC data to be consistent with other items provided by the state, such as the number of 

participants subject to the time limit. When we needed the missing item only to prepare national 

estimates, we adjusted the FSPQC data at a more aggregate level (across groups of states). 

Appendix B discusses in detail our use of the FSPQC sample data to supplement the state 

tabulations. 

d. Form FNS 583 

Beginning in FY99, the states were required to submit to FNS a quarterly report (Form FNS 

583) detailing what E&T services they provide for ABAWDs and other FSP participants, and 

indicating how many of their allotted 15 percent exemptions had been used. Data are reported 

for each of the three preceding months. We used data from FNS 583 for March 2000 to 

supplement the data submitted by the states on the number of participants meeting the work 

requirement through workfare or education and training and on the number exempted under the 

15 percent provision. We used the Form 583 numbers when a state provided no data. We also 

used Form 583 data for FY99 and FY00 to perform additional analysis of the use of qualifying 

work activities and the use of the 15 percent exemption. 
 15 

e. Limitations of Data on ABAWD Participants 

States differ in what characteristics of the ABAWD population they have found useful to 

tabulate on a regular basis and how closely they have monitored the size and composition of this 

population, including, in particular, the frequency with which ABAWDs are meeting the work 

requirement. This affected how much individual states could tell us about their ABAWD 

populations and the confidence with which they could do so. For example, few states could 

report what proportion of the ABAWDs subject to the time limit were meeting the work 

requirement, and fewer still could detail how many were meeting it by working, participating in 

workfare, or participating in another qualifying work activity. When a state could provide such 

information, the data often came from special tabulations rather than reports that state staff had 

become accustomed to reviewing. 

The variation in state practice also affected both the comparability of data across states and, 

from what we could observe, their quality. Providing estimates to us required a number of states 

to try to fit their concepts to ours. For example, one state does not include in its monthly 

ABAWD counts those participants who are meeting the work requirement by working. Other 

states define the ABAWD population to include those who are exempt from work registration for 

reasons other than age, unfitness for employment, responsibility for a dependent child, or 

pregnancy. Issues of data quality were evident in the frequent discrepancies between state 

tabulations, FSPQC data, and the reports submitted by states on form FNS 583. Which source is 

best is likely to depend on the state and the item. 

When aggregated to the national level, there is enough consistency across the sources to 

invite confidence that key characteristics of the ABAWD population have been described with 

reasonable accuracy. However, caution is warranted in making comparisons across states, as 

differences are undoubtedly overstated. 
 16 

2. Data Sources for Understanding ABAWD Policies and Their Implementation 

We conducted five surveys to collect a broad range of information on state choices on 

ABAWD policies and their implementation: 

1. A survey of state FSP directors and managers of local office operations 

2. A survey of county FSP administrators 

3. A survey of state E&T managers 

4. A survey of E&T managers in local offices 

5. A survey of data-processing managers 

We also conducted interviews with representatives of advocacy groups. Table I.2 indicates 

which surveys were used to address each research question. 

a. State Food Stamp Program Director Survey 

In spring and summer 2000, we conducted a telephone survey with staff at the state FSP 

office in all 50 states.5 The purpose of this survey was to collect information about state 

ABAWD policies. The survey included questions on the definition of ABAWDs, the use of 

waivers, the 15 percent exemption, tracking and other administrative issues, and challenges 

posed by the provisions. We asked about the policies in effect in March 2000—the month for 

which we collected data on the number of ABAWDs. The respondents to this survey varied. 

While we suggested that the state FSP director and the manager of local office operations might 

be best able to answer our questions, respondents also included the deputy FSP director or a 

staff-person responsible for ABAWD policy. 

 

5

 As the District of Columbia is completely waived from the ABAWD provisions, most of the questions on this 

survey were not relevant to the District. We did, however, conduct a short interview with a staff member of the FSP 

agency in the District of Columbia to learn how it defines an ABAWD. 
 17 

TABLE I.2 

SOURCES OF DATA TO ADDRESS RESEARCH QUESTIONS ON THE IMPLEMENTATION OF ABAWD 

POLICIES 

Survey of 

State FSP 

Directors 

Survey of 

County FSP 

Administrators 

Survey of 

State E&T 

Managers 

Survey of 

Local E&T 

Managers 

Survey of 

DataProcessing 

Managers 

Form 

FNS-583 

What policy choices have 

states agencies made in 

designing ABAWD 

policies? 

  

To what extent are states 

offering ABAWDs workfare 

and other qualifying work 

progams? 

   

How have the ABAWD 

policies been administered?   

b. County FSP Administrator Survey 

In 15 states, the FSP is administered by the counties rather than the state. In these states, 

some policy decisions are set at the county, rather than at the state, level. To complete our 

information on ABAWD policies in these states, we planned to conduct telephone interviews 

with eight county administrators in any of the 15 states in which important decisions about 

ABAWD policy were made at the county level (Czajka et al. 1999). As it turned out, key 

elements of ABAWD policy were set at the county level in only two states: California and New 

York. In both states, the county determines how “unfit for employment” is defined and decides 

whether and how to use the 15 percent exemption. In California and New York, we conducted 

interviews with eight county FSP administrators, asking questions only about the policies made 

at the county level.6

 The eight counties were randomly selected from a list of all partially waived 

and nonwaived counties in each state. In Alabama and North Carolina, we found that while the 

 

6

 One county in New York refused to participate in the survey. The interview was instead conducted with a 

member of the FNS regional office familiar with the ABAWD policy in that county. 
 18 

state sets most aspects of ABAWD policy, the counties determine some aspects of the definition 

of unfit for employment. Since we did not consider these responsibilities to involve major policy 

decisions, we conducted two, rather than eight, county interviews in those states. In the 

remaining 11 states where the FSP is county-administered, the state agency sets all the key 

elements of ABAWD policy. 

c. State E&T Managers Survey 

In summer 1999, HSR conducted a telephone survey of state E&T managers in all 50 states 

and the District of Columbia. The instrument for the survey was developed jointly by MPR and 

HSR for both this study and another study funded by the ERS. In this study, we used 

information from questions directed to E&T managers about the amount and types of qualifying 

work activities offered to ABAWDs in the state, policies related to these activities, and 

challenges in offering these activities to ABAWDs. 

d. Local E&T Managers Survey 

In spring and summer 2000, HSR conducted a telephone survey of E&T managers at local 

offices. The purpose of this survey was to obtain from staff who work directly with the 

ABAWD population some information about the effectiveness of different work activities in 

assisting ABAWDs and about the challenges involved in serving this population. This survey 

asked about qualifying work activities offered to ABAWDs in the office itself, policies related to 

the provision of these activities, and the perceived effectiveness of each type of activity in 

assisting ABAWDs. Some state FSP agencies contract with other public or private agencies to 

provide E&T services to FSP participants. In these states, we often interviewed an appropriate 

staff member at the relevant agency instead of the local food stamp office. 

We sampled the local offices for this survey in two stages. First, we selected two counties 

(eight counties in California and New York because we were also interviewing eight county 
 19 

administrators) from a list of all nonwaived counties in each state. We selected each county with 

a probability proportional to the number of FSP participants who did not receive public 

assistance (NPA clients). Given that most ABAWDs do not receive public assistance, the 

sampling procedure ensured that we were more likely to select counties with larger ABAWD 

populations. Second, we confirmed with the state agency that the county does provide E&T 

services to ABAWDs, and we then randomly selected a local office within the county. Again, 

we selected the local office with the probability of selection proportional to the number of NPA 

clients in that office so that we disproportionately selected local offices with larger ABAWD 

populations. We favored counties with larger ABAWD populations because of their greater 

experience in dealing with ABAWDs (many counties see very few ABAWDs).7

 In six states, 

MPR selected one or more of the counties that did not provide E&T services. For those states, 

we randomly selected replacement counties. 

We sampled local offices in all but the following four states: 

• Arkansas and Illinois. In these states, all ABAWDs who become ineligible for 

failing to meet the work requirement are exempted from the time limit under the 15 

percent exemption. 

• Kansas and Oklahoma. These states did not provide any E&T services to ABAWDs. 

We also did not sample local offices in the District of Columbia, which is totally waived from 

the ABAWD provisions. We sampled a total of 103 local offices: eight each in California and 

New York, one in Rhode Island, and two in each of the remaining 43 states. In Rhode Island 

only one local office provides E&T services to ABAWDs. 

 

7 Two randomly selected, small counties had fewer than 10 ABAWDs. As they had so few ABAWDs, we 

randomly selected different counties to replace them. 
 20 

We completed 94 interviews out of the 103 sampled offices for a response rate of 91 

percent. Two states and two counties in New York refused to participate in the survey, and we 

were unable to schedule interviews in another three counties. After completing the interviews, 

we found that one sampled local office did not provide any E&T services. Hence, we report 

information from 93 local offices. 

e. Data Processing Manager Survey 

Several questions on the tracking of ABAWDs’ use of time-limited benefits were included 

in the State FSP Director Survey, but the best person to provide information on the tracking of 

time-limited benefits is often the data processing manager. Hence, we included a short 

questionnaire for data processing managers about tracking in our mailing of the data request. We 

received completed questionnaires from all 50 states and the District of Columbia. 

f. Interviews with Representatives of Advocacy Groups 

We conducted structured interviews with representatives of about a dozen advocacy groups 

at the state level, primarily, to obtain their perspective on the ABAWD provisions. We discussed 

a wide range of issues including the steps the advocacy community has taken on behalf of 

ABAWDs, the effectiveness of the policy in helping ABAWDs seek and find employment, how 

the target population has responded to the provisions, how well this population understands the 

ABAWD provisions, the challenges that serving this population presents, and how the 

effectiveness of the policy might be improved. 

E. ORGANIZATION OF THE REPORT 

The rest of the report is organized as follows. The next chapter presents estimates of the 

number and characteristics of ABAWDs. State choices in implementing ABAWD policies are 

described in Chapter III. Chapter IV discusses policies related to meeting the work requirement 
 21 

and the extent to which ABAWDs are offered qualifying work activities. Some issues related to 

the implementation of ABAWD policy are discussed in Chapter V, and Chapter VI summarizes 

our principal conclusions. 
 23 

II. ABAWD PARTICIPANTS IN THE FOOD STAMP PROGRAM: 

NUMBER AND CHARACTERISTICS 

The PRWORA legislation placed limits on the amount of time that ABAWDs could receive 

food stamps unless they were engaged in work or a qualifying work activity. However, 

PRWORA allowed states to waive the time limit in areas with high unemployment or insufficient 

jobs, and later legislation enabled states to exempt a fraction of the participants who would 

otherwise have lost benefits because of the time limit. To begin to understand the full 

implications of the ABAWD provisions, we need to know how many participants are defined as 

ABAWDs, how many of these live in waived versus nonwaived areas, how many of those in 

nonwaived areas are meeting the work requirement, and how many of the remainder are either 

exempt or at risk of using up their time-limited benefits. 

In this chapter, we present estimates of the number and characteristics of FSP participants 

the states defined as ABAWDs and, therefore, potentially subject to the three-month time limit. 

We begin by presenting national estimates of the number of ABAWD participants in the FSP in 

March 2000. Next we present state estimates, which illustrate how the fraction of the population 

that is potentially subject to the time limit varies across jurisdictions. Then we examine the trend 

in ABAWD participation over time and discuss how often FSP participants who were subject to 

the ABAWD time limit were meeting the work requirement and how they were doing so. Next 

we explore some of the characteristics of ABAWD participants who were subject to the time 

limit, how they compare with those of all adult participants, and how participants who were 

meeting the work requirement differ from those who were not. We complete our empirical 

findings with estimates of how many ABAWDs have reached the three-month time limit since 

the ABAWD provisions went into effect and how the number hitting the time limit has changed 

from month to month. We conclude with a summary of our major findings. 
 24 

A. NATIONAL ESTIMATES OF THE NUMBER OF ABAWD PARTICIPANTS 

PRWORA specifies that participants who are 18 to 50 are not subject to the ABAWD time 

limit if they are: 

• Medically certified as physically or mentally unfit for employment 

• Responsible for a dependent child 

• Exempt from the FSP work registration requirement 

• Pregnant 

ABAWDs are those participants who are left after these exclusions. 

If a state applies, gets approval, and implements a federal waiver, ABAWDs who live in 

areas with high unemployment or insufficient jobs, as defined under PRWORA, can be 

exempted from the time limit. For those living in a waived area, none of the benefits that they 

receive count against the three-month limit. 

ABAWDs who live in nonwaived areas are subject to the time limit and must meet the 

ABAWD work requirement to maintain their eligibility for benefits. Any month in which an 

ABAWD recipient fails to satisfy the work requirement counts against his or her three-month 

limit. Some ABAWDs may be given individual exemptions up front under their state’s use of 

the 15 percent waiver authority, but these exemptions are more often used to extend benefits to 

recipients who have already exhausted the three months. 

1. Earlier Estimates 

Previous efforts to estimate the number of ABAWD participants in the FSP relied almost 

exclusively on simulations of ABAWD status based on FSPQC sample data. These simulations 

used age, the receipt of disability benefits, the presence of a child under 18 in the household, and 

exemption from FSP work registration to determine who would have been excluded from the 

ABAWD population, with the remainder being defined as ABAWDs. Applying this 
 25 

methodology, Stavrianos and Nixon (1998) estimated that 941,000 participants per month, on 

average, would have been identified as ABAWDs in FY96 if PRWORA had been in effect at the 

time.1

Researchers continued to use simulation methods to estimate the number of ABAWDs even 

after states implemented the ABAWD time limit. There were three principal reasons for this. 

First, FSPQC data did not directly identify ABAWDs until FY98, so estimates for FY97 had to 

rely on some form of simulation. Second, the ABAWD code field that was introduced in FY98 

had a number of inconsistencies with other variables in the FSPQC data, raising questions about 

its validity (see Castner 2000 and Czajka 2000). Third, applying a consistent simulation 

methodology made it possible to estimate trends in the number of ABAWD participants pre- and 

post-PRWORA. However, the early simulations were developed with little information on state 

policies regarding the operational definition of an ABAWD, so they minimized differences 

among the states and potentially either understated or overstated the national totals. 

Nevertheless, these initial estimates provided an early glimpse into the impact of PRWORA on 

the food stamp caseload and are still useful in documenting trends. 

In preparing a 1998 report, the GAO took a different approach to estimating the number of 

ABAWD participants. GAO staff asked the states how many ABAWD participants they had and 

how many were living in waived versus nonwaived areas. They obtained estimates from all but 

eight, primarily small, states and the District of Columbia. The 42 states reported a monthly 

average of 514,000 ABAWD participants over April, May, and June 1998 (GAO 1998). Of this 

total, 296,000 or about 58 percent were subject to the time limit, 208,000 (40 percent) were 

living in waived areas, and another 9,600 (2 percent) were exempted under the 15 percent 

 

1

 This estimate excludes those legal aliens who are likely to have been made ineligible for food stamps by 

PRWORA. 
 26 

provision. The nonreporting states accounted for about 9 percent of the total food stamp 

caseload, suggesting that they could have added an additional 50,000 ABAWDs to the total if

ABAWDs occurred with the same relative frequency as in the other states. 

This report relies on both methodologies to generate estimates of the number of ABAWDs 

who were participating in the FSP in March 2000. First, we asked the states to report the number 

of ABAWD participants for March 2000. We requested additional information to help determine 

how the ABAWD participants fit into the larger food stamp population, describe some of their 

characteristics, and give us a basis for evaluating state-to-state variation in the numbers. We also 

consulted the state reports submitted to FNS on Form 583. Second, we employed FSPQC data 

from the FY99 and FY00 samples to help us evaluate the data the states gave us and to fill in 

some of the items that individual states could not provide. While the FSPQC data on ABAWDs 

are limited by small sample sizes, the omission of key measures, and other deficiencies that are 

less well understood, they are available for all states and, for most items, reflect well-established 

procedures that have been reviewed at the state and federal levels. 

The data submitted to us by the states have limitations in addition to missing items—mostly 

due to the constraints imposed by state management information systems or the reports that they 

generated. When we determined—often in consultation with state staff—that particular state 

numbers differed conceptually from what we were trying to measure or were inconsistent with 

other state data, we substituted FSPQC data. Our approach to combining these data sources is 

detailed in Appendix B. 

2. ABAWD Participants as Defined Under PRWORA 

ABAWDs constitute a fairly small fraction of the overall FSP population. In March 2000, 

17.2 million people received food stamps in the United States. In that month 422,500 or 2.5 

percent of all participants were ABAWDs (Table II.1). 
 27 

TABLE II.1 

ESTIMATED NUMBER OF ABAWD PARTICIPANTS IN THE FSP, MARCH 2000 

 

Number 

of ABAWD 

Participants 

Percent 

of Total 

ABAWD 

participants 

Percent 

of All FSP 

Participants 

 

Total ABAWD Participants 422,500 100.0 2.5 

ABAWD Participants in Nonwaived Areas 232,000 54.9 1.3 

Subject to the Time Limit 

Excluded Under the 15 Percent Exemption 

215,800 

16,200 

 51.1 

 3.8 

1.3 

0.1 

ABAWD Participants in Waived Areas 190,500 45.1 1.1 

Three factors account for why this figure differs from earlier estimates. First, the number of 

ABAWD participants declined dramatically from 1996 to 2000. Later we document this decline 

with estimates based on simulations like those Stavrianos and Nixon employed. Second, a 

number of states improved their estimates of ABAWD participants after the GAO survey. Third, 

the additional data that we collected from the states and a comparison of the state estimates with 

those obtained from FSPQC data allowed us to refine the state estimates even further. 

Slightly more than one-half of the ABAWDs (55 percent) in March 2000 were living in 

nonwaived areas, and 215,800 of these participants—about 51 percent of all ABAWDs—were 

subject to the three-month time limit. The balance of ABAWD participants in nonwaived areas, 

numbering 16,200 or just 4 percent of the total, were exempted from the time limit under their 

state’s 15 percent waiver authority. The remaining ABAWD participants, numbering 190,500 or 

45 percent of the total, were residents of areas that were waived from the time limits because of 

high unemployment or insufficient jobs. Their future benefit eligibility was not affected in any 

way by whether they worked or participated in work-related activities, although in most states 
 28 

TABLE II.2 

FOOD STAMP PARTICIPANTS EXCLUDED FROM THE ABAWD POPULATION, 

BY REASON, MARCH 2000 

 Number of Percent of 

 Participants Participants 

Reason for Exclusion Excluded Excluded 

 

Total Number of FSP Participants 17,217,600 -- 

Participants Excluded by Age 

 Under 18 8,785,800 51.0 

 Over 50 2,545,000 14.8 

 

Participants Defined as Unable to Work 

 Not Fit for Employment 1,508,700 8.8 

 Responsible for a Dependent Child 3,436,800 20.0 

 Otherwise Exempt from Work Registration 439,800 2.6 

 Pregnant 79,000 0.5 

 

Total Participants Excluded 16,795,000 97.5 

 

SOURCE: Counts provided by the states and supplemental estimates prepared by Mathematica 

 Policy Research, Inc., from FSPQC data. 

they were required to register for work under provisions that predated time limits. ABAWD 

participants who were subject to the time limit accounted for 1.3 percent of the total caseload in 

that month. 

3. Exclusions from the ABAWD Population 

 Age restrictions excluded two-thirds of the food stamp caseload from the ABAWD 

population. In particular, just over one-half (51.0 percent) of the 17.2 million food stamp 

participants in March 2000 were under the age of 18, and 14.8 percent were over 50 (Table II.2). 

The language in PRWORA regarding the upper age limit for ABAWDs was open to 

interpretation. Most states have interpreted “18 to 50” as including people up to their 50th 

birthday, but a few states drew the line at the 51st birthday (see Chapter III). Our estimates of 
 29 

participants age 18 to 50 in Table II.2 and elsewhere in this chapter are consistent with state 

policies. 

The four additional exclusions outlined in the legislation removed nearly a third of all 

participants from the ABAWD population, with responsibility for a dependent child being the 

most important. About 1.5 million or 8.8 percent of all participants were excluded from the 

ABAWD population because they were certified as physically or mentally unfit for employment. 

Another 3.4 million (20.0 percent) were excluded because they were responsible for a dependent 

child. Other than being under 18, this was the single biggest category of exclusions from the 

ABAWD population. After these exclusions, relatively few participants were excluded because 

they were pregnant or exempt from the FSP work registration requirement. 

A participant between the ages of 18 and 50 might qualify to be excluded for more than one 

of these last four reasons. Our estimates reflect a hierarchical assignment, counting a participant 

under the first category for which he or she qualified, based on the order in which the exclusions 

are listed in PRWORA and in Table II.2. In reality, however, few states’ automated systems 

capture all of the exclusions for which a client may qualify, so there is little flexibility to tabulate 

multiple exclusions or to order the exclusions in different ways. To illustrate the incidence of 

multiple exclusions, we analyzed Wisconsin caseload data, which identify pregnant women 

regardless of their other exclusions. Pregnant women accounted for 7.1 percent of all food stamp 

participants 18 to 50, but 0.23 percent had disabilities that prevented them from working, another 

5.99 percent had dependent children, and an additional 0.37 percent were exempt from work 

registration for other reasons. Counting pregnant women under these other categories, which 

preceded pregnancy in the hierarchy of exclusions, meant that only 0.52 percent of Wisconsin 

participants 18 to 50 were excluded solely because they were pregnant. 

To summarize how the exclusions, waivers and exemptions limit the fraction of participants 

subject to the ABAWD time limit, Figure II.1 shows the progression from the total participant 
 30 

FIGURE II.1 

ABAWD PARTICIPANTS IN RELATION TO THE ENTIRE FOOD STAMP CASELOAD, 

MARCH 2000 

All FSP Participants

17,217,600

100.0% FSP Participants Under Age 18

8,785,800

51.0%

FSP Participants Over Age 50

2,545,000

FSP Participants 18 to 50 14.8%

5,886,800

34.2%

In an Area In an Area

With a Waiver Without a Waiver

1,662,100 4,224,700

9.7% 24.5%

Physically or Mentally Physically or Mentally

Unfit for Employment Unfit for Employment

417,300 1,091,400

2.4% 6.3%

Responsible for a Responsible for a

Dependent Child Dependent Child

915,300 2,521,500

5.3% 14.6%

Otherwise Exempt from Otherwise Exempt from

Work Registration Work Registration

119,500 320,300

0.7% 1.9%

Pregnant Pregnant

19,500 59,500

0.1% 0.3%

ABAWDs in ABAWDs in

Waived Areas Nonwaived Areas

190,500 232,000

1.1% 1.3%

ABAWDs Exempt

Under 15 Percent Exemption

16,200

0.1%

ABAWDs Subject to the

Time Limit

215,800

1.3%

SOURCE: Counts provided by the states and supplemental estimates prepared by Mathematica Policy Research, Inc., from FSPQC data.
 31 

caseload, at the top, to the small subset of participants who were subject to the ABAWD time 

limit, in the lower right-hand corner. Expanding upon the breakdown in Table II.2, the figure 

divides the population of 18- to 50-year-old food stamp recipients into those residing in 

nonwaived areas and those residing in waived areas before applying the four additional 

exclusions. As we will show later, this division is useful for examining the impact of waivers on 

ABAWD participation in the FSP and for comparing states with respect to the relative frequency 

of ABAWDs in their client populations. 

It is particularly noteworthy that ABAWDs accounted for a greater share of all participants 

18 to 50 in waived areas than in nonwaived areas. This is evident from the counts reported in 

Figure II.1 but shown more explicitly in Table II.3. ABAWD participants were 11.5 percent of 

all participants 18 to 50 in waived areas compared with only 5.5 percent in nonwaived areas—a 

difference of two to one. 

What accounts for this difference? There are three potentially important reasons. First, 

ABAWD participants in waived areas are not subject to termination if they fail to meet the work 

requirement. The lower percentage of ABAWD participants in nonwaived versus waived areas 

represents, in part, the cumulative impact of the time limit. Many of the areas that were waived 

in March 2000 had been waived since the ABAWD provisions first went into effect, so there 

have been no terminations due to the time limit. In other areas, the waivers are more recent. 

Participants may have been terminated earlier in these areas, but they are allowed to return to the 

program, and no additional terminations will occur as long as the waivers are in effect. 

Second, the identification of ABAWD participants in waived areas may be less accurate 

than it is in nonwaived areas. In waived areas, there are no consequences associated with 

meeting the ABAWD definition, so the information requested of and provided by clients may 

understate the actual prevalence of circumstances that would qualify them to be excluded from 
 32 

TABLE II.3 

COMPARATIVE FREQUENCY OF ABAWD PARTICIPANTS IN WAIVED AND 

NONWAIVED AREAS, MARCH 2000 

 Areas Areas 

 without with All 

Participant Subgroup Waivers Waivers Areas 

 

 

ABAWD Participants Including the 15 Percent Exempt 232,000 190,500 422,500 

All FSP Participants 18 to 50 4,224,700 1,662,100 5,886,800 

ABAWD Participants As a Percentage of 5.5% 11.5% 7.2% 

 All Participants 18 to 50 

 

SOURCE: Counts provided by the states and supplemental estimates prepared by Mathematica Policy Research, Inc. 

 from FSPQC data. 

the ABAWD population. With fewer exclusions, a higher proportion of the population would be 

classified as ABAWD. 

Third, nonwaived areas generally have stronger economies than waived areas. ABAWDs’

participation in the labor force is likely to be more responsive to changes in the local economy 

than that of other clients (for example, elderly or disabled clients). Compared to ABAWDs in 

waived areas, then, ABAWDs in nonwaived areas may be more likely to find employment that 

would increase their income sufficiently to move them out of eligibility for the FSP. 

4. Additional Participants at Risk of Using Time-limited Benefits 

PRWORA excludes from the ABAWD population those Program participants who are 

exempt from the FSP work registration requirement. However, it is reasonable, for some 

analyses, to consider a portion of this group along with ABAWDs as being at risk of using timelimited benefits. Of particular interest are individuals exempted from the work registration 

requirement because they are complying with Social Security or Unemployment Compensation 

work requirements, attending school or training programs, working at least 30 hours per week, or 
 33 

earning the equivalent of 30 times the minimum wage. What separates these participants from 

ABAWDs, statutorily, is simply their specific types—or quantities—of work activity. Without 

these or other qualifying work activities, they would be using up time-limited benefits. 

There are a number of reasons why policymakers might want to consider at least some of 

these participants in common with the ABAWD population. First, some of them are in fact 

meeting the ABAWD work requirement, and taking them into account gives a more accurate 

representation of how many able-bodied adult participants without dependents are doing so. 

Second, the distinction between meeting the ABAWD work requirement and not being subject to 

it by virtue of meeting other work requirements is unimportant from an administrative 

standpoint. Administrative systems may not track with much accuracy the movement of 

participants between one status and the other. Third, participants working 30 hours or more or 

complying with other work requirements are at risk of losing their FSP benefits if their hours 

fall. A more complete estimate of participants who would be at risk of losing benefits if the 

economy weakened would include these individuals. 

The number of participants who would be subject to the ABAWD time limit if they were not 

meeting other work requirements is non-trivial. Figure II.1 shows that a fairly large number of 

participants, especially in nonwaived areas, were excluded from the ABAWD population solely 

because they were exempt from FSP work registration. In fact, in nonwaived areas this group is 

larger than the number subject to the ABAWD time limit. The two most common reasons for 

exemption from work registration among participants who would otherwise be classified as 

ABAWDs were employment or meeting the work requirement of another program (Table II.4). 

More than a third (35.8 percent) of these participants in nonwaived areas and nearly half (44.3 

percent) in waived areas were working at least 30 hours per week or earning at least 30 times the 

minimum wage. Another 28.3 percent in nonwaived areas and 13.5 percent in waived areas were 

meeting the work requirements under another program. Other reasons for exemption from the 
34 

TABLE II.4 

ABLE-BODIED PARTICIPANTS 18 TO 50 WITHOUT DEPENDENTS WHO ARE EXCLUDED FROM THE 

ABAWD POPULATION BECAUSE THEY ARE EXEMPT FROM WORK REGISTRATION, BY REASON 

Nonwaived Areas Waived Areas 

Reason for Exemption from Work Registration Number Percent Number Percent Num Total 320,300 100.0 119,500 100.0 439Working 30 hours or more per week 114,700 35.8 52,900 44.3 167 or earning 30 times the minimum wageMeeting work requirements 90,500 28.3 16,100 13.5 106 under another programStudent meeting the requirements 25,700 8.0 11,600 9.7 37 for FSP eligibilityResponsible for caring for an 23,200 7.2 6,100 5.1 29 incapacitated personParticipating in a drug addiction 21,200 6.6 6,600 5.5 27 or alcohol treatment programOthera 45,000 14.0 26,200 21.9 71

SOURCE: Counts provided by the states and supplemental estimates prepared by Mathematica Policy Research, Inc., from FSPQC data.a Reasons often not specified but may include barriers to employment, such as a lack of transportation; the unavailability of E&T services in  or a temporary absence from employment.
 35 

work requirement—attending school, caring for an incapacitated person, participating in a 

treatment program—were much less common. 

Policymakers might want to include those additional participants with work registration 

exemptions for working or meeting the work requirement of another program when estimating 

the number of ABAWD participants generally or the number engaged in work or work activity. 

Doing so would add 205,000 to the March 2000 count of ABAWD participants in nonwaived 

areas, representing a nearly 90 percent increase. In waived areas the impact would be smaller—

both numerically and as a proportion of the ABAWD population. Participants with work 

registration exemptions for work or work activity totaled about 69,000 in March 2000 or about 

one-third the number in nonwaived areas. This is consistent with the relative number of 18 to 50 

year-old participants in these areas, with waived areas having about one-third as many as 

nonwaived areas. But because ABAWDs are a larger share of adult participants in waived 

versus nonwaived areas, the proportionate impact would be smaller as well. The number of 

ABAWD participants in waived areas would be increased by about 36 percent compared to the 

nearly 90 percent increase in nonwaived areas. 

B. STATE ESTIMATES OF THE NUMBER OF ABAWD PARTICIPANTS 

The states show considerable variation in the total number of Program participants identified 

as ABAWDs (including both waived and nonwaived areas) and the number of these who are 

subject to the ABAWD time limit—that is, living in nonwaived areas and not covered by a 15 

percent exemption. While differences in population size account for most of this variation, two 

other factors play roles as well. First, as we will explore in Chapter III, states have made policy 

choices that affect what proportion of their food stamp participants meet the criteria that define 

an ABAWD. Second, the use of waivers reduces the number of ABAWDs who are subject to 
 36 

the time limit but also appears to increase the total number of ABAWD participants in a state—

by limiting the cumulative effect of the time limit. 

Table II.5 reports state estimates of ABAWD participants in the FSP in March 2000. The 

total number of ABAWD participants in each state is disaggregated into those who were subject 

to the time limit, those who were living in nonwaived areas but were covered by a 15 percent 

exemption, and those who were living in waived areas. 

The total number of ABAWDs in each state varied across a broad range. Five states—

California, Illinois, New York, Pennsylvania, and Texas—had more than 25,000 ABAWD 

participants while another eight states had more than 10,000. At the bottom end, eight states had 

fewer than 1,000 ABAWD participants while 29 states and D.C. had between 1,000 and 10,000. 

Estimates of the number of ABAWD participants who were subject to the time limit show the 

substantial impact of waivers and the lesser impact of 15 percent exemptions. Twenty states had 

more ABAWDs in waived areas than ABAWDs subject to the time limit, but only four states 

applied the 15 percent exemption to more than half their ABAWDs in nonwaived areas.2,3 

Altogether 18 states had fewer than 1,000 ABAWD participants who were subject to the time 

limit while only five states had more than 10,000. Notably, more than one in four of the nation’s 

ABAWDs who were subject to the time limit lived in California, which had no waived areas in 

March 2000. 

 

2

 Illinois and Arkansas use the 15 percent exemption to exempt all ABAWDs living in areas that are not 

covered by waivers (in both states, most of the ABAWD population is waived). Both states apply the 15 percent 

exemption, correctly, to just those ABAWDs in nonwaived areas who are not meeting the work requirement, but in 

reality no one in either state must comply with the ABAWD work requirement as a condition for continued receipt 

of benefits. For this reason, in Table II.5 we have included in the 15 percent exemption column all Illinois and 

Arkansas ABAWDs who were living in nonwaived areas. 

3

 Missouri and Tennessee use the 15 percent exemption to extend two additional months of time-limited 

benefits to those ABAWDs who need them, effectively changing the time limit from three months to five months 

(see Chapter III). Those who receive the additional months of benefits remain subject to the time limit, and this is 

how we count them in Table II.5. Neither state reported estimates of the number of ABAWDs who were receiving 

their fourth or fifth month of time-limited benefits. 
 37 

TABLE II.5 

ESTIMATED NUMBER OF ABAWD PARTICIPANTS BY STATE, MARCH 2000 

ABAWDs in Nonwaived Areas

ABAWDs

ABAWDs Excluded ABAWDs

Subject to Under the in

the Time 15 Percent Waived

State Total Limit Exemption Areas

 U.S. Total 422,500 215,800 16,200 190,500

Alabama 4,241 2,302 0 1,939

Alaska 1,440 573 7 860

Arizona 13,406 * 7,029 240 6,137 *

Arkansas 9,562 * 0 3,240 * 6,322 *

California 55,614 55,358 256 0

Colorado 2,058 1,707 77 274

Connecticut 8,073 * 370 * 475 7,228 *

Delaware 672 * 672 * 0 0

District of Columbia 6,907 * 0 0 6,907 *

Florida 8,993 1,688 700 6,605

Georgia 10,405 2,664 1 7,740

Hawaii 2,689 * 1,353 31 1,305 *

Idaho 276 * 216 60 0 *

Illinois 34,422 0 4,571 29,851

Indiana 2,518 1,806 11 701

Iowa 1,388 1,388 0 0

Kansas 2,611 2,174 437 0

Kentucky 13,693 * 2,694 670 10,329 *

Louisiana 15,210 1,337 865 13,008

Maine 719 * 222 42 455 *

Maryland 5,551 1,180 149 4,222

Massachusetts 2,469 * 2,159 * 310 0

Michigan 16,644 16,644 0 0

Minnesota 5,822 4,282 102 1,438

Mississippi 1,460 1,160 300 0

Missouri 5,981 * 4,376 * 118 1,487 *

Montana 1,266 * 581 * 0 685 *

Nebraska 825 * 674 * 111 40 *

Nevada 999 774 9 216

New Hampshire 94 * 52 * 42 0

New Jersey 8,208 1,339 194 6,675

New Mexico 2,564 1,073 0 1,491

New York 28,029 25,413 495 2,121

North Carolina 6,681 * 5,348 * 1,333 0

North Dakota 597 * 404 0 193 *

Ohio 10,844 10,844 0 0

Oklahoma 4,081 4,081 0 0

Oregon 8,303 8,072 231 0

Pennsylvania 33,176 3,777 222 29,177

Rhode Island 1,769 286 0 1,483

South Carolina 4,173 2,077 455 1,641

South Dakota 1,279 * 400 0 879 *

Tennessee 10,534 * 3,447 * 0 7,087 *

Texas 35,531 16,435 0 19,096

Utah 1,014 * 952 * 6 56 *

Vermont 1,628 1,381 1 246

Virginia 12,761 7,801 0 4,960

Washington 4,891 * 3,604 371 916 *

West Virginia 7,668 967 20 6,681

Wisconsin 2,225 2,225 0 0

Wyoming 557 * 472 0 85 *

SOURCE: Counts provided by the states and supplemental estimates prepared by Mathematica Policy

 Research, Inc., from FSPQC and Form FNS 583 data.

* Denotes sample estimate. Estimates for Texas are based on an administrative file containing approximately

 70 percent of the full March caseload and have been adjusted accordingly.
 38 

From another perspective, there were also substantial differences among the states in the 

proportion of participants age 18 to 50 who were subject to the ABAWD time limit. Nationally, 

this proportion was 3.7 percent in March 2000 (Table II.6). Among the states, it varied from a 

low of 0 percent in Arkansas, D.C., and Illinois to a high of 9.6 percent in California. Altogether 

four states had proportions that were more than twice the national average while 20 states had 

proportions that were less than half the national average. 

Consistent with the national pattern, in nearly every state with waived areas, the proportion of 

18- to 50-year-old participants in those areas who were identified as ABAWDs was markedly 

larger than the proportion of 18- to 50-year-olds identified as ABAWDs in nonwaived areas 

(Table II.7). Of the 36 states with waived areas, only two—New York and Washington—had 

smaller ratios of ABAWD participants to all participants 18 to 50 in their waived versus 

nonwaived areas.4

Nevertheless, the proportion of 18- to 50-year-olds identified as ABAWDs varied across a 

broad range within the waived and nonwaived areas. In nonwaived areas, the percentage of all 

participants 18 to 50 who were identified as ABAWDs varied from less than 2 percent in the 

lowest six states (Florida, Idaho, Indiana, Maine, Mississippi, and New Hampshire) to more than 

8 percent in the top six (Arizona, Arkansas, California, Oregon, Vermont, and Virginia). In 

waived areas, the fraction of participants 18 to 50 who were identified as ABAWDs varied from 

5 percent or less in the lowest six states (Florida, Maine, New Mexico, New York, Utah, and 

Washington) to nearly 20 percent or more in the top four states (Arizona, D.C., Minnesota, and 

Virginia). While the fractions in waived areas vary across a broader range than the fractions in 

nonwaived areas, the two distributions have the same spread when we correct for their different 

 

4

 We exclude D.C. because it was entirely waived. 
 39 

TABLE II.6 

ABAWD PARTICIPANTS SUBJECT TO THE TIME LIMIT AS A PERCENTAGE 

OF ALL PARTICIPANTS 18 TO 50, BY STATE, MARCH 2000 

ABAWDs in Nonwaived Areas

ABAWDs

ABAWDs Excluded ABAWDs

Subject to Under the in

the Time 15 Percent Waived

State Total Limit Exemption Areas

 U.S. Total 422,500 215,800 16,200 190,500

Alabama 4,241 2,302 0 1,939

Alaska 1,440 573 7 860

Arizona 13,406 * 7,029 240 6,137 *

Arkansas 9,562 * 0 3,240 * 6,322 *

California 55,614 55,358 256 0

Colorado 2,058 1,707 77 274

Connecticut 8,073 * 370 * 475 7,228 *

Delaware 672 * 672 * 0 0

District of Columbia 6,907 * 0 0 6,907 *

Florida 8,993 1,688 700 6,605

Georgia 10,405 2,664 1 7,740

Hawaii 2,689 * 1,353 31 1,305 *

Idaho 276 * 216 60 0 *

Illinois 34,422 0 4,571 29,851

Indiana 2,518 1,806 11 701

Iowa 1,388 1,388 0 0

Kansas 2,611 2,174 437 0

Kentucky 13,693 * 2,694 670 10,329 *

Louisiana 15,210 1,337 865 13,008

Maine 719 * 222 42 455 *

Maryland 5,551 1,180 149 4,222

Massachusetts 2,469 * 2,159 * 310 0

Michigan 16,644 16,644 0 0

Minnesota 5,822 4,282 102 1,438

Mississippi 1,460 1,160 300 0

Missouri 5,981 * 4,376 * 118 1,487 *

Montana 1,266 * 581 * 0 685 *

Nebraska 825 * 674 * 111 40 *

Nevada 999 774 9 216

New Hampshire 94 * 52 * 42 0

New Jersey 8,208 1,339 194 6,675

New Mexico 2,564 1,073 0 1,491

New York 28,029 25,413 495 2,121

North Carolina 6,681 * 5,348 * 1,333 0

North Dakota 597 * 404 0 193 *

Ohio 10,844 10,844 0 0

Oklahoma 4,081 4,081 0 0

Oregon 8,303 8,072 231 0

Pennsylvania 33,176 3,777 222 29,177

Rhode Island 1,769 286 0 1,483

South Carolina 4,173 2,077 455 1,641

South Dakota 1,279 * 400 0 879 *

Tennessee 10,534 * 3,447 * 0 7,087 *

Texas 35,531 16,435 0 19,096

Utah 1,014 * 952 * 6 56 *

Vermont 1,628 1,381 1 246

Virginia 12,761 7,801 0 4,960

Washington 4,891 * 3,604 371 916 *

West Virginia 7,668 967 20 6,681

Wisconsin 2,225 2,225 0 0

Wyoming 557 * 472 0 85 *

SOURCE: Counts provided by the states and supplemental estimates prepared by Mathematica Policy

 Research, Inc., from FSPQC and Form FNS 583 data.

* Denotes sample estimate. Estimates for Texas are based on an administrative file containing approximately

 70 percent of the full March caseload and have been adjusted accordingly.
 40 

TABLE II.7 

COMPARATIVE FREQUENCY OF ABAWD PARTICIPANTS IN WAIVED AND NONWAIVED AREAS, 

BY STATE, MARCH 2000 

Nonwaived Areas Waived Areas

Number Percent of Number Percent of

of Participants of Participants

State ABAWDs 18 to 50 ABAWDs 18 to 50

 U.S. Total 232,000 5.5 190,500 11.5

Alabama 2,302 2.3 1,939 6.1

Alaska 580 6.0 860 13.4

Arizona 7,269 13.8 6,137 * 20.0

Arkansas 3,240 8.7 6,322 * 13.1

California 55,614 9.6 0 --

Colorado 1,784 4.3 274 18.2

Connecticut 845 * 4.9 7,228 * 15.8

Delaware 672 * 5.5 0 --

District of Columbia 0 -- 6,907 * 22.5

Florida 2,388 1.9 6,605 5.0

Georgia 2,665 2.5 7,740 10.5

Hawaii 1,384 4.6 1,305 * 9.4

Idaho 276 1.5 0 * --

Illinois 4,571 4.7 29,851 15.3

Indiana 1,817 1.8 701 7.2

Iowa 1,388 2.9 0 --

Kansas 2,611 6.0 0 --

Kentucky 3,364 4.6 10,329 * 12.0

Louisiana 2,202 3.4 13,008 13.9

Maine 264 1.4 455 * 2.7

Maryland 1,329 3.9 4,222 9.6

Massachusetts 2,469 * 3.0 0 --

Michigan 16,644 7.1 0 --

Minnesota 4,384 6.7 1,438 24.3

Mississippi 1,460 1.8 0 --

Missouri 4,494 * 3.5 1,487 * 5.7

Montana 581 * 3.8 685 * 7.5

Nebraska 785 * 2.7 40 * 5.7

Nevada 783 4.2 216 11.9

New Hampshire 94 * 0.7 0 --

New Jersey 1,533 5.6 6,675 8.7

New Mexico 1,073 3.8 1,491 4.9

New York 25,908 6.2 2,121 3.3

North Carolina 6,681 * 3.9 0 --

North Dakota 404 4.2 193 * 12.7

Ohio 10,844 5.0 0 --

Oklahoma 4,081 4.8 0 --

Oregon 8,303 8.6 0 --

Pennsylvania 3,999 4.0 29,177 14.5

Rhode Island 286 2.4 1,483 9.2

South Carolina 2,532 3.7 1,641 5.4

South Dakota 400 3.8 879 * 14.2

Tennessee 3,447 * 2.9 7,087 * 12.8

Texas 16,435 6.0 19,096 13.9

Utah 958 * 3.4 56 * 4.7

Vermont 1,382 9.1 246 16.0

Virginia 7,801 8.5 4,960 19.7

Washington 3,975 5.7 916 * 2.1

West Virginia 987 3.3 6,681 9.9

Wisconsin 2,225 3.5 0 --

Wyoming 472 6.0 85 * 7.5

SOURCE: Counts provided by the states and supplemental estimates prepared by Mathematica Policy

 Research, Inc., from FSPQC data.

* Denotes sample estimate. Estimates for Texas are based on an administrative file containing approximately

 70 percent of the full March caseload and have been adjusted accordingly.
 41 

mean values. A common statistic for expressing the variability of a distribution in a uniform 

metric, the “coefficient of variation,” calculated by dividing the standard deviation of a 

distribution by its mean, yields the same value for both distributions (.5). 

Several factors may contribute to these state-to-state differences in the relative frequency of 

ABAWD participants in the 18 to 50 population within waived and nonwaived areas. State 

policies regarding the definition of ABAWDs and how states implement their policies will 

account for a portion of these differences. Variation in the demographic characteristics and 

health of the population, by affecting who is potentially eligible to be exempted, will contribute 

to the differences as well. In nonwaived areas, the relative number of ABAWD participants may 

be affected by the extent to which ABAWDs are able to meet the work requirement and how

they are able to do so. Other things being equal, as the proportion of ABAWDs who meet the 

work requirement rises, the proportion using up their time-limited benefits falls. State-to-state 

variation in economic conditions will contribute to variation in the proportion of ABAWDs 

meeting the work requirement through employment while variation in the availability of 

qualifying work activities will affect the proportion of ABAWDs who can meet the work 

requirement without finding employment. Finally, sampling error affects some of the estimates, 

and measurement error in the identification or counting of ABAWDs affects potentially many 

more. Subsequent chapters will discuss some of these issues in greater detail. 

C. TRENDS IN PARTICIPATION OVER TIME 

While the ABAWD provisions were expected to have a direct, downward impact on the 

number of food stamp participants who are ultimately subject to them, they were implemented in 

an environment in which other major changes were taking place, including, most importantly, 

welfare reform and an expanding economy. A decline in FSP participation was well under way 

before the ABAWD provisions took effect, heralding the end of an unprecedented period of 
42 

FIGURE II.2 

NUMBER OF PARTICIPANTS IN THE FOOD STAMP PROGRAM, 

OCTOBER 1988 THROUGH SEPTEMBER 2000 

14,00016,00018,00020,00022,00024,00026,00028,00030,000

1988

1989

1990

1991

1992

1993

1994

1995

1996

1997

1998

1999

Calendar Year

Thousands of Participants

SOURCE: FNS Program Operations data. 
 43 

growth in the food stamp caseload. Caseloads peaked in March 1994 following a steep rise that 

began in late 1989 (Figure II.2). From a zenith of 28 million, the number of participants in the 

United States dropped by more than 4 million—a reduction of 15 percent—before the ABAWD 

provisions went into effect in November and December of 1996. The rate of decline began to 

slow in late 1997, and by early 1999 the number of participants dropped below the level of 10 

years earlier, completing a remarkable turnaround. The participation figures through late 2000 

suggest that the decline has run its course. The earlier, dramatic downward movement in FSP 

participation and the more gradual leveling off in recent years provide an important context in 

which to view trends in ABAWD participation over time. We offer, here, an assessment of how 

much the number of ABAWD participants is likely to have increased or decreased in the absence 

of PRWORA. 

Using data collected as part of the annual QC sample, we simulated the national ABAWD 

population as participants who were: 

• Above the age of 17 and under the age of 50 

• Neither receiving disability benefits nor exempt from FSP work registration 

• Members of a food stamp household containing no children under 18 

A second simulation modified this last criterion to exclude only one adult member in households 

with children—as some states have done. This approach yields a higher number of ABAWDs 

that falls closer to our March 2000 estimate than does the first approach. To reduce the impact 

of sampling error, we calculated three-month moving averages, which are assigned to the middle 

month of each triplet. For example, the December 1996 figure is an average of the November 

1996, December 1996, and January 1997 estimates. 

Figure II.3 shows the trend in the number of simulated ABAWD food stamp participants 

from October 1994 through September 2000. The two simulations show little change through 
44 

FIGURE II.3 

ALTERNATIVE SIMULATIONS OF ABAWD PARTICIPANTS IN THE FOOD STAMP PROGRAM, 

OCTOBER 1994 THROUGH SEPTEMBER 2000 

0

200,000400,000600,000800,000

1,000,0001,200,0001,400,000

1994

1995

1996

1997

1998

1999

Calendar Year

3-month Moving Average Number of Participants

Excluding only 1 adult in a household with children Excluding all adults in a household with 

SOURCE: Mathematica Policy Research, Inc., from FSPQC data. 
 45 

about mid-1995 but then display a consistent, if slow, decline, falling by about 17 percent over 

the next 18 months, before the ABAWD provisions went into effect. The number of ABAWD 

participants then fell by about 40 percent over the next 12 months, or between 300,000 and 

400,000 depending on the simulation. Much of that decline occurred during the initial two to 

three months of ABAWD terminations, beginning in February 1997.5

 From October 1997 the 

decline continued at a considerably reduced pace for another 12 to 24 months, depending on the 

series. Since late 1998 (lower series) or late 1999 (upper series) the decline appears to have 

ceased altogether. 

In late 1999, 36 months after the ABAWD provisions were implemented, most of the 

ABAWDs who used up their time-limited benefits during the initial implementation of the 

ABAWD provisions would have regained eligibility.6 Yet Figure II.3 provides no indication that 

these earlier participants returned to the program as ABAWDs. Where have they gone? Has 

there been no recurrence of their earlier needs for food assistance, or have their needs been 

addressed in some other manner? Have they changed their status such that they are no longer 

counted as ABAWDs, or have they simply become discouraged with the FSP and chosen not to 

return? These are important questions to address if we are to understand the full impact of the 

ABAWD provisions, but this study was not intended to answer them. 

Whatever may have happened to the ABAWD population after 1999, there is clear evidence 

that the ABAWD participant population experienced a much greater decline up to that point than 

 

5

 With three-month moving averages, the February 1997 caseloads contribute to the January, February, and 

March estimates. In other words, the estimates lead the actual caseload changes by one month. 

6

 Regardless of whether a state elected to use a fixed clock or a rolling clock to define the 36-month period (see 

Chapter III), participants who used up their time-limited benefits three months after the ABAWD provisions went 

into effect would have started a new 36-month clock and become eligible, once again, for three months of benefits in 

November or December 1999. 
 46 

the entire food stamp caseload. Figure II.4 compares the recent trends among all FSP 

participants and ABAWD participants (based on the higher simulated number), with each series 

expressed as a percentage of its October 1994 level.7

 Thus the two series begin at a common 

point (100 percent) but then diverge. Even before the ABAWD provisions went into effect in 

November and December 1996, the ABAWD participant population showed evidence of a 

slightly more rapid rate of decline than the all-participants series. With the implementation of 

the ABAWD provisions, the ABAWD series began to decline much more steeply than the allparticipants series, and it continued to do so for about a year. By the end of 1998, the number of 

ABAWD participants had dropped to barely more than 40 percent of the October 1994 level 

while the all-participants series fell to about 75 percent of the October 1994 level. The rate of 

decline in the ABAWD series then slowed to a level that roughly matched the continuing rate of 

decline in the all-participants series. The ABAWD series appears to have stopped declining 

before the all-participants series, but by late 2000, both series appear to have bottomed out, with 

the all- participants series standing at 62 percent of its October 1994 level and the ABAWD 

series at about 36 percent of its October 1994 level. 

Based on the rate at which the decline in the ABAWD caseload accelerated when the 

ABAWD provisions went into effect, we would infer that the ABAWD provisions clearly 

contributed to a net reduction in the number of ABAWDs participating in the FSP. However, 

this reduction occurred during a time when the overall number of FSP participants was also 

declining at an accelerated rate. While the number of ABAWD participants dropped from about 

80 percent of its October 1994 level to less than 50 percent of the October 1994 level—a 40 

percent decline—over the 12-month period from late 1996 through late 1997, there was a 15 

 

7

 Both of the participation series are expressed as three-month moving averages. The first month, then, 

represents an average of October, November, and December 1994. 
47 

FIGURE II.4 

ALL PARTICIPANTS AND ABAWD PARTICIPANTS, OCTOBER 1994 TO SEPTEMBER 2000, 

AS A PERCENTAGE OF OCTOBER 1994 LEVEL 

0.0

20.040.060.080.0

100.0120.0

1994

1995

1996

1997

1998

1999

Calendar Year

Percent of October 1994 Level

All Participants ABAWD Participants

SOURCE: FNS Program Operations data and FSPQC sample files, FY95 through FY00. 
 48 

percent decline among all participants during this same period. If ABAWDs resembled FSP 

participants generally in their response to the conditions that produced the decline in the FSP 

caseload, we would expect that in the absence of the ABAWD provisions the number of 

ABAWD participants would have declined by the same 15 percent. But given the evidence of a 

somewhat more rapid rate of decline among ABAWDs before the implementation of these 

provisions, it appears likely that ABAWD participation would have declined by more than 15 

percent over this period even if the ABAWD provisions had not been implemented. This 

suggests that other factors may have caused at least half of the 40 percent decline in the number 

of ABAWD participants the first year. 

D. MEETING THE WORK REQUIREMENT 

ABAWDs who are subject to the time limit may continue to receive benefits if they meet the 

associated work requirement. This can be done by working 20 or more hours per week, 

participating in workfare for the specified number of hours, or by participating for 20 or more 

hours per week in a qualifying work activity. In this section we present both national and state 

estimates of the number and proportion of ABAWD participants subject to the time limit who 

were meeting the work requirement in March 2000. These estimates are disaggregated by the 

ways in which participants were meeting the work requirement. 

1. Previous Research 

There have been few attempts to estimate the fraction of participants subject to the time limit 

who were meeting the work requirement in a given month and, therefore, losing no months of 

eligibility. With data from FY96, the year before PRWORA was implemented, Stavrianos and 

Nixon (1998) estimated that only about 50,000 or barely more than 5 percent of the 941,000 

participants whom they identified as ABAWDs were meeting the work requirement as it was 

later established under PRWORA. Of this number, 44,000 were working 20 or more hours per 
 49 

week, and 6,000 were participating in workfare. Stavrianos and Nixon could not estimate from 

FSPQC data how many additional participants would have met the work requirement through 

other qualifying work activities. Nor could they distinguish between participants in areas that 

were later waived from the time limit and those in areas that became subject to the limit. 

Nevertheless, their findings provide a useful benchmark for later efforts to examine the degree to 

which participants have been able to satisfy the ABAWD work requirement. 

Using data supplied by 24 states, the GAO (1998) estimated that in April, May, and June 

1998 an average of 8,000 ABAWDs held workfare positions and another 15,600 were enrolled in 

other qualifying work activities. These participants accounted for 17 percent of those who were 

subject to the time limit in the 24 states. This estimate excludes those who met the work 

requirement through employment, whom Stavrianos and Nixon (1998) found to be far more 

numerous than those participating in workfare (but at a time when workfare was less common). 

It is likely, then, that the 17 percent figure understates by a substantial margin the proportion of 

those subject to the time limit who were in fact meeting the work requirement, implying an even 

greater increase over the 5 percent fraction estimated by Stavrianos and Nixon with 1996 data. 

Furthermore, the 24 states contributing to the GAO estimate do not include California and New 

York, which account for most of the workfare participation by ABAWDs, as we show below. 

Beginning in October 1998, states that elected to use any of the federal E&T funds 

appropriated for ABAWDs were required to report to FNS each quarter the number of ABAWD 

participants enrolled in education, training, workfare and other work programs, separately for 

waived and nonwaived areas. Because these reports exclude counts of participants meeting the 

work requirement through employment or other qualifying activities not covered by federal E&T 

funds, they provide us with only a lower-bound estimate of the number of ABAWD participants 

in nonwaived areas who were meeting the work requirement. Based on data that all the states 

submitted to FNS on Form 583, the GAO (2001) reported that in FY2000 the average monthly 
 50 

number of ABAWDs subject to the time limits and meeting the work requirement through 

workfare and other work programs was 49,300 and the number meeting the work requirement 

through education and training was 9,200. These findings reflect a substantial increase in the 

use of workfare since the year before PRWORA took effect.8 But as with the earlier GAO 

estimates, they exclude the number of ABAWDs who were meeting the work requirement 

through employment. We address this limitation with our estimates for March 2000. 

2. Number Meeting the Work Requirement 

We would expect state data on the number of ABAWD participants meeting the work 

requirement to be rather strong, given the time limits that states must impose upon those 

participants who fail to meet the requirement. Yet many states were unable to extract this 

information from their state data systems. As a result, we had to rely on a combination of Form 

583 and FSPQC sample data for more than half of the states in order to construct the national 

estimates that we sought (see Appendix B). 

Table II.8 presents by state and for the nation the estimated number of ABAWDs who were 

subject to the time limit and both and number and percentage of these who were meeting the 

work requirement. Nationally, 110,000, or 51 percent, of the 215,800 participants who were 

subject to the ABAWD time limit were meeting the work requirement. This implies that about 

half of the participants who were subject to the time limit were at risk of losing their benefits in 

the next two months unless they started participating in a qualifying work activity. 

The proportion of participants who were meeting the work requirement varied substantially 

across the states. It ranged from a low of 0.5 percent, reported by Maryland, to a high of 100 

percent, reported by Mississippi. Only 12 states lay within 10 percentage points of the national 

 

8

 It is likely that nearly all of the increase over GAO’s 1998 estimate is due to the inclusion of the 26 states that 

were excluded from the earlier estimate—especially California and New York. 
 51 

TABLE II.8 

STATE ESTIMATES OF ABAWD PARTICIPANTS SUBJECT TO THE TIME LIMIT AND MEETING THE 

WORK REQUIREMENT, MARCH 2000 

Number of

ABAWDs Number Percent

Subject to Meeting Meeting

the Time the Work the Work

State Limit Requirement Requirement

 U.S. Total 215,800 110,000 51.0

Alabama 2,302 1,006 * 43.7

Alaska 573 * 238 41.5

Arizona 7,029 * 3,677 52.3

Arkansas 0 0 --

California 55,358 36,308 * 65.6

Colorado 1,707 730 42.8

Connecticut 370 * 123 * 33.2

Delaware 672 * 134 * 19.9

District of Columbia 0 0 --

Florida 1,688 * 563 * 33.4

Georgia 2,664 * 963 * 36.1

Hawaii 1,353 248 18.3

Idaho 216 84 38.9

Illinois 0 0 --

Indiana 1,806 390 21.6

Iowa 1,388 407 * 29.3

Kansas 2,174 443 20.4

Kentucky 2,694 1,295 48.1

Louisiana 1,337 389 * 29.1

Maine 222 48 21.6

Maryland 1,180 6 0.5

Massachusetts 2,159 * 353 * 16.4

Michigan 16,644 3,467 20.8

Minnesota 4,282 946 * 22.1

Mississippi 1,160 * 1,160 * 100.0

Missouri 4,376 * 370 * 8.5

Montana 581 * 394 * 67.8

Nebraska 674 * 181 * 26.9

Nevada 774 64 8.3

New Hampshire 52 * 46 * 88.5

New Jersey 1,339 1,272 * 95.0

New Mexico 1,073 * 17 * 1.6

New York 25,413 23,848 * 93.8

North Carolina 5,348 * 1,659 * 31.0

North Dakota 404 162 40.1

Ohio 10,844 * 1,194 11.0

Oklahoma 4,081 163 4.0

Oregon 8,072 7,637 94.6

Pennsylvania 3,777 * 515 13.6

Rhode Island 286 61 21.3

South Carolina 2,077 1,143 55.0

South Dakota 400 179 44.8

Tennessee 3,447 2,037 59.1

Texas 16,435 8,676 52.8

Utah 952 * 273 * 28.7

Vermont 1,381 444 32.2

Virginia 7,801 4,358 55.9

Washington 3,604 * 897 24.9

West Virginia 967 477 * 49.3

Wisconsin 2,225 721 32.4

Wyoming 472 262 55.5

SOURCE: Counts provided by the states and supplemental estimates prepared by Mathematica Policy

 Research, Inc., from FSPQC data. See Appendix B for details.

* Denotes sample estimate. Estimates for Texas are based on an administrative file containing

 approximately 70 percent of the full March caseload and have been adjusted accordingly.
 52 

average while another 10 states lay within 20 percentage points. With many of the state 

estimates being based at least in part on sample data, however, these estimates tend to overstate 

the true variation around the mean. 

Recall that participants who work more than 30 hours a week or who comply with the work 

requirement of another entitlement program are defined as exempt from food stamp work 

registration and therefore not subject to the ABAWD time limit. We suggested earlier that 

policymakers might be interested in knowing how the number of ABAWD participants and the 

percentage meeting the work requirement in nonwaived areas would change if such persons were 

included. We estimated from the results presented in Tables II.4 and II.8 that including those 

working 30 hours or more would raise the estimated proportion meeting the work requirement to 

68 percent. The work requirements under Unemployment Compensation and Social Security do 

not involve activities, generally, that would satisfy the ABAWD work requirement. Rather, they 

resemble the FSP work registration requirement that all ABAWDs—and many other FSP 

participants—must satisfy even if they do not meet the ABAWD work requirement. But if the 

intent is to estimate what fraction of able-bodied adult FSP participants are avoiding time-limited 

benefits by complying with a work requirement of any kind, then it may be appropriate to 

include these additional participants, which raises the proportion to 75 percent. Counting them, 

instead, as able-bodied adults who are not meeting the ABAWD requirement lowers the 

proportion to 53 percent. Under any of these scenarios, however, the number of Program 

participants who were in fact using up time-limited benefits in March 2000 remains unchanged at 

106,000. 

3. Ways of Meeting the Work Requirement 

Employment was the most common activity by which participants met the work 

requirement, followed by workfare (Table II.9). About 46 percent of participants who were 
 53 

TABLE II.9 

METHOD OF MEETING THE WORK REQUIREMENT: ABAWD PARTICIPANTS SUBJECT 

TO THE TIME LIMIT, MARCH 2000 

Method of Meeting the Work Requirement Number Percent 

 

 Total 110,000 100.0 

Working 20 Hours Per Week 50,600 46.0 

Participating in Workfare 50,400 45.8 

Participating in Education and Training 7,700 7.0 

Participating in Another Qualifying Activity 1,300 1.2 

 

 

SOURCE: Counts provided by the states and supplemental estimates prepared by Mathematica 

 Policy Research, Inc., from FSPQC and Form FNS-583 data. 

subject to the ABAWD time limit and meeting the work requirement were employed for at least 

20 hours per week (but less than 30). Another 46 percent participated in workfare. Just 7 

percent participated in education and training. Finally, 1 percent was engaged in other qualifying 

activities. Only four states—Indiana, Michigan, Nevada and Wisconsin—reported any 

enrollment in this last category, and only Michigan reported an appreciable amount, which 

accounted for nearly all the national total. Michigan identified these other activities as selfinitiated community service, which made up the vast majority of the category, and the former 

JTPA program. 

While workfare was as common as working nationally, ABAWD participants who were 

meeting the work requirement were more likely to be working than participating in workfare in 

all but 10 states (Tables II.10 and II.11). For each state, Table II.10 presents the number of 

ABAWD participants who were both subject to the time limit and meeting the work requirement 

and then breaks down this total by the way in which participants were meeting the work 

requirement. Table II.11 provides a percentage breakdown of the ABAWD participants who 
 54 

TABLE II.10 

STATE ESTIMATES OF ABAWD PARTICIPANTS MEETING THE WORK REQUIREMENT, BY METHOD, 

MARCH 2000 

Percent Meeting the Work Requirement, by Method

Number

Meeting Education Other

the Work and Qualifying

State Requirement Working Workfare Training Activity

 U.S. Total 110,000 46.0 45.8 7.0 1.2

Alabama 1,006 * 45.0 * 55.0 0.0 0.0

Alaska 238 75.2 * 24.8 0.0 0.0

Arizona 3,677 94.5 5.5 0.0 0.0

Arkansas 0 -- -- -- --

California 36,308 * 33.6 * 61.3 5.1 0.0

Colorado 730 7.1 68.1 24.8 0.0

Connecticut 123 * 63.4 * 12.2 24.4 0.0

Delaware 134 * 98.5 * 1.5 0.0 0.0

District of Columbia 0 -- -- -- --

Florida 563 * 74.4 * 19.7 5.9 0.0

Georgia 963 * 79.5 * 17.9 2.6 0.0

Hawaii 248 98.0 * 0.0 2.0 0.0

Idaho 84 23.8 * 75.0 1.2 0.0

Illinois 0 -- -- -- --

Indiana 390 39.0 0.0 43.3 17.7

Iowa 407 * 100.0 * 0.0 0.0 0.0

Kansas 443 100.0 0.0 0.0 0.0

Kentucky 1,295 56.5 0.0 43.5 0.0

Louisiana 389 * 87.4 * 11.3 1.3 0.0

Maine 48 85.4 12.5 2.1 0.0

Maryland 6 100.0 0.0 0.0 0.0

Massachusetts 353 * 70.0 * 30.0 0.0 0.0

Michigan 3,467 43.6 0.0 21.3 35.1 a

Minnesota 946 * 72.2 * 2.6 25.2 0.0

Mississippi 1,160 12.8 85.9 0.0 1.2

Missouri 370 * 89.7 * 0.0 10.3 0.0

Montana 394 * 0.0 * 0.0 100.0 0.0

Nebraska 181 * 85.1 * 14.9 0.0 0.0

Nevada 64 54.7 * 4.7 37.5 3.1

New Hampshire 46 * 0.0 * 87.0 13.0 0.0

New Jersey 1,272 * 31.4 * 12.3 56.3 0.0

New Mexico 17 * 58.8 * 0.0 41.2 0.0

New York 23,848 * 6.5 * 90.2 3.4 0.0

North Carolina 1,659 * 96.0 * 2.3 1.7 0.0

North Dakota 162 98.8 * 0.0 1.2 0.0

Ohio 1,194 35.8 43.3 20.9 0.0

Oklahoma 163 100.0 0.0 0.0 0.0

Oregon 7,637 87.6 12.1 0.3 0.0

Pennsylvania 515 90.1 0.0 9.9 0.0

Rhode Island 61 100.0 0.0 0.0 0.0

South Carolina 1,143 0.0 * 12.4 87.6 0.0

South Dakota 179 69.3 * 28.5 2.2 0.0

Tennessee 2,037 83.0 * 13.8 3.2 0.0

Texas 8,676 94.5 * 5.3 0.2 0.0

Utah 273 * 37.4 * 20.9 41.8 0.0

Vermont 444 95.0 * 2.9 2.0 0.0

Virginia 4,358 98.8 0.8 0.4 0.0

Washington 897 13.2 85.7 1.1 0.0

West Virginia 477 * 64.4 * 0.0 35.6 0.0

Wisconsin 721 41.9 38.8 18.2 1.1

Wyoming 262 94.7 0.0 5.3 0.0

SOURCE: Counts provided by the states and supplemental estimates prepared by Mathematica Policy

 Research, Inc., from FSPQC data.

NOTE: Arkansas, DC, and Illinois have no ABAWDs subject to the time limit. Other ABAWDs may be

 meeting the work requirement, and this is particularly true in Illinois, but they are not counted here.

* Denotes sample estimate.

a

 Self-initiated community service accounts for nearly all of this figure.
 55 

TABLE II.11 

STATE ESTIMATES OF PERCENTAGE OF ABAWD PARTICIPANTS SUBJECT TO THE TIME LIMIT 

WHO WERE MEETING THE WORK REQUIREMENT, BY METHOD, MARCH 2000 

 Method of Meeting the Work Requirement 

Number Education Other Not

Subject to and Qualifying Meeting

State Time Limit Working Workfare Training Activity Req.

 U.S. Total 215,800 23.4 23.4 3.6 0.6 49.0

Alabama 2,302 19.7 * 24.0 0.0 0.0 56.3 *

Alaska 573 * 31.2 * 10.3 0.0 0.0 58.5

Arizona 7,029 * 49.4 2.9 0.0 0.0 47.7

Arkansas 0

California 55,358 22.0 * 40.2 3.4 0.0 34.4 *

Colorado 1,707 3.0 29.1 10.6 0.0 57.2

Connecticut 370 * 21.1 * 4.1 8.1 0.0 66.8 *

Delaware 672 * 19.6 * 0.3 0.0 0.0 80.1 *

District of Columbia 0

Florida 1,688 * 24.8 * 6.6 2.0 0.0 66.6 *

Georgia 2,664 * 28.8 * 6.5 0.9 0.0 63.9 *

Hawaii 1,353 18.0 * 0.0 0.4 0.0 81.7

Idaho 216 9.3 * 29.2 0.5 0.0 61.1

Illinois 0

Indiana 1,806 8.4 0.0 9.4 3.8 78.4

Iowa 1,388 29.3 * 0.0 0.0 0.0 70.7 *

Kansas 2,174 20.4 0.0 0.0 0.0 79.6

Kentucky 2,694 27.2 0.0 20.9 0.0 51.9

Louisiana 1,337 25.4 * 3.3 0.4 0.0 70.9 *

Maine 222 18.5 2.7 0.5 0.0 78.4

Maryland 1,180 0.5 0.0 0.0 0.0 99.5

Massachusetts 2,159 * 11.4 * 4.9 0.0 0.0 83.6 *

Michigan 16,644 9.1 0.0 4.4 7.3 79.2

Minnesota 4,282 16.0 * 0.6 5.6 0.0 77.9 *

Mississippi 1,160 12.8 85.9 0.0 1.2 0.0

Missouri 4,376 * 7.6 * 0.0 0.9 0.0 91.5 *

Montana 581 * 0.0 * 0.0 67.8 0.0 32.2 *

Nebraska 674 * 22.8 * 4.0 0.0 0.0 73.1 *

Nevada 774 4.5 * 0.4 3.1 0.3 91.7

New Hampshire 52 * 0.0 * 76.9 11.5 0.0 11.5 *

New Jersey 1,339 29.8 * 11.7 53.5 0.0 5.0 *

New Mexico 1,073 * 0.9 * 0.0 0.7 0.0 98.4 *

New York 25,413 6.1 * 84.6 3.1 0.0 6.2 *

North Carolina 5,348 * 29.8 * 0.7 0.5 0.0 69.0 *

North Dakota 404 39.6 * 0.0 0.5 0.0 59.9

Ohio 10,844 * 3.9 4.8 2.3 0.0 89.0

Oklahoma 4,081 4.0 0.0 0.0 0.0 96.0

Oregon 8,072 82.9 11.4 0.3 0.0 5.4

Pennsylvania 3,777 * 12.3 0.0 1.4 0.0 86.4

Rhode Island 286 21.3 0.0 0.0 0.0 78.7

South Carolina 2,077 0.0 * 6.8 48.2 0.0 45.0

South Dakota 400 31.0 * 12.8 1.0 0.0 55.2

Tennessee 3,447 49.0 * 8.2 1.9 0.0 40.9

Texas 16,435 49.9 * 2.8 0.1 0.0 47.2

Utah 952 * 10.7 * 6.0 12.0 0.0 71.3 *

Vermont 1,381 30.6 * 0.9 0.7 0.0 67.8

Virginia 7,801 55.2 0.4 0.2 0.0 44.1

Washington 3,604 3.3 21.3 0.3 0.0 75.1

West Virginia 967 31.7 * 0.0 17.6 0.0 50.7 *

Wisconsin 2,225 13.6 12.6 5.9 0.4 67.6

Wyoming 472 52.5 0.0 3.0 0.0 44.5

SOURCE: Counts provided by the states and supplemental estimates prepared by Mathematica Policy Research, Inc.,

 from FSPQC data.

* Denotes sample estimate.
 56 

were subject to the time limit in each state, showing the percentage meeting the work 

requirement by the way in which they were doing so and, in the last column, the percentage who 

were not meeting the work requirement. 

 These tables illustrate how the distribution of ABAWD participants among the different 

methods varied widely by state. As Table II.10 suggests, California and New York accounted 

for most (87 percent) of the workfare participants nationally in March 2000. These two states 

skewed the national workfare totals, suggesting that workfare was more widely used than it was.9

 

From Table II.11 we see that while 23 percent of all ABAWDs who were subject to the time 

limit were meeting the work requirement through workfare, there were only 18 states in which at 

least 5 percent of the ABAWD participants were doing so. By contrast, there were 38 states in 

which at least 5 percent of the ABAWD participants who were subject to the time limit were 

meeting the work requirement by working, and 23 states in which at least 20 percent were doing 

so. If we exclude California and New York, we calculate from the data underlying Table II.10 

that 74 percent of those ABAWDs who were meeting the work requirement were doing so 

through work, 13 percent were participating in workfare, 10 percent were participating in 

education and training, and 3 percent were engaged in another qualifying work activity. 

Additionally, we observe that while working and workfare dominated education and training 

in the aggregate, there were a few states in which education and training accounted for a larger 

share of ABAWD participants than at least one if not both of these alternative activities. Still, 

there were only 12 states in which at least 5 percent of the ABAWDs subject to the time limit 

were meeting the work requirement through education and training. 

 

9

 Moreover, data supplied by the state of California indicates that Los Angeles accounted for 84 percent of the 

state’s workfare slots for ABAWDs. Thus, the use of workfare was even more limited, geographically, than Table 

II.10 suggests. Fully 80 percent of the reported workfare participants in March 2000 lived in Los Angeles or New 

York State. 
 57 

E. CHARACTERISTICS OF PARTICIPANTS SUBJECT TO THE TIME LIMIT 

Prior to this study, the best information on the characteristics of ABAWDs came from 

studies using FSPQC data and relying on simulation methods to identify participants who were 

likely to have been designated as ABAWDs. Using data from FY96, the year before the 

ABAWD provisions were implemented, Stavrianos and Nixon (1998) established several 

important findings about the characteristics of ABAWD participants who were neither working 

20 hours per week nor participating in workfare. First, the majority (58 percent) of these 

ABAWDs were male. This contrasted with all adult FSP participants, 70 percent of whom were 

female. Second, ABAWDs were somewhat older than all participants within the 18 to 50 age 

group. Third, ABAWDs tended to have shorter spells of participation, were much more likely to 

live in one-person units, and were much less likely to have any income than all adult participants. 

Fourth, ABAWDs were undifferentiated from all other participants with respect to educational 

attainment. 

Have the characteristics of ABAWD participants changed since the implementation of the 

ABAWD provisions and e dramatic decline in the size of this population? Using FSPQC data 

and tabulations provided by a subset of states, we examine two questions: (1) How do ABAWD 

participants who are subject to the time limit compare with all participants 18 to 50? (2) How do 

ABAWDs who are meeting the work requirement compare with those who are not?10

 

10 Estimates for all participants age 18 to 50 are based entirely on FSPQC data. Estimates for participants 

subject to the ABAWD time limit utilize the tabulations provided by about one-third of the states combined with 

FSPQC data for the remaining states. The small numbers of ABAWD participants in the state QC samples generally 

and questions about the identification of ABAWDs in at least some state QC samples argue for relying on the state 

tabulations to the fullest extent possible. Supplementing the state tabulations with FSPQC data allows us to make 

national estimates. See Appendix B for a discussion of methodology. 
 58 

1. ABAWD Participants Versus All Participants 18 to 50 

Participants who were subject to the ABAWD time limit were divided almost equally 

between men and women, with men accounting for 53 percent of this group (Table II.12). 

Among all participants age 18 to 50 only 28 percent were male. We attribute this difference 

almost entirely to the fact that participants who were responsible for a dependent child were 

excluded from the ABAWD population. While men and women in two-parent families are likely 

to have been excluded with equal frequency, single-parent families are predominantly female. 

Participants subject to the ABAWD time limit differed from all participants in their age 

distribution as well. Among ABAWD participants, men and women had very similar age 

distributions, with a decided shift toward the upper ages. The single largest age group among 

both men and women was 41 to 45.11 Even though the 18 to 20 age group encompasses just 

three years, the number of ABAWDs in this group was also relatively large. This pattern may 

vary seasonally, however. The FSPQC data, which reflect the full fiscal year, show this surplus 

of young ABAWDs, but the state tabulations, based on March 2000, do not.12 Among all 

participants age 18 to 50 there was a fairly uniform distribution by age, but males were 

distributed somewhat differently than females. Men were most numerous in the 36 to 45 age 

range while women were more heavily concentrated between 21 and 30. 

The racial and ethnic composition of participants subject to the ABAWD provisions was 

strikingly similar to that of all participants 18 to 50. In both populations white, non-Hispanic 

 

11 Note that the top age group, 46 to 50, includes only four rather than five years in most states. This is because 

we defined the upper end of this age group to be consistent with each state’s interpretation of “18 to 50” in the 

ABAWD provisions. In FY00 nearly every state excluded participants from the ABAWD population once they 

became 50. 

12 This pattern in the FSPQC data was evident both among states that submitted ABAWD tabulations and 

among those that did not, so the difference between the FSPQC data and state tabulations cannot be explained by 

differences between the states that submitted tabulations and those that did not. 
 59 

TABLE II.12 

DEMOGRAPHIC CHARACTERISTICS OF PARTICIPANTS SUBJECT TO THE ABAWD 

TIME LIMIT AND ALL PARTICIPANTS 18 TO 50, FY00 

 

Participants 

Subject to the All Participants 

 ABAWD Time Limit 18 to 50 

Characteristic Male Female Total Male Female Total 

 

 Percentage Distribution Percentage Distribution 

 

 Age 52.7 47.3 100.0 28.2 71.8 100.0 

18-20 9.4 8.1 17.6 3.0 6.7 9.7 

21-25 5.4 6.4 11.7 3.1 13.8 16.8 

26-30 5.5 4.1 9.6 3.7 13.1 16.8 

31-35 6.7 4.6 11.3 4.4 12.2 16.6 

36-40 7.0 8.1 15.1 5.3 11.5 16.8 

41-45 11.5 10.2 21.7 5.3 9.0 14.3 

46-50 7.1 5.8 12.9 3.4 5.5 8.9 

 

 Race 52.7 47.3 100.0 28.2 71.8 100.0 

White, Non-Hispanic 23.1 20.9 43.9 15.1 30.3 45.4 

Black, Non-Hispanic 19.3 18.0 37.3 7.3 28.1 35.4 

Hispanic 7.7 6.4 14.1 4.3 10.8 15.1 

Asian, Pacific Islander 1.7 0.9 2.6 0.9 1.5 2.4 

Native American 0.9 1.1 2.0 0.6 1.2 1.8 

 

SOURCE: Prepared by Mathematica Policy Research, Inc., from FSPQC data and tabulations provided by the states. 

NOTE: The age group 46-50 includes only four rather than five years in most states because we defined the upper limit to be 

consistent with each state’s interpretation of “18 to 50” in the ABAWD provisions. In FY00 nearly every state excluded 

participants from the ABAWD population once they became 50. 

participants were the largest group among both men and women with blacks being a close 

second. 

Participants subject to the ABAWD time limit tended to have shorter spells of food stamp 

participation to date than all participants age 18 to 50 did (Table II.13). The median duration 

among participants subject to the work requirement was 4.4 months versus 11.6 months among 

all participants. About three times as many ABAWD participants as all participants were in their 
 60 

TABLE II.13 

NUMBER OF CONSECUTIVE MONTHS RECEIVING FOOD STAMPS BY PARTICIPANTS 

SUBJECT TO THE ABAWD TIME LIMIT AND ALL PARTICIPANTS 18 TO 50, FY00 

Participants Subject to the All Participants

ABAWD Time Limit 18 to 50

Number of Consecutive Months Percent Cumulative Percent Cumulative

Receiving Food Stamps of Total Percent of Total Percent

 Total 100.0 100.0

1 17.8 17.8 6.1 6.1

2 12.3 30.1 7.6 13.7

3 11.9 42.0 7.2 20.9

4 to 6 16.8 58.8 13.8 34.7

7 to 9 7.8 66.6 8.8 43.5

10 to 12 4.5 71.1 7.5 51.0

13 or more 28.9 100.0 48.9 100.0

 Median Number of Months 4.4 11.6

SOURCE: Prepared by Mathematica Policy Research, Inc., from FSPQC data and tabulations

 provided by the states.

first month of benefit receipt. At the other end of the distribution, only 29 percent of ABAWD 

participants had been receiving food stamps for more than 12 months compared with nearly half 

of all participants 18 to 50. While this undoubtedly reflects, in part, the impact of time limits, 

Stavrianos and Nixon (1998) reported that even before the ABAWD provisions were 

implemented, participants who could be identified as ABAWDs were in shorter spells than were 

all adult participants. 

Well over half of ABAWD participants were in one-person households, and roughly threequarters were in households with fewer than three members (Table II.14). Like the sex 

distribution, this largely reflects the exclusion of participants with dependent children. By 
 61 

TABLE II.14 

HOUSEHOLD SIZE AND AVERAGE MONTHLY BENEFIT OF PARTICIPANTS 

SUBJECT TO THE ABAWD TIME LIMIT AND ALL PARTICIPANTS 18 TO 50, FY00 

Participants Subject to All Participants

The ABAWD Time Limit 18 to 50

Percent Average Percent Average

of Monthly of Monthly

Household Size Participants Benefit Participants Benefit

 Total 100.0 158 100.0 212

One 57.8 110 20.8 81

Two 17.5 162 19.6 157

Three 10.9 230 21.8 220

Four 7.0 249 18.5 269

Five 3.3 302 10.5 303

Six or more 3.5 394 8.7 401

 Median Size 1.0 2.4

SOURCE: Prepared by Mathematica Policy Research, Inc., from FSPQC data and tabulations

 provided by the states.

contrast, only about one-fifth of all participants 18 to 50 were in one-person households, and 

barely two-fifths were in households with fewer than three members. 

At least in part because of the differential distribution by household size, participants who 

were subject to the ABAWD time limit were in households with smaller average monthly 

benefits ($158) than all participants 18 to 50 ($212). However, ABAWD participants in oneperson households received larger monthly benefits than their counterparts among all 

participants. In other size categories, the monthly benefits were more nearly identical between 

ABAWD participants and all participants 18 to 50, suggesting that their household incomes were 

more nearly equal. 

Personal income data, while not broken down by household size, nevertheless suggest why 

ABAWD participants in one-person households tended to receive larger benefits than other 

participants in one-person households. In general, ABAWD participants had lower personal 
 62 

income than all participants 18 to 50. About half of ABAWD participants had no income 

compared with less than one-quarter of all participants 18 to 50 (Table II.15). There was no 

difference between the two groups with respect to the incidence of earnings, but ABAWD 

participants were markedly less likely to have unearned income. Even among those who did

have income, ABAWD participants had lower median total income, lower median earnings, and 

lower median unearned income than did all participants age 18 to 50. 

2. Meeting the Work Requirement 

Among participants who were subject to the ABAWD time limit, those who were meeting 

the work requirement were undifferentiated by sex from those who were not meeting the 

requirement, and they tended to be only slightly older (Table II.16). Racial differences were 

more pronounced. Hispanic participants accounted for a much greater share of those who were 

meeting the work requirement (21.8 percent) than of those who were not (6.2 percent), with 

white participants making up a correspondingly smaller share of those meeting (37.7 percent) 

versus not meeting the work requirement (50.4 percent). Location could account for at least 

some of the racial difference. Los Angeles and New York accounted for 80 percent of the 

workfare slots in the United States and had relatively large Hispanic populations. 

Statistics on the incidence of homelessness among the food stamp population in general and 

the ABAWD population in particular are not available in the FSPQC data or in national surveys 

that identify food stamp participants, but six states were able to provide such statistics on their 

ABAWD participants. Among these six states, 6.5 percent of the participants who were subject 

to the ABAWD time limit were reported to lack a stable or permanent residence (Table II.17). 

By this measure, the incidence of homelessness was slightly lower (5.6 percent) among those 

participants who were meeting the work requirement than among those who were not (6.8 

percent). 
 63 

TABLE II.15 

INCOME OF FOOD STAMP PARTICIPANTS SUBJECT TO THE ABAWD TIME LIMIT 

AND ALL PARTICIPANTS 18 TO 50, FY00 

Participants Subject to the All Participants

ABAWD Time Limit 18 to 50

Total Earned Unearned Total Earned Unearned

Income Measure Income Income Income Income Income Income

Percent with No Income 49.2% 68.5% 76.7% 24.4% 68.4% 45.6%

Median Amount $18 $0 $0 $484 $0 $119

Median Nonzero Amount $455 $584 $260 $569 $743 $486

SOURCE: Prepared by Mathematica Policy Research, Inc., from FSPQC data and tabulations provided

 by the states.

Both the degree to which ABAWD participants were homeless and the differential between 

those meeting and not meeting the work requirement varied substantially among the six states. 

In Kentucky and Ohio, fewer than 4 percent of ABAWD participants were homeless compared 

with 12.9 percent in Maine. In Maine and Rhode Island, homelessness was much less prevalent 

among participants meeting versus not meeting the work requirement. In the other states, 

however, the differences were small. In Colorado, homelessness was actually more prevalent 

among ABAWDs meeting the work requirement. 
 64 

TABLE II.16 

DEMOGRAPHIC CHARACTERISTICS OF PARTICIPANTS SUBJECT TO THE TIME LIMIT 

BY WHETHER OR NOT THEY WERE MEETING THE WORK REQUIREMENT, MARCH 2000 

Meeting the Not Meeting the

Work Requirement Work Requirement

Characteristic Male Female Total Male Female Total

Percentage Distribution Percentage Distribution

 Age 51.9 48.1 100.0 53.5 46.5 100.0

18-20 7.4 5.8 13.2 11.5 10.6 22.1

21-25 5.6 7.6 13.1 5.1 5.1 10.2

26-30 3.7 5.6 9.3 7.3 2.6 9.9

31-35 7.5 3.9 11.4 5.9 5.4 11.3

36-40 6.0 9.1 15.0 8.2 7.1 15.3

41-45 14.6 10.6 25.2 8.3 9.7 18.1

46-50 7.1 5.6 12.7 7.1 6.1 13.2

 Race 51.9 48.1 100.0 53.5 46.5 100.0

White, Non-Hispanic 19.3 18.4 37.7 27.0 23.4 50.4

Black, Non-Hispanic 18.0 18.1 36.1 20.7 18.0 38.6

Hispanic 11.2 10.6 21.8 4.0 2.1 6.2

Asian, Pacific Islander 2.0 0.2 2.2 1.3 1.7 3.0

Native American 1.4 0.9 2.2 0.4 1.4 1.8

SOURCE: Prepared by Mathematica Policy Research, Inc., from FSPQC data and tabulations

 provided by the states.

NOTE: The age group 46-50 includes only four rather than five years in most states because we

 defined the upper limit to be consistent with each state's interpretation of "18 to 50" in the

 ABAWD provisions. In FY00 nearly every state excluded participants from the ABAWD

 population once they became 50.

Meeting the work requirement allows participants to avoid using up their time-limited 

benefits, so we would expect to see evidence of longer benefit durations among participants who 

meet the work requirement than among those who do not. This expectation is borne out (Table 

II.18). Participants who were meeting the work requirement had been receiving food stamps for 

nearly eight months, on average, while those who were not meeting the work requirement had 

received food stamps for just over two months. Almost 40 percent of participants who were 
 65 

TABLE II.17 

LACK OF A STABLE OR PERMANENT RESIDENCE AMONG 

PARTICIPANTS SUBJECT TO THE ABAWD TIME LIMIT BY WHETHER 

OR NOT THEY WERE MEETING THE WORK REQUIREMENT, MARCH 2000 

State 

Participants Subject 

to the ABAWD 

Time Limit 

Meeting the Work 

Requirement 

Not Meeting the 

Work Requirement 

 Percent Who Lack a Stable or Permanent Residence 

Colorado 

Kentucky 

Maine 

Michigan 

Ohio 

Rhode Island 

6.3 

3.9 

12.9 

8.7 

3.7 

7.3 

7.7 

3.2 

2.1 

7.2 

2.7 

1.0 

5.3 

4.5 

15.3 

9.1 

3.8 

10.9 

 

State Average 

Weighted 

Not Weighted 

6.5 

7.1 

5.6 

4.0 

6.8 

8.2 

 

Source: Tabulations provided by the indicated states. 

Note: In Ohio, the proportion of all food stamp participants 18 to 50 who lacked a stable or permanent 

residence was 2.2 percent. This information was not obtained from the other states. 

meeting the work requirement had been receiving food stamps for more than 12 months 

compared with only 18 percent of participants who were not meeting the work requirement. 

Under the law, in general, an ABAWD participant who failed to meet the work requirements 

could receive food stamps for no more than three or four months (in the latter case with a partial 

first month). Yet more than one-fourth of those who were not meeting the work requirement had 

received food stamps for more than six months. How do we explain this? Given the timing of 

our data collection, some participants may have lived in states that had reset their 36-month 

clocks a few months earlier, allowing participants to receive food stamps for two consecutive 

three-month periods. But even this would allow at most six or seven months of benefits, and 

most of the participants who exceeded six months had accumulated nine months or more. The 
 66 

TABLE II.18 

NUMBER OF CONSECUTIVE MONTHS RECEIVING FOOD STAMPS: 

PARTICIPANTS SUBJECT TO THE ABAWD TIME LIMIT BY WHETHER 

OR NOT THEY WERE MEETING THE WORK REQUIREMENT, MARCH 2000 

Meeting the Not Meeting the 

 Work Requirement Work Requirement 

Number of Consecutive Months Percent Cumulative Percent Cumulative 

Receiving Food Stamps of Total Percent of Total Percent 

 

 Total 100.0 100.0 

1 7.2 7.2 28.7 28.7 

2 6.9 14.2 17.8 46.5 

3 9.8 23.9 14.2 60.7 

4 to 6 20.6 44.5 12.9 73.6 

7 to 9 9.9 54.4 5.7 79.2 

10 to 12 6.0 60.4 3.0 82.2 

13 or more 39.6 100.0 17.8 100.0 

 

 Median Number of Months 7.7 2.2 

 

Source: Prepared by Mathematica Policy Research, Inc., from FSPQC data and tabulations provided by 

the states. 

more likely explanation is that part of the time period did not count against the three-month limit. 

Participants may have met the work requirement in earlier months, been defined as a nonABAWD, or been waived. Without longitudinal data on these participants, we have no way in 

most cases to establish what may account for their extended participation. 

Participants who were meeting the work requirement tended to be in larger households and 

receive smaller monthly benefits than participants who were not meeting the work requirement 

(Table II.19). A possible explanation for the difference in household size is that ABAWD 

participants in larger households were more likely to work because they were more likely to be 

responsible for others. Whatever the explanation for the household size differential, the lower 

benefits in every size class among participants who were meeting the work requirement is an 
 67 

TABLE II.19 

HOULDHOLD SIZE AND AVERAGE MONTHLY BENEFIT: 

PARTICIPANTS SUBJECT TO THE ABAWD TIME LIMIT BY WHETHER 

OR NOT THEY WERE MEETING THE WORK REQUIREMNT, MARCH 2000 

Meeting the Not Meeting the 

 Work Requirement Work Requirement 

 

 Percent Average Percent Average 

 of Monthly of Monthly 

Household Size Participants Benefit Participants Benefit 

 

 Total 100.0 127 100.0 190 

One 49.9 79 66.0 133 

Two 18.1 118 16.9 210 

Three 14.2 172 7.5 345 

Four 9.7 198 4.1 374 

Five 4.8 231 1.8 503 

Six or more 3.3 350 3.7 434 

 

 Median Size 1.0 0.1 

Source: Prepared by Mathematica Policy Research, Inc., from FSPQC data and tabulations provided by 

the states. 

indication of their higher income, which we attribute to the fact that many of these participants 

were working. 

The employment differential is confirmed in Table II.20, which reports summary statistics 

for total income, earned income, and unearned income for the two groups of participants. It is no 

surprise that half of those who were meeting the work requirement had earned income; we 

showed earlier that nearly half of those who met the work requirement did so by working. It is 

noteworthy, however, that about 15 percent of participants who were not meeting the work 

requirement had earned income as well. They were apparently not working enough hours to 

satisfy the work requirement. Consistent with this interpretation, their median monthly income 

of $304 was well below the $412 that they would have earned with 80 hours per month at the 

minimum wage ($5.15 at the time). Participants who met the work requirement had median 

earnings more than twice as high, at $661. 
 68 

TABLE II.20 

INCOME OF FOOD STAMP PARTICIPANTS SUBJECT TO THE ABAWD TIME LIMIT BY 

WHETHER OR NOT THEY WERE MEETING THE WORK REQUIRENT, MARCH 2000 

Meeting the Not Meeting the

Work Requirement Work Requirement

Total Earned Unearned Total Earned Unearned

Income Measure Income Income Income Income Income Income

Percent with No Income 30.5% 53.0% 70.9% 68.7% 84.6% 82.7%

Median Amount $329 $0 $0 $0 $0 $0

Median Nonzero Amount $526 $649 $277 $271 $304 $238

SOURCE: Prepared by Mathematica Policy Research, Inc., from FSPQC data and tabulations provided

 by the states.

Participants who were meeting the work requirement were also somewhat more likely to 

have unearned income (about 29 percent versus 17 percent). This may reflect the impact of 

general assistance programs in a few large states with high workfare participation and, therefore, 

many ABAWD participants meeting the work requirement. 

F. NUMBER REACHING THE TIME LIMIT 

An important reason why the ABAWD share of the participant population is not higher is 

the cumulative impact of the ABAWD policy itself. The first terminations or departures of 

participants who failed to meet the work requirement for three months occurred in February or 

March 1997, depending on when each state implemented the ABAWD policy.13

Few states, however, can determine the number of ABAWD participants who reach the time 

limit in a given month and lose their benefits. Even fewer states have compiled such statistics 

 

13 See Chapter V for a discussion of what determined the implementation date of the ABAWD policy in each 

state. 
 69 

continuously since they implemented the ABAWD policy. We obtained complete statistics, 

covering February 1997 through March 2000, from six states and partial statistics from six 

additional states. Monthly counts of terminations due to the three-month time limit are plotted in 

Figure II.5 for each of the six states with complete data and for a total pooled across all six 

states. 

After a peak of nearly 7,000 in March 1997, the number of terminations of ABAWD 

participants reaching the three-month time limit in these six states dropped below 2,000 the next 

month. A few months later, the number of terminations more or less leveled off at a monthly 

average of just above 1,000. Each of the six states exhibited a very similar pattern although they 

differed in whether the first, and therefore peak, terminations occurred in February or March of 

1997. 

Three features of this time pattern are notable. First, the early peak of terminations reflects 

the large number of ABAWD participants who were in the program at the time that the 

provisions went into effect. Those who failed to satisfy the work requirement lost their benefits 

three months after implementation. From that point on, terminations reflected a changing mix 

of: 

• Members of the initial pool of ABAWD participants who met the work requirement 

during the initial three months but not subsequently 

• Members of the initial pool of non-ABAWD participants who later became subject to 

the time limit 

• Returning participants who had left without using up their three months of benefits 

• New participants who joined the program rolls after the ABAWD provisions had 

gone into effect 

Over time, new participants made up a larger proportion of the total ABAWD pool, reflecting the 

dynamics of the food stamp caseload. Second, the entry of new ABAWD participants into the 

FSP has been large enough, apparently, to maintain the monthly terminations at a relatively 
70 

FIGURE II.5 

NUMBER OF ABAWD PARTICIPANTS REACHING THE THREE MONTH TIME LIMIT 

IN SIX STATES, FEBRUARY 1997 THROUGH MARCH 2000 

0

1,0002,0003,0004,0005,0006,0007,0008,000

Feb 97

May 97

Aug 97

Nov 97

Feb 98

May 98

Aug 98

Nov 98

Feb 99

May 99

Aug 99

Nov 99

Feb 00

Month and Year

Number of Participants Reaching the Time Limit 

SOURCE: Tabulations provided by states. 
 71 

constant level after the provisions had been in effect for several months. This underscores the 

likelihood that there may be substantial turnover in participation in this group. Third, there is no 

echo of the initial peak terminations three years later—none whatsoever. The initial ABAWD 

participants who were enrolled when the provisions went into effect and lost their benefits in 

February or March of 1997 apparently did not return in large numbers when the start of a new 

36-month clock entitled them to do so. We cannot tell how many did in fact return and meet the 

work requirement for at least a short while, and the time series may end too early to show a 

secondary peak created by returning cases. But it is significant that we saw no evidence of an 

echo in the longer time series of ABAWD participants, presented earlier (see Figure II.3). It 

appears from these two time series that either very few of the participants who exhausted their 

three months of benefits during the initial 36-month period returned to the program or, if they did 

return, they came back as non-ABAWDs. 

One other small point deserves mention. The Kentucky series shows a sudden, substantial 

upturn in terminations in June 1998, which is followed by an almost as steep decline, except that 

the series remains above its May 1998 level for many months thereafter. We consulted with 

state staff in Kentucky and learned that in March of that year a number of counties lost their 

waivers from the ABAWD provisions, making a large number of participants suddenly subject to 

the time limit. The June upturn followed the loss of waivers by three months and was 

attributable to the subset of participants who were unable to meet the work requirement for even 

a single month. That the number of terminations remained at a level above the May 1998 figure 

was due to the increased pool of participants who became subject to the time limit and, over 

time, added to the numbers who were unable to maintain their eligibility indefinitely. We 

observed a similar phenomenon in the Rhode Island series, which is not shown because it did not 

span the full time period. State staff in Rhode Island provided the same explanation as the 

Kentucky staff. That the time series from both states should reflect so clearly the impact of a 
 72 

loss of waivers enhances their credibility and underscores the sensitivity of terminations to 

changes in the number of FSP participants subject to the ABAWD time limit. 

We can extrapolate from the 12 states with partial or complete termination data to estimate 

the total number of terminations nationally over the full period. To do so requires an appropriate 

scale factor for each month that will let us inflate the known number of terminations to the 

unknown total. For March 2000, we have observations on a small number of characteristics for 

all of the states. By selecting one or more characteristics that are correlated with the number of 

terminations, we can calculate the 12-state share of the national total for each characteristic and 

then divide the terminations in the 12 states by this share to inflate the number of terminations an 

equivalent amount. For example, if the 12 states account for 10 percent of the national total for a 

relevant characteristic, then we would inflate the number of terminations in the 12 states by a 

factor of 10. 

Two characteristics that appeared to be good candidates for this exercise are the number of 

ABAWD participants subject to the time limit and the number of these who failed to meet the 

work requirement. To incorporate into our estimates the incomplete observations for six states, 

we calculated shares of the national total of each characteristic for just those states with 

termination data in a given month and then inflated the terminations for those states. For the first 

month of the series we had only the six states with complete data, but we added a seventh state, 

Indiana, in the second month and five more states in subsequent months, ending with California 

as the 12th state in the final three months. While the change in the mix of states from one month 

to the next could introduce a disjuncture into the time series, only California was large enough to 

pose a serious problem. 

While we would have preferred to have measures of the number of participants subject to 

the time limit and the number failing to meet the work requirement in all states at multiple points 

along the 38-month continuum, we could assemble such measures for only March 2000. We run 
 73 

the risk, then, that even if one of the selected characteristics were perfectly related to the number 

of terminations in March 2000, this relationship might not hold in earlier months. Nevertheless, 

even with this limitation, and the attendant error in our extrapolation, being able to produce 

estimates of terminations at the national level for the full 38-month period was clearly preferable 

to having no estimates at all. 

Figure II.6 presents a plot of the time series of terminations obtained by application of this 

methodology using the two characteristics identified earlier. The series represented by the solid 

line was derived by calculating state shares of the number of ABAWD participants subject to the 

time limit. The series represented by the broken line was derived using state shares of the 

number of ABAWDs who failed to meet the work requirement. Intuitively, the latter is the more 

appropriate statistic for extrapolating the number of terminations. In fact, the data obtained using 

this variable shows less of a shift when California is introduced than does the series derived 

using shares of the number of ABAWD participants subject to the time limit. 

Table II.21 presents estimates of the cumulative number of terminations over selected time 

periods. The first two columns are based on the data from Figure II.6. The final two columns 

present estimates extrapolated from just the six states that provided complete data. Comparing 

the alternative estimates allows us to assess their sensitivity to some of the assumptions 

underlying the methods used to derive them. 

We regard the estimates in the first column as the most accurate because they make use of 

the available data from all 12 states and they base the extrapolation on what is, in theory, the 

more relevant of the two indicators. These estimates indicate that nearly 200,000 ABAWD 

participants used up their time-limited benefits during February, March, and April 1997—the 

first three months in which it was possible to do so. During the next three months the number of 

terminations dropped to 74,000 or little more than a third of the February through April number. 

Through November 1997, ending the first full year in which the ABAWD provisions were in 
74 

FIGURE II.6 

NATIONAL ESTIMATE OF ABAWD PARTICIPANTS REACHING THE 3-MONTH TIME LIMIT, 

BASED ON EXTRAPOLATION FROM 12 STATES 

0

20,00040,00060,00080,000

100,000120,000140,000

Feb 97

May 97

Aug 97

Nov 97

Feb 98

May 98

Aug 98

Nov 98

Feb 99

May 99

Aug 99

Month and Year

Number of Participants Reaching the Time Limit

Based on number subject to time limit Based on number not meeting work requirem

SOURCE: Extrapolation from data supplied by 12 states. 
 75 

TABLE II.21 

ESTIMATED NUMBER OF TERMINATIONS OF ABAWD PARTICIPANTS 

REACHING THE THREE-MONTH TIME LIMIT, SELECTED PERIODS 

Method of Extrapolating from States Reporting Terminations

12 States with Complete 

or Partial Data 6 States with Complete Data

Based on Based on Based on Based on

Share of Share of Share of Share of

ABAWDs ABAWDs ABAWDs ABAWDs

Not Meeting Subject Not Meeting Subject

the Work to Time the Work to Time

Time Period Requirement Limit Requirement Limit

February through April 1997 198,400 270,300 216,900 291,500

May through July 1997 74,100 101,800 82,400 110,700

August through November 1997 78,200 108,500 80,900 108,700

 Cumulative through November 1997 350,700 480,600 380,100 510,900

December 1997 through November 1998 242,300 336,300 222,200 298,500

December 1998 through November 1999 277,700 327,700 201,300 270,600

 Cumulative through November 1999 870,700 1,144,700 803,600 1,080,000

 (First 36-month period)

 Cumulative through March 2000 934,300 1,201,500 865,400 1,163,000

SOURCE: Mathematica Policy Research, Inc., based on tabulations supplied by 12 states and extrapolated to

 all states using additional tabulations provided by the states, supplemented with FSPQC sample

 data.

NOTE: The six states that provided complete data for February 1997 through March 2000 are Connecticut,

 Hawaii, Idaho, Iowa, Kentucky, and Minnesota. The six states that provided partial data, with the

 starting date of each series are: Indiana (March 1997), Washington (July 1997), Rhode Island

 (August 1997), Maine (October 1998), Texas, (February 1999), and California (January 2000).
 76 

effect, the cumulative number of terminations was 352,000. During the next year, ending 

November 1998, the number of terminations was 242,000. Terminations rose slightly to nearly 

278,000 during the year ending November 1999. For the first 36-month period, then, the 

cumulative number of terminations was about 871,000. This figure represents an estimate of the 

number of ABAWD participants who lost at least one month of benefits due to the time limit.14 

We cannot estimate the total number of months of benefits that were lost because we do not 

know the number of additional months for which the clients who were terminated would have 

continued to receive benefits in the absence of the time limit. 

With many states resetting their 36-month clocks in November or December 1999 (see 

Chapter V), the number of terminations might have been expected to have dropped around that 

time and not picked up until February or March 2000. Figure II.6 provides some indication of 

this pattern, with a decline in terminations beginning after November 1999. Starting in January 

2000, however, this effect is confounded by the addition of terminations from California, so we 

cannot be sure how much of the decline is due to participants starting a fresh 36-month period 

with a new three-month time limit. Terminations under the new 36-month period would have 

begun to occur in February or March 2000, and therefore some of the terminations recorded in 

those months may involve participants who were also terminated earlier. But as we have noted, 

neither the time series of participants presented earlier nor the terminations reported in this 

 

14 Participants who qualified for and received a second three months of benefits during the first 36 months may 

be counted twice, in which case our estimate of 871,000 overstates the number of participants who were terminated. 

However, it is not clear that the states providing estimates of terminations always included those involving the 

second three months of benefits, which must be used consecutively and, therefore, may not be fully used in every 

case. Moreover, statistics provided by a few states suggest that only a small percentage of ABAWD participants 

qualified for and used the second three months of benefits. Of the ABAWD participants who were not meeting the 

work requirement, less than 5 percent were receiving their second three months of time-limited benefits. This figure 

is depressed by states that applied the time limit to a 36-month period measured with a fixed clock (see Chapter V). 

Fixed clocks were reset in December 1999, so the typical fraction of ABAWDs qualifying for their second threemonth period in these states is higher than what we observed in March 2000. However, no state reported that more 

than 11 percent of its ABAWD participants who were not meeting the work requirement were receiving their second 

three months of benefits. 
 77 

section suggest that there was more than a minimal return of participants who reached the threemonth limit during the first three years after the ABAWD provisions were implemented. With 

little double counting of participants, we believe, the cumulative number reaching the time limit 

between the time the ABAWD provisions were implemented and March 2000 was about 

934,000. 

This estimate of cumulative terminations is sensitive to both the number of states in the 

underlying data series and the method of extrapolation. Extrapolating from just the six states that 

provided data on terminations for the entire time period suggests a somewhat lower cumulative 

number of terminations and a greater concentration in the first year. On the other hand, 

extrapolating from the states in proportion to their share of ABAWDs subject to the time limit 

rather than just those who were failing to meet the work requirement yields about a third more

terminations. 

How much confidence can we have that the extrapolation provides reasonable national 

estimates? There are several factors that invite confidence. First, it is evident in Figure II.5 that 

the six states with complete data show very similar profiles of terminations over the relevant 

time period, and this suggests that most other states would show similar profiles as well. 

Second, by using national shares as the basis for the extrapolation we reduce the impact of state 

variation. Third, the number of ABAWDs subject to the time limit and the number failing to 

meet the work requirement are clearly relevant to the number of ABAWD terminations. Fourth, 

the addition of the first five states with partial data has a fairly modest impact upon the estimates, 

even though the additional states account for about twice the share of the relevant national 

ABAWD populations as the first six (which account for just 5 or 6 percent of the national totals). 

Adding California for the final three months of the time series increases the overall coverage to 
 78 

between 32 and 40 percent of the nation.15 Fifth, the resulting estimates appear plausible in light 

of some of the trend data on ABAWD participation presented earlier. For the period 

encompassing the first three months of terminations, the estimated number of ABAWD 

participants dropped by about 240,000, or about 40,000 more than the preferred estimate of 

ABAWD participants who were terminated during that period. The residual decline is roughly 

consistent with the rate of decline in ABAWD participation preceding the first terminations.16

G. SUMMARY 

We estimate that in March 2000 there were 422,500 ABAWD participants in the FSP. 

Approximately 55 percent were living in nonwaived areas, and 51 percent—or 215,800—were 

subject to the three-month time limit. The balance of ABAWD participants in nonwaived areas, 

or just 4 percent of all ABAWD participants, were excluded with 15 percent exemptions. The 

remaining ABAWD participants, or 45 percent of the total, were residents of areas that were 

waived from the time limit because of high unemployment or insufficient jobs. 

Participants defined as ABAWDs represented about 2.5 percent of all FSP participants 

during the same month. Nearly two-thirds of all participants were under 18 or over 50 and 

therefore excluded by age. Another 8.7 percent were certified as physically or mentally unfit for 

employment while 19.9 percent were responsible for dependent children. About 2.6 percent 

were exempt from FSP work registration for reasons other than those described here, and 0.5 

percent were pregnant. 

 

15 These percentages refer to national shares of ABAWDs not meeting the work requirement and all ABAWDs 

subject to the time limit. 

16 Recall that monthly estimates of ABAWD participants do not support very precise estimates of the monthto-month decline, and this limits what we can say about the relative importance of terminations versus other factors 

affecting the number of ABAWD participants at a point in time. 
 79 

Due in large part to the cumulative impact of the time limit, ABAWD participants accounted 

for a much smaller share of all participants 18 to 50 in nonwaived areas—about 5.5 percent—

than they did in waived areas, where they were 11.5 percent of the participants 18 to 50. 

While the ABAWD provisions were expected to have a direct downward impact on the 

number of food stamp participants who are ultimately subject to them, they were implemented 

during a period of dramatic changes in participation. Along with the total caseload the number 

of ABAWD participants had begun to decline more than two years before the ABAWD 

provisions were implemented. Late in 1996 the number of ABAWD participants began a steep 

decline that reduced the caseload by more than 40 percent in less than a year. The decline 

continued at a reduced rate, and by late 1999 there was evidence that the ABAWD caseload had 

leveled off—at least a year sooner than the total caseload. While we estimate that at least half of 

the first-year decline may have occurred in the absence of the ABAWD provisions, the 

provisions themselves clearly had a direct and sizable impact on the exodus of ABAWD 

participants from the FSP. 

In March 2000, just over half of the ABAWD participants who were subject to the time limit 

were meeting the work requirement. Nearly all who met the work requirement did so by 

working 20 or more hours a week or participating in workfare, but most of the workfare slots 

were in Los Angeles or New York. Elsewhere, roughly three-quarters of the participants who 

met the work requirement did so by working. 

Compared with all participants 18 to 50, who were predominantly female, those who were 

subject to the ABAWD time limit were much more likely to be male, although females still 

accounted for nearly half of this group. Participants subject to the time limit also had shorter 

spells of participation, smaller household sizes, and lower unearned income. They were just as 

likely to have earnings, however. Participants who were meeting the work requirement differed 

in relatively minor ways from those who were not meeting the work requirement when we 
 80 

compared demographic characteristics. They had longer spells of participation and lived in 

somewhat larger households than participants who were not meeting the work requirement. 

They were also more likely to have earnings. Some participants who were not meeting the work 

requirement nevertheless had earnings as well, but they fell short of the 20 hours needed to meet 

the work requirement. 

In the first few months that ABAWDs began to exhaust their time-limited benefits, we 

estimate that nearly 200,000 were terminated. By March 2000 the total number who reached the 

three-month time limit and were terminated had grown to more than 900,000. There is little 

indication that very many of those who lost their benefits during the first 36 months that the time 

limit was in place returned to the FSP to receive additional benefits under a new clock. 
81 

III. WHO IS SUBJECT TO THE TIME LIMIT? 

VARIATION IN STATE POLICIES 

Following the implementation of PRWORA, states had broad latitude in determining who is 

subject to the ABAWD time limit. More specifically, states had policy options in three areas: (1) 

how to interpret federal law on who can be exempt from ABAWD provisions, (2) whether to 

apply for waivers from the time limit in areas of high unemployment and insufficient jobs, and 

(3) whether and how to use the 15 percent exemption, created by the BBA, which allows states 

to exempt up to a federally allotted number of additional persons using criteria of their choosing. 

The options for exemptions in the first area came about primarily because there were no final 

regulations on the ABAWD provisions for several years after PRWORA was passed. FNS did 

issue guidance to states on ABAWD policies soon after PRWORA was passed (USDA 1997), 

and FNS published proposed regulations in December 1999. However, state flexibility to 

interpret federal law regarding who is subject to the ABAWD provisions remained broad until 

the final regulations were published in January 2001. The regulations, which have to be 

implemented by all states on or before October 1, 2001, remove most of the states’ flexibility in 

the first area but do not reduce their options regarding waiver and 15 percent exemption policies. 

This chapter describes the variation in state ABAWD policies as they existed in March 2000 

and discusses how the polices are expected to change as states implement the final regulations. 

We explain how states have defined who is exempt from the ABAWD time limit, how they have 

elected to use waivers, and how they have implemented the 15 percent exemption. We also 

examine to what extent states’ ABAWD policies reflect a uniform motivation and how this may 

change in the future. Appendix C provides details of states’ ABAWD policies. The information 

reported here comes mainly from the State Food Stamp Program Director Survey. 
82 

A. STATE POLICIES ON EXEMPTIONS FROM THE TIME LIMIT 

Until the final ABAWD regulations were issued, policies exempting individuals from the 

time limit were left largely to the discretion of the states. More specifically, states could define 

(1) whether adults became exempt at age 50 or 51, (2) how eligibility workers certify individuals 

as unfit for employment, and (3) which adults are exempt by the presence of dependent children. 

PRWORA also exempts from the time limit pregnant women and individuals who are already 

exempt from FSP work registration, but neither of these exemption criteria varies by state. 

Shortly after the ABAWD provisions took effect, USDA advised states to consider as exempt all 

pregnant women regardless of the trimester of pregnancy, and every state adopted that policy. 

This provision is part of the final ABAWD regulations. Likewise, USDA establishes rules on 

work registration exemptions, and these rules do not vary by state. As a result, policies on 

pregnancy and work registration exemptions are not discussed in this chapter. 

The State Food Stamp Program Director Survey provides information on each state’s policy 

on exemptions. While most policies apply statewide, some states leave the decisions to counties, 

local offices, or individual eligibility workers. For instance, in California and New York, the 

counties set most of the policies on how eligibility workers certify individuals as unfit for 

employment. Our information on these states comes from the findings of the county FSP 

administrator surveys.1

 The District of Columbia, which is covered entirely by a waiver, has 

almost no policies on the exemptions of ABAWDs, so it is excluded from the discussion of 

exemptions. 

 

1

 Counties also made some policy decisions regarding ABAWDs in North Carolina and Alabama, however, 

most of the policies in these states were set by the state. 
83 

1. Age at Which Adults Become Exempt 

According to PRWORA, the time limit applies only to adults between the ages of 18 and 50; 

individuals younger than 18 and older than 50 are exempt. This provision makes it clear that 

individuals are no longer exempt as of their 18th birthday. However, the provision is not as clear 

on the upper age limit. Is an adult technically older than 50 on his or her 50th birthday, or not 

until his 51st birthday? USDA issued guidance on this topic, recommending that states consider 

adults as exempt on their 50th birthday. 

Forty-one states have policies consistent with this guidance, while five states do not exempt 

adults until their 51st birthday. Four other states—Kansas, Maryland, Pennsylvania and West 

Virginia—use their 15 percent exemption to effectively lower the maximum age at which adults 

are subject to the time limit by two to five years (Figure III.1). 

The final USDA regulations retain the policy that adults become exempt on their 50th

birthday. As a result, the five states that delay exemption until the 51st birthday will need to 

revise their policies, a change that is likely to cause a slight decrease in the number of ABAWDs. 

The four states that lower the maximum age through their use of the 15 percent exemption can 

continue to do so. 

2. Certified as Unfit for Employment 

Under PRWORA, adults are exempt from the time limit if they are “medically certified as 

physically or mentally unfit for employment.” Before the final ABAWD regulations were 

issued, states could determine how adults were certified as unfit for employment and how 

frequently these certifications were reviewed. The final ABAWD regulations specify that 

unfitness needs to be verified only if the eligibility worker is uncertain that the individual is 

disabled—a policy already in effect in 35 states. States still have some flexibility to determine 
84 

FIGURE III.1 

DISTRIBUTION OF STATES BY THE AGE ADULTS BECOME 

EXEMPT FROM TIME LIMITS 

5

41

1

2

1

Age 51

Age 50

Age 48

Age 47

Age 45

Number of States 

SOURCE: State Food Stamp Program Director Survey 

how to certify individuals whose disabilities are not evident. States can also determine how 

often certifications are reviewed. 

a. Methods of Certifying Unfitness for Employment 

States used one or more of the following methods to certify an individual as unfit for 

employment: 

• Checking that disability-based benefits are received 

• Obtaining written or verbal certification from a health professional 

• Directly observing the ABAWD 

• Accepting an individual’s word about being disabled 
85 

Whether or not these methods are used and how they are used varies from state to state. In 

California and New York, they vary by county. 

Checking for the Receipt of Disability-Based Benefits. Every state certifies individuals as 

unfit for employment if they receive certain disability-based benefits. In nearly all states, 

qualifying benefits include SSI, disability-based Social Security, disability-based General 

Assistance (GA), some Veterans’ benefits, and some Railroad Retirement benefits (Figure III.2). 

It is not surprising that states use these particular benefits to certify individuals as unfit for 

employment because they are the same five benefits used to identify which FSP clients should be 

subject to FSP eligibility rules that apply to people with disabilities. 

Only three states do not automatically certify individuals as unfit for employment if they 

receive any one of these five benefits. One of these states leaves the decision about which 

benefits to use to the discretion of eligibility workers. The other two states certify a person as 

unfit for employment on the basis of some, but not all, of these benefits. 

Many states consider benefits other than the five used in the FSP disability definition to 

certify someone as unfit for employment under the ABAWD provisions. For example, 36 states 

use workers’ compensation benefits, and 30 states use private disability benefits. Five states do 

not have a statewide policy on which disability benefits in addition to the five associated with the 

FSP disability definition can be used in certification but, rather, allow the local offices to choose 

other benefits as the basis for certification. Twenty-seven states certify unfitness on the basis of 

all five of the disability benefits used in the FSP disability definition plus workers’ compensation 

and private disability benefits. 

The final ABAWD regulations explicitly require states to accept the receipt of “temporary or 

permanent disability benefits issued by governmental or private sources” as certification that an 
86 

FIGURE III.2 

DISTRIBUTION OF STATES BY THE DISABILITY BENEFITS THAT 

QUALIFY INDIVIDUALS AS UNFIT FOR EMPLOYMENT 

3 0

3 6

4 7

4 8

4 8

4 9

4 9

P rivate D isab ility B e nefits

W orkers' C ompensation

Ra ilroa d Retire m e nt

V eterans' B enefits

D isability-based GA

D isability-based S ocial

Security

SSI

Number of States 

SOURCE: State Food Stamp Program Director Survey 

individual is unfit for employment. At least 22 states will have to change their policies to 

comply with the regulations.2

Certification by Health Professionals. Most states (36) have statewide policies on which 

health professionals can certify an adult who is not receiving any of the accepted disability 

benefits to be unfit for employment. Each of these states accepts medical certification from an 

M.D., and all but two accept medical certification from a licensed/certified psychologist (Figure 

III.3). Other professionals that can provide certification include drug or alcohol treatment 

program administrators, nurse practitioners, licensed therapists, physician’s assistants, and 

 

2

 An additional 13 states do not accept state disability benefits as certification, but many of these states may not 

have state disability programs. 
87 

FIGURE III.3 

TYPES OF HEALTH PROFESSIONALS WHO CAN CERTIFY 

UNFITNESS FOR EMPLOYMENTa 

7

19

22

22

22

24

24

34

36

Any

R.N.

Physician's Assistant

Licensed Therapist

Nurse Practitioner

Drug/Alcohol Program Professional

Alternative Medicine Practitioner

Psychologist

MD

Number of States 

SOURCE: State Food Stamp Program Director Survey a

14 states have no statewide policy and no common local policy affecting the majority of ABAWDs. 

registered nurses. Many states also accept certification from practitioners of alternative 

medicine, such as acupuncturists and chiropractors. Seven states accept certification from any 

health professional. 

Most of the 36 states accept certification from more than one type of health professional, 

and 21 states accept certification from six or more. However, 10 states accept certification from 

only two or three types of health professionals—typically from M.D.s and licensed 

psychologists. The 14 states without statewide policy on certification by health professionals 

leave the decision about who can provide medical certification of a disability to county FSP 

officials and/or to eligibility workers. 

States also vary with regard to the form of certification they will accept from a health 

professional. While all 50 states accept a written statement from health professionals, 6 states 
88 

have a form that health professionals must use, and the remaining 44 accept any written 

statement. In addition, 17 states also accept verbal certification from health professionals. 

The final ABAWD regulations specify that medical certification from a health professional 

is required only when “the unfitness is not evident to the eligibility worker.” Furthermore, the 

regulations explicitly allow certification from a “physician, physician’s assistant, nurse, nurse 

practitioner, designated representative of the physician’s office, a licensed or certified 

psychologist, a social worker, or any other medical personnel the state agency determines 

appropriate.” The 32 states that accept certification from a more limited set of health 

professionals or have no state policy will have to change their certification policy to comply with 

federal law. This will exempt more adults from the ABAWD provisions. However, the 

regulations do not specify whether the certification should be written or verbal, so no state will 

have to change this aspect of its certification policy.

Eligibility Worker Observation. In most states (35), eligibility workers can certify an 

individual as unfit for employment if a mental or physical disability is evident.3

 In this case, the 

individual does not need to be receiving disability benefits or to obtain certification from a health 

professional. The final ABAWD regulations also permit certification on the basis of direct 

observation by eligibility workers. This is likely to increase the number of individuals exempted 

from the time limit in the 15 states that currently do not allow certification based on direct 

observation. 

Client Self-Report. In 16 states, eligibility workers can certify an individual as unfit for 

employment based solely on the individual’s self-report about being disabled. In addition, some 

counties in New York certify on the basis of self-report. In either case, the eligibility worker 

does not need any proof of disability. These states and the counties in New York will have to 

 

3

 Additionally, in California and New York, some localities allow eligibility workers to certify on the basis of 

direct observation. 
89 

change their policy to comply with the final ABAWD regulations, which specify that a selfreported disability must also be evident to the eligibility worker to qualify as the basis for a 

disability certification. If it is not, the client must provide proof. This may lead to fewer exempt 

adults in these states. 

b. Reviewing Certifications 

Most states require eligibility workers to periodically review the certification of unfitness. 

Such reviews are more common when a client is certified as unfit because of a temporary, rather 

than a permanent, disability. In the review, the client must prove by any of the acceptable means 

(evidence of receipt of disability benefits, certification from a health professional, etc.) that 

he/she is still mentally or physically unfit for employment. 

Two states do not consider individuals with temporary disabilities to be unfit for 

employment (Indiana and Missouri). Of the remaining 48 states, 41 have policies governing 

when eligibility workers must review certifications of individuals with temporary disabilities. 

Typically, the review is conducted when the client recertifies for FSP benefits, on the date 

recommended by a health professional, or after “a change in circumstances,” whichever comes 

first. A change in circumstances may include a change in health status, income status, or 

household composition. A small number of states leave the decision about review timing to the 

eligibility worker, and four other states require periodic reviews for all people with temporary 

disabilities. 

For individuals with permanent disabilities, 34 states specify if or when eligibility workers 

must review certifications.4

 Three of these states do not require any review of certifications 

based on permanent disability; the remaining 31 states require some periodic reviews. As with 

 

4

 In California and New York, some localities have policies on reviewing certifications based on permanent 

disabilities. 
90 

temporary disabilities, certifications for permanent disabilities are reviewed at FSP benefit 

recertification, on the date recommended by a health professional, or after a change in 

circumstances. The final regulations continue to give states the discretion to determine the 

frequency with which certifications for both types of disabilities are reviewed, but they explicitly 

require states to accept the receipt of temporary disability benefits as evidence of unfitness for 

employment. 

3. Exemptions Based on Dependent Children 

PRWORA exempts from the FSP time limit all adults who care for dependent children. 

Until the final ABAWD regulations were issued, states could set the age at which children were 

no longer considered dependent. States could also set the standard for determining which adults 

in a household were considered to be caring for a dependent child, and they could establish the 

number of those adults that can be exempt. The final regulations specify that children are 

considered dependent until their 18th birthday, and that all adults in a household are exempt from 

the time limit if a child who has not reached his or her 18th birthday is present in the household 

(even if the child is not eligible for food stamps). 

To comply with the final regulations, six states must change the maximum age at which 

children are no longer considered dependent. Montana, North Dakota, and Pennsylvania 

consider children dependent until their 17th birthday. Alaska considers children to be dependent 

until their 6th birthday, and Rhode Island, until their 7th birthday, consistent with the TANF rules 

in both states. In Nebraska, the policy on maximum age is established at the local level, and we 

do not know how many localities set the maximum below 18 years. 

In 22 states, the policy on which adults are exempt from the time limit is consistent with the 

final ABAWD regulations: all adults in a household are exempt if a dependent child is present 

regardless of their relationship with the child or their role vis-à-vis the child (Figure III.4). 
91 

FIGURE III.4 

NUMBER OF ADULTS EXEMPT IF DEPENDENT CHILD IS PRESENT 

1

4

8

15

22

Up to Two Adults

One Adult

All Demonstrating Care

All Parents/Guardians

All Adults

Number of States 

SOURCE: State Food Stamp Program Director Survey 

However, the remaining 28 states will need to change their policy to comply with the 

regulations. In 15 states, only parents or guardians of a dependent child are exempt; in 8 states, 

only adults who can demonstrate that they are responsible for caring for a dependent child are 

exempt. Four states—Pennsylvania, Rhode Island, New York, and Florida—exempt only one 

adult per household. In Pennsylvania and Rhode Island, that adult must be the parent or guardian 

of the child; in New York, the person can be any adult who demonstrates responsibility for 

caring for the child; and in Florida, the household chooses which adult is exempt. Finally, 

Oregon exempts up to two adults when a dependent child is present (if more than two adults are 

in a household, the family chooses which two are exempt). In these 28 states, the final 

regulations will lead to an increase in the number of adults who are exempt on the basis of 

dependent children in the household. We can quantify the impact by simulating the new policy 

with FSPQC data and comparing the results with an alternative simulation based on current 
92 

policy. Using this methodology, we estimate that compliance with the federal regulations will 

redefine as many as 38,000 ABAWD participants to be non-ABAWDs, and we estimate that as 

many as 22,000 or more than half of these participants are in nonwaived areas.5

B. WAIVERS FOR AREAS WITH HIGH UNEMPLOYMENT AND 

INSUFFICIENT JOBS 

The use of waivers is another aspect of the ABAWD provisions in which state policy can 

vary. States can ask USDA to waive the work requirement and time limit for people who live in 

an area with an unemployment rate over 10 percent or with insufficient jobs. Not all states that 

could have qualified for waivers in FY00 chose to apply for them, however. Because states must 

actively seek waivers, the absence of waivers may reflect an explicit state policy decision not to 

eliminate the ABAWD time limit for at least some adults who would otherwise be subject to it. 

In March 2000, 37 states and the District of Columbia had waivers in effect, which are 

usually approved for one year.6

 The waiver in the District of Columbia is unique because it 

covers the entire District, so no one there is subject to the time limit. Alaska’s waivers, also 

unique, are in effect only during the winter and spring months, and the months vary by county. 

The absence of waivers may reflect either a state’s reluctance to exempt ABAWDs or the 

existence of healthy economic conditions, with no area qualifying for waivers. To ascertain how 

often the latter condition occurred, we determined whether the states that did not have waivers in 

effect in March 2000 had areas that were designated as LSAs—the most common criterion by 

which areas qualified for waivers. Ten of the 13 states with no waivers had multiple LSAs in 

 

5

 The FSPQC data will not support a simulation of the policy changes affecting certification of unfitness for 

employment. 

6

 California had a small number of areas with waivers in place during the previous 12 months (Appendix Table 

C9), but these expired before March 2000 and were not renewed. 
93 

2000.7

 In these 10 states, the absence of waivers seems to reflect an unwillingness to exempt 

ABAWDs from the time limit through this mechanism. 

In states with waivers covering only Indian reservations, it is not clear what this pattern 

reflects about state policy. In March 2000, three states—Idaho, Nebraska, and Wyoming—had 

waivers only for Indian reservations. Because all three of these states had multiple LSAs outside 

of the reservations, the observed waiver patterns may reflect Indian reservation preferences more 

than state policy. 

Most states with waivers implemented all that were approved; only New York and 

Washington did not. The primary reasons cited for this choice include (1) an improvement in 

economic conditions in the covered area(s) since the time of application and (2) a choice by local 

Program agencies not to implement after the waiver application. The waivers not implemented 

in New York included New York City, which accounted for nearly two-third of the state’s 

ABAWD population. 

C. THE 15 PERCENT EXEMPTION 

The BBA allows states to exempt some ABAWDs who would otherwise lose eligibility 

under PRWORA. For each state, USDA estimates the maximum number of persons who can be 

exempted under this provision. This estimate, known as the 15 percent exemption allotment, is 

intended to equal 15 percent of persons currently ineligible for the FSP because of the ABAWD 

provisions. Whether the exemption is used by states, the extent to which it is used, and the 

criteria for determining who is eligible for the exemption are matters of state discretion. 

As of March 2000, 35 states were using the 15 percent exemption (an additional 6 states 

planned to use it in the coming year). Most states implemented the 15 percent exemption 

 

7

 Delaware, Iowa, and New Hampshire had no LSAs. The information on these and the other 10 states is based 

on data provided by the Center for Budget and Policy Priorities. 
94 

statewide. Twenty-four of the 35 states use the exemption in every county not covered by a 

waiver. Most of the remaining 11 states do not use the 15 percent exemption in some counties 

because the extent of employment and/or the opportunities to participate in qualifying work 

activities in those counties is sufficiently high. California and New York do not have a statewide 

policy on how to use the exemption, so each county makes its own decision on whether and how 

to use the exemption. 

The 15 percent exemption policy was intended to be flexible and vary by state, and this 

flexibility is retained in the final regulations. As a result, states will continue to vary in the type 

and number of ABAWDs covered by the exemption. 

1. Reasons for Using the 15 Percent Exemption 

States cited a variety of reasons for using the 15 percent exemption (Figure III.5). Fifteen 

states indicated that a primary goal is to exempt as many adults as possible. Twelve states 

reported that a primary goal is to assist a specific population (homeless individuals, for example, 

are exempt in some states). Six states use the exemption to ease the administrative burden of 

partially waived counties by exempting individuals residing in the nonwaived portion of these 

counties. Four states exempt individuals residing in areas that were denied waivers. 

Fifteen states did not use the 15 percent exemption in March 2000, and their reasons varied 

as well. Three states indicated that there were enough jobs and/or qualifying work slots to 

accommodate ABAWDs. Three states wanted to be consistent with their TANF work 

requirements, which do not have broad exemptions like the 15 percent exemption. Four states 

did not use the exemption because of “political reasons,” and five states indicated that the policy 

was too difficult to monitor. 
95 

FIGURE III.5 

REASONS FOR USING THE 15 PERCENT EXEMPTIONa 

1

1

2

4

6

1 2

1 5

A d vocacy G roup Influe nce

Reduce A dm inistrative

Burden

L oca lity D ecision

E xem pt A rea D enied

W aiver

E xe m p t P a rtia lly-W a ive d

Area

He lp S pe cific P o pula tion

E xem pt A s M any A s

P o ssib le

Number of States 

SOURCE: State Food Stamp Program Director Survey a

Thirty-five states used the 15 percent exemption in March 2000; a few states indicated multiple reasons for using 

the exemption. 

Six of the 15 states that did not use the 15 percent exemption in March 2000 indicated that 

they intend to use it in the future. One of these states—Alabama—began using the exemption 

before the end of FY00. 

2. Eligibility Criteria for the 15 Percent Exemption 

The decision on the eligibility criteria for the 15 percent exemption is left entirely to the 

states, and the variation in policy is wide, not only in terms of who is eligible but also in terms of 

the how long people remain eligible. Some states consider all ABAWDs subject to the time limit 

eligible (Figure III.6). Other states use specific geographic or individual characteristics to 

determine eligibility. 
96 

FIGURE III.6 

15 PERCENT EXEMPTION ELIGIBILITY CRITERIAa 

4

10

12

6

All ABAW D s

By Geographic Area

By Specific C haracteristics

By Geographic Area and

Specific C haracteristics

Number of States 

SOURCE: State Food Stamp Program Director Survey a

15 percent exemption policy varies by county in three states, which are not included in this figure. 

Four states consider all ABAWDs who exceed their time limit to be eligible under the 15 

percent exemption, but for different lengths of time. For instance, in Arkansas and Illinois, every 

ABAWD who exceeds the three-month time limit can continue to receive benefits indefinitely 

under the exemption, effectively eliminating the time limit. In Missouri and Tennessee, every 

ABAWD who exceeds the three-month time limit can receive benefits for two additional months 

under the 15 percent exemption, effectively changing the time limit from three to five months. 

However, most states that use the 15 percent exemption have specific eligibility criteria for 

the exemption. In 16 states, ABAWDs can qualify for a 15 percent exemption if they reside in 

certain areas. For example, several states exempt all ABAWDs in counties that are partially 

waived or in areas where the economy and transportation resources are poor, or where E&T 

programs are few or nonexistent. Eighteen states consider ABAWDs with certain characteristics 
97 

to be eligible for the 15 percent exemption. For example, these states might exempt the 

homeless, and individuals with inadequate transportation, with health problems, and those 

deemed unemployable or over a certain age (e.g., Kansas exempts all adults over age 45). Six 

states use both geographic and personal characteristics to determine eligibility for the 15 percent 

exemption. 

States also have discretion on how long an individual can be exempted under the 15 percent 

exemption, and there is some state-to-state variation in this policy as well. In 26 states, 

individuals eligible for a 15 percent exemption remain exempt for as long as they meet the 

criteria. Three other states—Mississippi, Missouri, and Tennessee—limit the number of months 

in which an individual can remain exempt under 15 percent exemption. Missouri and Tennessee 

provide two extra months of benefits to all ABAWDs who exceed the three-month limit; 

Mississippi exempts for six months all individuals waiting for a place in an E&T program. In the 

remaining three states, eligibility workers determine the length of the exemption. In two of these 

states, the length of the exemption varies depending on which eligibility criteria are applicable. 

Five states—Connecticut, Georgia, Indiana, Oregon, and Pennsylvania—intended to 

broaden their 15 percent exemption criteria in the coming year. Connecticut and Oregon planned 

to cover more nonwaived counties. Georgia and Pennsylvania intended to make more types of 

individuals eligible for the exemption, such as homeless individuals or persons with insufficient 

transportation. Indiana expected to extend the time limit for all ABAWDs. 

3. Extent to Which States Use Their Allotments of 15 Percent Exemptions 

The BBA requires that the number of 15-percent exemptions allocated to each state be based 

on 15 percent of the estimated number of individuals in the state who have been denied 

eligibility for food stamp benefits solely because of the ABAWD provisions. As specified in the 

law, FNS estimated this number for FY98 on the basis of both FSPQC data for FY96 and 
98 

projected FY98 caseloads. For each subsequent fiscal year, the FY98 number was updated to 

reflect changes in the states’ FSP caseloads and any changes in the population covered by 

waivers—again, as specified in the law. FNS provides each state with an allotment of average 

monthly exemptions. Any unused exemptions can be carried over to the next fiscal year. Each 

state submits to FNS—on Form FNS 583—a quarterly report of the number of exemptions used. 

The allotment of new 15 percent exemptions nationwide (not including exemptions carried 

over from previous years) varied over the three fiscal years from about 63,500 per month to 

69,000 per month (Table III.1). Two key factors affect the size of the new allotment: (1) the 

size of the FSP caseload and (2) the size of the population covered by waivers. From FY98 to 

FY00, both the FSP caseload and the estimated population covered by waivers decreased. 

Initially, the effects of the decline in the estimated population covered by waivers more than 

offset the effects of the reduction in the FSP caseload, leading to an increase in the new allotment 

from FY98 to FY99. More recently, the drop in the estimated population covered by the waivers 

did not offset the decrease in the FSP caseload, leading to a decrease in the new allotment of 15 

percent exemptions from FY99 to FY00. 

Although states are using an increasing number of 15 percent exemptions, they used only a 

small fraction of the 15 percent exemptions available to them from FY98 through FY00. 

Collectively, the states used only about 8 percent of the total available 15 percent exemptions 

(the allotment plus the carryover from the previous year) in any of the three years. Even if we 

ignore the carryover from previous years, the states used only 14 percent of the allotment in 

FY99 and 21 percent of the allotment in FY00. 

Although more states are using the 15 percent exemption, 14 states were still not using it by 

the end of FY00. And even the states that were using it used only a small fraction of the total 

available allotment—12 percent or less in FY99 and FY00. Figure III.7 shows the distribution of 

states by the percentage of the allotment plus carryover used in FY99. Nineteen states used less 
99 

TABLE III.1 

AVERAGE MONTHLY ALLOTMENTS OF 15 PERCENT EXEMPTIONS AND THEIR USE 

SOURCE: Form FNS-583, Memoranda to Regional FSP Directors from Arthur Foley (FNS website) 

a

As the 15 percent exemption policy was first introduced in FY98, there were no unused exemptions from FY97. 

b

The total allotment of exemptions given to Minnesota in FY00 was calculated using data on the number of 

exemptions used in FY99 that was subsequently revised. Hence, for FY00, the national total allotment with 

carryover is not exactly equal to the allotment without carryover plus unused exemptions from the previous year. 

c

Alabama began using the 15 percent exemption after March 2000. 

than 10 percent of the FY99 allotment. Of the two states that used their allotments to exempt all 

ABAWDs in nonwaived areas, Arkansas used only 19 percent and Illinois used only 41 percent 

of its FY99 allotment. Only one state, Louisiana, used more than 50 percent of its allotment in 

FY99. In fact, Louisiana was unusual in that it used more than 100 percent of its allotment in 

both FY98 and FY99 (it used slightly less than its allotment in FY00). 

Louisiana’s use of more than its entire allotment in FY98 and FY99 reflects, in part, one of 

the difficulties associated with applying the 15 percent exemption to geographic areas. Part of 

the rationale for applying the 15 percent exemption to entire areas is to be able to treat them like 

federally waived areas, in which there is no need to keep track of time-limited months of benefit 

receipt. Indeed, the regulations specifically allow the states to count all of the ABAWDs in 

exempted areas when reporting the number of exemptions used rather than determining and then 

excluding the number who were meeting the work requirement or in their first three months of 

 FY98 FY99 FY00 

New Allotment (Without Carryover) 63,570 69,092 65,720 

Unused Exemptions From Previous Year -a 58,301 118,041 

Total Allotment (With Carryover) 63,570 127,393 183,265b

Number of States That Use 15-Percent Exemption 22 33 36c

Exemptions Used 5,269 9,352 13,970 

As percent of new allotment 8.3% 13.5% 21.3% 

As percent of total allotment 8.3% 7.3% 7.6% 

As percent of total allotment in those states that use 

exemption 

20.9% 12.0% 11.9% 
100 

FIGURE III.7 

PERCENTAGE OF 15 PERCENT EXEMPTION ALLOCATIONS 

USED BY THE STATES, FY99 

1

3

1

6

3

19

17

Over 100%

40 - 49%

30 - 39%

20 - 29%

10 - 19%

1 - 10%

0%

Number of States 

SOURCE: State Food Program Director Survey 

time-limited eligibility. But employing this simplification results in states using up exemptions 

unnecessarily. Indeed, we estimate that as many as a third of the 15 percent exemptions reported 

in March 2000 may have been used on participants who would have been eligible to receive food 

stamps without the exemption.8

 It is likely that Louisiana could have avoided exceeding its 

FY98 and FY99 allotments by limiting its exemptions to those participants in the exempted 

counties who were neither meeting the work requirement nor still using their first three months 

of eligibility. But to do so would have increased the cost of administering the 15 percent 

exemption. 

 

8

 We assumed that participants with time-limited benefits remaining accounted for 30 to 50 percent of the 

exemptions reported by states that use a geographic basis alone to apply the exemption, 15 to 25 percent of the 

exemptions reported by states that use both geographic and individual criteria, and none of the exemptions reported 

by states that use individual criteria alone. 
101 

4. Reasons for Using Fewer Exemptions Than Allotted 

To determine why states use such a small share of the 15 percent exemptions available to 

them, we asked the respondents in the State Food Stamp Director Survey whether the state 

planned to use its full allotment of exemptions in FY00 and, if not, why not. We also asked 

whether the state had used the same, more, or fewer exemptions than they had planned in FY99 

and, if they had not used the same number of allotments as planned, why the actual use differed 

from the planned use. 

About half the states that were using the 15 percent exemption reported that they aimed to 

use all of their allocation in FY00. That only one state approached full use in FY00 underscores 

the difficulty of using all the available exemptions even when motivated to do so. The responses 

to our questions suggest three reasons why states have used such a small proportion of their 

allotment. First, the allotments in some states far exceed the number of ABAWDs that could be 

covered by the 15 percent exemption. Second, states overestimated the number of exemptions 

they would use. Third, some states did not want to use their full allotment. 

a. Allotments Exceed the Covered Population 

Some respondents reported that they could not use all their available exemptions because the 

number of ABAWDs who would qualify is smaller than the number of available exemptions. In 

fact, respondents in nine states said they could not use all their 15 percent exemptions even if 

they exempted every ABAWD who lost eligibility because of the time limit. Data on the number 

of unused exemptions in FY00 support this contention. In 24 states, the average monthly 

number of unused exemptions exceeded the number of ABAWDs not meeting the work 

requirement in March 2000. Hence, if every ABAWD lost eligibility in the subsequent month, 

the state could cover each ABAWD with a 15 percent exemption and still have exemptions left 

over. 
102 

However, point-in-time estimates of ABAWDs potentially eligible for a 15 percent 

exemption ignore the fact that ABAWDs require one exemption for each month that they are 

covered. When we account for the dynamic aspect of the 15 percent exemptions, we still see that 

the total 15 percent exemption allotment remains high relative to the 2000 ABAWD population. 

In March 2000, about 29,000 ABAWDs were in their final month of the time limit and would not 

be able to receive food stamps in the next month. This would make them part of the population 

covered by the 15 percent exemption as expressed in the law. If such persons remained 

otherwise eligible for food stamps for an average of six months, the average monthly covered 

population would be 174,000. Fifteen percent of that population would equal 26,100, but this is 

only two-fifths of the new allotment in FY00 and only 14 percent of the total allotment in FY00. 

These estimates of the covered population are low because they are restricted to those who 

remain continuously eligible in every respect except for their exhaustion of time limited benefits. 

If we confine our attention to this population, it appears that the allotments are indeed large 

relative to 15 percent of this population—even more so in some states than others. 

The high number of allotments is in part the result of an overestimate of the number of 

persons who are denied benefits as a result of the ABAWD provisions. The original estimate of 

the number of allotments is based on the proportion of ABAWDs who were not meeting the 

work requirement in FY96 and on the estimated proportion of these individuals who had failed to 

meet the requirement for at least three months. However, the implementation of the time limit as 

well as the growing economy may have changed the behavior of participants, rendering the 

initial assumption incorrect. In addition, while the law specifies that the allotments be adjusted 

in proportion to changes in the caseload, the number of ABAWD participants has declined more 

rapidly than the total caseload (see Chapter II), resulting in too small a reduction in the annual 

allotments. 
103 

A second reason for the high number of allotments is that states did not use the exemptions 

when the policy was first introduced, so the carryover of exemptions from previous years has 

been large. The carryover of 15 percent exemptions nearly doubled the total availability of 15 

percent exemptions in FY99 and nearly tripled it in FY00. 

In addition, another factor cited by advocacy groups as a reason for the high number of 

allotments is that many of those who would have qualified for benefits under the 15 percent 

exemption left the program after using up their time-limited benefits. Without special outreach 

efforts, these former participants would not be aware that they could qualify, potentially, for 

additional food stamp benefits under the 15 percent provision. 

b. States Overestimated the Number of Exemptions They Would Use 

The number of exemptions used by some states fell short of the number they had planned to 

use. Twelve of the 33 states that used the 15 percent exemption in FY99 had planned to use 

more exemptions but incorrectly estimated the number of ABAWDs who would meet the criteria 

for the 15 percent exemption. In some states, changes in the economy, in the availability of 

qualifying work activities, or in the extent to which ABAWDs were encouraged to participate in 

qualifying work activities caused the actual number of ABAWDs who met the criteria for the 15 

percent exemption to fall short of the estimated number of exemptions that would be used. 

Only two states used more exemptions than planned. In New York, which has a countyadministered FSP, the counties used more than the state expected them to use. In Louisiana, the 

state agency underestimated the number of ABAWDs in the areas in which the 15 percent 

exemptions were used. 
104 

c. States Did Not Want to Use the Full Allotments 

Some states did not want to use the full allotment of 15 percent exemptions. Respondents in 

10 of the 35 states that used the exemption in March 2000 said they did not want to use their full 

allocation.9

 When asked to elaborate, they offered the following explanations:10

• Sufficient Jobs, Workfare, or Other Qualifying Work Activities. Respondents from 

six states said that jobs, workfare, or slots in other qualifying work activities could 

accommodate all ABAWDs subject to the work requirement. 

• Difficulties Choosing Criteria. One respondent in a state where the FSP is countyadministered reported that counties had difficulty in designing criteria for the 

exemption of ABAWDs. 

• Reserving for an Economic Downturn. One respondent said that his state was 

saving exemptions in case of an economic downturn in the state. 

• To Guard against Using Too Many. One respondent reported that his state was 

using the exemption for the first time and therefore wanted to be cautious in applying 

it. 

D. SUMMARY OF STATE ABAWD POLICIES 

ABAWD time limit policies vary from state to state, and in some cases from county to 

county. States use different rules to exempt individuals because of age, disability, and dependent 

children. More important, states vary in their use of both the broad waiver and 15 percent 

exemption policies. As a result, the number and types of ABAWDs subject to the time limit 

differ from state to state. 

Few states’ policies are uniformly strict or lenient across all options. Most states fall 

somewhere between these extremes. We examined the use of four key ABAWD policies in each 

state (disability certification, dependent child exemption, waiver use and 15 percent exemption 

 

9

 Two respondents said they did not want to use all the available exemptions and could not use them even if 

they wanted to. 

10 One respondent said they did not know why they did not plan to use the full allotment. 
105 

use), and we classified each policy as “strict,” “moderate,” or “lenient.”

11 All else being equal, a 

policy that is strict will result in more adults being made subject to the time limit, while a policy 

that is lenient will result in fewer adults being subject to the time limit. We then combined these 

ratings to create an ABAWD policy scale in which the lowest value (zero) represents the strictest 

policies, and the highest value (eight) represents the most lenient. Values for most states fall in 

the middle of the distribution (Figure III.8). In fact, only five states have policies that fall at the 

very strict end of the distribution (values of zero to two), and thirteen states have policies that fall 

at the very lenient end of the distribution (values of six to eight). 

Although in most states, the four policies combine into ABAWD rules that are moderate 

overall, few states employ moderate policies only. Instead, most states use a combination of 

strict, moderate, and lenient policies. In fact, we found almost no correlation between individual 

state policies. For instance, states with lenient disability certification policies do not necessarily 

have lenient dependent child or waiver policies. Likewise, states with lenient 15 percent 

exemption policies do not necessarily have lenient waiver or disability certification policies. 

These findings suggest that states’ agreement or disagreement with the concept of timelimited benefits for ABAWD participants may not be the main factor driving state ABAWD 

policies. For instance, if state policymakers disagreed with the ABAWD restrictions and wanted 

to exempt as many adults as possible, one could argue that they would adopt as many lenient 

policies as possible. Likewise, if state policymakers agreed with the ABAWD restrictions, they 

 

11 We classify disability certification policies based on whether states allow client self-report (lenient), 

caseworker observation but not client self-report (moderate), or neither (strict). We classify dependent children 

policies based on whether all adults in a household are exempt (lenient ), more than one but not all (moderate) or 

only one (strict). We classify waivers based on the percent of each states adults that are covered by waivers (states 

with proportionately more adults covered are considered lenient, states with no waivers are considered strict. 

Finally, we classify 15 percent exemptions based on the percent of each state's allotment that was used (states that 

use proportionately more are considered lenient, states that do not use the 15 percent exemption are considered 

strict). Table C.23 in Appendix C shows the classifications for each of these policies in each state. We did not 

examine state policies on the age adults become exempt because there is little variation in that policy. 
106 

FIGURE III.8 

STATE ABAWD POLICY RANKINGS 

13

32

5

Lenient (6 to 8)

Moderate (3 to 5)

Strict (0 to 2)

SOURCE: State Food Stamp Program Director Survey 

would adopt as many strict policies as possible. But this is not the case—instead, we see unique 

combinations of strict and lenient policies. 

While policies are evidently not driven entirely by state views on time-limited benefits for 

the ABAWD population, the other motivating factors are not clear. Some states may base policy 

decisions on administrative factors, such as ease of implementation. Other states may have 

strong advocacy groups that influence policy choices. Still other states may have competing 

views at various levels of government, leading to variation in policy. 

Even after the final regulations are implemented, we expect to observe continued variation 

in state ABAWD policies, as well as continued variation in the number and types of adults 

subject to the time limit. The regulations continue to allow some state flexibility in determining 

who meets the ABAWD definition. For instance, states maintain discretion over some aspects of 

their policy for certification of unfitness for employment. However, most of the future variation 
107 

will be driven by state waiver and 15 percent exemption policies. The final ABAWD regulations 

do not change state authority to develop and implement policies in either of these areas. 

Although policy variation will continue, we expect to observe a trend towards more 

exemptions from the time limit. Three factors will likely drive this trend. First, while most state 

policies that were in effect in March 2000 are broadly consistent with the final regulations, the 

regulations tend to be more lenient in their specification of criteria for exempting people from 

the ABAWD provisions. For example, 28 states exempted only certain adults in households with 

dependent children, and four of these states exempted only one adult. Under the final 

regulations, all adults in households with any children under 18 will be exempt. Implementation 

of the final regulations will make ABAWD policy more lenient in at least one respect in all but 

three states, with 39 of these states requiring changes in two or more policy areas. At the same 

time, the only states required to create stricter ABAWD policies in any area are the 16 that 

permitted a self-report of unfitness for employment. Under the final regulations, adults must 

show proof of unfitness if this condition is not evident to the caseworker. 

The second factor likely to drive the trend toward more exemptions is greater use of the 15 

percent exemption. FSP directors in six of the states that were not using the 15 percent 

exemption in March 2000 indicated that they had plans to use it in the future, and about half of 

the states that were using the 15 percent exemption reported that they were aiming to use their 

full allocation. While only one state has used its full allocation in any year, the total number of 

exemptions used by the states has increased substantially from year to year. 

Finally, if national economic conditions worsen in coming years, states will be in a position 

to apply for more waivers. States that already have waivers may find that more areas qualify, 

while states without waivers may decide to use them. Any additional waivers will exempt even 

more adults from the time limit. 
 109 

IV. HELPING ABAWDS MEET THE WORK REQUIREMENT: 

POLICIES AND CHALLENGES 

The intent of PRWORA is to limit how long people who are able, but unwilling, to work or 

participate in a work activity can receive food stamps. The law allows ABAWDs to meet the 

work requirement and avoid the time limit in one of two ways: working 20 hours or more per 

week or participating in a qualifying work activity. Nationwide, in March 2000, just over half of 

all ABAWDs subject to the time limit met the work requirement (Chapter II). But this 

nationwide average masks considerable variation across the states: less than 5 percent met the 

requirement in some states while more than 80 percent met it in others. While variation in state 

economies and characteristics of the ABAWDs undoubtedly affected this percentage, variation in 

state policies may also have played a role. This chapter discusses the extent to which states have 

implemented policies to assist ABAWDs in meeting the work requirement. 

Nationwide, just less than one-quarter of all ABAWDs subject to the time limit met the 

work requirement by working. This chapter describes how state policies vary in the extent to 

which they assist ABAWDs in finding and retaining employment. In particular, it describes how 

they vary in the extent to which they provide support services, such as transportation assistance, 

the extent to which they require ABAWDs (and other FSP participants) to search for a job, and 

in the assistance and training they provide ABAWDs in that search. Prior to the implementation 

of the final regulations, states also had flexibility in what they count as “work.” 

About another one-quarter of all ABAWDs subject to the time limit met the work 

requirement by participating in a qualifying work activity, mainly workfare or an education or 

training program. For the most part, states’ food stamp E&T programs funded these work 

activities. This chapter shows how states vary considerably in the number and types of work 

activities they offer ABAWDs and the extent to which the activities are available for all 
 110 

ABAWDs who are subject to the work requirement. We also discuss perceptions of the 

effectiveness of the work activities and other services provided to ABAWDs and the challenges 

in providing those services. 

The findings presented in this chapter draw mainly on the State E&T Managers Survey and 

hence refer to FY99. The discussion of the effectiveness of work activities and the challenges in 

engaging ABAWDs in work activities draws mainly on the Local E&T Managers Survey, which 

took place in Spring 2000. Some findings are also drawn from the State Food Stamp Program 

Directors Survey, which also refers to 2000. The survey data are supplemented by FY99 data on 

the use of E&T services by ABAWDs as submitted by the states to FNS on Form FNS 583. 

We excluded the District of Columbia when presenting the findings because the District has 

always had a waiver that exempts all of its residents from the ABAWD time limit. However, we 

do include Arkansas and Illinois, even though these two states use the 15 percent exemption to 

exempt all ABAWDs who would otherwise lose benefits because of the time limit. These states 

were included because the availability of qualifying work activities in these states affects the 

number of 15 percent exemptions that they use. 

We begin by discussing states’ policies on meeting the work requirement through work and 

the support services that are available to help ABAWDs find and retain employment. Next, the 

extent to which states offer ABAWDs qualifying work activities is described. Then, we discuss 

the perceived effectiveness of work activities and other services in helping ABAWDs find 

employment. We then discuss the available data on participation in qualifying work activities. 

The challenges of providing qualifying work activities and other services to ABAWDs and some 

approaches to addressing these challenges are also discussed. We conclude with a summary of 

our findings. Appendix D presents our findings by state. 
 111 

A. MEETING THE WORK REQUIREMENT THROUGH WORK 

The goal of the ABAWD regulations is to promote self-sufficiency through work. Hence, 

ABAWDs who work 20 hours or more per week can remain on food stamps indefinitely. 

1. State Policy on What Counts as Meeting the Requirement through Work 

Before the final ABAWD regulations became effective, the states had some flexibility in 

what counts as meeting the work requirement through work. First, states can decide whether to 

allow work without pay to meet the work requirement. Second, states can decide whether 

ABAWDs can meet the work requirement by combining work and participation in a qualifying 

work activity. Table IV.1 summarizes state variation in these policies. 

Most states (39) had statewide policies on both whether volunteer work counts toward 

meeting the work requirement and whether an ABAWD can meet the work requirement by 

combining work and other qualifying work activities. In the states that had not state or local 

policy, the decision on what counted work was either left up to the caseworkers’ discretion or 

decided upon by the local office when the issue arose. Twenty states had a statewide policy that 

counted both work without pay and a combination of work and other qualifying work activities. 

Only three states prohibited both counting volunteer work and combining work and other 

qualifying work activities. 

About half of all states (23) always counted unpaid or volunteer work toward meeting the 

work requirement. However, several respondents in the 16 states in which volunteer work was 

never counted said that if an ABAWD found a volunteer position, his or her caseworker would 

try to take the administrative steps to make it into a workfare position. Five states allowed 

volunteer work to count only under certain circumstances, such as if there were payment in-kind 

for the work, if the work were a community service position, or if the participant’s caseworker 

had approved the position. 
 112 

TABLE IV.1 

STATE POLICIES TOWARD MEETING THE WORK REQUIREMENT BY WORKING 

 Policy 

 Total Always Sometimes Never 

Volunteer Work Counts 

Statewide policy 44 23 5 16 

No statewide or local policy 6 n.a. n.a. n.a. 

Work Can Be Combined with Other 

Qualifying Work Activity 

 

Statewide policy 45 35 3 7 

No statewide or local policy 5 n.a. n.a. n.a 

Both Policies 

Statewide policy 39 20a

 16b 3c

No statewide or local policy 11 n.a. n.a. n.a. 

SOURCE: State Food Stamp Program Director Survey, 2000 

a

States that always count volunteer work and combinations of work and participation in qualifying work activities 

b

States that do not count both volunteer work and combinations of work and participation in qualifying work 

activities, but count either volunteer work or combinations of work and participation in qualifying work activities at 

least sometimes. 

c

States that never count volunteer work or combinations of work and participation in qualifying work activities 

n.a.: Not applicable 

Just over two-thirds of all states (35) had a statewide policy that explicitly allowed a 

combination of work and participation in work activities to satisfy the work requirement under 

all circumstances. Another three states allowed a combination to count under certain 

circumstances, such as if there were “not enough” jobs or qualifying work activities for the 

ABAWD to satisfy the work requirement solely by one activity or if the combined number of 

hours in work and work activities totaled 30 or more. 

The final ABAWD regulations remove some of the states’ flexibility in determining what 

counts as meeting the work requirement. They require that volunteer work be considered as 

satisfying the work requirement in accordance with “standards established by the State agency”

and that combined hours in work and participation in a qualifying work activity count as 
 113 

satisfying the work requirement.1 For the 30 states that did not already have statewide policies in 

place allowing both volunteer work and combinations of work and participation in work activity 

to count, the regulations are likely to increase the number of ABAWDs who satisfy the work 

requirement. 

2. Job Search and Job Search Training 

Even before PRWORA, the Food Stamp Act gave states the option to require food stamp 

participants who are subject to food stamp work registration (including all participants who 

subsequently became subject to the ABAWD time limit) to participate in job search or job search 

training for up to 120 hours a month, less any hours of workfare participation and/or any work 

hours. Hence, in some states, ABAWDs are required to conduct job search or job search training 

or be subject to a sanction. This requirement is in addition to the ABAWD work requirement. 

PRWORA explicitly excluded job search and job search training from the list of qualifying 

work activities unless the job search or job search training was part of a JTPA (now WIA) or 

Trade Adjustment Assistance (TAA) program. FNS later advised states that job search and job 

search training in the first 30 days of a workfare program also counted as a qualifying work 

activity. The final ABAWD regulations also allow job search and job search training to count as 

a qualifying work activity as long as it was a “subsidiary” part of a qualifying program and the 

job search activity was “less than half of the requirement.” Other than these exceptions, 

conducting a job search or participating in job search training does not count toward the 

ABAWD work requirement. 

 

1

 The regulations also state that work paid in-kind (such as in exchange for food or free rent) should be 

considered paid work. 
 114 

a. Job Search 

In FY99, more than two-thirds of states (34) required at least some participants who register 

for work, and hence some ABAWDs, to conduct a job search (Table IV.2). Of these, 27 states 

had either a statewide policy or had local policies in effect on how ABAWDs could satisfy the 

job search requirements. The requirements varied by state but were usually defined in terms of a 

minimum number of hours spent searching and/or a minimum number of contacts in a specified 

time period. Requirements ranged from 8 hours per day to 12 hours per month and 15 contacts 

per week to 10 contacts per month. Eight states had other requirements, such as requiring job 

counseling or participation in a job club, in addition to an hour or contact requirement. 

All but three states that required a job search provided participants some services (other than 

job search training) to help with this search.2

 Typically, states provided access to telephones to 

contact employers, access to word processors or typewriters, and lists of names of employers. 

b. Job Search Training 

Most states (30) that required a job search also offered job search training to at least some 

ABAWDs (Table IV.2). In addition, five states that did not require a job search offered job 

search training to some ABAWDs. 

All but one of the states that offered job search training offered training in resume writing, 

interviewing skills, and “soft skills,” such as how to dress for work or communicate with bosses 

and coworkers. In addition, most states provided training in time-management and/or money 

management skills. Many of the states (18) offering job search training reported that they also 

 

2

 In two additional states, California and Maryland, the respondent did not know what services were provided 

in the local offices. 
 115 

TABLE IV.2 

STATES THAT REQUIRED JOB SEARCH AND/OR OFFERED JOB SEARCH TRAINING TO AT LEAST 

SOME ABAWDS IN NONWAIVED AREAS 

Availability of Job Search Training 

 Offered Not Offered 

Require Job Search 30 4 

Do Not Require Job Search 5 11 

SOURCE: State E&T Managers Survey, FY99 

provided assessment/aptitude testing or training in other topics such as job retention, anger 

control, or personal hygiene. 

3. Work-Related Support Services 

To what extent do the states provide support services, such as assistance with transportation 

or other job-related expenses to ABAWDs who are working? The majority of states (45) 

provided some support services in FY99. Of these, 32 states provided one or more services in all 

nonwaived areas of the state; 13 states provided it in some but not all nonwaived areas. 

States varied in the types of support services they provided to ABAWDs. Figure IV.1 

presents the number of states that provided each type of service. All states that offered support 

services provided reimbursements for transportation expenses. The Food Stamp Act 

provides federal funding to match dollar-for-dollar state spending on transportation and other 

work-related expenses (other than dependent care) up to a cap of $12.50 per person per month. 

Seventeen states paid ABAWDs more than $25 per person per month for these expenses and thus 

paid more than 50 percent of the cost. In addition to providing work supplies and uniforms, 

paying for testing and licensing, and providing or paying for clothing for interviews, some states 

paid for some other noncash assistance such as medical services, eyeglasses, books and manuals, 
 116 

FIGURE IV.1 

TYPES OF WORK-RELATED SUPPORT SERVICES OFFERED TO ABAWD PARTICIPANTS 

25

27

28

45

13

3

0 50

Emergency Cash

Assistance

Other Non-Cash

Assistance

Clothing for Job

Interviews

Payment for

Testing/Licensing

Work

Supplies/Uniforms

Transportation

Reimbursement

Number of States

25

27

28

45

13

3

0 50

Emergency Cash

Assistance

Other Non-Cash

Assistance

Clothing for Job

Interviews

Payment for

Testing/Licensing

Work

Supplies/Uniforms

Transportation

Reimbursement

Number of States

SOURCE: State E&T Managers Survey, FY99

drivers’ education, car repairs, and payment of fees to renew drivers’ licenses. Three states also 

made available one-time emergency cash assistance for ABAWDs. 

On average, the states offered just less than three types of support services (the different 

types are listed in Figure IV.1). However, this average masks considerable variation across 

states in the number of services offered (Figure IV.2). Five states offered no support services to 

ABAWDs. Fourteen states provided only reimbursement for transportation and other expenses, 

and 12 of these states only spent up to the cap eligible for federal matching funds, providing 

participants at most $25 per person per month. In contrast, 23 states provided four or more 

different types of services. 
 117 

FIGURE IV.2 

DISTRIBUTION OF STATES BY NUMBER OF DIFFERENT TYPES OF SUPPORT SERVICES OFFERED 

TO ABAWD PARTICIPANTS 

5

14

4 4

9

13

1

0123456

Number of Supportive S ervices Offered

SOURCE: State E&T Managers Survey, FY99 

B. AVAILABILITY OF QUALIFYING WORK ACTIVITIES 

An unemployed ABAWD can meet the work requirement by participating in workfare or by 

participating in another qualifying work activity for 20 hours or more per week. Qualifying 

work activities fall into five categories: (1) workfare or other work programs, (2) education 

programs, (3) vocational training, (4) self-employment programs, and (5) under certain 

circumstances, job search and job search training. As described earlier, job search and job search 

training only qualify if they are provided as part of a WIA (formerly JTPA) or TAA program, or 

are a subsidiary part of a qualifying work activity. 

Most, but not all, of the qualifying work activities available to ABAWDs are funded by the 

food stamp E&T program. Other states use 50 percent federal matching funds rather than the 

100 percent E&T funds to fund some qualifying work activities. Some qualifying work activities 

are funded with WIA (formerly JTPA) funds. 
 118 

1. Number of States Offering Qualifying Work Activities 

Nearly all states (47) provided at least one of the five types of qualifying work activity for 

some ABAWDs in some areas of the state in FY99 (Table IV.3).3

 Three states—Iowa, 

Oklahoma, and Rhode Island—provided no qualifying work activities at all. Hence ABAWDs in 

these states could only satisfy the work requirement by working or self-financing their 

participation in education or vocational training.4 

States varied, however, in the number of qualifying work activities they offered (Figure 

IV.3). Of those states that offered some form of qualifying work activity, seven states provided 

only one of the five types of activity. The median number of different services offered was 

three; the mean number of services offered was just less than three. 

2. Types of Qualifying Work Activities Offered 

The types of qualifying work activities offered also varied by state. However, 26 states 

offered at least the following three activities--workfare, education, and vocational training. 

a. Workfare and Other Work Programs 

Work programs were by far the most frequently offered qualifying work activity. Forty 

states offered workfare or another type of work program (Table IV.3). This finding is confirmed 

by data submitted by the states to FNS on the FNS 583 that show 86 percent of all “slots” or 

places in E&T filled by ABAWDs in FY99 were workfare slots. It is also consistent with our 

 

3

 Data on the provision of job search and job search training through JTPA/TAA were collected for March 

2000, while the data on the provision of other qualifying work activities refers to FY99. 

4

 Iowa provided some job search training for ABAWDs; Oklahoma and Rhode Island (much of which is 

covered by waivers) provided no E&T services at all. By 2000, when the Local E&T Managers Survey was 

conducted, Rhode Island provided some limited E&T services. 
 119 

TABLE IV.3 

NUMBER OF STATES OFFERING QUALIFYING WORK ACTIVITIES TO ABAWDs 

 Activity Offered In: 

Activity 

Some Areas of 

the State 

Some Nonwaived 

Areas of the State 

All Nonwaived 

Areas of the State 

At Least One Qualifying Activity 47 46 32 

Workfare or Other Work Program 40 39 26 

Education Program 34 32a

 22a

Vocational Training 34 32a

 24a

Self-Employment Program 5 5 1 

Job Search/Job Search Training as Part of 

JTPA/TAAb

26 -c

 -c

SOURCE: State E&T Managers Survey FY99 and State Food Stamp Program Director Survey 2000 

a

One respondent did not know in which areas the activity was offered. 

b

These data were obtained from the State Food Stamp Program Director Survey and so refer to 2000. 

c

The survey did not ask in which areas the JTPA or TAA programs were offered. 

FIGURE IV.3 

DISTRIBUTION OF STATES BY NUMBER OF QUALIFYING WORK ACTIVITIES OFFERED 

ANYWHERE IN STATE 

3

7

8

14

16

2

012345

Number of Qualifying W ork Activities

SOURCE: State E&T Managers Survey, FY99 
 120 

finding in Chapter II that of those ABAWDs meeting the work requirement, 45 percent met it 

through workfare while only 9 percent met it through other qualifying work activities. 

Section 20 of the Food Stamp Act defines workfare as an activity in which food stamp 

participants perform work in a public service capacity in exchange for the food stamp benefits to 

which their household is entitled. Workfare provides positions for ABAWDs in public or private 

not-for-profit organizations only. The hours of participation in workfare are limited to the 

number of hours needed to “pay off” the household’s monthly benefit allotment at the higher of 

the applicable federal or state minimum wage. 

Most states (93 percent) that offer qualifying work programs to ABAWDs offer Section 20 

workfare programs (Table IV.4). However, four states operated an “optional” workfare 

program—a workfare program that need not meet all the requirements of the Section 20 

workfare programs and is funded with only 50 percent federal matching funds rather than 100 

percent federal E&T funds. Twelve more states operated other types of work programs that also 

provided work experience but with different requirements and funding than the workfare 

program. 

While most workfare slots are arranged by the Food Stamp E&T agency, some states allow 

ABAWDs to find their own “self-initiated” workfare positions. Of the 37 states that offered 

Section 20 workfare, 18 states provided prearranged workfare positions and also allowed 

ABAWDs to find their own positions, 17 states provided prearranged workfare positions but did 

not allow ABAWDs to obtain their own positions, and two states allowed ABAWDs to find their 

own self-initiated positions but did not provide any prearranged positions. 

The workfare programs may require participants to conduct job search or job search training 

in the first 30 days of the workfare program before they begin work at a site. This job search or 

job search training is counted as a qualifying activity as long as it is less than half of the 
 121 

TABLE IV.4 

NUMBER OF STATES OFFERING DIFFERENT TYPES OF WORK PROGRAMS 

Type of Work Program Number of States 

Section 20 Workfare Program Only 24 

Optional Workfare Program Only 1 

Another Type of Work Program Only 2 

Section 20 Workfare Program and Optional Workfare Program 3 

Section 20 Workfare Program and Another Type of Work Program 10 

Any Workfare or Work Program 40 

SOURCE: State E&T Managers Survey, FY99 

program. In the State Food Stamp Program Director Survey, nearly 70 percent of the 

respondents whose states provided workfare in 2000 required job search or offered job search 

training as part of their workfare program.5

 

Most states that offered workfare and/or other work programs did not place a limit on the 

length of time spent in workfare. However, one state limited participation in workfare to 33 out 

of 36 months and five states limited participation in workfare to two to six months. 

b. Education and Vocational Training Programs 

After workfare, education and vocational training were the most frequently offered 

qualifying work activities. Thirty-four states offered education and the same number offered 

vocational training (Table IV.3). 

The three most common types of education programs offered to ABAWDs were: classes 

aimed at providing a high school or GED diploma (offered by 33 states); classes to teach basic 

mathematics and literacy skills (offered by 31 states); and English as a Second Language classes 

 

5

 In March 2000, 43 states offered workfare or other work programs and 30 included job search or job search 

training. 
 122 

(offered by 29 states).6 Of the 34 states that provided any education programs for ABAWDs, at 

least 26 states offered all three of these types of classes. Six states offered some type of 

secondary or post-secondary education and two states offered driver’s education. 

Typically, states that provided vocational training to ABAWDs offered some classroom 

training (31 states) and some on-the-job training (19 states).7 Of the 34 states that provided 

vocational training to ABAWDs, at least 19 states offered both classroom training and on-the-job 

training. 

Fifteen states placed some limit on the amount of time an ABAWD could spend in either an 

education and/or a vocational program. Only eight states, however, placed limits on the number 

of months an ABAWD could participate in these programs. The limits varied from 3 to 24 

months. 

c. Self-Employment Programs 

Self-employment programs were the least frequently offered types of activity—only five 

states offered them. Although the content of these programs varied by state, they typically 

involved assistance in developing business plans, training in financing and business 

opportunities, and referrals to community organizations. 

3. Availability of Activities In Nonwaived Areas of the State 

Some of the states that offered qualifying work activities did not offer them in all food 

stamp offices. While 47 states offered at least one qualifying work activity somewhere in the 

state, only 32 states offered at least one qualifying work activity other than JTPA or TAA job 

search or job search training in all nonwaived areas of the state (Table IV.3). Among these 

 

6

 Two respondents did not know what types of education programs were offered. 

7

 Three respondents did not know what types of vocational programs were offered. 
 123 

states, there were on average two qualifying work activities available in all nonwaived areas 

(Figure IV.4). 

4. Availability of Qualifying Work Activities for ABAWDs Who Wish to Participate 

in Them 

While more than half the states offered at least one qualifying work activity in all nonwaived 

areas, there may not have been sufficient capacity in the available programs to offer a place or 

slot for all ABAWDs who wanted to participate. To explore the relative availability of slots, for 

each type of qualifying work activity, we asked state E&T managers whether a slot was available 

for any ABAWD subject to the time limit who wished to participate in that activity. 

FIGURE IV.4 

DISTRIBUTION OF STATES BY NUMBER OF QUALIFYING WORK ACTIVITIES OFFERED TO 

ABAWDS IN ALL NONWAIVED AREAS OF STATE 

18

8

11

13

0123

Number of Qualifying W ork Activities

SOURCE: State E&T Managers Survey, FY99 
 124 

Workfare was the activity that states were most likely to be able to offer to all ABAWDs 

who wanted to participate—22 states had a prearranged workfare slot for every ABAWD 

participant in nonwaived areas who wanted one (Table IV.5). About one-third of all states 

reported having a slot in an education or vocational training program for all ABAWDs who 

wanted one. 

A little over half of the states (28) reported having at least one qualifying work activity 

available for any ABAWD participant in nonwaived areas who wanted to participate in that 

activity (Figure IV.5). Relatively few states, however, could offer more than one type of work 

activity to all ABAWDs. Only 18 states had two or more work activities available for every 

ABAWD who wanted to participate. 

5. Work Activities Offered to ABAWDs Who Have Reached the Time Limit and 

Become Ineligible 

Many states (38) also offered activities to allow ABAWDs to regain FSP eligibility after 

they had reached the time limit. A majority (30) of these states offered the qualifying activities 

in all nonwaived areas. Of the 12 states that did not offer activities to nonparticipants, two states 

used the 15 percent exemption so that no ABAWD lost eligibility because of the time limit, three 

states provided no qualifying work activities to any ABAWDs, and the remaining seven states 

offered qualifying work activities only to ABAWDs who were still participating in the FSP. 

TABLE IV.5 

NUMBER OF STATES OFFERING A SLOT IN A QUALIFYING WORK ACTIVITY TO ALL ABAWD 

PARTICIPANTS IN NONWAIVED AREAS WHO WANTED ONE 

Prearranged Slot in Workfare or Other Work Program 22 

Education Program 16 

Vocational Training 17 

SOURCE: State E&T Managers Survey, FY99 
 125 

FIGURE IV.5 

DISTRIBUTION OF STATES BY NUMBER OF QUALIFYING WORK ACTIVITIES AVAILABLE TO 

ALL ABAWDS WHO WANTED TO PARTICIPATE 

22

10

11

7

0123

Number of Qualifying W ork A ctivities

SOURCE: State E&T Managers Survey, FY99 

How much ABAWDs who have lost eligibility use these activities depends in part on the 

extent to which the ABAWDs know they are available. However, of the local offices surveyed 

in the Local E&T Managers Survey, only 29 percent undertook outreach efforts to advise 

ABAWDs who had lost their eligibility that they could regain eligibility by participating in a 

qualifying work activity. 

6. Use of Federal Food Stamp E&T Funds 

Even though many states did not provide qualifying work activities to all ABAWDs who 

wanted to participate in a work activity, the states were far from using all available federal funds. 

The BBA required that at least 80 percent of the federal E&T grant be earmarked for qualifying 

work activities for ABAWDs. The remaining 20 percent of the allocated funds may be spent on 

activities that are not qualifying, such as job search, or on FSP participants who are not 
 126 

ABAWDs. Overall, states spent only 44 percent of total available federal E&T funds in FY99 

and 32 percent of the funds earmarked for qualifying activities for ABAWDs. 

Fifteen states spent 20 percent or less of the available funds, and seven of those did not 

spend any of the federal E&T funds on ABAWDs (Figure IV.6). Only two states spent all of the 

funds earmarked for ABAWDs only. 

Why are the states not using all the available E&T funds for ABAWDs? In the State E&T 

Managers Survey, we asked whether the states planned to use all their FY99 allocation, and if 

not, why not. Of the 48 states that did not spend their full allocation, 25 states planned to use 

less than the full allocation, 17 states planned to use all the allocation, and 6 states said they did 

not yet know the percentage they planned to spend. 

Respondents from the 25 states that did not plan to use all their allocation gave three related 

reasons. First, 18 respondents said that there were too few ABAWDs willing to participate in the 

qualifying work activities. Some of these states were concerned that it would not be economical 

to develop new types of activities or activities in new areas of the state. The number of 

ABAWDs subject to the time limit was relatively small and still falling in FY99 and, as we will 

discuss in the next section, ABAWDs have a low rate of participation in the activities that are 

offered. Since funding is provided on a per slot basis with reimbursement caps, the states were 

concerned that they would not recover the fixed costs of providing new work activities. 

In FY99, FNS approved eight states as “alternative reimbursement” states. These states 

were not subject to the reimbursement caps, but in return were required to offer a qualifying 

work activity slot to all ABAWDs in nonwaived areas. Most of these states used a higher than 

average proportion of their allocation of federal funds. While less than one-third of all states 
 127 

FIGURE IV.6 

DISTRIBUTION OF STATES BY PERCENTAGE OF E&T FUNDS DRAWN IN FY99 

15

19

11

3

100% 2

81-99%

51-80%

21-50%

20% or Less

Number of States 

SOURCE: Botsko et al. 2000 

used more than half of their allocation of federal funds, six out of the eight alternative 

reimbursement states spent more than half. All of the states, except South Dakota, exceeded the 

per slot reimbursement rate, often by large amounts (Botsko et al. 2000). 

Second, 11 respondents cited issues related to the requirements for using the federal funds. 

One specific concern expressed was the difficulty meeting the maintenance of effort 

requirement--the requirement that the state does not spend less on E&T from nonfederal sources 

that it did in FY96. Other concerns included uncertainty over the budget or the policy and the 

general complexity of the requirements. 

Third, respondents in four states said that they thought providing more work activities for 

ABAWDs was ineffective. One respondent said that work activities were ineffective unless they 

could provide transportation and other support services that were not reimbursable from these 
 128 

funds. Another respondent said that services were available for ABAWDs from other sources, 

such as JTPA. 

Although the State E&T Managers Survey did not ask why the 17 states that had planned to 

spend all their federal funds did not do so, several managers said that the number of ABAWDs or 

the number of ABAWDs who wished to participate in the work activity was lower than they had 

expected. 

C. PERCEIVED EFFECTIVENESS OF EMPLOYMENT AND TRAINING 

SERVICES FOR ABAWDS 

Does participation in qualifying work activities help ABAWDs find employment? Are other 

E&T services that are not qualifying work activities, such as job search training and support 

services, also helpful? For each service offered, we asked the respondents to the Local E&T 

Managers Survey whether they thought the service was helpful for some ABAWDs. The 

respondents who viewed a service as helpful for some ABAWDs were asked to tell us for which 

type of ABAWD it was helpful and why. 

A large majority of respondents reported that each service had helped at least some 

ABAWDs secure or retain employment (Table IV.6). Participation in education programs, job 

search training, and support services were most widely viewed as helpful. Workfare and 

vocational training were also viewed as helpful, but by a somewhat smaller proportion of 

respondents. 

Different activities are viewed as helpful for different types of ABAWDs. Workfare and 

other work programs are helpful for ABAWDs who lacked the “soft skills” necessary for work, 

such as how to dress for work, get into a work routine, attend to personal hygiene, as well as to 

communicate and behave appropriately with coworkers and bosses. Managers also reported that 

workfare is helpful for ABAWDs with little or no labor market experience, because it allows 
 129 

TABLE IV.6 

PERCENTAGE OF RESPONDENTS WHO VIEWED E&T SERVICE AS HELPFUL FOR SOME ABAWDS 

Number of 

Respondents 

Whose Office 

Offers Service 

Percentage of 

Respondents Who 

Viewed Service 

as Helpful 

Type of ABAWDs Who Managers Viewed 

Most Likely to Benefit from Service 

Workfare 73 89% Those Without Soft Skills or Work Experience 

Education 70 96% Those Who Lack Credentials 

Vocational Training 61 92% Those Who Lack Marketable Skills 

Job Search Training 76 99% Those Who are Job Ready 

Support Services 92 95% Those With Transportation Barriers 

SOURCE: Local E&T Managers Survey, 2000 

ABAWDs to gain work experience and earn good references from local employers. On the other 

hand, some respondents argued that for ABAWDs who are job ready, workfare can be 

distracting, reducing the time the ABAWDs have to look for regular employment. 

Many E&T managers reported that education programs are especially helpful for ABAWDs 

who lack credentials. By helping ABAWDs earn a high school diploma or GED, these programs 

can considerably increase their likelihood of securing employment. 

Many managers viewed vocational training as most helpful for ABAWDs who lack specific 

marketable skills. These may be ABAWDs who have work experience and a high school 

credential, but need training for a specific occupation. These may also be older persons whose 

current skills are obsolete or who can no longer do the work they used to and need to learn new 

skills. 

Job search training was viewed as most helpful for those ABAWDs who are job ready but 

lack work experience. It is seen as particularly helpful for ABAWDs with a high school 

credential or who had basic mathematics and literacy skills, but did not have a long employment 

history. 
 130 

Most respondents viewed support services as helpful for people with transportation barriers. 

Most respondents said transportation assistance is especially helpful for ABAWDs in rural areas. 

Other desirable support services include the provision of clothing, energy assistance, eyeglasses, 

uniforms, and tools. 

D. PARTICIPATION IN WORK ACTIVITIES BY ABAWDS 

 Both state and local E&T managers reported that many ABAWDs are unwilling to 

participate in work activities. Some local managers reported that many ABAWDs are referred to 

E&T services but do not show up to participate, instead choosing to use up their time-limited 

benefits and leave the FSP. While we would like to accurately quantify the rate at which 

ABAWDs choose to participate in qualifying work activities, the data necessary to do so are not 

available. However, information collected by FNS to reimburse the states for their E&T services 

is broadly consistent with the reports that many ABAWDs choose not to participate. 

States are reimbursed for slots in qualifying work activities that they fill each month. They 

are also reimbursed for “offered” slots--slots that are offered but not filled because they are 

refused or because the client does not show up to participate in the activities. A single slot can be 

offered to more than one ABAWD and is counted as an “offered” slot each time it is offered but 

not filled. However, a slot can be counted as filled only once in a month. Both the monthly 

number of filled slots and the monthly number of offered slots are reported on Form FNS 583. 

Nationally in FY99, the number of filled slots in any qualifying activity was 72 percent of 

the sum of filled and offered slots in nonwaived areas. The number of filled slots in workfare as 

a proportion of the sum of filled and offered slots was similar (73 percent). The percentage of 

slots filled in education and vocational training was slightly lower (67 percent). However, there 

is great variation across states in these numbers (Figure IV.7). While in 14 states, more than 75 

percent of filled and offered slots in any qualifying activity were filled, in seven states less than 
 131 

FIGURE IV.7 

PERCENTAGE OF FILLED AND OFFERED SLOTS IN QUALIFYING WORK ACTIVITIES THAT WERE 

FILLED BY ABAWD PARTICIPANTS, NONWAIVED AREAS, FY99a 

7

7

14

8

14

Offers No Qualifying

E&T Slots

Less than 25%

25% to 49%

50% to 74%

75% or More

Number of States

b 7

7

14

8

14

Offers No Qualifying

E&T Slots

Less than 25%

25% to 49%

50% to 74%

75% or More

Number of States

b

SOURCE: FNS 583 a

 Includes only qualifying work activities funded by federal E&T funds. 

b

One survey respondent reported that their state provided no qualifying E&T slots in FY99 but FNS 583 showed that 

they provided some slots. This figure reflects the FNS 583 data rather than the survey response. 

25 percent of filled and offered slots were filled. The two largest states--California and New 

York—have particularly high proportions of filled slots and substantially increase the national 

average. The number of filled slots as a percentage of offered and filled slots falls to about 40 

percent if these two states are excluded. 

It is important to note that these figures should not be interpreted as the percentage of the 

total available slots in work activities that are filled. Because single slots can be counted 

multiple times as “offered” slots by being offered to more than one ABAWD, the sum of filled 

plus offered slots could be greater than the number of existing slots in work activities. Similarly, 
 132 

as some slots may not be offered at all in a month, the sum of filled plus offered slots could be 

less than the number of existing slots. 

These figures do, however, provide an upper-bound to the proportion of ABAWDs who 

accept a slot when offered one—the proportion of ABAWDs who accept an offered slot in a 

month must be no greater than 72 percent and is probably considerably lower. By including the 

slots offered and accepted by ABAWDs in earlier months, the number of filled slots always 

exceeds the number of slots newly offered in the month. Hence, the proportion of filled and 

offered slots that are filled will be greater than the proportion of ABAWDs who are offered a slot 

that accept it. As an illustration of the extent to which the figures could overstate the rate at 

which offered slots are accepted: if half of qualifying work activity slots filled in a month were 

offered for the first time in that month, the finding that 72 percent of filled plus offered slots 

were filled implies that only about 56 percent of the ABAWDs that were offered slots in that 

month accepted the offer. In addition, the rate at which offers are accepted may overstate 

ABAWDs’ willingness to participate because in some states ABAWDs may not even be offered 

a slot if they do not show up at their E&T interview. 

E. CHALLENGES OF PROVIDING E&T SERVICES TO ABAWDS 

The majority of the respondents to our surveys at both the state and local level (88 percent of 

state E&T managers and 60 percent of the surveyed local office E&T managers) reported that 

there are significant challenges in providing E&T services to ABAWDs. The challenges 

described below are based on the responses of both state and local E&T managers when asked to 

describe the specific challenges they faced in providing E&T services to ABAWDs. 

1. Low Rate of Participation in Work Activities 

Between 40 and 48 percent of state and local E&T managers cited low participation as a 

challenge in serving ABAWDs. We asked local E&T managers what, if any, factors discouraged 
 133 

ABAWDs from participating in both qualifying work activities and job search training. More 

than half of the local E&T managers reported factors that discouraged ABAWDs from 

participating in each of these activities (Table IV.7). Three broad sets of reasons were given: 

(1) lack of motivation, (2) personal barriers to participation, and (3) lack of support services. 

a. Lack of Motivation 

Local E&T managers observed that some ABAWDs just do not want to put any effort into 

participating in available activities and mentioned that ABAWDs often do not show up for 

appointments. This was particularly the case for workfare. Twenty-five local-office managers 

said that the lack of regular pay was a factor in discouraging participation in workfare. Many 

said that ABAWDs considered the “lack of pay” in workfare as a “punishment.” 

b. Personal Barriers 

Managers also stated, however, that there are some ABAWDs with personal barriers that 

prevent them from participating. Lack of confidence and self-esteem were frequently mentioned 

as reasons that some ABAWDs do not participate in E&T activities, especially education and 

training. Managers whose offices offered education and vocational training programs to 

ABAWDs said they believed that some ABAWDs’ lack of basic skills (reading, writing, and 

basic mathematics) discouraged them from participating in these programs. In addition, many 

ABAWDs have other personal barriers, described in the next section, that make them hard-toserve and less likely to participate. 

c. Lack of Support Services 

A lack of support services was cited as a factor discouraging participation in each type of 

E&T activity. The most frequently mentioned was the lack of transportation. This was especially 

an issue in rural areas and for the homeless. Several managers noted the need for a range of 
 134 

TABLE IV.7 

FACTORS THAT DISCOURAGE ABAWD PARTICIPANTS FROM PARTICIPATING IN E&T ACTIVITIES 

 Type of E&T Activity 

Workfare Education 

Vocational 

Training 

Job Search 

Training 

Factor 

Number of Local E&T Managers Who Cited Factor as one that 

Discouraged E&T Participation by ABAWDs 

Lack of Motivation 25 5 9 4 

Personal Barriers 

Lack of Confidence/Self-Esteem 

Lack of Basic Skills 

Other Personal Barriers 

2 

0 

6 

11 

4 

7 

9 

2 

8 

5 

0 

9 

Lack of Support Services 

Lack of Transportation 

Lack of Funding for Tests 

Lack of Other Support Services 

10 

0 

3 

14 

0 

14 

9 

2 

6 

14 

0 

6 

Number of Respondents Who Responded 

that there were Factors that Discouraged 

ABAWDs from Participating 45 48 40 39a

Number of Respondents in Offices that 

Provided Service 73 70 61 76 

SOURCE: Local E&T Managers Survey, 2000 a

 One respondent did not know what factors discouraged participation. 

support services including appropriate clothing, help with housing issues, and payment of fees to 

take tests, such as the GED test. 

2. Hard-to-Serve Population 

The ABAWD participants’ personal barriers do not only discourage ABAWDs from 

participating in E&T activities, but also make it difficult to find appropriate work activities for 

them. Thirty-nine percent of local managers reported that ABAWDs’ personal barriers made it 

difficult to serve them. The most frequently mentioned three barriers were: medical or mental 

health issues, substance abuse, and homelessness. Some ABAWDs, who have medical problems 

that prevent them from participating in E&T activities, are not exempted because their problem 

is undiagnosed or because medical information to document the problem is not yet available. 
 135 

ABAWDs who are homeless or transient pose unique challenges in that they are especially 

difficult to contact. An inability to speak English serves as a barrier to participants in workfare 

and most education and training programs. Several respondents noted that it is difficult to find a 

workfare position for those with criminal records, especially sex offenders. 

3. Lack of Funds for Support Services 

In addition to discouraging ABAWDs from participating, the lack of funds for support 

services was viewed as a problem in finding appropriate services for those ABAWDs who 

wanted to participate. As noted earlier, the lack of transportation was viewed as the most 

prevalent challenge. After transportation, the lack of appropriate clothing for job interviews and 

employment was most frequently cited as a challenge. Managers frequently complained that the 

cap of $12.50 per person per month of federal matching funds is too low to adequately assist 

clients with transportation and other services. Several local managers also complained of the lack 

of funding for computers that could be used by ABAWDs when writing resumes and letters to 

employers. 

4. The Structure of E&T Funding for ABAWDs 

Respondents in both state and local offices complained about the fixed per slot 

reimbursement cap and the restriction that 80 percent of E&T funds be spent on qualifying work 

activities for ABAWDs. Some of the concern was that there were less funds available to spend 

on non-ABAWDs. Despite the overall increase in E&T funds, the 20 percent of funds the states 

could now spend on non-ABAWDs was less than the funds available for non-ABAWDs prior to 

the BBA. Respondents also complained, however, that the 80 percent requirement together with 

the fixed per-slot reimbursement cap made it difficult to serve ABAWDs, too. By serving only 

ABAWDs, the fixed costs involved in developing and running an E&T program may not be 

recovered. If the 80 percent requirement were removed, the states could provide the services to a 
 136 

larger population, making it more likely that the reimbursement cap would cover the average 

cost of the program. At the local level, managers complained of the difficulties of finding 

providers who would agree to be paid per filled and offered slot rather than for the actual costs of 

the program. The increase in the number of states that chose the “alternative reimbursement”

and so are not subject to the reimbursement cap, from eight in FY99 to 13 currently, may be a 

reflection of this concern. 

5. Complexity of the Policy 

Another issue that was noted by both state and local E&T managers was the challenge of 

dealing with a changing and administratively complex policy. At the state level, some 

respondents complained about the general complexity of the funding requirements. Local 

managers reported that caseworkers had difficulties with the changes that accompanied the 

ABAWD provisions, which, in many cases, significantly changed the nature of their job from 

determining eligibility to actively encouraging ABAWDs to work or participate in qualifying 

work activities. 

6. Restrictions on the Types of Qualifying Activities 

Some state and local E&T managers felt that the restrictions on what constitutes a qualifying 

work activity requires caseworkers to focus on maintaining food stamp eligibility rather than 

encouraging employment. In particular, states objected to the restrictions on counting job search 

and job search training as a qualifying activity because they found it to be an effective 

component. 

7. Lack of Qualified Staff 

Several local managers also raised the issue of limited staffing. It is a challenge at a time of 

a booming economy to hire enough trained staff to provide additional services to ABAWDs. 
 137 

F. APPROACHES TO ADDRESSING THE CHALLENGES 

We also asked local E&T managers how they have addressed these challenges. Although 

many view the challenges as largely intractable, some states and local offices had developed 

approaches to addressing the challenges. The approaches used by local E&T offices to increase 

participation in qualifying work activities included: 

• More Intensive Case Management. Managers reported that they increased the 

amount of time caseworkers spent with ABAWDs. For example, some group 

orientation sessions were replaced with one-on-one interviews with caseworkers. This 

increased time allowed caseworkers to provide clients with more information about 

available services and to help motivate the clients to participate. 

• More Rapid Placement into a Qualifying Activity. Several E&T managers noted the 

importance of moving ABAWDs into work activities and job search as quickly as 

possible. To avoid losing contact with the ABAWD after eligibility is determined, 

some offices ask food stamp applicants to participate in an E&T interview or 

assessment before their food stamp eligibility is determined. 

• Improved Coordination between Eligibility and E&T Workers. Managers reported 

that they had improved coordination between food stamp eligibility workers and E&T 

workers. For example, in one office, eligibility workers work directly with the E&T 

team in the DOL office to refer ABAWDs to the E&T service. 

• Additional Incentives to Participate. One E&T provider provides a store gift 

certificate to ABAWDs who complete 30 days of E&T activities. 

Some states and local offices have addressed the problem of the hard-to-serve by using the 

15 percent exemption to exempt those ABAWDs with severe barriers. Other states allowed 

eligibility workers to certify a medical problem based on their own observation, as all states will 

need to do when the final regulations are effective. This allows eligibility workers to exempt 

from the time limit persons with obvious, but undocumented, medical problems. In addition, 

local offices have made efforts to refer ABAWDs for other services, such as substance abuse 

treatment programs. 

Seventeen states also have found additional funds for support services so they can provide 

more than $25 per person per month. Others have encouraged ABAWDs to share rides to reduce 
 138 

the cost of transportation and/or have begun clothing banks so ABAWDs can have access to 

appropriate clothing for work. Local offices have drawn on community organizations, such as 

churches and charities, to provide additional support services for ABAWDs. 

G. SUMMARY 

The states varied considerably in both the rules for what counts as “work” and how much 

support and assistance they give ABAWDs in finding and keeping employment. Twenty states 

had quite flexible rules, always allowing volunteer work to count as meeting the work 

requirement and work of less than 20 hours a week to count if combined with another qualifying 

work activity. However, three states allowed neither volunteer work nor combinations of work 

and participation in other qualifying work activities to count. Most states required at least some 

ABAWDs to conduct a job search and most offered job search training. However, 11 states 

neither required job search nor offered job search training. 

Many state and local E&T managers complained of a lack of funds for support services. 

Support services were viewed as important for the ABAWD population both to help ABAWDs 

who work and those who participate in qualifying work activities. The $12.50 per person per 

month assistance of federal matching funds was viewed as inadequate. 

The increases in funding for the food stamp E&T program in the BBA were intended to 

ensure that qualifying work activities were available for all ABAWDs who needed them. While 

nearly all states offered ABAWDs some qualifying work activities, states varied considerably in 

how many different types of qualifying work activities they offered and the extent to which the 

activities were available to all ABAWDs who were subject to the work requirement. While just 

less than half of all states reported that they had a prearranged slot in workfare available for 

every ABAWD who wanted one, in 18 states there was no qualifying work activity at all 

available to some ABAWDs subject to the work requirement. 
 139 

Despite the fact that there are states that have not provided qualifying work activities for all 

ABAWDs, much of the federal funding for E&T services for ABAWDs has gone unspent. 

According to state E&T managers, this results from the difficulties in serving such a small 

population--the number of ABAWDs is small and many do not wish to participate in qualifying 

work activities. Some states have found that, because the fixed costs of developing and running 

programs can be spread over only a small number of people, the reimbursement amount per slot 

may not be large enough to cover the program costs. 

Both state and local E&T managers noted the low participation of ABAWDs in qualifying 

work activities—a finding that is broadly consistent with available FSP data. Respondents 

reported that the lack of motivation of some ABAWDs was one reason for low participation. 

However, respondents also believed that many ABAWDs faced serious barriers to both work and 

participation in qualifying work activities, including lack of transportation, undocumented 

medical problems, substance abuse problems, and homelessness. 
 141 

V. ADMINISTERING ABAWD POLICY: TRACKING AND 

OTHER CHALLENGES 

By making the determination of FSP eligibility more complex, the ABAWD provisions have 

had repercussions for both the state agencies and the eligibility workers in local FSP offices. 

According to some respondents to our survey of state FSP directors, the ABAWD provisions 

were the most difficult policy changes they had ever had to administer. This chapter discusses 

the issues that arose in administering the ABAWD policy. It describes the tracking of the receipt 

of time-limited benefits and other challenges faced by the states in administering the policy. 

Details of the administering of the ABAWD provisions by state appear in Appendix E. 

A. POLICIES AND PROCEDURES TO TRACK RECEIPT OF TIME-LIMITED 

BENEFITS 

Under the ABAWD provisions, eligibility is determined not only by the household’s 

financial circumstances in a given month but also by whether the ABAWD participant has 

received three months of time-limited benefits in a 36-month period. This means that the food 

stamp agency needs to track, or maintain a history of, each ABAWD participant’s receipt of 

time-limited benefits. States vary in how they define both the three-month time limit and the 36-

month period, along with their tracking capabilities, and the extent to which they check for 

benefit receipt in other localities. 

1. Defining the Three-Month Time Limit and the 36-Month Period 

PRWORA gives states some discretion in how to define both the three-month time limit and 

the 36-month period. At the time of our survey, all states had statewide policies on how to 

define both periods. 
 142 

a. Defining the Three-Month Time Limit 

How the three-month time limit is defined depends on which month counts as the first 

month of the three. The most stringent policy, used by six states, is to count the month of 

application toward the three-month limit (Table V.1). Therefore, if an ABAWD applied for 

benefits late in the month, the first countable month could include only a few days. The least 

stringent policy, used by most (36) states, was to count the month in which an ABAWD first 

received a full month of benefits as the first month. The remaining eight states had policies that 

are between these two extremes. 

The choice of how to define the three-month time limit can make a significant difference to 

ABAWD participants in the amount of benefits they receive without meeting the work 

requirement. If months of partial benefit receipt are included, some ABAWDs not complying 

with the work requirement will be eligible for just over two months of food stamp benefits before 

they are disqualified. On the other hand, if only full months of benefits are counted, some 

ABAWDs may receive nearly four months of benefits without complying with the work 

requirement. The final ABAWD regulations require states to count only full months of benefit 

receipt toward the time limit. In March 2000, 14 states counted partial months of benefit receipt 

as time-limited months. For them, implementing this aspect of the regulations will increase the 

number of ABAWDs receiving time-limited benefits. 

Respondents from several states remarked that, in practice, some ABAWDs could receive 

four full months of benefits without meeting the work requirement because they were notified 

too late of their disqualification. The FSP regulations require clients to be notified of an 

“adverse action,” such as termination, by a letter sent at least 10 days before the action takes 

place. If the state does not send the letter out quickly enough, benefits may have already been 

issued for the fourth month before the state could disqualify the ABAWD. 
 143 

TABLE V.1 

STATE POLICIES ON DEFINING THE THREE-MONTH 

TIME LIMIT 

The First Month of the Three-Month Limit is: Number of States 

Month of Application 6 

Month of Certification 1 

First Month of Benefit Receipt 4 

Month of Application if Application is Before the Middle of the 

Month 3 

First Month of Full Benefit Receipt 36 

Total 50 

SOURCE: State Food Stamp Directors Survey, 2000 

b. Defining the 36-Month Period 

States have flexibility in how to define the “preceding 36-month period” during which 

ABAWDs can receive benefits without satisfying the work requirement. By law, the first 36-

month period began either on November 22, 1996 or the date on which then-current participants 

were notified of the ABAWD provisions, whichever was later. 

Some states use a rolling clock, under which eligibility is always determined by benefit 

receipt in the preceding 36 months. The beginning and ending dates of the period are the same 

for each ABAWD participant, but change each month. For example, in December 2000, 

eligibility depends on the receipt of benefits between December 1997 and December 2000. In 

January 2001, eligibility depends on the receipt of benefits between January 1998 and January 

2001. 

In contrast, under a fixed clock, eligibility is determined by benefit receipt in a 36-month 

period with a specified beginning and ending date for each ABAWD that does not change each 

month. The beginning and ending dates may be the same for all ABAWDs in the state. For 

example, the fixed periods may have run from December 1996 to December 1999 and then from 

December 1999 to December 2002 for all ABAWD participants in the state. Alternatively, the 
 144 

beginning and ending dates may vary by ABAWD participant. The beginning date of the period 

may, for example, be the date the ABAWD most recently applied for benefits. 

A fixed clock of either type implies a less stringent time limit than a rolling clock. Under a 

fixed clock, an ABAWD can receive more than three months of time-limited benefits in a 36-

month period if he or she receives some or all of them more than three months into the fixed 

period. In this situation, an ABAWD will regain eligibility for benefits at the beginning of the 

new fixed period, which will be fewer than 36 months after the previous receipt of benefits. If, 

for example, the fixed clock runs from December 1996 to December 1999 and from December 

1999 to December 2002, an ABAWD who received three months of time-limited benefits in 

September, October, and November 1999 could then continue to receive benefits in December 

1999, January 2000, and February 2000 even without satisfying the work requirement. 

A fixed clock that is the same for all ABAWDs is less stringent than a fixed clock that 

begins on the date an ABAWD applies for benefits. When all ABAWDs have the same 

beginning and ending day of their 36-month period, the “36-month period” will last only a few 

months for the ABAWDs who apply near the end of the period. The “36-month period” will 

always be 36 months long if it begins when ABAWDs apply. 

Twenty-seven states used a rolling clock, and the remaining 23 used a version of the fixed 

clock (Table V.2). The ABAWD regulations explicitly allow states to use a rolling clock or a 

fixed clock to define the 36-month period. Although no state need change its policy for the 36-

month period as a result of the regulations, several respondents to our survey said their state is 

considering switching from a rolling clock to a fixed clock because of the complexity of 

administering a rolling clock. 
 145 

TABLE V.2 

STATE POLICIES ON DEFINING THE 36-MONTH PERIOD 

Method Used to Define the 36-Month Period Number of States 

Rolling Clock 27 

Fixed Clock, Varies by ABAWD 5 

Fixed Clock, Same for All ABAWDs 18 

Total 50 

SOURCE: State Food Stamp Directors Survey, 2000 

We checked to see if states were consistent with respect to the stringency of their policies 

for defining the 3-month time limit and the 36-month period. Only a weak association across 

states in the stringency of these two policies was observed. 

2. States’ Tracking Capabilities 

Tracking the information required to determine an ABAWD’s eligibility requires significant 

changes in the states’ information systems. The systems must keep track of the months in which 

ABAWDs received time-limited benefits, the beginning and ending dates of the 36-month 

period(s), and whether the ABAWD regained eligibility for an additional three consecutive 

months. 

States vary widely in how quickly they developed tracking systems and in the sophistication 

of these systems. Many states made changes quickly and were able to implement statewide 

automated tracking systems soon after the legislation took effect. Fifteen states implemented 

such systems before the end of 1997. However, at the time of this writing, other states were still 

working on the development of such systems or had deferred system development. 

We categorize the states’ tracking systems in March 2000 into four groups of sophistication 

as follows: 

1. No statewide automated tracking system (12 states) 
 146 

2. Very limited statewide tracking system (5 states) 

3. Partially automated statewide tracking system (7 states) 

4. Completely automated statewide tracking system (26 states) 

The majority of states operated systems that could track ABAWDs statewide, but these 

systems varied in the amount of information they provide to the eligibility workers. By March 

2000, 33 states had a sophisticated tracking system that stored most of the information necessary 

to determine ABAWDs’ eligibility (categories 3 and 4 above). Twelve states had no statewide 

automated tracking systems at that time. 

a. No Statewide Automated Tracking System 

In most states that have no statewide automated tracking system, eligibility workers use a 

form to track months of time-limited benefit receipt.1 The tracking form is usually a paper form 

in the case file, but some offices use an electronic form in an electronic case file. Without a 

statewide tracking system, eligibility workers do not have easy access to information on timelimited benefits the client may have received in other counties. Hence, the eligibility workers 

need to determine (from a paper tracking form maintained locally and by letters or telephone 

calls to other local offices) the months in which ABAWDs receive benefits in the 36-month 

period, whether they were exempt or waived during that time and, if not, whether they were 

satisfying the work requirement. 

b. Very Limited Statewide Tracking System 

These systems include a history of all benefits received by ABAWDs anywhere in the state, 

but the history does not indicate the months in which these benefits were time-limited. Hence, 

 

1

 We include New York in this category because it has no statewide system. However, some New York 

counties operate automated tracking systems that determine how many months of benefits the client has received in 

that county. 
 147 

the information on months the ABAWD received benefits is available on-line, but information 

on whether the ABAWD was exempt or waived, and if not, whether he or she was satisfying the 

work requirement is not available electronically. Again, the eligibility workers need to consult 

case files and may need to contact other local offices. 

c. Partially Automated Statewide Tracking System 

In these systems, a statewide on-line benefit history is available to eligibility workers and 

the history indicates the months the ABAWD received time-limited benefits. Hence, the 

eligibility workers need not consult other sources to determine whether the ABAWD was exempt 

or waived in a month, or whether he or she was satisfying the work requirement. 

This type of system differs from a completely automated system in that the eligibility 

workers must count the months of time-limited benefit receipt to determine eligibility. This may 

be somewhat burdensome because it requires the eligibility worker to know when the ABAWD’s 

36-month clock started. 

d. Completely Automated Statewide Tracking System 

The most sophisticated systems automatically calculate the number of months an ABAWD 

participant received time-limited benefits and determine whether the ABAWD is currently 

eligible for food stamps. Eligibility workers do not need to look back at the benefit history, since 

the system provides the information on a screen, nor do they need to know when the 36-month 

clock began. Respondents from four states with such systems reported that eligibility workers 

are also required to keep a paper tracking form in the client’s case file as a backup in case the 

computer is down or if information is not data entered correctly. 
 148 

3. Procedures for Tracking ABAWDs Who Move within and between States 

In states with an automated statewide tracking system, checking for previous receipt of food 

stamps in other localities within the state is easy and straightforward. Without such a system, 

however, the eligibility worker can obtain information on the client’s earlier receipt of timelimited benefits only by contacting other local offices in the state. Because it is impractical to 

contact every local office in the state when evaluating an ABAWD’s application, the eligibility 

worker must either rely on the applicant’s own report of previous benefit receipt or contact some 

limited subset of offices (in neighboring counties, for example). 

No states currently link their electronic ABAWD tracking systems to tracking systems in 

other states and no national database of FSP participants or ABAWDs currently exists. As a 

result, eligibility workers have no means of checking whether an ABAWD has received benefits 

in another state unless the ABAWD indicates that he or she lived in another state. If the 

eligibility worker knows or suspects that an ABAWD has received benefits in another state, he or 

she would need to contact the other state to find out how many countable months of time-limited 

benefits the ABAWD had received. 

All but one state without statewide tracking systems required eligibility workers to check on 

receipt of benefits in other localities in the state if the client reported receiving benefits there. 

And 44 states required eligibility workers to check on receipt of benefits in other states if the 

client reported receiving benefits there. The final ABAWD regulations explicitly require that 

eligibility workers check on benefit receipt in another state if the ABAWD indicates that he or 

she has received benefits there. 

B. CHALLENGES IN ADMINISTERING ABAWD POLICY 

Although we did not directly ask the respondents to the State Food Stamp Director Survey 

for their general opinion about the ABAWD provisions, 21 of the 50 respondents said that they 
 149 

would like to see either the ABAWD time limit and/or work requirement removed. Although 

some respondents view the ABAWD provisions as unfairly penalizing the targeted population, 

more respondents disliked the provisions because of the difficulties in administering them. They 

view the expense and time spent administering the provisions as too burdensome, especially 

given the small size of the ABAWD population. Survey respondents cited the following three 

main challenges, listed in order of difficulty, in administering the ABAWD provisions: 

1. Tracking (30 states) 

2. Ensuring that eligibility workers implement the policy correctly (22 states) 

3. Translating the ABAWD provisions of PRWORA and the BBA into state policy (12 

states) 

In addition, when asked specifically about the challenges of administering ABAWD policy, 

many respondents also talked about the difficulties of providing qualifying work activities to 

ABAWDs. These difficulties, discussed in detail in Chapter IV, include the personal barriers 

many ABAWD participants face, as well as a lack of sufficient supportive services and 

constraints related to the funding of E&T services. 

1. Tracking 

Thirty of the 50 respondents said that tracking has been a major challenge in administering 

the ABAWD provisions. To quote several respondents, “Tracking is a nightmare.” 

Respondents gave three broad reasons for why tracking is such a challenge: (1) developing the 

automated tracking system is problematic, (2) using the automated tracking systems is 

problematic, and (3) the activity is a burden on the eligibility workers. 

a. Problems in Developing the Automated Tracking System 

Because the ABAWD provisions required such fundamental changes to states’ existing 

automated systems, developing an automated tracking system proved expensive, difficult, and 
 150 

time-consuming. A respondent from one state pointed out that it was particularly challenging to 

develop a tracking system while ensuring that the state computer system’s would comply with 

the Year 2000 requirements. Another state had just completed a major overhaul of its automated 

eligibility system and did not believe it had the resources for another overhaul. Some state FSP 

agencies lacked the staff with the skills needed to change their systems and had to hire outside 

contractors, incurring additional cost, to make the changes. 

b. Problems Using the Automated Tracking System 

The automated tracking systems do not always work as intended. Some systems are still 

exhibiting start-up difficulties. Four respondents to the State Food Stamp Director Survey 

complained that their automated tracking systems still have bugs. Respondents in three states 

said that their system does not yet contain 36 months of data. Another problem cited by two 

respondents is that relevant data are not consistently entered into the database or that they are 

entered incorrectly. As part of this study, we visited a local office that has an automated 

statewide tracking system, but the eligibility workers track benefit receipt with a paper form 

because the information on the tracking system was deemed unreliable. 

c. Burden on the Eligibility Workers 

Tracking places a burden on eligibility workers. Even in states with automated statewide 

tracking systems, eligibility workers need to call offices in other states to check on benefits that 

may have been received in those states. If tracking is not automated, eligibility workers also 

need to keep track, in the ABAWD’s case file, of all receipt of time-limited benefits and may 

need to call offices in other localities within the state. 
 151 

2. Ensuring That Eligibility Workers Implement the Policy Correctly 

Respondents in 22 states said that the ABAWD policy is confusing, and that administering it 

has been time-consuming for eligibility workers. One respondent complained that this confusion 

increased the quality control error. Several managers in local offices seemed confused about 

state ABAWD policy. For example, one manager was confused about the number of hours an 

ABAWD was required to participate in workfare, and another manager thought that participation 

in education programs was not a qualifying work activity. 

Tracking was mentioned most often as a problem for eligibility workers. Other aspects of 

the policy that were challenges for eligibility workers included: 

• Regaining Eligibility within the 36-Month Period. Eligibility workers are especially 

confused about the part of the law that allows ABAWDs to regain FSP eligibility for 

an additional three consecutive months. 

• The Rolling Clock. Respondents described using a rolling clock as especially 

difficult both to implement and to explain to ABAWDs. Several states said they are 

planning to convert from a rolling clock to a fixed clock to reduce this burden. 

• Partial Waivers. Partial waivers—waivers that cover only some of the clients in an 

office—are particularly difficult to administer. However, state interview respondents 

in only six of the 22 states with partial waivers viewed them as a problem. Evidence 

from the county interviews, however, suggests that the state respondents may have 

been unaware of some of the local problems. Other than general confusion resulting 

from partial waivers, specific problems mentioned by include the burden of 

determining whether the client lives in a waived area and explaining the rules to the 

client. 

• Losing a Waiver. Eligibility workers also have difficulty when an area loses its 

waiver and needs to introduce the ABAWD provisions. 

• Reconciling the ABAWD Work Requirement with the FSP Work Registration 

Requirement. The eligibility workers need to apply two different criteria for 

determining whether a client is an ABAWD and whether that client is required to 

register for work. For example, a person responsible for the care of a child over six is 

usually exempt from the ABAWD provisions but is subject to work registration. 

Such differences are often confusing. 

• 15 Percent Exemption. A respondent from one state said it was particularly difficult 

to explain to eligibility workers the criteria for applying the 15 percent exemption. 
 152 

3. Translating the Law into State Policy 

PRWORA and the BBA allow the states considerable flexibility in setting ABAWD policy. 

However, many state agencies view the law as confusing and difficult to interpret. Several 

respondents requested more guidance on how to set ABAWD policy. The 15 percent exemption 

is viewed as particularly problematic. Respondents from six states reported that it is difficult to 

estimate how many ABAWDs would be exempted under different criteria for applying the 15 

percent exemption. At the time of the interview, at least one state agency was unaware that the 

15 percent exemption could be used to exempt all ABAWDs in a geographic area. Several 

respondents remarked that it is difficult to collect the information to apply for waivers, especially 

for Indian reservations, where labor market information is often not readily available. 

The final ABAWD regulations, by clarifying some aspects of the ABAWD provisions, such 

as the criteria for awarding waivers, the requirement for medical certification, and what counts as 

“work” for the purpose of the work requirement, may remove some confusion. However, the 

state agencies view the ABAWD provisions as inherently complicated. 

C. SUMMARY 

The ABAWD provisions are complex and quite different from previous food stamp rules. 

Hence, not surprisingly, both state and local agencies have found them challenging to implement. 

And because the ABAWD provisions affect a relatively small number of persons, their 

complexity is perceived as especially burdensome. The greatest implementation challenge is 

tracking, and states vary considerably in their success at meeting this challenge. While more 

than half of all states have sophisticated tracking systems, about one-quarter of all states still 

require eligibility workers to manually track the receipt of time-limited benefits. 
 153 

VI. CONCLUSIONS 

This study provides a wide range of findings with respect to the number and characteristics 

of persons affected by the ABAWD provisions of PRWORA, state policy choices for 

implementing these provisions, and the challenges states faced in doing so. Here, we present 

seven main conclusions and close with some observations on assessing the impact of the 

ABAWD provisions. 

A. THE ABAWD POPULATION IS SMALL 

In March 2000, there were approximately 422,000 ABAWD participants in the FSP, 

comprising 2.5 percent of the entire FSP caseload. This number is as small as it is for two 

reasons. First, the definition of an ABAWD is quite restrictive. Nearly two-thirds (66 percent) 

of all FSP participants were too young or too old to be ABAWDs. Another 20 percent of FSP 

participants were excluded because they had dependents. An additional 9 percent were 

medically certified as unfit for employment, and 3 percent were pregnant or exempt from work 

registration. 

The number of ABAWD participants would increase by 40 percent if we included those 

participants who were exempt from work registration solely because they worked 30 hours per 

week or earned at least 30 times the federal minimum hourly wage. This would bring the 

number of ABAWD participants in March 2000 to 590,000 or 3.4 percent of the FSP caseload. 

The second reason for the small number of ABAWD participants is the steep decline in 

participation among this population. This group has decreased in size even more rapidly than the 

entire FSP caseload. In FY96, before the ABAWD provisions went into effect, there were more 

than one million ABAWD participants, who made up 4.0 percent of all participants. 

Barely half of the ABAWD participants—216,000 or only 1.3 percent of all FSP 

participants—were subject to the time limit. This is because the states used waivers to exempt 
 154 

190,000 ABAWDs, and 16,000 of the ABAWDs in nonwaived areas were covered under the 15 

percent exemption. 

B. MANY ABAWDS WHO LEFT THE PROGRAM DID NOT RETURN 

Approximately 200,000 ABAWDS used up their time-limited benefits and were terminated 

from the FSP during the first six months after the ABAWD provisions were implemented. 

Through the first year the cumulative number of terminations exceeded 350,000. Unless they reestablished eligibility by meeting the work requirement as nonparticipants or qualified for 

benefits as non-ABAWDs, those who were terminated would not have become eligible again as 

ABAWDs until at least November 1999. In the 18 states that define the 36-month period with 

the same beginning and ending date for all ABAWDs, those terminated during the first three 

years after implementation would have become eligible again at the same time, when states reset 

their 36-month clocks in November or December 1999. This created the potential for a sizable 

rebound in participation by ABAWDs beginning late in 1999. 

Neither the number of ABAWD participants through September 2000 nor the number of 

terminations through March 2000, however, shows any evidence of an upswing in participation 

by ABAWDs. While the decline in the number of ABAWD participants appears to have ended 

in late 1999 or 2000, perhaps as a result of ABAWDs returning to the program, this stabilization 

of the ABAWD caseload represents only a small deviation from the trend in early 1999. If the 

return of previously terminated ABAWDs played any role, this could not have involved more 

than a small fraction of those who used up their time-limited benefits in 1997. Although some 

may have returned to the FSP as non-ABAWDs, the inference that many simply gave up on 

receiving food stamps provides a more plausible explanation. None of our state or local 

respondents gave any indication that ABAWDs who left the program were returning. Finally, 
 155 

advocates observed that outreach efforts made to coincide with the resetting of state clocks were 

largely unsuccessful, which supports this interpretation. 

C. DIVERSE FACTORS AFFECT STATES’ POLICY CHOICES 

We found surprisingly little association between states’ policy choices on different aspects 

of ABAWD policies. Few states made policy choices that consistently had either a positive or 

negative effect on the number of persons subject to the time limit. Most states had some policies 

that increased the number of persons subject to the time limit, and others that decreased the 

number of persons subject to the time limit. And while some states that provided few 

opportunities to participate in qualifying work activities had waivers and other policies designed 

to exempt many persons from the time limit, others did not apply for waivers and limited the 

number of exemptions. 

One reason for this lack of correlation between policies is that multiple factors played a role 

in the choice of policies. For example, some states chose to set fixed beginning and ending dates 

for the 36-month period (a fixed clock) because this is easier to administer. In addition, different 

players within the state were responsible for different policy decisions, and these players 

sometimes had philosophical differences. For example, in many states the governor’s office had 

a say in whether the agency would apply for waivers, while the food stamp agency made 

decisions about other aspects of ABAWD policy. Advocacy organizations were very active in 

promoting the use of waivers and the 15 percent exemption but much less active with respect to 

other policy areas. 

The concurrent implementation of major changes in the cash assistance program also 

affected states’ policy choices. Some states and counties viewed certain of the ABAWD 

provisions as being inconsistent with TANF policies. For example, some argued that requesting 

waivers for areas with high unemployment or insufficient jobs was inconsistent with requiring 
 156 

that TANF recipients find work in the same areas. They cited this conflict to support their 

decisions to not pursue or not implement approved waivers. In another area of policy, two states 

set the age at which children are considered “dependents” at six or seven to be consistent with 

the TANF policy. Finally, some states and advocates suggested that the need to develop work 

and training opportunities for the larger and, arguably, more worthy population of TANF 

recipients drew attention away from ABAWDs. 

D. STATE POLICIES AFFECT THE NUMBER OF PARTICIPANTS WHO ARE 

SUBJECT TO THE TIME LIMIT 

PRWORA and, later, the BBA allowed states to influence the number of participants 

affected by the ABAWD provisions in five principal ways: (1) the use of federal waivers to 

exempt qualifying geographic areas, (2) the use of the 15 percent exemption, (3) the 

determination, prior to FNS’s issuance of final regulations, of what constituted responsibility for 

a dependent child, (4) the establishment of rules—limited by the final ABAWD regulations—

governing the determination of who was considered mentally and physically fit for employment, 

and (5) the development of E&T slots to enable participants without steady jobs to meet the work 

requirement and become more work-ready. 

In March 2000, 190,000 ABAWD participants or 45 percent of the total number were 

exempt from the time limit because they lived in waived areas. Some of these ABAWDs would 

have exhausted their time-limited benefits if they had lived in nonwaived areas. ABAWDs 

accounted for 6 percent of all participants 18 to 50 in nonwaived areas but 12 percent in waived 

areas. If all of this difference is due to waivers we could infer that there would have been 91,000 

fewer ABAWDs in the absence of waivers. This is an upper limit to the effect of the waiver 

policy, however, because it is likely that other factors, such as errors in the estimates of 

ABAWDs and differences in the availability of jobs, contribute to the difference in the incidence 

of ABAWDs between waived and nonwaived areas. 
 157 

About 16,000 ABAWD participants received 15 percent exemptions. Not all of these 

ABAWDs would have exhausted their time-limited benefits prior to receiving the exemption. 

This is because many states use the 15 percent exemption to exempt entire areas, just as they use 

waivers. When they do so, FNS allows them to include all ABAWDs in the exemption counts 

that they report to the agency rather than just those participants who have used up their timelimited benefits. We estimate that as many as a third of the participants with 15 percent 

exemptions in March 2000 would have been eligible to receive benefits without the exemptions. 

While we cannot observe the direct effects of state policy defining responsibility for a 

dependent child, we can estimate the effects using FSPQC data.. If all of the states had 

exempted no more than one adult in a household with dependent child, the monthly average 

number of ABAWD participants would have been 87,000 higher than if all of the states had 

exempted all adults—the policy specified in the final regulations. In fact, only a few states chose 

to exempt only one adult per household, but nearly half the states adopted a policy that did not 

automatically exempt all adults. We estimate that the change in state policy to comply with the 

regulations will redefine as many as 38,000 ABAWD participants to be non-ABAWDs. 

Furthermore, we estimate that a majority, as many as 22,000, of these participants are in 

nonwaived areas, where as ABAWDs they would have been subject to the time limit. 

We estimated a number of multivariate models in an attempt to measure the impact of 

additional state policy choices and a variety of other factors on the fraction of adults subject to 

the ABAWD time limit. While we found some statistically significant effects, the paterns were 

difficult to interpret. We concluded that our data were too limited and the determination of 

variation in the size of the ABAWD population too complex to allow valid inferences about the 

effects of ABAWD policy by this methodology. 
 158 

E. THE ABAWD PROVISIONS ARE COMPLEX AND DIFFICULT TO 

ADMINISTER 

Nearly all respondents to the State Food Stamp Program Director Survey viewed ABAWD 

policy as excessively complicated and difficult to administer. The policy was viewed as 

particularly burdensome given the small population that was affected by the policy. 

Respondents identified the need to track the receipt of time-limited benefits over a 36-month 

period as the most difficult aspect of the policy. Development of automated systems to track 

receipt of time-limited benefits was technically challenging, time-consuming, and costly. While 

14 states had statewide, automated tracking systems by the time the ABAWD provisions went 

into effect, others completed such systems only later, and 12 states still had no statewide tracking 

systems in March 2000. 

Even when statewide tracking systems are in place, operational challenges remain. For 

example, no automated procedures exist to track the receipt of benefits by ABAWDs who move 

across states. Eligibility workers in all states need to call out-of-state local offices if they are told 

or have reason to believe that a client received benefits in another state. In addition, respondents 

reported that tracking systems do not always work as intended and require accurate data entry to 

ensure that benefit status is appropriately reported. 

More generally, respondents to our surveys reported that the complexity of the ABAWD 

provisions made them difficult for state administrators, eligibility workers, and clients to 

understand. Eligibility workers complain that allowing ABAWDs to regain eligibility for three 

consecutive months within the 36-month period is extremely difficult to administer and to 

explain to clients. Similarly, enforcing the time limit is especially difficult if the beginning and 

ending dates of the 36-month period change each month as they do under a rolling clock. 

Finally, eligibility workers find it difficult to apply two different sets of criteria to determine who 

is exempt from work registration and who is exempt from the ABAWD work requirement. 
 159 

F. HALF OF ALL PARTICIPANTS WHO WERE SUBJECT TO THE TIME 

LIMIT WERE MEETING THE WORK REQUIREMENT 

One-half of ABAWD participants who were subject to the time limit in March 2000 were 

meeting the work requirement. These participants can receive food stamps for as long as they 

met the work requirement and remain income-eligible. Almost one-quarter of ABAWDs who 

were subject to the time limit were meeting the work requirement by working. An equal fraction 

met the work requirement by participating in workfare while only 4 percent met the requirement 

through education and training or other qualifying work activity. The remaining ABAWDs who 

were subject to the time limit received time-limited benefits. 

These estimates do not include participants who were exempt from the time limit solely 

because they were working 30 hours or more or earning more than 30 times the minimum wage. 

Such persons are exempt from work registration and, therefore, are defined to be outside the 

ABAWD population. Counting them as ABAWDs subject to the time limit increases the 

percentage who are meeting the work requirement from 51 percent to 68 percent. 

G. WHILE SOME ABAWDS MAY BE UNWILLING TO MEET THE WORK 

REQUIREMENT, OTHERS ARE NOT ABLE TO MEET IT 

The intent of PRWORA was to place a time limit and a work requirement on FSP 

participants who were able to work—persons who were able-bodied, did not have family 

responsibilities that prevented them from working, and lived in areas with available jobs. And 

the BBA provisions on Food Stamp E&T were designed to provide sufficient funding for states 

to provide qualifying work activities for all ABAWDs who could not find work. If these two 

legislative actions worked as intended, the only persons who would not meet the work 

requirement would be those who did not want to work or participate in a qualifying work 

activity. 
 160 

Many state and local FSP staff who responded to our surveys expressed the opinion that 

some ABAWDs are indeed unmotivated and do not want to participate in a qualifying work 

activity. Local E&T managers reported that when offered a place in a qualifying work activity, 

many ABAWDs do not show up for the activity. However, the responses to our surveys also 

indicate that qualifying work activities appropriate to their individual needs were not available to 

all ABAWDs and that ABAWDs faced many barriers to participating in these activities. 

1. Despite Generous Federal Funding, Qualifying Work Activities Are Not Available 

For All ABAWDs 

In FY99, 22 states did not have a qualifying work activity for all ABAWDs who wanted one 

either because they did not offer qualifying work activities in all FSP offices in nonwaived areas 

or did not have enough slots to provide the activity for all ABAWDs who wanted to participate. 

And five states provided no qualifying services at all through their E&T program. 

The lack of qualifying work activities for all ABAWDs who wanted to participate was not, 

however, because of a lack of federal funding. In FY99, the states spent only 43 percent of total 

available federal E&T funds. Only five states spent more than 80 percent of their allocated 

funds. The respondents to our survey gave four main reasons for spending so little of the federal 

E&T funds. First, because there are so few ABAWDs to serve, providers of work activities were 

concerned that the reimbursement cap per slot would be too low to cover the fixed costs of 

developing and operating the programs. Second, some states were discouraged from using the 

funds because of administrative requirements. Third, some states viewed providing work 

activities to ABAWDs as ineffective in moving them toward self-sufficiency. Fourth, some 

states did not want to provide services to ABAWDs that they could not provide to a broader 

population. 
 161 

2. Many ABAWDs Face Significant Barriers to Both Work and Participation in 

Qualifying Work Activities 

According to state and local food stamp agency staff, many ABAWDs face significant 

barriers to both work and participation in qualifying work activities. The most frequently cited 

barriers are mental illness, substance abuse, homelessness, and lack of transportation. Other 

barriers include inability to speak English, illiteracy, and a criminal record. 

By definition, ABAWDs are supposed to be “able-bodied.” However, many survey 

respondents said that some ABAWDs who are in fact unfit for work do not get certified as such. 

These ABAWDs either did not want to go to a health professional or could not afford to go. This 

is especially an issue for ABAWDs suffering from mental illness. 

Lack of transportation was also reported to be an important barrier for some ABAWDs, 

especially those living in rural areas. The federal government matches only $12.50 in state 

expenditures per participant per month for transportation and other supportive services. Many 

respondents viewed this as much too little. 

H. THE ABAWD PROVISIONS: ASSESSING THEIR IMPACT 

When Congress added the ABAWD provisions to PRWORA, the goal was to encourage 

qualified FSP participants to become more self-sufficient through employment and to severely 

limit the benefits of those who did not work or participate in a qualifying work activity. After 

four years there is ample evidence that many participants who were defined as ABAWDs 

exhausted their time-limited benefits and more limited evidence suggesting that many of these 

did not return to the FSP after regaining their eligibility. The number who exhausted their 

benefits would have been substantially higher if states had not used waivers and the 15 percent 

exemption to exempt many ABAWDs from the time limit. 

It is much more difficult to document the extent to which the ABAWD provisions have 

succeeded in encouraging FSP participants to find and maintain employment. The ABAWD 
 162 

participants who were meeting the work requirement through employment in March 2000 and 

the additional, employed participants who would have been counted as ABAWDs had they been 

working fewer than 30 hours could be numbered as successes. However, an unknown fraction of 

these persons would have been working even in the absence of a time limit. At the same time, 

those who succeeded so well at employment that they no longer qualified for food stamps do not 

show up in the program rolls. Studies that collect data from ABAWD participants over time and 

compare the experiences of participants in waived and nonwaived areas are required to assess 

how the ABAWD provisions have affected the employment activity and well-being of those who 

were subject to the time limit. 

What we know from earlier research is that many of those likely to be affected by the 

ABAWD provisions tend to have fairly short spells of participation—less than six months—

bracketed by employment. This pattern of participation implies very different needs with respect 

to food assistance and work-related services than we would expect to find among those 

ABAWDs with very limited work experience. Our analysis of state tabulations and FSPQC 

sample data indicates that those who are meeting the work requirement at any one time differ 

little in their demographic characteristics from those who are not. That some are meeting the 

work requirement and some are not is due in part to geographic variation in the availability of 

qualifying work activities, which we have documented. But the comments from our state and 

local respondents suggest that many of those who are not meeting the work requirement may in 

fact hold attitudes or face personal barriers that are not adequately addressed by the activities that 

are available to them. Outside of a few states, only a small fraction of ABAWDs are meeting the 

work requirement through participation in workfare or education and training. This pattern is 

likely to continue in the absence of significant improvements in the matching of individuals to 

programs that best suit their needs. However, the small size of the ABAWD population remains 
 163 

a limiting factor in the development of an appropriately broad menu of programs that can be 

offered in a great many localities. 

 
 165 

REFERENCES 

Botsko, Christopher, Vivian Gabor, Susan Schreiber, and Susan Pachikara. “Report to Congress 

on State Use of Funds to Increase Work Slots for Food Stamp Recipients.” Washington, 

DC: ERS’ Food Assistance and Nutrition Research Program, October 2000. 

Castner, Laura. “ABAWD Data in the 1998 FSPQC File.” Washington, DC: Mathematica 

Policy Research, Inc., January 2000. 

Cody, Scott and Laura Castner. “Characteristics of Food Stamp Households: Fiscal Year 1997.” 

Washington, DC: Mathematica Policy Research, Inc., February 1999. 

Czajka, John L. “Evaluation of the ABAWD Code in the Food Stamp Quality Control Data.” 

Washington, DC: Mathematica Policy Research, Inc., August 2000. 

Czajka, John L., Vivian Gabor, Sheena McConnell, and Michael Stavrianos. “Data Collection 

Plan for the Study of the Food Stamp Time Limits on Able-Bodied Adults without 

Dependents.” Washington, DC: Mathematica Policy Research, Inc., October 1999. 

Gabor, Vivian. “Summary of Findings on State Food Stamp Policy Choices Regarding 

Provisions for Able-Bodied Adults without Dependents (ABAWDs).” Washington, DC: 

Health Systems Research, Inc., February 1998. 

Garasky, Steven, Helen Jensen, Sarah Nusser, and Cory Wessman. “What is Happening to Food 

Stamp Exiters in Iowa?” Paper presented at the 22nd Annual Research Conference of the 

Association for Public Policy Analysis and Management.” Seattle, WA: November 2000. 

Mills, Gregory and Robert Kornfeld. “Study of Arizona Adults Leaving the Food Stamp 

Program: Final Report.” Cambridge, MA: Abt Associates, Inc. December 2000. 

Rangarajan, Anu and Philip Gleason. “Food Stamp Leavers in Illinois: How are They Doing 

Two Years Later?” Princeton, NJ: Mathematica Policy Research, Inc. January 2001. 

Stavrianos, Michael and Lucia Nixon. “The Effect of Welfare Reform on Able-bodied Food 

Stamp Participants.” Washington, DC: Mathematica Policy Research, Inc., July 1998. 

Stavrianos, Michael, Scott Cody, and Kimball Lewis. “Characteristics of Childless, Unemployed 

Adult and Legal Immigrant Food Stamp Participants: Fiscal Year 1995.” Washington, DC: 

Mathematica Policy Research, Inc., February 1997. 

U.S. Department of Agriculture, Food and Nutrition Service. “Cumulative Questions and 

Answers on Certification and Work Issues in PRWORA.” Alexandria, VA: USDA, August 

15, 1997. 

U.S. General Accounting Office. “How States Are Using Federal Waivers of the Work 

Requirement.” GAO/RCED-00-5. Washington, DC: GAO, October 1999. 

U.S. General Accounting Office. “Food Stamp Program: Information on Employment and 

Training Activities.” GAO/RCED-99-40. Washington, DC: GAO, December 1998. 
 166 

U.S. General Accounting Office. “Welfare Reform: State and Local Responses to Restricting 

Food Stamp Benefits.” GAO/RCED-98-41. Washington, DC: GAO, December 1997. 
APPENDIX A 

SUMMARY OF FINAL ABAWD REGULATIONS
 A-1 

The final regulations on the ABAWD provisions of PRWORA were published on January 

17, 2001. These regulations became effective on August 1, 2001 and must be implemented by 

the state agencies by October 1, 2001. This appendix summarizes the seven main elements of 

the regulations. 

A. MEETING THE WORK REQUIREMENT 

1. An ABAWD who works 20 hours a week or 80 hours a month meets the work 

requirement 

2. Unpaid work under standards established by the state agencies counts as work 

3. Work paid in kind counts as work 

4. Persons who have missed work for good cause as determined by the state agency 

will be considered to meet the work requirement 

5. Qualifying work programs may contain job search as a component, but job search 

must be less than half of the requirement 

6. The work requirement can be met by combining hours of work and participation in 

a work program 

7. State agencies are given the option to count unreported work as work 

B. IMPLEMENTING THE TIME LIMIT 

1. State agencies can use either a fixed or rolling clock to measure the 36-month 

period 

2. Partial months do not count toward the time limit 

3. Benefits erroneously received are counted as having been received until they are 

repaid in full 

C. ESTABLISHING VERIFICATION AND REPORTING REQUIREMENTS 

1. State agencies must verify the work hours for individuals subject to the time limit 

2. Individuals are required to report when the number of hours they work falls below 

20 hours a week, averaged monthly 
 A-2 

D. TRACKING THE RECEIPT OF TIME-LIMITED BENEFITS 

1. State agencies must verify the countable months an individual has used in another 

state if there is an indication that the individual participated in another state. The 

state may accept the other state’s assertion as to the number of countable months the 

individual has used in the other state 

E. EXEMPTING INDIVIDUALS FROM THE WORK REQUIREMENT 

1. An individual is exempt from the ABAWD requirement if he or she is under 18 or 

50 years or older 

2. Medical certification of physically or mentally unfit for employment is required 

only where the unfitness is not evident to the eligibility worker 

3. Medical certification may include a statement from a nurse, nurse practitioner, 

designated representative at a doctor’s office, social worker, or other medical 

personnel the state agency deems appropriate 

4. The receipt of disability benefits is indirect proof that there has been a medical 

certification of a condition making the person unfit for employment 

5. An individual is exempt if he or she is a parent of a child under the age of 18 or is 

living in a household where a member is under the age of 18 

6. A person in any trimester of pregnancy is exempted 

F. REGAINING ELIGIBILITY 

1. An individual can regain eligibility if he or she works 80 hours in any 30 

consecutive days. 

2. The state agency has the option to prorate benefits from the date the “cure” is 

complete or back to the date of application. The state agency also has the option to 

determine eligibility for ABAWD purposes prospectively. 

3. There is no limit on the number of times an individual may regain and then 

maintain eligibility by fulfilling the work requirement 

4. The window of eligibility for the second three-month period starts on the date the 

state agency learns that the person has lost his or her job 

5. If an individual “forfeits” the opportunity to use the three consecutive countable 

months (for example, due to a voluntary quit sanction), the individual may work 

another 80 hours in a 30-day period and regain eligibility again for three 

consecutive months. 
 A-3 

G. APPLYING FOR WAIVERS 

1. To support a claim than an area has a 10 percent or higher unemployment rate, a state 

agency could provide the following evidence: (1) a recent 12-month average 

unemployment rate over 10 percent, (2) a recent 3-month average unemployment rate 

over 10 percent, or (3) a historical seasonal unemployment rate of over 10 percent 

2. To support a claim that an area has a lack of sufficient jobs, a state agency could 

provide the following evidence: (1) the Department of Labor’s Employment and 

Training Administration has designated the area as a labor surplus area, (2) the 

Department of Labor’s Unemployment Insurance Service has designated the area as 

qualifying for extended unemployment benefits, (3) the area has a low and declining 

employment-to-population ratio, (4) the area has a lack of jobs in declining 

occupations or industries, or (5) the area has a 24-month average unemployment rate 

20 percent above the national average for the same period. 

3. FNS will approve a waiver if a state agency submits and FNS confirms (1) data from 

the BLS or BLS cooperating agency that shows the most recent 12 month average 

unemployment rate in the area is over 10 percent, (2) data from the BLS or the BLS 

cooperating agency that an area has a 24-month average unemployment rate that 

exceeds the national average by 20 percent for any 24-month period, or (3) evidence 

that the areas has been designated as a Labor Surplus Area 

4. Data submitted to request a waiver for areas with unemployment rates higher than 10 

percent must be based on BLS data or methods 

5. Waivers can not be approved for more than one year 

6. State agencies have discretion in defining the geographic area covered by waivers 
APPENDIX B 

SOURCE OF QUANTITATIVE ESTIMATES OF ABAWDS 
B-1 

In Chapter II of this report we presented estimates of the number and characteristics of 

ABAWDs. These estimates were based on four sources: 

1. Tabulations provided by the states in response to a request (reproduced in Volume II) 

2. Caseload (micro) data submitted by five states in place of tabulations 

3. FSPQC sample data 

4. Data submitted to FNS by the states on Form FNS 583 

In this appendix we outline the procedures that we used to combine these data sources to 

develop both state and national estimates of ABAWD participants and their characteristics. We 

discuss, first, our estimates of the number of ABAWDs participating in the FSP. 

A. NUMBER OF ABAWDS PARTICIPATING IN THE FSP 

 In our request to the states we asked for separate counts of ABAWD participants in waived 

and nonwaived areas. Because ABAWDs in nonwaived areas are subject to the time limit while 

those in waived areas are not, states have much more reason to monitor the former than the latter 

and to have designed their data systems accordingly. Thus a state might be able to produce a 

count of ABAWDs in nonwaived areas without being able to produce a count in waived areas, 

but the reverse would not be true. Alternatively, a state might be able to report the total number 

of ABAWD participants but not break this down into waived and nonwaived areas. In response 

to our request, then, a state with waivers may have reported counts of both the waived and 

nonwaived ABAWD participants, just the nonwaived count, just the total count, or neither. A 

state with no waivers would have reported the nonwaived count (which is also the total count) or 

no count. The District of Columbia, which is fully waived, would have reported the waived count 

or no count. If every state reported the counts that were requested, we would have received 74 

counts from the 37 states with waivers and 14 counts from D.C. and the states with no waivers, 

for a grand total of 88. 
B-2 

 Table B.1 presents the counts that were reported by the states (tables appear at the end of 

this appendix). Altogether, 41 states reported at least one of the requested counts. Of the states 

with waivers, including D.C., 24 reported both the waived and nonwaived counts, 5 reported just 

the nonwaived count, 2 reported just the total count, and 7 reported nothing. Of the states 

without waivers, 10 reported the nonwaived count, and 3 reported nothing. Thus counts of 

ABAWD participants in nonwaived areas were reported by 39 states, and counts of total 

ABAWD participants were reported by 36 states. 

At a minimum, then, we needed to impute counts of ABAWDs to the following sets of areas 

in order to prepare complete national estimates: 

• Nonwaived areas in 8 states with waivers 

• Nonwaived areas in 3 states without waivers 

• Waived areas in 7 states that reported counts for just the nonwaived areas or the total 

• Waived areas in 6 states that reported nothing 

• D.C. 

This yields a total of 25 counts that were missing and needed to be imputed.1

 Our source of information from which to impute the missing data is the FSPQC sample file. 

These data allow the development of estimates of ABAWD participants through two independent 

approaches. The first is to use the participant’s age, household composition, receipt of disability 

benefits, and work registration exemption to simulate ABAWD status among the sample 

members in a given state. This yields an estimate of the total number of ABAWDs. If the state 

 

1

 If we have a count of ABAWD participants in nonwaived areas but not in waived areas, this represents one 

missing count because we will know the total number of ABAWDs once we know how many ABAWDs were in 

waived areas. Similarly, if we have a count of total ABAWD participants but not a breakdown by waived and 

nonwaived areas, this also represents one missing count because we will know the waived count once we know the 

nonwaived count.
B-3 

has waivers, the estimated total must be disaggregated into waived and nonwaived areas. This 

can be done quite readily by using the county code on the FSPQC file to distinguish residents of 

waived and nonwaived areas. Some waived counties are only partially waived, however, and the 

FSPQC file provides no additional geographic information with which to subdivide counties. 

The second approach makes use of an ABAWD status code that was introduced into the 

FSPQC file in FY98. The ABAWD code is designed to identify those persons whom a state has 

defined as ABAWDs, and it distinguishes between ABAWDs in waived and nonwaived areas, 

even when they reside in partially waived counties. It also breaks down the ABAWDs in 

nonwaived areas into those who are covered by the 15 percent exemption, those who are meeting 

the work requirement, and those who are not meeting the work requirement. The ABAWD code 

assumes the following values: 

1. ABAWD in a waived area 

2. Not an ABAWD 

3. Exempt based on 15 percent option 

4. ABAWD in first three time-limited months 

5. ABAWD in second three time-limited months 

6. ABAWD who has exhausted time-limited benefits 

7. ABAWD meeting work requirement 

8. ABAWD in a non-exempt area (and codes 1 through 7 do not apply) 

Codes 4, 5, and 6 identify ABAWDs who are subject to the time limit and not meeting the work 

requirement. Code 7 identifies those who are subject to the time limit but are meeting the work 

requirement. Code 8 is ambiguous, and the written documentation provides no additional 

explanation. We can imagine that code 8 might be assigned to persons who meet the state 

definition of an ABAWD but nevertheless have an exemption—perhaps only temporarily. The 
B-4 

fact that a participant with code 8 was not assigned a code of 4 through 7 suggests that this 

person is neither using up time-limited benefit-months nor meeting the work requirement. But 

this is purely speculation. 

 If the ABAWD code were applied as intended, it could help us not only with the imputation 

of counts of ABAWD participants in waived and nonwaived areas but with the imputation of the 

proportion of ABAWDs meeting the work requirement. Unfortunately, the application of the 

code in many states is flawed. For example, the code identifies far too many participants as 

ABAWDs in waived areas—including large numbers who are too young or too old to be 

ABAWDs—and too few ABAWDs with the 15 percent exemption (Castner 2000, Czajka 2000). 

In addition, the ambiguous code 8 is assigned to a large fraction of the ABAWDs in some states. 

Codes 4 through 7 are much less problematic, however. While they are sometimes inconsistent 

with other characteristics in the FSPQC data that bear on ABAWD status (age, presence of 

children, exemption from work registration), on the whole these four codes do seem to identify 

ABAWDs. They may misidentify some participants as ABAWDs and fail to identify others, and 

they may have biases that, likely, vary by state, but they provide a credible alternative to 

simulated ABAWD status. In theory, these four codes ought to be better than the simulation 

because they reflect elements of the ABAWD determination that cannot be simulated with the 

variables present in the FSPQC data, including how the eligibility workers actually apply aspects 

of state policy that give them some discretion. In sum, the ABAWD status code appears to be 

most useful in identifying participants who are subject to the time limit and, among these 

participants, those who are meeting the work requirement. 

 To determine how we might best use the FSPQC data to fill in the missing counts, we 

compared the estimates reported by the states with those obtained (for the same states) from 

FSPQC data for FY00. We had to do this for different subsets of states because, as we have 
B-5 

noted, the alternative methods of estimating the ABAWD population with FSPQC data are better 

suited to estimating somewhat different segments of the ABAWD population. 

 Table B.2 compares the state reports and the FSPQC simulations of the total number of 

ABAWD participants in the 36 states that provided such estimates. The FSPQC estimates are 

average monthly values for the fiscal year, with a midpoint corresponding to the end of March 

2000, which is also the approximate date of the estimates reported by the states. (Generally, the 

state reports represent end-of-month values.) 

 Over the 36 states, the total number of simulated ABAWD participants is less than threequarters of the number reported by the states. We note, however, that four states with 

exceptionally large discrepancies—Kentucky, North Carolina, Tennessee, and Texas—account 

for nearly all of the difference of 119,000 participants. Furthermore, if we exclude these four 

states, we find that half of the remaining 32 states have more reported participants than simulated 

participants and half have fewer. This suggests that, on average, the state reports and the 

simulations are measuring the same thing, but there is considerable variability between the two. 

While this is not a formal test of difference, since it assumes no random error in the state report, 

the estimated standard errors for the simulations suggest that in most states there is a statistically 

significant difference between the simulated number and the reported number of ABAWD 

participants. 

 There are good reasons why we would favor the state reports over the simulations, in 

general. First, the state reports have no sampling error whereas the simulations are often based 

on very few observations in a given state. Second, the state reports presumably tell us how many 

participants the states have actually defined as ABAWDs whereas the simulations represent how 

many participants the states should have defined as ABAWDs, given the characteristics captured 

in the FSPQC data and those aspects of state policy that we can replicate. But the discrepancies 

raise questions about the state reports, certainly. The simulations use much of the same 
B-6 

information that states would be using to identify ABAWDs. Furthermore, if there is an overall 

bias in the simulations, we would expect the simulations to overstate the number of ABAWDs—

more so in some states than others.2

 Yet, when we exclude four states with far more reported 

than simulated ABAWDs, as we have seen, the state reports and the simulations are roughly 

equal on average. This implies that an upward bias in the simulations is not the principal source 

of the discrepancies. 

 To compare the state reports with estimates based on the ABAWD code, we first restrict our 

attention to nonwaived areas. Table B.3 compares the state reports with two alternative 

estimates from the FSPQC data: (1) simulated ABAWDs residing in nonwaived counties and (2) 

participants with ABAWD status codes of 4 through 7 plus the state’s report of 15 percent 

exemptions used in March 2000. The comparison includes 37 states that provided estimates of 

the number of ABAWD participants in nonwaived areas (we excluded two states as noted in the 

table). Some counties are only partially waived from the ABAWD provisions, and in these 

counties we cannot determine whether a simulated ABAWD is in the waived or nonwaived 

portion. For the three-way comparison we excluded states with partially waived counties, 

leaving 23 states. In the final two columns of the table we add the 14 states with partially waived 

counties, but we limit the comparison to the state reports and the estimates based on the 

ABAWD code. 

 When summed over the 23 states the simulated number of ABAWDs is less than threequarters of the number reported by the states, and the number based on the ABAWD code is not 

much more than half the number reported by the states. If we restrict the estimates based on the 

 

2

 States may have additional criteria for determining unfitness for employment that do not show up in the work 

registration exemption and disability benefits that we used to identify such persons in the simulation. 
B-7 

ABAWD code to participants in nonwaived counties (column 4), the number drops slightly.3

 

There are only six states in which the estimate based on the ABAWD code is higher than the 

number reported by the state and seven states in which the estimate based on the simulation is 

higher than the state report. Unlike Table B.2, then, the aggregate differences between the state 

reports and the estimates based on the FSPQC data cannot be attributed to a few outliers. 

 When we expand the comparison to include states with partially waived areas, which limits 

the comparison to the estimates based on the ABAWD code, the similarity of the two sets of 

estimates increases somewhat.4

 Summed over the 37 states the estimate based on the ABAWD 

code approaches two-thirds of the aggregate number reported by the states, and in 12 states the 

estimate based on the ABAWD code is higher than the state report. But, clearly, the ABAWD 

code yields smaller estimates of ABAWDs in nonwaived areas than the states’ own reports. 

 Table B.4 compares the state reports with alternative estimates of ABAWD participants in 

waived areas. Again, if we exclude states with partial waivers we can estimate the number of 

simulated ABAWDs in waived areas. We also include in this comparison a separate estimate 

based on participants with ABAWD codes of 1 (ABAWD in a waived area) and living in waived 

counties. The three-way comparison is based on 12 states. Summed over the 12 states, the 

number of simulated participants is less than one-fourth the reported number while the estimate 

based on ABAWD code 1 is just under half the state report. Here, however, two outliers—

Tennessee and Texas—account for most of the aggregate difference. Furthermore, a comparison 

of the individual state estimates shows that in most states the state report and the estimate based 

 

3

 This restriction should not be necessary because the ABAWD code takes waiver status into account. The 

slight discrepancy could be due to errors in the assignment of the ABAWD code. It could also be due to counties 

that were waived later or earlier in FY00 but not March 2000. The FSPQC data are drawn from the entire year, but 

our assignment of waiver status to counties reflects March 2000. 4

 We included in the FSPQC estimate those participants in partially waived counties but excluded those in fully 

waived counties. 
B-8 

on ABAWD code 1 are actually rather similar. Extending the comparison to include states with 

partial waivers strengthens this assessment. Kentucky, Tennessee, and Texas account for nearly 

all of the aggregate difference between the state reports and the estimates based on ABAWD 

code 1. Further, while the state report is still more likely to be above than below the estimate 

based on the ABAWD code, the latter appears to provide a reasonable proxy for the state report. 

 On the basis of these comparisons, we decided to impute the missing counts as follows. For 

nonwaived areas, we assigned to each missing count the FSPQC estimate based on ABAWD 

codes 4 through 7 plus the number of 15 percent exemptions reported to FNS on form FNS 583. 

We excluded participants in fully waived counties but not in partially waived counties. Unlike 

the simulation, the ABAWD status code allows us to identify nonwaived ABAWDs in partially 

waived counties. We imputed waived areas differently, depending on whether the state reported 

a count of ABAWDs in nonwaived areas. For waived areas in the seven states that reported 

counts of ABAWDs in nonwaived areas, we first attempted to impute the number of ABAWDs 

in waived areas by subtracting the reported count of nonwaived ABAWDs from the estimate of 

total ABAWDs based on simulation. This was successful in three states, but in the other four it 

produced estimates that were either negative or too high relative to the count of nonwaived 

ABAWDs. In these four states we imputed the FSPQC estimate based on individuals 18 to 50 

who had ABAWD status code 1 and lived in counties that were fully waived or partially 

waived.5

 Again, this use of code 1 allowed us to separate waived from nonwaived ABAWDs in 

partially waived counties. For waived areas in states that did not report counts of ABAWDs in 

nonwaived areas, we substituted the number of simulated ABAWDs who were living in fully

 

5

 If the waived area in a partially waived county was an Indian reservation, we counted just those participants 

(18 to 50 with ABAWD code 1) who were Native Americans. 
B-9 

waived counties or who were Native Americans living in counties with waived Indian 

reservations. Except for two states, an alternative imputation using ABAWD code 1 would have 

yielded very similar results. We actually favored that approach until seeing that the estimate 

based on code 1 in one state was implausibly high. In the other state, however, we felt that the 

estimate based on the simulation was too low, and we made an exception to base this one state 

on code 1.

 In addition to the 25 missing counts we also imputed substitute counts for ABAWDs in 

waived areas in Kentucky and Maine, nonwaived areas in North Carolina, and both waived and 

nonwaived areas in Tennessee.6, 7 In doing so we followed the procedures described above 

except that in waived areas in Tennessee we substituted an estimate based on ABAWD code 1, 

which was more consistent with the total number of adults (18 to 50) in waived areas. For 

Alaska and Georgia, which reported the total number of ABAWDs but could not disaggregate 

them, we divided the state counts into waived and nonwaived areas based on additional 

information that the states provided rather than FSPQC data. 

The imputed numbers are reported in Table B.5. The final estimates of ABAWD 

participants in waived and nonwaived areas, including both reported and imputed values, are 

presented in Table B.6. 

 

6

 We consulted with all four states. Maine and North Carolina confirmed that the reported numbers in question 

represented a broader population than we were intending. Kentucky and Tennessee, on the other hand, could not see 

anything in their estimation procedures that would have produced excessively high numbers. Nevertheless, the 

reported numbers fell so far outside the plausible range that we elected to substitute alternative numbers anyway. 7

 We retained the reported counts for Texas, despite the fact that they were much higher than the simulations 

(Table B.1), because the frequency of ABAWD participants relative to all participants 18 to 50, broken down by 

waiver status, approximated the national average. 
B-10 

B. NUMBER OF ABAWDS MEETING THE WORK REQUIREMENT 

More than half of the states (29) reported to us the percentage of ABAWDs subject to the 

time limit who were meeting the work requirement. Table B.7 presents for each of these states 

the reported percentage meeting the work requirement in March 2000 and two alternative 

estimates for FY00 developed from the FSPQC data. The first of these is based entirely on the 

ABAWD status code while the second (constructed code) is based on measures of employment 

activity (which includes E&T) and workfare participation. The estimates based on these 

alternatives differ from each other rather considerably, but there is no consistent pattern. Each is 

occasionally very close to the number reported by the state, but often the discrepancy is 

considerable. 

States are required to report to FNS each quarter the number of workfare slots and education 

and training slots filled by ABAWDs and qualifying for federal reimbursement in each of the 

preceding three months. Slots are reported separately for waived and nonwaived areas. For 

states that did not report the percentage of their ABAWDs who were meeting the work 

requirement, the quarterly reports to FNS are a potential source of counts of ABAWDs who were 

meeting the work requirement by participating in workfare or education and training. 

The first four columns of Table B.8 shows what states provided us with respect to counts of 

ABAWDs participating in workfare, as well as education and training, plus the counts reported 

on Form FNS 583 for the same month. We expected that the counts states reported to us would 

occasionally exceed what they reported on Form 583 because states might have slots that were 

not federally funded. The states might also interpret our request differently from Form 583. 

Table B.8 shows the following. The total count of workfare participants over the 19 states is 

virtually identical between the state reports and Form FNS 583. The remains true even if we 

exclude California, which accounts for more than 80 percent of the total. But while the totals 

agree, there are sizable differences for about half the states—reflecting a pattern that has become 
B-11 

familiar. For education and training, the sum of state reports of participants is nearly 50 percent 

higher than the Form 583 total and would be nearly twice as high without California. At the 

state level, however, the two reports are more similar, with only four states accounting for most 

of the aggregate difference. 

Table B.8 also includes two pairs of estimates from the FSPQC data, based on the 

constructed code described earlier. The first pair of estimates reflects the incidence of workfare 

and of employment and training activities other than workfare among FSP participants with 

ABAWD codes of 4 through 7. Part of the difference between the FSPQC estimates and those 

reported by the state may be due to the fact that the (weighted) number of participants with codes 

4 through 7 differs from and generally understates the reported number of participants subject to 

the time limit. The second pair of estimates represents an attempt to adjust for this difference—

specifically, by multiplying the first pair of estimates by the ratio of two quantities in each state: 

(1) the reported or imputed number of participants subject to the time limit and (2) the number of 

participants with codes 4 through 7. For example, in Colorado the reported number of 

participants subject to the time limit is slightly lower than the estimate based on ABAWD codes 

4 through 7, so the adjusted workfare and education and training estimates are slightly lower than 

the unadjusted estimates. In Florida, however, the reported number of participants subject to the 

limit is only 40 percent of the number estimated from ABAWD codes 4 through 7, so the 

adjusted estimates of workfare and education and training participants are 40 percent of the 

unadjusted estimates. 

Summed over the 19 states, both of the FSPQC estimates of ABAWD workfare participants 

are considerably lower than the number reported by the states. This is due entirely to California, 

however. If we exclude California, the FSPQC estimates of workfare participants are actually 

higher than the numbers reported by the states. But there are very few states in which either 

estimate from the FSPQC is very close to what the state reported. With respect to education and 
B-12 

training, the two FSPQC estimates exceed the state reports by a considerable margin. Removing 

California increases the discrepancy. Over the remaining 18 states the sum of either set of 

FSPQC estimates is more than two-and-a-half times the sum of the state reports. As with the 

workfare estimates, there are very few states for which the state reports and the FSPQC estimates 

are remotely close. Unlike workfare, which meets the ABAWD work requirement almost by 

definition, the education and training activities captured in the FSPQC may include many that do 

not meet the work requirement—such as job search—or that fall short of the minimum 20 hours 

per week.8

 

 Based on these findings and certain additional considerations, we elected to use the Form 

583 data to impute the number of ABAWD participants meeting the work requirement through 

workfare or education and training. These additional considerations included the absence of 

sampling error in the Form 583 numbers, their monthly frequency (giving us figures for March 

2000), and their status as official state reports. 

When a state did not report the number of ABAWD participants who were meeting the work 

requirement or did not provide a complete breakdown of the way in which participants were 

meeting the work requirement, we did the following to impute the missing information. First, if 

a state did not report participation in workfare or education and training, we used the state’s 

submission on Form FNS 583 for March 2000 to obtain counts of ABAWDs in nonwaived areas 

who were participating in workfare or education and training. We directly substituted the Form 

 

8

 The FSPQC data may also include other work activities that do not qualify as workfare or education and 

training but that may nevertheless meet the ABAWD work requirement—such as the self-initiated community 

service by which many ABAWDs met the work requirement in Michigan. However, only in Michigan and Indiana, 

among states reporting how ABAWDs met the work requirement, did such activities account for a significant 

proportion of all qualifying activities. 
B-13 

583 numbers for the missing items.9

 Second, if a state reported the total number of participants 

meeting the work requirement but not the breakdown, which happened very rarely, we subtracted 

from this figure the number participating in workfare or education and training, as imputed in the 

first step. Third, if a state did not report the total number of participants meeting the work 

requirement, we estimated from FSPQC data the number who were meeting the work 

requirement by working. Specifically, we determined the proportion of ABAWDs subject to the 

time limit who were working at least 20 hours per week, and we multiplied this percentage by 

the reported or imputed number of participants subject to the time limit. We compared this 

estimate to an alternative estimate calculated by subtracting the reported or imputed numbers 

meeting the work requirement through methods other than work from an FSPQC-based estimate 

of the total number meeting the work requirement, and we took the smaller of the two—but not 

less than zero.10 This gave us the imputed number meeting the work requirement by working, 

which we then added to the reported or imputed numbers meeting the work requirement through 

workfare or education and training to obtain the imputed, total number meeting the work 

requirement.11

The results of these imputations are presented in Table B.9. Final estimates combining the 

reported and imputed values are presented in Table B.10. 

 

9

 We encountered one case in which the number of participants reported on Form 583 for education and 

training exceeded the state’s estimated number of ABAWDs in nonwaived areas. We determined in conversations 

with the state that the allocation of E&T participants between waived and nonwaived areas was the likely source of 

the problem, and we adjusted the estimates of workfare and education and training participants to be consistent with 

the number of ABAWD participants and the very high proportion of ABAWDs who were estimated to be meeting 

the work requirement in the FSPQC data. 10 We were concerned that in combining FSPQC estimates of employment with state reports of workfare and 

education and training participation, there existed a potential to overstate the total number of participants meeting 

the work requirement. This two-step approach limits the impact of sampling error and certain kinds of nonsampling 

error on the estimate of the number meeting the work requirement by working. 11 The state reports suggested that very few participants met the work requirement through activities other than 

these three and gave us little basis for imputing such activities, so we did not attempt to do so. This may result in 

our understating by a small margin the overall proportion meeting the work requirement. 
B-14 

C. CHARACTERISTICS OF ABAWD PARTICIPANTS 

States were less likely to provide tabulations of the characteristics of ABAWD participants 

and their households than they were to provide estimates of the percentage of participants who 

were meeting the work requirement. As a result, we had to rely more heavily on FSPQC data 

than we did for the basic counts of ABAWDs. We also used FSPQC data to prepare tabulations 

of information that was not requested from the states—namely, the characteristics of all 

participants 18 to 50. Chapter II includes two sets of national-level comparisons with respect to 

the characteristics of ABAWD participants: (1) a comparison of ABAWDs subject to the time 

limit with all participants 18 to 50 and (2) a comparison of ABAWD participants who were 

meeting the work requirement with those who were subject to the time limit but not meeting the 

work requirement. 

For both sets of comparisons we created national estimates of the characteristics of ABAWD 

participants who were subject to the time limit by combining the tabulations reported by the 

states with estimates that were constructed from FY00 FSPQC data for the remaining states. In 

constructing the combined estimates for a given characteristic, we first tabulated the FSPQC data 

for just those states that did not provide counts for that characteristic. As a rule, the FSPQC 

tabulation accounted for fewer ABAWDs across the set of states than did our separate estimates 

of ABAWDs in those states. Before combining the tabulations from the two sources to create 

national estimates, therefore, we ratio-adjusted the FSPQC tabulation so that it summed to the 

desired number of ABAWDs (which, depending on the tabulation, was the number subject to the 

time limit, the number meeting the work requirement, or the number not meeting the work 

requirement). We then added the adjusted FSPQC tabulation, cell by cell, to the corresponding 

tabulation constructed from the counts provided by the states. For example, in tabulating the 

number of ABAWDs subject to the time limit by age and sex, we estimated from the FSPQC 

data that there were 95,000 such ABAWDs in the states that supplied no counts. From Table 
B-15 

II.11 we estimated that there were 115,000 such ABAWDs, or about 20,000 more than the 

FSPQC estimate. We increased each cell of the FSPQC table by about 20 percent so that the 

FSPQC table summed to 115,000. We added this adjusted tabulation to the tabulation of state 

counts, and the resulting table summed to 216,000, the number of ABAWDs subject to the time 

limit, as reported in Table II.11. 

 We could have applied the ratio adjustment differently, by separately adjusting each state’s 

FSPQC tabulation to match the estimated number of ABAWDs in that state. We elected not to 

do this because the sampling error in the state-level FSPQC tabulations of ABAWDs is very 

high. Applying state-specific adjustments would have resulted in the largest adjustments being 

applied to the states with the weakest ABAWD sample data and the smallest adjustments being 

applied to the states with the strongest ABAWD sample data. This would have increased the 

sampling error in the national estimates relative to the procedure that we employed. 

For states that reported tabulations, we compared the estimates across the set of such states 

with the estimates that we generated from FSPQC data. While the FSPQC data for these states 

were not used in creating the national estimates, this comparison allowed us to confirm that the 

FSPQC data were roughly consistent with the state tabulations. 
B-16 

TABLE B.1

STATE REPORTS OF ABAWD PARTICIPANT COUNTS, MARCH 2000

Number of ABAWD Participants

In In

Waived Nonwaived

Total Areas Areas

Alabama 4,241 1,939 2,302

Alaska 1,440

Arizona 7,269

Arkansas

California 55,614 0 55,614

Colorado 2,058 274 1,784

Connecticut

Delaware 0

District of Columbia 0

Florida 8,993 6,605 2,388

Georgia 10,405

Hawaii 1,384

Idaho 276

Illinois 34,422 29,851 4,571

Indiana 2,518 701 1,817

Iowa 1,388 0 1,388

Kansas 2,611 0 2,611

Kentucky 40,657 37,293 3,364

Louisiana 15,210 13,008 2,202

Maine 4,142 3,878 264

Maryland 5,551 4,222 1,329

Massachusetts 0

Michigan 16,644 0 16,644

Minnesota 5,822 1,438 4,384

Mississippi 1,460 0 1,460

Missouri

Montana

Nebraska

Nevada 999 216 783

New Hampshire 0

New Jersey 8,208 6,675 1,533

New Mexico 2,564 1,491 1,073

New York 28,029 2,121 25,908

North Carolina 32,658 0 32,658

North Dakota 404

Ohio 10,844 0 10,844

Oklahoma 4,081 0 4,081

Oregon 8,303 0 8,303

Pennsylvania 33,176 29,177 3,999

Rhode Island 1,769 1,483 286

South Carolina 4,173 1,641 2,532

South Dakota 1,279 879 400

Tennessee 40,987 26,581 14,406

Texas 35,531 19,096 16,435

Utah

Vermont 1,628 246 1,382

Virginia 12,761 4,960 7,801

Washington 3,975

W. Virginia 7,668 6,681 987

Wisconsin 2,225 0 2,225

Wyoming 557 85 472

Number of Counts Requested 51 38 50

Number of Counts Provided 36 24 39

SOURCE: Mathematica Policy Research, Inc., from data supplied by the

 states.
B-17 

TABLE B.2

COMPARISON OF TOTAL ABAWD PARTICIPANTS AS REPORTED

BY STATES AND SIMULATED WITH FY00 QC DATA

Difference

Divided by

Reported Simulated Approximate Approximate

ABAWD ABAWD Standard Standard

Participants Participants Error of Error of

State March 2000 FY00 Simulation Simulation

 Total 450,616 331,461 -- --

Alabama 4,241 4,704 849 0.55

Alaska 1,440 4,129 421 6.39

Arizona

Arkansas

California 55,614 43,485 5,753 -2.11

Colorado 2,058 1,590 341 -1.37

Connecticut

Delaware

District of Columbia

Florida 8,993 18,045 2,509 3.61

Georgia 10,405 10,652 1,608 0.15

Hawaii

Idaho

Illinois 34,422 39,021 3,113 1.48

Indiana 2,518 4,173 721 2.29

Iowa 1,388 1,974 323 1.81

Kansas 2,611 1,879 321 -2.28

Kentucky 40,657 13,693 1,434 -18.80

Louisiana 15,210 16,748 1,741 0.88

Maine 4,142 1,957 367 -5.95

Maryland 5,551 3,005 543 -4.69

Massachusetts

Michigan 16,644 10,944 1,411 -4.04

Minnesota 5,822 3,153 558 -4.78

Mississippi 1,460 3,098 557 2.94

Missouri

Montana

Nebraska

Nevada 999 1,204 266 0.77

New Hampshire

New Jersey 8,208 8,405 1,088 0.18

New Mexico 2,564 3,681 428 2.61

New York 28,029 49,996 6,218 3.53

North Carolina 32,658 3,582 830 -35.03

North Dakota

Ohio 10,844 7,411 1,429 -2.40

Oklahoma 4,081 2,638 496 -2.91

Oregon 8,303 7,523 918 -0.85

Pennsylvania 33,176 18,011 2,510 -6.04

Rhode Island 1,769 7,051 588 8.98

South Carolina 4,173 5,113 752 1.25

South Dakota 1,279 838 204 -2.16

Tennessee 40,987 4,274 1,051 -34.93

Texas 35,531 12,408 2,238 -10.33

Utah

Vermont 1,628 210 109 -13.01

Virginia 12,761 4,978 889 -8.75

Washington

W. Virginia 7,668 7,387 830 -0.34

Wisconsin 2,225 4,129 505 3.77

Wyoming 557 373 107 -1.72

SOURCE: Counts reported by states and FY00 FSPQC sample data.
B-18 

TABLE B.3

ABAWD PARTICIPANTS IN NONWAIVED AREAS: COMPARISON OF

STATE REPORTS AND QC SAMPLE-BASED ESTIMATES

Excluding States with Partial Waivers No Exclusion

All Nonwaived Nonwaived

Simulated Code 4-7 Code 4-7 Code 4-7

Reported Nonwaived ABAWD ABAWD Reported ABAWD

ABAWD ABAWD Participants Participants ABAWD Participants

State Participants Participants +15% Exempt +15% Exempt Participants +15% Exempt

 Total 158,584 112,492 91,229 88,355 192,972 122,220

Alabama 2,302 2,946 1,493 1,196 2,302 1,196

Alaska

Arizona 7,269 883

Arkansas

California 55,614 43,485 28,184 28,184 55,614 28,184

Colorado 1,784 1,590 1,900 1,900 1,784 1,900

Connecticut

Delaware

District of Columbia

Florida 2,388 3,196

Georgia

Hawaii 1,384 1,653 1,250 1,250 1,384 1,250

Idaho 276 445 568 568 276 568

Illinois 4,571 8,482

Indiana 1,817 2,042

Iowa 1,388 1,974 871 871 1,388 871

Kansas 2,611 1,879 2,216 2,216 2,611 2,216

Kentucky 3,364 3,800

Louisiana 2,202 1,978

Maine 264 942

Maryland 1,329 353

Massachusetts 0 0 0 0 0 0

Michigan 16,644 10,944 10,473 10,473 16,644 10,473

Minnesota 4,384 2,971 1,822 1,725 4,384 1,725

Mississippi 1,460 3,098 4,905 4,905 1,460 4,905

Missouri

Montana

Nebraska

Nevada 783 386 1,266 452 783 1,266

New Hampshire

New Jersey 1,533 1,581

New Mexico 1,073 1,227 1,416 569 1,073 849

New York

North Carolina

North Dakota 404 189

Ohio 10,844 7,411 5,828 5,828 10,844 5,828

Oklahoma 4,081 2,638 720 720 4,081 720

Oregon 8,303 7,523 6,370 6,370 8,303 6,370

Pennsylvania 3,999 5,999

Rhode Island 286 54

South Carolina 2,532 2,497 2,126 2,021 2,532 2,021

South Dakota 400 140 383 383 400 383

Tennessee 14,406 2,924 3,447 3,447 14,406 3,447

Texas 16,435 9,817 9,387 8,990 16,435 8,990

Utah

Vermont 1,382 210 695 695 1,382 695

Virginia 7,801 2,318 1,699 1,381 7,801 1,381

Washington 3,975 3,064

West Virginia 987 209

Wisconsin 2,225 4,129 4,128 4,128 2,225 4,128

Wyoming 472 286 83 83 472 83

SOURCE: Counts reported by states and FY00 FSPQC sample data.

NOTE: New York and North Carolina are not included in this table. New York City is incorrectly coded as waived in the

 FSPQC data, and the reported counts for North Carolina represent a broader universe than just ABAWDs.

 In addition, in the final column we excluded fully waived counties but not partially waived counties.
B-19 

TABLE B.4

ABAWD PARTICIPANTS IN WAIVED AREAS: COMPARISON OF STATE REPORTS

AND QC SAMPLE-BASED ESTIMATES

Excluding States with Partial Waivers No Exclusion

Code 1 Code 1

Simulated ABAWD ABAWD

Reported Waived Participants Reported Participants

ABAWD ABAWD In Waived ABAWD In Waived

State Participants Participants Areas Participants Areas

 Total 58,846 13,934 28,341 200,541 133,823

Alabama 1,939 1,758 1,900 1,939 1,900

Alaska

Arizona

Arkansas

California

Colorado 274 0 0 274 0

Connecticut 0 0

Delaware

District of Columbia

Florida 6,605 15,212

Georgia

Hawaii

Idaho

Illinois 29,851 31,169

Indiana 701 1,397

Iowa

Kansas

Kentucky 37,293 2,149

Louisiana 13,008 19,212

Maine 3,878 455

Maryland 4,222 0

Massachusetts

Michigan

Minnesota 1,438 182 0 1,438 0

Mississippi

Missouri

Montana

Nebraska

Nevada 216 52 160 216 160

New Hampshire

New Jersey 6,675 13,790

New Mexico 1,491 2,126 893 1,491 893

New York 2,121 759

North Carolina

North Dakota

Ohio

Oklahoma

Oregon

Pennsylvania 29,177 20,493

Rhode Island 1,483 670

South Carolina 1,641 2,616 5,142 1,641 5,142

South Dakota 879 599 468 879 468

Tennessee 26,581 1,350 7,087 26,581 7,087

Texas 19,096 2,591 6,954 19,096 6,954

Utah

Vermont 246 0 0 246 0

Virginia 4,960 2,660 5,619 4,960 5,619

Washington 0 0

W. Virginia 6,681 178

Wisconsin

Wyoming 85 0 116 85 116

SOURCE: Counts reported by states and FY00 FSPQC sample data.
B-20 

TABLE B.5

QC SAMPLE-BASED IMPUTATION OF ABAWD PARTICIPANT COUNTS

Number of ABAWD Participants

In In

Waived Nonwaived

State Total Areas Areas

 Total 73,413 49,147 24,266

Alabama 0 0 0

Alaska 0 0 0

Arizona 6,137 6,137 0

Arkansas 9,562 6,322 3,240

California 0 0 0

Colorado 0 0 0

Connecticut 8,073 7,228 845

Delaware 672 0 672

District of Columbia 6,907 6,907 0

Florida 0 0 0

Georgia 0 0 0

Hawaii 1,305 1,305 0

Idaho 0 0 0

Illinois 0 0 0

Indiana 0 0 0

Iowa 0 0 0

Kansas 0 0 0

Kentucky 10,329 10,329 0

Louisiana 0 0 0

Maine 455 455 0

Maryland 0 0 0

Massachusetts 2,469 0 2,469

Michigan 0 0 0

Minnesota 0 0 0

Mississippi 0 0 0

Missouri 5,981 1,487 4,494

Montana 1,266 685 581

Nebraska 825 40 785

Nevada 0 0 0

New Hampshire 94 0 94

New Jersey 0 0 0

New Mexico 0 0 0

New York 0 0 0

North Carolina 6,681 0 6,681

North Dakota 193 193 0

Ohio 0 0 0

Oklahoma 0 0 0

Oregon 0 0 0

Pennsylvania 0 0 0

Rhode Island 0 0 0

South Carolina 0 0 0

South Dakota 0 0 0

Tennessee 10,534 7,087 3,447

Texas 0 0 0

Utah 1,014 56 958

Vermont 0 0 0

Virginia 0 0 0

Washington 916 916 0

W. Virginia 0 0 0

Wisconsin 0 0 0

Wyoming 0 0 0

SOURCE: Mathematica Policy Research, Inc., from FY00 FSPQC sample data.
B-21 

TABLE B.6

REPORTED PLUS IMPUTED ABAWD PARTICIPANT COUNTS, MARCH 2000

Number of ABAWD Participants

In In

Waived Nonwaived

State Total Areas Areas

 Total 422,521 190,536 231,985

Alabama 4,241 1,939 2,302

Alaska 1,440 860 580

Arizona 13,406 6,137 7,269

Arkansas 9,562 6,322 3,240

California 55,614 0 55,614

Colorado 2,058 274 1,784

Connecticut 8,073 7,228 845

Delaware 672 0 672

District of Columbia 6,907 6,907 0

Florida 8,993 6,605 2,388

Georgia 10,405 7,740 2,665

Hawaii 2,689 1,305 1,384

Idaho 276 0 276

Illinois 34,422 29,851 4,571

Indiana 2,518 701 1,817

Iowa 1,388 0 1,388

Kansas 2,611 0 2,611

Kentucky 13,693 10,329 3,364

Louisiana 15,210 13,008 2,202

Maine 719 455 264

Maryland 5,551 4,222 1,329

Massachusetts 2,469 0 2,469

Michigan 16,644 0 16,644

Minnesota 5,822 1,438 4,384

Mississippi 1,460 0 1,460

Missouri 5,981 1,487 4,494

Montana 1,266 685 581

Nebraska 825 40 785

Nevada 999 216 783

New Hampshire 94 0 94

New Jersey 8,208 6,675 1,533

New Mexico 2,564 1,491 1,073

New York 28,029 2,121 25,908

North Carolina 6,681 0 6,681

North Dakota 597 193 404

Ohio 10,844 0 10,844

Oklahoma 4,081 0 4,081

Oregon 8,303 0 8,303

Pennsylvania 33,176 29,177 3,999

Rhode Island 1,769 1,483 286

South Carolina 4,173 1,641 2,532

South Dakota 1,279 879 400

Tennessee 10,534 7,087 3,447

Texas 35,531 19,096 16,435

Utah 1,014 56 958

Vermont 1,628 246 1,382

Virginia 12,761 4,960 7,801

Washington 4,891 916 3,975

W. Virginia 7,668 6,681 987

Wisconsin 2,225 0 2,225

Wyoming 557 85 472

SOURCE: Mathematica Policy Research, Inc., from counts supplied by the states

 and supplemental counts imputed with FSPQC sample data.
B-22 

TABLE B.7

STATE REPORT AND ALTERNATIVE QC SAMPLE ESTIMATES

OF PROPORTION MEETING THE WORK REQUIREMENT

AMONG ABAWD PARTICIPANTS SUBJECT TO TIME LIMIT

States Not

States Providing Estimates Providing Estimates

State ABAWD Constructed ABAWD Constructed

State Report Code Code Code Code

Alabama 9.3% 60.7%

Alaska 41.5% 41.5% 21.8%

Arizona 51.7% 0.0% 25.1%

Arkansas 82.8% 23.8%

California 43.6% 65.6%

Colorado 42.8% 43.3% 33.0%

Connecticut 68.7% 33.2%

Delaware 13.0% 26.2%

District of Columbia

Florida 41.6% 57.9%

Georgia 69.6% 58.4%

Hawaii 17.9% 40.0% 35.3%

Idaho 29.6% 30.0% 39.0%

Illinois 87.4% 57.0%

Indiana 21.6% 19.0% 25.0%

Iowa 23.4% 29.3%

Kansas 20.4% 29.4% 20.5%

Kentucky 48.1% 38.2% 10.9%

Louisiana 56.6% 29.1%

Maine 21.6% 35.8% 14.2%

Maryland 0.5% 37.0% 0.0%

Massachusetts 35.2% 61.8%

Michigan 20.8% 34.4% 34.1%

Minnesota 28.0% 22.1%

Mississippi 100.0% 65.5% 37.0%

Missouri 69.4% 15.2%

Montana 33.5% 39.8%

Nebraska 29.5% 28.5%

Nevada 3.7% 30.6% 86.7%

New Hampshire 0.0% 0.0%

New Jersey 100.0% 90.4%

New Mexico 1.6% 76.4% 73.2%

New York 76.4% 61.6%

North Carolina 14.6% 40.8%

North Dakota 40.1% 46.8% 43.4%

Ohio 11.0% 23.0% 32.1%

Oklahoma 4.0% 25.2% 37.8%

Oregon 94.6% 55.2% 44.5%

Pennsylvania 13.6% 61.1% 51.0%

Rhode Island 25.0% 0.0% 100.0%

South Carolina 55.0% 42.7% 0.0%

South Dakota 44.8% 75.5% 49.0%

Tennessee 59.1% 30.4% 29.0%

Texas 52.8% 20.9% 5.7%

Utah 27.4% 38.9%

Vermont 32.1% 53.3% 15.4%

Virginia 55.9% 28.0% 27.5%

Washington 24.9% 11.1% 22.3%

W. Virginia 50.4% 49.3%

Wisconsin 32.4% 37.1% 50.5%

Wyoming 55.5% 35.9% 68.8%

SOURCE: Counts provided by the states and supplemental estimates prepared by Mathematica Policy Research,

 Inc., from FY00 FSPQC sample data.

NOTE: The percentage based on the ABAWD code equals the number of participants with ABAWD code equal to 7

 divided by the number with ABAWD codes 4 through 7. The constructed code is based on the same

 universe but uses employment status and workfare status fields to determine if the participant is working 20

 or more hours per week, participating in workfare, or participating in another E&T activity.
B-23 

TABLE B.8

ABAWD PARTICIPANTS IN WORKFARE AND EDUCATION AND TRAINING AS REPORTED IN

STATE TABULATIONS, FORM FNS 583, AND FSPQC DATA

FSPQC Adjusted FSPQC

State Report Form FNS 583 Constructed Code Constructed Code

Education Education Education Education

and and and and

Workfare Training Workfare Training Workfare Training Workfare Training

U.S. Total 26,794 5,034 26,909 3,547 11,302 8,178 18,493 8,214

Without California 4,545 3,178 4,676 1,692 5,272 8,178 6,542 8,214

Alabama

Alaska

Arizona 203 0 23 2 161 0 1,763 0

Arkansas

California 22,249 1,856 22,233 1,855 6,029 0 11,951 0

Colorado 497 181 652 208 74 305 70 285

Connecticut

Delaware

District of Columbia

Florida 111 33 111 33 1,062 349 420 138

Georgia

Hawaii

Idaho 63 1 0 0 0 48 0 20

Illinois

Indiana 0 169 82 140 0 253 0 225

Iowa

Kansas

Kentucky 0 563 217 0 341 0 293 0

Louisiana

Maine 6 1 7 2 63 0 16 0

Maryland

Massachusetts

Michigan 0 737 180 0 0 1,966 0 3,124

Minnesota

Mississippi 997 0 551 29 190 1,012 48 255

Missouri

Montana

Nebraska

Nevada 3 24 0 0 0 1,033 0 636

New Hampshire

New Jersey

New Mexico 0 7 0 7 469 47 355 36

New York

North Carolina

North Dakota

Ohio 517 250 1,414 122 1,059 0 1,971 0

Oklahoma

Oregon 923 0 298 23 783 932 1,029 1,225

Pennsylvania 0 51 0 389 0 1,135 0 703

Rhode Island

South Carolina 142 1,001 121 586 0 0 0 0

South Dakota

Tennessee

Texas

Utah

Vermont

Virginia 34 19 34 19 0 150 0 689

Washington 769 10 589 2 0 567 0 671

W. Virginia

Wisconsin 280 131 397 130 1,070 383 577 207

Wyoming

SOURCE: Counts provided by the states, Form FNS 583, and FSPQC data.
B-24 

TABLE B.9

IMPUTATION RESULTS FOR WAY OF MEETING THE WORK REQUIREMENT

Education

and

State Working Workfare Training

U.S. Total 38,173 23,597 2,708

Alabama 453 553 0

Alaska 179 59 0

Arizona

Arkansas

California 12,203

Colorado

Connecticut 78 15 30

Delaware 132 2 0

District of Columbia

Florida 419

Georgia 766 172 25

Hawaii 243 0 5

Idaho 20

Illinois

Indiana

Iowa 407 0 0

Kansas

Kentucky

Louisiana 340 44 5

Maine

Maryland

Massachusetts 247 106 0

Michigan

Minnesota 683 25 238

Mississippi

Missouri 332 0 38

Montana 0 0 394

Nebraska 154 27 0

Nevada 35

New Hampshire 0 40 6

New Jersey 399 157 716

New Mexico 0

New York 1,548 21,500 800

North Carolina 1,593 38 28

North Dakota 160 0 2

Ohio

Oklahoma

Oregon 6,691 23

Pennsylvania

Rhode Island

South Carolina 0

South Dakota 124 51 4

Tennessee 1,690 281 66

Texas 8,198 457 21

Utah 102 57 114

Vermont 422 13 9

Virginia

Washington

W. Virginia 307 0 170

Wisconsin

Wyoming 248 0 14

SOURCE: Mathematica Policy Research, Inc., from FSPQC sample data

 for FY00 and Form FNS 583 data for March 2000.
B-25 

TABLE B.10

REPORTED PLUS IMPUTED PARTICIPANTS WHO ARE SUBJECT TO THE TIME LIMIT

AND MEETING THE WORK REQUIREMENT

Education

and

State Total Working Workfare Training Other

U.S. Total 110,028 50,585 50,391 7,742 1,310

Alabama 1,006 453 553 0 0

Alaska 238 179 59 0 0

Arizona 3,677 3,474 203 0 0

Arkansas

California 36,308 12,203 22,249 1,856 0

Colorado 730 52 497 181 0

Connecticut 123 78 15 30 0

Delaware 134 132 2 0 0

District of Columbia

Florida 563 419 111 33 0

Georgia 963 766 172 25 0

Hawaii 248 243 0 5 0

Idaho 84 20 63 1 0

Illinois

Indiana 390 152 0 169 69

Iowa 407 407 0 0 0

Kansas 443 443 0 0 0

Kentucky 1,295 732 0 563 0

Louisiana 389 340 44 5 0

Maine 48 41 6 1 0

Maryland 6 6 0 0 0

Massachusetts 353 247 106 0 0

Michigan 3,467 1,513 0 737 1,217

Minnesota 946 683 25 238 0

Mississippi 1,160 149 997 0 14

Missouri 370 332 0 38 0

Montana 394 0 0 394 0

Nebraska 181 154 27 0 0

Nevada 64 35 3 24 2

New Hampshire 46 0 40 6 0

New Jersey 1,272 399 157 716 0

New Mexico 17 10 0 7 0

New York 23,848 1,548 21,500 800 0

North Carolina 1,659 1,593 38 28 0

North Dakota 162 160 0 2 0

Ohio 1,194 427 517 250 0

Oklahoma 163 163 0 0 0

Oregon 7,637 6,691 923 23 0

Pennsylvania 515 464 0 51 0

Rhode Island 61 61 0 0 0

South Carolina 1,143 0 142 1,001 0

South Dakota 179 124 51 4 0

Tennessee 2,037 1,690 281 66 0

Texas 8,676 8,198 457 21 0

Utah 273 102 57 114 0

Vermont 444 422 13 9 0

Virginia 4,358 4,305 34 19 0

Washington 897 118 769 10 0

W. Virginia 477 307 0 170 0

Wisconsin 721 302 280 131 8

Wyoming 262 248 0 14 0

SOURCE: Mathematica Policy Research, Inc., from FSPQC sample data for FY00 and Form FNS 583 data

 for March 2000.
APPENDIX C 

STATE POLICIES ON DEFINING WHO IS SUBJECT TO THE ABAWD TIME LIMIT
State

Age Policy Uniform 

Across State?

Age At Which 

Adults Are Exempt

Alabama Y 50

Alaska Y 50

Arizona Y 50

Arkansas Y 50

California Y 50

Colorado Y 50

Connecticut Y 51

Delaware Y 50

District of Columbia n.a. n.a.

Florida Y 50

Georgia Y 50

Hawaii Y 50

Idaho Y 51

Illinois Y 50

Indiana Y 50

Iowa Y 50

Kansas Y 45a

Kentucky Y 50

Louisiana Y 50

Maine Y 50

Maryland Y 47a

Massachusetts Y 51

Michigan Y 50

Minnesota Y 50

Mississippi Y 50

Missouri Y 50

Montana Y 50

Nebraska Y 50

Nevada Y 50

New Hampshire Y 51

New Jersey Y 50

New Mexico Y 50

New York Y 50

North Carolina Y 50

North Dakota Y 50

Ohio Y 50

Oklahoma Y 51

Oregon Y 50

Pennsylvania Y 47a

Rhode Island Y 50

South Carolina Y 50

South Dakota Y 50

Tennessee Y 50

Texas Y 50

Utah Y 50

Vermont Y 50

Virginia Y 50

Washington Y 50

West Virginia Y 48a

Wisconsin Y 50

Wyoming Y 50

SOURCE: State Food Stamp Program Director Survey .

n.a. = Not applicable.

a

 State uses 15 percent exemption to lower age limit.

TABLE C1

EXEMPTION FOR PEOPLE OVER 50
TABLE C2

CONDITIONS FOR CERTIFYING MENTAL OR PHYSICAL UNFITNESS FOR EMPLOYMENT

State

Exempt If 

Client Meets 

FSP Disability 

Definition?

Specific State 

Form for Health 

Professionals 

Required

Verbal 

Statement 

from Health 

Professional 

Sufficient

Client's SelfReport of 

Disability 

Sufficient

Caseworker's 

Direct 

Observation 

Sufficient

Alabama Y 9

Alaska Y 99 9

Arizona Y 9 9

Arkansas Y 9

California Y a a

Colorado Y 9

Connecticut Y

Delaware Y 99 9

District of Columbia n.a.

Florida Y 9

Georgia Y 9 9

Hawaii Y 99 9

Idaho Y 9

Illinois Y 99 9

Indiana Y 99 9

Iowa N

Kansas Y

Kentucky Y 9

Louisiana Y 9 99 9

Maine Y 9 9

Maryland Y 9

Massachusetts Y 9 9

Michigan N 9 9

Minnesota Y

Mississippi Y 9 9

Missouri Y

Montana Y 99 9

Nebraska Y 9 9

Nevada Y 9

New Hampshire N

New Jersey Y 9 9

New Mexico Y 9

New York Y a a

North Carolina Y 9 9

North Dakota Y 9

Ohio Y 9 9

Oklahoma Y 99 9

Oregon Y

Pennsylvania Y 9

Rhode Island Y

South Carolina Y 9 9

South Dakota Y 99 9

Tennessee Y 9

Texas Y 9 9

Utah Y

Vermont Y

Virginia Y 99 9

Washington Y 9 9

West Virginia Y 9

Wisconsin Y 99 9

Wyoming Y 9

SOURCE: State Food Stamp Program Director Survey.

n.a. = Not applicable.

a Policy varies by locality.
TABLE C3

DISABILITY BENEFITS USED TO DOCUMENT MENTAL OR PHYSICAL UNFITNESS FOR EMPLOYMENT

Receipt of 

Some Benefits

State

 Documents 

Disability? Always

Alabama Y 9

Alaska N

Arizona Y 9 9

Arkansas Y 9 99 9

California Y 9

Colorado Y 9 9 99 9

Connecticut Y 9 9 999

Delaware Y 9 9 999

District of Columbia n.a.

Florida Y 9 9

Georgia Y 9 999

Hawaii Y 9 9 99 9

Idaho Y 9 9 99 9

Illinois Y 9 9 999

Indiana Y 99 9

Iowa Y 9

Kansas Y 9 9 999

Kentucky Y 9 999

Louisiana Y 9 999

Maine Y 99 9

Maryland Y 9 9 999

Massachusetts Y 9 99

Michigan Y 9

Minnesota Y 9 9 999

Mississippi Y 9 99 9

Missouri Y 99 9

Montana Y 9 99 9

Nebraska Y 99 9

Nevada Y 9 999

New Hampshire Y 9 99 9

New Jersey Y 9

New Mexico Y 9 9 999

New York Y 9

North Carolina Y 9 9 999

North Dakota Y 9 999

Ohio Y 9 999

Oklahoma Y 9 99

Oregon Y 9 9 99 9

Pennsylvania Y 9 99 9

Rhode Island Y 9 99 9

South Carolina Y 9 9

South Dakota Y 9 9

Tennessee Y 9 999

Texas Y 9 99 9

Utah Y 9 9 99 9

Vermont Y 9 9 999

Virginia Y 9 9 999

Washington Y 9 9 99 9

West Virginia Y 9 99

Wisconsin Y 9 999

Wyoming Y 9 99 9

SOURCE: State Food Stamp Program Director Survey.

Workers 

Comp.

Private 

Disability

Depends 

on % 

Disability

Benefits Specified State-Wide

No Statewide 

Policy on 

Which 

Benefits

 State 

DisabilityBased 

Benefits

Veterans Benefits

Railroad 

Retirement 

Disability
TABLE C4

HEALTH PROFESSIONALS THAT CAN CERTIFY CLIENTS AS UNFIT FOR EMPLOYMENT

State

 Statewide 

Policy on 

Health Professionals?

Local Policy 

On Health 

Professionals?

Any 

Certified/ 

Licensed 

Professional M.D.

Licensed or 

Certified 

Psychologist

Licensed 

Therapist

Nurse 

Practitioner

Registered 

Nurse

Alabama N d.k.

Alaska Y 9 9 999

Arizona Y 9 9 999

Arkansas Y 9 9

California Y 9 9

Colorado Y 9 9 9 999

Connecticut Y 9 9 9 999

Delaware Y 9 9 999

District of Columbia n.a.

Florida Y 9 9

Georgia N N

Hawaii Y 9 9

Idaho Y 9 9 999

Illinois N N

Indiana Y 9 9

Iowa N N

Kansas Y 9 9 999

Kentucky Y 9 9 9 999

Louisiana N N

Maine Y 9 9 99

Maryland Y 9 9 999

Massachusetts Y 9 9 99

Michigan Y 9

Minnesota Y 9 9

Mississippi Y 9 9 9 999

Missouri N N

Montana Y 9 9 999

Nebraska N N

Nevada Y 9 9 999

New Hampshire N N

New Jersey Y 9 9

New Mexico Y 999

New York N Yb

North Carolina N d.k.

North Dakota Y 9 9

Ohio Y 9 9

Oklahoma Y 9 9 999

Oregon Y 9 9 9 999

Pennsylvania Y 9 9 9 999

Rhode Island N Ya 9 9 99

South Carolina N N

South Dakota Y 9 9 99

Tennessee N N

Texas Y 9 9

Utah N N

Vermont Y 999

Virginia Y 9 9 9 999

Washington Y 9 9 999

West Virginia Y 9 9

Wisconsin Y 9 9 999

Wyoming Y 9 9

SOURCE: State Food Stamp Program Director Survey.

d.k. = Respondent didn't know if localities have policies.

n.a. = Not applicable.

a

The policies shown are applicable in most localities.

b

 Local policies exist, but the state does not know if a policy is common in most localities.

Health Professional
State

Physican's 

Assistant

Drug/Alcohol

Treatment 

Program 

Professional

Practitioner of 

Alternative 

Medicine Otherc

Alabama

Alaska 999

Arizona 9 9 99

Arkansas

California

Colorado 999

Connecticut 999

Delaware 999

District of Columbia

Florida 9

Georgia

Hawaii

Idaho 999

Illinois

Indiana

Iowa

Kansas 999

Kentucky 999

Louisiana

Maine 9 9

Maryland 9 9 99

Massachusetts 9 99

Michigan 9

Minnesota 9 9

Mississippi 9 9

Missouri

Montana 999

Nebraska

Nevada 9 99

New Hampshire

New Jersey 9 9

New Mexico 9 9

New York

North Carolina

North Dakota 9 9

Ohio

Oklahoma 999

Oregon 999

Pennsylvania 999

Rhode Island 9

South Carolina

South Dakota 999

Tennessee

Texas 9

Utah

Vermont

Virginia 999

Washington 9 9

West Virginia 9

Wisconsin 999

Wyoming 9 9

SOURCE: State Food Stamp Program Director Survey.

d.k. = Respondent didn't know.

n.a. = Not applicable.

TABLE C4 (Continued)

HEALTH PROFESSIONALS THAT CAN CERTIFY CLIENTS AS UNFIT FOR 

EMPLOYMENT

c

 Other includes licensed social worker, midwife, master of mental health, unlicensed 

psychologist, and accupuncturist.
TABLE C5

REVIEW OF TEMPORARY DISABILITIES

Frequency of Review

State

Statewide 

Policy On 

Reviews?

 Local Policy 

On Reviews?

 No 

Exemption For 

Temporary 

Disabilities

Caseworker 

Discretion

As Indicated 

By Health 

Professional

Specific 

Number Of 

Months

At Recertification

Change in 

Circumstance

Alabama N d.k.

Alaska N N

Arizona Y 9

Arkansas Y 9 9

California N d.k.

Colorado Y 99 9

Connecticut Y 9 9

Delaware Y 9 9

District of Columbia n.a.

Florida Y 9(3)

Georgia Y 9(varies)

Hawaii Y 9 9

Idaho N N

Illinois Y 9

Indiana Y 9

Iowa N N

Kansas N N

Kentucky Y 9 9

Louisiana Y 9

Maine Y 99 9

Maryland Y 9 9

Massachusetts Y 9 9

Michigan Y 9 9

Minnesota Y 99 9

Mississippi Y 99 9

Missouri Y 9

Montana Y 9 9 (1) 9

Nebraska Y 9 9

Nevada Y 9 9

New Hampshire N N

New Jersey Y 9

New Mexico Y 9 9

New York N Ya

North Carolina Y 9 9

North Dakota Y 9

Ohio Y 9 9

Oklahoma Y 9 9

Oregon Y 9 9

Pennsylvania Y 9 9

Rhode Island Y 9

South Carolina Y 9 99(3) 9

South Dakota Y 9

Tennessee Y 9

Texas Y 9

Utah N N

Vermont Y 9

Virginia Y 9

Washington Y 9 9

West Virginia Y 9

Wisconsin Y 9 99

Wyoming Y 9 9

SOURCE: State Food Stamp Program Director Survey.

d.k. = Respondent didn't know if localities have policies.

n.a. = Not applicable.

a

 Local policies exist, but the state does not know if a policy is common in most localities.
Frequency of Review

State

Statewide 

Policy on 

Reviews?

Local Policy 

On 

Reviews? No Review

Caseworker 

Discretion

As Indicated 

by Health 

Professional

Specific 

Number of 

Months

At Recertification

Change in 

Circumstance

Alabama Y 9

Alaska Y 9 9

Arizona N N

Arkansas Y 9

California N Y

Colorado Y 9 9

Connecticut Y 9

Delaware N N

District of Columbia n.a

Florida N N

Georgia N N

Hawaii Y 9 9

Idaho Y 9

Illinois Y 9

Indiana N N

Iowa N N

Kansas N N

Kentucky Y 99 9

Louisiana Y 9

Maine N N

Maryland Y 9 9

Massachusetts Y 9 9

Michigan Y 9

Minnesota N N

Mississippi Y 9

Missouri Y 9

Montana Y 9 9

Nebraska Y 9

Nevada Y 9 9

New Hampshire N N

New Jersey Y 9

New Mexico Y 9 9

New York N Ya

North Carolina N N

North Dakota Y 9

Ohio Y 9

Oklahoma Y 9 9

Oregon Y 9

Pennsylvania Y 9

Rhode Island Y 9

South Carolina N N

South Dakota Y 9 9

Tennessee N N

Texas Y 9

Utah N N

Vermont Y 9

Virginia Y 9

Washington Y 9 9

West Virginia Y 9

Wisconsin Y 9

Wyoming Y 9

SOURCE: State Food Stamp Program Director Survey.

d.k. = Respondent didn't know.

n.a. = Not applicable.

a

 The state does not know if a policy is common in most localities.

TABLE C6

REVIEW OF PERMANENT DISABILITIES
TABLE C7

POLICY ON AGE OF DEPENDENT CHILDREN AND NUMBER OF ADULTS MADE EXEMPT

Number of Adults Exempted

State

Statewide 

Policy?

Age Individual 

Is No Longer a 

Dependent 

Child 

Only 

One 

Adult

 Up to Two 

Adults

All Adults That 

Meet The 

Criteria All Adults

Alabama Y 18 9

Alaska Y 6 9

Arizona Y 18 9

Arkansas Y 18 9

California Y 18 9

Colorado Y 18 9

Connecticut Y 18 9

Delaware Y 18 9

District of Columbia n.a. n.a.

Florida Y 18 9 c

Georgia Y 18 9

Hawaii Y 18 9

Idaho Y 18 9

Illinois Y 18 9

Indiana Y 18 9

Iowa Y 18 9

Kansas Y 18 9

Kentucky Y 18 9

Louisiana Y 18 9

Maine Y 18 9

Maryland Y 18 9

Massachusetts Y 18 9

Michigan Y 18 9

Minnesota Y 18 9

Mississippi Y 18 9

Missouri Y 18 9

Montana Y 17 9

Nebraska Na n.a. 9

Nevada Y 18 b 9

New Hampshire Y 18 9

New Jersey Y 18 9

New Mexico Y 18 9

New York Y 18 9

North Carolina Y 18 9

North Dakota Y 17 9

Ohio Y 18 9

Oklahoma Y 18 9

Oregon Y 18 9

Pennsylvania Y 17 9

Rhode Island Y 7 9

South Carolina Y 18 9

South Dakota Y 18 9

Tennessee Y 18 9

Texas Y 18 9

Utah Y 18 9

Vermont Y 18 9

Virginia Y 18 9

Washington Y 18 9

West Virginia Y 18 9

Wisconsin Y 18 9

Wyoming Y 18 9

SOURCE: State Food Stamp Director Survey.

n.a. = Not applicable.

b

Can be age 19 if in high school.

c

In Florida, two adults can be exempt if there is an incapacitated adult in the household.

a

Nebraska's policy on age is not set at the state level. However, the policy on which adults are exempt is 

set at the state level.
TABLE C8

EXEMPT ADULTS IN HOUSEHOLDS WITH DEPENDENT CHILDREN

Exempt Adults

State

Parent or 

Guardian Only

Demonstrate 

Care/ 

Responsibility

Chosen by 

Family Any

Alabama 9

Alaska 9

Arizona 9

Arkansas 9

California 9

Colorado 9

Connecticut 9

Delaware 9

District of Columbia

Florida 9

Georgia 9

Hawaii 9

Idaho 9

Illinois 9

Indiana 9

Iowa 9

Kansas 9

Kentucky 9

Louisiana 9

Maine 9

Maryland 9

Massachusetts 9

Michigan 9

Minnesota 9

Mississippi 9

Missouri 9

Montana 9

Nebraska 9

Nevada 9

New Hampshire 9

New Jersey 9

New Mexico 9

New York 9

North Carolina 9

North Dakota 9

Ohio 9

Oklahoma 9

Oregon 9

Pennsylvania 9

Rhode Island 9

South Carolina 9

South Dakota 9

Tennessee 9

Texas 9

Utah 9

Vermont 9

Virginia 9

Washington 9

West Virginia 9

Wisconsin 9

Wyoming 9

SOURCE: State Food Stamp Program Director Survey.
TABLE C9

WAIVERS IMPLEMENTED IN PREVIOUS 12 MONTHS

Reason for Not Implementing All Approved Waivers

State

Waivers In Effect 

During Previous 12 

Months

Some 

Approved 

Waivers Not 

Implemented

Economic 

Conditions 

Improved

County 

Refused

Political 

Reasons

County 

Partially 

Waived

Alabama Y

Alaska Y

Arizona Y

Arkansas Y

California Y

Colorado Y

Connecticut Y

Delaware N

District of Columbia Y

Florida Y

Georgia Y

Hawaii Y

Idaho Y

Illinois Y

Indiana Y

Iowa N

Kansas N

Kentucky Y

Louisiana Y

Maine Y

Maryland Y

Massachusetts N

Michigan N

Minnesota Y

Mississippi N

Missouri Y

Montana Y

Nebraska Y

Nevada Y

New Hampshire N

New Jersey Y

New Mexico Y

New York Y Y 99 9

North Carolina N

North Dakota Y

Ohio N

Oklahoma N

Oregon N

Pennsylvania Y

Rhode Island Y

South Carolina Y

South Dakota Y

Tennessee Y

Texas Y

Utah Y

Vermont Y

Virginia Y

Washington Y Y 9

West Virginia Y

Wisconsin N

Wyoming Y

SOURCE: State Food Stamp Program Director Survey.
TABLE C10

STATE USE OF THE 15 PERCENT EXEMPTION

State

15 Percent 

Exemption 

Used?

Year First 

Used

Future Plans 

to Use 15 

Percent 

Exemption?a

Alabama N Y

Alaska Y 1997 

Arizona Y 1999 

Arkansas Y 1998 

California Y 1997 

Colorado Y 1998 

Connecticut Y 1999 

Delaware N N

District of Columbia n.a. 

Florida Y 1997 

Georgia Y 1997 

Hawaii N Y

Idaho Y 1998 

Illinois Y 1998 

Indiana Y 1997 

Iowa Y 2000 

Kansas Y 1998 

Kentucky Y 1997 

Louisiana Y 1997 

Maine Y 1997 

Maryland Y 1998 

Massachusetts Y 1998 

Michigan N Y

Minnesota Y 1997 

Mississippi Y 1998 

Missouri Y 1999 

Montana N N

Nebraska Y 1997 

Nevada Y 1999 

New Hampshire Y 1997 

New Jersey Y 1999 

New Mexico N N

New York Y 1998 

North Carolina Y 1997 

North Dakota N N

Ohio N N

Oklahoma N N

Oregon Y 1998 

Pennsylvania Y 1999 

Rhode Island N Y

South Carolina Y 1998 

South Dakota N Y

Tennessee Y 1999 

Texas N N

Utah Y 1998 

Vermont Y 1998 

Virginia N N

Washington Y 1998

West Virginia Y 1998 

Wisconsin N Y

Wyoming N N

SOURCE: State Food Stamp Program Director Survey.

d.k. = Respondent didn't know.

n.a. = Not applicable.

a

Asked only of states not using the 15 percent exemption.
State

State Uses 15 

Percent 

Exemption

Preserve 

Benefits For 

As Many As 

Possible

Preserve 

Benefits For 

Specific 

Population

Reduce 

Administrative 

Burden

Exempt 

Balance Of 

PartiallyWaived AreaExempt Area 

Denied Waiver

Insufficient 

Jobs

Local Office 

Decision

Advocacy 

Group 

Pressure

Alabama N

Alaska Y 9 9

Arizona Y 9

Arkansas Y 9

California Y 9 9

Colorado Y 9

Connecticut Y 9

Delaware N

District of Columbia n.a.

Florida Y 9

Georgia Y 9

Hawaii N

Idaho Y 9

Illinois Y 9

Indiana Y 9

Iowa Y 9

Kansas Y 9

Kentucky Y 9

Louisiana Y 9

Maine Y 9

Maryland Y 9 9

Massachusetts Y 9

Michigan N

Minnesota Y 9

Mississippi Y 9

Missouri Y 9

Montana N

Nebraska Y 9 99

Nevada Y 9

New Hampshire Y 9 9

New Jersey Y 9

New Mexico N

New York Y 9 9

North Carolina Y 9

North Dakota N

Ohio N

Oklahoma N

Oregon Y 9

Pennsylvania Y 9

Rhode Island N

South Carolina Y 9

South Dakota N

Tennessee Y 9

Texas N

Utah Y 9

Vermont Y 9 9

Virginia N

Washington Y 9 9

West Virginia Y 9

Wisconsin N

Wyoming N

SOURCE: State Food Stamp Program Director Survey.

TABLE C11

REASONS FOR USING 15 PERCENT EXEMPTION

Reason
TABLE C12

REASONS FOR NOT USING THE 15 PERCENT EXEMPTION

Reasons For Not Using 15 Percent Exemption

State

Local Input in 

Decision Not to 

Use?

 Too Few 

Abawds

Sufficient 

Jobs

Sufficient 

Workfare/ 

E&T

Requires 

State 

Regulatory 

Process

Political 

Reasons

Too Difficult 

to Monitor

To Be 

Consistent 

with TANF Othera

Will Use 15 

Percent 

Exemption in 

Future

Alabama N 9 Y

Alaska 

Arizona 

Arkansas 

California 

Colorado 

Connecticut 

Delaware N 9 99 N

District of Columbia

Florida 

Georgia 

Hawaii N 9 Y

Idaho 

Illinois 

Indiana 

Iowa 

Kansas 

Kentucky 

Louisiana 

Maine 

Maryland 

Massachusetts 

Michigan N 9 Y

Minnesota 

Mississippi 

Missouri 

Montana Y 9 N

Nebraska 

Nevada 

New Hampshire 

New Jersey 

New Mexico N 9 9 N

New York 

North Carolina 

North Dakota N 9 N

Ohio N 9 N

Oklahoma N 9 N

Oregon 

Pennsylvania 

Rhode Island N 9 Y

South Carolina 

South Dakota N 9 Y

Tennessee 

Texas N 9 N

Utah 

Vermont 

Virginia N 9 9 N

Washington

West Virginia 

Wisconsin N 99 9 Y

Wyoming N 9 N

SOURCE: State Food Stamp Program Director Survey.

a

Other includes states unclear how to implement 15 percent exemption, states who did not implement in time, and states that did not know the reason.
Reason Not Used in All Counties Without Waivers

State

Used In All 

Counties 

Without 

Waivers?

Used In Most 

Counties 

Without 

Waivers? Sufficient Jobs

Sufficient 

Workfare/ E&T Build Reserve

Some Counties 

Did Not Meet 

Criteria For Use

Unclear 

How To 

Implement

Alabama n.a. 

Alaska Y 

Arizona Y 

Arkansas Y 

California N 99 9

Colorado Y

Connecticut N 9

Delaware n.a.

District of Columbia n.a.

Florida N 9

Georgia Y 

Hawaii n.a. 

Idaho Y 

Illinois Y 

Indiana Y 

Iowa N 9 9

Kansas Y 

Kentucky N 9

Louisiana N 9

Maine Y 

Maryland Y 

Massachusetts Y 

Michigan n.a. 

Minnesota Y 

Mississippi Y 

Missouri Y 

Montana n.a. 

Nebraska N 9 9

Nevada Y

New Hampshire N 9 9

New Jersey N 9

New Mexico n.a.

New York N

North Carolina N 9

North Dakota n.a.

Ohio n.a.

Oklahoma N

Oregon Y 

Pennsylvania Y 

Rhode Island n.a. 

South Carolina Y 

South Dakota n.a. 

Tennessee Y 

Texas n.a. 

Utah Y 

Vermont Y 

Virginia n.a. 

Washington Y 

West Virginia Y 

Wisconsin n.a. 

Wyoming n.a. 

SOURCE: State Food Stamp Program Director Survey.

n.a. = Not applicable -- state does not use 15 percent exemption.

TABLE C13

USE OF 15 PERCENT EXEMPTION IN COUNTIES WITH AND WITHOUT WAIVERS
TABLE C14

CRITERIA FOR DETERMINING 15 PERCENT EXEMPTION

State

State Uses 15 

Percent 

Exemption

Based On 

Geographic 

Characteristics

Based On 

Individual 

Characteristics

Extend Time 

Limit To All

Indefinitely 

Exempt All

Alabama N

Alaska Y 9 9

Arizona Y 9 9

Arkansas Y 9

California Ya

Colorado Y 9 9

Connecticut Y 9

Delaware N

District of Columbia n.a.

Florida Y 9

Georgia Y 9

Hawaii N

Idaho Y 9

Illinois Y 9

Indiana Y 9

Iowa Y 9

Kansas Y 9

Kentucky Y 9

Louisiana Y 9

Maine Y 9

Maryland Y 9 9

Massachusetts Y 9

Michigan N

Minnesota Y 9

Mississippi Y 9

Missouri Y 9

Montana N

Nebraska Y 9

Nevada Y 9

New Hampshire Y 9

New Jersey Y 9

New Mexico N

New York Ya

North Carolina Y 9

North Dakota N

Ohio N

Oklahoma N

Oregon Y 9

Pennsylvania Y 9

Rhode Island N

South Carolina Y 9

South Dakota N

Tennessee Y 9

Texas N

Utah Ya

Vermont Y 9 9

Virginia N

Washington Y 9 9

West Virginia Y 9

Wisconsin N

Wyoming N

SOURCE: State Food Stamp Program Director Survey.

n.a. = Not applicable.

a 15 percent exemption policy varies by locality.
State

Exemption Based 

On Geographic 

Area

Unsuccessful 

In Obtaining 

Waiver

Poor Labor 

Market/ 

Economy

Balance Of 

Waived County

Poor 

TransportationLittle Or 

No E&T

Area Has 

Few 

ABAWDS

Alabama n.a.

Alaska Y 9 9

Arizona Y 9 9

Arkansas N

California a

Colorado Y 9

Connecticut Y 9

Delaware n.a.

District of Columbia n.a.

Florida Y 9

Georgia N

Hawaii n.a.

Idaho N

Illinois N

Indiana N

Iowa Y 9

Kansas N

Kentucky Y 9

Louisiana Y 9

Maine N

Maryland Y 9 9

Massachusetts N

Michigan n.a.

Minnesota N

Mississippi N

Missouri N

Montana n.a.

Nebraska Y 9

Nevada N

New Hampshire Y 9

New Jersey Y 9

New Mexico n.a.

New York a

North Carolina Y 9 9

North Dakota n.a.

Ohio n.a.

Oklahoma n.a.

Oregon N

Pennsylvania N

Rhode Island n.a.

South Carolina Y 9 9

South Dakota n.a.

Tennessee N

Texas n.a.

Utah N

Vermont Y 9 99

Virginia n.a.

Washington Y 9 9

West Virginia N

Wisconsin n.a.

Wyoming n.a.

SOURCE: State Food Stamp Program Director Survey.

n.a. = Not applicable -- state does not use 15 percent exemption.

a 15 percent exemption policy varies by locality.

TABLE C15

15 PERCENT EXEMPTION POLICIES BASED ON GEOGRAPHIC AREA

Characteristics of Geographic Areas Used for 15 Percent Exemption
TABLE C16

15 PERCENT EXEMPTION POLICIES BASED ON INDIVIDUAL CHARACTERISTICS

State

Exemption Based 

on Individual 

Characteristics

Deemed 

Unemployable

Over 

Specific 

Age

Undocumented 

Health 

Problems Homeless

Inadequate Work 

History

Alabama n.a.

Alaska Y 9

Arizona Y

Arkansas N

California a

Colorado Y 9 9

Connecticut N

District of Columbia n.a.

Delaware n.a.

Florida N

Georgia Y 9 9

Hawaii n.a.

Idaho Y

Illinois N

Indiana Y

Iowa N

Kansas Y 9

Kentucky N

Louisiana N

Maine Y 9

Maryland Y 9

Massachusetts Y 9

Michigan n.a.

Minnesota Y

Mississippi Y

Missouri N

Montana n.a.

Nebraska N

Nevada Y 9

New Hampshire N

New Jersey N

New Mexico n.a.

New York a

North Carolina N

North Dakota n.a.

Ohio n.a.

Oklahoma n.a.

Oregon Y 9 99 9

Pennsylvania Y 9

Rhode Island n.a.

South Carolina N

South Dakota n.a.

Tennessee N

Texas n.a.

Utah Ya

Vermont Y 9

Virginia n.a.

Washington Y 9

West Virginia Y 9

Wisconsin n.a.

Wyoming n.a.

SOURCE: State Food Stamp Program Director Survey.

n.a. = Not applicable -- state does not use 15 percent exemption.

a 15 percent exemption policy varies by locality.

Individual Characteristics Used for 15 Percent Exemption
TABLE C17

15 PERCENT EXEMPTION POLICIES BASED ON INDIVIDUAL CHARACTERISTICS

Individual Characteristics Used for 15 Percent Exemption

State

Inadequate 

Education 

Level

Inadequate 

TransportationWaiting For 

E&T Slot

In ESL/GED And 

Not Meeting Work 

Requirement Otherb

Alabama

Alaska

Arizona 9

Arkansas

California

Colorado 9

Connecticut

District of Columbia

Delaware

Florida

Georgia

Hawaii

Idaho 9

Illinois

Indiana 9

Iowa

Kansas

Kentucky

Louisiana

Maine 99 9

Maryland

Massachusetts 9

Michigan

Minnesota 9

Mississippi 9

Missouri

Montana

Nebraska

Nevada 9

New Hampshire

New Jersey

New Mexico

New York

North Carolina

North Dakota

Ohio

Oklahoma

Oregon 9 9

Pennsylvania

Rhode Island

South Carolina

South Dakota

Tennessee

Texas

Utah

Vermont 9 9

Virginia

Washington 9

West Virginia

Wisconsin

Wyoming

SOURCE: State Food Stamp Program Director Survey.

b

 Other includes: Violent client, limited language, GA recipients, employed by closed mine, or 

recently released from mental institution.
TABLE C18

LENGTH OF 15 PERCENT EXEMPTION 

Length of Exemption 

State

As Long As 

Criteria Are Met 

(No Limit)

Specified 

Time Limit 

for All

Caseworker 

Discretion

Varies By 

Client 

Alabama

Alaska 9

Arizona 9

Arkansas 9

California a

Colorado 9

Connecticut 9

Delaware

District of Columbia

Florida 9

Georgia 9

Hawaii

Idaho

Illinois 9

Indiana 9

Iowa 9

Kansas 9

Kentucky 9

Louisiana 9

Maine 9

Maryland 9

Massachusetts 9

Michigan

Minnesota 9

Mississippi 9 (6months)

Missouri 9 (2months)

Montana

Nebraska 9

Nevada 9

New Hampshire 9

New Jersey 9

New Mexico

New York 9

North Carolina 9

North Dakota

Ohio

Oklahoma

Oregon 9 9

Pennsylvania 9

Rhode Island

South Carolina 9

South Dakota

Tennessee 9 (2months)

Texas

Utah 9

Vermont 9

Virginia

Washington 9

West Virginia 9

Wisconsin

Wyoming

SOURCE: State Food Stamp Program Director Survey.

a 15 percent exemption policy varies by locality.
State

Plan To Change 

Policy Next 

Year? Expected Change

Alabama n.a.

Alaska N

Arizona N

Arkansas N

California N

Colorado N

Connecticut Y Cover as many non-waived counties as possible

Delaware n.a.

District of Columbia n.a.

Florida N

Georgia Y Broaden criteria

Hawaii n.a.

Idaho N

Illinois N

Indiana Y Provide more months

Iowa N

Kansas N

Kentucky N

Louisiana N

Maine N

Maryland N

Massachusetts N

Michigan n.a.

Minnesota N

Mississippi N

Missouri N

Montana n.a.

Nebraska N

Nevada N

New Hampshire N

New Jersey N

New Mexico n.a.

New York N

North Carolina N

North Dakota n.a.

Ohio n.a.

Oklahoma n.a.

Oregon Y Cover non-waived counties

Pennsylvania Y Add individual characteristics

Rhode Island n.a.

South Carolina N

South Dakota n.a.

Tennessee N

Texas n.a.

Utah N

Vermont N

Virginia n.a.

Washington N

West Virginia N

Wisconsin n.a.

Wyoming n.a.

SOURCE: State Food Stamp Program Director Survey.

n.a. = Not applicable -- state does not use 15 percent exemption.

TABLE C19

PLANS FOR CHANGING EXISTING 15 PERCENT EXEMPTION POLICIES
TABLE C20

ALLOTMENTS AND USE OF 15 PERCENT EXEMPTION, FY99

State

Allotment Plus 

Carryover from FY98 Exemptions Used

Exemptions Used as 

Percent of Allotment 

Plus Carryover

Alabama 1,633 3,283 0 0.0

Alaska 117 295 17 5.7

Arizona 750 1,594 74 4.7

Arkansas 757 1,440 276 19.2

California 11,560 15,087 392 2.6

Colorado 455 926 42 4.5

Connecticut 533 1,050 83 7.9

Delaware 145 301 0 0.0

District of Columbia 0 0 0 0.0

Florida 2,245 4,684 407 8.7

Georgia 2,147 4,373 105 2.4

Hawaii 437 856 29 3.4

Idaho 252 505 11 2.2

Illinois 2,925 4,828 1992 41.3

Indiana 1,124 2,255 10 0.5

Iowa 456 931 0 0.0

Kansas 363 627 304 48.5

Kentucky 1,213 1,190 566 47.5

Louisiana 966 1,121 1180 105.3

Maine 431 841 20 2.4

Maryland 523 939 280 29.8

Massachusetts 1,057 2,056 527 25.6

Michigan 6,276 12,544 0 0.0

Minnesota 750 1,413 518 36.7

Mississippi 1,718 3,611 568 15.7

Missouri 1,517 3,249 18 0.6

Montana 235 465 0 0.0

Nebraska 334 589 120 20.3

Nevada 388 802 33 4.1

New Hampshire 60 119 19 15.8

New Jersey 823 1,679 0 0.0

New Mexico 339 718 0 0.0

New York 2,881 5,954 67 1.1

North Carolina 2,318 4,001 968 24.2

North Dakota 136 276 0 0.0

Ohio 3,126 6,522 0 0.0

Oklahoma 1,433 2,774 0 0.0

Oregon 1,578 2,842 91 3.2

Pennsylvania 1,767 3,562 0 0.0

Rhode Island 103 209 0 0.0

South Carolina 659 1,277 84 6.5

South Dakota 104 204 0 0.0

Tennessee 3,046 5,817 22 0.4

Texas 4,819 10,061 0 0.0

Utah 230 458 96 20.9

Vermont 311 619 14 2.3

Virginia 2,035 4,265 0 0.0

Washington 783 1,650 396 24.0

West Virginia 412 809 22 2.7

Wisconsin 671 1,415 0 0.0

Wyoming 149 307 0 0.0

SOURCE: FNS Form 583 and FNS' website.

Allotment
TABLE C21

STATE PLANS TO USE 15 PERCENT EXEMPTION IN FY00

Reason For Using Less Than Allotment

State

Plans to Use 

Less Than Total 

Allotment

Sufficient 

Jobs

Sufficient 

E&T

Not 

Enough 

ABAWDs

Sufficient 

Carryover

Difficulty 

Choosing

Criteria

Reserve for 

Economic 

Downturn Othera

Alabama

Alaska 9b

Arizona

Arkansas

California 9 9

Colorado 99 9

Connecticut

Delaware

District of Columbia

Florida

Georgia

Hawaii

Idaho 9 99

Illinois

Indiana

Iowa

Kansas

Kentucky

Louisiana

Maine

Maryland

Massachusetts 9 9

Michigan

Minnesota 9 999

Mississippi 9 9

Missouri 9 9

Montana

Nebraska

Nevada 9 9

New Hampshire 9 9

New Jersey

New Mexico

New York 9 9

North Carolina

North Dakota

Ohio

Oklahoma

Oregon 99 9

Pennsylvania 9 9

Rhode Island

South Carolina

South Dakota

Tennessee 9 9

Texas

Utah 9 9

Vermont 9 9

Virginia

Washington 9 9

West Virginia

Wisconsin

Wyoming

SOURCE: State Food Stamp Program Director Survey.

a

 Other includes states with localities that choose not to use exemptions and states with recently introduced exemptions.

b Respondent did not know why the state planned to use less than its allotment
TABLE C22

EXEMPTIONS USED IN 1999 RELATIVE TO NUMBER PLANNED

Reason Used More/Fewer Than Planned

State

 Number Of 

Exemptions Used 

Relative To Number 

Planned

More/Fewer 

Counties Used 

Exemptions

Criteria Led To 

More/Fewer Than 

Expected

More/Fewer 

ABAWDs Qalified for 

Exemptions

Alabama n.a.

Alaska same

Arizona fewer 9

Arkansas same

California fewer 9

Colorado same

Connecticut same

Delaware n.a.

District of Columbia n.a.

Florida same

Georgia fewer 9

Hawaii n.a.

Idaho fewer 9

Illinois fewer 9

Indiana same

Iowa n.a.

Kansas same

Kentucky same

Louisiana more 9

Maine fewer 9

Maryland same

Massachusetts same

Michigan n.a.

Minnesota same

Mississippi fewer 9

Missouri same

Montana n.a.

Nebraska same

Nevada fewer 9

New Hampshire same

New Jersey fewer 9

New Mexico n.a.

New York more 9

North Carolina same

North Dakota n.a.

Ohio n.a.

Oklahoma n.a.

Oregon same

Pennsylvania fewer 9

Rhode Island n.a.

South Carolina same

South Dakota n.a.

Tennessee n.a.

Texas n.a.

Utah fewer 9

Vermont same

Virginia n.a.

Washington fewer 9

West Virginia same

Wisconsin n.a.

Wyoming n.a.

SOURCE: State Food Stamp Program Director Survey.

n.a. = Not applicable.
State

Disability 

Certification 

Policya

Dependent 

Children Policyb Waiver Usec

15 Percent 

Exemption Used

Aggregate 

Policy Measure

Alabama 11103

Alaska 20215

Arizona 21115

Arkansas 02226

California 12014

Colorado 12115

Connecticut 02215

Delaware 21003

Florida 10214

Georgia 21216

Hawaii 22116

Idaho 11013

Illinois 22228

Indiana 11114

Iowa 02002

Kansas 01023

Kentucky 11226

Louisiana 21227

Maine 21216

Maryland 11226

Massachusetts 12025

Michigan 22004

Minnesota 01124

Mississippi 11024

Missouri 02114

Montana 21205

Nebraska 12126

Nevada 01113

New Hampshire 01023

New Jersey 22206

New Mexico 12205

New York 10113

North Carolina 21025

North Dakota 12104

Ohio 11002

Oklahoma 22004

Oregon 01012

Pennsylvania 00202

Rhode Island 00202

South Carolina 11114

South Dakota 22206

Tennessee 11114

Texas 21104

Utah 02125

Vermont 02114

Virginia 12104

Washington 11226

West Virginia 12216

Wisconsin 22004

Wyoming 11103

SOURCE: State Food Stamp Program Director Survey.

n.a. = Not applicable.

c

Equals 2 if percent of adults in waived areas is above median, 1 if state uses waiver but percent of adults 

in waived areas is below the median, 0 if no waivers.

d

Equals 2 if state uses more than 10 percent of allotment, 1 if staet uses less than 10 percent of the 

allotment, 0 if state doesn't use 15 percent exemption.

STATE ABAWD POLICY RANKINGS

TABLE C23

a

Equals 2 if client self report, 1 if caseworker observation or if policy varies by county, 0 otherwise.

b

Equals 2 if all adults exempt, 1 if multiple adults but not all exempt, 0 if 1 adult exempt or children defined 

as under 17
APPENDIX D 

STATE POLICIES ON MEETING THE WORK EQUIREMENT AND THE PROVISION OF 

QUALIFYING WORK ACTIVITIES
State

Statewide 

Policy? Local Policy? Always

If Paid InKindIf Community 

Service

At Caseworker 

Discretion

Alabama Y 9 9

Alaska Y 9

Arizona Y 9

Arkansas Y 

California Y 

Colorado Y 

Connecticut Y 9

Delaware Y 9

District of Columbia n.a. 

Florida Y 

Georgia N N

Hawaii N N

Idaho Y 

Illinois Y 9

Indiana Y 

Iowa Y 9

Kansas Y 

Kentucky Y 9

Louisiana Y 9

Maine Y 9

Maryland Y 9

Massachusetts Y 9

Michigan Y 9

Minnesota Y 9

Mississippi Y 9

Missouri N N

Montana Y 9

Nebraska N N

Nevada Y 9

New Hampshire N N

New Jersey Y 

New Mexico Y 

New York N N

North Carolina Y 9

North Dakota Y 9

Ohio Y 9

Oklahoma Y 

Oregon Y 9

Pennsylvania Y 9

Rhode Island Y 

South Carolina Y 9

South Dakota Y 

Tennessee Y 9

Texas Y 9

Utah Y 

Vermont Y 

Virginia Y 9

Washington Y 

West Virginia Y 

Wisconsin Y 9

Wyoming Y 9

SOURCE: State Food Stamp Program Director Survey.

n.a. = Not applicable.

TABLE D1

POLICIES ON WORKING WITHOUT PAY, 2000

 Meets Work Requirement
COMBINING WORK AND QUALIFYING WORK ACTIVITIES, 2000

If Combined for 20 or More Hours

Meets Work Requirement

State

Statewide 

Policy? Local Policy? Always

When Not Enough 

Jobs/Training 

Available

If They Combine 

30 Hours or More

Alabama Y 9

Alaska N N

Arizona Y 9

Arkansas N N

California Y 9

Colorado Y 9

Connecticut Y 9

Delaware Y 9

District of Columbia n.a.

Florida Y 9

Georgia Y 9

Hawaii Y 9

Idaho Y 9

Illinois Y 9

Indiana Y 9

Iowa Y

Kansas Y

Kentucky Y 9

Louisiana Y 9

Maine Y 9

Maryland Y 9

Massachusetts Y 9

Michigan Y 9

Minnesota Y 9

Mississippi Y

Missouri Y 9

Montana Y 9

Nebraska Y

Nevada Y 9

New Hampshire Y 9

New Jersey Y 9

New Mexico Y 9

New York Y 9

North Carolina Y 9

North Dakota Y 9

Ohio Y 9

Oklahoma Y

Oregon Y 9

Pennsylvania Y 9

Rhode Island N N

South Carolina Y 9

South Dakota Y 9

Tennessee Y 9

Texas Y 9

Utah N N

Vermont N N

Virginia Y 9

Washington Y 9

West Virginia Y

Wisconsin Y 9

Wyoming Y

SOURCE: State Food Stamp Program Director Survey.

n.a. = Not applicable.

TABLE D2
State Job Search Required Job Search Training Offered

Alabama 9

Alaska 9 9

Arizona 9 9

Arkansas

California 9 9

Colorado

Connecticut 9 9

Delaware 9

District of Columbia 9

Florida 9 9

Georgia

Hawaii 9 9

Idaho 9 9

Illinois 9 9

Indiana 9 9

Iowa 9 9

Kansas

Kentucky 9

Louisiana 9

Maine 9

Maryland 9 9

Massachusetts

Michigan 9

Minnesota 9 9

Mississippi 9 9

Missouri

Montana

Nebraska 9 9

Nevada 9 9

New Hampshire 9 9

New Jersey 9 9

New Mexico

New York 9 9

North Carolina 9 9

North Dakota 9

Ohio

Oklahoma

Oregon 9 9

Pennsylvania 9

Rhode Island 9

South Carolina 9 9

South Dakota 9 9

Tennessee 9 9

Texas 9 9

Utah 9 9

Vermont 9 9

Virginia

Washington 9 9

West Virginia 9 9

Wisconsin 9 9

Wyoming 9 9

SOURCE: State E&T Managers Survey.

TABLE D3

JOB SEARCH REQUIRED OF ABAWDS AND JOB SEARCH TRAINING 

OFFERED TO ABAWDS, FY99
State Minimum Number of Contacts Required

Alabama Y 20 / 2 weeks No requirement 9

Alaska Y 20 / 2 months No requirement 9

Arizona Y 12 / week 30 hours / week 9

Arkansas n.a.a n.a.b

California N d.k.

Colorado n.a.a n.a.b

Connecticut N 9

Delaware Y 24 / month No requirement 9 9

District of Columbia Y 48/month No requirement 9

Florida Y 12 / month No requirement 9 9

Georgia n.a.a n.a.b

Hawaii Y No requirement 16 hours / month 9 9

Idaho Y No requirement 24 hours / 2 months 9

Illinois Y 20 / month 12 hours / month 9

Indiana Y 10 / week No requirement 9 9

Iowa Y No requirement No requirement 9 9

Kansas n.a.a n.a.b

Kentucky Y 12 / month No requirement 9

Louisiana n.a.a n.a.b

Maine n.a.a n.a.b

Maryland N

Massachusetts n.a.a n.a.b

Michigan n.a.a n.a.b

Minnesota Y 15 / week No requirement 9 9

Mississippi N

Missouri n.a.a n.a.b

Montana n.a.a n.a.b

Nebraska Y No requirement 8 hours / day 9

Nevada Y 10 / 2 weeks No requirement 9

New Hampshire Y 6 / week No requirement 9 9

New Jersey Y No requirement 30 hours / week 9

New Mexico n.a.a n.a.b

New York N 9

North Carolina Y 3 / weekb No requirement 9 9

North Dakota n.a.a n.a.b

Ohio n.a.a n.a.b

Oklahoma n.a.a n.a.b

Oregon Y No requirement 5 hours / week 9

Pennsylvania n.a.a n.a.b

Rhode Island Y 24 / 2 months No requirement 9

South Carolina N 9

South Dakota N 9

Tennessee Y 12 / month 12 hours / month 9

Texas Y 12 / month No requirement 9

Utah Y No requirement No requirement 9

Vermont Y 12 / week 20 hours / week 9 9

Virginia n.a.a n.a.b

Washington Y 5 / week 40 hours / month 9

West Virginia Y 18/week in urban areas and 12 / month in rural areas No requirement 9

Wisconsin Y No requirement 12 hours / month c 9

Wyoming Y No requirement 30 hours / week 9

SOURCE: State E&T Managers Survey.

n.a. = Not applicable.

a

 State does not offer job search to ABAWDs. b

 In North Carolina, policy varies by county. It can be two contacts per week in higher unemployment areas. c

 In Wisconsin, it is recommended, but not required.

d

 Includes one-on-one counseling every two weeks or participation in job club.

TABLE D4

JOB SEARCH REQUIREMENTS, FY99

Requiring Clients 

to Document Job 

Contacts Made

Statewide 

Policy?

Minimum Number of Hours 

Required

Other 

Requirement d
State

After Referral To 

E&T 

Alabama Y 9

Alaska Y 9

Arizona Y 9

Arkansas n.a.a

California N

Colorado n.a.a

Connecticut N

Delaware Y 9

District of Columbia Y 9

Florida Y 9

Georgia n.a.a

Hawaii Y 9

Idaho Y 9

Illinois Y 9

Indiana Y 9b

Iowa Y 9c

Kansas n.a.a

Kentucky Y 9

Louisiana n.a.a

Maine n.a.a

Maryland N

Massachusetts n.a.a

Michigan n.a.a

Minnesota Y 9

Mississippi N

Missouri n.a.a

Montana n.a.a

Nebraska Y 9

Nevada Y 9

New Hampshire Y 9

New Jersey Y 9

New Mexico n.a.a

New York N

North Carolina Y 9

North Dakota n.a.a

Ohio n.a.a

Oklahoma n.a.a

Oregon Y 9

Pennsylvania n.a.a

Rhode Island Y 9

South Carolina N

South Dakota N

Tennessee Y 9

Texas Y 9

Utah Y 9

Vermont Y 9

Virginia n.a.a

Washington Y 9

West Virginia Y 9

Wisconsin Y 9

Wyoming Y 9

SOURCE: State E&T Managers Survey.

a

 State does not offer job search to ABAWDs.

c

 In Iowa, job search is required after job club or job search training.

b

 In Indiana, ABAWDs are only in job search if they are already completing 20 hours/week in a qualified work 

activity or if they are in Community Work Experience.

TABLE D5

POLICY ON WHEN ABAWDs ARE REQUIRED TO CONDUCT JOB SEARCH, FY99

Policy

Statewide 

Policy?

When First 

Applying For Food 

Stamps

 

After Eligibilty

Determination

While Or After 

Completing Another 

E&T Component
State

Alabama Y 9

Alaska Y 9

Arizona Y 9

Arkansas n.a.a

California N

Colorado n.a.a

Connecticut N

Delaware Y 9

District of Columbia Yb

Florida Y 9

Georgia n.a.a

Hawaii Y 9

Idaho Y 9

Illinois Y 9

Indiana Y 9

Iowa Y 9

Kansas n.a.a

Kentucky Y 9

Louisiana n.a.a

Maine n.a.a

Maryland N

Massachusetts n.a.a

Michigan n.a.a

Minnesota Y 9

Mississippi N

Missouri n.a.a

Montana n.a.a

Nebraska Y 9

Nevada Y 9

New Hampshire Y 9

New Jersey Y 9

New Mexico n.a.a

New York N

North Carolina Y 9

North Dakota n.a.a

Ohio n.a.a

Oklahoma n.a.a

Oregon Y 9

Pennsylvania n.a.a

Rhode Island Y 9

South Carolina N

South Dakota N

Tennessee Y 9

Texas Y 9

Utah Y 9

Vermont Y 9

Virginia n.a.a

Washington Y 9

West Virginia Y 9

Wisconsin Y 9

Wyoming Y 9

SOURCE: State E&T Managers Survey.

n.a. = Not applicable.

a

 State does not offer job search to ABAWDs. b

 In the District of Columbia, job search takes place between two and three months.

TABLE D6

LENGTH OF JOB SEARCH REQUIRED OF ABAWDs, FY99

Length of Job Search

Until They Find a Job/Until 

They Begin Another E&T 

Component

Statewide 

Policy?

One Month Or 

Less

Between One and 

Two Months
State

Alabama 9 9 9

Alaska 9 9

Arizona 9 9 9

Arkansas

California d.k. d.k. d.k.

Colorado

Connecticut 9 9 9

Delaware

District of Columbia 9 9 9

Florida 9 9 9

Georgia

Hawaii 9 9 9

Idaho 9 9 9

Illinois 9 9 9

Indiana 9 9

Iowa 9 9 9

Kansas

Kentucky 9

Louisiana

Maine

Marylanda

Massachusetts

Michigan

Minnesota 9 9 9

Mississippi 9 9 9

Missouri

Montana

Nebraska 9 9

Nevada 9 9 9

New Hampshire 9 9 9

New Jersey 9 9 9

New Mexico

New York 9 9 9

North Carolina 9 9 9

North Dakota

Ohio

Oklahoma

Oregon 9 9 9

Pennsylvania

Rhode Island

South Carolina

South Dakota 9 9 9

Tennessee 9 9 9

Texas 9 9 9

Utah 9 9 9

Vermont 9 9 9

Virginia

Washington 9 9 9

West Virginia 9

Wisconsin 9 9 9

Wyoming 9 9 9

SOURCE: State E&T Managers Survey.

d.k. = Respondent didn't know.

a

 In Maryland, the nature of the job search component is decided by the local 

 Access to Word 

Processors or 

Typewriters

TABLE D7

 Access to 

Telephones to 

Contact Employers

ASSISTANCE OFFERED IN JOB SEARCH, FY99

 Names of 

Potential 

Employers
State

 

In All Areas

Only In Some 

Areas

 

In All Areas

Only In Some 

Areas

Alabama N N

Alaska Y Y 9a

Arizona Y Y 9 9

Arkansas Y N

California Y Y 9

Colorado Y N

Connecticut Y Y 9 9

Delaware N N

District of Columbia Y N

Florida Y Y 9 9

Georgia N N

Hawaii Y Y 9 9

Idaho Y Y 9 9

Illinois Y Y 9

Indiana Y Y 9 9

Iowa Y Y 9

Kansas Y N

Kentucky N N

Louisiana Y Y 9 9

Maine Y Y 9

Maryland Y Y 9 9

Massachusetts Y N

Michigan Y Y 9

Minnesota Y Y 9 9

Mississippi Y Y 9

Missouri Y N

Montana Y N

Nebraska Y Y 9

Nevada Y Y 9

New Hampshire Y Y 9

New Jersey Y Y 9 9

New Mexico Y N

New York Y Y 9 9

North Carolina Y Y 9

North Dakota Y Y 9

Ohio Y N

Oklahoma N N

Oregon Y Y 9

Pennsylvania Y Y 9 9

Rhode Island N N

South Carolina Y Y 9 9

South Dakota Y Y 9 9

Tennessee Y Y 9 9

Texas Y Y 9 9

Utah Y Y 9 9

Vermont Y Y 9

Virginia Y N

Washington Y Y 9

West Virginia Y Y 9 9

Wisconsin Y Y 9

Wyoming Y Y 9

SOURCE: State E&T Managers Survey.

a

 Depends on the season. Waivers are seasonal.

TABLE D8

EXTENT TO WHICH ABAWDS ARE REQUIRED TO CONDUCT JOB SEARCH TRAINING, FY99

Is Job Search Training Offered 

In Any Areas That Are Not 

Waived From The ABAWD 

Provisions?

Is Job Search Training Offered 

In Any Areas That Are Waived 

From The ABAWD Provisions?

Is Job Search Training

Required Of At Least 

Some Food Stamp E&T 

Mandatory Participants?

Is Job Search Training

Required Of At Least 

Some ABAWDS?
State Soft Skills Other

d

Alabama n.a.

a n.a.a n.a.a n.a.a n.a.a n.a.a

Alaska 9 9 9 9 99

Arizona 9 9 9 9 99

Arkansas n.a.

a n.a.a n.a.a n.a.a n.a.a n.a.a

Californiab

Colorado n.a.

a n.a.a n.a.a n.a.a n.a.a n.a.a

Connecticut 99 9 9

Delaware n.a.

a n.a.a n.a.a n.a.a n.a.a n.a.a

District of Columbia n.a.

a n.a.a n.a.a n.a.a n.a.a n.a.a

Florida 9 9 9 99

Georgia n.a.

a n.a.a n.a.a n.a.a n.a.a n.a.a

Hawaii 9 9 9 99

Idaho 9 9 9 9 99

Illinois 99 9 9 9

Indiana 9 9 9 99

Iowa 9 9 d.k. d.k. d.k. 9

Kansas n.a.

a n.a.a n.a.a n.a.a n.a.a n.a.a

Kentucky n.a.

a n.a.a n.a.a n.a.a n.a.a n.a.a

Louisiana 9 9 9 9 99

Maine 9 d.k. d.k. d.k. d.k. 9

Maryland 99 9 9 9

Massachusetts n.a.

a n.a.a n.a.a n.a.a n.a.a n.a.a

Michiganc 9

Minnesota 9 9 9 99

Mississippi 9 9 9 9 99

Missouri n.a.

a n.a.a n.a.a n.a.a n.a.a n.a.a

Montana n.a.

a n.a.a n.a.a n.a.a n.a.a n.a.a

Nebraska 99 9 9 9

Nevada 9 9 9 99

New Hampshire 99 9 9

New Jersey 9 9 9 9 99

New Mexico n.a.

a n.a.a n.a.a n.a.a n.a.a n.a.a

New Yorkb

North Carolinab

North Dakota 9 9 9 99

Ohio n.a.

a n.a.a n.a.a n.a.a n.a.a n.a.a

Oklahoma n.a.

a n.a.a n.a.a n.a.a n.a.a n.a.a

Oregon 99 9 9 9

Pennsylvania 99 9 9 9

Rhode Island n.a.

a n.a.a n.a.a n.a.a n.a.a n.a.a

South Carolina 99 9 9 9

South Dakota 9 9 9 99

Tennessee 9 9 9 9 99

Texas 9 9 99

Utah 9 9 9 9 99

Vermont 99 9 9 9

Virginia n.a.

a n.a.a n.a.a n.a.a n.a.a n.a.a

Washington 99 9 9 9

West Virginia 99 9

Wisconsin 99 9 9 9

Wyoming 9 9 9 99

TABLE D9

NATURE OF JOB SEARCH TRAINING PROGRAM OFFERED TO FOOD STAMP E&T 

Time 

Management 

Skills

Money

Management 

Skills

Resume 

Writing

Interview 

Skills

b In California, New York and North Carolina, the nature of the program is decided at the c

 In Michigan, job search training is individualized to the needs of the client.

SOURCE: State E&T Managers Survey.

d

 Includes assessment testing, life skills, job retention skills, discussion of relocation, interview practice, 

anger management, personal hygiene and appearance.

a

 State does not offer job search training programs to ABAWDs.
State Othera

Alabama 9 99 9 9

Alaska 9 99 9 9 9

Arizona 9 99 9 9 9 9

Arkansas

California 9 9

Colorado 9 99 9 9 9 9

Connecticut 9 9

Delaware 9 9

District of Columbia 9 99 9

Florida 9 99

Georgia 9 99 9 9 9

Hawaii 9 9

Idaho 9 99 9 9 9

Illinois 9 99 9 9 9 9

Indiana 9 99 9 9 9 9

Iowa 9 9

Kansas

Kentucky 9 99 9 9

Louisiana 99 9

Maine 9 99 9 9 9 9

Maryland 9 99 9

Massachusetts 9

Michigan 9 99 9 9 9

Minnesota 9 99 9 9 9 9

Mississippi 9

Missouri 99 9 9 9

Montana

Nebraska 9 99 9 9

Nevada 9 99 9 9 9

New Hampshire 9

New Jersey 9 9

New Mexico 9 9

New York 9 99 9 9

North Carolina 99 9 9 9

North Dakota

Ohio 9 99 9 9 9 9

Oklahoma

Oregon 9 99 9 9

Pennsylvania 9 99 9 9 9 9

Rhode Island 9 9

South Carolina 9 9 99

South Dakota 9 99 9 9 9 9

Tennessee 99 9

Texas 99 9

Utah 9 99 9 9 9

Vermont 9 9

Virginia 9 99 9 9 9 9

Washington 9 99 9 9 9

West Virginia 9

Wisconsin 9 99 9 9 9 9 9

Wyoming 9 9

SOURCE: State E&T Managers Survey.

a

Includes some medical and dental services, drug rehabilitation, resume preparation and duplication, and assistance with cost of drivers 

licenses, drivers tests, police clearances, vehicle repair, car insurance, books and supplies.

TABLE D10

Transportation 

Reimbursement

Financial 

Assistance 

for 

Dependent 

WORK-RELATED SUPPORTIVE SERVICES OFFERED TO ABAWDS, FY99

Payment for 

Other EducationRelated Testing

One Time 

Emergency 

Assistance

Clothing 

for Job 

Interview

Assistance for 

Purchase of 

Work Supplies 

or Uniforms

Payment for 

EmploymentRelated Licensing 

or Testing
State Workfare Education

Alabama 9 9 9

Alaska 9 9

Arizona 9 9 9 9 9

Arkansas 9b

California 9 9 9 9

Colorado 9 9 9 9 9 9

Connecticut 9 9 9 9 9 9

Delaware 9 9 9

District of Columbia 9 9 9

Florida 9 9 9 9

Georgia 9 9 9

Hawaii 9 9 9 9

Idaho 9 9 9

Illinois 9 9 9 9

Indiana 9 9 9 9 9 9

Iowa

Kansas 9 9

Kentucky 9 9

Louisiana 9 9 9 9

Maine 9 9 9 9 9 9

Maryland 9 9

Massachusetts 9

Michigan 9 9 9 9

Minnesota 9 9 9 9 9 9

Mississippi 9 9 9

Missouri 9 9 9 9

Montana 9 9

Nebraska 9 9 9

Nevada 9

New Hampshire 9 9 9 9

New Jersey 9 9 9 9 9

New Mexico 9 9 9 9 9

New York 9 9 9 9

North Carolina 9 9 9

North Dakota 9 9

Ohio 9 9 9 9

Oklahoma

Oregon 9 9 9 9 9

Pennsylvania 9 9 9 9 9 9

Rhode Island

South Carolina 9 9 9 9

South Dakota 9 9 9

Tennessee 9 9 9

Texas 9 9 9 9 9

Utah 9 9 9

Vermont 9

Virginia 9 9

Washington 9 9 9 9

West Virginia 9 9 9

Wisconsin 9 9 9 9 9 9

Wyoming 9 9

SOURCE: State E&T Managers Survey and State Food Stamp Program Director Survey.

b

Arkansas only offers workfare through the optional workfare program in two counties.

a

 These states responded that job search and/or job search assistance in JTPA and TAA programs met the work requirements in 

March 2000. Such information was not provided for FY99.

TABLE D11

FOOD STAMP E&T QUALIFYING SERVICES OFFERED TO ABAWDs, FY99

SelfEmployment 

Program

Job Search In 

JTPA or TAA 

Programs a

Job Search Training

In JTPA or TAA 

Programs a

 Other Work 

Program

Vocational 

Training
Job Search Training

Job Search Training Meets Work 

Requirement

State

Part of JTPA 

and/or TAA?

No StateWide Policy

Policy 

varies by 

county or 

local office

Meets Work 

Requirement ? 

Part of JTPA 

and/or TAA?

No StateWide Policy

Policy 

varies by 

county or 

local office

Meets Work 

Requirement ?

Alabama Y YY Y

Alaska Y YY Y

Arizona Y YY Y

Arkansas N N 

California Y YY 9 N 

Colorado Y YY Y

Connecticut Y YY Y

Delaware Y Y Y Y

District of Columbia n.a. 

Florida Y NY Y

Georgia N N 

Hawaii N N 

Idaho N N 

Illinois Y YN 

Indiana Y YY Y

Iowa N N 

Kansas Y YY Y

Kentucky N N 

Louisiana Y YN 

Maine Y YY Y

Maryland N N 

Massachusetts N N 

Michigan Y YY Y

Minnesota Y YY Y

Mississippi N N 

Missouri Y YY Y

Montana Y YY Y

Nebraska Y YY Y

Nevada N N 

New Hampshire N N 

New Jersey Y YY Y

New Mexico Y YY Y

New York Y 9 d.k. 9 d.k. 

North Carolina N N 

North Dakota N N 

Ohio Y NY N

Oklahoma N N 

Oregon Y YY Y

Pennsylvania Y YY Y

Rhode Island Y 9 N N 

South Carolina N N 

South Dakota N N 

Tennessee N YN

Texas Y YN 

Utah N N 

Vermont Y NY N

Virginia N N 

Washington Y YY Y

West Virginia N N 

Wisconsin Y YY Y

Wyoming Y YY Y

SOURCE: State Food Stamp Program Director Survey.

d.k. = Respondent didn't know.

n.a. = Not applicable.

TABLE D12

JOB SEARCH AND JOB SEARCH TRAINING IN JTPA PROGRAMS AND TAA PROGRAMS, 2000

Job Search

Job Search Meets Work Requirement
State

 

In All Areas

Only In 

Some Areas

 

In All Areas

Only In 

Some Areas

Alabama Y Y 9 9

Alaska N N

Arizona Y Y 9

Arkansas N N 

California Y Y 9

Colorado Y Y 9

Connecticut Y Y 9 9

Delaware Y Y 9

District of Columbia Y Y 9

Florida Y Y 9 9

Georgia Y Y 9 9

Hawaii N N

Idaho Y Y 9 9

Illinois Y Y 9

Indiana Y Y 9 9

Iowa N N

Kansas Y N

Kentucky Y Y 9

Louisiana Y Y 9 9

Maine Y Y 9

Maryland Y Y 9 9a

Massachusetts Y Y 9

Michigan Y Y 9

Minnesota Y Y 9 9

Mississippi Y Y 9

Missouri N N

Montana N N

Nebraska Y Y 9

Nevada Y Y 9

New Hampshire Y Y 9

New Jersey Y Y 9 9

New Mexico Y Y 9 9

New York Y Y 9 9

North Carolina Y Y 9

North Dakota Y Y 9

Ohio Y Y 9

Oklahoma N N

Oregon Y Y 9

Pennsylvania Y Y 9 9

Rhode Island N N

South Carolina Y Y 9 9

South Dakota Y Y 9 9

Tennessee Y Y 9 9

Texas Y Y 9 9

Utah Y Y 9 9

Vermont Y Y 9

Virginia Y Y 9 9

Washington Y Y 9

West Virginia Y Y 9 9

Wisconsin Y Y 9

Wyoming N N

SOURCE: State E&T Managers Survey.

a

 In Maryland, workfare is available in all Food Stamp offices, but none of the waived counties are utilizing it.

TABLE D13

EXTENT TO WHICH WORKFARE PROGRAM IS OFFERED TO ABAWDs, FY99

Is The Workfare 

Program Offered To 

At Least Some 

ABAWDS?

Is Workfare Component Offered In Any Areas 

That Are Not Waived From The ABAWD 

Provisions?

Is Workfare Component Offered In Any 

Areas That Are Waived From The ABAWD 

Provisions?

Does The 

State Have A 

Workfare 

Program?
State

Alabama 9 N

Alaska n.a.a

Arizona 9 N

Arkansas n.a.a

California 9 N

Colorado 9 N

Connecticut 9 n.a.b

Delaware 9 Y

District of Columbia 9 Na

Florida 9 N

Georgia 9 Y

Hawaii n.a.a

Idaho 9 Y

Illinois 9 N

Indiana 9 N

Iowa n.a.a

Kansas n.a.a

Kentucky 9 Y

Louisiana 9 Y

Maine 9 N

Maryland 9 Y

Massachusetts 9 Y

Michigan 9 Y

Minnesota 9 Y

Mississippi 9 Y

Missouri n.a.a

Montana n.a.a

Nebraska 9 Y

Nevada 9 Y

New Hampshire 9 Y

New Jersey 9 Y

New Mexico 9 Y

New York 9 Y

North Carolina 9 N

North Dakota 9 N

Ohio 9 Y

Oklahoma n.a.a

Oregon 9 Y

Pennsylvania 9 N

Rhode Island n.a.a

South Carolina 9 d.k.

South Dakota 9 Y

Tennessee 9 N

Texas 9 N

Utah 9 Y

Vermont 9 Y

Virginia 9 d.k.

Washington 9 Y

West Virginia 9 n.a.b

Wisconsin 9 N

Wyoming n.a.a

SOURCE: State E&T Managers Survey.

d.k. = Respondent didn't know.

n.a. = Not applicable.

a State does not offer workfare to ABAWDs.

b

 State does not offer prearranged workfare slots.

TABLE D14

FOOD STAMP WORKFARE REQUIREMENT FOR ABAWDs AND SLOT AVAILABILITY, FY99

ABAWDs Are Required 

To Take Prearranged 

Slots

ABAWDs Are Required 

To Find Their Own 

Workfare Slot

ABAWDs Are Required To 

Take A Prearranged Slot Or 

Find Their Own Slot

 Is There A Prearranged 

Workfare Slot For Every

ABAWD Who Wants One? 
TABLE D15

JOB SEARCH AND JOB SEARCH TRAINING IN WORKFARE OR OTHER WORK PROGRAMS, 2000

 Job Search Component Job Search Training

Job Search Meets Work Requirement 

Job Search Training Meets Work 

Requirement

State

State Has 

Workfare Or 

Other Work 

Program?

As Part Of 

Workfare Or 

Work 

Program?

No StateWide Policy

Policy 

varies by 

Locality

Meets Work 

Requirement ? 

As Part of 

Work Fare or 

Work 

Experience?

No StateWide Policy

Policy varies 

by county or 

local office

Meets Work 

Requirement ?

Alabama Y Y Y N 

Alaska N 

Arizona Y N N 

Arkansas Ya Y 9 N N 

California Y Y Y Y Y 

Colorado Y Y Y Y Y 

Connecticut Y N N 

Delaware Y Y Y Y Y 

District of Columbia n.a. 

Florida Y Y Y Y Y 

Georgia Y N N 

Hawaii Ya Y Y Y 9 N 

Idaho Y N N 

Illinois Y Y Y Y Y 

Indiana Y Y Y Y Y 

Iowa Ya Y Y N 

Kansas Nb 

Kentucky Y Y Y N 

Louisiana Y Y Y Y Y 

Maine Y N N N 

Maryland Y Y Y Y Y 

Massachusetts Y N N 

Michigan Y Y Y Y Y 

Minnesota Y Y N N 

Mississippi Y N N 

Missouri N 

Montana Ya Y Y Y Y 

Nebraska Y Y Y Y Y 

Nevada Nc 

New Hampshire Y N N 

New Jersey Y N N 

New Mexico Y Y Y Y Y 

New York Y Y 9 Yd N 

North Carolina Y Y N Y N 

North Dakota Y N Y 9 Ye N 

Ohio Y N N 

Oklahoma N 

Oregon Y Y Y N 

Pennsylvania Y Y Y Y Y 

Rhode Island N 

South Carolina Y Y Y N 

South Dakota Y Y Y Y Y 

Tennessee Y Y N N 

Texas Y Y Y N 

Utah Y N Y N 

Vermont Y Y 9 N Y 9 N 

Virginia Y N N 

Washington Y Y Y Y Y 

West Virginia Y N N 

Wisconsin Y Y Y Y Y 

Wyoming N 

SOURCE: State Food Stamp Program Director Survey.

n.a. = Not applicable.

a

Respondent reported workfare was available in 2000, but respondent to state E&T Managers Survey reported no workfare in FY99.

b

Kansas has workfare but it is not offered to ABAWDS.

c

Nevada recently discountinued its workfare program.

d

Policy varies by locality. State does not know if a common policy exists.

e

Policy varies by locality. Policy shown is the most common policy.
State Statewide Policy? Limit No Limit

Alabama Y 9

Alaska n.a.a

Arizona Y 6 months out of 12

Arkansas n.a.a

California N

Colorado Y 9

Connecticut Y 9

Delaware Y 9

District of Columbia Ya 3 months

Florida Y 9

Georgia Y 9

Hawaii n.a.a

Idaho Y Reassess after 13 weeks 

Illinois Y 9

Indiana Y 9

Iowa n.a.a

Kansas n.a.a

Kentucky Y 9

Louisiana Y 9

Maine Y 9

Maryland n.a.a

Massachusetts Y 33 / 36 months

Michigan Y 9

Minnesota N

Mississippi Y 9

Missouri n.a.a

Montana n.a.a

Nebraska Y 9

Nevada Y 6 months

New Hampshire Y 9

New Jersey Y 9

New Mexico n.a.a

New York Y 9

North Carolina Y 9

North Dakota n.a.a

Ohio Y 9

Oklahoma n.a.a

Oregon N

Pennsylvania Y 9

Rhode Island n.a.a

South Carolina Y 9

South Dakota Y 9

Tennessee Y Reassess after 6 months

Texas Y 9

Utah Y 9

Vermont Y 2 months

Virginia Y 9

Washington Y 9

West Virginia Y 9

Wisconsin Y 9

Wyoming n.a.a

SOURCE: State E&T Managers Survey.

n.a. = Not applicable.

a

 State does not offer workfare to ABAWDs.

TABLE D16

POLICY ON HOW LONG AN ABAWD CAN REMAIN IN WORKFARE, 1999

Policy 
State Other

Alabama Y 9

Alaska n.a.a

Arizona Y 9

Arkansas n.a.a

California N

Colorado Y 9

Connecticut N

Delaware Y 9

District of Columbia Y 9

Florida Y 9

Georgia Y 9

Hawaii n.a.a

Idaho Y 9d

Illinois Y 9

Indiana Y 9

Iowa n.a.a

Kansas n.a.a

Kentucky Y 9

Louisiana Y 9

Maine Y 9b 9b

Maryland n.a.a

Massachusetts Y 9

Michigan Y 9c 9c

Minnesota N

Mississippi N

Missouri n.a.a

Montana n.a.a

Nebraska Y 9

Nevada N

New Hampshire Y 9

New Jersey N

New Mexico n.a.a

New York Y 9

North Carolina Y 9

North Dakota n.a.a 9

Ohio Y 9

Oklahoma n.a.a

Oregon Y 9

Pennsylvania Y 9

Rhode Island n.a.a

South Carolina N

South Dakota Y 9

Tennessee Y 9

Texas Y 9

Utah Y 9

Vermont Y 9

Virginia Y 9

Washington Y 9

West Virginia Y 9

Wisconsin N

Wyoming n.a.a

SOURCE: State E&T Managers Survey.

n.a. = Not applicable.

a

 State does not offer workfare to ABAWDs.

b

 ABAWDs begin the regular workfare program after application or they can wait until the time limit is ending. c

 ABAWDs begin the regular workfare program after application and self-initiated community service after job search training. d

 In Idaho, the policy was not specified.

After Job 

Search 

Training

Statewide 

Policy?

After 

Application

After Job 

Search

TABLE D17

POLICY ON WHEN ABAWDs BEGIN PARTICIPATION IN WORKFARE, FY99

Policy

After 

Eligibility Is 

Determined

In The Second 

Month Of Time 

Limit

In The 

Third Month 

Of Time 

Only After 

Their Time 

Limit Is Over
State In All Areas In Some Areas In All Areas In Some Areas

Alabama N N 9

Alaska N N 9a

Arizona Y Y 9

Arkansas Y N

California Y Y 9

Colorado Y Y 9

Connecticut Y Y 9 9

Delaware Y N

District of Columbia Y Y 9

Florida Y Y 9 9

Georgia Y Y 9 9

Hawaii Y Y 9 9

Idaho Y Y 9 9

Illinois Y Y 9

Indiana Y Y 9 9

Iowa N N

Kansas Y N

Kentucky N N

Louisiana Y Y 9 9

Maine Y Y 9

Maryland Y Y 9 9

Massachusetts N N

Michigan Y Y 9

Minnesota Y Y 9 9

Mississippi Y Y 9

Missouri Y Y 9 9

Montana Y N

Nebraska N N

Nevada N N

New Hampshire Y Y 9

New Jersey Y Y 9 9

New Mexico Y Y 9 9

New York Y Y 9 9

North Carolina Y Y 9

North Dakota Y Y 9

Ohio Y Y 9

Oklahoma Y N

Oregon N N

Pennsylvania Y Y 9 9

Rhode Island N N

South Carolina Y Y 9 9

South Dakota Y Y 9 9

Tennessee Y Y 9 9

Texas Y Y 9 9

Utah Y Y 9 9

Vermont Y Y d.m. d.m. d.m. d.m.

Virginia Y N

Washington Y Y 9

West Virginia Y Y 9 9

Wisconsin Y Y 9

Wyoming N N

SOURCE: State E&T Managers Survey.

d.m.=Data Missing.

a For Alaska, these answers can change depending on the season. Waivers are only in effect during months of high unemployment. No area is 

exempt for the work requirement year-round.

TABLE D18

EXTENT TO WHICH EDUCATION PROGRAMS ARE OFFERED TO ABAWDS, FY99

Is The Education 

Program Offered 

To At Least Some 

ABAWDS?

Is the Education Component Offered 

In Any Areas That Are Not Waived 

From The ABAWD Provisions?

Is the Education Component Offered In 

Any Areas That Are Waived From The 

ABAWD Provisions?

Does The State 

Have An Education 

Program?
State

 

In All Areas

 

In Some Areas

 

In All Areas

 

In Some Areas

Alabama N N

Alaska N N

Arizona Y Y 9

Arkansas Y N 

California Y Y 9

Colorado Y Y 9

Connecticut Y Y 9 9

Delaware Y N

District of Columbia Y Y 9

Florida Y Y 9 9

Georgia Y Y 9 9

Hawaii Y Y 9 9

Idaho Y Y 9 9

Illinois Y Y 9

Indiana Y Y 9 9

Iowa N N

Kansas Y N

Kentucky Y Y 9

Louisiana Y Y 9 9

Maine Y Y 9 9

Maryland Y Y 9 9

Massachusetts N N

Michigan N N

Minnesota Y Y 9 9

Mississippi Y Y 9

Missouri Y Y 9 9

Montana Y N

Nebraska N N

Nevada N N

New Hampshire Y Y 9

New Jersey Y Y 9 9

New Mexico Y Y 9 9

New York Y Y 9 9

North Carolina Y Y 9

North Dakota Y Y 9

Ohio Y Y 9

Oklahoma Y N

Oregon Y Y 9

Pennsylvania Y Y 9 9

Rhode Island N N

South Carolina Y Y 9 9

South Dakota N N

Tennessee Y Y 9 9

Texas Y Y 9 9

Utah Y Y 9 9

Vermont Y Ya d.m. d.m. d.m. d.m.

Virginia Y Y 9 9

Washington Y N

West Virginia Y Y 9 9

Wisconsin Y Y 9

Wyoming N N

SOURCE: State E&T Managers Survey.

d.m.= Data Missing.

a Vermont offers vocational services but few clients participate in these services

TABLE D19

EXTENT TO WHICH VOCATIONAL TRAINING IS OFFERED TO ABAWDS, FY99

Is The Vocational 

Training Program 

Offered To At 

Least Some 

ABAWDS?

Is Vocational Training Offered In Any 

Areas That Are Not Waived From The 

ABAWD Provisions?

Is Vocational Training Offered In Any 

Areas That Are Waived From The 

ABAWD Provisions?

Does The State 

Have A 

Vocational 

Training 

Program?
State

Alabama n.a.a n.a.a

Alaska n.a.a n.a.a

Arizona N Y

Arkansas n.a.a N

California d.kb d.k

Colorado N N

Connecticut N N

Delaware n.a.a n.a.a

District of Columbia Y N

Florida N N

Georgia Y Y

Hawaii Y Y

Idaho N Y

Illinois Y Y

Indiana Y Y

Iowa n.a.a n.a.a

Kansas n.a.a n.a.a

Kentucky n.a.a Y

Louisiana N N

Maine N N

Maryland Y Y

Massachusetts n.a.a n.a.a

Michigan Y n.a.a

Minnesota Y Y

Mississippi Y Y

Missouri N N

Montana n.a.a n.a.a

Nebraska n.a.a n.a.a

Nevada n.a.a n.a.a

New Hampshire Y Y

New Jersey Y Y

New Mexico Y Y

New York d.kb d.k

North Carolina N N

North Dakota Y N

Ohio Y Y

Oklahoma n.a.a n.a.a

Oregon n.a.a Y

Pennsylvania N N

Rhode Island n.a.a n.a.a

South Carolina d.k. d.k.

South Dakota N n.a.a

Tennessee Y Y

Texas N N

Utah Y Y

Vermont d.m. d.m.

Virginia n.a.a d.k.

Washington Y n.a.a

West Virginia N N

Wisconsin Y Y

Wyoming n.a.a n.a.a

SOURCE: State E&T Managers Survey.

d.k. = Respondent didn't know.

d.m.= Data missing.

n.a. = Not applicable.

a State does not offer education/vocational training programs to ABAWDs. b

 Varies by county.

Is There A Slot In Vocational 

Training For All ABAWDs Who 

Want Them?a

SLOTS AVAILABLE IN EDUCATION AND VOCATIONAL TRAINING PROGRAMS FOR ABAWDs, 

FY99

TABLE D20

Is There A Slot In An Education 

Program For All ABAWDs Who Want 

Them?a
State

Alabama n.a.b n.a.b n.a.b n.a.b n.a.b n.a.b n.a.b

Alaska n.a.b n.a.b n.a.b n.a.b n.a.b n.a.b n.a.b

Arizona 9 99

Arkansas n.a.b n.a.b n.a.b n.a.b n.a.b n.a.b n.a.b

California 9 99

Colorado 9 999 9

Connecticut 9 99

Delaware n.a.b n.a.b n.a.b n.a.b n.a.b n.a.b n.a.b

District of Columbia 9 9a 9

Florida 9 99

Georgia 9 99

Hawaii 9 99

Idaho 9 99

Illinois 9 99

Indiana 9 99

Iowa n.a.b n.a.b n.a.b n.a.b n.a.b n.a.b n.a.b

Kansas n.a.b n.a.b n.a.b n.a.b n.a.b n.a.b n.a.b

Kentucky n.a.b n.a.b n.a.b n.a.b n.a.b n.a.b n.a.b

Louisiana

Maine 9 99

Maryland 9 999

Massachusetts n.a.b n.a.b n.a.b n.a.b n.a.b n.a.b n.a.b

Michigan 9 99

Minnesota 9 99

Mississippi 9 9

Missouri 9 99

Montana n.a.b n.a.b n.a.b n.a.b n.a.b n.a.b n.a.b

Nebraska n.a.b n.a.b n.a.b n.a.b n.a.b n.a.b n.a.b

Nevada n.a.b n.a.b n.a.b n.a.b n.a.b n.a.b n.a.b

New Hampshire 9 99

New Jersey 9 99

New Mexico 9 99 9

New York 9 99 9

North Carolina 9 99

North Dakota d.m. d.m. d.m. d.m. d.m. d.m. d.m.

Ohio 9 99 9 9

Oklahoma n.a.b n.a.b n.a.b n.a.b n.a.b n.a.b n.a.b

Oregon n.a.b n.a.b n.a.b n.a.b n.a.b n.a.b n.a.b

Pennsylvania 9 99

Rhode Island n.a.b n.a.b n.a.b n.a.b n.a.b n.a.b n.a.b

South Carolina 9 9

South Dakota 9 9

Tennessee 9 99

Texas 9 999 9

Utah 9 99

Vermont d.m. d.m. d.m. d.m. d.m. d.m. d.m.

Virginia n.a.b n.a.b n.a.b n.a.b n.a.b n.a.b n.a.b

Washington 9 99

West Virginia 9 99 9

Wisconsin 9 99 9

Wyoming n.a.b n.a.b n.a.b n.a.b n.a.b n.a.b n.a.b

SOURCE: State E&T Managers Survey.

d.m.= Data missing

n.a. = Not applicable.

b

 State does not offer education programs to ABAWDs.

a The District of Columbia offers computer programming, computer repair, clerical skills training, hotel training, culinary

arts, nursing aides, home aides, training to be taxi cab drivers

TABLE D21

NATURE OF EDUCATION PROGRAM OFFERED TO FOOD STAMP E&T PARTICIPANTS BY STATE, FY99

Classes to Help 

Clients Obtain a 

High School or 

GED Diploma

Secondary

and PostSecondary

Education

English as a 

Second 

Language

Basic Skills 

Training

Literacy

classes

Adult Basic 

Education

Driver's 

Education
State

Classroom 

Training

On-the-Job 

Training

 

JTPA

Community 

Colleges

Employment 

Counselors

Alabama n.a.a n.a.a n.a.a n.a.a n.a.a

Alaska n.a.a n.a.a n.a.a n.a.a n.a.a

Arizona 9

Arkansas 9 9

California 9 9

Colorado 9

Connecticut 9 9

Delaware n.a.a n.a.a n.a.a n.a.a n.a.a

District of Columbia 9 9

Florida 9 9

Georgia 9 9

Hawaii 9 9

Idaho 9

Illinois 9

Indiana 9 9

Iowa n.a.a n.a.a n.a.a n.a.a n.a.a

Kansas n.a.a n.a.a n.a.a n.a.a n.a.a

Kentucky 9

Louisiana d.k. d.k.

Maine 9 d.k.

Maryland 9 9

Massachusetts n.a.a n.a.a n.a.a n.a.a n.a.a

Michigan n.a.a n.a.a n.a.a n.a.a n.a.a

Minnesota 9 9

Mississippi 9 9 9

Missouri 9 9

Montana n.a.a n.a.a n.a.a n.a.a n.a.a

Nebraska n.a.a n.a.a n.a.a n.a.a n.a.a

Nevada n.a.a n.a.a n.a.a n.a.a n.a.a

New Hampshire 9 9

New Jersey 9 9

New Mexico 9

New York 9 9

North Carolina 9 9 9 9

North Dakota d.m. d.m. d.m. d.m. d.m.

Ohio 9

Oklahoma n.a.a n.a.a n.a.a n.a.a n.a.a

Oregon 9 9

Pennsylvania 9

Rhode Island n.a.a n.a.a n.a.a n.a.a n.a.a

South Carolina 9 9

South Dakota n.a.a n.a.a n.a.a n.a.a n.a.a

Tennessee 9

Texas 9 9

Utah 9

Vermont d.m. d.m. d.m. d.m. d.m.

Virginia 9

Washington n.a.a n.a.a n.a.a 9 n.a.a

West Virginia 9

Wisconsin 9 9

Wyoming n.a.a n.a.a n.a.a n.a.a n.a.a

SOURCE: State E&T Managers Survey.

d.m.= Data missing

n.a. = Not applicable.

a

 State does not offer vocational training to ABAWDs.

TABLE D22

NATURE OF VOCATIONAL TRAINING COMPONENT OFFERED TO FOOD STAMP 

E&T PARTICIPANTS BY STATE, FY99
State Statewide Policy? Months No Limit Other

Alabama n.a.a

Alaska n.a.a

Arizona Y 9

Arkansas n.a.a

California N

Colorado N

Connecticut Y 9

Delaware n.a.a

District of Columbia Y 12

Florida Y Depends on client's needs

Georgia N

Hawaii Y 4

Idaho Y 9

Illinois Y Varies depending on education program participant joins

Indiana Y 9

Iowa n.a.a

Kansas n.a.a

Kentucky n.a.a

Louisiana Y 9

Maine Y 6

Maryland N

Massachusetts n.a.a

Michigan Y 9

Minnesota N

Mississippi Y 24

Missouri Y 9

Montana n.a.a

Nebraska n.a.a

Nevada n.a.a

New Hampshire Y Contingent on individual curriculum

New Jersey Y 9

New Mexico Y 9

New York Y 9b

North Carolina Y Limitation as long as class lasts

North Dakota d.m.

Ohio N

Oklahoma n.a.a

Oregon n.a.a

Pennsylvania Y 9

Rhode Island n.a.a

South Carolina N

South Dakota Y 9

Tennessee Y 9

Texas N

Utah Y 9

Vermont d.m.

Virginia n.a.a

Washington Y 9

West Virginia Y 3c

Wisconsin Y Left to the discretion of counties

Wyoming n.a.a

SOURCE: State E&T Managers Survey.

d.m.= Data missing.

n.a. = Not applicable.

a

 State does not offer education programs to ABAWDs.

b

 In New York, there is a limit of two years for post-secondary education.

c

In West Viriginia, the limit can be longer if the client is working.

TABLE D23

POLICY ON HOW LONG AN ABAWD CAN REMAIN IN EDUCATION, 1999

Policy 
State Statewide Policy? Months No Limit Other

Alabama n.a.a

Alaska n.a.a

Arizona Y 9

Arkansas n.a.a

California N

Colorado N

Connecticut Y 9

Delaware n.a.a

District of Columbia Y 3b

Florida Y 9

Georgia Y Length of class

Hawaii Y Length of class

Idaho Y 9

Illinois Y 6

Indiana Y 12

Iowa n.a.a

Kansas n.a.a

Kentucky Y Same as JTPA limit

Louisiana Y 9

Maine Y 6

Maryland Y 9

Massachusetts n.a.a

Michigan n.a.a

Minnesota Y 9

Mississippi Y Length of class

Missouri Y 9

Montana n.a.a

Nebraska n.a.a

Nevada n.a.a

New Hampshire Y 9

New Jersey Y 9

New Mexico Y 24

New York N

North Carolina Y 9

North Dakota d.m.

Ohio N

Oklahoma n.a.a

Oregon Y Duration of activity

Pennsylvania Y 6c

Rhode Island n.a.a

South Carolina N

South Dakota n.a.a

Tennessee Y 9

Texas N

Utah Y 9

Vermont d.m.

Virginia Y 9

Washington n.a.a

West Virginia Y 12

Wisconsin Y "Short term"

Wyoming n.a.a

SOURCE: State E&T Managers Survey.

d.m.= Data missing

n.a. = Not applicable.

a

 State does not offer vocational training to ABAWDs.

b

 In the District of Columbia, this limit can be longer.

c

 In Pennsylvania, the time limit is sometimes a year.

TABLE D24

POLICY ON HOW LONG AN ABAWD CAN REMAIN IN VOCATIONAL TRAINING, FY99

Policy 
State

 When They 

First Apply At Another Timea

Alabama Y 9

Alaska Y 9

Arizona Y 9

Arkansas n.a.b

California Y 9

Colorado Y 9

Connecticut Y 9

Delaware Y 9

District of Columbia n.a.b

Florida Y 9

Georgia Y 9

Hawaii Y 9

Idaho Y 9

Illinois n.a.b

Indiana Y 9

Iowa n.a.c

Kansas n.a.c

Kentucky Y 9

Louisiana Y 9

Maine Y 9

Maryland Y 9

Massachusetts Y 9

Michigan Y 9

Minnesota Y 9

Mississippi Y 9

Missouri Y 9

Montana n.a.c

Nebraska Y 9

Nevada Y 9

New Hampshire Y 9

New Jersey Y 9

New Mexico Y 9

New York Y 9

North Carolina Y 9

North Dakota Y 9

Ohio Y 9

Oklahoma n.a.c

Oregon Y 9

Pennsylvania Y 9

Rhode Island n.a.d

South Carolina Y 9

South Dakota Y 9

Tennessee Y 9

Texas Y 9

Utah Y 9

Vermont Y 9

Virginia Y 9e 9e

Washington Y 9

West Virginia Y 9

Wisconsin Y 9

Wyoming n.a.c

SOURCE: State E&T Managers Survey .

n.a. = Not applicable.

a

 Includes within the first three months and if not still employed after 30 days of job search.

b

 In Arkansas, Illinois and the District of Columbia, there are no ABAWDs, subject to the work requirement.

c

 Kansas, Montana, and Oklahoma do not offer E&T services to ABAWDs.

d

 Iowa, Rhode Island and Wyoming do not offer qualifying E&T services to ABAWDs.

e In Virginia, the policy is either the first month or the second month. It depends on how long it takes to process and send the notices.

TABLE D25

POLICY ON WHEN ABAWDs SHOULD BE OFFERED A QUALIFYING E&T SLOT, FY99

Timing of Services

During The First Month or 

After They Are Found 

Eligible And Subject To 

Time Limits

After They 

Have 

Exhausted 

The Three 

Statewide 

Policy?

During The 

Second 

Month

During 

The Third 

Month
Alabama

Alaska

Arizona 9

Arkansas

California

Colorado

Connecticut

Delaware 9

District of Columbia

Florida

Georgia 9

Hawaii

Idaho 9

Illinois

Indiana 9

Iowa

Kansas

Kentucky 9

Louisiana 9

Maine 9

Maryland 9

Massachusetts 9

Michigan 9

Minnesota

Mississippi 9

Missouri 9

Montana

Nebraska 9

Nevada 9

New Hampshire 9

New Jersey 9

New Mexico 9

New York

North Carolina

North Dakota

Ohio 9

Oklahoma

Oregon 9

Pennsylvania 9

Rhode Island

South Carolina 9

South Dakota 9

Tennessee 9

Texas

Utah 9

Vermont 9

Virginia

Washington 9

West Virginia 9

Wisconsin 9

Wyoming

SOURCE: State E&T Managers Survey.

b

 As of October 1999, Montana offers qualifying E&T to 

all ABAWDs. As of 2000, participation of job search 

and job search training as part of JTPA and TAA 

TABLE D26

AVAILABILITY OF QUALIFYING E&T WORK 

ABAWD Qualifying E&T Work 

Activities Available In All Nonwaived Offices For ABAWDs 

Who Have Used Up Their 

State Three Month Limit

a

 A qualifying E&T slot may include a work component, 

education, or training, or job search or job search 

training as part of JTPA/TAA.
Between

State 20% and 99% 100%

Alabama 9 23 9

Alaska 9 20

Arizona 9 47

Arkansas 9 14

California 9 73 9

Colorado 9 100

Connecticut 9 46

Delaware d.k. d.k. 33

District of Columbia 9 12 9

Florida 9 82

Georgia 9 39 9

Hawaii 9 16 9

Idaho 9 20

Illinois 9 93 9

Indiana 9 6 9

Iowa 9 20

Kansas 9 20

Kentucky d.k. d.k. 34

Louisiana 9 26

Maine 9 73

Maryland 9 13 9

Massachusetts 9 14 9

Michigan d.k. d.k. 11

Minnesota 9 73 9

Mississippi 9 62 9

Missouri 9 7 9

Montana 9 56 9

Nebraska 9 63 9

Nevada 9 21

New Hampshire 9 21 9

New Jersey 9 100

New Mexico 9 27

New York 9 40 9

North Carolina 9 6 9

North Dakota 9 44 9

Ohio 9 73 9

Oklahoma 9 14

Oregon 9 43

Pennsylvania 9 24 9

Rhode Island 9 16

South Carolina 9 93 9

South Dakota d.k. d.k. 80

Tennessee 9 29

Texas d.k. d.k. 64

Utah d.k. d.k. 52

Vermont 9 42

Virginia 9 21 9

Washington 9 68 9

West Virginia 9 15 9

Wisconsin 9 30

Wyoming 9 21 9

SOURCE: State E&T Managers Survey and Botsko et al. (2000).

d.k. = Respondent didn't know.

Plans to Change 

Expenditure in FY00

TABLE D27

PLANNED AND ACTUAL FEDERAL FOOD STAMP E&T FUNDING BY STATE, FY99

Percent of Federal Funds State 

Planned To Draw

20% or 

less

Percent of Federal Funds 

State Actually Drew
State

Alabama

Alaska 9

Arizona 9 9

Arkansas 9

California

Colorado

Connecticut 9 9

Delaware

Dist. of Col.

Florida 9 9

Georgia

Hawaii 9

Idaho 9 9

Illinois

Indiana 9 9

Iowa 9 9

Kansas 9

Kentucky

Louisiana 9

Maine 9

Maryland

Massachusetts 9

Michigan

Minnesota

Mississippi

Missouri 9 9

Montana 9 9

Nebraska

Nevada 9 9

New Hampshire

New Jersey

New Mexico 9

New York

North Carolina

North Dakota

Ohio

Oklahoma 9 9

Oregon 999

Pennsylvania

Rhode Island 9

South Carolina

South Dakota

Tennessee 9 9

Texas

Utah

Vermont 999

Virginia 9 9

Washington

West Virginia 9 9

Wisconsin 9

Wyoming 9

SOURCE: State E&T Managers Survey.

Unable To Provide 

The Support 

Services That Are 

Needed

ABAWDs Can 

Receive These 

Services in JTPA

TABLE D28

REASONS FOR DRAWING LESS THAN 100% FROM FEDERAL FOOD STAMP E&T GRANT BY STATE, FY99

No FS E&T 

Program In Many

Offices Or Local 

E&T Program 

Does Not Provide 

Enough Slots

Does Not Want 

To Spend More 

Money On 

ABAWDs

Not Enough 

ABAWDs to Spend 

All the Money

Too Few ABAWDs 

Are Filling

Available Slots

Problems with E&T 

Requirements
State

U.S. Totals 662,842 252,324 915,166 72%

Alabama 2,780 0 2,780 100%

Alaska 0 0 0 n.a.

Arizona 179 223 402 45%

Arkansas 0 0 0 n.a.

California 293,922 58,109 352,031 83%

Colorado 11,984 215 12,199 98%

Connecticut 271 543 814 33%

Delaware 25 145 170 15%

District of Columbia 0 0 0 n.a.

Florida 2,425 4,850 7,275 33%

Georgia 4,782 2,931 7,713 62%

Hawaii 201 174 375 54%

Idaho 136 12 148 92%

Illinois 93 5 98 95%

Indiana 601 387 988 61%

Iowa 0 0 0 n.a.

Kansas 0 0 0 n.a.

Kentucky 1,278 551 1,829 70%

Louisiana 784 293 1,077 73%

Maine 19 1,258 1,277 1%

Maryland 175 184 359 49%

Massachusetts 931 1,166 2,097 44%

Michigan 1,437 15 1,452 99%

Minnesota 4,430 10,071 14,501 31%

Mississippi 3,414 986 4,400 78%

Missouri 445 508 953 47%

Montana 0 0 0 n.a.

Nebraska 359 1,872 2,231 16%

Nevada 65 231 296 22%

New Hampshire 1,710 0 1,710 100%

New Jersey 64,106 42,681 106,787 60%

New Mexico 3 16 19 16%

New York 214,540 21,120 235,660 91%

North Carolina 588 878 1,466 40%

North Dakota 21 10 31 68%

Ohio 22,737 1,077 23,814 95%

Oklahoma 0 0 0 n.a.

Oregon 2,315 57,697 60,012 4%

Pennsylvania 1,132 0 1,132 100%

Rhode Island 0 0 0 n.a.

South Carolina 5,147 6,844 11,991 43%

South Dakota 601 4,156 4,757 13%

Tennessee 3,158 9,498 12,656 25%

Texas 5,472 10,403 15,875 34%

Utah 1,736 1,622 3,358 52%

Vermont 626 675 1,301 48%

Virginia 140 294 434 32%

Washington 4,176 10,450 14,626 29%

West Virginia 2,115 0 2,115 100%

Wisconsin 1,719 174 1,893 91%

Wyoming 64 0 64 100%

SOURCE: FNS-583.

TABLE D29

ABAWD E&T Slots 

Filled In Non-Waived 

Areas

ABAWD E&T Slots 

Offered But Not Filled 

In Non-Waived Areas

Filled And Offered 

E&T Slots In NonWaived Areas

PERCENTAGE OF ABAWD E&T SLOTS FILLED IN NON-WAIVED AREAS, FY99

Percentage Of E&T 

Slots That Are Filled In 

Non-Waived Areas
State

Percentage Of 

Workfare Slots 

That Are Filled 

In Non-Waived 

Areas

U.S. Totals 577,117 209,912 787,029 73%

Alabama 2,780 0 2,780 100%

Alaska 0 0 0 n.a.

Arizona 142 171 313 45%

Arkansas 0 0 0 n.a.

California 273,296 56,023 329,319 83%

Colorado 9,598 60 9,658 99%

Connecticut 91 211 302 30%

Delaware 25 145 170 15%

District of Columbia 0 0 0 n.a.

Florida 1,694 3,310 5,004 34%

Georgia 3,566 2,074 5,640 63%

Hawaii 0 0 0 n.a.

Idaho 70 11 81 86%

Illinois 93 5 98 95%

Indiana 276 238 514 54%

Iowa 0 0 0 n.a.

Kansas 0 0 0 n.a.

Kentucky 1,261 551 1,812 70%

Louisiana 447 212 659 68%

Maine 17 609 626 3%

Maryland 0 0 0 n.a.

Massachusetts 931 1,166 2,097 44%

Michigan 1,391 15 1,406 99%

Minnesota 737 4,634 5,371 14%

Mississippi 3,063 986 4,049 76%

Missouri 0 0 0 n.a.

Montana 0 0 0 n.a.

Nebraska 359 1,872 2,231 16%

Nevada 65 231 296 22%

New Hampshire 1,649 0 1,649 100%

New Jersey 21,019 21,381 42,400 50%

New Mexico 0 0 0 n.a.

New York 214,300 21,000 235,300 91%

North Carolina 470 764 1,234 38%

North Dakota 0 0 0 n.a.

Ohio 21,063 959 22,022 96%

Oklahoma 0 0 0 n.a.

Oregon 2,225 57,555 59,780 4%

Pennsylvania 33 0 33 100%

Rhode Island 0 0 0 n.a.

South Carolina 1,324 1,752 3,076 43%

South Dakota 551 3,555 4,106 13%

Tennessee 2,271 7,969 10,240 22%

Texas 5,275 10,346 15,621 34%

Utah 962 1,089 2,051 47%

Vermont 217 266 483 45%

Virginia 66 153 219 30%

Washington 4,167 10,441 14,608 29%

West Virginia 0 0 0 n.a.

Wisconsin 1,623 158 1,781 91%

Wyoming 0 0 0 n.a.

SOURCE: FNS-583

TABLE D30

PERCENTAGE OF ABAWD WORKFARE SLOTS FILLED IN NON-WAIVED AREAS, FY99

ABAWD Workfare 

Slots Filled In NonWaived Areas

ABAWD 

Workfare Slots 

Offered But Not 

Filled In NonWaived Areas

 Filled And 

Offered Workfare 

Slots In NonWaived Areas
Percentage Of 

Total Slots That 

Are Filled In

State Non-Waived Areas

U.S. Totals 85,725 42,412 128,137 67%

Alabama 0 0 0 n.a.

Alaska 0 0 0 n.a.

Arizona 37 52 89 42%

Arkansas 0 0 0 n.a.

California 20,626 2,086 22,712 91%

Colorado 2,386 155 2,541 94%

Connecticut 180 332 512 35%

Delaware 0 0 0 n.a.

District of Columbia 0 0 0 n.a.

Florida 731 1,540 2,271 32%

Georgia 1,216 857 2,073 59%

Hawaii 201 174 375 54%

Idaho 66 1 67 99%

Illinois 0 0 0 n.a.

Indiana 325 149 474 69%

Iowa 0 0 0 n.a.

Kansas 0 0 0 n.a.

Kentucky 17 0 17 100%

Louisiana 337 81 418 81%

Maine 2 649 651 0%

Maryland 175 184 359 49%

Massachusetts 0 0 0 n.a.

Michigan 46 0 46 100%

Minnesota 3,693 5,437 9,130 40%

Mississippi 351 0 351 100%

Missouri 445 508 953 47%

Montana 0 0 0 n.a.

Nebraska 0 0 0 n.a.

Nevada 0 0 0 n.a.

New Hampshire 61 0 61 100%

New Jersey 43,087 21,300 64,387 67%

New Mexico 3 16 19 16%

New York 240 120 360 67%

North Carolina 118 114 232 51%

North Dakota 21 10 31 68%

Ohio 1,674 118 1,792 93%

Oklahoma 0 0 0 n.a.

Oregon 90 142 232 39%

Pennsylvania 1,099 0 1,099 100%

Rhode Island 0 0 0 n.a.

South Carolina 3,823 5,092 8,915 43%

South Dakota 50 601 651 8%

Tennessee 887 1,529 2,416 37%

Texas 197 57 254 78%

Utah 774 533 1,307 59%

Vermont 409 409 818 50%

Virginia 74 141 215 34%

Washington 9 9 18 50%

West Virginia 2,115 0 2,115 100%

Wisconsin 96 16 112 86%

Wyoming 64 0 64 100%

SOURCE: FNS-583

Non-Waived Areas Non-Waived Areas Non-Waived Areas

PERCENTAGE OF ABAWD EDUCATION AND TRAINING SLOTS FILLED IN NON-WAIVED AREAS, 

FY99

TABLE D31

ABAWD Education 

And Training Slots 

Filled In

ABAWD Education 

And Training Slots 

Offered But Not 

Filled In

 Filled And Offered 

Education And 

Training Slots In 
APPENDIX E 

ADMINISTERING THE ABAWD POLICIES, STATE POLICIES AND PROCEDURES
TABLE E1

FIRST MONTH OF THREE-MONTH TIME LIMIT

First Month of Three-Month Limit

State

Alabama Y 9

Alaska Y 9

Arizona Y 9

Arkansas Y 9

California Y 9

Colorado Y 9

Connecticut Y 9

Delaware Y 9

District of Columbia n.a.

Florida Y 9

Georgia Y 9

Hawaii Y 9

Idaho Y 9

Illinois Y 9

Indiana Y 9

Iowa Y 9

Kansas Y 9

Kentucky Y 9

Louisiana Y 9

Maine Y 9

Maryland Y 9

Massachusetts Y 9

Michigan Y 9

Minnesota Y 9

Mississippi Y 9

Missouri Y 9

Montana Y 9

Nebraska Y 9

Nevada Y 9

New Hampshire Y 9

New Jersey Y 9

New Mexico Y 9

New York Y 9

North Carolina Y 9

North Dakota Y 9

Ohio Y 9

Oklahoma Y 9

Oregon Y 9

Pennsylvania Y 9

Rhode Island Y 9

South Carolina Y 9

South Dakota Y 9

Tennessee Y 9

Texas Y 9

Utah Y 9

Vermont Y 9

Virginia Y 9

Washington Y 9

West Virginia Y 9

Wisconsin Y 9

Wyoming Y 9

SOURCE: State Food Stamp Program Director Survey.

n.a. = Not applicable.

First Full Month of 

Benefits

State-Wide 

Policy?

Month of 

Application

Month Case is 

Certified

First Month Benefits 

Received

Month Of Application 

Before Mid-Month
TABLE E2

DETERMINING THE 36-MONTH PERIOD

Fixed Clock

State

State-Wide 

Policy? Rolling Clock

Same for All 

ABAWDs

Varies Among 

ABAWDs

Alabama Y 9

Alaska Y 9

Arizona Y 9

Arkansas Y 9

California Y 9

Colorado Y 9

Connecticut Y 9

District of Columbia n.a.

Delaware Y 9

Florida Y 9

Georgia Y 9

Hawaii Y 9

Idaho Y 9

Illinois Y 9

Indiana Y 9

Iowa Y 9

Kansas Y 9

Kentucky Y 9

Louisiana Y 9

Maine Y 9

Maryland Y 9

Massachusetts Y 9

Michigan Y 9

Minnesota Y 9

Mississippi Y 9

Missouri Y 9

Montana Y 9

Nebraska Y 9

Nevada Y 9

New Hampshire Y 9

New Jersey Y 9

New Mexico Y 9

New York Y 9

North Carolina Y 9

North Dakota Y 9

Ohio Y 9

Oklahoma Y 9

Oregon Y 9

Pennsylvania Y 9

Rhode Island Y 9

South Carolina Y 9

South Dakota Y 9

Tennessee Y 9

Texas Y 9

Utah Y 9

Vermont Y 9

Virginia Y 9

Washington Y 9

West Virginia Y 9

Wisconsin Y 9

Wyoming Y 9

SOURCE: State Food Stamp Program Director Survey.

n.a. = Not applicable.
TABLE E3

SOPHISTICATION OF STATE TRACKING SYSTEMS

State

No State-Wide 

Automated 

Tracking System

Months of Receipt of TimeLimited Benefits Not 

Indicated

Months of Receipt of TimeLimited Benefits Indicated, 

Eligibility Not Determined 

Automatically

Months of Receipt of TimeLimited Benefits Indicated, 

Eligibility Determined 

Automatically

Alabama 9

Alaska 9

Arizona 9

Arkansas 9

California 9

Colorado 9

Connecticut 9

Delaware 9

District of Columbia 9

Florida 9

Georgia 9

Hawaii 9

Idaho 9

Illinoisa

Indiana 9

Iowa 9

Kansas 9

Kentucky 9

Louisiana 9

Maine 9

Maryland 9

Massachusetts 9

Michigan 9

Minnesota 9

Mississippi 9

Missouri 9

Montana 9

Nebraska 9

Nevada 9

New Hampshire 9

New Jersey 9

New Mexico 9

New York 9

North Carolina 9

North Dakota 9

Ohio 9

Oklahoma 9

Oregon 9

Pennsylvania 9

Rhode Island 9

South Carolina 9

South Dakota 9

Tennessee 9

Texas 9

Utah 9

Vermont 9

Virginia 9

Washington 9

West Virginia 9

Wisconsin 9

Wyoming 9

SOURCE: State Food Stamp Program Director Survey.

a

 Illinois did not track ABAWDs at the time of the survey, but does have tracking capabilities.

Online Benefit History Available 
TABLE E4

 PROBLEMS ENCOUNTERED TRACKING FOOD STAMP RECEIPT IN OTHER LOCALITIES IN STATE

Type of Problems Encountered

State

State Requires Caseworkers to 

Check for Prior Receipt In Other 

Localities In State

 Problems 

Encountered

Database 

Incorrect

Database Does Not 

Track ABAWDs for 36 

Months

Difficulties 

Contacting Other 

Offices

Time 

Consuming New System

Alabama Y

Alaska Y 9 9

Arizona Y

Arkansas Y

California Y

Colorado Y

Connecticut Y

Delaware Y

District of Columbia n.a.

Florida Y

Georgia Y

Hawaii Y 9 9

Idaho Y

Illinois Y 9 9

Indiana Y

Iowa Y

Kansas Y

Kentucky Y

Louisiana Y

Maine Y

Maryland Y

Massachusetts Y

Michigan Y

Minnesota Y

Mississippi Y

Missouri Y

Montana Y 9 9

Nebraska Y

Nevada Y

New Hampshire Y

New Jersey Y 9 9

New Mexico Y 99 9 9

New York Y 9 9

North Carolina N 99 9 9 9

North Dakota N

Ohio Y

Oklahoma Y

Oregon Y

Pennsylvania Y 9 9

Rhode Island Y

South Carolina Y

South Dakota Y

Tennessee Y

Texas Y

Utah Y

Vermont Y

Virginia Y

Washington Y

West Virginia Y

Wisconsin Y

Wyoming Y

SOURCE: State Food Stamp Program Director Survey.

n.a. = Not applicable.
TABLE E5

PROBLEMS ENCOUNTERED TRACKING FOOD STAMP RECEIPT IN OTHER STATES

Problems Encountered

State

State Requires 

Caseworkers to 

Check for Prior 

Receipt

Problems 

Encountered

Difficulties 

Contacting 

Office

Time 

Consuming

Information Not 

Available

Alabama 9

Alaska 99 9

Arizona 9

Arkansas

California 9

Colorado 9

Connecticut 9

Delaware 9

District of Columbia

Florida 9

Georgia 9 999

Hawaii 9

Idaho 9

Illinois

Indiana 9 99

Iowa 9

Kansas 9

Kentucky 9 99

Louisiana 9

Maine 9

Maryland 999

Massachusetts 9

Michigan 9

Minnesota 9 999

Mississippi 9 999

Missouri

Montana 9

Nebraska 9

Nevada 9 9 99

New Hampshire 9

New Jersey 99 9

New Mexico 9 99

New York 9

North Carolina 9 999

North Dakota 9

Ohio 9

Oklahoma 9 9999

Oregon 9

Pennsylvania 9 999

Rhode Island 9

South Carolina 9

South Dakota 9

Tennessee 9

Texas

Utah 9

Vermont 9

Virginia 9

Washington 9

West Virginia 9

Wisconsin 9 99

Wyoming 9

SOURCE: State Food Stamp Program Director Survey.
TABLE E6

DIFFICULTIES USING 15 PERCENT EXEMPTION

State

Experienced 

Difficulty Using 

15% Exemption

Counties Do Not 

Know How To 

Implement

Estimating Size 

Of Group 

Affected

Tracking 

Exemptions

Time 

Consuming To 

Train Staff

Alabama

Alaska

Arizona Y 9

Arkansas

California Y 9

Colorado

Connecticut

Delaware

District of Columbia

Florida

Georgia

Hawaii Y

Idaho

Illinois

Indiana

Iowa

Kansas

Kentucky

Louisiana

Maine Y 9

Maryland

Massachusetts

Michigan

Minnesota Y 9

Mississippi

Missouri

Montana

Nebraska

Nevada

New Hampshire

New Jersey Y 9

New Mexico

New York

North Carolina Y 9

North Dakota

Ohio

Oklahoma

Oregon

Pennsylvania Y 9

Rhode Island Y

South Carolina

South Dakota

Tennessee

Texas

Utah Y 9

Vermont

Virginia

Washington

West Virginia Y 9

Wisconsin

Wyoming

SOURCE: State Food Stamp Program Director Survey.

Nature Of Difficulty
TABLE E7

PARTIALLY WAIVED AREAS

Offices With Partially-Waived Areas

Partial-Waived Areas Cause Difficulties

State

Offices with PartiallyWaived Areas? Difficulties?Explaining Rules 

to Clients

Tracking Street 

Address

Worker 

Confusion

Alabama N

Alaska N

Arizona N

Arkansas Y 

California Y Y 

Colorado Y 

Connecticut Y Y 9

Delaware n.a.

District of Columbia N

Florida N

Georgia Y 

Hawaii N

Idaho Y 

Illinois Y 

Indiana Y 

Iowa n.a.

Kansas n.a.

Kentucky Y 

Louisiana Y Y 9 9

Maine Y Y 9 99

Maryland N

Massachusetts n.a.

Michigan n.a.

Minnesota Y 

Mississippi n.a.

Missouri N

Montana N

Nebraska N

Nevada Y 

New Hampshire n.a.

New Jersey Y Y 9

New Mexico Y Y 9

New York Y 

North Carolina n.a.

North Dakota N

Ohio n.a.

Oklahoma n.a.

Oregon n.a.

Pennsylvania Y 

Rhode Island Y 

South Carolina N

South Dakota Y 

Tennessee Y 

Texas N

Utah N

Vermont Y 

Virginia N

Washington N

West Virginia N

Wisconsin n.a.

Wyoming Y 

SOURCE: State Food Stamp Program Director Survey.

n.a.= Not applicable
APPENDIX F 

DETERMINANTS OF THE PROPORTION OF ADULT FSP 

PARTICIPANTS SUBJECT TO THE TIME LIMIT

 F-1 

The proportion of adults subject to the time limit varies from state to state. To what extent is 

this related to the variation in state ABAWD policies? We used multivariate analysis to test the 

relationship between policies on ABAWDs and the proportion of adult FSP participants who are 

subject to the ABAWD time limit. This appendix describes the methodology and results of this 

analysis. 

The multivariate analysis was conducted in two steps. First, we ranked the individual state 

ABAWD policies as being “strict” or “lenient”. Next, we conducted regression analysis to 

determine the relationship between the state policies and the proportion of adults that are subject 

to the ABAWD time limit in each state. 

A. MEASURES OF STATE ABAWD POLICIES 

Of the state ABAWD policies discussed in Chapters III and IV, we identified six that will 

likely have the largest impact on the number of ABAWDs subject to the time limit in each state: 

(1) policy to certify an ABAWD as unfit for employment; (2) policy on exemption because of 

care of a dependent child; (3) use of ABAWD waivers; (4) use of the 15 percent exemption; (5) 

policy on how the three month time limit is definied; and (6) policy on tracking the three month 

time limit. For each state, we ranked each policy as either “strict,” “moderate” or “lenient” 

(Table F.1). All else being equal, a policy that is “strict” will result in more ABAWDs subject to 

the time limit, while a policy that is “lenient” will result in fewer ABAWDs subject to the time 

limit. 

For the multivariate analysis, we created six distinct variables that reflect the ranking for 

each of these policies (Table F.2). Each of these variables takes on a value of 0 if the policy is 

strict, 1 if the policy is moderate and 2 if the policy is lenient. We also created an aggregate 

policy measure equal to the sum of the six individual policies. The minimum possible value for 
 F-2 

TABLE F.1 

STATE POLICY RANKING CRITERIA 

Policy Strict Moderate Lenient 

Requirements for Disability 

Certification 

Clients can be certified 

based neither on 

caseworker observation 

nor on self-report 

Clients can be certified 

based on caseworker 

observation but not selfreport, or policies vary by 

county 

Clients can be certified 

based on self-report 

Dependent Child 

Exemption 

Only one adult per 

household is exempt, or 

maximum age for 

dependent children is 

under 17 

Multiple adults but not all 

adults exempt, and 

maximum age for 

dependent children is 17 or 

older 

All adults exempt if a 

dependent child is in the 

household and maximum 

age for dependent children 

is 17 or older 

Waiver Use State does not use waivers State uses waivers and the 

proportion of adult FSP 

participants in waived 

areas is below national 

median 

State uses waivers, and the 

proportion of adult FSP 

participants in waived 

areas is above national 

median 

15 Percent Exemption Use State does not use 15 

percent exemption 

State uses 15 percent 

exemption, but uses less 

than 10 percent of its 

allotment 

State uses 15 percent 

exemption and uses more 

than 10 percent of its 

allotment 

First Month of Time 

Limited Benefits 

First month is month of 

application 

First month is month case 

is certified, first month any 

benefits are received, or 

month of application if 

before mid-month 

First month is first full 

month of benefits 

Method of Tracking State uses a rolling clock State uses a fixed clock 

that varies among 

ABAWDs 

State uses a fixed clock 

that is the same for all 

ABAWDs 

 

the aggregate measure is 0, an indication that all of the state’s policies are strict; the maximum 

possible value is 12, an indication that all of the state’s policies are lenient. 
 F-3 

TABLE F.2 

STATE ABAWD POLICY RANKINGS 

State

Requirements 

for Disability 

Certificationa

Dependent 

Children 

Exemptiona W aiver Usea

15 Percent 

Exemption 

Usea

First Month of 

Time Limited 

Benefits a

Method of 

Trackinga

Aggregate 

Policy 

Measureb

Alabama 1110003

Alaska 2021227

Arizona 2111227

Arkansas 0222228

California 1201216

Colorado 1211227

Connecticut 0221207

Delaware 2 1 0 0 2 0 5

Florida 1021004

Georgia 2121228

Hawaii 2211208

Idaho 1101225

Illinois 2 2 2 2 2 0 10

Indiana 1111206

Iowa 0200204

Kansas 0102225

Kentucky 1122107

Louisiana 2122209

Maine 2121016

Maryland 1122228

Massachusetts 1202227

Michigan 2200125

Minnesota 0112206

Mississippi 1102206

Missouri 0211206

Montana 2120227

Nebraska 1212208

Nevada 0111205

New Hampshire 0102003

New Jersey 2220006

New Mexico 1220005

New York 1011205

North Carolina 2102106

North Dakota 1210105

Ohio 1100204

Oklahoma 2200105

Oregon 0101224

Pennsylvania 0020224

Rhode Island 0020204

South Carolina 1111226

South Dakota 2220228

Tennessee 1111125

Texas 2110105

Utah 0212207

Vermont 0211206

Virginia 1210115

W ashington 1122228

W est Virginia 1221218

W isconsin 2200226

W yoming 1110205

a

A value of 0 indicates the policy is strict; a value of 1 indicates the policy is m oderate; a value

 of 2 indicates the policy is lenient.

b

Equals the sum of the six individual policy rankings.
 F-4 

B. MULTIVARIATE ANALYSIS 

To understand the impact of ABAWD policies on the number of ABAWDs in each state, we 

estimated the following model: 

A = P E Ls ss s s λ ++ + β ψ ε

where 

 As = the proportion of adults in nonwaived areas in state s who are ABAWDs subject to 

the time limit 

 Ps = vector of state ABAWD policies for state s

 Es = vector of state economic conditions for state s

 Ls = estimated 1996 proportion of adults in state s that are ABAWDs 

 

 

The dependent variable (As) reflects the extent to which adult FSP participants in each state 

are subject to the ABAWD time limit. We restrict the analysis to nonwaived areas because no 

adults in waived areas are subject to the time limit. We exclude from the analysis Illinois and 

Arkansas for similar reasons – these states use their 15 percent exemption to exempt all adults 

from the time limit. 

For the basic model, we include in the vector Ps the six state ABAWD policy rankings 

discussed above. We would expect policies that are more lenient to lead to a decrease in the 

proportion of adults that are subject to the time limit as lenient policies exclude more adults from 

the time limit (in other words, we expect the coefficients of the policy variables to be negative). 

We also include two variables that measure the work activities and E&T services provided 

to ABAWDs. The first variable is the proportion of each state’s allocation of federal E&T funds 

for ABAWDs that was spent. The second variable is a dummy variable indicating that the state 

provides qualifying work activities to ABAWDs who lost their eligibility and are no longer 

participating in the FSP. We expect states that spend more money on E&T to ABAWDs will 

have more ABAWDs receiving food stamps because more will meet the work requirement. 
 F-5 

Similarly, states that provide qualifying work activities to nonparticipants will help 

nonparticipants regain eligibility and thus increase the proportion of adults that is ABAWDs. 

We included in the vector Es the state unemployment rate in 1999 and a dummy variable 

indicating that the proportion of the state population that lives in urban areas is in the 90th

percentile of the national distribution. Given the complex relationship between economic 

conditions, waivers, work requirement rules and the time limit, it is unclear how the economic 

variables should affect the proportion of adults that is ABAWDs. For instance, high 

unemployment rates will lead more ABAWDs to participate in the FSP, but proportionately 

fewer will meet the work requirement and thus lose eligibility because of the time limit. 

The results of the basic model show that policies have a small influence on the proportion of 

adults that are ABAWDs (Table F.3). The only two policies that have a statistically significant 

relationship with this measure are the states’ use of waivers and the proportion of the states’

allocation of E&T funding that was spent. The negative coefficient on the waiver policy variable 

suggests that states apply waivers to areas that contain a disproportionately high share of 

ABAWDs, and as a result, the nonwaived areas tend to have a disproportionately low share. It 

could be the case that states intentionally select for waivers areas with a high proportion of 

ABAWDs. Alternatively, it could be the case that the areas eligible for waivers – those with high 

unemployment rates – are also areas with high proportions of ABAWDs. The positive 

coefficient on the E&T funding variable suggests that states which spend more money on E&T 

have more adults subject to the time limit. This may occur because more ABAWDs are meeting 

the work requirement through E&T in these states, as opposed to losing eligibility. 

Overall, this model explains little of the variation in state ABAWD populations. No other 

variables had a significant effect on the ABAWD population in the basic model. Neither the 

variation in state economic conditions nor the pre-welfare reform size of the ABAWD caseload 
 F-6 

TABLE F.3 

RESULTS OF REGRESSION MODELS

Model 1: Model 2: Model 3:

Basic Aggregate Policy PRA Measure

Model Measure Included

Intercept -0.10 1.24 0.24

( 2.36 ) ( 2.16 ) ( 2.24 )

State Unemployment Rate in 1999 0.40 0.18 0.12

( 0.40 ) ( 0.37 ) ( 0.40 )

Metro Population Dummy 0.34 -0.24 -1.84

(State in 90th Percentile) ( 0.98 ) ( 0.99 ) ( 1.34 )

Pre-Welfare Reform ABAWD Proportion 0.20 0.19 0.21

( 0.13 ) ( 0.13 ) ( 0.13 )

Proportion of 1996 Non-Elderly That Are 0.14 *

Permanent Resident Aliens ( 0.06 )

Policy Variables

Aggregate Policy Variable 0.09

( 0.20 )

Waiver Use Rating -1.07 * -0.73

( 0.50 ) ( 0.49 )

15 Percent Exemption Use Rating -0.12 -0.07

( 0.52 ) ( 0.49 )

Disability Certification Policy Rating 0.26 0.18

( 0.53 ) ( 0.50 )

Dependent Child Policy Rating 0.32 0.39

( 0.60 ) ( 0.57 )

First Month of Time Limit Rating 0.57 0.62

( 0.58 ) ( 0.55 )

Tracking Policy Rating 0.24 0.31

( 0.41 ) ( 0.39 )

Qualified Work Activities for -1.20 -1.26 -1.20

Nonparticipants (Dummy Variable) ( 0.95 ) ( 0.93 ) ( 0.90 )

Percent of E&T Funding Spent 3.01 * 2.43 2.11

( 1.47 ) ( 1.47 ) ( 1.44 )

R2 0.2962 0.1377 0.3853

Adjusted R2 0.0811 0.0115 0.1746

Number of Observation 48 48 48 

Degrees of Freedom 36 41 35 

Standard errors presented in parentheses.

*Significant at the 90 percent level of confidence.
 F-7 

can explain the proportion of adults that is ABAWDs in 2000 (although the latter does border on 

statistical significance). 

In an alternative specification of the basic model, we replaced the six policy rankings with 

the aggregate policy ranking discussed above. As with the first model, this model explains little 

of the variation in state ABAWD populations. No variable in this model has a significant impact 

on the proportion of adults that is ABAWDs. 

Another variation of the first model includes a variable measuring the proportion of the FSP 

population in each state that is permanent resident aliens (PRAs). This variable has a significant 

positive impact, and the inclusion of this variable more than doubles the model’s adjusted R2. 

However, there is not a strong conceptual basis for understanding why the relative size of the 

PRA caseload would have such a large impact on the relative size of the ABAWD caseload. We 

suspect that the PRA variable is actually capturing the effects of other factors that are correlated 

with the PRA caseload. Efforts to identify those other factors were unsuccessful. One theory is 

that states with large PRA caseloads were also states with large urban populations – and as such 

have larger ABAWD populations. However, measures of the proportion of each state’s 

population that is urban typically were not significant, and they did not reduce the impact of the 

PRA variable on the adjusted R2

. 

In addition to these three models, we estimated other specifications of the basic model that 

included such explanatory variables as: 

• Number of qualifying work activities for ABAWDs in each state 

• Number of supportive services provided to ABAWDs in each state 

• A dummy variable indicating that the state offers qualifying work activities to 

nonparticipants 

• A dummy variable indicating the state intends to use 100 percent of future E&T funds 

• A dummy variable indicating that volunteer work counts as a qualifying work activity 
 F-8 

• State unemployment rates weighted by the proportion of each state’s population in 

nonwaived areas 

• Quadratic functions of state unemployment rates 

• Dummy variables indicating a state’s unemployment rate is in the highest 5 or 10 

percent of the nation 

• The proportion of each state’s population in metropolitan areas weighted by the 

proportion of the state’s population in nonwaived areas 

• Dummy variables indicating that the proportion of a state’s population in 

metropolitan areas is in the top 5 or 10 percent of the nation 

None of the alternative specifications performed better than the basic model. In most cases, the 

results were consistent with the basic model: few variables were significant, and R2

 values were 

low. Most showed that state waiver policies are the only policies with a significant impact on the 

proportion of adults that is ABAWDs. Moreover, they continue to show that state-level 

economic conditions have little influence. 

Thus, most of the variation in state ABAWD populations is unexplained by our models. 

Sampling error (for some states) and measurement error may account for some of the variation 

(while sampling error does not bias the coefficients, measurement error may). Additionally, our 

models may not appropriately measure the effects of policies on ABAWDs. For instance, the 

policies may interact in ways not specified in the models. Moreover, the aggregate state 

unemployment rates may not capture the effects that local unemployment rates have on the 

ABAWD population. Still, the results appear to suggest that there are other factors besides those 

in our models that account for the variation in the number of ABAWDs across states.