19 January 2005 FY 2005 Allocations of 15% Exemptions for ABAWDs and
Reporting Guidance
SUBJECT: |
Fiscal Year (FY) 2005 Allocations of the 15
Percent Exemptions for Able- Bodied Adults without Dependents (ABAWDS)
and Correct Reporting Procedures for FNS-583 form, “Food Stamp
Employment and Training (E&T) Program Activity Report” |
TO: |
All Regional Directors
Food Stamp Program |
For FY 2005, we are providing you with 2 lists of 15 percent ABAWD
exemptions. We are also providing guidance on reporting procedures for the
FNS-583 form for the portion dedicated to ABAWD information.
FY 2005 15 Percent ABAWD Exemptions (unadjusted):
Attachment A is a list of state-by-state 15 percent ABAWD exemptions for
FY 2005. 7 CFR 273.24 authorizes the Food and Nutrition Service to adjust
the number of 15 percent exemptions allocated to each State at the beginning
of the fiscal year to reflect changes in the States’ caseloads and our
estimate of changes in the proportion of food stamp recipients covered by
waivers.
We are no longer providing the charts that showed the allowable per
case-month exemptions by State and the number of persons that can be
exempted if no time limit was placed on exemptions; if a three-month time
limit was placed on exemptions; and if a 6-month time limit was placed on
exemptions. We believe these charts caused confusion and were not widely
understood or used by States.
FY 2005 15 Percent ABAWD Exemptions (adjusted for FY 2004 carryover):
Attachment B is the list of adjusted FY 2005 adjusted case-month
exemptions. These figures include the number of 15 percent exemptions used
by States that were reported in their final FY 2004 FNS-583 reports.
Based on our calculations, four states [Arizona, Illinois, Kansas, and
South Carolina] used more exemptions than they were allotted in FY 2004.
When we added their negative numbers from FY 2004 to the FY 2005 exemptions,
the adjusted amounts were a negative number. Therefore, these states have no
15 percent exemptions for FY 2005. Please notify these states that they must
immediately cease granting ABAWD exemptions in areas that are not exempt by
an ABAWD waiver.
The following states have not submitted their final FY 2004 FNS 583
reports: California, Idaho, Montana, Nevada, and Oklahoma. As soon as we
receive these reports we will send you an updated 15 percent exemption list.
FNS-583 Report Guidance
We are taking this opportunity to provide guidance to States regarding
the quarterly FNS-583 report. There seems to be some confusion over the 15
percent ABAWD exemptions and how to report them on the quarterly FNS-583
report. We believe the regulation is very clear - “The State agency will
track the number of exemptions used each month and report this number to the
regional office on a quarterly basis as an addendum to the quarterly
Employment and Training Report (Form FNS-583) required by 7 CFR
273.7(c)(8).” [7 CFR 273.24(i)] The intent of the regulation is that States
monitor their monthly usage of 15 percent exemptions and report this
information to FNS on a regular basis.
Background
The Food Stamp Act of 1977 (FSA), as amended, allows States to exempt up
to 15 percent of unemployed ABAWDS from the 3-month time limit. The FSA
grants FNS the authority to determine the number of yearly exemptions for
each State. If, by the end of a fiscal year, a State did not use all its
ABAWD exemptions, it may carry over the balance into the next fiscal year.
If more exemptions are used than authorized in a fiscal year, the State’s
allocation for the next fiscal year will be reduced.
When we implemented the 15 percent exemptions, we stressed that the ABAWD
population is dynamic; its members will cycle on and off the Program, and/or
in and out of ABAWD status for a variety of reasons. Based on FNS analysis
of the longitudinal data from the Survey of Income and Program Participation
(SIPP), we created a statistical model that determined the average ABAWD who
reaches the 3-month time limit would likely remain on the Program an
additional 2.66 months if granted an exemption. However, the 2.66 month
estimate is just that – an estimate. The actual amount of time an average
ABAWD may remain on the Program may vary according to State conditions and
State policy choices. Therefore, when a State agency makes a determination
that an ABAWD qualifies for a 15 percent exemption, it must also take into
account the total number of months the individual will participate under the
exemption.
For example, a State is allocated 1,200 case months for a fiscal year. In
October, the State grants exemptions to 100 ABAWDS who reach the 3-month
time limit in that month and who are not otherwise eligible to continue
participation in the Program. These ABAWDS will, on average, need that
exemption for three months – October, November, and December.
When the State sends in its quarterly FNS-583 report, it should report
that it used 100 exemptions for October, 100 exemptions for November, and
100 exemptions for December. However, some States would report this
situation differently; they would report using 100 exemptions for October
and then zero exemptions for November and December. They incorrectly believe
they must report the number of actions taken in a month because the State
agency acted to exempt 100 ABAWDS in October for 3 months. This is an
incorrect interpretation of the FNS-583 reporting requirements. The State
agency is actually
under-reporting the number of 15 percent exemptions used. Moreover, the
State agency is applying a 15 percent exemption to a month the individual is
already exempt.
Current situation of 15 percent exemption usage:
In the first quarter of the current fiscal year, the Certification Policy
Branch (CPB) sends out a list of 15 percent case month exemptions allocated
to each State for that year. This list is meant to guide States in planning
how many ABAWDS they can exempt in a year. This list is in no way a
substitute for the requirement that State agencies track actual use of the
15 percent exemptions.
We are hearing from Regions that a growing number of States are using up
their case month exemptions in the first quarter of the fiscal year. We must
emphasize again that State agencies must ration their case month exemptions
so there are enough exemptions available to use in each month of the fiscal
year. Once a State uses up its annual allocation, we ask that they cease
from granting additional exemptions. If a State decides to continue to
exempt ABAWDS after reaching its annual exemption allocation, we will deduct
any “overage” from the next fiscal year’s allocation.
We suggest States visit the ABAWD section of our website to review the
various memorandums posted there. The website is
http://www.fns.usda.gov/fsp/rules/memo/PRWORA/abawds/ABAWDsPage.htm .
We also ask that you continue to work with your States in this important
program area.
Please contact Patricia Maggi (703) 305-2468 if you have any questions.
/s/
Patrick Waldron
Chief
Certification Policy Branch
Program Development Division
Attachments
-- FY 2005 Allowable per Case-Month Exemptions by State
-- FY 2005 ADJUSTED CASE-MONTH EXEMPTIONS BY STATE
Attachment A
FY 2005 Allowable per Case-Month Exemptions by State
UNADJUSTED FOR CARRY-OVER
Original Allocation |
|
Case-months |
Persons |
|
|
Case-months |
Persons |
State |
Allowed* |
Exempted** |
|
State |
Allowed* |
Exempted** |
Alabama |
1,762 |
663 |
|
Missouri |
2,085 |
784 |
Alaska |
0 |
0 |
|
Montana |
223 |
84 |
Arizona |
1,324 |
498 |
|
Nebraska |
385 |
145 |
Arkansas |
864 |
325 |
|
Nevada |
614 |
231 |
California |
7,923 |
2978 |
|
New Hampshire |
73 |
27 |
Colorado |
541 |
204 |
|
New Jersey |
733 |
276 |
Connecticut |
1,043 |
392 |
|
New Mexico |
659 |
248 |
Delaware |
161 |
60 |
|
New York |
3,629 |
1364 |
Dist. of Col. |
0 |
0 |
|
North Carolina |
0 |
0 |
Florida |
2,390 |
899 |
|
North Dakota |
167 |
63 |
Georgia |
2,579 |
970 |
|
Ohio |
3,650 |
1372 |
Guam |
23 |
9 |
|
Oklahoma |
1,602 |
602 |
Hawaii |
444 |
167 |
|
Oregon |
0 |
0 |
Idaho |
174 |
65 |
|
Pennsylvania |
3,170 |
1192 |
Illinois |
1,620 |
609 |
|
Rhode Island |
148 |
56 |
Indiana |
1,367 |
514 |
|
South Carolina |
0 |
0 |
Iowa |
527 |
198 |
|
South Dakota |
124 |
47 |
Kansas |
309 |
116 |
|
Tennessee |
3,942 |
1482 |
Kentucky |
997 |
375 |
|
Texas |
6,895 |
2592 |
Louisiana |
0 |
0 |
|
Utah |
252 |
95 |
Maine |
375 |
141 |
|
Vermont |
247 |
93 |
Maryland |
686 |
258 |
|
Virginia |
2,225 |
836 |
Massachusetts |
1,123 |
422 |
|
Virgin Islands |
26 |
10 |
Michigan |
0 |
0 |
|
Washington |
0 |
0 |
Minnesota |
820 |
308 |
|
West Virginia |
1,063 |
400 |
Mississippi |
993 |
373 |
|
Wisconsin |
624 |
235 |
|
|
|
|
Wyoming |
145 |
55 |
* Average monthly case-months allowed.
** Assumes the dynamic of a typical ABAWD FSP recipient remaining on program
for 2.66 months with no time limit.
For planning purposes ONLY. States need to count their exempted case months.
96 CWEP Adj. does not take into account states providing work opportunities
through the E&T program
Attachment B
FY 2005 ADJUSTED CASE-MONTH EXEMPTIONS BY STATE
(Includes FY 2004 carryover)
State |
Monthly |
Annual |
|
State |
Monthly |
Annual |
|
|
|
|
|
|
|
Alabama |
9855 |
118262 |
|
Montana ** |
|
|
Alaska |
789 |
9466 |
|
Nebraska |
1853 |
22235 |
Arizona |
0 |
0 |
|
Nevada ** |
|
|
Arkansas |
5530 |
66357 |
|
New Hampshire |
147 |
1766 |
California ** |
|
|
|
New Jersey |
5097 |
61167 |
Colorado |
1963 |
23556 |
|
New Mexico |
654 |
7850 |
Connecticut |
792 |
9498 |
|
New York |
26935 |
323215 |
Delaware |
1065 |
12780 |
|
North Carolina |
8195 |
98335 |
Dist. of Col. |
0 |
0 |
|
North Dakota |
965 |
11579 |
Florida |
2428 |
29141 |
|
Ohio |
24752 |
297018 |
Georgia |
15445 |
185335 |
|
Oklahoma ** |
|
|
Guam |
161 |
1932 |
|
Oregon |
5057 |
60688 |
Hawaii |
3119 |
37430 |
|
Pennsylvania |
3491 |
41888 |
Idaho ** |
|
|
|
Rhode Island |
795 |
9536 |
Illinois |
0 |
0 |
|
South Carolina |
0 |
0 |
Indiana |
9321 |
111847 |
|
South Dakota |
659 |
7904 |
Iowa |
973 |
11672 |
|
Tennessee |
10566 |
126797 |
Kansas |
0 |
0 |
|
Texas |
38127 |
457527 |
Kentucky |
6308 |
75690 |
|
Utah |
1368 |
16415 |
Louisiana |
868 |
10411 |
|
Vermont |
2150 |
25800 |
Maine |
1376 |
16513 |
|
Virginia |
15221 |
182652 |
Maryland |
2280 |
27359 |
|
Virgin Islands |
249 |
2988 |
Massachusetts |
5226 |
62706 |
|
Washington |
2358 |
28296 |
Michigan |
41084 |
493013 |
|
West Virginia |
5033 |
60397 |
Minnesota |
3605 |
43257 |
|
Wisconsin |
4660 |
55919 |
Mississippi |
9287 |
111441 |
|
Wyoming |
1137 |
13644 |
Missouri |
6724 |
80684 |
|
|
|
|
** No 4th quarter data.
Last
modified:
11/21/2008
|