JCAR tables attempt to invalidate ODJFS SNAP rules after debate over ABAWD exemptions

The Joint Committee on Agency Rule Review on the record reviewed Ohio Department of Job and Family Services rules (5101:4-3-11 and 5101:4-3-13) to implement recent SNAP work requirement changes, focusing on whether Ohio must tie ABAWD exemptions to general work-registration exemptions or may evaluate them independently. Representative Brennan moved to recommend invalidation of the rules; the committee later voted to table that motion.

Representative Brennan, who introduced the invalidation motion, argued that federal guidance treats the two sets of SNAP work requirements as distinct and that Ohio's approach could produce "an absurd result" in which a birthday alone could change a person's eligibility. Brennan said USDA/FNS materials and state practice in other jurisdictions suggest exemptions for the able-bodied adults without dependents (ABAWD) population should be screened separately from general work-registration exemptions.

Rachel Johansson, policy director at the Ohio Department of Job and Family Services, told the committee the department views the question as legal rather than philosophical and cited timing and federal compliance concerns. Johansson said ODJFS had asked USDA for clarification but had not received a timely response and that HR1 took effect in July 2025. She warned that a different interpretation could risk a federal management-evaluation finding by FNS and higher payment-accuracy error rates that might lead to cost-sharing of SNAP benefits.

An unnamed ODJFS bureau chief for SNAP and TANF policy echoed that the department continued to screen for ABAWD exemptions for the affected age group and explained that Ohio historically used a "funnel" approach, screening for general work-registration exemptions first and then ABAWD exemptions; HR1 separated those age ranges, complicating the prior process.

Committee members asked whether other states had adopted Ohio's approach. ODJFS said it surveyed other states and found about 17 states in an unclear category, roughly 15 states taking the same interpretation as Ohio, and the remainder taking a different approach. Members noted some states remain under waivers, which affects whether they have adopted rules.

Representative Brennan moved that JCAR recommend invalidation of the two rules on the ground they "implement a federal law in a manner more stringent or burdensome than what federal law requires." Senator Schafer subsequently moved to table the invalidation motion. The roll call on the tabling motion recorded votes as follows: Gavrun Yes; Callender Yes; Brenner Yes; Schaefer Yes; Craig Yes; Mora No; Matthews Yes; Santucci Yes; Brennan No; Piccolantonio No. With a sufficient majority, the committee tabled the invalidation motion.

The committee did not adopt a recommendation of invalidation at this meeting. Chair announced the next JCAR meeting for April 13, 2026, at 1:30 p.m. in the Finance Hearing Room.

Why it matters: The dispute centers on how Ohio applies federal SNAP work requirements and exemptions after HR1. If the department's stricter interpretation stands and is later upheld by federal auditors, it could reduce benefit eligibility for some in the 60-to-64 age bracket; if federal guidance permits a more generous reading, Ohio could revise rules later. The committee's tabling of the invalidation motion leaves the rules in effect while the debate continues.