M E M O R A N D U M

TO:                 EES Program Administrators

FROM:           Carla Whiteside-Hicks, PhD. - EES Director

DATE:           September 25, 2026

SUBJECT:    Implementation Instructions - KEESM Revision 130

This memo provides implementation instructions and information for the following October 1, 2026, policy changes in the Kansas Economic and Employment Services Manual (KEESM).

Food Assistance

USDA Food and Nutrition Administration (FNA), formerly known as Food and Nutrition Services, released guidance for ABAWD policy changes stemming from the One Big Beautiful Bill Act of 2025. KEESM has been updated to align with federal regulations.

Effective October 1, 2026, KEESM 2521 is being updated to clarify that the exemption listed in KEESM 2521(1) applies to all ABAWDs, including those aged 60-64. This means that the work registrant exemptions listed in KEESM 3220 will apply to all ABAWDs, even those aged 60-64 who are not subject to work registrant rules. The only work registrant exemption that would not apply is KEESM 3220(8), a person who is age 60 or over, as the current ABAWD upper age limit is 64.

Reminder: Qualified non-citizens who do not have authorization to work in the United States shall be considered unfit for employment and exempt as a Work Registrant and/or ABAWD per KEESM 3220(2). The workaround outlined below applies to this population.

At the next case action (interim report, 12-month report, review, or change report), ABAWDs aged 60–64 who were not meeting or exempt from ABAWD provisions at any time from 11/01/2025 through the current date must be reviewed to determine whether they previously met or are currently meeting a work registrant exemption. Any countable ABAWD months applied to an ABAWD who had been meeting a verified exemption must be removed, and the exempt reason documented.

The workaround for entering an ABAWD Time Limit exemption for any exemption reason under KEESM 3220 is as follows:

1. When entering a time limit record, select Exempt from Work/Training Requirement for the status and “Workaround” for the reason.
   
   
2. Add a KEES journal entry: “Workaround applied for ABAWD exemption – “Exempt from Mandatory Work Registration”.

Example

1. A worker is processing an application for a household of 1. The PA is 61 years old and works a part-time job of 15 hours per week at $15 per hour. This meets the exemption under KEESM 3220(1) since the individual earns more than the federal minimum wage multiplied by 30 hours per week. This PA is an exempt ABAWD.