County Welfare Directors (CWDs) must ensure equal access to Refugee Cash Assistance (RCA), Entrant Cash Assistance (ECA), and Trafficking and Crime Victims Assistance Program (TCVAP) cash aid for individuals with disabilities. Reasonable accommodations may involve waiving rules or modifying procedures to enable individuals with disabilities or their associate’s full access to programs while avoiding sanctions. During all stages of aid administration, CWDs must proactively identify needs and respond accordingly. Requests can be made at any time and in any form. Additionally, there is no cap on the number of accommodations individuals may request.
Notice of accommodation rights may be provided verbally in face-to-face interviews, group presentations, in written communications, or through published materials such as posted notices and outreach materials in newspapers. Notices must always be given in plain language.
CWDs are required to notify RCA/ECA and TCVAP cash aid applicants/recipients of their rights through California Department of Social Services Publication 86/13 and on CWD-generated recruitment materials in all languages translated by the California Department of Social Services. Posters must be prominently displayed in all CWD waiting rooms and reception areas. All web pages with general information about RCA/ECA and TCVAP cash aid must contain a nondiscrimination statement. Additionally, webpages must have accurate and clear information about programs serving noncitizens.
When a disability is known or obvious, the CWD must determine whether an RCA/ECA or TCVAP cash aid applicant/recipient needs additional assistance while identifying disability-specific accommodations. When communication limits the ability to determine whether an applicant or recipient has a known or obvious disability, CWDs are required to establish virtual screening questions for all intakes and redeterminations.
An applicant/recipient does not need to disclose a specific diagnosis or condition before requesting accommodation, and a CWD cannot ask for verification nor challenge the legitimacy of the accommodation. CWDs must accommodate individuals with Limited English Proficiency and provide auxiliary aids, such as interpreters, Braille, or large print materials, at all stages of the intake and redetermination process.
Staff must initiate offers of accommodation during any point of interaction, regardless of whether the individual explicitly uses the word “disability,” and requests must be honored unless they impose an undue burden or fundamentally alter the program. Denials require high-level review and documentation by the CWD Director or their designee.
RCA/ECA and TCVAP applicants/recipients may request reasonable accommodation at any time, in any form (in person, phone, writing), by themselves or through a representative. Requests can be modified or withdrawn, and no special forms or procedures are required. Accommodations may apply across all program stages and components, including applications, redeterminations, rights notifications, employment services/education, exemptions, extensions, sanctions, participation support, appeals, and fraud investigations.
No specific terminology is required, and requests may be made in descriptive or indirect language. Staff must recognize these, ask whether the request is related to a disability, and clarify the type of assistance needed. Requests may also be made due to the disability of someone associated with the applicant (e.g., a caregiving situation). The ADA does not require disclosure or verification of a medical diagnosis; only a disability-related need for the accommodation must be stated. Staff cannot challenge the legitimacy of the disability but may ask clarifying questions to understand the limitation or the connection between the disability and the accommodation.
If agreement is not immediate, the CWD must begin the “interactive process” to explore solutions. All requests must be considered, and accommodations granted as requested or mutually agreed upon through this process, unless legally valid grounds exist for denial.
A CWD may deny a reasonable accommodation request only if it would fundamentally alter the program, service, or activity, or impose an undue financial/administrative burden. Such denials must be decided by the CWD Director or designee, and the fact that a request falls outside usual program rules is not sufficient grounds for denial. CWDs must document all disability-related disclosures, reasonable accommodation requests, and subsequent actions in the applicant’s/recipient’s case file
CWDs must provide civil rights training to all public contact staff (eligibility workers, employment specialists, domestic abuse providers, supervisors, program managers, reception, clerical staff, appeals specialists, civil rights staff, etc.) at least every two years, though annual training is encouraged. CWD’s are required to train public contact staff, program managers, and supervisors upon hire and, at a minimum, annually providing reasonable accommodations to people with disabilities. Training must cover how to notify applicants/recipients of their rights, identify disabilities, respond to and document accommodation requests, and check case files for noted needs. Practice exercises on giving notice and offering accommodations are recommended.
Americans with disabilities act (ADA) compliance may require exceptions to RCA/ECA and TCVAP program rules, so staff must be trained on both program rules and nondiscrimination laws, including how to resolve conflicts. These obligations extend to contractors and vendors providing direct. Additional recommended training includes culturally competent service delivery, trauma-informed care, working with victims of crime/trafficking and PTSD, and addressing language and cultural barriers to avoid traumatization and promote safety and trust.
Under the ADA and Rehabilitation Act, CWDs must ensure effective communication with applicants, recipients, the public, and their companions. Qualifying companions include family, friends, or a guardian representative. To do so, they must provide needed auxiliary aids and services such as devices or support services. Primary consideration must be given to the individual’s requested aid or service. CWDs must also guarantee effective communication across all delivery methods (phone, digital, in-person) and ensure staff are trained to access and use these aids.
CWDs must provide individuals with disabilities equal opportunity to participate in and benefit from Employment Servies and Employment-Directed Education/Training. RCA/ECA and TCVAP recipients are generally required to participate unless exempt. Disability alone does not automatically exempt them. CWD’s must ensure access to all programs, not just programs and services designed solely for individuals with disabilities. Collaboration with disability-serving organizations is encouraged to reduce workforce barriers.
Because disabilities vary widely, assessments must be individualized to identify strengths and appropriate services. Where disabilities interfere with participation, CWDs must provide reasonable accommodations, such as adjusting required hours or activity types. Participants should also be informed of their right to request workplace accommodations.
CWDs may find “good cause” for a participant’s noncompliance with Employment Services or Employment-Directed Education requirements. CWDs must consider whether the individual’s physical or mental impairment, illness, or caregiving responsibilities prevented them from participating. Determination must be based on the individual’s reported challenges. If disability-related information emerges during this process, CWDs must offer, document, and provide reasonable accommodations.
If a participant fails to meet program requirements, it may be due to the CWD’s failure to offer or provide necessary reasonable accommodations. If an individual is sanctioned for not being offered needed accommodation, they may file a disability discrimination complaint in addition to an appeal of the sanction.
Individuals who have physical or mental impairment that prevents them from participating in employment or training programs are exempt from Employment Services or Employment-Directed Education/Training requirements. Similarly, individuals who are temporarily unable to participate due to illness or injury may be exempt if a physician verifies their condition. CWDs must respond to each exemption notice by offering, documenting, and, if applicable, providing accommodation in all areas of program participation.
Individuals may require both language services and disability-related accommodations to participate fully in RCA/ECA and TCVAP cash aid. CWDs are required to identify and offer accommodation regardless of language barriers and must provide certified bilingual staff or interpreters with the necessary language skills. Individuals may not be aware that they can request both language assistance and accommodations. Staff must proactively ensure both needs are addressed. (ACL 24-67, October 4, 2025.)
