HR1 caused substantial changes to noncitizen eligibility for CalFresh.  The California Department of Social Services (CDSS) will implement these changes effective April 1, 2026.  Counties cannot implement these changes prior to April 1, 2026. Counties cannot implement these changes by manual processes or system workarounds.

Under HR 1, individuals are eligible for CalFresh only if they reside in the United States and are either:

• United States citizens
• Noncitizen nationals

People born in American Samoa and Swain’s Island after December 21, 1952, or residents of the Northern Mariana Islands who choose not to become United States citizens

• Lawful Permanent Residents
• Individuals who reside in the United States in accordance with a Compact of Free Association, or
• Cuban and Haitian Entrants.

Certain categories are no longer eligible for CalFresh, but continue to qualify for an exemption from the five year waiting period, and therefore are eligible immediately when they become Lawful Permanent Residents.  Those categories are: noncitizens admitted to the U.S. as refugees  ,Noncitizens granted asylum, noncitizens whose deportations were withheld, Cuban and Haitian entrants, Compact of Free Association Citizens, Iraqis and Afghans with Special Immigrant Visas, certain Afghan Nationals Granted Parole Between July 31, 2021, and September 30, 2023, certain Ukrainian Nationals Granted Parole Between February 24, 2022, and September 30, 2024 noncitizens admitted to the United States as Amerasian immigrants, and victims of trafficking.

Categories of noncitizens who are no longer eligible for CalFresh are: asylees, refugees, parolees (unless they are Cuban or Haitian Entrents), individuals with deportation or removal withheld,  conditional entrants, victims of trafficking, battered noncitizens, certain Afghan Nationals granted parole between July 31, 2021, and September 30, 2023, and certain Ukrainian Nationals granted parole between February 24, 2022, and September 30, 2024.

Effective April 1, 2026, counties must apply these new rules for new applications, and for recertifications.  Effective April 1, 2026, counties must ask about where there has been a change in immigration status.  Immigration statues must be verified through the federal Systematic Alien Verification System.

Households are not required to report a change in immigrations status midperiod.

A SAVE match is considered Verified Upon Receipt. If a household disagrees with SAVE

An ineligible noncitizen household member’s resources must be included in the budget calculation to determine the benefit amount.  (ACL 25-92, December 31, 2025.)

HR1 caused substantial changes to the CalFresh time limit and work requirements.  The California Department of Social Services (CDSS) will implement these changes effective June 1, 2026.  Counties cannot implement these changes prior to automation in the CalSAWS computer system.  Counties cannot implement these changes by manual processes or system workarounds.

CalFresh recipients subject to the time limit are limited to three full months of countable benefits in a fixed 36-month period unless they are exempt from the time limit, satisfy the work requirement, live in a county with a waiver of the time limit, qualify for an additional three consecutive months of eligibility, or receive a discretionary exemption.

Under HR1, CalFresh recipients age 18 to 64 are subject to the time limit unless they are exempt.

CalFresh recipients age 60 or older remain exempt from work registration.  Recipients who are age 60 through 64 are exempt from work registration, but are still subject to the time limit unless they qualify for another work registration exemption or a time limit exemption.  ESAP households with individuals age 60 through 64 cannot be subject to time limits until they have been screened for exemptions.

HR1 created a new time limit exemption for individuals who meet the definition of Indian, Urban Indian, or California Indian in the Indian Health Care Improvement Act.  Self-attestation is sufficient to grant the exemption.

HR1 eliminated the time limit exemptions for veterans, individuals experiencing homelessness, and youth under age 25 who were in foster care on their 18th birthday.

HR1 limited the dependent child exemption to recipients who are either the parent of, or otherwise responsible for the care of, a dependent child under age 14.  A single dependent child under age 14 may exempt more than one adult if each adult independently meets the definition of being responsible for the child’s care.

Counties can only request verification to establish an exemption if verification is required by ACL 19-93 at pp. 11-21, or if the information provided is questionable.

Counties cannot take any negative action related to the time limit or work requirements on a case, until an individual who is subject to the time limit has been rescreened for exemptions and has been informed of the time limit and work requirements. Counties must complete or voluntarily offer exemption screening if an individual discloses that they may meet the criteria for an exemption.  Counties must screen each household member individually.

Beginning on June 1, 2026, counties must screen all recipient households at their next recertification and every subsequent recertification.  Counties cannot assign a countable month until exemption screening is completed.

Beginning June 1, 2026, new applicants must complete exemption screening at initial certification.

If an individual loses an exemption, the county cannot assign countable months until the individual is rescreened for exemptions.  Recipients must report mid-period if their income is over the Income Reporting Threshold, or their work hours drop below 20 hours per week or 80 hours per month.  If an individual reports a drop in work hours, the county must assess whether there is good cause or another exemption.  If an individual’s circumstances change mid-period to make them eligible for an exemption, the county must apply the new exemption within 10 days.

Beginning January 1, 2026, a new statewide time limits begins.  This means that individual subject to the time limit have three countable months in the period January 1, 2026 to December 31, 2028.

Noticing requirements for time limit rules are unchanged.

Individuals subject to the time limit may meet the work requirement by performing volunteer or community service hours.  Volunteer or community service hours can be combined with work or other qualifying activities to meet the work requirement.  Volunteer or community service hours must be verified.

California does not currently have any discretionary exemptions.  CDSS will release a letter with instructions when California is allocated new discretionary exemptions.  Counties must continue to evaluate recipients for exemptions or good cause not meeting the work requirement.  (ACL 25-93, December 31, 2025.)

The California Department of Social Services (CDSS) has issued questions and answers about mid-period reporting for CalFresh.

If the county cannot determine the impact of a mid-period report on the household’s benefits, the county must contact the household.  If that is unsuccessful, the county must document the information in the case record and send the household a No-Change Notice of Action.

When a household reports a change in shelter expense mid-period and does not provide the amount of the new shelter cost, the county must send the household a CW 2200 Request for Verification form.  The client’s statement of the new shelter cost is sufficient verification.  The County allow ten days to provide the verification.  If the household does not provide the information, the county must document the information in the case record and send a No-Change notice of action.  If the shelter expense information is questionable and verification is not provided, benefits must be recalculated without the shelter cost.

When a household reports an address change mid-period, the county must act on any change in shelter cost related to the address change. If the household does not provide the new shelter cost, the county can attempt to contact the household.  If that is not successful, the county must send a CW 2200 Request for Verification form to the household.  If the household does not provide the information within 10 days, the county calculates the benefits without the shelter cost.  Note that California has a waiver until June 30, 2026 that if the household does not provide new shelter cost information, the county will update the address but not change the shelter cost information until the next recertification or periodic report.

If a household makes a mid-period report and provides necessary information and/or verification, the county must determine if the information is a mandatory mid-period report or is verified upon receipt. If it is neither a mandatory mid-period report nor is verified upon receipt and the change would decrease benefits, the county does not act on it.  If the report will increase benefits, the county must act on it for the next monthly benefit allotment.

When a new household member is reported mid-period, the county does not consider the new household member’s income for purposes of the Income Reporting Threshold.  The county must update the household’s Income Reporting Threshold to reflect the new number of household members.

Counties do not verify changes in income from the same income source that are $50 or less.  However, counties must act upon changes in income from the same income source that are less than $50 if the additional income puts the family over the Income Reporting Threshold.

Households with income between 131 and 200 percent of the Federal Poverty Level do not have an income reporting threshold requirement.  Mid-period reports of income for those households are not actionable.

When multiple household composition changes are reported at the same time, the county can only act on the household composition changes that increase benefits.  (ACIN I-58-25, October 14, 2025.)

The United States Department of Agriculture has granted a CalFresh time limit waiver for Colusa, Imperial and Tulare Counties from November 1, 2025 to October 31, 2026.  This waiver was approved based on each of these counties having an average unemployment rate over 10 percent from July, 2024 to July, 2025.

Colusa, Imperial and Tulare Counties must remain ready to implement the time limit when the waiver expires.  These counties must identify clients subject to the time limit; screen for exemptions; inform clients of the time limit and work rules; and track work registration, time limit, and Employment and Training data.  (ACL 25-79, November 7, 2025.)