Documentation of reasonable accommodation in CalSAWS.

The California Department of Social Services (CDSS) has issued guidance regarding documentation of reasonable accommodation in the California Statewide Automated Welfare System (CalSAWS).

This guidance applies to individuals with a “disability” as defined under the Americans with Disabilities Act (ADA). Some CDSS programs have their own definition of disability for purposes of determining eligibility, and may have their own requirements for documenting and qualifying disability. This ACL does not change program definitions or requirements, and meeting the requirements of this ACL does not fulfill any program-specific requirements and vice versa.

The County must document all disclosures of disability, requests for and offers of reasonable accommodations, and subsequent actions taken by the County, in the applicant’s/recipient’s case file. This also includes auxiliary aids and service. This documentation must include:

  • The fact that an applicant/recipient has a disability and/or has requested an The applicant/recipient is not required to provide a specific diagnosis;
  • The accommodation(s) requested by the applicant/recipient, if applicable, and
  • The accommodation(s) provided to the applicant/recipient.

Counties can learn about an applicant’s/recipient’s need for a disability-related accommodation in many ways, including but not limited to verbal request, case record information, and e-application responses. For example, a “yes” in response to the question “Are you a person with a disability” informs the county of a disability. Counties must offer reasonable accommodation when an individual’s disability is known or their need for reasonable accommodation is obvious.

The individual is not required to provide or verify a specific diagnosis to qualify as disabled under the ADA. An individual’s disability is considered documented in the case journal when the County has confirmed there is no need for accommodation, including documenting that reasonable accommodation was offered and declined.

When an individual needs a reasonable accommodation, Counties must document this information in the Special Circumstances Details page in CalSAWS if there is a request for an accommodation, and in the Case Journal if an accommodation is offered and provided. This includes documenting discussion about effective alternatives like “interactive process” if the requested accommodation is not immediately agreed upon.

All Counties can allow staff access to the CalSAWS Special Circumstances Detail page.

Counties must manually migrate all existing, active reasonable accommodation information from its current location to the Special Circumstances Detail page as soon as possible but in no case later than 18 months from the release of this guidance (by July 1, 2027). These updates must also be documented in the case journal.

A County may only deny a reasonable accommodation request when the requested accommodation would either:

  • fundamentally alter the nature of the program, service, or activity; or
  • impose an undue financial or administrative burden on the program, taking into account all resources available to the program, service, or activity.

If a reasonable accommodation request is denied, the County must inform the individual of that denial in writing. The County’s denial letter must notify that that the reasonable accommodation request is denied, the reasons for the denial, and any other accommodation(s) offered and/or provided.

Employees who perform Program Integrity functions, including Special Investigation Unit (SIU) investigators and individuals contracted to conduct investigative work, must check the CalSAWS case record for the Special Circumstances icon prior to any contact with the subject of a fraud referral.

If an individual named in a fraud referral discloses a previously unidentified disability-related need for accommodation to an SIU investigator or other staff member performing Program Integrity-related work, must offer reasonable accommodation to the individual and document this information in the Special Investigations section “Note Detail” page.

A decision to deny a reasonable accommodation request based on the limited permissible grounds must be made by the County Director or their designee. SIU investigators and other staff members performing Program Integrity functions should elevate such issues accordingly if they arise.

Contractors who receive federal or state assistance through a County must comply with the requirements of the ADA, MPP Division 21, and other civil rights laws and regulations, and are required to provide written assurance of nondiscrimination as part of their contract with the County. They are responsible for ensuring that the documentation requirements in this letter are met, including by developing workarounds with contracted service providers who do not have direct edit access to CalSAWS.

The CWD must establish procedures to ensure:

  • That the CWD notifies the contracted service provider in writing if an applicant/recipient has a need for a reasonable accommodation that must be provided by or in coordination with the contractor.
  • That the agreed-upon accommodation is provided in all applicable settings and program contexts, and that such provision is documented at each instance either in the CalSAWS case journal as instructed above or in a different record maintained by the contractor that the CWD deems appropriate to maintain civil rights compliance
  • That contractors who are unable to edit or notate the CalSAWS case record directly notify the CWD in writing if an applicant/recipient discloses a new disability-related need for a reasonable accommodation to them so CWD staff can add the information to the CalSAWS Special Circumstances Detail page, and
  • That clear communication channels, authority structures, and documentation responsibilities exist between the CWD and its contractors to address these and all applicable requirements covered in this letter.

There is no limit to the number of accommodations an individual may request, and requests may change over time. The County is required to train public contact staff, program managers, and supervisors upon hire and, at a minimum, annually thereafter, on providing reasonable accommodations to individuals with disabilities

County staff should copy all disability-related information from other CalSAWS locations like the “Medical Condition” page to the Special Circumstances Detail page. There is no automatic requirement to copy such information from one location to the other. but, if an applicant/recipient has disability information documented in another CalSAWS location, and that person also needs a reasonable accommodation because of the same disability, then the County must document the relevant information in the Special Circumstances Detail page.

It is recommended that Counties use other CalSAWS locations such as county-created Flag Detail pages to document applicants’/recipients’ non-ADA-related information with the exception of a non-disability related literacy issue.  (ACL 25-87, December 22, 2025.)

CalWORKs pregnancy verification form

The California Department of Social Services has issued a new form for third party pregnancy verification. People pursuing financial benefits from CalWORKS must prove they are pregnant. This can be done temporarily by the pregnant applicant providing a sworn statement or verbal attestation and upon payment providing a signed Statement of Facts. Medical verification is still needed within 30 working days from the sworn statement. This new form allows a third party to provide pregnancy verification. Pregnant recipients with other eligible children in the home still need to verify their pregnancy with these methods. If a pregnant applicant has made an effort in good faith but is unable to provide verification, the County must assist the applicant. The County should use the new form to get the required third party verification. This form is not required if the individual is trying to get verification on their own.  (ACL 25-86, December 8, 2025.)

CalWORKs definition of fleeing felon

People who are fleeing to avoid prosecution, or custody and confinement after conviction, for a crime or an attempt to commit a crime that is a felony, are ineligible for CalWORKs.  Effective January 1, 2024, the definition of a fleeing felon for CalWORKs purposes changed.  Now, a person is considered a fleeing felon for CalWORKs purposes only if they have an outstanding felony warrant which contains the National Crime Information Center Offense Classification Codes Escape, Flight to Avoid, and/or Flight-Escape.

Counties must initiate action on a CalWORKs case when they receive information from law enforcement, or from the Fleeing Felon Match that an applicant or recipient is a fleeing felon pursuant to this definition, and law enforcement presents the felony arrest warrant to the county.

The county must process an application while waiting for verification of fleeing felon status and must process the case within required processing timeframes.  If fleeing felon status is verified later, there will be an overpayment.

Counties must continue to use the Fleeing Felon Match report to identify potential fleeing felons.  When the county receives information about a case, the county must verify the identity and that the warrant is active.  There is no requirement that the individual knows about the warrant.  For probation or parole violators, the county must verify the identity, whether the violation is current, and whether the issuing agency is actively seeking the individual.

Because of federal and state confidentiality rules, information about potential fleeing felons or probation or parole violators can only be released to local, state, or federal law enforcement officers, unless release is otherwise authorized.  (ACL 24-70, October 25, 2024.)

Requirement to provide copies of electronically filed CalFresh applications and allow corrections

The California Department of Social Services has issued guidance regarding providing CalFresh households with a copy of their application. If the application was completed and signed with a telephonic or gestured signature then the county is required to promptly supply a copy of the application and instructions on how to fix any mistakes or omissions.

The applications completed on paper or electronically include any submitted in-person, online, by mail, by fax or other electronic transmission. Telephonic applications require the verbal assent of the household to be audio recorded in order to be valid. These may be completed over the phone. Gestured signatures include the use of signs and expressions communicating assent or agreement in American Sign Language (ASL), Manually Coded English (MCE), or another similar language or method during an interview in person or over video call. The requirement to provide copies of the application applies to both the original application and to recertifications.

For electronically signed applications, households have 10 days from the time of the completion of the electronic signature to review the information on the application and make any necessary changes. This can be done by crossing out incorrect information and writing in correct details. They may also call the county and submit the corrections online or visit the county office to submit corrections. This must be completed within that 10-day period but the applications do not need to be signed again.

Corrections made within the ten days following the completion of the signature are not considered mid-period reports and must be treated in accordance with application processing rules. Corrections are submitted after 10 days are considered mid-period reports. If incorrect benefits were given to the household because of late corrections, the CWD may make a claim for the amount over- or under- issued.  (ACL 25-83, November 19, 2025.)

Housing and Disability Advocacy program funding for Fiscal Year 2025-26

The Housing and Disability Advocacy (HDAP) program has been allocated $44.6 million through June 30, 2028.  HDAP provides housing-related financial assistance and supportive services The HDAP program provides housing supports and disability benefit advocacy to people experiencing homelessness or at risk of homelessness and who are likely eligible for disability benefits.

The requirement to collect Interim Assistance Reimbursement (IAR) from HDAP participants has been indefinitely removed.  IAR is collection of funds spent on the participant from the participant’s retroactive SSI award.  HDAP grantees may continue collecting IAR, as determined by the local program. However, client participation in IAR collection process must not be a condition of enrollment into the HDAP or permanent housing tenancy.

Counties operating a HDAP program will be required to implement a local complaint resolution process.  If program participants are not satisfied with the result of the local complaint resolution process, they will have the right to a California Department of Social Services (CDSS) administrative hearing.  Counties will be required to provide certain types of housing-related assistance pending the outcome of the hearing.  Assistance paid while the hearing is pending may be subject to overpayment.

Counties will be required to issue individualized, written housing plans outlining the housing related assistance to be provided to Home Safe recipients.

CDSS is expected to issue instructions about complaint resolution and housing plans in March, 2027.  Counties will be required to implement complaint resolution and housing plans within six months after CDSS issues its guidance.  (ACWDL, November 10, 2025.)

Bringing Families Home program funding for Fiscal Year 2025-26

The Bringing Families Home (BFH) program has been allocated $81 million through June 30, 2028.  BFH provides housing-related financial assistance and supportive services to families who are receiving child welfare services, including tribal child welfare services, and are experiencing or at risk of homelessness.

The dollar-for-dollar match requirement for Home Safe grantees has been removed.

Counties operating a BFH program will be required to implement a local complaint resolution process.  If program participants are not satisfied with the result of the local complaint resolution process, they will have the right to a California Department of Social Services (CDSS) administrative hearing.  Counties will be required to provide certain types of housing-related assistance pending the outcome of the hearing.  Assistance paid while the hearing is pending may be subject to overpayment.

Counties will be required to issue individualized, written housing plans outlining the housing related assistance to be provided to Home Safe recipients.

CDSS is expected to issue instructions about complaint resolution and housing plans in March, 2027.  Counties will be required to implement complaint resolution and housing plans within six months after CDSS issues its guidance.  (ACWDL, November 3, 2025.)