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.)