The California Department of Social Services has issued its seventh set of questions and answers about SB 1041. Most of the questions and answers involve data gathering. However, a few of the questions and answers contain important policy guidance.
Question and Answer 3 addresses averaging of welfare-to-work participation hours. Hourly welfare-to-work participation hours are determined using an average weekly requirement. However, in some months, this average calculates to more than the minimum required 20, 30 or 35 hours. When that happens, an alternative calculation method must be used. The alternative methods are the most days averaging method, which is based on the number of weeks in the month that contain four or more days, or the Friday Falls Averaging Method, which is based on the number of weeks in the month that contain a Friday. The intent of these alternative methods is to prevent sanctions for recipients who are participating their minimum 20, 30 or 35 hours per week.
Several questions and answers address cross-over between California and federal work participation requirements. California allows certain activities that are federal work participation requirements limit. In particular, California allows vocational education while federal work participation limits vocational education to 12 months in the participants lifetime, and California requires job search at the beginning of the welfare-to-work process while federal work participation requirements limit the amount of countable job search. CDSS states that participants are not required to have their federal time and the time on their 24 month clock run concurrently. The participant can choose whether to first count these activities toward their 24 month clock or towards their federal limit.
CDSS also states that counties are not required to initiate a new review of 24 month extensions when there is an intercounty transfer. Counties can review the case if the extension is not based on a formal request from the participant, but the new county cannot request verification until it has reviewed documentation from the prior county and determined it is insufficient. The receiving county cannot deny a 24 month extension based on the county already having met its 20% extension target.
In addition, CDSS states that counties must reevaluate all 24 month extensions every six months even if the participant does not request to continue the extension. (ACL 17-78, September 1, 2017.)