CDSS has issued clarification regarding county completion of the Cash Assistance Program for Indigents (CAPI) indigence exception form. Included in this clarification are several policy statements about evaluating eligibility for the indigence exception from sponsor deeming.
CDSS states that an applicant for the CAPI indigence exception is considered homeless if he or she has no permanent living arrangement, that is, no fixed place of residence. Examples include persons who sleep in doorways, homeless shelters or parks, and persons who are couch surfing and have no permanent living arrangement at the beginning of the month.
CDSS states that monthly income for purposes of determining eligibility for the CAPI indigence exception include any in-kind contributions from either a sponsor or anyone else. In addition, monthly income includes the cash value of any other public benefits that the applicant receives. If the applicant resides with their spouse, the spouse’s earned or unearned income is included.
CDSS states that if an applicant for the indigence exception claims to be living independently or living with others and paying rent (as opposed to claiming to be homeless), there is a contradiction with claiming the indigence exception. In those cases, CDSS requires the applicant to submit a written statement from anyone who has given the applicant a loan, and failure to submit that statement means the indigence exception is denied.
Based on the written statement, the county determines whether the loan is genuine. A loan is considered genuine if it must be repaid under any circumstances (for example repayment from CAPI benefits if received is considered conditional and the loan is not genuine) and the applicant currently (before a decision on the CAPI application) has sufficient income such that there is a reasonable likelihood of repayment of the loan.
If the loan is genuine, it does not count as income for purposes of the CAPI income standard, but its value is considered for in determining eligibility for the indigence exception by counting it towards the CAPI applicant’s ability to purchase shelter and food. If the loan is not genuine, it is considered a gift, and the applicant is ineligible for the indigence exception because the applicant’s needs for shelter and food are satisfied by gifts. (ACL 17-100, September 20, 2017.)