The California Department of Social Services (CDSS) has issued instructions about using electronic signatures in the CalWORKs and CalFresh programs.  Electronic signatures can be used for applications, recertifications and periodic reports.

An electronic signature for CalFresh must have each of the following: 1) the client must take an affirmative action to indicate agreement such as entering a PIN number or a verbal statement, 2) the record of the signature must be maintained electronically and linked to the document to which the signature attests and 3) the process must constitute a legal signature as defined by the California Secretary of State and the Uniform Electronic Signatures Act. (Civil Code Section 1633.1 et. seq.)

Electronic signatures can include handwritten signature input onto an electronic signature pad; handwritten signature, mark or command input on a display screen; digitized image of handwritten signature that is attached to an electronic record; typed name; unique identifier (for example a password or PIN); electronically recorded sound; using a mouse to click a button such as an “I agree” button) or a digital signature.

Counties must maintain the electronic record of the signature linked to the document for a minimum of three years.  For telephone signatures, the county must have technology to catalog and maintain a retrievable audio file recording of both the household’s assent and a summary of what the household is agreeing to.  For other electronic signature options, the county must have technology to catalog and maintain a record of the household member’s affirmative action agreeing to using electronic signatures.

Counties must promptly provide a written copy of information given over the telephone with simple instructions for correcting errors or omissions, establish privacy safeguards and must ensure that the electronic signature option does not interfere with the right to apply in person or in writing.  CDSS recommends that counties consider using a unique identifier as an alternative to telephone signatures.  Counties are not required to transmit the record of electronic signature to the receiving county in an inter-county transfer.

The same instructions apply to CalWORKs except that CalWORKs requires a face-to-face interview for applications unless the county has opted to allow telephone interviews, and all aided adults must sign application, reporting and recertification forms.  The requirements in the Uniform Electronic Signatures Act apply to CalWORKs.  (ACL 17-57, June 9, 2017.)

The California Department of Social Services has issued instructions about processing Income and Eligibility Verification System (IEVS) data matches.  IEVS is a system to verify income and other information for applicants and recipients of both CalWORKs and CalFresh.

County staff must review IEVS information and compare it to information in the case record. If the information is consistent with information provided by the applicant or recipient, no action is taken.  If the information is different from information provided by the applicant or recipient, the county must verify the information from IEVS to determine if it affects eligibility or benefit level.  County staff first requests verification from the recipient.  If the recipient is unable to provide verification, county staff must seek verification from third-party sources (an employer for example).  After the county has received third party verification, county staff determines the effect on eligibility or benefit levels.

Follow-up with the recipient following an IEVS match must happen within 45 calendar days of CDSS transmitting the match to the county.  If there is no discrepancy, the county must make a case note documentating that determination.  For CalFresh only cases, failure to respond to this letter within 10 days can be a basis for terminating benefits.

Counties must either establish an overpayment or overissuance or determine that no discrepancy exists by the end of the quarter following the quarter when the county received the IEVS match.  This timeframe does not apply to closed cases.  A pending investigation by the county Special Investigation Unit cannot delay processing of an IEVS match.  ACL 17-41 (June 6, 2017).