NOTE — The section of this ACL regarding the Work Number being used in conjunction with, but not in lieu of, existing income and eligibility sources, is superseded by ACL 21-16.
The California Department of Social Services (CDSS) has issued guidance regarding use of the Work Number consumer credit report in determining initial and ongoing eligibility for various programs.
For CalFresh, if documentary evidence of income is unavailable, for example because a household member did not provide or does not have access to necessary documentation at the time of the application or interview, the Work Number can be used to verify income in real time at application, during the certification period, at recertification, or for a Quality Control review.
Information obtained through the Work Number is not considered verified upon receipt which means the applicant or recipient must be consulted before the county can use the information. If the information provided by the Work Number is consistent with information provided by the applicant or recipient, consultation is not necessary. If the household confirms the information from the Work Number is accurate or there is no discrepancy, the Work Number can be used to verify income.
The Work number can be used in conjunction with, but not instead of existing required income and eligibility sources including IEVS.
Counties cannot require the household to submit additional documentation that is duplicative of information received through the Work Number. Counties can request additional documentation only if the household states that the information is inaccurate or the Work Number does not verify all income sources.
If the county takes adverse action based on information from the Work Number, the notice of action must state the name, address and telephone number of the Work Number, a statement that the Work Number did not make the adverse decision, a statement of the right to obtain free disclosure of the consumer’s file within 60 days, and a statement of the consumer’s right to dispute the accuracy or completeness of any information provided by the Work Number.
Counties can use the Work Number to verify information received at initial application or recertification. This can allow same day service when documentary evidence is not available on the day the application is submitted.
Counties can use the Work Number to verify a voluntary report of a change in income or to verify income information provided at periodic report.
For Quality Control reviews, counties can use the Work Number to substantiate information provided by the household or if the household refuses to cooperate.
For CalWORKs, counties can use the Work Number to verify information at application, redetermination and to determine ongoing eligibility. The Work Number can be used to verify welfare-to-work information for Work Participation Rate purposes. Counties can use the Work Number to verify income when transitioning clients from State One to Stage Two child care.
The Work Number cannot be used to verify a missing mandatory report of income over the Income Reporting Threshold.
For IEVS matches, if the client does not respond to the verification letter, the county can use the Work Number as the independent verification source.
The Special Investigations Unit can use the Work Number to verify information from IEVS. (ACL 19-08, February 9, 2019.)