Questions and answers about changes to education as a Welfare-to-Work activity

The California Department of Social Services has issued questions and answers regarding SB 1232 which makes significant changes to education as a Welfare-to-Work activity. These changes are described in ACL 21-04, summarized here.

The SB 1232 changes do not apply to privately funded institutions.  SB 1232 does apply to online institutions that are publicly funded even if they are located outside of California.  SB 1232 applies to non-profit postsecondary institutions. SB 1232 applies to all education courses at publicly funded postsecondary institutions, including Associate, Bachelors, Masters and PhD programs.

Counties do not need to approve a student’s course of study.  Counties cannot deny a student’s choice of postsecondary education program, courses or field of study.

SB 1232 supersedes guidance about Self-Initiated Programs (SIPs) for students in publicly funded postsecondary institutions.  Counties must transition current SIPs for students in publicly funded postsecondary institutions to a new plan that meets the requirements of SB 1232 as soon as possible.  SIPs who have not been transitioned to a new plan are entitled to advanced standard ancillary service payments.

SB 1232 creates a separate Welfare-to-Work track for clients enrolled in publicly funded postsecondary institutions.  Such clients are required to attend appraisal and orientation/OCAT, but are not required to do an assessment.  Counties can require an assessment for students enrolled in education part-time to assign additional educational activities during the education session, and for bridging activities between academic sessions to assign hours needed to fill hourly participation requirements.  This is because clients enrolled in a SB 1232 program are subject to Welfare-to-Work hourly participation requirements.  Part time students can submit a proposal for meeting their hours.  Clients not assigned to bridging activities when school is out of session will have good cause to not participate.  Clients who are enrolled full time in publicly funded postsecondary institutions meet participation requirements by making satisfactory progress as defined by the educational institution.

Clients enrolled in publicly funded postsecondary institutions need a new Welfare-to-Work plan.  Counties must provide a new plan no later than 30 days before the start of the education session.  If the plan is not provided, the prior plan will remain in effect and the previous advance standard payment amount will be issued to the client.  Plans must be modified by the Fall, 2021 academic session.  Although counties must mail clients a new plan for each academic session, clients do not need to sign and return a new or revised plan if their enrollment status and supportive services needs have not changed.

Counties are not required to change all Welfare-to-Work plans.  However, counties must inform clients as soon as possible about SB 1232 and their ability to enroll in school and receive an advanced standard ancillary payments.

Three hours of study time, whether supervised or unsupervised, are counted per week for each academic unit in which the client is enrolled.

Students in publicly funded postsecondary institutions are not subject to noncompliance.  If a student fails to attend their assigned activities, or provide required documentation, then the client will be scheduled for a non-SB 1232 activity.

Clients must provide enrollment documentation at the institution which serves as proof that the client is enrolled and is making satisfactory progress.

Clients must sign a Welfare-to-Work plan to receive the advance standard payment.  If there is a delay in the county receiving the plan, the county must issue the payment within 20 days of receiving the signed plan.  Counties can continue to provide vouchers as long as they are at least the full value of the advance standard payment.

The advance standard payment can only be an overpayment if the student was ineligible for the payment.  There is no overpayment even if the student’s enrollment status changes during the term.  The county cannot ask for receipts to show how the advance standard payment was spent.  The county cannot seek an overpayment if actual cost of books and supplies are less than the advance standard payment.  The county cannot limit the advance standard payment to the actual cost of books and supplies.

Clients can receive payment greater than the advance standard payment if they verify that the cost of required materials for classes are more than the advance standard payment.  Counties cannot cap the amount ancillary service payments. (ACL 21-75, June 28, 2021 and ACL 21-75E, November 29, 2021.)