Author: Stephen Goldberg

COVID-19 CalWORKs Welfare-to-Work guidance

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The California Department of Social Services (CDSS) has issued guidance regarding the impact of COVID-19 on CalWORKs Welfare-to-Work (WTW).

Counties should exercise discretion regarding optional documentation and verification in order to continue providing WTW services and supports.

Counties can issue temporary blanket good cause for not meeting WTW requirements.  This includes all initial engagement activities, all assessments and evaluations, completion or maintenance of a WTW plan and WTW participation.

Sanctioned clients may now have good cause not to participate or who have a cure plan with activities that are no longer available.  For those clients, counties should implement cure plans documenting that the activity that the client failed to do is not available because of COVID-19.  The cure plan can specify an alternative activity such as reviewing orientation materials or conducting job search online.  When assigning another activity is not practical or feasible because of COVID-19, counties may implement cure plans stating the lack of available activities and that the client temporarily has good cause not to participate.

Counties cannot cure all sanctioned participants because of COVID-19. Clients must sign a cure plan.  Counties are encouraged to issue pre-populated sanction sure plans for individuals to sign without solicitation from the client.  Counties should consider telephonic, electronic or mail-in signatures.  For counties that cannot accept electronic or recorded telephonic signatures, counties must enter a case not stating the individual attested to the information provided.

For clients who are in noncompliance but are not yet sanctioned, counties should make all attempts to avoid imposing sanctions by offering other available and appropriate activities, or by applying good cause.

Counties can continue subsidizing wages in the Expanded Subsidized Employment program even when the worksites are closed because of COVID-19.

CalWORKS Work Study subsidies can continue where work hours are reduced, worksites are closed or students are otherwise unable to meet work study obligations because of COVID-19.  For example, the subsidy may continue when students are unable to work because of lack of supportive services, such as when the student’s child care provider is closed because of COVID-19.  The subsidized payment can be made directly to the CalWORKs recipient, or through the employer or third-party payor if they are able to issue subsidized wages to the recipient.  (All County Welfare Directors Letter, March 30, 2020.)

COVID-19 new interim homeless assistance program guidance

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The California Department of Social Services (CDSS) has issued new guidance CalWORKs Homeless Assistance (HA) and COVID-19.  This new guidance supersedes CDSS’ March 19, 2020 All County Welfare Directors Letter for HA only.

Up to 16 days of motel vouchers are available from HA for eligible or apparently eligible CalWORKs participants.  Because of COVID-19, counties may waive the three-day limit to verify homelessness.  Counties may issue benefits in increments of more than one week, up to all 16 days at once.

Families should be granted good cause for not completing daily permanent housing search.

Receiving HA because of a state or federally declared disaster does not count against a client’s once per 12-months limit on HA.  In addition, clients affected by COVID-19 may be eligible for an exception to the once per 12-months limit because of uninhabitability of the home or a medical illness. For example, if a parent needs to isolate themselves because of COVID-19, HA should be granted based on exception because of medical illness.

HA applications are not required to be made in person or to include a face-to-face interview.  Counties can complete the application and have the client electronically sign it.  Counties can also record a verbal attestation over the phone or enter a case note stating the client attested to the information.

Counties can accept sworn statements for not providing paper verification such as hotel receipts or counties can grant good cause for not submitting paper verification.

Although existing guidance requires counties to issue vendor payments when there has been a finding of mismanagement, if there is no feasible way to issue vendor payments because of COVID-19, counties should consider issuing benefits on the client’s EBT card.  (All County Welfare Directors Letter, March 31, 2020.)

COVID-19 PrEP-AP enrollment

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The California Department of Public Health has issued instructions regarding the Pre-Exposure Prophylaxis Assistance Program (PrEP-AP) to minimize exposure to COVID-19 and maintain coverage.  For clients with expiring eligibility or expired eligibility back to March 1, PreP-AP is extending eligibility for 90 days to June 30, 2020.

However, for clients in a Gilead Assistance Program, Gilead is not extending eligibility.  Clients enrolled with expiring eligibility should submit a re-enrollment application with income documentation to Gilead prior to their eligibility ending to avoid a lapse in coverage.

If clients are unable to obtain their medication or submit a re-enrollment application before their eligibility expires, Gilead can provide the pharmacy override on a case-by-case basis.  If Gilead does not allow a medication dispense, PrEP-AP may approve an override on a case-by-case basis.

Clients enrolled in Gilead’s Patience Assistance Program and Copayment Assistance Program can receive up to a 90-day fill of medication as long as there is eligibility throughout the 90 day time period.  Clients in Gilead’s Copayment Assistance Program can only receive a 90 day dispense if their insurance allows for a 90-day prescription fill.  Pharmacies must contact Gilead to get an override code.  This is in effect until April 30, 2020.

Clinical providers are encouraged to consider converting PrEP to virtual if their agency has the capacity.  PrEP-AP can reimburse telemedicine using the same billing code as for an in person visit. Providers are encouraged to reach out to client to inform them that in-person appointments are changing to telemedicine.

Providers are also asked to postpone services that require person-to-person interaction but will maintain access to in-person visits when needed based on the client’s symptoms such as acute HIV or a sexually transmitted infection.  Laboratory testing for people on PrEP with good adherence and no symptoms can usually be postponed for 3 months.  (Management Memorandum 20-08, March 20, 2020.)

COVID-19 ADAP enrollment

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The California Department of Public Health has issued instructions regarding the AIDS Drug Assistance Program (ADAP) to minimize exposure to COVID-19.  For clients with expiring eligibility or expired eligibility back to March 1, ADAP is extending eligibility for 90 days to June 30, 2020.

New or lapsed clients can enroll over the phone.  New or lapsed clients will be required to provide documentation of eligibility.  Workers can email the client so the client can respond with enrollment and supporting documentation.

ADAP will now have early medication refills and has extended the dispense quantity to 90-day fills.  (Management Memorandum 20-06, March 16, 2020.)

COVID-19 CBAS services

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The California Department of Aging has issued guidance about changes to Community-Based Adult Services (CBAS) because of COVID-19.  CBAS centers have temporary flexibility to reduce day center activities and to provide services in the home, telephonically or by videoconference, including professional nursing care, personal care services, behavioral health services and therapeutic activities.  CBAS center may provide physical therapy and occupational therapy at the beneficiary’s home.

CBAS centers can provide for home-delivered meals in the absence of meals provided at CBAS centers, and may continue to provide transportation services.

Centers can provide individual in-center services such as individual meetings to receive services, indivuduals comont to the center to pick up supplies, meals, receive wound care assistance or receive assistance with a shower.  Participants assembling and receiving services in groups of more than one or being served in the same space at the same time is prohibited.  (All Center Letter 20-06, March 27, 2020.)

COVID-19 APS investigation and visits

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The California Department of Social Services (CDSS) has issued information about modifying Adult Protective Services investigations and monitoring visits because of COVID-19.  Face-to-face investigations continue to be required when an elder or dependent adult is imminent danger or immediate or 10-day in-person response is necessary to protect the individual’s health or safety.  Counties may collect and review information by phone prior to a home visit.

30-day in person monitoring visits remain mandatory unless the written visitation plan justifies why it is not necessary to visit the client once every 30 days and it is approved by a supervisor.  The mandatory visits can only be substituted by telephone calls with supervisor approval.  (Program Manager Letter, March 13, 2020.)