Author: Stephen Goldberg

COVID-19 extension of time eligibility for RCA, ECA and TCVAP

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The California Department of Social Services (CDSS) has issued instructions for an additional extension of time eligibility for Refugee Cash Assistance (RCA), Entrant Cash Assistance (ECA) and Trafficking and Crime Victim Assistance Program (TCVAP).  Effective October 1, 2020, this extension applies to RCA, ECA and TCVAP until January 31, 2021.  This extension is limited to persons whose date of eligibility for benefits is April 1, 2019 through May 31, 2020.

Applicants for RCA, ECA and TCVAP are not required to provide Social Security Numbers.

Verification and documentation requirements are waived for all three programs. Verbal declarations are acceptable verification, including verification of immigration status.

Counties must provide uninterrupted assistance retroactive to October 1, 2020 through January 31, 2021 regardless of whether they received the prior benefits extension.  For benefits recipients for September through December, 2020, counties must rescind any discontinuances of benefits. Recipients who reached their time limit before August, 2020 may reapply for benefits.  Those persons must confirm that they were economically impacted by COVID-19.

People receiving extension benefits must comply with SAR-7 and annual redetermination requirements.

Counties are encouraged to use flexibilities to help client meet employment requirements.  Counties should ensure that all RCA and ECA recipients are enrolled in and referred for employment services and English classes.

TCVAP recipients must provide proof of submission of a T-Visa application within 12 months of the date of application.  Counties should review cases where applicants or recipients are unable to apply for a T-Visa for good cause.  Counties can accept written declarations for verification that an applicant or recipient has applied for a U-Visa.

Counties should disregard certain COVID-19 emergency payments when determining income and assets for applicants impacted by COVID-19.

Counties must notify RCA, ECA and TCVAP recipients receiving extended cash assistance of the time extension and continuance of aid at least 10 days prior to issuing cash payments.  (ACWDL, December 15, 2020.)

COVID-19 emergency procedures for CAPI

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The California Department of Social Services (CDSS) has extended certain COVID-19 emergency procedures for the Cash Assistance Program for Immigrants.

The CAPI face-to-face interview requirement will continue to be waived through the end of the State of Emergency in California.  Counties must accept CAPI applications by telephone, mail, fax and email.

The waiver of the requirement for CAPI applicants to submit proof of SSI application denial because of immigration status expires on December 31, 2020.  After December 31, 2020, and through the end of the State of Emergency in California, the SSI ineligibility requirement may be met by verification that an SSI application has been filed and is pending final determination.  Counties must get a copy of the application summary letter issued by SSI after the applicant completes a SSI application.  Verbal attestations of having applied for SSI will not longer be acceptable after December 31, 2020.

Counties can check the MEDS system for proof that the CAPI applicant applied for SSI and was denied because of immigration status.  (ACL 20-143, December 18, 2020.)

COVID-19 stage one child care provider subsidy

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Child care providers who were open in July and submitted requests will receive a stipend check.  This includes providers who submitted requests for children who were not in care because of COVID-19.  Stipends are based on the number of children enrolled and the average per child cost based on the Regional Market Rate.  This means that providers in different counties may receive different stipend amounts.

Stipend checks were mailed in November.  A second round of stipends will be mailed after consultation with counties to determine if any providers may have been missed because of late form submission.  In counties that contract Stage One child care through an Alternative Payment Provider (APP), the APP will issue the stipend check with funds from the California Department of Education.  (ACWDL, November 13, 2020.)

CalFresh work study verification

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The California Department of Social Services (CDSS) has issued guidance regarding verification of work study approval for college students who have applied or are applying for CalFresh.  CDSS also provides a form that colleges can use to verify work study approval.

Students are ineligible for CalFresh unless they meet an exemption.  Students who provide verification showing they are approved for work study for the school term and can reasonably anticipate working during the school term meet an exemption and can be eligible for CalFresh.  (ACL 20-114, October 28, 2020.)

COVID-19 CalFresh Employment and Training supportive services and equipment

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The California Department of Social Services (CDSS) has issued guidance regarding provision of equipment and supportive services to CalFresh employment and training (E & T) participants, particularly in response to COVID-19.

Counties and state partners can purchase necessary equipment for use by CalFresh E & T participants.  Equipment purchased by a county, state partner, or third-party partner may include laptops, cell phones, and other computer equipment to be loaned to participants for programs that require remote access such as distance learning.

Supportive services assist participants with overcoming barriers that prevent participation in CalFresh E & T.  Providers are required to pay directly or reimburse CalFresh E & T participants for expenses that are reasonable, necessary and directly related to participation upon presentation of appropriate documentation.  Reimbursable supportive services include dependent care costs, transportation, uniforms, personal safety items, books or training materials, and internet or telephone services.

Personal protective equipment necessary to engage in CalFresh E & T, when not provided by an employer, is covered, including personal protective equipment, hard hats, non-slip shoes, cloth face coverings and protective gloves for use during COVID-19 consistent with public health guidance.  (ACL 20-125, November 17, 2020.)

COVID-19 CalFresh overissuances

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The California Department of Social Services (CDSS) provides clarification about CalFresh overissuances in the context of COVID-19.  Beginning in March, 2020, all CalFresh households have been receiving maximum amount of CalFresh.  Households entitled to less than the full allotment have been receiving the difference between their entitled allotment and the full allotment as an emergency allotment.  For any month a household receives an emergency allotment, there cannot be an overissuance unless the household is found to have been completely ineligible.

Households are only required to report a change in income during the reporting period that are over the income reporting threshold. Changes in household circumstances such as a change in household composition or expenses, and income fluctuations that are less then the income reporting threshold are not required to be reported during the certification period.

If households report all income as required at application, periodic report or recertification, an overissuance can only be calculated for months in which gross monthly income exceeds the income reporting threshold for two months or more.  Changes in household income or other circumstances that are not required to be reported do not result in an overissuance.

Nonrecurring lump sum payments, including any government stimulus payment or retroactive unemployment insurance payments, do not count as income for CalFresh.  Nonrecurring lump sum payments are a resource in the month received. In this context, there is an overissuance only if a household subject to the resource limit receives a nonrecurring lump sum, does not report at application, periodic report or recertification, and the countable resources exceed the resource limit.

Income that is not reasonably anticipated cannot be used in determining eligibility.  When recreating the circumstances to determine the amount of an overissuance, the county must determine whether the income was required to be reported and if the income was reasonably anticipated to continue.

When determining if an overissuance is administrative error or inadvertent household error, counties must consider the circumstances at the time of the overissuance.  These circumstances include various waivers because of COVID-19 including waiver of periodic reporting and extension of certification periods, and elimination of the interview requirement at initial certification and recertification.  In addition, COVID-19 created significant application and call volume and changes in county operations that may have resulted in a households inability to complete required reports.  Counties must consider these circumstances when establishing an overissuance claim. These circumstances are likely to have impacted a household’s ability to report timely, increasing the occurrence of overissuance claims caused by administrative error.

When an administrative error overissuance claim is established for an active CalFresh household as a result of administrative error, collection is by grant adjustment of 5% or $10 per month, whichever is greater, for no more than 36 consecutive months.

When an overissuance is established for an inactive CalFresh household as a result of an administrative error or inadvertent household error, the claim establishment threshold is $400. (ACIN I-87-20, November 19, 2020.)