Extension of CalFresh Standard Medical Expense Deduction

The California Department of Social Services has issued guidance regarding extension of the CalFresh Standard Medical Expense Deduction (SMD).  The SMD waiver and has been extended to September 30, 2029.

The SMD is a standard $150 per month deduction for households with an elderly and/or disabled member with verified medical expenses of at least $35 per month.  Households with more than $185 per month in verified medical expenses can deduct all expenses from their income.

Failure to verify medical expenses is not a basis to deny or discontinue a case.

Except as stated, the details of the SMD are unchanged.  (See ACL 17-35, 21-117, 21-117E, and 24-59.   (ACL 26-04, January 15, 2026.)

 

Documentation of reasonable accommodation in CalSAWS.

The California Department of Social Services (CDSS) has issued guidance regarding documentation of reasonable accommodation in the California Statewide Automated Welfare System (CalSAWS).

This guidance applies to individuals with a “disability” as defined under the Americans with Disabilities Act (ADA). Some CDSS programs have their own definition of disability for purposes of determining eligibility, and may have their own requirements for documenting and qualifying disability. This ACL does not change program definitions or requirements, and meeting the requirements of this ACL does not fulfill any program-specific requirements and vice versa.

The County must document all disclosures of disability, requests for and offers of reasonable accommodations, and subsequent actions taken by the County, in the applicant’s/recipient’s case file. This also includes auxiliary aids and service. This documentation must include:

  • The fact that an applicant/recipient has a disability and/or has requested an The applicant/recipient is not required to provide a specific diagnosis;
  • The accommodation(s) requested by the applicant/recipient, if applicable, and
  • The accommodation(s) provided to the applicant/recipient.

Counties can learn about an applicant’s/recipient’s need for a disability-related accommodation in many ways, including but not limited to verbal request, case record information, and e-application responses. For example, a “yes” in response to the question “Are you a person with a disability” informs the county of a disability. Counties must offer reasonable accommodation when an individual’s disability is known or their need for reasonable accommodation is obvious.

The individual is not required to provide or verify a specific diagnosis to qualify as disabled under the ADA. An individual’s disability is considered documented in the case journal when the County has confirmed there is no need for accommodation, including documenting that reasonable accommodation was offered and declined.

When an individual needs a reasonable accommodation, Counties must document this information in the Special Circumstances Details page in CalSAWS if there is a request for an accommodation, and in the Case Journal if an accommodation is offered and provided. This includes documenting discussion about effective alternatives like “interactive process” if the requested accommodation is not immediately agreed upon.

All Counties can allow staff access to the CalSAWS Special Circumstances Detail page.

Counties must manually migrate all existing, active reasonable accommodation information from its current location to the Special Circumstances Detail page as soon as possible but in no case later than 18 months from the release of this guidance (by July 1, 2027). These updates must also be documented in the case journal.

A County may only deny a reasonable accommodation request when the requested accommodation would either:

  • fundamentally alter the nature of the program, service, or activity; or
  • impose an undue financial or administrative burden on the program, taking into account all resources available to the program, service, or activity.

If a reasonable accommodation request is denied, the County must inform the individual of that denial in writing. The County’s denial letter must notify that that the reasonable accommodation request is denied, the reasons for the denial, and any other accommodation(s) offered and/or provided.

Employees who perform Program Integrity functions, including Special Investigation Unit (SIU) investigators and individuals contracted to conduct investigative work, must check the CalSAWS case record for the Special Circumstances icon prior to any contact with the subject of a fraud referral.

If an individual named in a fraud referral discloses a previously unidentified disability-related need for accommodation to an SIU investigator or other staff member performing Program Integrity-related work, must offer reasonable accommodation to the individual and document this information in the Special Investigations section “Note Detail” page.

A decision to deny a reasonable accommodation request based on the limited permissible grounds must be made by the County Director or their designee. SIU investigators and other staff members performing Program Integrity functions should elevate such issues accordingly if they arise.

Contractors who receive federal or state assistance through a County must comply with the requirements of the ADA, MPP Division 21, and other civil rights laws and regulations, and are required to provide written assurance of nondiscrimination as part of their contract with the County. They are responsible for ensuring that the documentation requirements in this letter are met, including by developing workarounds with contracted service providers who do not have direct edit access to CalSAWS.

The CWD must establish procedures to ensure:

  • That the CWD notifies the contracted service provider in writing if an applicant/recipient has a need for a reasonable accommodation that must be provided by or in coordination with the contractor.
  • That the agreed-upon accommodation is provided in all applicable settings and program contexts, and that such provision is documented at each instance either in the CalSAWS case journal as instructed above or in a different record maintained by the contractor that the CWD deems appropriate to maintain civil rights compliance
  • That contractors who are unable to edit or notate the CalSAWS case record directly notify the CWD in writing if an applicant/recipient discloses a new disability-related need for a reasonable accommodation to them so CWD staff can add the information to the CalSAWS Special Circumstances Detail page, and
  • That clear communication channels, authority structures, and documentation responsibilities exist between the CWD and its contractors to address these and all applicable requirements covered in this letter.

There is no limit to the number of accommodations an individual may request, and requests may change over time. The County is required to train public contact staff, program managers, and supervisors upon hire and, at a minimum, annually thereafter, on providing reasonable accommodations to individuals with disabilities

County staff should copy all disability-related information from other CalSAWS locations like the “Medical Condition” page to the Special Circumstances Detail page. There is no automatic requirement to copy such information from one location to the other. but, if an applicant/recipient has disability information documented in another CalSAWS location, and that person also needs a reasonable accommodation because of the same disability, then the County must document the relevant information in the Special Circumstances Detail page.

It is recommended that Counties use other CalSAWS locations such as county-created Flag Detail pages to document applicants’/recipients’ non-ADA-related information with the exception of a non-disability related literacy issue.  (ACL 25-87, December 22, 2025.)

Requirement to provide copies of electronically filed CalFresh applications and allow corrections

The California Department of Social Services has issued guidance regarding providing CalFresh households with a copy of their application. If an application is signed via handwritten or electronic signature, the CWD must offer to provide a copy of the completed application. If the application was completed and signed with a telephonic or gestured signature then the county is required to promptly supply a copy of the application and instructions on how to fix any mistakes or omissions.

The applications completed on paper or electronically include any submitted in-person, online, by mail, by fax or other electronic transmission. Telephonic applications require the verbal assent of the household to be audio recorded in order to be valid. These may be completed over the phone. Gestured signatures include the use of signs and expressions communicating assent or agreement in American Sign Language (ASL), Manually Coded English (MCE), or another similar language or method during an interview in person or over video call. The requirement to provide copies of the application applies to both the original application and to recertifications.

For electronically signed applications, households have 10 days from the time of the completion of the electronic signature to review the information on the application and make any necessary changes. This can be done by crossing out incorrect information and writing in correct details. They may also call the county and submit the corrections online or visit the county office to submit corrections. This must be completed within that 10-day period but the applications do not need to be signed again.

Corrections made within the ten days following the completion of the signature are not considered mid-period reports and must be treated in accordance with application processing rules. Corrections are submitted after 10 days are considered mid-period reports. If incorrect benefits were given to the household because of late corrections, the CWD may make a claim for the amount over- or under- issued.  (ACL 25-83, November 19, 2025.)

Implementation of CalFresh changes to noncitizen eligibility

HR1 caused substantial changes to noncitizen eligibility for CalFresh.  The California Department of Social Services (CDSS) will implement these changes effective April 1, 2026.  Counties cannot implement these changes prior to April 1, 2026. Counties cannot implement these changes by manual processes or system workarounds.

Under HR 1, individuals are eligible for CalFresh only if they reside in the United States and are either:

  • United States citizens
  • Noncitizen nationals

People born in American Samoa and Swain’s Island after December 21, 1952, or residents of the Northern Mariana Islands who choose not to become United States citizens

  • Lawful Permanent Residents
  • Individuals who reside in the United States in accordance with a Compact of Free Association, or
  • Cuban and Haitian Entrants.

Certain categories are no longer eligible for CalFresh, but continue to qualify for an exemption from the five year waiting period, and therefore are eligible immediately when they become Lawful Permanent Residents.  Those categories are: noncitizens admitted to the U.S. as refugees  ,Noncitizens granted asylum, noncitizens whose deportations were withheld, Cuban and Haitian entrants, Compact of Free Association Citizens, Iraqis and Afghans with Special Immigrant Visas, certain Afghan Nationals Granted Parole Between July 31, 2021, and September 30, 2023, certain Ukrainian Nationals Granted Parole Between February 24, 2022, and September 30, 2024 noncitizens admitted to the United States as Amerasian immigrants, and victims of trafficking.

Categories of noncitizens who are no longer eligible for CalFresh are: asylees, refugees, parolees (unless they are Cuban or Haitian Entrents), individuals with deportation or removal withheld,  conditional entrants, victims of trafficking, battered noncitizens, certain Afghan Nationals granted parole between July 31, 2021, and September 30, 2023, and certain Ukrainian Nationals granted parole between February 24, 2022, and September 30, 2024.

Effective April 1, 2026, counties must apply these new rules for new applications, and for recertifications.  Effective April 1, 2026, counties must ask about where there has been a change in immigration status.  Immigration statues must be verified through the federal Systematic Alien Verification System.

Households are not required to report a change in immigrations status midperiod.

A SAVE match is considered Verified Upon Receipt. If a household disagrees with SAVE

An ineligible noncitizen household member’s resources must be included in the budget calculation to determine the benefit amount.  (ACL 25-92, December 31, 2025.)

Implementation of CalFresh time limit

HR1 caused substantial changes to the CalFresh time limit and work requirements.  The California Department of Social Services (CDSS) will implement these changes effective June 1, 2026.  Counties cannot implement these changes prior to automation in the CalSAWS computer system.  Counties cannot implement these changes by manual processes or system workarounds.

CalFresh recipients subject to the time limit are limited to three full months of countable benefits in a fixed 36-month period unless they are exempt from the time limit, satisfy the work requirement, live in a county with a waiver of the time limit, qualify for an additional three consecutive months of eligibility, or receive a discretionary exemption.

Under HR1, CalFresh recipients age 18 to 64 are subject to the time limit unless they are exempt.

CalFresh recipients age 60 or older remain exempt from work registration.  Recipients who are age 60 through 64 are exempt from work registration, but are still subject to the time limit unless they qualify for another work registration exemption or a time limit exemption.  ESAP households with individuals age 60 through 64 cannot be subject to time limits until they have been screened for exemptions.

HR1 created a new time limit exemption for individuals who meet the definition of Indian, Urban Indian, or California Indian in the Indian Health Care Improvement Act.  Self-attestation is sufficient to grant the exemption.

HR1 eliminated the time limit exemptions for veterans, individuals experiencing homelessness, and youth under age 25 who were in foster care on their 18th birthday.

HR1 limited the dependent child exemption to recipients who are either the parent of, or otherwise responsible for the care of, a dependent child under age 14.  A single dependent child under age 14 may exempt more than one adult if each adult independently meets the definition of being responsible for the child’s care.

Counties can only request verification to establish an exemption if verification is required by ACL 19-93 at pp. 11-21, or if the information provided is questionable.

Counties cannot take any negative action related to the time limit or work requirements on a case, until an individual who is subject to the time limit has been rescreened for exemptions and has been informed of the time limit and work requirements. Counties must complete or voluntarily offer exemption screening if an individual discloses that they may meet the criteria for an exemption.  Counties must screen each household member individually.

Beginning on June 1, 2026, counties must screen all recipient households at their next recertification and every subsequent recertification.  Counties cannot assign a countable month until exemption screening is completed.

Beginning June 1, 2026, new applicants must complete exemption screening at initial certification.

If an individual loses an exemption, the county cannot assign countable months until the individual is rescreened for exemptions.  Recipients must report mid-period if their income is over the Income Reporting Threshold, or their work hours drop below 20 hours per week or 80 hours per month.  If an individual reports a drop in work hours, the county must assess whether there is good cause or another exemption.  If an individual’s circumstances change mid-period to make them eligible for an exemption, the county must apply the new exemption within 10 days.

Beginning January 1, 2026, a new statewide time limits begins.  This means that individual subject to the time limit have three countable months in the period January 1, 2026 to December 31, 2028.

Noticing requirements for time limit rules are unchanged.

Individuals subject to the time limit may meet the work requirement by performing volunteer or community service hours.  Volunteer or community service hours can be combined with work or other qualifying activities to meet the work requirement.  Volunteer or community service hours must be verified.

California does not currently have any discretionary exemptions.  CDSS will release a letter with instructions when California is allocated new discretionary exemptions.  Counties must continue to evaluate recipients for exemptions or good cause not meeting the work requirement.  (ACL 25-93, December 31, 2025.)

CalFresh mid-period actions questions and answers

The California Department of Social Services (CDSS) has issued questions and answers about mid-period reporting for CalFresh.

If the county cannot determine the impact of a mid-period report on the household’s benefits, the county must contact the household.  If that is unsuccessful, the county must document the information in the case record and send the household a No-Change Notice of Action.

When a household reports a change in shelter expense mid-period and does not provide the amount of the new shelter cost, the county must send the household a CW 2200 Request for Verification form.  The client’s statement of the new shelter cost is sufficient verification.  The County allow ten days to provide the verification.  If the household does not provide the information, the county must document the information in the case record and send a No-Change notice of action.  If the shelter expense information is questionable and verification is not provided, benefits must be recalculated without the shelter cost.

When a household reports an address change mid-period, the county must act on any change in shelter cost related to the address change. If the household does not provide the new shelter cost, the county can attempt to contact the household.  If that is not successful, the county must send a CW 2200 Request for Verification form to the household.  If the household does not provide the information within 10 days, the county calculates the benefits without the shelter cost.  Note that California has a waiver until June 30, 2026 that if the household does not provide new shelter cost information, the county will update the address but not change the shelter cost information until the next recertification or periodic report.

If a household makes a mid-period report and provides necessary information and/or verification, the county must determine if the information is a mandatory mid-period report or is verified upon receipt. If it is neither a mandatory mid-period report nor is verified upon receipt and the change would decrease benefits, the county does not act on it.  If the report will increase benefits, the county must act on it for the next monthly benefit allotment.

When a new household member is reported mid-period, the county does not consider the new household member’s income for purposes of the Income Reporting Threshold.  The county must update the household’s Income Reporting Threshold to reflect the new number of household members.

Counties do not verify changes in income from the same income source that are $50 or less.  However, counties must act upon changes in income from the same income source that are less than $50 if the additional income puts the family over the Income Reporting Threshold.

Households with income between 131 and 200 percent of the Federal Poverty Level do not have an income reporting threshold requirement.  Mid-period reports of income for those households are not actionable.

When multiple household composition changes are reported at the same time, the county can only act on the household composition changes that increase benefits.  (ACIN I-58-25, October 14, 2025.)