CalFresh / SNAP

CalFresh changes in federal reconciliation bill

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The California Department of Social Services (CDSS) has provided information about changes to the federal Supplemental Nutrition Assistance Program (SNAP, knows as CalFresh in California) as a result of H.R. 1, the federal budget reconciliation act.

The act restricts updates to the Thrifty Food plan amount (the food cost used to determine benefit amount) to no earlier than January 1, 2027, and any benefit increase must be cost neutral.  The act also caps benefits amounts for households with nine or more members to the equivalent of 200% of the federal poverty level for a family of four.

The act changes rules regarding Able Bodied Adults Without Dependants (ABAWDs).  When implemented, the ABAWD requirements will apply to persons age 18-64, limits the work requirement exemption for to households with a dependent child under age 14, eliminates the exceptions for former foster youth, veterans and homeless are repealed and adds a new exception for tribal members who are eligible for Indian Health Service services is added.  The threshold for a waiver of the ABAWD requirements will be raised to the unemployment for an area being over 10%, and ends waivers based on lack of sufficient jobs.  CDSS is waiting for additional guidance for implementation.

Internet expenses will no longer count toward the excess shelter deduction.  California had not yet implemented counting internet expenses toward the excess shelter deduction, so this change will not impact California policy.

California currently provides a $20.01 Low Income Home Energy Assistance (LIHEAP) payment to allow all households to claim the Standard Utility Allowance.  This option is called Heat and Eat.  The act prevents states from continuing Heat and Eat.  CDSS is waiting for additional guidance for implementation.

Effective October 1, 2027, states must pay a percentage of CalFresh benefit allotments on a sliding scale based on the state’s error rate.  States with an error rate below 6% will have zero match.  States with an error rate between 6% and 7.99% will have a 5% state match.  States with an error rate between 8% and 9.99% will have a 10% state match.  States with an error rate of 10% or higher will have a 15% state match.

States will be able to choose to use to use their error rate for fiscal year 2025 or 2026 to calculate their fiscal year 2028 match.  After that, states must use their error rate for the third fiscal year prior to determine their match percentage.

Effective October 1 2026, the federal portion of administrative costs will be reduced to 25%.

The act repeals the National Education and Obesity Prevention Grant Progam (SNAP-Ed).  As a result, the CalFresh Healthy Living program will end on September 30, 2025.

Most qualified immigrants will no longer eligible for CalFresh, including refugees, asylees, public interest parolees, battered noncitizens, trafficking victims, and others.  Exceptions are Cuban and Haitian Entrants, Lawful Permanent Residents and Compact of Free Association states citizens.  Financial resources of ineligible noncitizens in a CalFresh household will be included in eligibility and benefit determinations.  CDSS is waiting for additional guidance for implementation.  (ACL 25-50, July 14, 2025.)

CalFresh Timeliness Standards

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The California Department of Social Services has issued clarifications about CalFresh timelines. For initial applications, after an application is filed, County Welfare Department (CWD) must process the application as soon as possible, but in no later than in 30 calendar days. Households who qualify for Expedited Service will have their applications processed within three calendar days following their application. CalFresh benefits are considered available when the household has an active EBT card and PIN, and benefits have been posted to the household’s EBT account and are available for use.

Households eligible for expedited service are: Households with less than $150 in monthly gross income and liquid resources (cash, money in checking or savings accounts, saving certificates, and lump sum payments) that are less than $100; or migrant or seasonal farmworker households who are destitute provided their liquid resources do not exceed $100; or households whose combine monthly gross income and liquid resources are less than the household’s monthly rent or mortgage, and utilities

CalFresh households may choose to pick up their EBT card at the CWD office or have the EBT mailed to their mailing address.

For Annual Recertifications, eligible households can remain eligible for CalFresh if they file the recertification application by the 15th day of the last month of their expiring recertification period and complete all required actions.

Households should receive a Notice of Expiration of Certification before the first day of their last month of recertification.

The CWD will consider any application for recertification submitted on or before the 15th day of the final month of the certification period to be on time. Submissions past this date will be considered untimely, but CWDs must process all recertification applications, including those that are submitted late.

For periodic reports, households receiving benefits must complete the SAR 7 Eligibility Status Report (SAR 7) by the 5th of the submission month. The SAR 7 determines if the reported information affects the household’s eligibility and/or benefit level for the next payment period.

SAR 7s submitted between the 1st and 11th calendar day of the submit month are considered timely, but any SAR 7 received past the 11th calendar day of the submit month is considered untimely. In that case, households will receive a discontinuance notice from the CWD, effective the end of the submit month.

Before benefits are terminated, the CWD must attempt to make personal contact via telephone, text, or other electronic message with the household to remind them of the SAR 7 report and collect the necessary information for it.

If the SAR 7 is submitted by the end of the 1st business day after the SAR 7 was due, the county will restore aid. CWDs must make benefits available to households eligible for ES no later than the third calendar day following the date of the application.

If a household fails to provide the required information or verification and becomes ineligible for CalFresh, benefits may be reinstated if the household complies within 30 days of the effective date of ineligibility. This Restoration of Aid waiver lasts through June 30, 2027.

Households who have previously received CalFresh but are not currently receiving benefits must file a new application to receive benefits again. However, under this waiver, a recently discontinued household that provides a missing report (like the SAR 7), required verification, and/or other required information to re-establish eligibility may be reinstated when there is at least one month remaining in the certification period after the effective date of ineligibility.

For Mid-Period Reports, the CWD must act on information that would increase the household benefits and not act on information that would decrease the household’s benefits. If reported information is actionable, the CWD must take action on the case effective no later than the first allotment issued 10 days after the date the change was reported.  (ACIN I-35-25, July 11, 2025.)

New ABAWD forms

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The California Department of Social Services (CDSS) has issued two new forms for CalFresh ABAWD requirements.  The new CF 887 is an optional form to verify an individual’s physical or mental unfitness to work when it is not obvious or is considered questionable. This form may be used to determining exemptions from the ABAWD time limit, work registration, or the student eligibility rule.

The new CF 888 is an optional form to verify volunteer work hours for non-exempt ABAWDs. ABAWDs may engage in community service or volunteer work to satisfy the ABAWD work requirement.  ABAWDs must verify their participation hours, and this form will verify that participation.  (ACL 25-34, May 14, 2025.)

ABAWD waiver now ends on January 31, 2026

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The California Department of Social Services (CDSS) has informed counties that the United States Department of Agriculture rescinded California’s two-year waiver of the CalFresh Able Bodied Adults Without Dependants (ABAWD) requirements.  In its place, the United States Department of Agriculture issued a new one year waiver of the ABAWD requirements that expires on January 31, 2026.

The ABAWD rule is that CalFresh recipients between the ages of 18 and 54 with no children and who is not disabled, are limited to three months of CalFresh benefits every three years unless they are working at least 20 hours per week or 8 hours per month.

Regardless of the status of the waiver, counties must: identify ABAWDs, screen for exemptions, inform participants of the ABAWD and work rules, and track and report work registrant, ABAWD, and Employment and Training data.  (ACL 25-41, June 13, 2025.)

Civil rights obligations to people who are deaf or hard of hearing

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County Welfare Directors (CWD) are legally required to ensure that communication with Deaf and Hard of Hearing (DHH) individuals is just as effective as communication with individuals without disabilities. DHH obligations include applicants for services and their companions, such as family members, friends, or associates. Written notes and lip reading are not effective or reliable forms of communication for most DHH individuals.

To ensure effective communication, CWDs must provide auxiliary aids and services promptly. Examples of aids and services include qualified interpreters, notetakers, captioning, and telecommunications devices. DHH individuals can choose which auxiliary aid or service they prefer.

Documentation of services provided to DHH individuals must be detailed and meet requirements for both language access and disability accommodations. Counties cannot charge for auxiliary aids and services.  CWDs must ensure that DHH individuals can obtain information about the existence of services. Best practices include visible posters informing the right to interpreter and including information about language access on websites or notices.

When an individual with a disability requests specific auxiliary aid or service, the CWD must give primary consideration to that request. CWDs must grant the individual preferred aid unless the preference causes undue administrative burdens, fundamentally alters the service, or an equally effective alternative is available. Denials must be approved by the County Welfare Director or their designee and documented with a written statement explaining the reason for the denial. In all cases, the CWD is responsible for offering effective alternative means of communication. There is no limit on the number of disability requests an individual can submit and no specific timeline for making these requests.

CWDs are required to provide interpreters when requested. Interpreters may include American Sign Language (ASL) interpreters, deaf Interpreters, tactile interpreters, or cued-speech transliterators, depending on the individual’s needs. Importantly, CWDs must not require or pressure individuals to bring their own interpreters. Only under minimal circumstances—such as emergencies involving imminent safety threats or when the individual voluntarily chooses to use an accompanying adult—is it acceptable to rely on a non-staff interpreter. Situations where it would be inappropriate for a guardian to provide effective communication include an interview with a child during a Child Protective Services (CPS) investigation. Children should never be used as interpreters except in genuine emergencies when no other options are available.

The California Department of Social Services (CDSS) encourages CWDs to establish contracts with Video Remote Interpretation (VRI) providers to help the CWD fulfill its obligation to provide timely services. VRI allows remote interpreters to facilitate communication via videoconferencing and can be helpful in situations where in-person interpreters are unavailable. However, VRI is not always suitable for every circumstance, especially when a DHH individual has low vision or when visual cues and body language are crucial for communication. Even when VRI is available, CWDs must prioritize the individual’s preferred communication method.

When communicating by phone, CWDs are required to create accessible telecommunication systems, including Video Relay Services (VRS), Text telephones (TTY), and captioned telephone services. However, telecommunication services are not a substitute for in-person interpreting services and should only be used when effective communication can occur by telephone.

CWD staff who interact with the public must receive civil rights and disability accommodation training upon hire and at least annually thereafter. This includes training in requesting interpreters, use of assistive technologies, and proper documentation procedures. In programs involving home visits, such as Child Welfare or CalWORKs, staff must plan to arrange interpreters or bring necessary tools to ensure effective communication off-site. If an interpreter cannot be secured in advance, visits should be rescheduled, except in programs that involve unannounced visits. In such cases, staff must be trained in obtaining real-time interpreter support.

CWDs must consider the unique needs of DHH children in out-of-home placements. For instance, assisting DHH children with communication through Resource Families and contacting individuals outside the home, such as relatives, social workers, or attorneys. Staff should be aware that family members may not be fluent in (ASL), which may necessitate the use of interpretation during visits. (ACIN I-39-24, September 17, 2024.)

End of CalFresh Comparable Disqualification

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Previously, California imposed a comparable CalFresh disqualification when an individual was sanctioned for noncompliance with CalWORKs welfare-to-work, Unemployment Insurance, or substitute programs such as General Assistance and Refugee Resettlement programs participation requirements.  Effective May 15, 2025, the California will no longer impose the comparable disqualification for CalFresh or the California Food Assistance Program.

When an individual does not comply with participation requirements of CalWORKs, Unemployment Insurance, or substitute programs, the CalFresh allotment cannot increase because of the decreased CalWORKs grant.  CalFresh can increase if the individual becomes ineligible for CalWORKs for another reason, or the household’s CalWORKs case is closed.

Individuals who were disqualified from CalFresh because of a comparable disqualification may participate without completing the sanction.  One person households must reapply.  Existing households can request to add the individual to the household.

Counties must continue to ensure that CalFresh recipients who do not comply with participation requirements of CalWORKs, Unemployment Insurance, or substitute programs are registered for work unless they are exempt.

Individuals who do not comply with CalFresh work registration requirements without good cause may be disqualified if they not exempt.  Work registrants must participate in an Employment and Training Program (which is voluntary in California), provide enough information to determine employment status or availability for work, report to an employer when referred by the county, accept an offer of suitable employment, and not voluntarily quit a job of 30 or more hours a week, earning the equivalent of Federal minimum wage for 30 hours per week, or reduce work to less than 30 hours per week without good cause.

Good cause for noncompliance with CalFresh work registration is circumstances beyond the individual’s control, including, but not limited to: illness, illness of another household member that requires the work registrant’s presence, a household emergency, lack of adequate child care for children age 6 to 11, lack of transportation, declaration of disaster, language barriers, discrimination or workplace rights violations, or unpredictable or inconsistent employment hours.  Verification of good cause is not required unless the good cause is questionable.

Counties must screen for CalFresh work registration exemptions before imposing a disqualification.  Individuals are exempt from CalFresh work registration when they are: under age 16 or over age 59, a 16 or 17 year old who is attending school or enrolled in a training program on at least a half-time basis, physically or mentally unfit for employment, complying with CalWORKs work requirements, parent of a child under age 6, responsible for care of a disabled person, applying for or receiving Unemployment Insurance, a regular participant in a drug or alcohol addiction treatment and rehabilitation program, employed or self-employed for at least 30 hours per week or earning the equivalent of Federal minimum wage for 30 hours per week, or enrolled in a school, training program or institution of higher learning on at least a half-time basis.

If an individual is disqualified from CalFresh, the disqualification period is one month for the first disqualification, three months for the second disqualification, and six months for the third or subsequent disqualifications.   Counties cannot count prior comparable disqualifications for future disqualifications.

A household is ineligible for Modified Categorical Eligibility if the head of household does not comply with work requirements.  This means that these households must meet the CalFresh resource limit.

A CalFresh disqualification period can end when the period ends and the work registrant meets work registration requirements, the disqualified person complies during the disqualification period, or the disqualified person qualifies for an exemption during the disqualification period.  When the disqualification period ends, one person households must reapply, and existing households can request to add the individual to the household.

Counties must issue a notice within 10 days of discovering CalFresh work registration noncompliance, and must provide notice at least 10 days prior to imposing the disqualification.  (ACL 25-32, May 15, 2025.)