COVID-19 treatment of individual stimulus for CalWORKs and CalFresh

The California Department of Social Services (CDSS) has issued guidance about how the individual stimulus payment is to be treated for purposes of CalWORKs, CalFresh and TCVAP.

Individual stimulus payments are excluded from being considered income in the month received and will not be considered as asset for 12 month following receipt.  (ACWDL, April 15, 2020.)

Implementation of EBT online purchasing

The California Department of Social Services (CDSS) informs counties that Electronic Benefits Transfer online purchasing will be available on April 28, 2020.  EBT online purchasing will initially be available at Amazon and Walmart.

Both Amazon and Walmart accept EBT for food purchases using CalFresh benefits. Walmart also accepts EBT purchases of non-food items using CalWORKs benefits.  Federal law prohibits using CalFresh benefits to pay delivery charges or other fees for online purchases.  Walmart accepts CalWORKs benefits via EBT to pay for delivery fees. Amazon offers Amazon cash to deposit money to pay for delivery fees or other purchases.

Counties should refer clients to the retailer’s website or the customer service number on the back of the EBT card for assistance with online purchasing.  (ACWDL, April 14, 2020.)

Limitations period for collecting CalFresh overissuances

The California Department of Social Services (CDSS) informs counties that they must stop all noticing and collection efforts for CalFresh overissuances except for Treasury Offset Program, when a claim has been delinquent for three consecutive years.  This letter supercedes Manual of Policy and Procedure Section 63.801.53 which does not comply with federal regulations.  This applies to all CalFresh overissuance types.

A CalFresh overissuance claim is delinquent if the claim has not been paid by the due date and payment arrangements have not been made, or a repayment agreement has been made and a payment not made.  A claim is established when the initial notice of action is sent to the household.  When the claim is established, the household has 30 days to respond to state how they have chosen to pay or to request a hearing.  If a household that is no longer receiving aid does not respond in 30 days, the claim is delinquent.

A claim is not delinquent if it is being paid through a repayment agreement or through allotment adjustment.  A claim is delinquent on the date of a missed installment payment.  A claim remains delinquent until either a repayment agreement is established or resumed, a payment is made by a former recipient, payment is received in full, or the recipient reenrolls in CalFresh and allotment reduction begins.

Once a claim is delinquent for three years, the only allowable collection method is the federal Treasury Offset Program.  All other collection efforts by the county or county revenue and recovery department must stop.  (ACL 20-24, March 26, 2020.)

COVID-19 CalFresh waiver of interview and signature requirements

The California Department of Social Services (CDSS) has issued guidance regarding federal waivers of the initial application interview and signature requirements.  These waivers are effective from March 27, 2020 to May 31, 2020.  The waivers can be applied to any application pending at the time of the release of the guidance.

Counties may waive the requirement for an interview at initial certification of eligibility for benefits if the county has verified the identity of the applicant and has completed all mandatory verifications.  Households entitled to expedited service and whose identity is verified within the three-day expedited service timeframe will have their initial interview waived prior to benefit issuance.  If an expedited service household does not provide missing mandatory verification, benefits will be discontinued per existing CDSS policy.

To verify identity counties must accept any readily available documentary evidence which reasonably establishes the applicant’s identity.  If documentary evidence is not readily available, counties may verify identity using collateral contacts.

For other verification, counties should use electronic verification such as Work Number when it is available.

Verification of job loss is not a mandatory verification for CalFresh.  Verification of job loss should be requested only if the job loss is questionable. A client’s statement of job loss is sufficient evidence that the client cannot reasonably anticipate income from that job.

For households whose interviews cannot be waived, counties may require the household to completed a telephone interview even if they request a face-to-face interview.

Counties can document in the case file that the client verbally attested to the information provided on the application instead of having an audio recording of a telephonic signature.  This flexibility can only be used when a telephonic or electronic signature is not available and a wet signature has not been provided.

Counties must ensure that their phone systems have capacity and staffing to implement these waivers.  Phone system performance, including dropped calls, wait times, call completion times and staff adequacy, must be monitored and adjusted to adequately serve incoming calls.  (All County Welfare Directors Letter, April 2, 2020.)

COVID-19 CalFresh emergency allotments

The California Department of Social Services (CDSS) has issued information regarding emergency CalFresh allotments authorized by the Families First Coronavirus Response Act.  The emergency allotments will raise each household’s monthly allotment of CalFresh to the maximum allowable based on household size for March and April 2020.  CalFresh households already receiving the maximum allotment will not receive an emergency allotment.

The March, 2020 emergency allotment will be available on April 12, 2020.  The April emergency allotment will be available on May 10, 2020.  The emergency allotments will be issued on the client’s existing electronic benefits transfer card.

Counties must employ mass change informing practices to inform of the emergency allotment, including text messaging, robocalling, social media, client-facing websites and pre-recorded calls on interactive voice response systems.  (All County Welfare Directors Letter, April 2, 2020.)

COVID-19 suspension of periodic reporting and annual recertification

The California Department of Social Services (CDSS) has issued instructions implementing Executive Order N-29-20 regarding eligibility redeterminations for CalWORKs and CalFresh.  CalWORKs and CalFresh redeterminations are suspended for March, April, and May, 2020, and months or partial months of CalWORKs aid are exempt from being counted toward the 48-month time clock through June, 2020.

For March CalFresh and CalWORKs semi-annual reports (SAR 7s), as many discontinuances as as possible will be stopped using an automated process.  For March SAR 7s that have already been processed, counties must manually rescind any discontinuances as a result of information on the SAR 7.  Processing that resulted in a benefit increase will not be changed.  Counties must stop processing March SAR 7s.

Households will continue to receive benefits in the amount they were eligible for in the month the report was due.  That amount will continue unless the household completes a voluntary or mandatory report resulting in a benefits change.

For March CalFresh annual recertifications and CalWORKs annual redeterminations, households will be granted a new six-month certification period with a recertification due in September, 2020.  All CalFresh households granted a new six month certification period must be issued a notice informing of their new certification period and new recertification due date.  Otherwise, March annual recertifications and redeterminations are handled in the same way as the March SAR 7s.

For April and May CalFresh and CalWORKs SAR 7s, automated mailing of the April and May SAR 7 documents has stopped.  Households will continue to receive benefits in the amount they were eligible for in the month the report was due.  Households must continue to complete all mandatory reports. The waiver of the SAR 7 reporting requirement does not change the household’s originally assigned certification period.  That amount will continue unless the household completes a voluntary or mandatory report resulting in a benefits change.  Counties will disregard any April or May SAR 7s that are submitted.

For April and May CalFresh recertifications and CalFresh retedetminations, households will be granted a new six-month certification period with a recertification due in October or November, respectively.  Automated mailing of May recertification packets will stop.  April recertification packets have already been mailed.  Households will continue to receive benefits in the amount they were eligible for in the month the report was due.  That amount will continue unless the household completes a voluntary or mandatory report resulting in a benefits change.  Counties will disregard any April or May recertifictions or redeterminations that are submitted.

Transitional CalFresh households who have recertification due in March, April or May will need to complete recertification as originally scheduled.

The county welfare department computer systems have stopped all discontinuances set to occur in March, April, May or June for exceeding the 48-month time on aid limit.  Cases that have already been discontinued for exceeding the 48-month time on aid limit in March should be reinstated through June.  People who are on a time-limit extender must continue to meet the extender requirements to remain on aid.

Counties should implement mass informing practices to communicate this change such as a message on their websites, social media and interactive voice response systems. (All County Welfare Directors Letter, March 27, 2020.)