Extension of waiver to combine CalFresh reminder notice and notice of adverse action

The California Department of Social Services (CDSS) has issued guidance regarding an extension of a federal waiver allowing combining the reminder notice and notice of adverse action for households that fail to submit a complete semiannual report form (SAR 7) by the required filing date.

The waiver extension continues the current practice of sending the NA 960X notice to households that did not timely submit a SAR 7 and the NA 960Y notice to households that submitted an incomplete SAR 7.  Both the NA 960X and the NA 960Y act as combined reminder notice and notice of adverse action.

Counties must send the NA 960X or the NA 960Y no later than 10 days after the SAR 7 report should have been submitted.  If a household files a complete SAR 7 during the 10 days period following the date the NA 960X or the NA 960Y is mailed, the county must provide benefits no later than 10 days after the normal benefit issuance date.  (ACL 20-52, May 1, 2020.)

CalFresh verification requirements and job loss reports

The California Department of Social Services (CDSS) has issued guidance regarding CalFresh verification requirements and treatment of reports of job loss or zero income at initial application and thereafter.  CDSS has listed 13 categories of information that must be verified.  Not all of those mandatory verifications apply to all households.  The county must only verify information that applies to the household and/or to claim a deduction.  Of the household cannot provide verification to claim a deduction and the household is eligible without the deduction, the county must complete the eligibility determination.  The household may qualify for the deduction later if they provide the verification.

Counties cannot require a specific type of verification even if the information is considered a mandatory.  Verification can be provided by various methods including documentary evidence, electronic verification, collateral contact and client statement.   When certain verification methods are unavailable to the household, the county must use the best available information.

Counties must assist all households in obtaining mandatory verification.  Counties must use existing verification sources when available, and electronic verification when applicable to the household.

Information that is not considered mandatory verification must only be verified is it is questionable.  The county must document in the case record why the information is considered questionable before requesting verification from the household.

At initial application, households must provide verification of income earned over the last 30 days unless the household just started working.  Verification of job loss is not mandatory. When a household member reports to have lost a job, the county must not require verification unless it is questionable.  The client’s statement of recent job loss is sufficient evidence that a household cannot reasonably anticipate income from that job to continue during the certification period.

When a household has zero income at initial appliction, a statement on the application that it has zero income is sufficient evidence that the household cannot reasonably anticipate income during the certification period.  The county must not require verification of zero income unless it is questionable.

When a household member is subject to CalFresh work requirements and the county learns that the applicant voluntarily quit their job within 60 days prior to the date of the application, the county must determine whether there was good cause to quit.  The county must request verification if the information provided is questionable.

When a CalFresh household reports a job loss after initial application, counties must request verification of the decrease in income and the amount of the decrease.  If the job loss caused a decrease in income of $50 or more, the county must verify the household’s new income to determine continuing eligibility.  If the job loss led to zero income, a statement from the household that it has zero income is sufficient unless it is questionable.

For voluntary mid-period reports of a decrease in income of $50 or more, the county must change benefits no later than the month following the month when the decrease was reported.  If the change was reported after the 20th of the month and it is too late to adjust the following month’s benefits, the county shall issue an underpayment by the 10th of the following month.  (ACL 20-48, April 22, 2020.)

COVID-19 PUC, PEUC and PUA are income for CalFresh

The California Department of Social Services (CDSS) has issued guidance regarding counting benefits from new unemployment programs as income for CalFresh.  Benefits from the Pandemic Unemployment Compensation (PUC), Pandemic Emergency Unemployment Compensation and Pandemic Unemployment Assistance program are unearned income for purposes of CalFresh eligibility and benefits.  (ACWDL, April 21, 2020.)

COVID-19 overpayment and overissuance collection

The California Department of Social Services (CDSS) has issued guidance regarding temporary changes to Franchise Tax Board (FTB) and Treasury Offset Program (TOP) collection of CalWORKs overpayments and CalFresh overissuances.

On March 25, 2020, FTB suspended all non-tax collection, including CalWORKS and CalFresh debts, until July 15, 2020 because of COVID-19.  FTB pre-offset letters will be suspended.

California was granted permission by the Food and Nutrition service to suspend TOP offsets for CalFresh debt between April 6, 2020 and July 6, 2020. TOP pre-offset letters will continue to be generated for debts that are 120 days delinquent.

Counties may approve refund requests for circumstances related to COVID-19 for TOP and FTB collections that occurred on or after March 1.  This is discretionary with the county.  These debts will remain outstanding to be collected starting in July, 2020.  Any refunds must also include administrative fees.

Counties may continue to accept payments and enter into new repayment agreements.  Counties can modify agreements or defer payments on request to mitigate the effects of COVID-19.

All other collection activities should continue.  (ACWDL, April 16, 2020.)

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.)