The California Department of Social Services (CDSS) has issued guidance regarding delayed processing of CalFresh annual recertifications.  An application for recertification is considered delayed if the recertification process is not completed by the end of the final month of the certification period.

The county should consider an application for recertification timely if it was submitted before the 15th day of the final month of the certification period.

If a household files a timely application for recertification but recertification is not completed within the final month of the certification period because of county-caused delay, the county must continue to process the case and provide a full month of benefits for the first month after the new certification period as soon as administratively possible.

If a household files an application before the end of the certification period but the recertification process cannot be completed within the final month of certification period because of a client-caused delay, the county shall deny the application at the end of the period.  This applies whether the application for recertification was timely or untimely filed.  After the county denies the application, the household has up to 30 days after the end of the certification period to complete the recertification process.  If the household takes the required action within 30 days after the end of the certification period, the county shall withdraw the denial and provide prorated benefits retroactive to the date the client took the required action and completed the recertification process.

If the household files an application for recertification within 30 days following the last month of the certification period, benefits must be prorated based on when the application for recertification is received.  If the application is then delayed beyond what would be the first month of the new certification period because of fault of the county, that delay is considered county-caused delay.

If an application for recertification is received more than 30 days following the end of the last month of the certification period, delayed processing is not permitted.  However, the application for recertification shall be considered a new application for CalFresh and the county cannot require the client to submit an additional new application.

When the county receives an incomplete application for recertification, the county must send a denial notice.  The Notice of Expiration of Certification form does not satisfy the requirement for denying an application for recertification.

When a household misses their recertification interview appointment, the county sends the household a notice of missed interview.  The Notice of Missed Interview is dated to reflect the end of the certification period, even when the certification end date falls on a weekend or holiday.

The Manual of Policy and Procedure will be updated as soon as administratively possible to reflect this guidance.   In the interim, counties must comply with the guidance in this letter.  (ACL 19-10, February 3, 2019.)

CDSS is issuing CalFresh benefits for February 2019 early between January 16 and January 20.  This early issuance is required because, as a result of the federal government shutdown, there is no appropriation to fund the Supplemental Nutrition Assistance Program (SNAP)  after January 20.

Counties must provide client notice as they would for a mass change.  This includes county websites, posters, press and social media.  There is no individual household noticing requirement.  However, counties are encouraged to contact individual households as feasible using communication channels such as text messaging, email and phone messges.

Most clients will receive their benefits between January 16 and 20.  However, some clients will receive benefits on their normal issuance date if they are eligible and federal reserve funds are available.  These clients are 1) current clients who have a report due in January but the report is received and processed after the early issuance but before the end of January; 2) current clients who have a report due in January and whose eligibility is determined after the end of January; 3) News client determined eligible after the early issuance is completed and 4) New clients who apply on or after February 1.  CDSS estimates that about $86 million in benefits is associated with cases which will not be completed by January 20 because reports have not been submitted or case processing is not completed.

Without a new appropriate for the United States Department of Agriculture either by resolution of the federal government shutdown or by enactment of separate legislation appropriating funds for the SNAP program, there is insufficient federal funding for March benefits.  (All County Welfare Directors Letter, January 11, 2019.)

The California Department of Social Services (CDSS) has issued instructions regarding allocation and use of the 15% exemptions for counties implementing the Able Bodied Adults Without Dependants (ABAWD) requirement.

The ABAWD requirements is that able bodied persons age 18 to 49 are eligible for CalFresh for only 3 full months in a 36 month period unless they are exempt or satisfying work requirements.  Federal law gives each state individual exemptions equal to 15% of its annual caseload.  These exemptions allow counties to extend CalFresh eligibility to ABAWDs who would otherwise be ineligible.  Each exemption is equal to one full month of CalFresh eligibility for one ABAWD.

The 15% exemptions are only available to persons at risk of losing CalFresh benefits for not satisfying work requirements.  California has established equivalent exemptions for persons receiving California Food Assistance Program benefits.  People serving a sanction are ineligible for a 15% exemption.

For the period September 1, 2018 to August 31, 2019, San Francisco, Santa Clara and San Mateo counties are subject to the ABAWD requirement.  The ABAWD requirement is implemented by first assessing persons subject to the ABAWD requirement and screening for exemptions, second engaging ABAWDs to find additional work or participate in qualifying work activities, then third providing 15% exemption to maintain food assistance.

For fiscal year 2018, California has 866,894 15% exemptions including exemptions carried over from prior years.  (ACIN I-72-18, October 30, 2018.)