The California Department of Social Services has issued instructions implementing changes to the Inter-County Transfer (ICT) process required by SB 1339.  Effective June 1, 2017, CalWORKs and CalFresh recipients can report a move to either their old county or their new county.  CalWORKs recipients must report a change of residence within 10 days of the actual move.  Failure to report a move, by itself, cannot be a basis for an overpayment, overissuance or other negative action.

The county that the recipient informs of the move must initiate the ICT process within seven days.  Benefits must be transferred from the sending county to the receiving county with no redetermination or recertification of eligibility in the receiving county.  The new county cannot interview the recipient, request or require a new application, or request or request any verification.  The new county can interview the client only regarding Welfare-to-Work participation.

The sending county must provide the receiving county copies of documents necessary to verify current benefits and grant amount within seven business days, including the most recent SAR 7, SAWS 2 Plus, SAWS 1 and Welfare-to-Work plan.  Benefits and payment responsibility must be transferred to the receiving county no later than the first day of the next month following 30 days after the county is notified of the move.  If the move is from a Region1 to Region 2 county or visa versa, the receiving county adjusts the grant accordingly.

The county can provide the Child Care Request form (CCP 7) as part of the ICT process, but the recipient must apply for child care in the receiving county.

The receiving county is responsible for determination of homeless assistance eligibility and issuance of homeless assistance benefits.

The process is the same for non-assistance CalFresh cases except that CalFresh recipients are not required to report a mid-period move to a new county.  CalFresh recipients are encouraged to promptly notify the county when they move to another county to ensure continuity of benefits.

The ICT process now applies to Transitional CalFresh cases.  This change will be effective when the computer systems are programmed for it, but no later than September 1, 2017.  (ACL 17-58, June 23, 2017.)

The California Department of Social Services (CDSS) has issued instructions about using electronic signatures in the CalWORKs and CalFresh programs.  Electronic signatures can be used for applications, recertifications and periodic reports.

An electronic signature for CalFresh must have each of the following: 1) the client must take an affirmative action to indicate agreement such as entering a PIN number or a verbal statement, 2) the record of the signature must be maintained electronically and linked to the document to which the signature attests and 3) the process must constitute a legal signature as defined by the California Secretary of State and the Uniform Electronic Signatures Act. (Civil Code Section 1633.1 et. seq.)

Electronic signatures can include handwritten signature input onto an electronic signature pad; handwritten signature, mark or command input on a display screen; digitized image of handwritten signature that is attached to an electronic record; typed name; unique identifier (for example a password or PIN); electronically recorded sound; using a mouse to click a button such as an “I agree” button) or a digital signature.

Counties must maintain the electronic record of the signature linked to the document for a minimum of three years.  For telephone signatures, the county must have technology to catalog and maintain a retrievable audio file recording of both the household’s assent and a summary of what the household is agreeing to.  For other electronic signature options, the county must have technology to catalog and maintain a record of the household member’s affirmative action agreeing to using electronic signatures.

Counties must promptly provide a written copy of information given over the telephone with simple instructions for correcting errors or omissions, establish privacy safeguards and must ensure that the electronic signature option does not interfere with the right to apply in person or in writing.  CDSS recommends that counties consider using a unique identifier as an alternative to telephone signatures.  Counties are not required to transmit the record of electronic signature to the receiving county in an inter-county transfer.

The same instructions apply to CalWORKs except that CalWORKs requires a face-to-face interview for applications unless the county has opted to allow telephone interviews, and all aided adults must sign application, reporting and recertification forms.  The requirements in the Uniform Electronic Signatures Act apply to CalWORKs.  (ACL 17-57, June 9, 2017.)

The California Department of Social Services has issued instructions about processing Income and Eligibility Verification System (IEVS) data matches.  IEVS is a system to verify income and other information for applicants and recipients of both CalWORKs and CalFresh.

County staff must review IEVS information and compare it to information in the case record. If the information is consistent with information provided by the applicant or recipient, no action is taken.  If the information is different from information provided by the applicant or recipient, the county must verify the information from IEVS to determine if it affects eligibility or benefit level.  County staff first requests verification from the recipient.  If the recipient is unable to provide verification, county staff must seek verification from third-party sources (an employer for example).  After the county has received third party verification, county staff determines the effect on eligibility or benefit levels.

Follow-up with the recipient following an IEVS match must happen within 45 calendar days of CDSS transmitting the match to the county.  If there is no discrepancy, the county must make a case note documentating that determination.  For CalFresh only cases, failure to respond to this letter within 10 days can be a basis for terminating benefits.

Counties must either establish an overpayment or overissuance or determine that no discrepancy exists by the end of the quarter following the quarter when the county received the IEVS match.  This timeframe does not apply to closed cases.  A pending investigation by the county Special Investigation Unit cannot delay processing of an IEVS match.  ACL 17-41 (June 6, 2017).