Welfare to Work and college summer session, winter intersession and adult school

SB 1232 (2020) changed education as a welfare-to-work activity for publicly funded institutions, including establishing an advanced standard supportive services payment for necessary books and supplies, requiring counties to accept education as a welfare-to-work activity, allowing 3 hours of study time for each academic unit, and mandating that full time post-secondary school enrollment meets minimum welfare-to-work requirements.  The California Department of Social Services (CDSS) has provided clarification regarding application of welfare to work policies to summer session, winter intersession, adult schools and adult education.

For education activities that do not have academic units such as non-credit courses and adult schools, one instructional hour will be considered one academic unit, rounded up to the nearest hour.

Students in summer sessions that last the duration of the summer term as determined by the academic institution, are eligible for a $350 supportive services payment for full-time enrollment and $175 for part-time enrollment.  For a condensed summer session, all students are entitled to a $175 supportive services payment.  Students enrolled in two condensed summer sessions are entitled to two $175 supportive services payments.  Students who are enrolled full time meet their minimum welfare-to-work requirements regardless of the duration of the session.

All students enrolled in winter intersessions are entitled to a $175 supportive services payment.  Students who are enrolled in winter intersessions meet their minimum welfare-to-work requirements.

For adult schools, students enrolled for 13 weeks or less are considered enrolled in a quarter term, and students enrolled for more than 13 weeks are considered enrolled in a semester term.  This applies to open entry enrollment.  Students who enroll midsession have their quarter/semester determination made based on the number of weeks they have enrolled.

For adult schools, enrollment for 12 or more instructional hours per week are considered full time. Enrollment for less than 12 hours is part time.  Enrollment in an academic session that is less than 8 weeks is part-time for purposes of the standard supportive services payment.  The number of hours in a self-directed course is based on the number of expected hours for the course as documented in school materials.

For adult schools, study time is calculated based on the number in instructional hours.  Students get 3 hours of study time per instructional hour.  Students can request actual study time that is more than 3 hours per hour of instruction if the school verifies the need or based on the student’s individual need (such as a learning disability that requires more study time).

For students enrolled in multiple education institutions at the same time, counties must determine the number of units or instructional hours across all institutions.  Students who are enrolled for a total of 12 units or hours, or more, are full time, and students enrolled for less than 12 units or hours are part time.  Students enrolled in quarter-based and semester-based programs at the same time receive the semester standard supportive services payment amount.

Clients must provide proof of enrollment for each term.  Counties must provide a new or revised welfare-to-work plan at least 30 days prior to the start of the term.  If the county does not provide a new plan, the prior plan remains in effect.  Counties must issue the standard supportive services payment regardless of whether a welfare-to-work plan is signed on time.  The standard supportive services payment must be issued at least 10 days prior to the start of the term.

Overpayments can occur when the client is not eligible for the payment they received, such as not being enrolled.  Overpayment do not occur if the client’s enrollment status changes or they drop out.  Counties cannot ask for receipts to show how the supportive services payment was spent.  Counties cannot seek an overpayment is the actual cost of books and supplies is less than the standard supportive services payment.

For requests for supportive payments above the standard supportive services payment amount, the student must verify the expenses that exceed the amount of the standard supportive service payment.  The county shall issue the amount that exceeds the standard supportive services amount within 20 days of the request and providing verification of expenses.  (ACL 22-31, April 27, 2022.)

Changes to Integrated Earnings Clearance/Fraud Detection match frequency change

Integrated Earnings Clearance/Fraud Detection (IFD) is quarterly match that gives various income data to the California Department of Social Services (CDSS) to compare CalFresh and CalWorks records submitted by the counties. These records show quarterly wage data maintained by the Employment Development Department (EDD) and Social Security Administration (SSA).

A workgroup was formed in 2016 to provide technical assistance, updates on policy changes, and calculations of best practices to ensure precise determination for benefits in the California Work Opportunity and Responsibility to Kids (CalWORKs) and CalFresh programs.

The workgroup identified some previous issues with the frequency and outdated data provided by the IFD match. Finding that data was nine months old by the time it reached the association. Income data will now come in faster and will be no more than four to six months old to prevent outdated information from showing up two quarters later. The processing timeframes for the IFD match remain unchanged. Match follow-up must be finalized within 45 days of transmission of the data to the County Welfare Departments.  (ACIN I-30-22, April 21, 2022.)

Eligibility of Ukranian nationals for federal and state benefits

The California Department of Social Services (CDSS) has provided guidance regarding eligibility of Ukranian nationals for various public benefits programs.

Ukranian arrivals who have refugee or asylee status qualify for CalWORKs, CalFresh, SSI, and Refugee Cash Assistance (RCA).

Ukranian refugees and asylees are eligible for RCA. Persons with Temporary Protected Status are not eligible for RCA.  Counties must accept a declaration under penalty of perjury of the applicant’s immigration status while documentary verification is pending.

Ukranian nationals who have Temporary Protected Status are not eligible for most federal or state public benefits.

Ukranian humanitarian parolees can be eligible for CalWORKs with state funds.  This is because humanitarian parolees have Permanent Residence Under Color of Law (PRUCOL).  This includes eligibility for Homeless Assistance and Housing Support Program, both of which can supplement federal refugee resettlement funding.

Ukranian humanitarian parolees are eligible for the Cash Assistance Program for Immigrants (CAPI).  They are not eligible for SSI.

Ukranian humanitarian parolees are eligible for CalFresh or California Food Assistance Program (CFAP) if they have been paroled into the United States for at least one year.  Paroled for at least one year means the duration of parole.  A humanitarian parolee is eligible for CalFresh or CFAP from the day they are paroled into the United States if their parole will last at least one year.

Public interest parolees must be admitted to the United States for at least one year and must meet two additional criteria to be eligible for CalFresh, including five years of residence, working 40 quarters, children under age 18, elderly or disabled as defined.  People who do not meet two of the additional criteria can be eligible for CFAP.

Ukranians with refugee, asylee or humanitarian parolee status are eligible for Project Roomkey, Bringing Families Home, Housing and Disability Advocacy Program, and Home Safe.

Ukranian arrivals, including humanitarian parolees, can be eligible for Medi-Cal.

Regardless of the documentation presented, counties must verify immigration status with the SAVE system.  (ACIN I-40-22, April 22, 2022.)

CalWORKs time limit exemption for indian country residents in areas with over fifty percent unemployment

The California Department of Social Service (CDSS) has informed County Welfare Departments (CWDs) of Temporary Assistance for Needy Families program updates on whether the Indian Country residents who participate qualify for federal and state time limit exemptions. Members of federally recognized tribes that have over fifty percent unemployment are exempt from both federal and state time limits. The letter identifies federally recognized tribes that had over fifty percent unemployment in 2021. The exemption also applies to tribal TANF programs.

Individuals who live in these areas qualify for the time limit exemption for specified months. If an individual lives in the exterior boundaries of an Indian reservation that is not listed in the letter as having over fifty percent unemployment, the county or Tribal TANF program can get written documentation from the tribe that the individual lived in an area where unemployment of adults is 50 percent or higher.

The California Work Opportunity and Responsibility to Kids (CalWORKS) time limit is 48 months, and the federal TANF time limit for aid is 60 months. As of May 1, 2022, the CalWORKs time limit will increase to 60 months.

CalWORKs applicants and recipients must be informed of all program time limit requirements and of how to request an exemption. Recipients must also be provided with information about their accumulated time on aid at specific intervals.  (ACL 22-28, April 8, 2022.)

Increase in CalWORKs Earned Income Disregards

For the CalWORKs program, certain earned income and disability-based income is disregarded in determining eligibility.  This is called the Earned Income Disregard.  Starting July 1, 2022, the Earned Income Disregard for applicants will increase from the first $90 per month of earned income for each employed person to the first $450 of earned income.

Starting June 1, 2022, the Earned Income Disregard for recipients will increase from $550 per month to $600.   This increase in the recipient Earned Income Disregard applies to the state KinGAP program, but not to the federal KinGAP program.

(ACL 21-130, November 29, 2021 and ACL 21-130E, March 22, 2022.)

 

EBT card CVV enablement and card replacement

The California Department of Social Services is activating Card Verification Value (CVV) on Electronic Benefits Transfer (EBT) cards.  CVV is an is an additional layer of coding embedded in the magnetic stripe on the back of the EBT card and not visible to clients.  It is the three-digit code on the back of credit cards.  However, unlike the CVV number on most credit or debit cards, the EBT CVV number is not printed on the EBT card.

All cards issued by the EBT vendor after June, 2018, and all cards printed at the county welfare department since October, 2019, have the CVV embedded.  Cardholders with EBT cards printed before those dates will need a replacement card.  This is about 911,000 replacement cards.  New cards were mailed from mid-February to mid-March, 2022.  The mailing has instructions for activating the new cards.

The CVV technology will be enabled in late April, 2022.  Cards that do not have the CVV will not work after the CVV technology is activated.  If cardholders have issues with not receiving new cards or with activation of new cards, cardholders need to contact the EBT vendor.  Counties will refer callers to the EBT Customer Service Center.  Counties should follow the current card replacement process if a customer did not receive their new card or otherwise needs a replacement card.  (ACWDL, March 17, 2022.)