CalWORKs

COVID-19 CalWORKs Welfare-to-Work guidance

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The California Department of Social Services (CDSS) has issued guidance regarding the impact of COVID-19 on CalWORKs Welfare-to-Work (WTW).

Counties should exercise discretion regarding optional documentation and verification in order to continue providing WTW services and supports.

Counties can issue temporary blanket good cause for not meeting WTW requirements.  This includes all initial engagement activities, all assessments and evaluations, completion or maintenance of a WTW plan and WTW participation.

Sanctioned clients may now have good cause not to participate or who have a cure plan with activities that are no longer available.  For those clients, counties should implement cure plans documenting that the activity that the client failed to do is not available because of COVID-19.  The cure plan can specify an alternative activity such as reviewing orientation materials or conducting job search online.  When assigning another activity is not practical or feasible because of COVID-19, counties may implement cure plans stating the lack of available activities and that the client temporarily has good cause not to participate.

Counties cannot cure all sanctioned participants because of COVID-19. Clients must sign a cure plan.  Counties are encouraged to issue pre-populated sanction sure plans for individuals to sign without solicitation from the client.  Counties should consider telephonic, electronic or mail-in signatures.  For counties that cannot accept electronic or recorded telephonic signatures, counties must enter a case not stating the individual attested to the information provided.

For clients who are in noncompliance but are not yet sanctioned, counties should make all attempts to avoid imposing sanctions by offering other available and appropriate activities, or by applying good cause.

Counties can continue subsidizing wages in the Expanded Subsidized Employment program even when the worksites are closed because of COVID-19.

CalWORKS Work Study subsidies can continue where work hours are reduced, worksites are closed or students are otherwise unable to meet work study obligations because of COVID-19.  For example, the subsidy may continue when students are unable to work because of lack of supportive services, such as when the student’s child care provider is closed because of COVID-19.  The subsidized payment can be made directly to the CalWORKs recipient, or through the employer or third-party payor if they are able to issue subsidized wages to the recipient.  (All County Welfare Directors Letter, March 30, 2020.)

COVID-19 new interim homeless assistance program guidance

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The California Department of Social Services (CDSS) has issued new guidance CalWORKs Homeless Assistance (HA) and COVID-19.  This new guidance supersedes CDSS’ March 19, 2020 All County Welfare Directors Letter for HA only.

Up to 16 days of motel vouchers are available from HA for eligible or apparently eligible CalWORKs participants.  Because of COVID-19, counties may waive the three-day limit to verify homelessness.  Counties may issue benefits in increments of more than one week, up to all 16 days at once.

Families should be granted good cause for not completing daily permanent housing search.

Receiving HA because of a state or federally declared disaster does not count against a client’s once per 12-months limit on HA.  In addition, clients affected by COVID-19 may be eligible for an exception to the once per 12-months limit because of uninhabitability of the home or a medical illness. For example, if a parent needs to isolate themselves because of COVID-19, HA should be granted based on exception because of medical illness.

HA applications are not required to be made in person or to include a face-to-face interview.  Counties can complete the application and have the client electronically sign it.  Counties can also record a verbal attestation over the phone or enter a case note stating the client attested to the information.

Counties can accept sworn statements for not providing paper verification such as hotel receipts or counties can grant good cause for not submitting paper verification.

Although existing guidance requires counties to issue vendor payments when there has been a finding of mismanagement, if there is no feasible way to issue vendor payments because of COVID-19, counties should consider issuing benefits on the client’s EBT card.  (All County Welfare Directors Letter, March 31, 2020.)

COVID-19 suspension of periodic reporting and annual recertification

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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.)

Interim housing and homeless program guidance on COVID-19

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The California Department of Social Services (CDSS) has issued guidance regarding CDSS housing and homeless programs for COVID-19.  The guidance relates to CalWORKs Homeless Assistance (HA), CalWORKs Housing Support Program (HSP), Bringing Families Home (BFH), Housing and Disability Advocacy Program (HDAP) and Home Safe.

CDSS does not limit the number of days of interim shelter, including nights in a hotel or motel, for HSP, Bringing Families Home, HDAP and Home Safe.

HA applications are not required to be in person or to include a face-to-interview.  Counties can complete the CW 42 application form for the client and have then sign electronically.  Existing rules requiring issuing 3-days of benefits while homelessness is verified remain in effect.  However, counties are strongly encouraged to issue benefits without requiring clients to come to the office, including allowing sworn statements and granting good cause instead of requiring clients to come to county offices.  Although existing guidance requires counties to issue vendor payments when there has been a finding of mismanagement, if there is no feasible way to issue vendor payments because of COVID-19, counties should consider issuing benefits on the client’s EBT card.

Clients affected by COVID-19 may be eligible for an exception to the once-every 12 months rule for HA.  For example, if a parent in an assistance unit is concerned about infection and asks to isolate themselves, HA should be granted based on an exception because of illness.

HDAP funds can expand existing housing options used by HDAP clients, including shelters, recuperative care housing, hotel or motel leases, or interim housing programs.  For example, expanding a shelter program could include offering specialized quarantine options or leases with motels to provide housing for homeless persons impacted by COVID-19.  Counties can also purchase supplies for a specialized quarantine area or establish a new shelter program for HDAP clients specific to COVID-19.  In addition, HDAP funds can be spent on outreach to locate persons potentially eligible for HDAP who are residing in homeless camps who require medical care related to COVID-19.

Home Safe funds can be spent on landlord engagement, including incentives for landlords to participate in Home Safe.  Such payments can include in-kind goods to address COVID-19 impacts such as medical or sanitizing equipment and supplies.  Home Safe funds may also be used for interim housing, including motels.

HSP funds can be used for a range of financial and supportive services, including providing interim housing, helping participants navigate systems of care, providing rental assistance, incentive payments in the form of good for landlords participating in HSP, and supplies necessary to keep housing habitable.  Counties can provide landlord mediation and discussion of tenant’s rights to avoid eviction or housing displacement.

BFH for families experiencing homelessness or at risk of homelessness with an open child welfare case can include interim housing, tenant engagement, case management, public systems assistance, and conflict mediation with landlords or neighbors.  BFH can locate and pay for motel stays for families seeking interim housing that is not a shelter.  BFH can also pay for cleaning supplies.

A three-day notice to pay rent or quit meets eligibility requirements for HA, BFH, HDAP and Home Safe.  HA can be used to pay up to two month rental arrearages to prevent eviction.  (ACWDL, March 19, 2020.)

The HA provisions of this letter are superceeded by All County Welfare Directors Letter, March 31, 2020, summarized here.

90 day suspension of redeterminations, CalWORKs clock stop, and public meeting requirements

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Governor Gavin Newsom has issued an executive order regarding public benefits programs in California.  The executive order suspends otherwise required redeterminations for Medi-Cal, CalWORKs, CalFresh , Cash Assistance Program for Immigrants, California Food Assistance Program, and In Home Supportive Services for 90 days.

The executive order also stops the CalWORKs 48 month time clock through June 17, 2020.  Any month or partial month of CalWORKs received will not be counted toward California’s 48 month time on aid limit.

The Executive Order also suspends any requirement of physical presence in the Brown Act or the Bagley-Keene Act for meetings or local or state bodies.  Meetings of state or local bodies held via teleconference and allowing members of the public to observe and address the meeting shall satisfy any requirement that the body allow members of the public to attend the meeting and offer public comment.

The body must have a procedure for reasonable accommodations for persons with disabilities and advertise that procedure in each public meeting notice.  Requirements for notice of the time and agenda for meetings are unchanged, except that the notice of the time of the meeting must also give notice of how the public may observe and comment.  These public meeting provision apply as long as state or local public officials have imposed or recommended social distancing. (Executive Order N-29-20, March 17, 2020.)

CDSS guidance regarding COVID-19

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The California Department of Social Services (CDSS) has issued guidance regarding the impct of COVID-19 on CalWORKs, CalFresh, housing and homelessness programs, and Refugee Cash Assistance.  Counties must ensure continuity of and safe access to services during pandemic conditions or periods of social distancing.

Current CalWORKs recipients are eligible for waiver of existing rules regarding homeless assistance, including the once-every-12-months limit.

Counties are encouraged to explore Diversion eligibility.  Diversion is designed to address a specific crisis or item of need and may be appropriate for affected families.  People who receive diversion are not subject to work requirements or child support assignment.  However, Diversion payments count toward the 48-month time on aid clock.

For CalWORKs applicants, when evidence concerning eligibility does not exist, the applicant’s sworn statement under penalty of perjury is sufficient except for verification of U.S. citizenship or immigration status, and medical verification of pregnancy.  Written statement is also acceptable to establish residency for the forseeable future.  The photo identification requirement is unchanged, meaning that if the applicant cannot present photo identification within 15 days of application, aid shall continue if the applicant presents evidence of good faith efforts to obtain photo identification.  Income rules remain the same.  Some persons impacted by school or work closures will no longer have an income that is reasonably anticipated.

For CalWORKs, counties can conduct interviews telephonically or by electronic means.  Counties that want to implement electronic/telephonic interviewing now because of COVID-19 can contact CDSS for immediate approval, and must submit a plan to CDSS within one week of implementation.

Counties may provide welfare-to-work good cause or exemptions in response to COVID-19. Good cause determinations should be made on a case-by-case basis.  However, counties can implement county-wide good cause to avoid face-to-face interactions to mitigate COVID-19.

Child care providers may not be reimbursed for days on which the provider is not operating unless that provider has a paid day of non-operation and can provide documentation that contractual terms require parents to pay for days of non-operation.  Reimbursable days of non-operation are limited to 10 days per fiscal year.  Payments to alternative providers when regular providers are not operating are limited to 10 days per child per fiscal year.  Counties must pay for child care on behalf of the client when the child is ill for during excuses absences for illness or quarantine.

For CalFresh, counties should promote online, phone or mail-in applications.  Counties should conduct as many interviews as possible by phone.  Counties should fulfill EBT card replacement requests by phone or mail as often as possible.

Counties must ensure that they are granting maximum allowable CalFresh certification periods.  Counties should maximize use of existing databases for verification.  If a household cannot provide required verification because of unusual circumstances, self-certification can be used.

Counties can exempt households from certain requirements for good cause.

If county offices close during regular business hours, they must make it possible for individuals to apply for and receive CalWORKs and CalFresh, including emergency benefits, within time frames required by state and federal law.  Counties must also provide notice of hours of operation, and procedures during closure hours for applying for and receiving benefits.  These procedures must include making applications available and providing a drop-box or mail slot for filing applications.  Such applications must be deemed to have been filed on the date of the county closure.  Counties must maintain sufficient staff to accept and act upon all applications, and telephone staff to accept and act upon all applications as if they were made in person.  This includes making immediate need available no later than the third calendar day following the application date.

Refugee Cash Assistance and Refugee Support Services will use the CalWORKs guidance.  (ACWDL, March 12, 2020.)