COVID-19 Treatment of Pandemic Emergency Assistance Fund payments in various programs

The California Department of Social Services has provided guidance regarding treatment of the one-time payment issued to CalWORKs recipients pursuant to the Pandemic Emergency Assistance Fund (PEAF) for CalWORKs, CalFresh and Medi-Cal.  The PEAF payment was a $640 payment to CalWORKs recipients that was issued on July 10, 2021.  PEAF is to assist low income families impacted by COVID-19.

PEAF does not count as income for CalWORKs and CalFresh and does not count as a resource for 12 months after receipt.  Both MAGI and non-MAGI Medi-Cal treat the PEAF payment as a disaster payment which does not count as income.

Families who received the PEAF payment were informed of the payment by phone and email message during the week of July 12, 2021.

The PEAF payment does not tick either the CalWORKs or federal TANF time-on-aid clocks.

The PEAF payment will not impact the amount of the CalWORKs unreimbursed assistance pool for purposes of child support distribution.

Lost PEAF payments can only be replaced if the assistance unit incurs skimming or scamming of their benefits.  (ACL 21-65, July 22, 2021.)

Increasing dual enrollment between CalFresh and Medi-Cal

The California Department of Social Services (CDSS) now requires counties to provide additional outreach to help bridge the gap between Medi-Cal and CalFresh enrollment. Effective on January 1, 2022, county staff must verbally screen new and renewing Medi-Cal applicants for CalFresh and provide the opportunity to apply for CalFresh if eligible. All CalFresh applicants must also be screened for entitlement to expedited service.

Medi-Cal beneficiaries eligible for CalFresh include (but are not limited to) beneficiaries with Modified Adjusted Gross Income (MAGI) income less than or equal to 200% of the Federal Poverty Level (FPL), non-MAGI income less than or equal to 200% of the FPL, and non-MAGI Aged, Blind, and Disabled (ABD) FPL less than or equal to 138%. If the beneficiary is not interested in CalFresh, then the county must inform them of an online and paper application for the program.

Online Medi-Cal applications (SAWS and CalHEERS) already offer eligible beneficiaries applications to additional benefits programs at the same time. County staff are encouraged, but not required to verbally ask online applicants if they are interested in CalFresh.

Counties must cross-train staff who process Medi-Cal applications to perform CalFresh eligibility determinations.

Counties must designate a CalFresh liaison to establish CalFresh application referral procedures and establish outreach procedures to increase CalFresh enrollment among Medi-Cal applicants and beneficiaries. Counties must provide CDSS with contact information of these liaisons by January 1, 2022.  (ACL 21-52, April 30, 2021.)

Changes to federal Public Charge rule

The Department of Homeland Security will not enforce the 2019 public charge rule. As a result, the 1999 interim field guidance on the public charge inadmissibility provision will now apply.  Under the 1999 Interim Guidance, the Department of Homeland Security and United States Citizenship and Immigration Services will not consider receipt of Medi-Cal (except for long-term care, public housing or CalFresh as part of determining public charge inadmissibility.  Public cash assistance for income maintenance, including CalWORKs, Supplemental Security Income (SSI), Cash Assistance Program for Immigrants and general assistance/general relief.

However, receipt of benefits alone will not automatically cause a public charge determination.  Receipt of benefits is only one factor among several considered as part of the totality of circumstances determination for whether someone is likely to become a public charge.  Receipt of benefits by family or household members is not considered for public charge purposes.

Medical testing, treatment, and preventative services for COVID-19, including vaccines, is not considered for public charge purposes. (ACL 21-32, March 15, 2021.)

COVID-19 Medi-Cal managed care guidance

The California Department of Health Care Services (DHCS) has issued information to Medi-Cal managed care plans (MCP) about changes because of COVID-19.  Several fee-for-service policies already issued apply to Medi-Cal including providing care in alternative settings, pharmacy, transporation and telehealth.  MCPs must waive prior authorization requirements, including screening and testing, for services related to COVID-19.  MCPs are strongly encouraged to implement expedited authorization procedures during the COVID-19 public health crisis.

For Health Homes, DHCS encourages MCPs and their contracted Community-Based Care Management Entities to use telephone and video conference assessments.  In-person requirements are suspended until the COVID-19 emergency declaration is rescinded.

The requirement for an Initial Health Assessment for newly enrolled members within 120 days is temporarily suspended.  MCPs can deter Initial Health Assessments until the COVID-19 emergency declaration is rescinded.  However, Initial Health Assessments must be done for these members when the public health emergency is over.  (APL 20-004, April 27, 2020.)

COVID-19 CCS guidance

The California Department of Health Care Services (DHCS) has issued guidance regarding California Childrens Services and Special Care Centers during the COVID-19 public health emergency.  Policies issued by DHCS regarding Medi-Cal services apply to CCS when Medi-Cal beneficiaries are seeking services from CCS paneled providers.

All DHCS telehealth policies for Medi-Cal services apply to CCS.  Medically necessary CCS services can be delivered in-person or by telehealth.  CCS providers and SCCs should implement telehealth to provide remote consultation during the public health emergency.  DHCS and managed care plans must reimburse CCS providers at the same rate whether services are provided in person or by telehealth if the service is the same regardless of how it is delivered.

The requirement for an in-person Annual Team Conference for SCCs is suspended for the duration of the public health emergency.  DHCS has waived the requirement for an Annual Team Conference as a precondition for authorization of other new or re-authorized services for CCS clients.

CCS hearings may be conducted by phone or video conference.

DHCS is temporarily suspending prior authorization requirements.  Treatment Authorization Requests (TAR) and Service Authorization Requests (SAR) are still required but may be submitted after the date of service.

Telehealth may be used for visits related to a durable medical equipment order, including repairs and supplies.  TAR/SAR can be submitted retrospectively.

DHCS is providing flexibility for High Risk Infant Follow-up (HRIF) services for clinic to use individual approaches for follow-up services.  The age-out limit for HRIF is extended so that the third and final standard visit may be performed up to age 42 months.  (DHCS notice, April 28, 2020.)