Reasonable Accommodations in RCA, ECA, and TCVAP programs

County Welfare Directors (CWDs) must ensure equal access to Refugee Cash Assistance (RCA), Entrant Cash Assistance (ECA), and Trafficking and Crime Victims Assistance Program (TCVAP) cash aid for individuals with disabilities. Reasonable accommodations may involve waiving rules or modifying procedures to enable individuals with disabilities or their associate’s full access to programs while avoiding sanctions. During all stages of aid administration, CWDs must proactively identify needs and respond accordingly. Requests can be made at any time and in any form. Additionally, there is no cap on the number of accommodations individuals may request.

Notice of accommodation rights may be provided verbally in face-to-face interviews, group presentations, in written communications, or through published materials such as posted notices and outreach materials in newspapers. Notices must always be given in plain language.

CWDs are required to notify RCA/ECA and TCVAP cash aid applicants/recipients of their rights through California Department of Social Services Publication 86/13 and on CWD-generated recruitment materials in all languages translated by the California Department of Social Services. Posters must be prominently displayed in all CWD waiting rooms and reception areas. All web pages with general information about RCA/ECA and TCVAP cash aid must contain a nondiscrimination statement. Additionally, webpages must have accurate and clear information about programs serving noncitizens.

When a disability is known or obvious, the CWD must determine whether an RCA/ECA or TCVAP cash aid applicant/recipient needs additional assistance while identifying disability-specific accommodations. When communication limits the ability to determine whether an applicant or recipient has a known or obvious disability, CWDs are required to establish virtual screening questions for all intakes and redeterminations.

An applicant/recipient does not need to disclose a specific diagnosis or condition before requesting accommodation, and a CWD cannot ask for verification nor challenge the legitimacy of the accommodation. CWDs must accommodate individuals with Limited English Proficiency and provide auxiliary aids, such as interpreters, Braille, or large print materials, at all stages of the intake and redetermination process.

Staff must initiate offers of accommodation during any point of interaction, regardless of whether the individual explicitly uses the word “disability,” and requests must be honored unless they impose an undue burden or fundamentally alter the program. Denials require high-level review and documentation by the CWD Director or their designee.

RCA/ECA and TCVAP applicants/recipients may request reasonable accommodation at any time, in any form (in person, phone, writing), by themselves or through a representative. Requests can be modified or withdrawn, and no special forms or procedures are required. Accommodations may apply across all program stages and components, including applications, redeterminations, rights notifications, employment services/education, exemptions, extensions, sanctions, participation support, appeals, and fraud investigations.

No specific terminology is required, and requests may be made in descriptive or indirect language. Staff must recognize these, ask whether the request is related to a disability, and clarify the type of assistance needed. Requests may also be made due to the disability of someone associated with the applicant (e.g., a caregiving situation). The ADA does not require disclosure or verification of a medical diagnosis; only a disability-related need for the accommodation must be stated. Staff cannot challenge the legitimacy of the disability but may ask clarifying questions to understand the limitation or the connection between the disability and the accommodation.

If agreement is not immediate, the CWD must begin the “interactive process” to explore solutions. All requests must be considered, and accommodations granted as requested or mutually agreed upon through this process, unless legally valid grounds exist for denial.

A CWD may deny a reasonable accommodation request only if it would fundamentally alter the program, service, or activity, or impose an undue financial/administrative burden. Such denials must be decided by the CWD Director or designee, and the fact that a request falls outside usual program rules is not sufficient grounds for denial. CWDs must document all disability-related disclosures, reasonable accommodation requests, and subsequent actions in the applicant’s/recipient’s case file

CWDs must provide civil rights training to all public contact staff (eligibility workers, employment specialists, domestic abuse providers, supervisors, program managers, reception, clerical staff, appeals specialists, civil rights staff, etc.) at least every two years, though annual training is encouraged. CWD’s are required to train public contact staff, program managers, and supervisors upon hire and, at a minimum, annually providing reasonable accommodations to people with disabilities. Training must cover how to notify applicants/recipients of their rights, identify disabilities, respond to and document accommodation requests, and check case files for noted needs. Practice exercises on giving notice and offering accommodations are recommended.

Americans with disabilities act (ADA) compliance may require exceptions to RCA/ECA and TCVAP program rules, so staff must be trained on both program rules and nondiscrimination laws, including how to resolve conflicts. These obligations extend to contractors and vendors providing direct. Additional recommended training includes culturally competent service delivery, trauma-informed care, working with victims of crime/trafficking and PTSD, and addressing language and cultural barriers to avoid traumatization and promote safety and trust.

Under the ADA and Rehabilitation Act, CWDs must ensure effective communication with applicants, recipients, the public, and their companions. Qualifying companions include family, friends, or a guardian representative. To do so, they must provide needed auxiliary aids and services such as devices or support services. Primary consideration must be given to the individual’s requested aid or service. CWDs must also guarantee effective communication across all delivery methods (phone, digital, in-person) and ensure staff are trained to access and use these aids.

CWDs must provide individuals with disabilities equal opportunity to participate in and benefit from Employment Servies and Employment-Directed Education/Training. RCA/ECA and TCVAP recipients are generally required to participate unless exempt. Disability alone does not automatically exempt them. CWD’s must ensure access to all programs, not just programs and services designed solely for individuals with disabilities. Collaboration with disability-serving organizations is encouraged to reduce workforce barriers.

Because disabilities vary widely, assessments must be individualized to identify strengths and appropriate services. Where disabilities interfere with participation, CWDs must provide reasonable accommodations, such as adjusting required hours or activity types. Participants should also be informed of their right to request workplace accommodations.

CWDs may find “good cause” for a participant’s noncompliance with Employment Services or Employment-Directed Education requirements. CWDs must consider whether the individual’s physical or mental impairment, illness, or caregiving responsibilities prevented them from participating. Determination must be based on the individual’s reported challenges. If disability-related information emerges during this process, CWDs must offer, document, and provide reasonable accommodations.

If a participant fails to meet program requirements, it may be due to the CWD’s failure to offer or provide necessary reasonable accommodations. If an individual is sanctioned for not being offered needed accommodation, they may file a disability discrimination complaint in addition to an appeal of the sanction.

Individuals who have physical or mental impairment that prevents them from participating in employment or training programs are exempt from Employment Services or Employment-Directed Education/Training requirements. Similarly, individuals who are temporarily unable to participate due to illness or injury may be exempt if a physician verifies their condition. CWDs must respond to each exemption notice by offering, documenting, and, if applicable, providing accommodation in all areas of program participation.

Individuals may require both language services and disability-related accommodations to participate fully in RCA/ECA and TCVAP cash aid. CWDs are required to identify and offer accommodation regardless of language barriers and must provide certified bilingual staff or interpreters with the necessary language skills. Individuals may not be aware that they can request both language assistance and accommodations. Staff must proactively ensure both needs are addressed. (ACL 24-67, October 4, 2025.)

Civil rights obligations to people who are deaf or hard of hearing

County Welfare Directors (CWD) are legally required to ensure that communication with Deaf and Hard of Hearing (DHH) individuals is just as effective as communication with individuals without disabilities. DHH obligations include applicants for services and their companions, such as family members, friends, or associates. Written notes and lip reading are not effective or reliable forms of communication for most DHH individuals.

To ensure effective communication, CWDs must provide auxiliary aids and services promptly. Examples of aids and services include qualified interpreters, notetakers, captioning, and telecommunications devices. DHH individuals can choose which auxiliary aid or service they prefer.

Documentation of services provided to DHH individuals must be detailed and meet requirements for both language access and disability accommodations. Counties cannot charge for auxiliary aids and services.  CWDs must ensure that DHH individuals can obtain information about the existence of services. Best practices include visible posters informing the right to interpreter and including information about language access on websites or notices.

When an individual with a disability requests specific auxiliary aid or service, the CWD must give primary consideration to that request. CWDs must grant the individual preferred aid unless the preference causes undue administrative burdens, fundamentally alters the service, or an equally effective alternative is available. Denials must be approved by the County Welfare Director or their designee and documented with a written statement explaining the reason for the denial. In all cases, the CWD is responsible for offering effective alternative means of communication. There is no limit on the number of disability requests an individual can submit and no specific timeline for making these requests.

CWDs are required to provide interpreters when requested. Interpreters may include American Sign Language (ASL) interpreters, deaf Interpreters, tactile interpreters, or cued-speech transliterators, depending on the individual’s needs. Importantly, CWDs must not require or pressure individuals to bring their own interpreters. Only under minimal circumstances—such as emergencies involving imminent safety threats or when the individual voluntarily chooses to use an accompanying adult—is it acceptable to rely on a non-staff interpreter. Situations where it would be inappropriate for a guardian to provide effective communication include an interview with a child during a Child Protective Services (CPS) investigation. Children should never be used as interpreters except in genuine emergencies when no other options are available.

The California Department of Social Services (CDSS) encourages CWDs to establish contracts with Video Remote Interpretation (VRI) providers to help the CWD fulfill its obligation to provide timely services. VRI allows remote interpreters to facilitate communication via videoconferencing and can be helpful in situations where in-person interpreters are unavailable. However, VRI is not always suitable for every circumstance, especially when a DHH individual has low vision or when visual cues and body language are crucial for communication. Even when VRI is available, CWDs must prioritize the individual’s preferred communication method.

When communicating by phone, CWDs are required to create accessible telecommunication systems, including Video Relay Services (VRS), Text telephones (TTY), and captioned telephone services. However, telecommunication services are not a substitute for in-person interpreting services and should only be used when effective communication can occur by telephone.

CWD staff who interact with the public must receive civil rights and disability accommodation training upon hire and at least annually thereafter. This includes training in requesting interpreters, use of assistive technologies, and proper documentation procedures. In programs involving home visits, such as Child Welfare or CalWORKs, staff must plan to arrange interpreters or bring necessary tools to ensure effective communication off-site. If an interpreter cannot be secured in advance, visits should be rescheduled, except in programs that involve unannounced visits. In such cases, staff must be trained in obtaining real-time interpreter support.

CWDs must consider the unique needs of DHH children in out-of-home placements. For instance, assisting DHH children with communication through Resource Families and contacting individuals outside the home, such as relatives, social workers, or attorneys. Staff should be aware that family members may not be fluent in (ASL), which may necessitate the use of interpretation during visits. (ACIN I-39-24, September 17, 2024.)

Reduction in eligibility period for RCA, ECA, and TCVAP cash assistance

The eligibility period for Refugee Cash Assistance (RCA), Entrant Cash Assistance (ECA), and Trafficking and Crime Victims Program (TCVAP) cash assistance is reduced to 4 months for individual’s whose eligibility start date is on or after May 5, 2025.

The eligibility start date for RCA and ECA is either the date of admission into the united States in a qualifying status, the grant date of a qualifying status, or the issuance date on the Certification of Eligibility Letter for a Victim of a Severe Form of Human Trafficking.  The eligibility state date for TCVAP cash assistance is the date of application.

RCA, ECA, and TCVAP cash assistance recipients whose eligibility started before May 5, 2025 remain eligible for twelve months of benefits.

Groups who are eligible for RCA or ECA are: refugees, asylees, Cuban and Haitian entrants, Amarasians, certain Iraqi and Afghan Special Immigrants (SIVs), certain Afghan Humanitarian Parolees, certain Ukranian Humanitarian Parolees, and certain victims of human trafficking.  People who are eligible for TCVAP cash assistance are qualifying noncitizen victims of human trafficking, domestic violence, or other serious crimes.

Automation of this change is pending.  Program forms and notices must be manually changed until automation is implemented.

CDSS recommends that counties verbally inform clients of this eligibility change until August 5, 2025.

This eligibility reduction does not impact eligibility for Refugee Support Services or TCVAP social services.  (ACWDL, May 2, 2025.)

CalWORKs eligibility for citizens of Compact of Free Association states

The California Department of Social Services (CDSS) has provided guidance regarding CalWORKs eligibility for citizens of the Compact of Free Association (COFA) states of Micronesia, Palau and the Marshall Islands.

Effective March 9, 2024, federal law changed to make citizens of the Compact of Free Association states of Micronesia, Palau and the Marshall Islands qualified immigrants who are eligible for certain federal benefits including federal Temporary Assistance to Needy Families benefits.  The new also exempts these families from the five-year residency requirement to be eligible for benefits.

This change in federal law means that COFA citizens are eligible for CalWORKs.  COFA citizens who applied for CalWORKs on or after March 9, 2024 and were denied because of their immigration status may reapply for CalWORKs.  In processing these applications, counties must check for earlier applications, and if located use the earlier application date for the beginning date of aid.

People who applied on or after March 9, 2024 can ask for an administrative hearing within 90 days of the date of the denial.  If the county determines that the household was eligible for CalWORKs at the time of application, the county must issue retroactive benefits back to the date of application.

CDSS encourages counties to reconnect with COFA citizens who were denied CalWORKs after March 9, 2024.

Counties must verify the immigration status of COFA citizens using the federal SAVE system and the I-94 documentation with the admission stamp.

COFA citizens may also be eligible for Refugee Cash Assistance or Entrant Cash Assistance.  (ACL 24-95, December 16, 2024.)

Update about EBT card mass replacement with chip/tap card

The California Department of Social Services (CDSS) issued an update about the replacement of current EBT cards with chip/tap cards.  This is an update to ACWDL June 6, 2022, summarized here.

Replacement of county administrative equipment was completed in Summer, 2024.  Mass replacement of all current EBT cards with chip/tap cards is expected to begin in early 2025.

The new cards will be mailed in three phases.  The first phase will be combined CalWORKs and CalFresh cases, GA, RCA, TCVAP, CAPI and LIHEAP.

SunBucks and Women, Infants and Children benefits will not be moved to the new chip/tap cards.

Counties must continue to order the current magnetic stripe cards and equipment to ensure that they remain fully stocked until chip/tap cards are deployed.

Prior to mass mailing of the chip/tap cards, counties will get a list of unhoused cardholders who have their mailing address listed as the county welfare department.  The list is intended to support triage for those clients.

During either the Semi-Annual Report or Recertification/Redetermination interview, county workers should tell cardholders to promptly activate their new cards.  One successful transaction with the new card will deactivate the old card.

Cardholders will have 180 days after issuance of the chip/tap card to activate it before the old card becomes unusable.  (ACWDL December 19, 2024.)

Income Reporting Threshold for Fiscal Year 2025

Effective October 1, 2024, a new CalWORKs Income Reporting Threshold (IRT) will be effective.  The new IRT amounts are in a chart attached to this ACL.  Income over the IRT amount must be reported mid-period, that is, when it occurs between semi-annual reports or annual recertifications.  Income that must be reported is the total combined earned and unearned income of the assistance unit.  The IRT reporting amount is 55% of the federal poverty level for a family of 3, plus the amount of income used most recently used to determine the assistance unit’s grant.  Income over the IRT must be reported within 10 days of receipt.

Assistance Units with no income or only unearned income are required to report income changes only if they receive new earned income that, when combined with other earned income, exceeds the IRT.

When income over the IRT is reported to the county, the county must determine if the income is reasonably anticipated to continue.  If it is reasonably anticipated to continue, the county must redetermine the CalWORKs grant amount using the new income amount.  If the grant will be decreased, the county must give timely and adequate notice to decrease the grant at the end of the month.  If the new income amount exceeds 130% of the Federal Poverty Level, the county must discontinue CalWORKs at the end of the month after timely and adequate notice is given.

It is possible that there will be some cases that are over the IRT, but under 130% of the Federal Poverty Level, where the assistance unit will not be eligible for a cash grant.  Those cases will have zero grant, but will be eligible for supportive services and CalWORKs special needs.

Counties must inform recipients of their IRT at application approval, at least once per semi-annual reporting period, and whenever the IRT amount changes.  The IRT level which the recipient was last notified of is used for reporting purposes.

These instructions also apply to Refugee Cash Assistance, Entrant Cash Assistance and Trafficking and Crime Victims Assistance Act.

The income reporting threshold for a CalWORKs assistance unit of 1 is $1,632, for 2 is $2,215, for 3 is $2,798, for 4 is $3,380, for 5 is $3,963, for 6 is $4,456, for 7 is $5,129, for 8 is $5,712, and add $583 for each additional member. (ACL 24-63, September 6, 2024.)