Clarifications of Income Reporting Thresholds (IRT) in the CalFresh program

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This is a must-read for CalFresh advocates. But to read a 10-page All County Letter like ACL 15-42 is to be reminded how complicated and therefore error-prone welfare programs have become, or at least continue to be, despite improvements such as broader categorical eligibility and simplified reporting requirements. Exhibit A here is an admittedly helpful chart on page two that breaks down six differing types of CalFresh-eligible households, each with differing rules for gross income limits and/or household compositions, with corresponding semi-annual reporting requirements (SAR), triggered by the applicable Income Reporting Thresholds (IRT). Or not.

This is an arena where client advocates need to be something akin to a tax lawyer. Perhaps it was a bit of CDSS humor that it chose to publish this on Tax Day? In any event, the rules here are quite technical and demand close reading to get them right. ACL 15-42 (April 15, 2015). Be sure also to review the “errata” related to these same issues in ACL 14-56E, laying out corresponding corrections to its earlier 2014 ACL about CalFresh modified categorical eligibility (MCE).

Updated County instructions about verification of Social Security numbers and income

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In July 2014, the Social Security Administration (SSA) announced the availability of SSA benefit verification letters and other SSA verification processes, via its My Social Security site. CDSS has now issued updated instructions (along with a few pointed reminders) to counties about the changes in the SSA processes for verification of Social Security account information, and how they relate to largely unchanged CDSS requirements for a client’s submission of Social Security numbers and income information. The specifics for verification of Social Security account information vary somewhat in the CalWORKs, Medi-Cal and and CalFresh programs, highlighted here. There is language here that is horatory but still helpful to the client’s cause, where CDSS reminds counties that “the CWD shall make every effort to assist the individual in obtaining the documents necessary to submit a complete application for a SSN card” and “strongly recommends that counties ensure that the forms they are using are adequate in providing all necessary information to clients.” ACIN I-24-15 (April 13, 2015).

Counties must accept updated Medi-Cal beneficiary address information from health plans

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DHCS has instructed counties that they must accept updated beneficiary contact information from managed care plans.  If the beneficiary approves of the plan doing this, the county must update within 2 days.  If the beneficiary has not approved, the county must contact the beneficiary to get an update within 5 days.  DHCS ACWDL 15-19 (4/16/15).

Counties should also accept this information from Health Care Options immediately, with consent from the enrollee.  DHCS ACWDL 15-20 (4/27/15).

New Medi-Cal noticing requirements under Rivera

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DHCS issued guidance about notice requirements for Medi-Cal applicants whose applications have not been processed within 45 days per the Rivera decision.  These beneficiaries have a right to file an appeal and request a hearing when the Medi-Cal determination has not been made within 45 days of application.

To comply with these requirements, DHCS has implemented in two phases a Rivera notice that foregoes the 90 day deadline to file for a hearing (applicable only for Rivera notices).  Notices are available only in English and Spanish; samples are available with the letter.

DHCS MEDIL I 15-11 (4/7/15)