Requirements for truncating Social Security Numbers

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The California Department of Social Services (CDSS) has issued guidance regarding AB 499 (2020) that requires mailings from state agencies, which includes counties operating state and federal programs on behalf of CDSS, to only include the last four digits of a Social Security Number in outgoing mail.

Effective January 1, 2023, with limited exceptions, state agencies must only include the last four digits of a Social Security Number in outgoing mail.  Computer systems must make changes to implement this requirement.  County processes must be revised to meet this requirement.  Computer systems that must make changes to comply include, but are not limited to, CalSAWS and BenefitsCal, CMIPS, ACMS, EBT, Child Welfare Services/Case Management System, Child Welfare Services CARES, and County Expense Claim Reporting Information System.

If a system is unable to make necessary changes in a reasonable timeframe, the system must implement a workaround to redact or truncate all Social Security Numbers in outgoing mail.

Counties should report any mailings that violate this requirement to CDSS using the breach and incident process.  (ACL 23-17, January 31, 2023.)

End of child care flexibility for COVID-19

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The California Department of Social Services (CDSS) has issued guidance regarding the end of child care flexibilities for COVID-19 effective June 30, 2023.

Effective July 1, 2023, provider will no longer be able to bill for non-operational days because of COVID-19 closures.

The statewide waiver of family fees expires on June 30, 2023.  Contractors must resume collecting family fees effective July 1, 2023.

Effective July 1, 2023, providers and contractors will be reimbursed in accordance with pre-COVID-19 attendance and reporting requirements.

Contractors must issue notices of action to the parent when changes are made to the service agreement, including an increase or decrease in family fees.  Due process requires suspending any action while an appeal is pending.  (CCB 23-09, April 13, 2023.)

Disaster Unemployment Assistance for February and March storms

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Residents of Kern, Mariposa, Monterey, San Benito, Santa Cruz, Tulare and Tuolumne Counties can now apply for Disaster Unemployment Assistance (DUA).  DUA is available to workers business owners, and self-employed persons who lost their job or business, or had their work hours reduced or interrupted because of impacts of the severe storms that began on February 21, 2023.

DUA applies to losses beginning the week of February 26, 2023.  Eligible full-time workers and self-employed persons can get between $171 and $450 per week for up to 32 weeks.  Part-time workers and part-time self-employed persons may be eligible.  The last payable week of DUA ends October 7, 2023.

DUA is available to storms victims who meet any of the following criteria:

  1. Worked or were a business owner or self-employed, or were scheduled to begin or resume work or self-employment, in the disaster area and lost work or had their hours reduced or interrupted because of the disaster.
  2. Cannot reach work because of the disaster or can no longer work or perform services because of physical damage or destruction to the place of employment or self-employment as a direct result of the disaster.
  3. Live in the major disaster area and cannot reach their place of work or self-employment outside the major disaster area because of the disaster.
  4. Cannot perform work or self-employment because of an injury caused by the disaster.
  5. Became the major support for their household because of the death of their head of household caused by the disaster.

Persons must have applied for and used all regular unemployment insurance benefits, or be ineligible for regular unemployment benefits, and remain unemployed, to be eligible for DUA.  In addition, the work or self-employment that the person can no longer do must have been their primary source of income.

Applicants must submit all required documentation within 21 days of applying.  Required documentation includes the most recent federal tax form or check stubs, or other documentation to support that the applicant was working or self-employed when the disaster happened.

Applications for DUA must be filed by May 15, 2023 unless the applicant has good cause.  (EDD News Releases 23-15, April 14, 2023.)

Disaster CalFresh April 2023

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The California Department of Social Services has issued guidance and information regarding implementation of Disaster CalFresh for April, 2023 for the California winter storms and power outages.  Disaster CalFresh has been approved for Kern, Mariposa, Monterey, San Benito, Santa Cruz, Tulare, and Tuolumne Counties.

Disaster CalFresh provides one month of temporary food assistance to households affected by natural disasters who were not already receiving CalFresh.

To be eligible for Disaster CalFresh, a household must have:

1) lived or worked in the disaster impacted county at the time of the disaster;

2) Purchased or planned to purchase food during the benefits period, which is February 21, 2023 through March 22, 2023;

3) Experienced an adverse effects because of the disaster, such as food loss, loss of income, inaccessible resources, or disaster-related expenses;

4) Meet the Disaster Gross Income Limit.  To be eligible, the household’s income received plus accessible liquid resources, minus disaster related expenses, must be less than the Disaster Gross Income Limit.

A Disaster CalFresh household includes people who lived and purchased and prepared food together on the start date of the disaster. A Disaster CalFresh household does not include people who the applicant is temporarily staying with at the time of application due to the disaster. A Disaster CalFresh household may include people who had been excluded from an ongoing CalFresh household at the time of the disaster.

Disaster CalFresh requires verification of 1) Identity; 2. Residency and loss/inaccessibility of income or liquid resources, if possible; and 3. Household composition and food loss, when questionable.

While identity verification is required, a specific type of documentary proof is not Acceptable identity verification may include, but is not limited to, a driver’s license, a work or school identification card, an identification card for health benefits, a voter registration card, a foreign passport, and “matricula consulares.”

A social security number is not required to apply for D-CalFresh.

To the extent possible, verification of residency should be satisfied via information from other sources, such as a rent or mortgage billing statement, utility billing statement, and identity documents. No specific type of documentary proof is required.

Counties should assist households in obtaining necessary verification. This includes, with the client’s permission, verifying information through alternative sources such as online banking or utility accounts, and using collateral contacts.

Certified households must be able to access benefits within 72 hours of application, which begins to run on the day of the interview.

Authorized representatives may assist with Disaster CalFresh applications following the same policy as for regular CalFresh.

The Disaster CalFresh application for April, 2023, is April 17, 2023 through April 21, 2023, and April 24, 2023 through April 25, 2023.  The filing date is the day that the interview is completed and not the day that county receives the application.  Applicants must complete the CF 385 form and submit it during the application period.  Applications can be submitted by phone, online or in person. When accepting Disaster CalFresh applications by phone, verbal attestation is acceptable. Applicants who submit the application and verification online will be called for an interview within 24 hours.  If an online application does not have a phone number, the county must send the applicant a reminder notice to complete the interview no later than April 28, 2023..

Disaster CalFresh interviews should be done in-person when possible, but they can be done by phone.  (ACWDL, April 14, 2023.)

County requests for approval of exemption of Guaranteed Income project income for CalWorks and CalFresh

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The California Department of Social Services (CDSS) has issued a notice to describe how counties with Guaranteed Income (GI) projects can request that their programs be approved as CalWORKs GI Projects and therefore not be counted as income for CalWORKs and CalFresh. GI payments will count as income CalWORKs unless CDSS grants an exemption requested by the county.  Counties that would like to receive the CalWORKs exemption must submit the TEMP 3023 form.  County requests that GI not be counted as income for CalWORKs must include a comprehensive plan, a research plan and an Institutional Review Board approval.  CDSS will approve requests by formal order of the Director.  The order cannot extend beyond three years.

Note that CalWORKs Guaranteed Income Projects are different than California Guaranteed Income projects.  Income from California Guaranteed Income projects is also exempt for CalWORKs and CalFresh if the program including any private funding.

GI income will count for CalFresh unless any part of the GI payments are funded by a  nongovernment source, and the GI program is approved by CDSS. (ACIN I-35-22, April 14, 2022.)

AB 2300 changes to sanctions, exemptions and good cause and counting of Paid Family Leave

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The California Department of Social Services (CDSS) informs counties of changes in sanctions, exemptions, good cause, and counting of Paid Family Leave.

For CalWORKs, the first $225, and then one-half of remaining disability-based income is disregarded.  Effective October 1, 2024 or when automation is completed, whichever is later, disability-based income will include Paid Family Leave benefits.  Note that the $225 initial disregard amount will also increase when the addition of Paid Family Leave benefits as disability-based income occurs.

In addition, effective October 1, 2024 or when automation is completed, whichever is later any month in which a CalWORKs recipient receives Paid Family Leave benefits will not count towards the CalWORKs 60-month time on aid clock.  This exemption only applies to the CalWORKs time on aid clock and does not apply to the federal Temporary Assistance to Needy Families time on aid clock.

16 and 17 year olds who are required to attend school, and qualifying custodial parents under age 20 are exempt from Welfare-to-Work participation as long as they are attending school.  Previously, individuals lost this exemption if they stopped attending school.  Effective January 1, 2023, these individual can regain their exemption if they return to school.

Effective January 1, 2023, there are several new reasons for good cause for not meeting Welfare-to-Work requirements.  A CalWORKs recipient should be granted good cause for nonparticipation in Welfare-to-Work if anticipated hours of employment are unpredictable,  the recipient has one of list of labor or employment law violations, the recipients states they have experienced sexual harassment or other abusive conduct at work, or the recipient states that their rights under and federal, state or local labor or employment law were violated.  A recipient is not required to verify their statement, and is not required to reference any specific law.  These good cause reasons may not last longer than three months.

These good cause reasons also apply to CalFresh work requirements.  (ACL 23-30, March 22, 2023.)