CALFRESH - Benchmark Institute · 209 The Express Lane Enrollment Project – Medi-Cal for CalFresh...

______________________________________________________________________________ FOOD ASSISTANCE MANUAL 2/1

CALFRESH

______________________________________________________________________________ 2/2 FOOD ASSISTANCE MANUAL


Contents 90 Latest Revisions to CalFresh Statutes & Regulations .................... 2/7 100 Supplemental Nutrition Assistance Program ............................. 2/33 101Overview

101.1 Introduction 101.2 Agencies 101.3 Governing Laws Chart: Law & Agencies 101.4 Options, Waivers and Demonstration Projects 101.5 Eligible Food 101.6 Restaurant Meals Program (RMP) 101.7 Electronic Benefits Transfer (EBT) System

102 Special Treatment for Elders and Persons with Disabilities 102.1 Elderly or Disabled Member (E/D) Definition 102.2 Special Rules

103 Supplements 103.1 Work Incentive Nutritional Supplement (WINS) 104 CalFresh Check List 200 Category Eligibility .................................................................... 2/42 201 Household Concept 202 Required Household Combinations

202.1 Child and Non-Parent 202.2 Parents and Children 202.3 Spouses 202.4 Elderly and Disabled Persons Exception

203 Boarders 203.1 Generic Boarders 203.2 Commercial Boarding Houses 203.3 Foster Care Children

204 Residents of Institutions 205 Roomers and Live-in Attendants 206 Persons Who Do Not Purchase & Prepare Food with Household 207 Ineligible Household Members

207.1 Supplemental Security Recipients in California 207.2 Students 207.3 Failure to Provide SSN 207.4 Non-Citizens 207.5 Failure to Satisfy ABAWD Work Requirements 207.6 Felony Drug Convictions 207.7 Fleeing Felon/Probation/Parole Violators 207.8 Workfare/Work Requirement Sanctions 207.9 Intentional Program Violation (IPV)

208 Categorical Eligibility 208.1 Traditional Categorical Eligibility (CE) 208.2 Modified Categorical Eligibility (MCE)

209 The Express Lane Enrollment Project Medi-Cal for CalFresh Recipients 210 Residents 211 CalFresh Intercounty Transfer (ICT)


212 Immigrants

212.1 Federal Benefits 212.2 California Food Assistance Program (CFAP) 212.3 Sponsor Deeming

300 Financial Eligibility ......................................................................... 2/60 300.1 Traditional SNAP 300.2 Modified Categorical Eligibility 300.3 Two Pathways to CalFresh Eligibility 301 Steps to Determine Financial Eligibility 302 Resources 302.1 Definition

302.2 Limits 302.3 Excluded resources

303 Income 303.1 Definitions

303.2 Income limits 303.3 Excluded Income 303.4 Deductions

304 Income and Deductions of Excluded Household Members 305 How to Calculate a CalFresh Budget

305.1 Find Countable Income 305.2 Find Gross Income Eligibility 305.3 Find Net Income Eligibility 305.4 Find Amount of Benefits 305.5 Prorate First Months Allotment

306 Income Worksheet 307 Income Proration Worksheet for Excluded Non-Citizen Members 308 Income Exclusions Checklist 309 CalFresh Budget Work Sheet 310 Modified Categorical Eligibility for Elderly or Disabled Worksheet 311 Allotments and Deductions CalFresh - October 1, 2015 September 30, 2016 400 Conduct Eligibility .......................................................................... 2/83 401 Overview 402 Exemptions from Work 403 Registration for Work 404 Participation in Employment and Training Programs

404.1 Administration 404.2 E&T Components, Participation Levels and Reimbursement 404.3 E&T Deferrals 404.4 E&T Sanctions 404.5 Good Cause 404.6 Disqualification Notice

405 Voluntary Quit or Reducing Work Effort 405.1 Applicant Household

405.2 Recipient Household 405.3 Good cause 405.4 Suitable Employment


406 Able-Bodied Adults Without Dependents 406.1 Work programs 406.2 Good cause 406.3 Exemptions 406.4 Regaining Eligibility 406.5 Waivers

500 Procedural Eligibility ................................................................... 2/92 501 Application Process

501.1 Application 501.2 Interview 501.3 Verification

501.31 Verification Sources 501.32 Mandatory Verification 501.33 Optional verification 501.34 Questionable Information

502 Filing Reports 502.1 Semi-Annual Reporting System 502.2 SAR Overview 502.3 Semi-Annual Reporting Cycle 502.4 Good Cause for Failing to Submit a SAR 7 502.5 Restoring Eligibility 502.6 Change Reporting Households

503 Recertification: Reapplying for Benefits 503.1 Certification Periods 503.2 Recertification Process

600 Reserved

700 Debt Issues ............................................................................. 2/103 701 Overview

701.1 Definition 701.2 Types of Claims 701.3 Notice 701.4 Fair Hearing 701.5 Collection

702 Administrative Error (AE) 702.1 Recoupment Rate 702.2 Threshold for Inactive Households 702.3 Overissuance NOAs

703 Inadvertent Household Error (IHE) 704 Intentional Program Violation (IPV)

704.1 Overview 704.2 Administrative Disqualification Hearing (ADH) 704.2 ADH Hearing Waiver 704.3 Administrative Disqualification 704.4 Fraud Investigation Referrals 704.5 Special Investigation Unit


800 Administrative Processes ............................................................. 2/108 801 Application Process 802 Appeal Process

802.1 In General 802.2 Governing Law

803 Hearing Rights 804 Notice of Agency Action

804.1 In General 804.2 Exemptions from Notice 804.3 E-Notification

805 Requesting a Fair Hearing 805.1 In General 805.2 Aid-Paid Pending (APP) Diagram: CalFresh Odyssey

900 Emergency Benefits ............................................................... 2/114 901 Overview 902 Eligibility for Expedited Service 902.1 Eligibility Factors

902.2 Migrant and Seasonal Farm Workers 903 Expedited Service Procedure 904 Verification

904.1 Proof of identity 904.2 Social Security Number 904.3 Other Verification Requirements 904.4 Postponed Verification Procedure

905 Disasters 905.1 Expedited Services 905.2 Replacement CalFresh 905.3 Disaster SNAP/CalFresh

1000 Glossary ................................................................................ 2/119 CalFresh CFR 271.2 Definitions ........................................................... 2/131

Appendix: Forms ....................................................................................... A/1


90 Latest Revisions to CalFresh Statutes & Regulations (Current through August 19, 2016)

Legislation 2013 - 2014 Federal On February 7, President Obama signed the Agriculture Act of 2014 (H.R. 2642, the 2014 Farm Bill) into law. The bill includes $8.6 billion in cuts to SNAP. FNS implementing memo is here. Heat & Eat may live. In the 2014 Farm Bill, Congress chose to narrow Heat and Eat program that helps SNAP recipients meet their food and utility bills. In effect it allowed all households to take the standard utility allowance for a small Low Income Home Energy Assistance Program (LIHEAP) grant per year. Congress required states to invest $20.00 energy assistance to trigger the SNAP option. Now these states are opting to maintain their Heat and Eat programs at a lower rate include California (See SUAS below), Connecticut, Massachusetts, Montana, New York, Oregon, Pennsylvania, Rhode Island, Vermont and Washington, as well as the District of Columbia. (List current as of June 20, 2014) FRAC has more http://goo.gl/74Sh8w The SNAP provisions in the 2014 Farm Bill are summarized below under ACL 14-54 (May 29, 2014) California Enacted Budget (2014-2015) SB 855 (Chapter 29, Statutes of 2014), the Human Services Omnibus Trailer Bill, makes various statutory changes to implement the 2014-15 budget. CalWORKs/CalFresh Drug Felon Eligibility The Budget includes $10.6 million General Fund to allow an individual convicted of a drug felony to be eligible to receive CalWORKs and

CalFresh benefits effective April 1, 2015 as long as they do not violate the conditions of their parole or probation. Ongoing General Fund costs are $32.5 million. State Utility Assistance Subsidy (SUAS) The Budget includes an increase of $10.5 million General Fund to provide a statefunded energy assistance subsidy for CalFresh recipients. This change was necessary to comply with recent federal changes regarding the minimum energy assistance benefit that must be received by a household in order to access the standard utility allowance. This program increases household monthly food budgets by an average of $62 for over 320,000 families. Modified Categorical Eligibility This item provides for the modification of categorical eligibility for CalFresh by raising the gross income limit for non E/D households to 130%FPL. Enacted 2013-2014 SB 134 (Hueso) Military Housing Excluded from Countable Income; Veteran Exclusion from E&T This law (Welfare and Institutions Code 18926.5) requires DSS to submit a federal waiver request by December 31, 2014 to exclude military housing allowances from countable income when determining CalFresh eligibility. It also requires CWDs that participate in CalFresh E&T to exempt active military personnel and veterans from mandatory placement in CalFresh E&T and refer them to local veterans assistance and job training agencies. SB 672 (Leno) CalFresh: eligibility: guidelines. This law (Welfare and Institutions Code 18901.1) streamlines the verification process and eliminates a barrier to CalFresh participation among low-wage workers. It requires DSS to issue guidance to simplify earned income and dependent care verification

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in that expenses shall be considered verified upon receiving a self-certified statement of monthly dependent care expenses unless federal law or guidance requires additional documentation. DSS must adopt regulations to implement the changes to the process for considering dependent care expenses by January 1, 2015, and authorizes DSS, until regulation are adopted, to implement these changes by all-county letters or similar instructions. AB 191 (Bocanegra) CalFresh Categorical Eligibility for Medi-Cal Recipients This law (Welfare and Institutions Code 18901.5) requires DSS, to the extent permitted by federal law, to design and implement a program of categorical eligibility to establish the gross income limit for TANF Families and state maintenance of effort funded service that confers categorical eligibility for any household that is categorically eligible and that includes a member who receives, or is eligible to receive, medical assistance under Medi-Cal. AB 309 (Mitchell) Homeless Youth and CalFresh eligibility This law (Welfare & Institutions Code 18901 and 18904.25) clarifies that CalFresh eligibility, including expedited services, is not dependent on an applicants age and requires CWDs, upon receiving a signed CalFresh application from unaccompanied persons under 18 years, to determine their eligibility for benefits and expedited services. If the application is denied, the CWD is required to notify applicants in writing the reason for the denial. This law also requires that CWDs make information about CalFresh expedited services targeted to the homeless population available to local educational agency liaisons.

AB 1614 (Stone) Electronic transfers: payments and benefits This law amends Welfare and Institutions Code 10072 and requires users of Electronic Benefits Transfer (EBT) cards to be provided

access to transaction history via toll-free telephone hotline and Internet Web site, among other methods. It requires the system to be designed so that users are informed when the EBT system is down and funds are not accessible. EBT card users must be informed of where they can use their cards to withdraw funds without fees, and other information regarding fees. This law to be implemented by ACLs no later than April 1, 2015, and until regulations are developed. The department shall adopt regulations implementing this act on or before October 1, 2016. AB-1930 (Skinner) CalFresh: student eligibility This law (adding Welfare and Institutions Code 18901.11) requires a CWD to screen students for potential exemptions to work requirements when determining CalFresh eligibility. The bill exempts all students who participate in Community College Extended Opportunity Programs and Services (EOPS), as specified, and requires the state to establish protocols to screen for all potential exemptions, and identify and verify participation in the EOPS program, criteria for self-initiated placement, and other educational programs that exempt students from work requirements. The bill requires DSS to implement these provisions by all-county letters or similar instructions beginning no later than October 1, 2015, until regulations are adopted, and would require the department to adopt regulations on or before October 1, 2017. ACLs and ACINs CWDs May Provide Copy of Application on Request ACL 16-59 (July 13, 2016) 7 CFR 273.2(c)(1) requires state agencies to provide households who complete an online application at the local office the opportunity to review the application and provide households a copy. Under this waiver CWDs will allow individuals who complete an online application at their local offices to print their application information for their records, upon request.

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Annual CalFresh Participants By Race/Ethnicity Group Reports ACIN I-47-16 (June 29, 2016) Annual CalFresh Participants By Race/Ethnicity Group Reports DFA 358F (7/16) And DFA 358S (7/16) DSS Discontinues Two Statistical Report Forms and Adds A New One ACL 16-39 (May 4, 2016) A new form (CF 296) now replaces two old ones (DF296, 296X). Why should anyone but CWDs care? Because these reports contain useful information: applications received and disposed of during the month; applications processed under expedited service; certified caseload movement; and disposition of recertifications. ACIN I-19-16 (March 3, 2016) announces this change.

ABAWD Time Limit Summary ACL 16-24 (April 21, 2016) This letter clarifies ABAWD rules and describes the DSS Expedited Service Workgroup recommendations on Applicant Screening, Application Submission and Agency Conference. Expedited Service ACL 16-14 (February 29, 2016) This letter clarifies state and federal rules and describes DSS Workgroup recommendations on application screening and submission and Agency Conference. Extended Statewide Waiver of ABAWD Time Limit ACIN I-11-16 (February 2, 2016) This letter announces the extension of the statewide waiver through December 31, 2017. California has been approved for the waiver based on an unemployment rate greater than 20% above the national average for the 36-month period of September 2012 through August 2015.

AccessTo Case Records ACL 16-02 (January 20, 2016) This letter summarizes the law and policy on clients right to inspect their case records. It distinguishes between clients general ability to inspect their case record and when an administrative hearing is pending. It also discusses a clients ability to inspect documents contained in a fraud investigative file. This letter supersedes instructions in ACL 07-29 and 09-50. Student Eligibility ACIN I-89-15 (December 31, 2015) This Notice reminds CWDs that they must determine whether students who are disqualified under the student rule are exempt under MPP 63-406.2. This letter also clarifies when a household is required to report a change in student status and how educational assistance is treated.

DSS makes particular note on work study. That no jobs are available does not disqualify students from receiving the exemption. Many students have to wait for a job opening and sometimes no job becomes available. If the student is approved for work study and a job does not materialize, a student is not penalized. EBT New Client Materials ACIN I-03-16 (December 30, 2015) This Notice describes two new EBT posters intended to educate cardholders regarding surcharge-free Automated Teller Machines and a new EBT Client Website tutorial. All materials are available online for the CWDs to download, print, and use for EBT cardholder education. New Policy in Calculating Overpayments and Overissuances ACL 15-95 (December 1, 2015) This ACL implements a policy change in the way that OPs and OIs are calculated under the SAR and AR/CO systems in CalWORKs and CalFresh. It contains numerous examples designed to describe how to calculate OPs and OIs when IEVS matches show unreported income under varying circumstances.

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CalFresh Previously, OPs were calculated by recreating the case circumstances and then calculating what the grant should have been had the client met all of their mandatory reporting requirements for those months. Any grant amount that clients received over the amount they were entitled to would be an OP. Any income decreases that took place during the payment period, but were not reported, were not considered when calculating the OP.

Effective immediately, in order to more accurately recreate case circumstances, the policy of disregarding decreases in income when calculating OPs ends. Income Decreases as well as Increases The CalFresh Policy Bureau has determined that CalFresh OIs will be computed as follows: when establishing a CalFresh OI, the OI amount is computed by determining the actual household circumstances, including changes the household failed to report. This includes decreases as well as increases in income. As stated in MPP 63-801.312, the amount of the OI is the difference between the benefit amount the household received compared to the benefit amount the household was entitled to receive. The CalFresh Bureau will provide more information about their change in policy in a separate ACL. Fee Waivers for Birth Certificates for Homeless People AB 1733 ACIN I-90-15 (November 25, 2015) Deny Initial Applications Before the 30th Day ACL 15-93 (November 20, 2015) This instructs CWDs on federal regulations at 7 CFR 273.2(h)(2) which allows CWDs to deny an initial application 10 days after the date of a verification request when an applicant fails to provide the required information. FNS approved this waiver effective May 1, 2015 for a 12 month period. DSS reminds CWDs that 1) they may not deny an application for failure to provide requested verification within 10 days unless an interview

was completed and 2) households that fail to provide required verification within the 10-day period may be denied in the CWDs automated system. The Notice of Denial may be sent before the 30th day but must not be effective until the 30th day.

Residency ACL 15-94 (November 3, 2015) DSS clarifies policy on residency issues including Inter-County Transfers, temporary absences (both out-of-county and out-of-state), homelessness, persons applying for CalFresh in California who reside in another state and reporting requirements related to residency. DSS relies on 7 CFR 273.3 (a) and provides examples as guidance. Federal and State Earned Income Tax Credits ACL 15-87 (November 2, 2015) This letter is notable for referring to the spanking new California State EITC. Read all about it here. https://www.ftb.ca.gov/individuals/faq/net/900.shtml No more Change Reporting ACL 15-90 (October 30, 2015) SB 79 (Chapter 20, Statutes of 2015) requires DSS to convert CR households Semi-Annual Reporting (SAR) households no later than January 1, 2017. All systems say they will implement the change by July 1, 2016. Federal regulations had required CR households -- migrant and seasonal farmworker households, homeless households, and households in which all adults are elderly/disabled households -- to report changes to certain eligibility factors (e.g., employment, income, residency, etc.) within 10 days of the change. From CR to SAR Federal rules at 7 CFR 273.12(a)(5) now allow states the option to assign all households to SAR. As a result of SB 79, California will be exercising the option to eliminate CR, resulting in administrative simplification for CWDs and simplified reporting requirements for households previously designated as CR.

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Attached charts illustrate the conversion months, due dates for initial SAR 7 and recertification months for the three SAWS Consortia.

Certification Periods DSS strongly recommends providing the maximum allowable certification period for households converting from CR to SAR. For example, households in which all adult members are elderly or disabled will continue to be certified for a period of 24 months. Based on their source of income (earned or unearned), these households will be required to submit a SAR 7 at different intervals. Good Cause To mitigate the possibility during transition, DSS urges CWDs to use the extenuating circumstances provision under the good cause regulations for the first twelve months. Good cause criteria are listed under MPP 40-181.23 and 63-508.64. Good cause provides for discontinuances due to non-submission of the SAR 7 to be rescinded with no loss of benefits when the household cannot reasonably be expected to fulfill his or her reporting responsibilities due to factors outside of his or her control. DSS describes guidelines CWDs should follow when implementing good cause. CF Only HHs: Using SAWS 1 as Initial Application ACL 15-84 (October 21, 2015) Fleeing Felon and Probation Parole Violators ACL 15-82 (October 14, 2015) This letter describes changes in eligibility to individuals with a fleeing felon warrant as well as probation or parole violators. The changes are effective December 1, 2015 and supersede previous guidance on the definition of fleeing felons. FNS, on September 10, 2015, published the final rule (80 FR 54410) defining fleeing and actively seeking.

The letter also details CWDs on the steps they must follow to comply with this policy. Fleeing Felon An individual is considered a fleeing felon when a warrant for arrest is presented with one of three National Crime Information Center codes: Escape (4901) Flight to Avoid (prosecution, confinement, etc.) (4902), and Flight-Escape (4999). Probation or parole violator To be considered a probation or parole violator, an impartial party, such as a judge or officially sanctioned tribunal, must determine that the individual violated a condition of his or her probation or parole imposed under federal or state law and that federal, state, or local law enforcement authorities are actively seeking the individual to enforce the conditions of the probation or parole, as defined by 7 CFR 273.11(n)(3). Actively Seeking Only for the purpose of determining if an individual is in violation of probation or parole CWDs must verify that law enforcement is actively seeking the individual. Once verification that an individual is a probation or parole violator and is being actively sought has been attained, the CWD shall take immediate action to terminate or deny CalFresh benefits. New Statewide Minimum Wage January 1, 2016 ACIN I-81-15 (September 21, 2015) Disaster SNAP Effective October 1, 2015 ACIN I-77-15 (September 8, 2015) Student Eligibility ACL 15-70 (September 17, 2015) AB1930, (Chapter 729, Statutes of 2014) mandates that DSS establish a protocol to identify and verify all potential exemptions to the eligibility rule described in 7 CFR 273.5(a) and to identify and verify participation in educational programs, including, self-initiated placements, that would exempt a student from the eligibility rule described in 7

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CFR 273.5(a). The law must be implemented by October 1, 2015.

WIOA and EOPS Activities Through this letter, DSS authorizes WIOA and EOPS activities as qualifying students for CalFresh exemption. The workgroup will continue meeting until all educational programs that qualify as exemptions to the student eligibility rules are identified. In addition, DSS and the workgroup participants are developing the optimal process for keeping CWDs informed of the specific qualifying programs. Workforce Innovation and Opportunity Act (WIOA) reauthorizes the Workforce Investment Act (WIA) which superseded the Job Training Partnership Act (JTPA). MPP 63-406.216(a) identifies JPTA as one of the allowable exemptions from the student rules. Therefore, a student enrolled in a WIOA activity shall be considered as eligible for CalFresh if all other conditions of eligibility are satisfied. Extended Opportunity Programs and Services (EOPS) assists eligible low-income and educationally disadvantaged students to achieve academic success by offering support services to enhance persistence, retention, graduation and transfer goals. Enrollment in EOPS qualifies an otherwise CalFresh-eligible student for the CalFresh exemption as stated in MPP 63-406.216. Verification Form CDSS and the workgroup are in the process of developing a form that CWDs may use to verify enrollment in WIOA or EOPS. Until such time that the form has been transmitted, CWDs should adhere to the verification requirements as described in All County Information Notice I-45-11, I-45-11E and MPP 63-300.5. Update On CF Forms ACL 15-68 (September 15, 2015) California Drought Relief Initiative And Brochure ACIN I-62-15 (July 22, 2015)

FFY 2016 Numbers ACIN I-75-15 (September 4, 2015) Allotments and deductions for FFY 2016 10/1/15 9/30/16. See 311, below.

FFY 2016 Resource Limit Adjustments ACIN I-74-15 (September 4, 2015) Effective October 1, 2015, the resource limit for households will remain unchanged at $2,250; elderly & disabled also remains unchanged at $3,250. CW and CF: School Records Requests ACL 15-47 (June 17, 2015) This ACL clarifies the authority to request educational records of children in an AU or HH as part of verifying eligibility or investigating fraud. Effective with the date of this letter, CWD and SIU staff are notified to discontinue requesting educational information which is not considered directory information under the FERPA, unless the CWD or SIU have written parental consent, a judicial order or subpoena. Counties can still request access to directory information. As determined by each educational agency, the information can be provided unless the parent has opted out, in writing.

Background W&I Code 11484 mandates that all state, county and local agencies (including educational agencies) cooperate with an agency whose primary function is to detect, prevent, or prosecute public assistance fraud. Family Educational Rights and Privacy Act (FERPA) protects the privacy of student educational records and governs what information may be disclosed. One category that educational agencies may release is directory information. Directory Information Depending on the school district, directory information relating to a student may include, but is not limited to: the students name; address; telephone listing; date and place of birth; emergency contact information; major

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field of study; participation in officially recognized activities and sports; weight and height of members of athletic teams; dates of attendance; degrees and awards received; and the most recent previous educational agency or institution attended by the student.

Any educational agency or institution making directory information available must give public notice of the categories of information and must allow a reasonable period of time after such notice has been given for a parent to inform the educational agency in writing, that any or all of the information designated cannot be released without the parents prior consent. Information that may not be disclosed Information other than what is available as directory information may NOT be disclosed by the educational entity unless: 1. The CWD or SIU has obtained a written consent from the students parents specifying records to be released, the reasons for such release, and to whom, and with a copy of the records to be released to the students parents; or 2. A judicial order or a lawfully issued subpoena is presented to the school School Attendance Pursuant to AB 2382 (Chapter 905, Statutes of 2014), CWDs will no longer require applicants and recipients of CalWORKs to verify school attendance for children under age 16, nor are they required to ask about attendance. CWDs will only ask for school attendance verification once a child aged 16 or older has been deemed a chronic truant pursuant to Education Code 48263.6. AUs will no longer have their grant reduced when the CWD learns that a child under 16 years of age is not regularly attending school. See ACL 15-22 (February 23, 2015) References: Family Educational Rights And Privacy Act (FERPA) (20 U.S.C. 1232g; 34 CFR Part 99) ; W&I Code 11484; Education Code 48263.6; AB 2382 Chapter 905 Statutes of 2014; ACL 15-22

FFY 2016 Disaster CalFresh Plans ACIN I-37-15 (May 6, 2015); ACIN I-37-15E (May 18, 2015) D-CalFresh Plans are due to DSS by June, 2015. County disaster plans are intended to be an internal guide for county staff for use in the event of a natural or man-made disaster. This notice contains plan guidance and instructions. EBT - Implementing AB 1614 (Chapter 720, Statutes of 2014) ACL 15-39 (April 21, 2015) AB 1614 (W&I Code 10072) codified several EBT program procedures and practices and established new requirements to become effective April 1, 2015. AB 1614 requires EBT users to be provided access to transaction history via toll-free telephone hotline and Internet Web site, among other methods. requires the system to be designed so that users are informed when the EBT system is down and funds are not accessible. requires users of the EBT card to be informed of where they can use their cards to withdraw funds without fees, and other information regarding fees. promotes financial education so recipients can maximize their benefits. memorializes existing EBT services that are already part of the EBT program such as the EBT Client Website and EBT Customer Service, and adds new features to the program. References: AB 1614, ACIN I-15-14 CF: Clarification of Household Reports over the Income Reporting Threshold (IRT) For SAR System ACL 15-42 (April 15, 2015)

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This letter clarifies the gross income limit for conferring Modified Categorical Eligibility (MCE), for HH reports of income over the IRT, required case actions for households with continued eligibility, and requirements for notifying households of their IRT. It also gives revised IRT informing notices SAR 2, AR 2 SAR and AR 2 CR. This letter also clarifies the proration of ineligible noncitizens income relating to SAR and MCE. A households IRT is established at initial certification, at recertification, with they submit their SAR 7, or mid-period as described below. HHs determined eligible with gross income at or below 130% FPL are required to report changes in income when HHs gross income exceeds 130% FPL during the SAR payment period and at recertification and submission of the SAR 7. HHs certified between 131% and 200% FPL are not required to make any reports of income during the SAR payment period. These HHs do not have an IRT because they have already reported income of over 130% and per FNS guidance, a HH is only required to report that its gross income exceeds 130% FPL once time during a reporting period. They are required to report all income on their SAR 7 and at recertification. The IRT must be provided to the CalFresh Household and CalWORKs AU using the SAR 2 form at approval of initial application and at any time the household/AUs IRT changes during the certification period, whether the household has an IRT or not. References: AB 6 (Chapter 501, Statutes of 2011),ACLs 09-24; 11-11; 12-25; 12-25E; 12-62; 12-62E; 13-08; 13-17; 13-32; ACIN I-50-13; ACL 14-56; SB 855 (Chapter 29, Statutes of 2014); AB1468 (Chapter 26, Statutes of 2014)

Work Incentive Nutritional Supplement (WINS) Q&As ACIN I-27-15 (April 14, 2015) This notice provides answers to some of the questions that have come up regarding WINS program policy on these topics: Aid Codes (Page 1) Automation (Page 2) Automation of Hours Calculation with Wages Only (Page 3) California Food Assistance Program (CFAP) (Page 4) Eligibility (Page 5) Excluded Individuals Income (Page 11) Forms (Page 12) Issuances (Page 14) Meds Alerts (Page 15) Overissuances (Page 16) Reports (Page 17) Transitional CalFresh (Page 18) Voluntary Mid-Period Reports (Page 20) Work Experience (Page 21) Miscellaneous (Page 22) References: 7 CFR 273.12(a)(1)(i)(C)(2), ACLs 09-07, 13-14, 13-71, ACINs I-14-14, I-14-14E, CFL 13-14-14, CFL 13-14-34, California Constitution, Article XVI, 6, MPP 22-003.1, 22-107.1, 63-402.22, 63-504.42, 63-509 (a), 81-215, W&I Code 11253 CW and CF: Verification of SSNs ACIN I-24-15 (April 13, 2015); ACIN I-24-15E (May 5, 2015) This notice reviews the CW and CF verification rules for SSNs, describes recent SSA rules for proving SSNs and reminds CWDs that they are responsible to help individuals obtain SSN verification. CW - SSN verification Applicants are required to furnish their SSN or submit a completed application for a SSN card. (W&I Code 11268) Immediate need - MPP 40-105.21. CWDs must verify the SSN by viewing the SSN card, or by other means of verification

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pursuant to MPP 40-107(g)(1)(A) through 40-107(g)(1)(C). Per MPP 40-105.212(a) if individuals cannot furnish a SSN, they may apply directly to the local SSA office and then submit verification within 30 days following the CW application date. CWDs shall make every effort to assist individuals in obtaining the documents to apply for SSN card. This requirement may be met by furnishing a referral notice, (MC 194) and/or by providing the local SSA office address. If individuals cannot complete the application because the documentation is not immediately available, the CWD shall determine if good cause exists as outlined in MPP 40-209. CF SSN ACIN I-45-11 (October 28, 2011) Households must provide a SSN for each HH member applying for benefits, but do not need to provide a SSN card (MPP 63-404). If the household cannot provide a SSN for any member applying for benefits, the household must complete an application for the number and apply directly with SSA or show good cause why they cannot apply (MPP 63-404.13). Once the SSN application is filed with SSA, benefits must be continued, providing all other eligibility criteria are met, pending verification through IEVS. More detailed information is found at MPP 63-404. If no SSN is available for an individual in the household, benefits for the other household members must be issued if they are eligible. SSA Rules SSA has discontinued providing Social Security number printouts effective August 1, 2014. To prove social security numbers, people must request a replacement Social Security card by completing the Application for a Social Security

Card (Form SS-5) and providing the required documentation. People may also be able to get an instant letter online or call to request a letter by mail. See fact sheet at http://www.ssa.gov/pubs/EN-05-10544.pdf CW 2200- Request for Verification Form CW 2200 must be used to request verification for CalWORKs and CalFresh cases. ACIN I-24-15E (May 5, 2015) not just recommended as in ACIN I-24-15 (April 13, 2015). DSS reminds CWDs that they are responsible to assist applicants or recipients who need to obtain a SSN by referring them to the local SSA office, MPP 40-107(g)(1)(D) and 63-300.5(i). DSS strongly encourages CWDs to review and provide clients the following fact sheets when referring clients to their local SSA field office to apply for a new or replacement Social Security card: Application for a Social Security Number: http://www.ssa.gov/ssnumber/ss5doc.htm Learn what documents you need to get a Social Security Card U.S. Citizen/Adult - Replacement Social Security Card: http://www.ssa.gov/pubs/EN-05-10512.pdf U.S. Citizen/Child - Replacement Social Security Card: http://www.ssa.gov/pubs/EN-05-10514.pdf References: 45 CFR 45 205.52; W&I Code 11268; MPP 40-105.201(a), 40-105.212(b), 40-107(g)(1)(A)40-107(g)(1)(C), 40-105.21, 40-115.22, 40-209; 44-101(f)(1)(D), 63-300.5(e)(1), 63-300.5(i), 63-301.544, 63-404.6, 63-404.13; ACINs 21-115, 1-45-11

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Template for Counties Not Offering A CF E&T Program In FFY 2016 ACIN I-09-15 (February 11, 2015) This letter provides the FFY 2016 non- Employment and Training (E&T) template to be completed by those counties not offering a CF E&T Program. The template is part of the non-E&T handbook which includes policy instructions and program definitions. The non-E&T template is used by counties to estimate CF work registrant and Able-Bodied Adult Without Dependents (ABAWD) numbers. DSS uses this data to prepare state CF Employment and Training plan. Reference: MPP 63-407 Revised CF 31-Supplemental Form for Special Medical Deductions ACL 14-106 (December 31, 2014) The letter describes revisions made to the CF Supplemental Form for Special Medical Deductions (CF 31) (previously DFA 285-C) and instructions on when to use it. DSS revised and included CF 31 in newly developed applications [Application for CF (CF 285) and Application for CF, Cash Aid and/or Medi-Cal/Health Care Programs (SAWS 2 PLUS)] to reduce the number of pages used during intake and recertification. This form will replace the current version of DFA 285-C upon implementation of this letter. This form is used when adding a person to an existing case and the person being added is elderly (60 or older) or disabled (disability approved by Social Security) or when an existing CalFresh household member turns 60 or is determined disabled mid-period (MPP 63-102(e)(1) and 63-300(e)(9)). References: ACL 04-59, 13-75, 13-96; ACIN I-25-04, MPP 63-102(e)(1), 63-300(e)(9); CF 31 CF 37: New Form for CF Recertification ACL 14-101 (December 22, 2014) The letter instructs on implementing CF 37, a new form for recertifying a Nonassistance

CalFresh (NACF) household (HH) in which no member receives CW. This change should improve access, decrease churn (cases discontinued that reapply within 30-90 days), simplify RC requirements and decrease the administrative burden on CWDs. The CF 37 replaces the CF 285 as the form for completing RCs and must be utilized by CWDs as soon as the form is programmed in the countys consortia, but no later than October 1, 2015. The CF 37 is a shorter version of the CF 285 and only asks the HH for new or changed information the CWD has not already gathered or received. The CF 37 is a No Substitute Permitted form. DSS cites a newly released FNS November 2014 report Understanding the Rates, Causes, and Costs of Churning in the Supplemental Nutrition Assistance Program (SNAP) that found that for a very high proportion of churning cases, the precipitating exit occurs at the time of a scheduled RC. The most frequently cited example was nonresponse to a RC notice. The findings suggest that changes in RC policy or procedure could reduce churn and client burden at RC. The report also found that churn imposes added RC costs as reapplications for HHs returning to CF take more staff time. CWDs should continue to follow the RC process for all CF HHs as indicated in MPP 63-504.6, 63-300.3, and 63-504.25. CWDs should also continue to use the guidance provided in ACLs 12-25, 13-75, and 13-96. References: MPP 63-504.6, 63-300.3, 63-504.25, ACL 12-25, 13-75, and 13-96 DSS Revises CF 285 - Eliminates Felony Drug Conviction from CalFresh Application ACL 14-92 (December 22, 2014) Assembly Bill AB 1468 (Chapter 26, Statutes of 2014) eliminates the drug felon ban. This letter transmits the revised Application for CalFresh Benefits form (CF 285), a Required No

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Substitute Permitted form for CalFresh benefits only. CF 26 becomes obsolete on April 1, 2015. References: AB 1468 (Chapter 26, Statutes of 2014); W&I Code 11251.3, 18901.3; Application For CalFresh Benefits (CF 285); ACWD (July 1, 2014); ACL 12-74, 12-74e, 13-75, 13-96; MPP 63-300.5(E)(11) and (12), and 63-402.229(A),(B), and (C) CW and CF Eligibility Changes for People with a Prior Felony Drug Conviction ACL 14-100 (December 19, 2014) Effective April 1, 2015, no person will be denied aid because they have a prior felony drug conviction. Individuals who are currently ineligible for CalWORKs or CalFresh and therefore excluded from the AU/HH will no longer be excluded by law. These individuals must be added to the AU/HH effective April 1, 2015, if all other conditions of eligibility are met. This letter covers these issues in detail: Identifying and informing individuals of CW eligibility Adding optional persons or new members to the CW assistance unit Identifying and adding individuals with a prior felony drug conviction to the CF household Verifying parole or probation status Changing CWs tier 2 income reporting Threshold Transitioning between reporting systems Identifying child support requirements and collections for CW cases Changing CW aid codes Referring applicants to CW WTW services Issuing CW and CF benefits

Changes to application, notices of action, and forms

References: 7 USC 862a; AB 1468 (Chapter 26, Statutes of 2014); W&I Code 11251.3 & 18901.3; MPP 40-107; 40-118; 40-173; 40-181; 44-316; 63-402; 82-506; 82-510; 82-828; ACWDL JULY 1, 2014; ACL 01-66; 02-66; 04-59; 13-70; 14-26; 14-78; ACIN I- 03-05; I-17-05 Revisions to EBT 2260 in ACL-14-90 ACL 14-90E (May 7, 2015) DSS adds a title to EBT Excessive Card Replacement (ECR) Warning Letter, EBT 2260, and designates it as Required Form - Substitutions Permitted References: ACL 14-90 (December 2, 2014) Electronic Benefit Transfer (EBT) Excessive Card Replacement Warning Letter Process ACL 14-90 (December 2, 2014) This letter describes changes to the current EBT excessive card replacement (ECR) warning letter process. FNS made the ECR Interim Final Rule permanent on April 24, 2014. It requires state agencies (CWDs in California) to monitor the frequency of requests for EBT card replacements and to send a warning letter to clients who have requested four cards in a 12-month period. If a client requests a fifth replacement card, and the CWD has reason to believe that the client is trafficking, county staff shall refer the case for investigation. ECR Process The letter describes the new ECR process and attaches the warning letter (Attachment A-EBT 2260). If CWDs suspect that the reason for the ECR is a lack of understanding about how to use or manage an EBT card, CWDs should educate clients on how to manage the EBT card, including individualized training, or appointing authorized representatives. Frequent requests for card replacement may be indicative of

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several non-fraudulent situations (i.e., need for a reasonable accommodation of a disability, frequently misplaced card, clients inability to properly use the EBT card) and these alternate reasons should be explored with the client before determining if a referral for investigation is warranted. Referrals for Investigation After the fifth card replacement request within a 12-month period, and where trafficking (7 CFR 271.2 (1-6) is suspected, CWDs must refer to the Special Investigative Unit (SIU). SIUs may investigate to determine if potential trafficking, and CWDs may pursue prosecutions or administrative disqualification (MPP 20-300). CWDs should refer for investigate any time they suspect fraud. ACL 13-89 (October 31, 2013) describes steps to take before referring for investigation. References: FNS Final Rule and Interim Final Rule 7 C.F.R. 271 (1-6) Trafficking Definition: ACLs 13-54 and 13-89 WINS Monthly Caseload Report ACL 14-83 (November 17, 2014) This letter informs CWDs that effective with the October 2014 report month, counties are required to submit data on the WINS program by submitting the Work Incentive Nutritional Supplement Caseload Report (WINS 2) monthly report form. WINS provides a ten dollar monthly food supplement benefit for WINS-eligible CalFresh and CFAP household. The monthly WINS report provides data on the number of CalFresh Non-Public Assistance households and persons participating in the federal and state CalFresh programs who are eligible for WINS benefits. WINS Eligibility Receiving CalFresh, but not receiving CalWORKs or Tribal TANF; Child in the home under 18, or 19 if the child meets the requirements of W&I 11253;

A parent/caretaker who is receiving CalFresh and meeting the federal TANF definition of a work-eligible individual (WEI) in accordance with 45 CFR Part 261.2(n) and 42 USC 607; WEI participating in a sufficient number of hours in work activities that meet federal TANF work participation hours requirements under 42 USC 607 for subsidized or unsubsidized employment, which are as follows: - 20 hours per week for single custodial parents/caretakers with a child under the age of six; - 30 hours per week for non-two parent/caretakers with children age six or older; - 35 hours per week for two-parent/caretaker families; and Documentation that the household meets the federal work requirements for subsidized or unsubsidized employment, per the federally approved work verification plan ACL 14-27 (April 2, 2014) Counties must continue to report the federal and state CFAP benefit amounts issued to households composed of federal and state persons on the DFA 256 report. References: ACL 13-71 (September 10, 2013) Implementation of The Work Incentive Nutritional Supplement (WINS) Program Automation; ACL 09-07 (March 5, 2009), Californias TANF Work Verification Plan (WVP) Effective October 1, 2008; ACL 14-27 (April 2, 2014) TANF Program Work Participation Data Reporting for FFY 2014 CalWORKs and CalFresh: Implementation of SAR System Q&A ACL 14-77 (October 15, 2014) This letter responds to questions received by DSS on CalWORKs and CalFresh Semi-Annual Reporting rules implemented on October 1, 2013, as outlined in AB 6 and ACL 12-25. Most of these questions clarify existing policy; however, question 18, regarding terminating or transferring Trafficking and

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Crime Victims Assistance Program (TCVAP) clients mid-period is a new policy. This additional county-initiated mid-period action will be added to the regulations in the near future. References: AB 6 (Chapter 501, Statutes of 2011); W&I Code 11265.3(C)(1), ACLs 12-25, 13-08, 13-17, and 13-28; ACINs I-54-03 And I-58-13. State Utility Assistance Subsidy (SUAS) ACL 14-66 (September 19, 2014) This letter instructs CWDs on the new State Utility Assistance Subsidy (SUAS) program. All County Welfare Directors Letter (June 30, 2014) gives preliminary information.

SUAS replaces LIHEAP-based Heat and Eat Program. DSS, however, will continue to refer to it as Heat and Eat. Background Heat & Eat - Heat and Eat provided all CalFresh households with a nominal Low Income Home Energy Assistance Program (LIHEAP) benefit (10cents) that qualified them to use the standard utility allowance (SUA) to calculate CalFresh benefit levels. California implemented its "Heat and Eat" program, Chapter 501 of Statutes of 2011 AB 6 (Fuentes, D-Los Angeles) in January 2013. Knowing that a majority of California households incur utility expenses in one way or another, Heat and Eat removed the verification requirement associated with utility costs (i.e. utility bill) for all households thus simplifying the application process. The program was widely supported because it increased benefits for a significant number of eligible CalFresh households while simplifying and streamlining paperwork for both clients and administrators. In the 2014 Farm Bill (the Agriculture Act of 2014), Congress changed the rules and required states to invest more energy assistance benefits ($20.00 rather than10 cents) to trigger the

SNAP option. States opting to maintain their Heat and Eat programs include California, Connecticut, Massachusetts, Montana, New York, Oregon, Pennsylvania, Rhode Island, Vermont and Washington, as well as the District of Columbia. (List current as of June 20, 2014) SB 855 (Chapter 29, Statutes of 2014) repealed LIHEAP-based Heat and Eat and established SUAS effective July 1, 2014. Eligibility Receiving a SUAS payment during its certification period entitles households to use the SUA deduction in computing their CalFresh allotment. The SUAS payment ($20.01) is only to be provided to those households who will actually receive additional CalFresh benefits or become eligible for CalFresh as a result of receiving the payment. These households include those who are not - otherwise eligible for the SUA, already receiving the maximum CalFresh allotment for their household size, or already receiving the maximum shelter deduction (for those households that contain no elderly or disabled members). Note: CalFresh Households which are eligible to receive the Homeless Shelter Deduction continue to receive the Homeless Shelter Deduction instead of the SUAS payment/ SUA expense, if receiving the Homeless Shelter Deduction results in a higher benefit than if the recipient received the SUA deduction. If there would be no change in the households allotment, CWDS are to continue using the Homeless Shelter Deduction. Attached Chart A chart attached to the ACL describes the impact of SUAS changes for new and ongoing CalFresh households with specific case examples.

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Other issues The letter also deals with Heat and Eat on these issues: Inter-County Transfer (ICT) Multiple SUAS Issuances in a 12-Month period Restorations Change in household circumstances during the certification period Transitional CalFresh (TCF) Expedited Service Overissuance 24 Month Certification Periods Automation

The letter also includes the SUAS Informing Notice sent to CF participants. References: All County Welfare Directors Letter (June 30, 2014); ACL 12-61 (October 30, 2012); ACL 13-35 (April 24, 2013); ACL 14-54 (May 29, 2014); ACIN I-11-13 (March 6, 2013); (SB) 855 (Chapter 29, Statutes of 2014); H.R. 2642; The Agricultural Act of 2014 Households Eligible for CalFresh, But Entitled to No Benefits ACL 14-63 (September 16, 2014) This letter describes how to treat households comprised of three or more members who are categorically eligible (CE) for CalFresh, but whose net income does not entitle them to receive any benefits. For traditional or modified categorical eligibility, households may be gross income eligible but not entitled to receive benefits due to their net income level.

No benefits are issued for the initial month when initial months allotment is less than $10.

CE households with one or two members will receive no less than the current minimum allotment regardless of their net income.

CE households of three or more will receive the benefit allotment that corresponds to the

amount indicated on the tables of benefit issuance based on their net income regardless of their net income http://www.mass.gov/eohhs/docs/dta/c-snap-364-980-hh-1-10.pdf - even if the corresponding allotment amount is under $10. CE existing households with three or more members in which the tables of benefit issuance indicate a benefit amount of zero are to be terminated. As stated in ACIN I-50-13, California has opted to deny zero benefit cases as less administratively costly than certifying and carrying cases that are eligible for zero benefits. CWDs will deny zero benefit households on the grounds that the households net income exceeds the level at which benefits are issued. References: ACIN I-50-13 (August 23, 2013); 7 CFR 273.10 (e)(2)(iii)(A) and (B) Annual Eligibility Standards, COLAs, Allotments, Deductions October 1, 2014 September 30, 2015 ACIN I-53-14 (September 3, 2014)

References: FNS Approval of Californias SUA, LUA, and TUA (June 25, 2014) and Allowance Increase Effective October 1, 2014. CF Modified Categorical Eligibility - Erratum ACL 14-56E (April 10, 2015); ACL 14-56 (August 22, 2014) This letter corrects ACL 4-56. It shows the prior and the corrected language for the impacted paragraph only, and should be read in conjunction with ACL 14-56. In one paragraph it makes clear that the gross income is less than 200%. It adds a revised table under Income Reporting Thresholds (ITRs. CalFresh Modified Categorical Eligibility ACL 14-56 (August 22, 2014) This ACL explains CalFresh Broad-based Categorical Eligibility (BBCE) known in

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California as Modified Categorical Eligibility (MCE). Effective July 1, 2014, all households (with a few exceptions see Ineligibility for MCE, below) with gross income at or below 200% FPL, must be conferred MCE status if they are issued or have online access to the Temporary Assistance to Needy Families (TANF)-funded Family Planning PUB 275 brochure. Background AB 433 (Chapter 625, Statutes of 2008) established a program of categorical eligibility for CF to promote nutrition and asset retention and development. Beginning 7/1/09, MCE was conferred on households with children under 18 with a maximum gross income of 130% FPL. On 2/1/11, the MCE program was expanded to include all Non-assistance CF Households (NACF). On 4/24/13, DSS in ACL 13-32, clarified that Elderly/Disabled (E/D) households do not have a gross income test for income eligibility but do have a gross income level to be eligible for MCE. E/D households with gross income at or below 200% FPL are to be conferred MCE status if they were issued or had online access to the "Family Planning - PUB 275" brochure. As of 1/1/14, AB 191 (Chapter 669, Statutes of 2013) required that any household including a member who receives Medi-Cal be conferred MCE status if the households gross income does not exceed 200% FPL (see ACL No. 12-62). SB 855 (Chapter 29, Statutes of 2014), effective 7/1/14, raised the MCE gross income test to at or below 200% FPL. MCE for Medi-Cal recipients, as outlined in AB 191, became inoperative as of 6/30/14. Implementation All counties must immediately implement a 200% FPL gross income level for MCE for all NACF households. For any case pending as of July 1, 2014, if automation indicates ineligibility

for a non-aged/disabled CalFresh applicant household because of the 130% FPL gross income limit, the county must pull the case and manually verify whether eligibility under MCE status exists because of gross income at or under 200% FPL. Corrective action must be taken on any cases that would have been eligible under the MCE 200% FPL gross income test in June and July 2014. Automation DSS is currently working with the Statewide Automated Welfare Systems to develop an automated procedure for processing households based on the 200% FPL for MCE, to be completed by November 2014. In the interim, a manual workaround at the county level is necessary, effective July 1, 2014. Ineligibility for MCE The NACF households that have been approved for CalFresh as MCE are subject to the same conditions that result in ineligibility as all other Categorically Eligible (CE) households. Federal guidance and regulations [7 CFR 273.2(j)(2)(vii)] and State regulations (MPP Section 63-301.74) state that households are not CE and are subject to all CalFresh eligibility requirements in these scenarios: Any household member who is disqualified for an intentional program violation (IPV). Household head who does not comply with work requirements. Any household member who has been convicted of a drug-related felony (MPP 63-402.229). [Note: with the passage of AB 1468 (Chapter 26, Statutes of 2014) which removes the drug felon ban in California effective April 1, 2015, this may no longer apply. CDSS will address this issue in subsequent guidance.] A household may be conferred MCE status once it is determined that the sanction period has expired and the household meets all other conditions of MCE eligibility.


Ongoing Cases Households of one or two persons that have been conferred MCE status will be entitled to the minimum CalFresh benefit even though the households net income exceeds the maximum allowable regardless of the bracketed amounts displayed in the benefit of issuance tables http://www.mass.gov/eohhs/docs/dta/c-snap-364-980-hh-1-10.pdf An MCE household of one or two persons will never have a zero benefit they will always be allowed the minimum benefit (currently set at $15). Households of three or more persons that have been conferred MCE status will be entitled to the allotment amount indicated in the benefit of issuance tables even if the households net income exceeds the maximum amount allowable, even if this amount is under $10. At the point where there is no corresponding bracketed amount, the household would be considered having a zero benefit. Zero Benefit Cases For households of three or more who are entitled to no benefits, FNS allows states to either deny the application or certify the household and carry the zero benefit case. California has opted to deny these households and discontinue their cases. If CE/MCE households of three or more change their gross income and/or allowable expenses that cause their net income to increase so that they no longer qualify for CF, the county will discontinue their cases because their net income exceeds the level at which benefits are issued. For those CE households being recertified that would receive no benefits due to their net income, the county will deny the recertification application because the households net income exceeds the level at which benefits are issued. As stated previously, if the household has an E/D member in it, the county must determine regular CalFresh eligibility (including countable resources, but with no gross income test).

Retroactive Benefits If the CWD is unable to make necessary changes to implement MCE for all NACF applicants and continuing cases on July 1, 2014, CWDs must restore, where appropriate, lost benefits as soon as administratively feasible. In order to be able to correct the action, the county must flag the case. Benefit Issuance As a reminder, no issuance of less than $10 shall be made in the month of application for all households, including those that are considered MCE, regardless of the size of the household and the amount shown in the Tables of Benefit Issuance. This includes, but is not limited to, a household whose benefit is prorated and results in a CalFresh allotment of less than $10. References: ACWL (June 30, 2014); SB 855 (Chapter 29, Statutes of 2014); ACL 13-108 (12/31/13); ACIN I-52-13 (/12/13); ACL 13-32 (4/24/13); ACL 12-62(6/28/13); ACL 12-62(11/2/12); ACL 11-11 (1/27/11); ACL 09-24 (5/27/09) Statewide Waiver of ABAWD Work Requirement FFY 2015 ACIN I-49-14 (August 21, 2014) FNS announced that 37 states or geographic areas, including California, qualify for a waiver of the ABAWD work requirement for FFY 2015 - October 1, 2014 - September 30, 2015. (AN) 14-34 (May 23, 2014). California received a statewide ABAWD waiver in FFY 2014 and no CalFresh recipients are currently subject to the ABAWD work requirement. Other CalFresh work requirements still apply. SNAP law and regulations provide that FNS may waive the ABAWD work requirement for a state, or portions of a state, that meets at least one of the federally-established waiver criteria. These criteria include DOL Unemployment Insurance Service determining that an area qualifies for Extended Benefits (EB). Emergency Unemployment Compensation Trigger Notice 2013-38 identifies California as one of the states that qualify for Extended

http://www.mass.gov/eohhs/docs/dta/c-snap-364-980-hh-1-10.pdfhttp://www.mass.gov/eohhs/docs/dta/c-snap-364-980-hh-1-10.pdfhttp://www.dss.cahwnet.gov/lettersnotices/EntRes/getinfo/acin/2014/I-49_14.pdf


Benefits. The Emergency Unemployment Compensation (EUC) program expired 1/1/14 and Congress has not passed any further extensions. Implementation Policies Counties are reminded of the following ABAWD waiver implementation policies: ABAWD waiver counties must continue to report work registrants, ABAWDs, and Employment and Training (E&T) data on STAT 47 and 48. Persons who do not meet one of the ABAWD exemptions at MPP 63-410.31 or .32 are still considered ABAWDs even while residing in a county with a waiver. ABAWD waiver counties must not establish a 36-month calendar for a new ABAWD applicant during the waiver period. ABAWD waivers do not affect CalFresh E&T participation requirements or program sanction rules for E&T mandatory placements. Currently, E&T is voluntary in all participating counties and CalFresh sanctions are not imposed for noncompliance with E&T requirements. ABAWD waiver counties must continue to apply sanction requirements at MPP 63-408 to CalFresh work registrants who voluntarily quit a job of 30 hours or more per week which provides weekly earnings equal to or greater than the federal minimum wage times 30, or who reduce the weekly number of hours worked to less than 30. If a CalFresh recipient quits a job of less than 30 hours, no sanction is imposed. Those counties that participate in the waiver must inform their ABAWD population that they are not subject to the ABAWD work requirement for those months they reside in the county so long as the waiver is in effect. Procedure for Declining an ABAWD Waiver The FFY 2015 ABAWD waiver will be effective October 1, 2013 unless a county notifies CDSS via a letter from its County Board of Supervisors that it intends to pursue opting out of the ABAWD waiver

References: W&I Code 18926; FNS Administrative Notice 14-34(May 23, 2014) CalWORKs and CalFresh: Implementation of SAR System Q&A ACL 14-77 (October 15, 2014) This letter responds to questions received by DSS on CalWORKs and CalFresh Semi-Annual Reporting rules implemented on October 1, 2013, as outlined in AB 6 and ACL 12-25. Most of these questions clarify existing policy; however, question 18, regarding terminating or transferring Trafficking and Crime Victims Assistance Program (TCVAP) clients mid-period is a new policy. This additional county-initiated mid-period action will be added to the regulations in the near future. References: AB 6 (Chapter 501, Statutes of 2011); W&I Code 11265.3(C)(1), ACLs 12-25, 13-08, 13-17, and 13-28; ACINs I-54-03 And I-58-13. State Utility Assistance Subsidy (SUAS) ACL 14-66 (September 19, 2014) This letter instructs CWDs on the new State Utility Assistance Subsidy (SUAS) program. All County Welfare Directors Letter (June 30, 2014) gives preliminary information.

SUAS replaces LIHEAP-based Heat and Eat Program. DSS, however, will continue to refer to it as Heat and Eat. Background Heat & Eat - Heat and Eat provided all CalFresh households with a nominal Low Income Home Energy Assistance Program (LIHEAP) benefit (10cents) that qualified them to use the standard utility allowance (SUA) to calculate CalFresh benefit levels. California implemented its "Heat and Eat" program, Chapter 501 of Statutes of 2011 AB 6 (Fuentes, D-Los Angeles) in January 2013.

http://www.dss.cahwnet.gov/lettersnotices/EntRes/getinfo/acl/2014/14-77.pdfhttp://www.dss.cahwnet.gov/lettersnotices/EntRes/getinfo/acl/2014/14-66.pdfhttp://www.dss.cahwnet.gov/lettersnotices/EntRes/getinfo/coletters/StateUtilityAssistanceSubsidyHeatAndEat.pdfhttp://www.dss.cahwnet.gov/lettersnotices/EntRes/getinfo/coletters/StateUtilityAssistanceSubsidyHeatAndEat.pdfhttps://www.google.com/search?sourceid=navclient&ie=UTF-8&rlz=1T4WQIB_enUS529US529&q=%28AB%29+6+%28Chapter+501%2c+Statutes+of+2011%29


Knowing that a majority of California households incur utility expenses in one way or another, Heat and Eat removed the verification requirement associated with utility costs (i.e. utility bill) for all households thus simplifying the application process. The program was widely supported because it increased benefits for a significant number of eligible CalFresh households while simplifying and streamlining paperwork for both clients and administrators. In the 2014 Farm Bill (the Agriculture Act of 2014), Congress changed the rules and required states to invest more energy assistance benefits ($20.00 rather than10 cents) to trigger the SNAP option. States opting to maintain their Heat and Eat programs include California, Connecticut, Massachusetts, Montana, New York, Oregon, Pennsylvania, Rhode Island, Vermont and Washington, as well as the District of Columbia. (List current as of June 20, 2014) SB 855 (Chapter 29, Statutes of 2014) repealed LIHEAP-based Heat and Eat and established SUAS effective July 1, 2014. Eligibility Receiving a SUAS payment during its certification period entitles households to use the SUA deduction in computing their CalFresh allotment. The SUAS payment ($20.01) is only to be provided to those households who will actually receive additional CalFresh benefits or become eligible for CalFresh as a result of receiving the payment. These households include those who are not - otherwise eligible for the SUA, already receiving the maximum CalFresh allotment for their household size, or already receiving the maximum shelter deduction (for those households that contain no elderly or disabled members). Note: CalFresh Households which are eligible to receive the Homeless Shelter Deduction continue to receive the Homeless Shelter Deduction instead of the SUAS payment/ SUA expense, if receiving the Homeless Shelter

Deduction results in a higher benefit than if the recipient received the SUA deduction. If there would be no change in the households allotment, CWDS are to continue using the Homeless Shelter Deduction. Attached Chart A chart attached to the ACL describes the impact of SUAS changes for new and ongoing CalFresh households with specific case examples. Other issues The letter also deals with Heat and Eat on these issues: Inter-County Transfer (ICT) Multiple SUAS Issuances in a 12-Month period Restorations Change in household circumstances during the certification period Transitional CalFresh (TCF) Expedited Service Overissuance 24 Month Certification Periods Automation

The letter also includes the SUAS Informing Notice sent to CF participants. References: All County Welfare Directors Letter (June 30, 2014); ACL 12-61 (October 30, 2012); ACL 13-35 (April 24, 2013); ACL 14-54 (May 29, 2014); ACIN I-11-13 (March 6, 2013); (SB) 855 (Chapter 29, Statutes of 2014); H.R. 2642; The Agricultural Act of 2014 Households Eligible for CalFresh, But Entitled to No Benefits ACL 14-63 (September 16, 2014) This letter describes how to treat households comprised of three or more members who are categorically eligible (CE) for CalFresh, but whose net income does not entitle them to receive any benefits. For traditional or modified categorical eligibility, households may be gross income

http://www.dss.cahwnet.gov/lettersnotices/EntRes/getinfo/coletters/StateUtilityAssistanceSubsidyHeatAndEat.pdfhttp://www.dss.cahwnet.gov/lettersnotices/entres/getinfo/acl/2012/12-61.pdfhttp://www.dss.cahwnet.gov/lettersnotices/entres/getinfo/acl/2012/12-61.pdfhttp://www.dss.cahwnet.gov/lettersnotices/EntRes/getinfo/acl/2013/13-35.pdfhttp://www.dss.cahwnet.gov/lettersnotices/EntRes/getinfo/acl/2014/14-54.pdfhttp://www.dss.cahwnet.gov/lettersnotices/EntRes/getinfo/acl/2014/14-54.pdfhttp://www.dss.cahwnet.gov/lettersnotices/EntRes/getinfo/acin/2013/I-11_13.pdfhttp://www.dss.cahwnet.gov/lettersnotices/EntRes/getinfo/acin/2013/I-11_13.pdfhttp://www.dss.cahwnet.gov/lettersnotices/EntRes/getinfo/acl/2014/14-63.pdf


eligible but not entitled to receive benefits due to their net income level.

No benefits are issued for the initial month when initial months allotment is less than $10.

CE households with one or two members will receive no less than the current minimum allotment regardless of their net income.

CE households of three or more will receive the benefit allotment that corresponds to the amount indicated on the tables of benefit issuance based on their net income regardless of their net income http://www.mass.gov/eohhs/docs/dta/c-snap-364-980-hh-1-10.pdf - even if the corresponding allotment amount is under $10. CE existing households with three or more members in which the tables of benefit issuance indicate a benefit amount of zero are to be terminated. As stated in ACIN I-50-13, California has opted to deny zero benefit cases as less administratively costly than certifying and carrying cases that are eligible for zero benefits. CWDs will deny zero benefit households on the grounds that the households net income exceeds the level at which benefits are issued. References: ACIN I-50-13 (August 23, 2013); 7 CFR 273.10 (e)(2)(iii)(A) and (B) Annual Eligibility Standards, COLAs, Allotments, Deductions October 1, 2014 September 30, 2015 ACIN I-53-14 (September 3, 2014) References: FNS Approval of Californias SUA, LUA, and TUA (June 25, 2014) and Allowance Increase Effective October 1, 2014.

CalFresh Modified Categorical Eligibility ACL 14-56 (August 22, 2014) This ACL explains CalFresh Broad-based Categorical Eligibility (BBCE) known in California as Modified Categorical Eligibility (MCE). Effective July 1, 2014, all households (with a few exceptions see Ineligibility for MCE, below) with gross income at or below 200% FPL, must be conferred MCE status if they are issued or have online access to the Temporary Assistance to Needy Families (TANF)-funded Family Planning PUB 275 brochure. Background AB 433 (Chapter 625, Statutes of 2008) established a program of categorical eligibility for CF to promote nutrition and asset retention and development. Beginning 7/1/09, MCE was conferred on households with children under 18 with a maximum gross income of 130% FPL. On 2/1/11, the MCE program was expanded to include all Non-assistance CF Households (NACF). On 4/24/13, DSS in ACL 13-32, clarified that Elderly/Disabled (E/D) households do not have a gross income test for income eligibility but do have a gross income level to be eligible for MCE. E/D households with gross income at or below 200% FPL are to be conferred MCE status if they were issued or had online access to the "Family Planning - PUB 275" brochure. As of 1/1/14, AB 191 (Chapter 669, Statutes of 2013) required that any household including a member who receives Medi-Cal be conferred MCE status if the households gross income does not exceed 200% FPL (see ACL No. 12-62). SB 855 (Chapter 29, Statutes of 2014), effective 7/1/14, raised the MCE gross income test to at or below 200% FPL. MCE for Medi-Cal recipients, as outlined in AB 191, became inoperative as of 6/30/14.

http://www.mass.gov/eohhs/docs/dta/c-snap-364-980-hh-1-10.pdfhttp://www.mass.gov/eohhs/docs/dta/c-snap-364-980-hh-1-10.pdfhttp://www.dss.cahwnet.gov/lettersnotices/EntRes/getinfo/acin/2014/I-53_14.pdfhttp://www.dss.cahwnet.gov/lettersnotices/EntRes/getinfo/acl/2014/14-56.pdf


Implementation All counties must immediately implement a 200% FPL gross income level for MCE for all NACF households. For any case pending as of July 1, 2014, if automation indicates ineligibility for a non-aged/disabled CalFresh applicant household because of the 130% FPL gross income limit, the county must pull the case and manually verify whether eligibility under MCE status exists because of gross income at or under 200% FPL. Corrective action must be taken on any cases that would have been eligible under the MCE 200% FPL gross income test in June and July 2014. Automation DSS is currently working with the Statewide Automated Welfare Systems to develop an automated procedure for processing households based on the 200% FPL for MCE, to be completed by November 2014. In the interim, a manual workaround at the county level is necessary, effective July 1, 2014. Ineligibility for MCE The NACF households that have been approved for CalFresh as MCE are subject to the same conditions that result in ineligibility as all other Categorically Eligible (CE) households. Federal guidance and regulations [7 CFR 273.2(j)(2)(vii)] and State regulations (MPP Section 63-301.74) state that households are not CE and are subject to all CalFresh eligibility requirements in these scenarios: Any household member who is disqualified for an intentional program violation (IPV). Household head who does not comply with work requirements. Any household member who has been convicted of a drug-related felony (MPP 63-402.229). [Note: with the passage of AB 1468 (Chapter 26, Statutes of 2014) which removes the drug felon ban in California effective April 1, 2015, this may no longer apply. CDSS will address this issue in subsequent guidance.] A household may be conferred MCE status once it is determined that the sanction period has

expired and the household meets all other conditions of MCE eligibility. Ongoing Cases Households of one or two persons that have been conferred MCE status will be entitled to the minimum CalFresh benefit even though the households net income exceeds the maximum allowable regardless of the bracketed amounts displayed in the benefit of issuance tables http://www.mass.gov/eohhs/docs/dta/c-snap-364-980-hh-1-10.pdf An MCE household of one or two persons will never have a zero benefit they will always be allowed the minimum benefit (currently set at $15). Households of three or more persons that have been conferred MCE status will be entitled to the allotment amount indicated in the benefit of issuance tables even if the households net income exceeds the maximum amount allowable, even if this amount is under $10. At the point where there is no corresponding bracketed amount, the household would be considered having a zero benefit. Zero Benefit Cases For households of three or more who are entitled to no benefits, FNS allows states to either deny the application or certify the household and carry the zero benefit case. California has opted to deny these households and discontinue their cases. If CE/MCE households of three or more change their gross income and/or allowable expenses that cause their net income to increase so that they no longer qualify for CF, the county will discontinue their cases because their net income exceeds the level at which benefits are issued. For those CE households being recertified that would receive no benefits due to their net income, the county will deny the recertification application because the households net income exceeds the level at which benefits are issued. As stated previously, if the household has an E/D member in it, the county must determine regular CalFresh eligibility (including countable resources, but with no gross income test).

http://www.mass.gov/eohhs/docs/dta/c-snap-364-980-hh-1-10.pdfhttp://www.mass.gov/eohhs/docs/dta/c-snap-364-980-hh-1-10.pdf


Retroactive Benefits If the CWD is unable to make necessary changes to implement MCE for all NACF applicants and continuing cases on July 1, 2014, CWDs must restore, where appropriate, lost benefits as soon as administratively feasible. In order to be able to correct the action, the county must flag the case. Benefit Issuance As a reminder, no issuance of less than $10 shall be made in the month of application for all households, including those that are considered MCE, regardless of the size of the household and the amount shown in the Tables of Benefit Issuance. This includes, but is not limited to, a household whose benefit is prorated and results in a CalFresh allotment of less than $10. References: ACWL (June 30, 201

CALFRESH - Benchmark Institute · 209 The Express Lane Enrollment Project – Medi-Cal for CalFresh...

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