Update : CalFresh Elimination of Change Reporting in CalFresh

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1 Santa Clara County Social Services Agency page 1 Date: 03/18/16 References: Cross-References: Clerical: Handbook Revision: ACL #15-90, ACL #15-90E None No Yes Elimination of Change Reporting in CalFresh Background Currently, certain CalFresh households are considered Change Reporting (CR) and are subject to the CR requirements. These households are identified as homeless, elderly, or disabled, migrant and seasonal farmworker households. Changes As a result of Senate Bill (SB) 79, California eliminates CR and all CR households will be converted to Semi-Annual Reporting (SAR) no later than July CalWIN counties will implement the change effective June 1, Intake & Upon receipt of this Update, EW staff conducting Intake and interviews must explain the SAR reporting requirements, including the Income Reporting Threshold (IRT) concept and the SAR 7 schedule. The CR households are subject to CR regulations until May 31, date SAR 7 due date will be set by the beginning date of aid. Note: No SAR7s will be due in the month of conversion for cases transiting from CR to SAR (i.e., June 2016). Number of SAR 7 Based on their certification period and source of income (earned or unearned), households are required to submit a SAR 7 at different intervals as described below:

2 page 2 Elderly/ Disabled or Indian Reservation Residents Elderly/Disabled households or households residing on Indian reservations with earned income must submit a SAR 7 at 6, 12, and 18 months during their 24 month-certification period. Elderly/Disabled households or households residing on Indian reservations with unearned income or no income must submit a SAR 7 at 12 months during their 24 month-certification period. Reminder: Households in which all adult members are elderly or disabled, or households which reside on an Indian reservations are certified for a period of 24 months. Homeless Households Homeless households will receive one SAR 7 at six months into their 12-month recertification period. This is a change from the current policy. SAR 7 & Calendars The below charts illustrate the conversion months, due dates for initial SAR 7, and recertification months. Elderly/Disabled Households w/ No Earned Income & Households Residing on Indian Reservations w/ No Earned Income 24 Certification Periods Beginning Date of Aid SAR 7 Data 12th August 2015 June 2016 July 2016 July 2017 September 2015 July 2016 August 2016 August 2017 October 2015 August 2016 September 2016 September 2017 November 2015 September 2016 October 2016 October 2017 December 2015 October 2016 November 2016 November 2017 January 2016 November 2016 December 2016 December 2017 February 2016 December 2017 January 2017 January 2018 March 2016 January 2017 February 2017 February 2018 April 2016 February 2017 March 2017 March 2018 May 2016 March 2017 April 2017 April 2018 June 2016 April 2017 May 2017 May 2018 July 2016 May 2017 June 2017 June 2018 August 2016 June 2017 July 2017 July 2018 September 2016 July 2017 August 2017 August 2018 October 2016 August 2017 September 2017 September 2018 November 2016 September 2017 October 2017 October 2018 December 2016 October 2017 November 2017 November 2018

3 page 3 Elderly/Disabled Households w/ Earned Income & Households Residing on Indian Reservations w/ Earned Income 24 Certification Periods Beginning Date of Aid 6th 12th 18th August 2015 N/A July 2016 January 2017 July 2017 September 2015 N/A August 2016 February 2017 August 2017 October 2015 N/A September 2016 March 2017 September 2017 November 2015 N/A October 2016 April 2017 October 2017 December 2015 N/A November 2016 May 2017 November 2017 January 2016 June 2016* December 2016 June 2017 December 2017 February 2016 July 2016 January 2017 July 2017 January 2018 March 2016 August 2016 February 2017 August 2017 February 2018 April 2016 September March 2017 September 2017 March 2018 May 2016 October 2016 April 2017 October 2017 April 2018 June 2016 November 2016 May 2017 November 2017 May 2018 July 2016 December 2016 June 2017 December 2017 June 2018 August 2016 January 2017 July 2017 January 2018 July 2018 September 2016 February 2017 August 2017 February 2018 August 2018 October 2016 March 2017 September 2017 March 2018 September 2018 November 2016 April 2017 October 2017 April 2018 October 2018 December 2016 May 2017 November 2017 May 2018 November 2018 Homeless & Migrant Seasonal Farmworker Households 12 Certification Periods Beginning Date of Aid SAR 7 Data 6th Mont August 2015 December 2016 January 2017 July 2016 September 2015 January 2017 February 2017 August 2016 October 2015 February 2017 March 2017 September 2016 November 2015 March 2017 April 2017 October 2016 December 2015 April 2017 May 2017 November 2016 January 2016 May 2016* June 2016* December 2016 February 2016 June 2016 July 2016 January 2017 March 2016 July 2016 August 2016 February 2017 April 2016 August 2016 September 2016 March 2017 May 2016 September 2016 October 2016 April 2017 June 2016 October 2016 November 2016 May 2017 July 2016 November 2016 December 2016 June 2017 August 2016 December 2016 January 2017 July 2017 September 2016 January 2017 February 2017 August 2017 October 2016 February 2017 March 2017 September 2017 November 2016 March 2017 April 2017 October 2017 December 2016 April 2017 May 2017 November 2017

4 page 4 Note: *Due to the timing of the conversion from CR to SAR, in the conversion month these households will not receive or be required to submit a SAR 7. The households will be subject to SAR reporting rules ongoing. Good Cause It is critical that eligible households do not lose benefits during the transition to SAR period (June 1, 2016-May 31, 2017). The EW should utilize the extenuating circumstances provision under the good cause regulations for the first twelve months subsequent to implementation for each affected household. The household must submit its SAR 7 during the restoration month to be granted good cause and a full rescission. Good cause allows for discontinuances due to non-submission of the SAR 7 to be rescinded with no loss of benefits when the household cannot reasonable be expected to fulfill his or her responsibilities due to factors outside of his or her control. Extenuating Circumstances The county should unitize the extenuating circumstances provision for the first 12 months subsequent to implementation for each affected household. The following guidelines apply when implementing good cause: Good cause may be granted if the household submits their SAR 7 after the extended filing date, but no later than the last day of the month following termination. The household must submit its SAR 7 during the restoration month to be granted good cause and the full month benefit. After the twelve-month transition period for the elimination of change reporting, if a household submits its SAR 7 after the extended filing date, but in the month following termination, the EW must apply the Restoration of Aid rules. If a household submits their SAR 7 later than the last day of the month following termination, the household must file a new application if they wish to continue to receive benefits. Example: The household was initially certified in September 2016 and is due for recertification August The household s first SAR 7 is due in February If the household submits their SAR 7 in March 2017, but after the extended filing date, good cause should be approved and documented in the case record and benefits must be rescored effective March 1, 2017 with no break in aid.

5 page 5 Example: Same scenario as described above. If the household submits the SAR 7 in April 2017, the discontinuance due to failure to submit a complete SAR 7 remains effective and the household must reapply for benefits. Implementation The change is effective June 1, Documentation The reason why good cause has been approved must be documented in the case record. CalWIN CalWIN will convert all CR cases to SAR effective June 1, The conversion process will be completed in May CalWIN has mailed the CF 500 to all affected CalFresh households in December 2015 and March It will be mailing the CF 500 in May Forms The CF 500, Informational Notice to CalFresh Recipients informational notice explaining the new reporting requirements and the transition to SAR was developed by the State. Other Program The changes addressed in this Update only apply to the CalFresh Program. Quality Control No special procedures are required for these cases. There is no hold-harmless period and QC staff will continue reviewing cases using standard review procedures. Supervisors EW Supervisors must review this Update with their unit no later than March 31. DENISE BOLAND, DIRECTOR, Department of Employment and Benefit Services Contact Person(s): Michelle Demetrius, CalFresh Program Coordinator, (408)

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