Verifications the CalFresh office requires

CalFresh offices should tell applicants clearly what verifiable information they must bring in, and the date by which they must bring in that information. [7 U.S.C. § 2020(e)(3); MPP § 63-300.37.] The CalFresh office should be flexible about what is acceptable verification. [7 C.F.R. § 273.2(f)(5)(i).] “In general, counties should verify only mandatory eligibility factors for CalFresh unless its for the purpose of maximizing benefits.” [ACIN 1-45-11]

SNAP regulations require applicants to give the case worker proof of 14 things. [ACL 20-48.]

  1. Income. [7 C.F.R. § 273.2(f)(1)(i); MPP § 63-300.5(e)(1).] The state should only “reverify” income at recertification if the household’s income has changed more than $50. [7 C.F.R. § 273.2(8)(i)(A).] Some notable irregularities include situations where a household member’s name differs from the name on an earnings statement, and households with California Employment Development Department (EDD) debt cards. [See ACIN I-51-11.] (See the section about the definition of income for more details). At application, households must provide verification of income earned over the last 30 days unless the household just started working. Note that Excluded income is not subject to verification. [ACIN I-01-24.] Counties can only request verification if the information provided by the applicant or recipient is questionable. [Id.]
  2. The immigration status of any non-U.S. citizen household member. [7 C.F.R. § 273.2(f)(1)(ii); MPP § 63-300.5(e)(2).] The CalFresh office will send this information to the U.S. Citizenship and Immigration Services (USCIS) to be checked.
  3. The Standard Utility Allowance (SUA) only before the Standard Utility Allowance is allowable as a deduction from gross income. [7 C.F.R. § 273.2(f)(1)(iii); MPP § 63-502.363; ACIN I-61-08.] See the section about income deductions for more details.
  4. Shelter costs only before shelter costs are allowable as a deduction from gross income. [ACL 20-48.]
  5. The Social Security numbers of everyone in the household. [7 C.F.R. § 273.2(f)(1)(v); MPP § 63-404.1.] The CalFresh office will check the numbers with the Social Security Administration (SSA). If a household member applying for benefits does not provide a Social Security number, that person must prove they applied for one. [7 C.F.R. § 273.6(b)(2); MPP § 63-404.3.]. See the section about Social Security number requirements for more details.
  6. Where the applicant lives. The CalFresh office does not have to verify where the applicant lives if it is not reasonably possible to get verification. [MPP § 63-300.5(e)(5).] For example, the county does not have to verify where the applicant lives if she just came to the area, if she is homeless, or if she is a migrant farm worker and cannot get verification easily. [MPP § 63-300.5(e)(5)(A).] Homeless people who live in a general area should simply have to show that they live in that area. They can verify this through someone who knows them, e.g., a letter from a collateral contact. [7 C.F.R. §§ 273.3(a), 273.2(f)(1)(vi); MPP § 63-300.5(e)(5).]
  7. The identity of the person making the application for CalFresh benefits, i.e., the adult or head of household. [7 C.F.R. § 273.2(f)(1)(vii); MPP § 63-300.5(e)(3).] If an authorized representative applies for the household, the CalFresh office must verify the identity of both the authorized representative and the head of the household. [Id.] If the person cannot prove identity through readily available documents — e.g., because they lack a photo ID — the county must use the collateral contact process.[Id.] Counties cannot limit verification to any single type of document if multiple sources are available. [ACIN 1-45-11.] If the household was already verified through the SSA for a Medi-Cal application, the household is considered verified for CalFresh. [Id.]
  8. Medical expenses, for households with an elderly or disabled member. [7 C.F.R. § 273.2(f)(1)(iv); MPP § 63-300.5(e)(7).] The state shouild only “reverify” medical expenses at recertification if they have changed more than $50. [7 C.F.R. § 273.2(8)(i)(A).] If the medical expense is not verified, the household does not get the deduction, but the failure to verify does not affect eligibility otherwise. (See the section about medical expense deductions for more information.)
  9. Disability benefits. If a member of the household wants the special benefits the CalFresh Program gives to disabled people, then she must prove she is getting disability benefits. [7 C.F.R. § 273.2(f)(1)(viii); MPP § 63-300.5(e)(9).] (See the section about how “elderly” and “disabled” are defined for more information.)
  10. Child support payments. The household must show what amount it is legally obligated to pay, and what amount the household actually pays per month. [7 C.F.R. § 273.2(f)(5)(xii); MPP § 63-300.5(e)(10).] The household is responsible for providing verification. [MPP § 63-300.5(e)(10).] (For related information on verifying child support obligations and payments, see the first set of Questions and Answers Regarding the Food Stamp Program Certification Provisions of the 2002 Farm Bill.)
  11. Physical or mental “unfitness. This is only necessary if one individual in the household says she is a student not traditionally eligible for CalFresh benefits. This does not apply to those obviously “unfit.”; [7 C.F.R. § 273.2(f)(1)(xi).] A statement from a doctor or psychologist is OK. [7 C.F.R. § 273.2(f)(1)(xi).; MPP § 63-406.121.]
  12. “ABAWD” recipients. Able-bodied adults without dependents (ABAWD) subject to the three-month time limit must verify the number of hours per week they are working or in a work program. An individual can also use the number of months of SNAP benefits he has received in another state to show that he is currently eligible for SNAP benefits. [7 C.F.R. § 273.2(f)(1)(xiv); MPP § 63-410.2.] See Able-bodied adults without dependants for the status of the ABAWD rule in your county and statewide.
  13. Sponsored non-citizen information only for a member of the household who is a sponsored non-citizen, who is applying for benefits, and who has not claimed to be indigent. [ACL 20-48.]
  14. “Drug felony” compliance with drug treatment that is a condition of probation or parole. [ACL 20-48.] In states other than California, the so-called drug-felony exclusion may still apply. These states may require specific verifications related to current involvement in a drug treatment program and testing negative for drug use.

Counties cannot require a specific type of verification even if the information is considered a mandatory. Verification can be provided by various methods including documentary evidence, electronic verification, collateral contact and client statement. When certain verification methods are unavailable to the household, the county must use the best available information. [ACL 20-48.] For formerly incarcerated individuals, identification cards and booking sheets from the prison or jail are examples of acceptable forms of identification. [ACWDL, November 18, 2022.] Any documents which reasonably establish the applicant’s identity must be accepted, [Id.]

Counties must assist all households in obtaining mandatory verification. Counties must use existing verification sources when available, and electronic verification when applicable to the household. [ACL 20-48; ACWDL, November 18, 2022.]

To the extent permitted by federal law, counties must seek verification via available electronic sources or client statement when allowed, before requiring submission of additional information, use of collateral contacts, or home visits. Before sending a household request for missing verification, the county must check all available electronic resources to verify the missing information, and use the client statement to the extent allowed by federal law. [ACL 20-135.]

Counties must not send a request for missing verification or deny a case based on missing verification, unless they have first checked all available electronic sources or determined whether client statement is an allowable option. [Id.]

Available electronic sources include IEVS, MEDS, SSA, CMIPS, or any other source available to the county. The Work Number can only be used for verification when confirmed by the household to be accurate. [Id.]

Counties must accept verbal confirmation from the household whenever client statement is a valid form of verification. For information that can be verified by client statement and that is not questionable, counties are not required to also check electronic sources, and cannot delay processing of an application, recertification or periodic report by checking electronic resources. [ACL 20-135.] When regulations only allow for verification via client statement under specific circumstances, and all other attempts at verification have failed, counties can use the best available information which can include verbal client statement. [Id.] For information that can be verified via client statement and that is not questionable, it is not necessary for CWDs to also check available electronic sources because the information is already verified by virtue of the clients’ statement. [Id.]

To request information, counties must use the CW 2200 – Request for Verification form. [See ACIN I-33-21, ACL-20-135, ACIN 1-24-15; ACIN I-01-24 at p.3.] Counties must get written approval from the California Department of Social Services (CDSS) to use a “substitute request for verification” form. A substitute form must contain certain essential information to be valid. [See ACL 14-26.] Adverse actions based on an improper or defective request for verification form may be subject to challenge even beyond the normal 90-day appeal time. Such adverse actions can include denials, terminations or disallowance of deductions.

The County residency requirement

A household must apply for CalFresh benefits in the county in which it lives. [7 C.F.R. § 273.3(a); MPP § 63-401.1.] No person can participate as a member of more than one household, or in more than one county in any month. An exception is made for eligible residents of shelters for battered women and children who were program participants in the home of the abuser. [MPP § 63-401.2, 63-503.46.] The county cannot impose any durational residency requirements. [7 C.F.R. § 273.3(a); MPP § 63-401.4.] The county also cannot require an “intent to reside permanently in the county.” [7 C.F.R. § 273.3(a); MPP § 63-401.5.] Persons in a county solely for vacation purposes should not be considered residents of that county. [MPP § 63-401.5, 401.6.]

No fixed address is necessary. The county cannot require anyone to reside in a permanent dwelling or have a fixed mailing address as a condition of eligibility. [MPP § 63-401.5.] Categorically eligible households do not have to provide verification of residency. (i.e., those already on CalWORKs (TANF) or other public assistance programs)[MPP § 63-301.7.]

Residency can be shown through proof of “rent or mortgage payments, utility expenses, and identity.” If verification cannot be accomplished due to a lack of acceptable evidence, a collateral contact or other readily available documentary evidence should be used. Any documents or collateral contacts which reasonably establish an applicant’s residency must be accepted. The county cannot require a specific type of verification be used. [See 7 C.F.R. § 273.2(f)(1)(vi); MPP § 63-300.5(e)(5).] Residency must be verified to the extent possible, using all documents already provided by a household.

Migrant farm worker households, homeless households, or households newly arrived in the community may not be able to provide satisfactory verification of residency. In these instances, if the applicant with the county’s assistance has (1) made reasonable efforts to obtain verification; and (2) verification cannot be obtained; and (3) the applicant’s statement regarding residency is not questionable, the county must proceed with certification if the household is otherwise eligible. Except for homeless household, verification of residency must be provided by such households prior to their next certification. [See MPP § 63-300.5(e)(5)(A).]

Optional verifications

The CalFresh case worker may also ask the applicant to prove other facts. Information that is not considered mandatory verification must only be verified is it is questionable. The county must document in the case record why the information is considered questionable before requesting verification from the household. [ACL 20-48.] The CalFresh office should not ask the applicant to bring in any specific documentation. [7 C.F.R. §§ 273.2(f)(4)(i) and 273.2(f)(5).] The CalFresh office’s rules about verification must not have the effect of discriminating against any group of people. [7 C.F.R. § 273.2(f)(3)(i).] The CalFresh office should ask the household members to verify their present circumstances. Applicants should not be asked about things in the past that do not affect their current eligibility.

The CalFresh office may ask the household to verify the following:

For factors other than mandatory verifications, a client statement must be accepted as verification unless the information provided is questionable. [ACL 20-135.]

Exceptions to the CalFresh student eligibility rule only need to be verified when information provided by the household is questionable, or if the student’s mental or physical unfitness is not evident. [ACL 21-58.] Information is considered questionable if it differs from previous statements or other information received by the county, and the inconsistency must be resolved before receiving CalFresh benefits. [Id.] Verification for physical or mental unfitness is required when the unfitness or disability is not evident to the county and can be provided by any medical health professional or the applicant’s case manager. [Id.]

Verification of job loss or zero income

Verification of job loss is not mandatory. When a household member reports to have lost a job, the county must not require verification unless it is questionable. The client’s statement of recent job loss is sufficient evidence that a household cannot reasonably anticipate income from that job to continue during the certification period. [ACL 20-48.]

If an applicant who is subject to work requirements voluntarily quit their job within 60 days prior to the date of the application, the county must determine whether there was good cause to quit. The county must request verification if the information provided is questionable. [Id.]

When a household has zero income at initial application, a statement on the application that it has zero income is sufficient evidence that the household cannot reasonably anticipate income during the certification period. The county must not require verification of zero income unless it is questionable. [Id.]

If an applicant or recipient has applied for Unemployment Insurance but is not yet receiving that benefit, the county must accept a statement under penalty of perjury that the applicant or recipient is not receiving Unemployment Insurance, even if that statement differs from documentary evidence from the Employment Development Department. [All County Welfare Directors Letter, January 29, 2021.]