Verification Requirements  

Use of The Work Number (TWN)

Due to changes enacted by House of Representatives 1 (H.R. 1) and the State's initiatives to reduce the Payment Error Rate (PER), use of TWN income verification tool has been expanded. Effective immediately, SSBSs are authorized to request and review a 3-month TWN report for all household members whose income must be included at:

• Initial certification,
• Periodic report (SAR 7),
• When adding a household member mid-period, and
• Recertification.

A TWN report must be requested whether or not income and employment is reported or relevant verification is submitted by the household. The SSBSs are required to save a copy of TWN reports in imaging. The signed application or recertification, which includes written authorization to use TWN, applies to all members of the household whose income must be included.

The SSBS must review all available TWN reports in the case record before requesting additional verification from the household. This includes using TWN to verify employment and work hours for Able Bodied Adults Without Dependents (ABAWD) determinations whenever possible, prior to seeking further verification.

Verification Requirements at Application

Once the SSBS receives an application, a TWN report must be requested and reviewed for all household members whose income must be included, regardless of whether income or employment information and/or verification is provided by the household (i.e., paystubs, W-2, bank statement, etc.). 

During the interview process, the SSBS must also offer Truv when required income, employment, and work hour verification is still pending. If after using TWN or offering Truv additional verification of income, employment, and work hours is still required to determine eligibility, the SSBS must send a Request for Verification (CW 2200) form.

Income received during the previous 30 days from the date of application shall be used as an indicator of the income that is and will be available to the household during the certification period. Initial requests for income verifications must be for the 30 days prior to the application date unless the household anticipates changes for the certification period.

For households reporting earned or unearned income, request verification of any income received during the last 30 days prior to submission of the household's application unless the income received 30 days prior has changed or is anticipated during the certification period.

Changing the 30 Day Period 

The requirement for verifying the 30 day income can be adjusted if income received 30 days from the application has changed and cannot be anticipated for the certification period.

The income verification is considered sufficient if the income can be reasonably anticipated and can be used to determine eligibility and benefit amounts. If a household paid weekly or bi-weekly provides a partial pay stub that can be reasonably anticipated, then the income verification is sufficient to determine eligibility and the monthly benefit amount. 

ExampleExample

If a household member’s last day of work was within 30 days of the date of application, then the SSBS must verify the household member’s income and will need to consider the household member’s last day of work and last pay day to determine eligibility and benefit amounts. The SSBS must document why the specific income was anticipated to determine eligibility. 

 

ExampleExample

 

If the client provides income verification that is outside of the 30 days from the date of application but is sufficient for determining eligibility, the SSBS must accept the verification. The intent is to obtain the most recent income verification 30 days prior from the date of application.  However, if there is a change that is reasonably anticipated during the certification period then we can adjust the time period to request verification. Ask for the most recent income information to support an accurate eligibility determination while also providing needed flexibility to request income verification received by the household.

 

Zero Income at Application

Zero income stated on the application on its own is not is sufficient verification that the household cannot reasonably anticipate income during the certification period. A TWN report must be requested and reviewed for all household members whose income must be included, regardless of whether income or employment information and/or verification is provided by the household (i.e., paystubs, W-2, bank statement, etc.).  

Verification Requirements at Recertification

SSBSs must determine the relevant 30 day period based on when the household submits their application for recertification or when a request for income verification is made using the Request for Verification form (CW 2200). When the interview is conducted by TS instead of paper applications, income verification for the last 30 days prior to the TS interview date is used. 

• A TWN report must be requested whether or not income and employment is reported or relevant verification is submitted by the household
• If after using TWN or offering TRUV additional verification of income, employment, and/or work hours is still required to determine eligibility,  then the SSBS must request income verification for the 30 days from the date listed on the CW 2200.

At recertification verification is not required for households who report receiving zero income during the 30 days prior to submitting their annual application for recertification unless it is questionable or there is conflicting information on the case record. Conflicting information includes information received on the TWN report. Verification of income received in the last 30 days prior to submission of a household’s application for recertification is not required if:

• The income source has stopped (i.e., job loss); or
• The income is not reasonably anticipated to continue; and
• The loss of income is not questionable.

Reminder

Prior to requesting verification, the SSBS must:

• Review the case file

• Maximize the use of electronic verification

• Use client statement if allowed

• Request the last 30 days of income from the CW 2200 request date, if required.

Verification Requirements on the SAR 7

The SAR recipients must provide information and answers to all questions and items on the SAR 7 and attest, under penalty of perjury, that they have truthfully reported all required information. The following items are reporting requirements which require verification with the SAR 7.

• Gross non-excluded earned income and non-excluded unearned income when first reported on the SAR 7 and when there is a change in the source and amount of income received.
• Source and amount of all excluded income when first reported on the SAR 7 and any changes in the source and amount of the income.
• Dependent care costs when there is questionable information which is inaccurate, incomplete, outdated, or inconsistent.
• Medical Expenses when there is a change and that change would increase the household’s allotment. The county must act on reported changes without requiring verification if the changes would decrease the household’s allotment or makes the household ineligible, although verification which is required shall be obtained prior to the household’s recertification.
• Verification for actual costs of producing self employment income.
• Residency when there is a change.
• Social security numbers or citizenship or noncitizen status for household members when there is a change.
• A change in the legal obligation to pay child support to a person not in CalFresh household and/or an increase in the amount of child support payments.
• A change in household composition or loss of job or source of earned income on the applicability of the work registration or voluntary quit requirements. Refer to Reporting Requirements on the Semi-Annual Report (SAR 7).

Once a SAR 7 is marked as received, TWN must be requested and reviewed for all household members whose income must be included, regardless of whether a change in income or employment is reported and verification is provided (i.e., paystubs, W-2, bank statement, etc.).

Verification must be requested immediately from the recipient when there is a decrease in income or a new household member is reported, or for other changes that would require verification when benefits would increase. Action to increase or decrease benefits shall not take place until verification is received. The recipient must be allowed 10 days to provide the requested verification. A “No Change NOA” must be sent to the recipient when benefits cannot be increased due to non-receipt of verification. The “No Change NOA” must be sent within 30 days of the reported change. The NOA must remind the recipient to re-report the change on the SAR 7 and submit the verification of the reported change at that time.

A SAR 7 must not be considered incomplete if information regarding child support disregard payments has not been included. If the household submits information and/or verification with the SAR 7 which the county determines to be questionable, the household must be notified and be allowed until the extended filing date to submit the necessary verification/clarification.

Verification Requirements Mid-Period

Changes reported during the certification period shall be subject to the same verification procedures as apply at initial certification, except that the State agency shall not verify changes in income if the source has not changed and if the amount has changed by $50 or less, unless the information is incomplete, inaccurate, inconsistent or outdated. The County shall also not verify total medical expenses or actual utility expenses that are unchanged or have changed by $25 or less unless the information is incomplete, inaccurate, inconsistent, or outdated.

When adding a household member mid-period, a TWN report must be requested and reviewed for all household members whose income must be included, regardless of whether income or employment information and/or verification is provided by the household (i.e., paystubs, W-2, bank statement, etc.). The SSBS must also offer Truv if required income, employment, and/or work hour verification is still pending.

Responsibility for Obtaining Verification [63-300.5(i)]

The household is primarily responsible for providing documentary evidence to support its income statements and resolve any questionable information. Households may supply documentary evidence in person, through the mail, or through an authorized representative. The SSBS will accept any reasonable documentary evidence provided by the household and will be primarily concerned with how adequately the verification proves the statements on the application. If it would be difficult or impossible for the household to obtain the documentary evidence in a timely manner, or the household has presented insufficient documentation, the SSBS will either offer assistance to the household in obtaining the documentary evidence, except as otherwise stated in this section or will use a collateral contact or home visit. The SSBS will not require the household to present verification in person.

Whenever documentary evidence is insufficient to make a determination of eligibility or benefit level, or cannot be obtained, the SSBS may require either a collateral contact or a home visit. The SSBS will rely on the household to provide the name of any collateral contact. The household may request assistance in designating a collateral contact. The SSBS is not required to use a collateral contact designated by the household if the collateral contact cannot be expected to provide an accurate third-party verification. 

When the collateral contact designated by the household is unacceptable, the SSBS will either ask the household to designate another collateral contact or substitute a home visit. The SSBS is responsible for obtaining verification from acceptable collateral contacts.

Release of Information/Consent Forms

When None Is Required

The SSBS does not need client consent for information from public records as long as the purpose is to determine eligibility. This includes obtaining information from:

• DMV
• Vital Statistics (birth, death, marriage, divorce)
• Other County Agencies (DA, Probation, Public Health, CHDP, Mental Health)
• EDD
• Census Records
• Assessor's Office
• Service Worker case files
• Social Security for a program that involves federal funds

CSF 13

An “Authorization for Release of Information” (CSF 13) is required for all third party contacts. The applicant AND spouse should sign, if possible.

Always explain to the client how the form will be used. Review with the client those agencies/persons who may be contacted.

Use the CSF 13 to obtain information from:

• Life insurance clearances
• Employer contacts
• Credit checks
• Medical requests
• Employer termination letter
• Landlords
• Schools
• Prison systems

CSF 17

Use a “Authorization For Release of Information - Financial Institution” (CSF 17) to obtain information from financial institutions on checking and savings accounts, stocks, bonds, credit union accounts, trust funds, etc.

The SSBS must send the completed bottom portion of the CSF 17 to the client within 30 days after receiving financial information. (Required by the California Right to Financial Act.)

Related Topics

Verification

The Work Number (TWN) and Truv