Restricted Accounts Good Cause

[EAS 42-213(j)]

Good cause exists for exceeding the 30-calendar-day time limit regarding withdrawals, when circumstances are beyond the AU's control. Those circumstances include:

Illness or medical emergency,
Failed or delayed completion of a home purchase,
Lack of transportation, or
The EW finds other extenuating circumstances.

When good cause is found to exist, the AU is allowed to fulfill the necessary requirement within a reasonable period of time. A reasonable period of time is based on the circumstances for the delay as determined by the EW to avert a determination of a nonqualifying withdrawal.

In this situation, the good cause must be reviewed and approved by the EW Supervisor and thoroughly documented on the CalSAWS Journal Detail page.

Period of Ineligibility

[EAS 42-213(k)]

When a nonqualifying withdrawal is made from a restricted account, a period of ineligibility (POI) must be calculated for the AU.

The POI must be determined even if the AU's total countable property, including the balance in the restricted account prior to the nonqualifying withdrawal, does not exceed the property limit.

Calculation

To calculate the POI, the EW must:

Determine the total amount in ALL of the restricted accounts immediately prior to the nonqualifying withdrawal or prior to the issuance of an interest payment when it is not directly deposited into the account by the financial institution.
Subtract any portion that the EW determines to be a qualifying withdrawal.
Divide the result by the MBSAC for the number of persons in the AU, plus any special needs.
Round down the result to the nearest whole number for the number of months of ineligibility.

Note: If the balance in the restricted account prior to a nonqualifying withdrawal is less than the AU's MBSAC (plus special needs), there is no POI. However, the above computation must be completed and documented on the Journal Detail page.

Other Circumstances

If the recipient makes a withdrawal from a restricted account but does not provide any verification of the withdrawal or expenditure, the POI must be determined, as it is based on the total balance PRIOR to the nonqualifying withdrawal or interest not directly deposited.

If the EW is determining a POI from an initial withdrawal and the recipient makes a second withdrawal, the EW must determine if the second withdrawal meets the appropriate criteria:

If the...	Then...
Second withdrawal was appropriate,	Determine the POI based on the balance minus the second withdrawal.
Second withdrawal was not appropriate,	Determine the POI based on the balance prior to both withdrawals.
Amount of the prior balance is unknown, and the client fails to provide the balance,	The AU is ineligible until the balance is provided and a POI can be determined.

Applying the Period of Ineligibility (POI)

When it is determined that a POI must be applied, the period begins on the first day of the month of the next SAR Payment Period following the reported nonqualifying withdrawal on the SAR 7 and continues for the determined number of months.

If a timely notice cannot be given and the POI does not start until the first day of the month of the next SAR Payment Period, an overpayment exists for any aid issued during the POI.

Example 1Example 1

An AU of three with an April/May/June SAR Payment Period has the following situation:

Restricted account balance prior to the 5/08 withdrawal:	$6,000
Amount withdrawn from account:	4,500
Amount used to purchase home:	3,000
Amount used to buy furniture:	1,500

Since the AU used a portion of the withdrawal on a non-allowable expenditure, the EW must calculate a POI as follows:

Step 1	$6,000	Balance prior to withdrawal
Step 2	- $3,000	Allowable expense for purchase of home
Step 3	$3,000	Remainder
	2.79 months	Divide the remainder ($3,000) by MBSAC + Special Needs for an AU of 3 ($1,026 + 47 in 5/08) = 2.79
Step 4	2 months	Round down the result to the nearest whole number.

The AU is ineligible for two months beginning July due to a nonqualifying withdrawal. The AU can reapply for aid on September 1.

Example 2Example 2

An AU of three with an April/May/June SAR Payment Period has $6,000 in a restricted account, and the AU withdraws $500 to pay the rent in April.

Since the AU made a nonqualifying withdrawal, the EW must calculate a POI as follows:

Step 1	$6,000	Balance prior to withdrawal
Step 2	- 00000	Allowable expense for purchase of home
Step 3	$6,000	Remainder
	5.79 months	Divide the remainder ($6,000) by MBSAC + Special Needs for an AU of 3 ($1,026 + 47 in 5/08) = 5.79
Step 4	5 months	Round down the result to the nearest whole number.

The AU is ineligible for 5 months beginning July. The AU can reapply for aid on December 1.

Example 3Example 3

An AU of two with an April/May/June/July/August & September (Cycle 2) SAR Payment Period has the following property:

$1,000   Restricted account
+   500   checking account
+   400 Savings account
$1,900   Total

The AU wants to buy new furniture and withdraws all of the funds from their accounts, including the restricted account, to pay for the purchases in May. It is determined that the AU made a nonqualifying withdrawal.

Although the AU's total property reserves prior to the nonqualifying withdrawal is under the property limit, a POI is calculated as follows:

Restricted account balance prior to nonqualifying withdrawal in May	$1,000
Divide by MBSAC for 2 ($828 in 05/08)	= 1.207
Round down for the number of months of ineligibility	1

Aid is discontinued effective September 30th. The AU may reapply on October 1st.

Shortening the POI

[EAS 42-213(n)]

The EW must shorten the period of ineligibility (POI) when the AU reapplies for aid and MBSAC has increased.

An increase in MBSAC includes any:

Increase in AU size,
General increase in the MBSAC (COLA increases), or
Determination that the ineligible family would be eligible for a special need item.

Note: These are the only situations when a POI due to a nonqualifying withdrawal may be shortened.

Shortening the POI Calculation

To shorten the POI due to an increase in MBSAC or an increase in special needs, the EW must follow these steps:

Identify the restricted account balance used to calculate the original POI.
Identify the original MBSAC plus any special needs allocated to the ineligible family unit.
Multiply the amount from Step 2 by the number of ineligible months prior to the increase.
Subtract the amount from Step 3 from the amount in Step 1.
Divide the result from Step 4 by the new MBSAC + special needs.
Round down the result to the nearest whole number.
Add the number of ineligible months prior to the increase to the result of Step 5 to determine the revised POI.

The revised POI begins in the same month as the original POI.

ExampleExample

An AU of 2 is in a POI due to a nonqualifying withdrawal. The original POI was calculated as follows:

$2000	Original balance used to calculate the POI
$798	Original MBSAC for AU of 2 in 02/07
2	Number of months of ineligibility

The AU size increased to 3 people in March, and MBSAC increased to $989 (as of 02/07):

$2000	Original balance
-$798	Original MBSAC for 2
$1202	Result

$1202	Divided by increased MBSAC for 3 ($989 in 3/07) = 1.21 Round down to 1

1	Number of ineligible months after the increase
Therefore:
1	Number of months before the increase
+ 1	Number of months after the increase
2	Revised POI (# of months)

The prior POI was reduced from three months to two months. January and February are the ineligible months. If the client reapplies, the beginning date of aid could NOT be before March 1st.

Separate AU for Other Eligibles

[EAS 42-213(o)]

A separate AU may be established for an otherwise eligible person whose needs were not considered in the calculation of the POI.

When a person is added to an AU who has an existing POI, the AU has a choice of either:

Requesting a recalculation of the POI with the additional person included in the MBSAC, or
Asking that a separate AU be established for the additional person not included in the POI, using MBSAC and MAP for 1

The EW must explain to the client the effect of each option and allow the client to make the decision as to which option they choose, then document the results on the Journal Detail page.