Vendor Payment and/or Designated Alternate Cardholders

[EAS 44-303.34 & 44-307.12]

Anytime a parent or caretaker relative has been sanctioned for a minimum of three consecutive months, the CalWORKs (CW) grant must be issued via a Vendor Payment (VP) to the landlord and/or to a Designated Alternate Cardholder (DAC).

The CW grant must continue to be issued via VP/DAC until the adult(s) is no longer subject to the CalWORKs Employment Services (CWES) sanction. Once the client is eligible for an exemption or has cured their sanction, the VP/DAC must be terminated, and the grant must be issued directly to the client.

Failure to comply with the VP requirements and assign a DAC will result in the discontinuance of the Assistance Unit (AU)'s CW benefits. The discontinuance reason must be clearly documented as "Failure to comply with the VP requirements."

If...	Then...
The client chooses to assign a DAC,	The entire grant amount must be issued to the DAC.
The client chooses VP, and the rent amount is more than the CW grant,	The entire CW grant amount is issued via VP to the landlord to pay for a portion of the rent amount. Explore how the client is meeting needs.
The client chooses VP, and the rent amount is less than the CW grant,	The entire rent amount is paid to the landlord via VP. The client must also assign a DAC. The remaining grant amount must be issued to a DAC. Note: If, after making all reasonable efforts, an appropriate individual cannot be appointed as a DAC, the remaining grant amount may be issued directly to the client.
The landlord refuses to provide the necessary information,	The CW grant must be issued to a DAC.
The client refuses to comply with the VP/DAC requirements,	The AU’s CW benefits must be discontinued for failure to provide the necessary documentation and/or information to comply with the VP process.
The landlord refuses to provide the necessary information, and the client does not have anyone to serve as the DAC, and CW will fail if the client is not part of the AU,	Follow the One-Day Lift workflow.

Refer to CalWORKs Business Processes Handbook CalWORKs Vendor Payment for detailed information.

Vendor Payment and Sanctions

All clients who have been sanctioned for 3 or more consecutive months and reapply for CW on or after 4/1/2010 will be required to comply with the VP/DAC requirements before CW can be approved for the AU, if otherwise eligible.

Sanctions from Other Counties

When a client is sanctioned in another county (for more than 90 days), the individual would remain sanctioned in Santa Clara County; however, the VP requirements would not apply at the point of intake. The remaining AU members would be approved for CW if eligible. The individual must be referred to CWES for Welfare-to-Work (WTW) compliance. After the sanctioned individual has not complied with the work requirements for 90 days in Santa Clara County, the client would be subject to the VP requirements.

Example Example The client applies for CW for herself and her 2 children in Santa Clara County on 4/20. The intake SSBS reviews the case and sees that the client has an uncured sanction from San Mateo County since 2009. If otherwise eligible, the two children are approved for CW, and the sanctioned adult is denied. The client is not yet subject to the VP requirements; however, she is referred to CWES to comply with the work requirements. If by 7/19 (90 days), the client has not complied with CWES, the client will be required to comply with the VP requirements by 8/1 in order to prevent discontinuance of the entire case for failure to provide.

Vendor Payment and DAC

When the client selects a DAC, the following rules and restrictions must be explained to the client:

The DAC must not be currently receiving aid (i.e., have a case active on either CW, RCA, or CalFresh (including Transitional CalFresh (TCF)).
The DAC may be receiving Medi-Cal only benefits.
The DAC must not be living with the client.
The DAC must not be the absent parent.
The DAC must not be an SSA employee.
The DAC must provide a valid ID and complete the DAC form.

Note: The DAC may reside in a neighboring county. However, if the situation appears to be suspicious, the Social Services Benefits Specialist (SSBS)/Associate Employment Counselor (AEC)/Employment Counselor (EC) may do a fraud referral for further investigation.

Vendor Payment DAC & SSI/SSP Recipients

If an SSI/SSP recipient does not have an open case for themselves with Social Services (i.e., CalFresh, GA, etc.), they may be a DAC for a VP client. If the SSI/SSP adult is only a DAC in a case, then the SSI/SSP adult can be a DAC in another case. If the SSI/SSP adult is the parent of children in a CW or CalFresh case and the case payee, then the SSI/SSP adult cannot be a DAC in another case.

Note: If the SSI/SSP recipient is on an open MC-only case, this person may be selected to be a DAC in another case.

Example 1 Example 1 SSI/SSP mom and her two children are on a CW/CalFresh case, SSI/SSP mom is the payee. The SSI/SSP mom cannot be a DAC for another case.

Example 2 Example 2 SSI/SSP grandmother is the NNCTR for her grandson and the payee for his CW benefits. The SSI/SSP grandmother can be a DAC for another case.

One-Day Lift for Sanctioned Individuals

A sanction may be lifted in one day if an applicant or recipient meets any one of the following criteria:

Sanctioned previous to CalWIN - 6/1/05,
Good Cause for domestic abuse referral,
Good Cause for homelessness - must be verified,
If AU of one due to a child on SSI/SSP or Pregnant Person Only (PPO) with no other children,
Client is exempt due to:
- Medical exemption,
- Caregiver of an ill/incapacitated household member,
- Young Child Exemption
  - 0-23 month exemption, or
  - 3-month exemption or
  - 6-month exemption,
Sanctioned from another County,
Client is full-time employed,
DFCS Common Case.

Note: When the applicant’s landlord refuses to cooperate with the VP process, and the applicant does not have anyone to appoint as the DAC, the One-Day Lift workflow should be followed.

One-Day Lift Workflow for Intake

Intake SSBS
1. Clears all other CW eligibility factors.
  1. Note: If the client is pending for other eligibility factors/verification, do not refer to CWES until the applicant complies to prevent erroneous referrals.
2. Contacts the CWES Engagement Unit Officer of the Day (OD) to determine what the client needs to do in order to lift the sanction.
  1. Note: The CWES Engagement Unit OD calendar is emailed to AAC, CBS, North County, and South County on a monthly basis.
3. Enters WTW drop-down Journal Type in the Journal Detail page.
4. In the Short Description, enters Vendor Payment and adds journal entry.
Engagement AEC/EC
1. Reviews the case for the possibility of processing a one-day lift and provides the CWES Orientation information to the SSBS.
2. Enters WTW drop-down Journal Type in the Journal Detail page.
3. In the Short Description, enters Vendor Payment and adds journal entry.
Intake SSBS
1. The CW application will be left in pending status to allow the applicant to attend the CWES Orientation.
Engagement AEC/EC
1. Clears the Orientation Roster and confirms the case is in pending status for VP/DAC only.
  1. When the individual qualifies for the one-day lift, the AEC/EC will follow the sanction lift business process.
  2. When the applicant does not qualify for the one-day lift, the AEC/EC will document findings using the Vendor Pay drop-down and will make a courtesy call to the SSBS. The client will be advised of the regular sanction process.
Intake SSBS
1. When the applicant is in the 30-day curing process, and there are no other eligible members in the AU, the CW application should remain pending until the sanction is lifted or the client has failed to cure the sanction by the 30th day.
2. When the AU contains the sanctioned applicant, and the applicant refuses to cooperate with the VP/DAC requirement or to cooperate with CWES to lift the sanction, deny the CW application with the Failure to Cooperate, Deny (M40-171A) Notice of Action (NOA).

One-Day Lift Work Flow for Continuing

Continuing SSBS
1. Discovers that the sanctioned recipient meets one of the One-Day Lift criteria.
2. Contacts CWES to determine what the client needs to do to lift the sanction.
  1. When the WTW Program is unassigned, contact the CWES Engagement Unit OD.
    1. Note: The CWES Engagement Unit OD calendar is emailed to AAC, CBS, North County, and South County on a monthly basis.
  2. When the WTW Program is assigned, contact the assigned AEC/EC.
3. Enters WTW drop-down Journal Type in the Journal Detail page.
4. In the Short Description, enters Vendor Payment and adds journal entry.
Engagement AEC/EC or Assigned AEC/EC
1. Reviews the case for the possibility of processing a one-day lift and provides the CWES Orientation information to the SSBS.
2. Enters WTW drop-down Journal Type in the Journal Detail page.
3. In the Short Description, enters Vendor Payment and adds journal entry.
4. Clears the Orientation Roster and confirms the case is in Active status.
  1. When the individual qualifies for the one-day lift, the AEC/EC will follow the sanction lift business process.
  2. When the recipient does not qualify for the one-day lift, the AEC/EC will document findings in the Journal Detail page and will make a courtesy call to the SSBS.
Continuing SSBS
1. When the client complies, follow the Lift Sanction instructions per Task Creation instructions.
2. When the AU contains a sanctioned individual and refuses to cooperate with the VP/DAC requirement or to cooperate with CWES to lift the sanction, discontinue the CW Program, and send the appropriate NOA.

Scenarios

Scenario 1: One-Parent CaseScenario 1: One-Parent Case

The case is discontinued effective 8/31 for Failure To Provide.
On 9/6, the client contacts CWES to cure the sanction and attends Orientation.
1. In order to have the sanction lifted, the client must still participate for 30 days (until 10/6) with CWES.
2. CWES refers the client to the appropriate continuing District Office for Application Registration and VP/DAC compliance.
On 9/16, the client provides VP/DAC documentation.
1. The SSBS will restore CW for the children effective the date of reapplication.
On 10/7, CWES lifts the sanction effective 10/1 and notifies the SSBS.
1. The SSBS will add the parent to the CW grant effective 10/1.
2. The VP/DAC will end on 10/7.

Note: The VP/DAC is already issued for the current month (October). The supplement due to the addition of a parent must be issued to the parent, not the landlord. The entire grant amount for the future month (November) is issued to the parent.

Scenario 2: One-Parent CaseScenario 2: One-Parent Case

The case is discontinued effective 8/31 for Failure To Provide.
On 9/6, the client contacts CWES to cure the sanction and attends Orientation.
1. In order to have the sanction lifted, the client must still participate for 30 days (until 10/6) with CWES.
2. The continuing District Office takes the application and "App reg's" the case and schedules a VP/DAC appointment.
The client does NOT provide VP/DAC.
The SSBS will deny the reapplication and notify CWES of the denial.

Scenario 3: Intake CaseScenario 3: Intake Case

The sanctioned client applies for CW on 2/19. The SSBS interviews the client and determines the AU is CW eligible on 3/10.
The client chooses VP. However, rent has already been paid for February and March.
The client must also choose a DAC in order to issue CW benefits for February and March to the EBT account. Effective April, rent will be paid directly to the landlord with VP.

Scenario 4: Continuing CaseScenario 4: Continuing Case

The case is set up for VP. The rent amount is $300, and the grant amount is $250. Therefore, all of the CW grant amount is issued directly to the landlord on a monthly basis as a VP.
There is a budget change in the client’s CW grant determination that will result in an additional $80 in CW. The new grant amount is $330.
The client must also assign a DAC in order to issue the remaining $30 in CW grant (after $300 is issued as a vendor payment to the landlord).

Scenario 5: ICT CaseScenario 5: ICT Case

A CW case is transferred from Solano County. The adult in the case had been sanctioned for more than 3 months in the other county.

The sanctioned adult must cooperate with CWES or comply with the VP/DAC requirement within 90 days. If the client fails to comply with the VP/DAC requirement, the AU will be discontinued from CW.

Scenario 6: Selects VP but Unable to Appoint a DAC for Remaining AmountScenario 6: Selects VP but Unable to Appoint a DAC for Remaining Amount

A client subject to the VP requirements chooses to have the CW grant issued via VP to her landlord. The client’s rent is $90, and her total grant is $516. She must appoint a DAC to be issued the remaining CW grant amount.

The client chooses to appoint her sister as her DAC. After reviewing CalSAWS, it is determined that the client’s sister cannot be her DAC since she is also receiving CW benefits.

The client then chooses to appoint her uncle as her DAC. Her uncle is currently employed at SSA and, therefore, is also not eligible to be a DAC. The client has no further individuals she can appoint as a DAC.

In this scenario, the client has complied with the VP requirements but was unable to provide an eligible DAC for VP. The remaining CW grant amount would be issued to the client.

Scenario 7: AU of One Unable to Select VP and Does not Have Anyone to Appoint as a DACScenario 7: AU of One Unable to Select VP and Does not Have Anyone to Appoint as a DAC

An AU of one subject to the VP/DAC requirements does not have a landlord that is willing to accept VP for rent, and the applicant does not have anyone to appoint as a DAC.

The applicant is willing to cooperate with CWES to lift the sanction and is eligible for a one-day lift.

In this scenario, once the sanction is lifted, there is no requirement for VP/DAC, as the applicant will be added to the AU.