Allowable and Unallowable CFET Participant Reimbursements

CFET Third-Party Partners are required to provide supportive services to CFET participants to aid in removing or removing employment barriers. Supportive service plans must specify the types of supportive services offered, whether supportive services are distributed as reimbursements or allowances, as well as the methods used to administer and track the supportive services. Verification of cost and need for a supportive service is required prior to issuance. The verification must demonstrate that the supportive service is necessary, reasonable, and directly related to participation in CFET. When documenting a supportive service, the component(s) in which a participant is enrolled must be tracked. Records and/or copies of receipts for all supportive services issued, along with justification for each issuance, must be kept. The County can provide technical assistance regarding the types of supportive services allowable and eligible for reimbursement; however, each CFET Third-Party Partner is ultimately responsible for providing supportive services that are reasonable, necessary, and directly related to participation in their CFET program.

When a CFET Third-Party Partner does not have an established direct supportive service issuance, the Third-Party Partner must create a process to refer CFET participants to available linkages to provide needed supportive services, and demonstrate an ability to track and document the success of those linkages to provide the needed supportive services to CFET participants.

Supportive services may not:

Be used for the purpose of overcoming barriers which exempt individuals from federal work registration.
Be available through another government program or available at no cost to the participant through a private source (e.g., charitable donations).
Be used for supporting a participant’s regular employment.

Transportation

CFET participants must be reimbursed for the costs of transportation determined to be reasonable, necessary and directly related to participation in CFET. Such costs must be the actual costs incurred unless the CFET Third-Party Partner responsible for administering CFET has an approved method to provide allowances rather than reimbursements. CFET participants must be provided an opportunity to claim actual expenses up to the maximum level of reimbursement established by the responsible entity. Transportation issuance may include Valley Transport Authority (VTA) bus passes and tokens, and ride share fares (Uber, Lyft, etc.).

Childcare

CFET participants must be reimbursed for the cost of dependent care that is determined to be necessary and directly related to participation in CFET, up to the actual cost of dependent care or the applicable payment rate for childcare, whichever is lowest based on local market rate surveys.

Dependent care reimbursement must be provided to CFET participants for all dependents requiring care unless otherwise prohibited. Reimbursement for a dependent age 13 or older may not be provided unless the dependent is physically and/or mentally incapable of caring for themselves or is under court supervision. Verification of the physical and/or mental incapacity for dependents age 13 or older must be obtained if the physical and/or mental incapacity is not readily apparent.

A CFET participant is not entitled to the dependent care reimbursement if a member of the CalFresh E&T participant's household provides the dependent care services. Dependent care expenses beyond what is required for participation in CalFresh E&T activities are not eligible for 50 percent reimbursement. Verification of the cost and the participant’s need for dependent care is required prior to the issuance of the supportive service. The verification must include the name and address of the dependent care provider, cost, and the hours of service.

In lieu of providing reimbursements for dependent care expenses, arrangements can be made for dependent care with providers through service contracts, by providing vouchers to the household, or by other means. A CFET participant may refuse available appropriate dependent care as provided or arranged if the participant can arrange other dependent care.

Ancillary Expenses

Ancillary expenses are costs incurred by the participant that are directly related to participation in the CFET program. Examples include, but are not limited to uniforms, personal safety items, other necessary equipment, books or training manuals, internet costs, and housing subsidies.

ALLOWABLE COSTS

To be allowable, costs for the CFET program services must:

Be directly related to an approved CFET component or service.
Be necessary and reasonable.
Not be for the purpose of overcoming barriers to work registration (i.e., drug or alcohol treatments and rehabilitation programs).
Not be a general expense required to carry out the overall responsibilities of a state or local government, such as a state’s funding for education provided for by statute.

Reasonable Costs

A cost is reasonable if, in its nature and amount, it does not exceed what a prudent person would pay under the circumstances prevailing at the time the decision was made to incur the cost. To be considered reasonable, a cost must:

Provide a program benefit generally proportionate with the cost incurred.
Not be higher than the cost charged to the general public for the same service.
Be within the scope of the CFET program.

Necessary Costs

Necessary costs are incurred to carry out essential functions which cannot be avoided without adversely affecting program operation and do not duplicate existing efforts. To be considered necessary, a cost must:

Be incurred to carry out essential functions of CalFresh E&T.
Be unavoidable without adversely affecting program operations.
Not be duplicative of existing efforts.

UNALLOWABLE COSTS

The following costs are unallowable for CalFresh E&T:

Advertising
Advisory Councils
Alcoholic beverages
Alumni activities
Bad debt (includes late fees and/penalties)
Commencement and convocation costs
Defense and prosecution of criminal and civil proceedings, claims appeals, and patent infringement
Entertainment costs
Fundraising costs
Goods and services for personal use
Interest on borrowed capital
Lobbying costs
Membership costs-such as country club, social or dining
Relocation and rental costs associated with staff administering the program
Selling and marketing, unless approved and necessary for the performance of the grant
Severance costs
Student activity costs

Below are examples of participant reimbursements that are and are not allowed. Items marked as "Almost Always" or "Sometimes" assume the item is required for successful participation in a CFET component.

All CFET allowable costs must be reasonable and necessary.

Item	Almost Always	Sometimes	Never	Notes
Automobile Insurance			X
Automobile Purchase			X
Automobile Repairs		X		Capped or limited to a reasonable amount
Background Checks		X		Only if required for a job
Books & Supplies	X			Must be necessary to complete CFET training session/educational coursework
Clothing for Job Interviews	X
Clothing for Work		X		As part of a job retention component (up to 90 days)
Course Registration Fees	X
Dental Work		X		Minor work, such as a cleaning; Not major work such as oral surgery, bridge work, braces, dentures, etc.
Dependent Care Costs	X
Drug/Alcohol Counseling or Therapy			X	Usually Covered by Medi-Cal
Drug Tests		X		Only if required for a job
Equipment		X		Must be necessary to complete CFET component or job retention component (up to 90 days)
Fingerprinting		X		Only if required for a job
Gasoline	X
Legal Services		X
Licensing and Bonding Fees for Work Experience/ Placement	X
Living Stipends			X
Medical Services		X		Usually covered by Medi-Cal, but allowable if required for a job (i.e. TB test)
Mental Health Treatment			X	Usually Covered by Medi-Cal
Personal Computers			X
Personal Safety Items	X			Must be necessary to complete CFET training session/educational coursework
Relocation Expenses			X
Student Activity Fees		X		Only if required to participate in class
Student Loans			X
Test Fees		X		Must be directly associated with an CFET component
Tools		X		Must be necessary to complete CFET vocational training or required for job
Training Materials	X			Must be necessary to complete CFET vocational training
Transportation Expenses (i.e. Public Transportation Fare or Gas Voucher)	X
Tuition/Fees		X
Uniforms	X			Must be necessary for a job
Union Dues		X		Must be necessary for job
Vision Needs (Eye Glasses or Eye Exam)		X