California Relay Services (CRS)

CRS may be used by anyone who has limitations hearing or speaking and to communicate with someone who has these limitations. A specially-trained Communications Assistant (CA) relays telephone conversations for all of the calls. 

Incoming Calls

When you receive a Relay call, the Communications Assistant (CA) (aka Relay Operator) will usually ask, “Have you received a Relay call before?” If you have not, then the CA will give you a brief introduction on what to do during a Relay call.

Outgoing Calls

When reaching out to a client identified as having hearing or speaking limitations:

• Dial 711
• Provide the CA the client’s 10 digit phone number (including area code) 
• When the client answers, identify yourself and read from the CRS phone script below.

CRS Phone Script

The following script must be read to clients prior to any CRS conversation.

“This call was initiated using the California Telephonic Relay Service. The relay service is a third-party that is participating in this conversation with Santa Clara County Department of Employment and Benefit Services. If you would prefer to speak without the presence of the relay service operator you may end this call or arrange for you and me to have our conversation some other way.”

Confidentiality

Federal regulations specify very strict confidentiality requirements for CAs of all Relay services. No part of the conversation that takes place between callers is revealed or recorded in written, verbal, or any other form. CRS CAs do not participate in the conversation and acquire no benefit from information relayed.

Communication Tips

• Talk the same way as you would with anyone else.
• Ask the person how he or she prefers to communicate.
• When speaking through an interpreter, remember the interpreter may lag a few words behind, so pause occasionally to allow him or her time to translate completely and accurately.
• Talk directly to the person who is deaf or who has difficulty hearing, not to the interpreter.
• Look directly at the person and speak clearly, naturally and slowly. Do not over-enunciate or exaggerate words. Unless requested, do not raise your voice.
• To facilitate speech-reading, place yourself facing the light source and keep hands, etc. away from your mouth when speaking. Face the person while you are speaking.

Mental, Cognitive, Literacy or Learning Disability Impairments

Should the worker become aware of a mental, cognitive, or learning disability, the worker is to allow the client to record the conversation if requested by client. Other types of accommodations may include scheduling appointment after hours, reading documents out loud, providing oral explanations of written documents and allowing extra time for information to be fully understood, and repeating phrases as needed if worker is not sure if client understood. 

Other accommodations for clients who have difficulty waiting in office lobbies may include scheduling appointment at client’s preferred time; or for clients sensitive to noise and distractions, use appropriate meetings rooms; offer breaks during longer meetings.

Example Example A human trafficking victim who suffers from mental impairment (severe Post Traumatic Stress Disorder and anxiety) is unable to be around large groups of people. The client has requested an accommodation of meeting away from large groups and offices. The assigned worker will schedule the interview at an off site location. 

Communication Tips

• Always respond in a calm and relaxed manner even if the person makes unusual statements.
• If someone is having trouble understanding you, use language that is concrete, not abstract.
• Allow time for information to be fully understood. Some people who have processing and mental health disabilities will need more time to process and respond to information.
• Check for understanding by asking questions such as, “Did I explain that clearly?” or “Do you have any questions about what I told you?”

Physical Impairments

For applicants who are not able to come to the office in person due to having a physical disability or being housebound, the worker is to accommodate the client by having the appointment in the client’s home.

Communication Tips

• Do not make assumptions about what a person can and cannot do. A person with a physical disability is the best judge of his or her own capabilities.
• Be aware that some people using wheelchairs may choose to transfer themselves out of their wheelchairs and into an office chair during an interview

When speaking to a person in a wheelchair or on crutches for more than a few minutes, sit in a chair. Place yourself at the person's eye level to facilitate conversation.

If an individual is having difficulty doing something, such as filling out forms correctly or making it to appointments on time, staff should ask:

• If there is anything that can/needs to be done to assist the individual, and 
• Offer to the “Need Additional Assistance” (SCD 2371) form and complete on the clients behalf when necessary.

In addition, staff is required to provide reasonable accommodations to family members of an applicant/recipient, as needed, to assist the individual with access to services.

Refer to Disability/Special Accommodation Review Form for additional information. 

Assistance from Third Parties

If an applicant or beneficiary requests the assistance of a third party, the third party assistance can be provided as a reasonable accommodation. However, staff cannot assume that every client with special needs has a third party individual who can assist them. It is important to remember limitations associated with third parties. Refer to Interpreter Services for additional information.

Sometimes it may be appropriate to provide referrals to other agencies for assistance. Referrals to another organization for assistance in, for example, in completing forms, is not a substitute for the SSA's responsibility to provide a reasonable accommodation.

Service Animals

Pursuant to ADA Title II, policies, practices and procedures must be modified to allow the use of service animals on the premises. Service animals are permitted in all areas of county facilities where members of the public or participants in services, programs, or activities are normally permitted. 

Only dogs are recognized as service animals under Title II of the ADA. Specifically, a service animal is defined as a dog that is individually trained to work or perform tasks for an individual with a disability. The work or tasks performed by a service animal must be directly related to the individual’s disability. 

Some examples of work or tasks performed by service animals include: 

• guiding people who are blind, 
• alerting people who are deaf to sounds or people, 
• pulling a wheelchair, assisting a person having a seizure, and 
• reminding an individual with mental illness to take medication 

A dog that provides only emotional support, comfort, or companionship does not qualify as a service animal. When it is not obvious what service a service animal provides, staff may ask only two questions:

1. Is the animal required because of a disability?
2. What work or tasks is the animal trained to perform?

Certification or other proof that an animal has been trained or licensed as a service animal is not required. Staff may only ask an individual to remove their service animal from the premises if:

• the animal is out of control and the handler does not take effective action to control it, or
• the animal is not housebroken.

If staff request that an individual’s service animal be removed on the basis of one of the above reasons, they must offer the person the opportunity to participate in the program, service, or activity without the animal’s presence.

Physical Facilities

In the event that structural modifications are required to provide program accessibility, the agency will conform to accessibility standards approved by the Office of the State Architect, pursuant to Title XXIV of the California Administrative Code. Where structural modifications are not practical, SSA will provide services at an alternate accessible site.

Staff may conduct home visits as part of the Intake business process when a face-to-face interview is required. Where appropriate, clients have option for applying on-line and contacting staff by phone as an alternative to coming to an office.

As part of the process for alternative site accommodations for Intake Process, the “Identification and Intake Record” (SCD 41) form, Part II is completed to indicate need for “Home Visit.”

All SSA office sites work to maintain compliance with relevant building codes and statutes.

Reasonable Accommodation Examples

The following examples illustrate how to assist with providing reasonable accommodations when it is determined that an individual is in need of additional assistance:

Example Example An individual walks in to the Agency’s lobby with required forms that are not filled out. The client states that it is difficult understanding the forms and requests a face-to-face interview to receive assistance with completing the forms. The worker will assist the client with understanding and completing the forms during a face-to-face interview. 

For various reasons, individuals with disabilities might not request special accommodations; however, staff must inquire of the need for such accommodations when the need is obvious or suspected, and if accepted, provide a reasonable accommodation. Staff should make it clear that people are not required to disclose whether they have a disability or what that disability is. When the need for a reasonable accommodation is obvious, staff should provide the reasonable accommodation without requesting documentation proving the need for one. 

Example Example An 85-year-old woman who appears to have a visual impairment and is walking with the help of a walker, comes in to the office to apply for assistance. Staff should ask what assistance she needs to expedite the application process. Examples of reasonable accommodations that staff can provide include assisting this woman so she does not have to wait in line, helping her complete her forms, and providing any other assistance deemed necessary and reasonable. 

Example Example A CalWORKs applicant with a disability of quadriplegia has his redetermination due this month. Due to his disability, he is unable to complete or sign the forms. His disability and need for a reasonable accommodation are recorded in the case record. The EW may conduct a home visit to ensure applicant meets all program requirements. A mark, name stamp, or verbal assent may be accepted in place of a signature. 

Example Example A General Assistance recipient fails to submit her periodic report or complete the Annual reinvestigation redetermination, and her benefits are going to be discontinued. After she receives her discontinuance notice, she calls to report that she was overwhelmed by the paperwork and forgot to turn it in. A “good cause” inquiry reveals the client has an anxiety disorder and a learning disability. The EW offers her an extension to finish the paperwork and ask if she needs help completing the forms. 

Special Accommodation Indicators & Documenting Accommodation

An individual’s need for a reasonable accommodation must be identifiable at the point of contact to ensures that staff offer and provide reasonable accommodations without the client having to re-request or the worker having to ask the client’s need for an accommodation again. This is done by selecting the appropriate Special Characteristics in CalWIN, and narrating the accommodation using Special Accomm/Sensitive Info Case Comments Type linked to the Special Accommodation (SA) indicators. Refer to “When there is no indicator associated to a SA or SI type, a gray color check mark displays on the window headers". 

When the indicator is entered in the Collect Special Characteristics Detail – Accommodation window, a yellow color yield sign indicator is displayed on the window headers (Case, Individual, Application and Contact windows). Refer to CATS Chewable Byte (CB 2016-8.0) for CalWIN illustration. 

Special Accommodation Indicator	Indicators Usage and/or Examples
Visual Accommodation	Requires large font or braille services
Audio Accommodation	Requires hearing devices and/or tape recorders, or is hearing impaired and needs other audio aid
Physical Accommodation	Physical Accommodation Special Indicator is selected along with narrating within the Special Accomm/Sensitive Info case comment type, “Client uses wheel chair and needs to be directed to the front of the line of wheel chair accessible booth.”
Literacy Accommodation	Used for cognitive, speech impediment, learning disability, requires reading out loud and/or repeating phrases; or due to inability to read/write in their primary language, needs an accommodation.
Language Accommodation	Used only when the client requires a special accommodation pertaining to the language. (see below)

Language Accommodation 

The Language Accommodation Special Indicator is used only when the client requires a special accommodation pertaining to language. The indicator is to be used to specify language codes that are general and not specific (i.e. “Other Chinese,” “Other Sign Language,” etc.). The special indicator is not used to indicate that the client speaks another language and should not be selected to indicate a client speaks another language (i.e. “Client speaks Vietnamese”). This information is captured by following CalWIN language coding procedures. 

ExampleExample

Example Example Client is deaf and uses a video phone that connects him to an interpreter he can sign to that will communicate with worker directly. The Language Accommodation Special Indicator is selected, along with narrating using Special Accomm/Sensitive Info case comment type: “Client is deaf and needs sign language interpretation services when he visits the office. When client calls our office he uses a video phone that connects him to an interpreter he can sign to that will communicate with worker directly.” 

Sensitive Information Indicators

Similar to how Special Accommodation Indicators are linked to Special Characteristics, Sensitive Information (SI) Indicators are used to help SSA staff identify other individuals with sensitive information. When the indicator is entered, a red color exclamation mark indicator is displayed on the window headers (Case, Individual, Application and Contact). The following are the SI indicators:

• Domestic Abuse
  • (Used to identify present victims and survivors of Domestic Abuse/Domestic Violence)
• Household Awareness
  • (Used to identify potentially disruptive individuals, or to become aware of other sensitive information about the case.)
• Mental Health Accommodation
  • (Indicator is associated with both Special Accommodation and Sensitive Information, to identify individuals requiring special accommodation, such as offering appropriate meeting rooms for clients sensitive to noises or other distractions)

Note: When there is no indicator associated to a SA or SI type, a gray color check mark displays on the window headers.

Documenting Accommodations

Staff must narrate the client’s accommodation, using Special Accomm/Sensitive Info Case Comments Type, in conjunction with using one or more of the Special Accommodation Indicators. All requests for a special accommodation must be documented in Case Comments, including:

• The fact that the individual has a disability and/or requested an accommodation;
• The accommodation(s) requested and 
• The accommodation) provided, 
• The specific accommodations provided, such as auxiliary aids, special language needs, and other services to meet the request; including any interactive process negotiations, and
• When selecting a Sensitive Information Indicator, document pertinent information.

If a specific accommodation requested cannot be granted document in Case Comments the interactive negotiation process and what accommodation was granted. 

If the accommodation request is not reasonable, the individual and Staff will discuss whether there is an alternative that would effectively address the individual’s disability-related need. This discussion will be a “good faith negotiation” to discuss alternative accommodations that would meet the needs of the person’s disability-related request.

Note: Under the ADA, in order to receive a reasonable accommodation, the client only needs to disclose that they are disabled; they are not required to disclose the specific disability. They only need to mention they need an accommodation. For example, they can say, “I have a disability that makes it hard for me to read small print.” They cannot be asked what the disabling condition is, whether dyslexia, a brain tumor or glaucoma, etc.

Example Example “Client reported that s/he has a [physical, mental, other] disability. S/he requested [some modification/extra help] as an accommodation, which was granted. Special indicator entered so that accommodation can be provided in the future.” 

[Refer to Common Place Handbook Chapter 36.2.13 Documentation for additional information regarding documentation.] 

Refer to Special Accommodation Indicators & Documenting Accommodation and Sensitive Information Indicators for entering Special Indicators in addition to documenting through Case Comment type.

Example Example An English speaking client discloses that due to illiteracy, he is not able to read forms and has difficulty listening when spoken to. The Literacy Accommodation Special Indicator is selected along with narrating within the Special Accomm/Sensitive Info case comment type, “Client is illiterate and staff needs to read forms and notices slowly to client.” 

Staff Training

The SSA will:

• Provide Civil Rights training, and assistance to staff to evaluate practices and policies in order to ensure that discrimination does not occur on the basis of disability. Reasonable Accommodations training is provided to public contact staff, program managers, and supervisors upon hire and, at minimum, annually thereafter to ensure compliance with disability nondiscrimination laws and on providing reasonable accommodations for persons with disabilities. 
• Ensure that each program is readily accessible to people with disabilities.

In choosing available methods for meeting the requirements of this section, the SSA will give priority to those methods that offer programs and activities to people with disabilities in the most integrated setting appropriate.

Reasonable Accommodations Poster

A Reasonable Accommodations poster titled “Need Help” is required to be displayed at office lobbies. The poster informs clients of their rights to notify county staff of a disability such as hearing or speaking impairment; difficulty walking, sitting, or standing for a long time; the need for a sign language interpreter; the need for information in Braille; assistance with completing a form or understanding complicated instructions. Staff is required to work with the client to find a way to help and accommodate the client. The contact information for the County’s SSA Civil Rights Coordinator is included within the reasonable accommodations office poster. The poster is also available in the DEBS Form’s Library. Refer to Section 504/ADA Coordinator (Civil Rights Coordinator) for additional information pertaining to role of coordinator.

In addition to the SCD 2372 poster, the “Your Rights Under California Welfare Programs” is required to be at office lobbies and included in Intake/RRR packets. Refer to Intake/RRR Packets for additional information.

Related Topics

Civil Rights Compliance/Complaints

California Relay Services (CRS)