County of San Diego Health and Human Services Agency HHSACalWORKs Program Guide Underpayment Number Page 44350K 1 of 3 Revision Date April 21 2020 BackgroundAn underpayment occurs when an Assistance Unit AU receives less than the amount to which they are entitled in a given month PurposeThe purpose of this material revision is to incorporate clarification in differentiating an underpayment from a supplemental payment and the guidelines for balancing these payments against an overpayment No policy changes PolicyInvestigation of Underpayments When there is a reason to suspect that an underpayment may have occurred the Eligibility Worker is to investigate and determine whether an underpayment did in fact occur All reasonable steps necessary must be taken to promptly correct any underpayment All underpayments must be corrected in accordance with the regulations in effect on the date of discovery There is no minimum underpayment correction amount as long as there is eligibility Correction of the Underpayment Case review recalculation and correction of any underpayments will be completed as soon as possible and no later than the following deadlines o The date of the next annual redetermination of eligibility or the date of termination whichever is earlier for all current customers o Sixty days from the date aid is granted for reapplications and requests for restoration of aid o Sixty days from the date of a request for review in all other cases Underpayments are corrected through retroactive payments based on SemiAnnual Reporting SAR CPG 44270 and Annual ReportingChild Only ARCO CPG 44260 rules If an AU has both an underpayment and an overpayment in the same benefit month the worker will offset one against the other before making a retroactive corrective payment o An adjustment must be made on CalWIN to change the claim balance owing to the new amount the worker will email Fiscal Benefit Recovery at HHSA BenRecovery when an adjustment is required on an existing claim balance and the worker is not processing the adjustment in CalWIN by running EDBC to regroup the claim balance For purposes of continued eligibility and the grant computation retroactive payments are not considered income or resource in the month of receipt or in the following month Payments are to be issued to correct underpayments even when the AU is not currently aided Edwards v McMahon final court order Supplemental Payment A supplemental payment is a payment issued to a customer for the current month when the worker has recalculated the current months cash grant as a result of a change in anticipated income and determined the customer is eligible for a larger aid payment amount than what was previously issued County of San Diego Health and Human Services Agency HHSACalWORKs Program Guide Underpayment Number Page 44350K 2 of 3 for the given month A supplemental payment is not considered an underpayment and as such is not subject to adjustment for any overpayment A supplemental payment which was correctly computed will not be subjected to an overpayment determination provided the customers report upon which the county based its determination was complete and accurate If there is a computational error the supplemental payment will be corrected Refer to the Voluntary MidPeriod Reporting section below for additional information Mandatory Inclusion An underpayment may only be issued for months in which all technical conditions of eligibility are met These are considered to have been met as of the date the mandatory person entered the AU provided The person is cooperating in meeting these conditions The caretaker relative fulfilled their reporting responsibilities in making a timely and accurate report of the change in AU composition Example If an additional person entered the home was not reported in a timely manner no underpayment exists Grant Adjustment Due to SAR 7 or SAWS 2 Plus If information reported on the SAR 7SAWS 2 Plus results in a grant increase and the worker cannot increase the grant by the first day of the month of the next payment period a supplement must be issued for that month and cash aid increased for the remaining months of that payment period A supplement will be provided for the month the decrease in income is reported or the month the change actually occurs whichever is later after all verification has been provided Voluntary MidPeriod Reporting A midperiod supplemental payment resulting from a voluntary midperiod report which was correctly computed based on a recalculation of reasonably anticipated income and or other changed AUs circumstances must not be considered an underpayment and cannot be used to offset balancing an overpayment Erroneous Denial Any underpayment which is due to the erroneous denial of an application for aid must be corrected even though the applicant failed to perform an act constituting a condition of eligibility when such failure was caused by the denial Acts include but are not limited to failing to furnish a Social Security Number failing to provide NonCitizen Sponsor information failing to assign support rights or failing to obtain unconditionally available income For the purpose of determining the beginning date of aid for correcting an underpayment which is due to the erroneous denial of an application refer to CPG 44300F Erroneous Denials When Not to Establish an Underpayment An underpayment does NOT occur in the following circumstances Failure to apply for or request aid including special needs such as the pregnancy special need County of San Diego Health and Human Services Agency HHSACalWORKs Program Guide Underpayment Number Page 44350K 3 of 3 When a change in circumstances occurs or actual income received is less than what was reasonable anticipated during the payment period and the AU did not voluntarily report the change in circumstances or the decrease of income during the payment period Actual verified income must not be used to reconcile against prospectively budgeted income that was used in the benefit calculation only income that was reasonably anticipated at the time benefits were initially calculated can be used Procedure When an underpayment has occurred correct the underpayment as follows Using the regulations in effect on the date of discovery calculate the correct grant for each month in question compare the correct grant to the amount actually paid to the AU for each month and if the amount paid to the AU is less than the correct grant for that month an underpayment exists Enter the new income in the Collect Income Received Detail or the Collect Unearned Income Detail window Add the person in the Collect Case Individual Detail window as appropriate Select the appropriate Use Effective Month UEM Run EDBC and evaluate cash benefits for the months affected on the Capture Discrepancy Information window References EAS 44340 44350 ACIN No I7219 Sunset Date This policy will be reviewed for continuance by April 30 2023 Approval for Release Rick Wanne Director Eligibility Operations