BILL ANALYSIS                                                                                                                                                                                                    Ó




                   Senate Appropriations Committee Fiscal Summary
                            Senator Kevin de León, Chair


          SB 999 (Liu) - CalFresh: Community College Student Eligibility
          
          Amended: May 7, 2014            Policy Vote: Education 9-0
          Urgency: No                     Mandate: Yes
          Hearing Date: May 19, 2014      Consultant: Jacqueline  
          Wong-Hernandez
          
          This bill meets the criteria for referral to the Suspense File. 

          
          Bill Summary: This bill requires the California Community  
          Colleges (CCC) Chancellor's Office and the Department of Social  
          Services (DSS) to establish detailed guidelines identifying  
          categories of students that may qualify for federal exemptions  
          that would allow them to receive CalFresh benefits, and  
          recommends that the California State University (CSU)  
          Chancellor's office, and the University of California (UC)  
          President's office do the same. This bill requires CCCs to  
          provide specific documentation to students who may qualify for  
          an exemption. This bill authorizes a county that elects to  
          participate in the CalFresh Employment and Training (E&T)  
          program to enter into an agreement with a CCC or a CSU campus to  
          establish an E&T program, as specified. 

          Fiscal Impact: 
              Develop guidelines: Potentially significant costs to the  
              CCC Chancellor's office and the DSS to analyze and interpret  
              federal regulations, and collaboratively develop detailed  
              guidelines, as required. Significant cost pressure to  
              "recommend" that the CSU Chancellor's office and the UC  
              President's office do the same.
              Documentation: Potentially substantial new reimbursable  
              state mandate on CCCs to provide specified documentation  
              upon request. Statewide, potential costs in the hundreds of  
              thousands of dollars. 
              CalFresh E&T program: Potentially significant cost pressure  
              to establish E&T programs.

          Background: Federal law establishes the Supplemental Nutrition  
          Assistance Program (SNAP) for the purpose of promoting the  
          general welfare and to safeguard the health and well-being of  
          the nation's population by raising the levels of nutrition among  








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          low-income households.  (Code of Federal Regulations, Title 7, §  
          271.1) 

          State law establishes the CalFresh program to administer the  
          provision of federal SNAP benefits to families and individuals  
          meeting the eligibility criteria.  
          (Welfare and Institutions Code § 18900-18927)

          Federal requirements prohibit an individual who is enrolled at  
          least half-time in an institution of higher education from SNAP  
          eligibility, unless the student qualifies for one of the  
          following exemptions:

                  a)        Be younger than age 17 or older than 50.

                  b)        Be physically or mentally unfit.

                  c)        Be receiving TANF (or CalWORKs) benefits.

                  d)        Be enrolled in school as a result of  
                    participation in the Job Opportunities and Basic  
                    Skills program, as specified.

                  e)        Be employed for a minimum of 20 hours per  
                    week, as specified;

                  f)        Be participating in a state or federally  
                    financed work study program during the regular school  
                    year, as specified.

                  g)        Be participating in an on-the-job training  
                    program, as specified.

                  h)        Be responsible for the care of a dependent  
                    household member under the age of 6.

                  i)        Be responsible for the care of a dependent  
                    household member who has reached age 6-12 when the DSS  
                    has determined that adequate child care is not  
                    available to enable the student to attend class and  
                    comply with the work requirements of items (e) or (f).

                  j)        Be a single parent enrolled in an institution  
                    of higher education on a full-time basis and be  








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                    responsible for the care of a dependent child under  
                    age 12, as specified.

                  aa)       Be assigned to or placed in an institution of  
                    higher education through a federally identified  
                    program, as specified. (CFR, Title 7, § 273.5)

          State law established the CalFresh E&T program for  
          non-assistance CalFresh recipients. Non-assistance recipients  
          are people who receive CalFresh benefits each month, but do not  
          receive a cash grant under the CalWORKs program. CalFresh E&T  
          assists members of CalFresh households in gaining skills,  
          training, work, or experience that will increase their ability  
          to obtain regular employment. (WIC § 18926.5.)

          State law provides funding for CCCs with students who are  
          enrolled in the CalWORKs program, for the purpose of designing  
          specific curriculum offerings, and creating work experience and  
          internships, among other specifics. (Education Code § 79202 and  
          § 79203) 

          Proposed Law: SB 999 requires the CCC Chancellor's Office and  
          the DSS to examine and interpret federal regulations, and create  
          detailed guidelines identifying categories of students that may  
          qualify for federal exemptions that would allow them to receive  
          CalFresh benefits. This bill "recommends" that the CSU  
          Chancellor's office, and the UC President's office also examine  
          and interpret federal regulations, and create detailed  
          guidelines identifying categories of students that may qualify  
          for federal exemptions that would allow them to receive CalFresh  
          benefits.

          This bill requires CCCs to provide related "documentation" to  
          students who may qualify for an exemption when they create their  
          education plans, as specified. 

          This bill authorizes a county that elects to participate in the  
          CalFresh E&T program to enter into an agreement with a CCC or a  
          CSU campus to establish an E&T program, as specified. It also  
          authorizes the CCC Board of Governors to enter into an  
          interagency agreement with the DSS to establish an E&T program,  
          as specified.

          Staff Comments: The costs of this bill are unclear, because its  








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          vague language makes the requirements on state and local  
          entities ambiguous. 

          This bill requires the CCC Chancellor's office and the DSS to  
          work together to examine and interpret federal regulations and  
          determine "categories" of CCC students who might be eligible for  
          CalFresh benefits through a federal exemption. The Chancellor's  
          office and DSS must then "establish clear and detailed  
          guidelines identifying the categories of students who may  
          qualify for an exemption and the programs in which enrollment  
          may qualify a student for an exemption." The term "category" is  
          not defined in the bill, and the requirement implies that it  
          could include anything from special program enrollments to  
          demographic and socioeconomic information. This bill also  
          recommends that the CSU Chancellor's office, and the UC  
          President's office examine and interpret federal regulations and  
          determine "categories" of students who may be eligible for an  
          exemption; this creates cost pressure for those segments to  
          undertake the activities.

          This bill mandates that once the CCC student categories are  
          identified, a CCC "shall provide documentation to each student  
          identified pursuant to Section 79220 as qualifying for an  
          exemption to the prohibition on student eligibility for CalFresh  
          benefits? at the time that the student develops an education  
          plan, as required by Section 78215, and at any other time a  
          student requests that documentation." This requirement seems to  
          imply that the CCCs are supposed to identify specific students  
          who could qualify for an exemption, and provide them  
          documentation. It is unclear whether the CCCs are to provide  
          documentation that informs students of their possible  
          eligibility for CalFresh benefits, or whether they are to  
          provide documentation that would "prove" that the student is  
          eligible (to the satisfaction of county welfare agencies). The  
          bill sponsor has indicated that the intention is the latter, but  
          the language of the bill leaves the requirement (and, thus, the  
          reimbursable mandate) open to interpretation. Whatever the  
          documentation is, the requirement for CCCs to provide it to  
          every student identified as categorically eligible during their  
          education plan development and upon any request from the  
          student, will be a new reimbursable state mandate on CCCs.

          To the extent that providing information and documentation to  
          certain students results in those students accessing Cal Fresh  








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          benefits, CalFresh administrative costs (which are normally  
          shared 50% federal, 35% state, and 15% county) could increase.  
          Additional administrative costs would increase commensurate with  
          the participating caseload and ratio of new to existing  
          households receiving benefits. Additional costs to the state  
          would also be partially offset by a likely increase in sales tax  
          revenue. Studies show that low-income families spend a  
          significant portion of their money on food, and increasing  
          CalFresh access would allow them to spend that money on taxable  
          items. 

          This bill authorizes a county that elects to participate in the  
          CalFresh E&T program to enter into an agreement with a CCC or a  
          CSU campus to establish an E&T program. Nothing currently  
          prevents CCCs or CSUs from entering into these agreements;  
          specifically authorizing the agreements in statute creates cost  
          pressure to enter into them.