June 15, 2010

CalWORKs Program Guide (CPG) Letter No. 207

 

Subject

REMINDER REGARDING ETHNIC AND RACE CIVIL RIGHTS DATA COLLECTION REQUIREMENTS

 

Reference

All County Letter 07-07, Final Rule on Civil Rights Data Collection; Special Notice 07-08, Final Rule on Civil Rights Data Collection; and recommendations from United States Department of Agriculture (USDA), Food and Nutrition Service (FNS), Supplemental Nutrition Assistance Program (SNAP) access review results received by San Diego County in April 2010. 

 

Effective Date

June 15, 2010

 

Purpose

The purpose of this letter is to remind staff of requirements regarding:

·        The collection of race and ethnic information when completing the SAWS 1 application, and

·        Updating Ethnicity and/or Race/Ethnic origin data, as needed, during the redetermination process, and

To outline related updates to the CalWORKs Program Guide (CPG).

 

Background

Strategic Planning and Operational Support (SPOS) previously issued CalWORKs Program Guide Special Notice 07-08, Final Rule on Civil Rights Data Collection, which provided implementation instructions on new racial, and ethnic data collection and reporting requirements.

 

The CalWIN system was updated with additional Ethnicity and Race/Ethnic Origin data collection questions in Release 15 to correspond to Question 10 on the SAWS 1.

 

Summary of Modifications
 

The following section has been modified and loaded to the CPG online.

 

CPG Section

Title

Program Updates/Changes

40-100.E

Application Process

Section entitled, “Guidelines for the Collection of Ethnicity and Race/Ethnic Origin Data,” added to provide related guidance.

 

Changes to the CPG are noted with highlighted text.

 

 

Guidelines for the Collection of Ethnicity and Race/Ethnic Origin Data

Federal and state laws require the collection of ethnic and racial data for Civil Rights purposes.  Workers are to observe the following guidelines regarding the collection of Ethnicity and Race/Ethnic Origin Data:

 

General Guidelines:

·        The applicant/recipient’s provision of ethnicity and race information is voluntary.

·        Self-identification is the preferred method of obtaining ethnic and racial data

·        All actions related to the collection of Ethnicity and Race/Ethnic Origin Data must be clearly documented in CalWIN Case Comments.

 

When Assisting Applicants With Completion of the SAWS 1:

·        The question regarding Hispanic or Latino ethnicity must be asked first, followed by race.

·        Clients who declare to be of multi-racial/ethnic origins, must have all of their races/ethnicities captured and reported.

 

If a Client Declines to Identify Ethnicity and/or Race/Ethnic Origin:

When a face-to-face interview is conducted and the applicant declines to identify his/her ethnicity and/or race, the worker must:

·        Inform client that workers are required to collect ethnic and race data through visual observation if a client declines to identify,  to encourage them to self-identify their race or ethnicity, and

·        Complete appropriate sections of the SAWS 1 (Question 10), using their best judgment and visual observation to identify which category best applies.

 

When visual observation is not possible, such as during a telephone interview, and the individual declines to report his or her ethnicity and/or race:

 

If…

Then…

Completing a manual SAWS 1 or entering data from a manual SAWS 1 into CalWIN

The corresponding sections of the manual SAWS1 (Question 10) should be left blank, and 

 

Data fields on the Collect Applicant Information window should be selected as:

o       “Unable to be determined,” for Ethnicity and/or

o       “No Response, Client Declined to State,” for Race/Ethnicity.

Completing a SAWS 1 in CalWIN

Data fields on the Collect Applicant Information window should be selected as:

o       “Unable to be determined,” for Ethnicity and/or

o       “No Response, Client Declined to State,” for Race/Ethnicity.

 

 

Scenario Examples:

·        The individual checks the box indicating she/he is Chinese and declines to complete the other ethnic or race data questions. The worker should inform the individual that the information is voluntary and the worker will use his/her best judgment to select the ethnicity and race that best applies. In this instance, the worker could reasonably assume that the individual is not of Hispanic or Latino ethnicity and unless otherwise indicated by visual observation, the individual’s race is most likely Asian.

 

·        The individual declines to state her/his ethnicity or race and the worker finds it difficult to visually determine the individual’s ethnicity or race. The worker should inform the individual that the information is voluntary and the worker will have to use his/her best judgment and select the ethnicity and race that best applies. The worker could examine the individual’s primary language and/or surname for clues to the individual’s ethnicity or race. Again, the worker is expected to use his/her best judgment to determine which ethnicity and race best applies to the individual.

 

 During the Redetermination Interview: 

·        Workers are to encourage clients to self-identify any missing  Ethnicity and/or Race/Ethnic origin data during the redetermination interview process

·        Updates to Ethnicity and/or Race/Ethnic origin data need to be entered in CalWIN on the Collect Individual Demographic Detail window for the appropriate individual(s)

·        Workers are to select, “Multi race/ethnic categories,” under the Race/Ethnic field, if a client declares to be of multi-racial/ethnic origins

·        Workers are to enter appropriate case comments, as needed, to clarify related data regarding Ethnicity and/or Race/Ethnic origin.    

 

 

Food Stamp Program Impact

 

Food Stamp Program has issued related instructions via Food Stamp Program Guide Special Notice 10-12, Food Stamp USDA Food and Nutrition Service (FNS) Review, which will subsequently be incorporated into the FSPG. 

 

Forms Impact

No forms impact.

 

Imaging Impact

No imaging impact as the SAWS 1 form is already included as a document to be imaged. 

 

Automation Impact

No automation impact. However staff can refer to the Change Highlights for CalWIN Release 15 (pages 30-34) for historical information and detailed instructions on entering ethnic and racial information in CalWIN.

 

ACCESS Impact

ACCESS Customer Service Agents may enter the updated data or corrections to Ethnicity and/or Race/Ethnic origin in the Collect Individual Demographic Detail window for the appropriate individuals, once the information is established by the caller. Appropriate case comments should be entered in CalWIN.

 

Operations Impact

No Operations impact

 

QA Impact

QA will cite the appropriate error when the regulations cited in the material have not been followed.

 

Assistant Deputy Director

 

Original CPG Letter No. 207 signed  June  09, 2010

 

 

 

Sylvia Melena

Assistant Deputy Director

Self-Sufficiency Programs

Strategic Planning & Operational Support

 

Manager Contact

CalWORKs Program