18.2.5 RCA RCA Financial Eligibility

In addition to meeting the RCA nonfinancial eligibility criteria, applicants must also meet financial eligibility criteria to be considered eligible for RCA. RCA financial eligibility testing consists of both an asset and an income test. As in the W-2 program, minor parents do not have to pass the asset and income tests. (See 3.1)

18.2.5.1.1 $2500 Gross Asset Test

At application, the RCA assistance group must have total countable assets that are less than or equal to $2,500, excluding any reception and placement assets provided by the Volag.

18.2.5.1.2 Asset Availability

Only assets that are actually available for use may be counted. An asset is considered “available” if the person has a legal interest in it and has the legal ability to make it available for support and maintenance. An asset is unavailable when the individual can reasonably document that it cannot be accessed for 31 or more days. A payment may not be counted as an asset and income in the same month. Count income in the month received and any amount remaining as an asset in the following month.

Note: Any assets remaining in the refugee’s country of origin are considered disregarded for RCA.

18.2.5.2.1 115% Gross Income Test

At application, the RCA assistance group must have total countable income that is less than or equal to 115% of the FPL for the size of the RCA assistance group.

18.2.5.2.2 Prospective Income Eligibility

Available earned and unearned income is tested prospectively for RCA eligibility. The FEP makes a best estimate to determine what income will be received by the participant each month.

18.2.5.2.3 Estimating Income

To get the best estimate of monthly earned income for employees paid an hourly rate, a FEP must use:

· (hourly rate) x (average hours per week) x (4.3 weeks per month) if paid on a weekly basis;

· (hourly rate) x (average hours biweekly) x (2.15 weeks per month) if paid on a biweekly basis;

· monthly amount if paid on a monthly basis (this includes self-employment and other averaged incomes); or

To get the best estimate of monthly unearned income for the RCA group, the FEP must use:

The prospective income estimate must not be changed due to missed work or irregular spikes in work hours. An RCA assistance group must be prospectively ineligible for two consecutive months before the case closes.

As in W-2, the RCA group’s income only affects eligibility and does not affect the amount of the RCA payment. The payment amount is a flat grant determined solely by the employment position in which the adult is participating.

18.2.5.2.4 Income Availability

As with assets, only income that is actually available for use may be counted. Income is considered available when the individual has a legal interest in it and has the legal ability to make it available for support or maintenance. Income is considered unavailable when the individual can reasonably document that it cannot be accessed for 31 or more days. Unavailability is usually documented by a letter from an agency or the source stating when the person will receive the income. Income is counted beginning in the first month it is received and thereafter. Until the amount and the payment date are known, the income must not be counted.

A payment received must not be counted as an asset and income in the same month. Current payments must be counted as income in the month received. Any amount remaining becomes an asset in the following month.

18.2.5.2.5 Fluctuating Income

If the amount of regularly-received income varies, the W-2 agency must use an average. Income that is received on an irregular basis must also be averaged over the period between payments. If neither the amount nor the frequency is consistent or predictable, the income may only be counted for the month in which it is received.

18.2.5.2.6 Prorating Income

Income received on a yearly basis or less often may be converted to a monthly amount. The agency may count only income that is predictable in amount and frequency, such as land contract income or income from a trust fund. Count the prorated income beginning in the month it is received.

18.2.5.2.7 Changing Estimated Income

Once determined eligible for RCA, if the RCA assistance group has income and it is expected to exceed the 115% gross income limit (see 18.2.5.2.1) for at least two consecutive months, the group becomes ineligible for RCA. Participants must report any change in earned or unearned income within 10 calendar days of the occurrence. (See 18.2.6.6) The FEP must redetermine the best estimate for income when any change in the income’s source, rate of pay, or payment schedule has been reported.

If earned income renders an assistance group ineligible for RCA before the 1st of the month prior to the final month of eligibility, then the grace period policy shall be applied. The grace period will give FEPs sufficient time to make an income availability determination and properly reduce or terminate cash benefits.

FEPs verify eligibility near the end of each time-eligible month before scheduled payments are issued. If an individual obtained employment during the previous month and is no longer financially eligibility for RCA, then a 30-day grace period clock will begin on the date on which an individual entered employment. One final payment will be issued for the upcoming month, which will be a partial payment accounting for the remaining days of the 30-day grace period, the first day of which is the day the refugee entered employment. Example 1 illustrates how the grace period policy should be applied in the instance that the individual is no longer financially eligible for RCA.

If an individual obtained employment totaling less than 30 hours per week, FEPs should continue to follow guidance from 7.4.1.4 (per 18.2.6.9) pertaining to Prorated CSJs. If the individual is determined to be eligible for a prorated CSJ, the grace period policy applies only to the month for which the full CSJ-level payment has already been issued. The prorated CSJ payment level must then be applied beginning the first of the month following the date on which the part-time employment began. Example 2 illustrates how the grace period policy should be applied to a prorated CSJ placement.

The grace period payments will be reported in a separate line item in SPARC, called RCA Incentive Payments. The line item code to be used for these payments is 0134A.Grace period payments should be recorded in SPARC in the month they are made. This may require making a report correction, which SPARC accountants can do upon request for up to 90 days after the end of the reporting month.

EXAMPLE 1: A refugee’s date of entry to the United States is 8/14/2022 and their twelve-month eligibility for Refugee Cash and Medical Assistance ends on 8/13/2023. The refugee is eligible for cash assistance and is placed into a CSJ payment level ($653/month). At the end of November, the FEP verifies the client’s ongoing eligibility before issuing the upcoming December payment and discovers that the refugee entered employment on November 20th and their earned income renders them financially ineligible for RCA. The FEP issues a final check for the remainder of the grace period, which will end on December 19th, in the amount of $400. The total RCA Incentive Payment to be reported in SPARC is $653, which was issued partially in November and partially in December.

EXAMPLE 2: A refugee’s date of entry to the United States is 9/10/2022 and their twelvemonth eligibility for Refugee Cash and Medical Assistance ends on 9/09/2023. The refugee is eligible for cash assistance and is placed into a CSJ payment level ($653/month). At the end of February, the FEP verifies the client’s ongoing eligibility before issuing the upcoming March payment and discovers that the refugee entered part-time employment on February 10th. Their earned income renders them eligible for a 1/3 CSJ payment of $218 per month. In this instance, the grace period policy applies to the time period during which they were no longer eligible for the full CSJ, beginning on the day they entered employment and ending at the end of that month. The FEP issues a $218 check for the month of March. The total RCA Incentive Payment to be reported in SPARC is $280, which is the difference between 18 days of a full CSJ payment ($420) and 18 days of a 1/3 CSJ payment ($140). The remaining partial payments are not considered an RCA Incentive Payment.

18.2.5.2.8 Counting Income

All earned and unearned income of all RCA assistance group members is counted in determining the 115% gross income test (see 18.2.5.2.1) unless specifically disregarded. See 3.2.8 for a list of income that should be disregarded.

In some cases, the husband and wife in an RCA assistance roup may have different arrival dates. In such a case, consider any applicable income of the first-arrived spouse (such as employment earnings) when determining RCA eligibility for the group based on entry of the newly-arrived spouse. In these cases, the assistance group would remain eligible for RCA through the end of the newly arrived spouse’s 8 month RCA eligibility period. (See 18.2.4.2)

18.2.5.2.8.1 Deeming

United States Citizenship and Immigration Services (USCIS) requires certain individuals who are admitted as permanent resident aliens to have a sponsor sign an affidavit of support to ensure that the immigrant does not become a public charge. In these cases, the sponsor’s income may be counted or “deemed” to be available to the sponsored alien when determining financial eligibility for W-2 or other public benefits.

Refugees’ relationship to sponsors, however, differs from the relationship described above. A refugee is typically “sponsored” by a Volag , whose role is to help the refugee effectively settle into their new community and become socially and economically self-sufficient. In some cases a refugee may also be “sponsored” by individuals or groups in the community (such as church groups), and may be given additional help by friends or relatives (often themselves refugees) who are more acclimated to the community. These agency and individual sponsors DO NOT meet the USCIS definition of a sponsor because they do not have legal obligations to provide financial support to the refugee. W-2 agencies should not, therefore, deem a sponsor’s income for any of the groups listed with refugee status even if they obtain permanent resident status.

EXAMPLE: A single female refugee arrives to the U.S. on 3/1/2012 and is assigned to the local Volag. The woman has relatives in the community who arrived as refugees two years ago, and are able to further help her with her integration into American life. When determining RCA financial eligibility, the income of the woman’s relatives should not be counted.

If a refugee has a sponsor (other than a Volag) from whom they are receiving direct income, count the amount of income actually received by the refugee from the sponsor.

18.2.5.2.8.2 Self-Employment Income

If a refugee begins to receive self-employment income, the W-2 agency must count the gross receipts from the self-employment business. As in W-2, gross receipts must not be adjusted based on expenses. If IRS tax forms were completed for the previous year, use these forms to calculate the self-employment income. RCA’s twelve-month time period, however, means that IRS tax forms from the previous year may not be available. In such cases, calculate the income using average monthly anticipated earnings.

18.2.5.2.8.3 Census Employment and Other Temporary Employment Income

Income from temporary employment, including employment as a census enumerator, is counted when determining RCA financial eligibility.

18.2.5.2.9 Disregarded Income

All earned and unearned income of all RCA assistance group members is counted in determining the 115% gross income test (see 18.2.5.2.1) with the exception of the income listed in 3.2.8.1.

18.2.5 RCA Financial Eligibility