[NFBSF] DOR Interim Policy Regarding Use of Electronic Signatures

[Lisa Irving]

Hello All, 

 

I just received the official DOR interim policy for the use of electronic
signatures. Please share as deemed appropriate. 

 

Lisa M. Irving 

 

Interim Policy Memo

 

This memorandum serves to update the Interim Policy - Using Email for
Electronic Signatures (published April 16, 2020, and later revised on May 8,
2020).

 

Revisions to this policy are: (1) permitting use of email correspondence for
electronic signature for a consent to release or obtain personal information
(e.g., DR 260 Consent to Release and Obtain Information form); and (2)
referring Department of Rehabilitation (DOR) staff to separate, linked
supportive guidance.

Background

 

On March 4, 2020, Governor Newsom declared a State of Emergency and on March
19, 2020, Governor Newsom issued a Stay at Home order statewide and declared
government operations as essential. To further the purpose and intent of
these orders, DOR's electronic signature policy allows critical program
services and business operations to continue.

 

INTERIM Policy

 

Effective immediately, until further notice, DOR will accept email
correspondence as an acceptable means of electronic signature on all
internal and external documents for program areas, business services, and
administrative and accounting processes. Specifically, email correspondence
is considered an acceptable method for a signature received from program
recipients and participants, cooperative partners, service providers,
vendors, and DOR staff.

While DOR has established an email correspondence process as a method of
electronic signature, it is important to note that other parties involved in
a transaction must also agree to utilize the email correspondence protocol
(e.g., parties to a contract or an entity receiving an authorization to
release personal confidential information). As an example, due to the
signature requirements of the Social Security Administration, the DOR is
unable to process the SSA 3288 Social Security Administration - Consent for
Release of Information form, without a wet signature.

 

Additionally, wet signatures and / or DOR email correspondence protocol may
not meet the needs of some individuals with disabilities, and DOR staff, in
collaboration with the individuals, and their representatives as
appropriate, will explore alternatives to meet their reasonable
accommodation needs. These alternatives will need to be identified and
discussed with any third party associated with any specific document.

 

Procedures / Templates to Assist DOR Staff:

The following procedures and templates are being provided to DOR staff to
support the effective use of email correspondence as an electronic
signature, and encryption as necessary, applicable to both internal and
external documents:

*	Standardized Email Template to Attribute a Signature via Email
*	Procedure for Attaching Email to Record of Services in Aware
*	Procedure for Encrypting Emails with Sensitive Information

 

Resources

Applicants, consumers, and their representatives who have questions about
this policy may contact a local DOR office or their Rehabilitation
Counselor.

Staff members may direct inquiries to their Team Managers or District
Operations Support (DOS) Managers. Regional Directors, District
Administrators, DOS Managers, and Team Managers may direct policy questions
to program.policy at dor.ca.gov <mailto:program.policy at dor.ca.gov> .

 

Contract Administrators may contact the Cooperative Programs Section email
at cssinfo at dor.ca.gov <mailto:cssinfo at dor.ca.gov>  and Cooperative partners
may contact their assigned DOR Cooperative Program Specialist.

 

Community Rehabilitation Programs may contact the DOR Community Resources
Development Section at crdssinfo at dor.ca.gov <mailto:crdssinfo at dor.ca.gov>
or their assigned DOR CRD Specialist.

 

Contractors, vendors, and DOR staff with questions regarding contracts and
procurement, please email contractsinfo at dor.ca.gov
<mailto:contractsinfo at dor.ca.gov> .

For accounting questions, please email Accounting.Section at dor.ca.gov
<mailto:Accounting.Section at dor.ca.gov> .

 

Sarah Isaacs 
Associate Managing Attorney

(Pronouns: she, her, hers)

I include pronouns in an effort to share my commitment to transgender,
gender non-conforming, and non-binary inclusivity and visibility

 

Disability Rights California

Legal Advocacy Unit
1330 Broadway Street, Suite 500, Oakland, CA 94612

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