Background:

The Disability Financial Assistance Program (DFA) is a state and county-funded program which provides cash assistance to persons who meet DFA program requirements and who are ineligible for any financial assistance program supported in whole or in part by federal funds (e.g., Ohio Works First (OWF), Supplemental Social Security Income (SSI) or Social Security Disability Insurance (SSDI)).  No federal regulations govern the administration of the DFA program.  In accordance with Section 812.40 of the Ohio Revised Code, the DFA program is being repealed; State funding will no longer be available and the program will end effective December 31, 2017. 

New Policy:

 Effective July 1, 2017, the guidance provided below shall supersede any existing rule, policy guidance or training material issued by the Ohio Department of Job and Family Services (ODJFS). 

Any new application (or reapplications) for DFA received on or after July 1, 2017 must be denied.  A denial notice must be issued to the applicant. 

• Any DFA recipient who has a pending application for SSI or SSDI with the Social Security Administration, and who has ever received a denial of SSI or SSDI at the reconsideration appeal level on or before July 1, 2017 shall be terminated effective 7/31/2017 with prior notice of adverse action and fair hearing rights.
• Any DFA recipient who does not have a pending application for SSI or SSDI with the Social Security Administration, and who has ever received an initial denial of SSI or SSDI on or before July 1, 2017 shall be terminated effective July 31, 2017 with prior notice of adverse action and fair hearing rights.
• Any DFA recipient who receives a denial of SSI or SSDI at the reconsideration appeal level after July 1, 2017 shall be terminated with prior notice of adverse action and fair hearing rights.
• Any DFA recipient who does not have an application for SSI or SSDI pending with the Social Security Administration on or before September 30, 2017, shall be terminated with prior written notice of adverse action with fair hearing rights.
• Any DFA recipient still in receipt of benefits on December 1, 2017, shall be terminated effective December 31, 2017.  Recipients shall be provided prior written notice of the termination.

Implementation:

In order to ease the administrative burden to the county agencies, ODJFS has automated as much of the new policy requirements as possible.  However, some of the new requirements do not lend themselves to automation and will require action from the county agencies to terminate some DFA benefits and deny applications/reapplications.  Implementation of the new policy will take place in the following phased approach:

ODJFS Actions:

• On July 8, 2017, ODJFS will auto-terminate DFA recipients who meet the criteria for termination on July 31, 2017. 
• In early August 2017, ODJFS will mail a notice to all remaining DFA recipients informing them that if they do not currently have an application for SSI or SSDI pending, they must have one pending on or before September 30, 2017; and that the failure to do so will result in a termination of DFA.  The notice will also inform recipients that if their SSI or SSDI applications are denied at the reconsideration appeal level, they will be terminated from DFA.  Lastly, the notice will explain that the program will be ending on December 31, 2017, and no benefits will be issued after December 2017.
• Beginning in August 2017, ODJFS will provide county agencies with monthly reports that will identify DFA recipients who appear to have received a denial of SSI or SSDI at the reconsideration appeal level after July 1, 2017; and a one-time report in October, that will identify recipients who did not have an SSI or SSDI application pending on or before September 30, 2017. 
• On December 2, 2017, ODJFS will auto-terminate all remaining DFA recipients, effective December 31, 2017.  

County Agency Actions:

• The county agency shall accept DFA applications or reapplications received on or after July 1, 2017, then the application will be denied with a system-generated reason code of 523.  For applications pending on or before June 30, 2017, the county agency shall process the application in accordance with the pre-July 1 guidance and authorize benefits until they meet the new July 2017 termination criteria described above. The county agency must provide prior written notice of the termination and fair hearing rights.
• Beginning in August, when a monthly report from ODJFS indicates a recipient meets termination criteria for having received an SSI/SSDI application denial at reconsideration, the county agency shall confirm the denial at reconsideration on the CRISE screens “DESX” or “SVE1”, or by contacting SSA.  If confirmed, the county agency shall terminate the DFA with reason code 599 and provide prior written notice of the adverse action and fair hearing rights.
• In early October, when ODJFS sends a report indicating DFA recipients who do not have an SSI/SSDI application pending on or before September 30, 2017.  The county agency shall confirm there is no pending application on the CRISE screen “DESX” or by contacting SSA.   If confirmed, the county agency shall terminate DFA with reason code 500 and provide prior written notice of the adverse action and fair hearing rights.
• If after July 1, 2017, a DFA recipient has a continuing disability review (CDR) scheduled to be completed prior to December, the county agency shall not initiate or complete the CDR.  The recipient shall continue to receive DFA (without a CDR) until he or she is either denied at reapplication, or meets one of the new termination criteria.

Attached to this Letter is a Desk Guide for use by county agencies.