Background: On March 9, 2020 Governor Mike DeWine declared a state of emergency for the entire state of Ohio (Executive Order 2020-01D) to protect the well-being of the citizens of Ohio from COVID-19.  In order to protect the lives, safety and health of Ohio’s citizens, various orders have been issued from the Governor and the Ohio Department of Health to limit social interaction. These orders include: prohibiting mass gatherings (100 or more people in a single room); closing schools; prohibiting visitors in hospitals and jails; closing restaurants and bars; encouraging businesses to allow employees to work from home as well as asking parents to keep children out of day care settings. In addition to the state-declared state of emergency, on March 13, 2020, President Trump declared a national state of emergency due to the COVID-19 pandemic.

The Families First Coronavirus Response Act (Public Law 116-127) became law on March 18, 2020 and provided states the ability to seek waivers from the United States Department of Agriculture, Food and Nutrition Services (FNS), to expand flexibility of to ease administrative burdens of issuing Supplemental Nutrition Assistance Program (SNAP) benefits while under a state of emergency. As part of this effort, the Ohio Department of Job and Family Services (ODJFS) submitted a waiver and was approved to extend SNAP certification periods.

To align policy among SNAP and the Ohio Works First (OWF) programs, ODJFS will extend certification periods for households receiving OWF, including child only assistance groups.

Additionally, as part of this effort and to maintain compliance with Ohio Administrative Code rule 5101:1-3-15, which requires the JFS 03804 “Ohio Works First/Supplemental Nutrition Assistance Program (SNAP) Sanction Compliance Agreement” to be signed, ODJFS has established the following procedure for accepting verbal signatures over the telephone the JFS 03804 compliance form.

New Procedure: Effective immediately, the following changes apply:

Extending Certification Periods: 

• All assistance groups scheduled to expire in March 2020, who have not already been recertified for April 1, 2020, will have their certification periods extended through September 2020.

o   If the recertification process has not been completed in Ohio Benefits as of the date ODJFS runs the batch process, the assistance group will be notified that their certification date will be extended. No further recertification actions will be required by the household or county agency until September 2020.

o   If an assistance group has completed the recertification process in March 2020 and benefits have been approved beginning in April, the new certification period will remain and will not be changed to September 2020. 

• All assistance groups due for recertification in April 2020 will have their certification periods extended through October 2020.

o   Assistance groups will be notified that their certification date will be extended and they do not have to reapply and participate in the interview until October 2020. 

• All assistance groups due for recertification in May 2020 will have their certification periods extended through November 2020.

o   ODJFS will notice assistance groups that their certification date will be extended.

Accepting a Verbal Signature for the JFS 03804

While under the state of emergency declared through executive order 2020-01D, a county agency may opt to accept a verbal signature over the telephone for the JFS 03804 compliance form. During the telephone appraisal the county agency must read to the client the contents of the JFS 03804 compliance form. Following the verbal signature, a copy of the JFS 03804 compliance form must be mailed to the individual.

The county agency must record the following information in the case journal notes to document the verbal signature: “On [insert date] [Insert client name] provided a verbal signature to the JFS 03804 compliance form. This verbal signature is in accordance with Action Change Transmittal Letter No. 272.  A copy of the JFS 03804 compliance form has been mailed to the individual. ”