ACT 274 (Extending Certification Periods, Erroneous Payment Processing and Refugee Cash Assistance Extension)
Action Change Transmittal Letter No. 274
April 28, 2020
TO: All Cash Assistance Manual Holders
FROM: Kimberly Hall, Director Ohio Department of Job and Family Services
SUBJECT: Extending Certification Periods, Erroneous Payment Processing and Refugee Cash Assistance Extension

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.

On April 13, the United States Department of Agriculture, Food and Nutrition Services FNS (FNS), issued guidance allowing states to accept a blanket waiver for flexibilities in the time frame for establishing or disposing of new claims. Ohio has accepted part of the terms of the blanket waiver. Furthermore, on April 22, FNS issued guidance that recertification periods scheduled to expire in June can be extended six months to December.

To align policy between SNAP and the Ohio Works First (OWF) program, initial demand notices for newly established erroneous payment claims shall be delayed being sent to the individual until after May 31, 2020.  Additionally, certification periods for households receiving OWF, including child only assistance groups, will be extended.

Additionally, on April 22, 2020 the Administration of Children and Families, Office of Refugee Resettlement (ORR), released Policy Letter (PL) 20-03 providing states the waiver option to extend the Refugee Cash Assistance (RCA) eligibility period. Ohio has applied for and been approved for this waiver.

New Procedure: Effective immediately, the following changes apply:

Extending Certification Periods:

All OWF assistance groups due for recertification in June 2020 will have their certification periods extended through December 2020. Assistance groups will be notified that their certification date will be extended and that they do not have to reapply and participate in the interview until December 2020.

OWF Erroneous Payment Processing

Ohio Administrative Code 5101:1-23-70 (F) states, in part, that the county agency shall take action to recover erroneous payments in accordance rule and with provisions set forth in sections 5107.05 and 5107.76 of the Revised Code.

As a result of accepting the blanket waiver from FNS and to align OWF and SNAP policy, any erroneous payment claim established after the date this ACT is published shall not have an initial demand notice mailed to the individual until after May 31, 2020.

Refugee Cash Assistance

RCA provides time-limited cash assistance to refugees who are not eligible for OWF or Supplemental Security Income (SSI) if eligibility requirements are met. Ohio Administrative Code 5101:1-2-40.1 (C) states that the eligibility period for RCA begins with the refugee's entry date and ends the last day of the eighth month after the entry date. When the first eight months since the entry date have passed, the refugee is no longer eligible for RCA.

As a result of waiver approval from ORR, effective immediately through September 30, 2020 Ohio can extend the RCA eligibility period from 8 months up to 18 months for individuals who became eligible for RCA between April 1, 2019 and January 31, 2020. 

  • Individuals who became eligible for RCA between April 1, 2019 - September 30, 2019 have exhausted their 8 months of RCA eligibility. They must reapply and meet all eligibility requirements as outlined in rule 5101:1-2-40.1 of the Ohio Administrative Code (OAC). Their RCA benefits will be terminated as of September 30, 2020. 
  • Current RCA recipients who became eligible between October 1, 2019 -January 31, 2020 will have their eligibility period extended to September 30, 2020. They must continue to meet all eligibility requirements as outlined in rule 5101:1-2-40.1 of the OAC.
  • RCA recipients who became eligible for RCA on or after February 1, 2020, the eligibility period will remain at eight months. Additional months cannot extend beyond September 30, 2020.

Since this a very small population of individuals, a list will be sent to county agencies to run and extend the period with an override as well as document in journal notes.