ACT 277 (Update to Face-to-Face Interview and Erroneous Payment Procedures- Timeframe Extended)
Action Change Transmittal Letter No. 277
July 28, 2020
TO: All Cash Assistance Manual Holders
FROM: Kimberly Hall, Director Ohio Department of Job and Family Services
SUBJECT: Update to Face-to-Face Interview and Erroneous Payment Procedures- Timeframe Extended

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.  Additionally, 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 to expand flexibility of programs to ease administrative burden 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) received various waiver approvals from the United States Department of Agriculture, Food and Nutrition Services (FNS). The waivers include: not requiring an interview to be conducted face-to face when this interview method is requested by the client; and delaying collection on newly established overpayments.  In order to align the SNAP and OWF programs, the same procedures for interviews and erroneous payments were implemented for OWF through Action Change Transmittal (ACT) No. 273 & 274. ODJFS must request an extension of the SNAP waivers month-to-month.

Update:

FNS has approved ODJFS to extend the SNAP waivers to not require an interview to be conducted face-to-face interview when this interview method is requested by the client and to delay sending initial demand notices on claims through August 31, 2020. To maintain program alignment, ODJFS will not require county agencies to conduct an interview face-to-face when this method is requested by the OWF clients/applicants and will delay the sending of initial demand notices for newly established erroneous payment claims until after August 31, 2020.

Face-to-Face Interview

Through August 31, 2020, a county agency is not required to conduct the interview face-to-face, even if the client/applicant requests this interview method.  If a face-to-face interview is requested, the county agency can schedule an interview to be conducted by telephone.

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 with 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 August 31, 2020.