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 authorized the
United States Department of Agriculture, Food and Nutrition Services (FNS) to
grant waivers to States to assist in managing the influx of applications. One
of these waivers was to extend recertifications occurring in March – June 2020
by six months. In order to align the SNAP and OWF programs, the same procedure around
extending certification periods was implemented for OWF through Action Change
Transmittal (ACT) No. 272 & 274.
While FNS is pushing States to return to “normal order,” it
recognizes the challenges States are facing in regard to the substantial
increase in recertifications. In response, FNS provided States with two new
waiver options, in addition to current state options and pre-pandemic waivers, States
were required to submit a transition plan to FNS identifying which options
and/or waivers they would be requesting to implement.
The Ohio Department of Job and Family Services (ODJFS) submitted
a transition plan and received approval from FNS to implement the state option
to stagger certification periods for cases recertified in October, November,
and December 2020. This will provide
county agencies with the ability to reduce the number of recertifications every
Fall and re-balance the number throughout the year.
New Procedure for October – December 2020:
Staggered Certification Periods
Ohio Administrative Code rule 5101:1-2-10 requires a recertification
of eligibility every twelve months. However, the rule also permits a shorter
certification period when the county agency determines the assistance group has
anticipated changes that would make them ineligible for cash assistance, such
as a migrant farm worker, or homeless individual. Under these circumstances,
county agencies have always been allowed to assign either a four-, five- or
six-month certification period consistent with their circumstances.
ODJFS is implementing the staggered certification option to
provide the county agencies with additional flexibility. County agencies can
choose to assign 6-month certification periods for assistance groups recertified
in October, November, and December 2020, who would normally be certified for 12
months under rule 5101:1-2-10. However, child only assistance groups are still
required to be assigned 24-month certification periods. When choosing to
implement this option, the county agency must use objective criteria for
selecting cases for a 6-month certification. Examples of objective criteria
include, but are not limited to:
- Cases that previously received a 6-month
recertification extension;
- Based on the last digit of the case number,
or using odd or even numbers;
- Based on the first letter of last names
(e.g. A-M).
Journal notes will need to document the certification period
assigned and criteria used to establish the certification period.
This staggered certification option is only available for
recertifications that occur in October, November and December 2020.