ACT 281 (Interview Requirements, Extending Certification Periods and Refugee Cash Assistance Update)
Action Change Transmittal Letter No. 281
October 14, 2020
TO: All Cash Assistance Manual Holders
FROM: Kimberly Hall, Director Ohio Department of Job and Family Services
SUBJECT: Interview Requirements, Extending Certification Periods and Refugee Cash Assistance Update

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.

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 the administrative burden of issuing Supplemental Nutrition Assistance Program (SNAP) benefits while under a state of emergency.

On October 1, 2020 the Continuing Appropriations Act, 2021, and Other Extensions Act became law and provides States with the option to extend recertifications by six months, and to adjust interview requirements without requiring waiver approval from the United States Department of Agriculture. Ohio is implementing these options. To align procedures among SNAP, Ohio Works First (OWF) and Refugee Cash Assistance (RCA) programs, the Ohio Department of Job and Family Services (ODJFS) has outlined the procedures below.

Additionally, on September 30, 2020 the Administration of Children and Families, Office of Refugee Resettlement (ORR), released Policy Letter (PL) 20-06 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 Procedures:

Initial Application Interview

Effective immediately through December 31, 2020, a county agency can opt to not conduct an interview at application prior to approving OWF or RCA benefits, provided the following are met:

  • The applicant’s identity has been verified;
  • All other verifications required to establish eligibility as outlined in rule 5101:1-2-20 of the Ohio Administrative Code (OAC) have been completed. (i.e. income, social security numbers, age, citizenship, living arrangement, etc.); and
    • A county agency shall obtain documentary verifications (including electronic sources); if documentation is not able to be obtained, the county agency may use a collateral contact. If neither documentation nor collateral contact can be obtained, client statement may be used. Case notes must clearly document the verification used to make an eligibility determination.
    • A county agency is required to contact the applicant if any information on the application is questionable.
    • When a county agency is unable to contact the applicant, it shall schedule a telephone interview and send notice of the appointment to the applicant. The scheduled interview establishes a means of contact with the applicant to gather missing information not included in the application. If there is no contact with the applicant at the scheduled appointment time, and the applicant does not request to reschedule, the application shall be denied.
  • For all work eligible individuals, an appraisal is conducted and a self-sufficiency contract (SSC) or individual opportunity plan (IOP) must be completed and signed prior to authorization. As outlined in Action Change Transmittal (ACT) No. 271 (03/17/2020), the SSC or IOP may be completed and signed over the telephone.
    • As part of the appraisal process, the county agency must screen for domestic violence and refer any individual who responds affirmatively to a screening question to counseling and supportive services as outlined in rule 5101:1-3-20 of the OAC.

A county will need to inform Program Policy Services if it will implement this option, and for which months, by sending an email to TANF-FSTA@jfs.ohio.gov.

Face-to-Face Interview Method

Through December 31, 2020, when a county agency is conducting an interview, it is not required to conduct a face-to-face interview when an applicant requests this method. If a face-to-face interview is requested, the county agency can schedule it to be conducted by telephone. The client will be serviced through other available options during the pandemic.

Extending Certification Periods

All assistance groups scheduled to expire in November and December 2020, who have not previously received a 6-month extension of their certification period, will have their certification periods extended through May and June 2021 respectively. 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 May or June 2021. These updates will be made in Ohio Benefits accordingly.

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 January 31, 2021 Ohio can extend the RCA eligibility period for individuals who became eligible for RCA between April 1, 2019 and May 31, 2020.

  • Individuals who became eligible for RCA between April 1, 2019 - February 28, 2020 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 January 31, 2021.
  • Current RCA recipients who became eligible between March 1, 2020-May 31, 2020 will have their eligibility period extended to January 31, 2021. 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 June 1, 2020, the eligibility period will remain at eight months. Additional months cannot extend beyond January 31, 2021.

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.

If you have questions regarding any of the information please reach out to Program Policy Services by sending an email to TANF-FSTA@jfs.ohio.gov.