ACT 288-A (Interview Requirements and Child Tax Credit)
Action Change Transmittal Letter No. 288-A
October 21, 2021
TO: All Cash Assistance Manual Holders
FROM: Matt Damschroder, Director, Ohio Department of Job and Family Services
SUBJECT: Interview Requirements and Child Tax Credit
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Background:

On June 18, 2021, Director Damschroder issued a declaration of a continuing emergency due to COVID-19 and ordered the Ohio Department of Job and Family Services to continue taking all necessary actions to address the COVID-19 pandemic through the state of Ohio.

On October 1, 2020 the Continuing Appropriations Act, 2021, and Other Extensions Act became law and provided States with the option to adjust interview requirements without requiring waiver approval from the United States Department of Agriculture. Ohio implemented this option. 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, the American Rescue Plan Act of 2021 became law and contains changes regarding promoting economic security, specifically as it relates to the Child Tax Credit. Below is information on how this is to be treated for the Ohio Works First (OWF) and Refugee Cash Assistance (RCA) programs.

Updated Procedures:

Initial Application Interview

Effective October 1- December 31, 2021, as long as the federal public health emergency is in effect, 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

o   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.  

o   A county agency is required to contact the applicant if any information on the application is questionable.

o   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. Action Change Transmittal (ACT) No. 288 (9/24/21), incorrectly stated that the SSC or IOP may be completed and signed over the telephone through the state of emergency. ACT 288 has been rescinded. At this time, county agencies may accept an electronic signature for SSCs or IOPs, but can no longer accept a telephonic signature for these documents.

o   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

From October 1- December 31, 2021, as long as the federal public health emergency is in effect, 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.

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.

If the federal public health emergency ends prior to December 31, 2021, the above waivers are only effective until the end of the month subsequent to the month in which the Secretary of Health and Human Services lifts the emergency declaration.

Child Tax Credit

The American Rescue Plan Act of 2021 allows the Child Tax Credit to be issued in advance monthly payments to eligible families and these payments began in July 2021. The Child Tax Credit, whether received as an annual credit or in the form of advance payments, is excluded from consideration as income and as a resource for 12 months following receipt for OWF and RCA purposes.

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.