Application Project Background

In October 2003, the Food and Nutrition Service awarded Ohio a grant that provided an opportunity to work with the Kleimann Communication Group (KCG) for technical assistance and mentoring on redesigning and reorganizing Ohio's combined application. KCG is an established Washington, D.C. firm that has experience in providing research-based assistance to agencies that want to improve their communication with the public.

KCG is currently working with eight new states to improve their application. The goal of the project is to make sure eligible applicants get the benefits to which they are entitled. KCG's contribution to the goal is to make sure that application forms are not a barrier to the applicants.

Workgroup

A workgroup was formed consisting of county representatives and cash assistance, food stamp assistance, and medical assistance policy staff. The workgroup made a decision to revise the JFS 07200, "Request for Cash, Medical and Food Stamp Assistance," and to eliminate the JFS 07100, "Application for Income, Medicaid, and Food Assistance." The revised JFS 07200 will be the only application utilized for cash programs and the Food Stamp program. The newly developed JFS 01846, "Case Worksheet -Cash, Food Stamp, and Medical Assistance Interview," will be used by the county agencies to capture additional data needed when CRIS-E is unavailable, for off- site interviews such as home visit, and telephone interviews when applicable. The newly developed "Eligibility Information Worksheet/ Nursing Home and Community Based Services Waiver" will be used by the county agencies as appropriate for nursing home and HCBS situations.

Over the past several months KCG has provided technical assistance through forms design training, expert reviews of the JFS 07200 drafts, and ongoing assistance and advice on such things as readability, font styles, and applying emphasis techniques. The workgroup conducted a needs analysis of the application users, context, purpose, issues, and political implications to develop the revised application.

Feedback

The workgroup met with several community partners and county agencies to receive input on the revised JFS 07200, the new JFS 01846, and the new nursing home and HCBS worksheet. Some of the suggestions included addressing citizenship eligibility, listing required verifications by program, and specifying other available services. Modifications were made to the forms based upon their suggestions/input.

Testing

KCG provided training to the workgroup on conducting a usability test for the application. Usability testing tries out a document in a real world scenario. Applicants are encouraged to act as they would if they were sitting in the lobby filling out the application or if they were at home filling it out. A moderator conducts the interview while a note taker records observations and comments from applicants. Usability testing starts with a think-aloud protocol, which is an unstructured review of the form by the applicants. Applicants go through the form and attempt to fill it out, speaking aloud as they go through the form. The note taker records areas of confusion or questions the applicant has and any areas the applicant skips. After the applicant has gone through the form on their own, the moderator asks structured questions that have been decided on in advance.

The workgroup in conjunction with KCG tested the JFS 07200 with applicants. Based on the testing we found that the applicants felt "comfortable" to "very comfortable" with the way information as presented in the form, the application provided the right information for them, the application was "simple" and written at the right level for most people to understand. In addition, the applicants indicated a number of other things they liked about the application such as the application's colors, simplicity, and overall tone. One applicant appreciated that it "wasn't condescending." Further, the use of sections and clear headings was mentioned numerous times by applicants. There was no problem with securing signatures from applicants. The overall feedback was favorable and modifications were made to the JFS 07200 based upon the testing results.

Implementation

The rules included in this FSTL/CAMTL have been modified to update language to the revised JFS 07200,the new JFS 01846, and the elimination of the JFS 07100. These rules are proposed to be effective May 1, 2005. If no revisions are made to the proposed rules prior to the finalization by JCARR, they will become effective on a permanent basis on May 1, 2005. If changes are necessary, a copy of the revised rules will be forwarded to you at that time.

Description of the revised "Request for Cash, Food Stamp, and Medical Assistance," JFS 07200:

The JFS 07200 name has been changed to "Request for Cash, Food Stamp, and Medical Assistance." The purpose of the JFS 07200 is to obtain basic information and to screen for expedited food stamps in order to avoid collecting duplicate information gathered in the interactive interview. The JFS 07200 consists of a two-page coversheet (front and back) and a four page application. The applicant keeps the two page cover sheet for their records.

Application Coversheet

The county agency is to complete the top portion of the coversheet in the shaded area to list the appointment date and time of the interview. The coversheet is designed to provide information to the applicant regarding the following application procedures:

• How to apply for assistance.
• How to obtain help completing the application if English is not their primary language, if they are hearing impaired, or have a disability.
• How to complete the application, what to do if they cannot fill out the application the same day, and the procedures for applying for someone else.
• Where to turn in the application and that county agencies offer evening and/or weekend hours (reference Code of Federal Regulations (CFR) section 273.2 (e)(3) and Ohio Revised Code (ORC) section 329.023 for hours of operation).
• How to complete the face-to-face interview and what to do if they cannot come in for the interview.
• Types of verification needed for cash assistance, food stamps, and health coverage.
• The timelines for processing the application by program.
• What to do if they need food right away.
• Information on citizenship guidelines to let the applicant know that they should not let fear of the U.S. Citizenship and Immigration Services (USCIS), formerly known as the Immigration Naturalization Services (INS), deter them from seeking needed assistance for their family.
• List of other available services such as child care assistance, prenatal care, housing costs, work skills and help getting a job. If they need help with day care costs, they are to contact their local CDJFS for a child care application.

Page One of the Application

The first page of the application provides instructions informing the applicant to complete sections one and two for the person for whom they are applying and section three is to be completed by the authorized representative.

A shaded box is located in the first section for county agency use to record information such as the date received, application and case number, and if they are applying for expedited food stamps, Prevention Retention and Contingency (PRC), and/or child care.

The following information is provided on page one:

• Section one of the application provides information about the applicant such as name, if the individual has special needs, and if they have ever received cash, food stamp, or medical assistance.
• Section two provides information on how to reach the applicant and includes a space for an e-mail address.
• Section three provides information about the authorized representative.
• Section four is for the signature of the applicant/authorized representative.

CFR section 273.2 (b)(iv), OAC rule 5101:4-2-01, requires a place on the front page of the application where the applicant can write his/her name, address, and signature.

Page Two of the Application

• Section five is for applicants who need food stamp assistance right away and is used to screen for expedited food stamp assistance (reference rule 5101:4-6-09).
• Section six provides information about the people living with the applicant to assist the CDJFS in accomplishing the screening process. In addition, this section is used to determine if the applicant is applying for or in need of nursing home/in-home care.

Page Three of the Application

• Section six (continued) will determine if the household member(s) over age 60 and who are disabled are able to receive food stamp assistance separately from other members of the assistance group.
• Section seven provides information about the household's finances such as employment status, income, and resources.
• Section eight provides information about the household's expenses such as day care costs for a child or other dependents, child support payments, medical expenses for anyone who is disabled or age 60 or older, rent/mortgage payments, and utility payments.

Page Four of the Application

• Section nine contains a statement to be signed by the applicant or authorized representative which certifies, under penalty of perjury, the truth of the information contained in the application, including the information concerning citizenship and alien status of the members applying for assistance.
• Section ten informs the applicant that they are to return the application to their local CDJFS office. A space is available for the county agency to provide their information such as an address and/or telephone number.
• The last section provides a civil rights description and how to file a discrimination complaint.

Description of the new "Case Worksheet -Cash, Food Stamp, and Medical Assistance Interview," JFS 01846:

The JFS 01846, "Case Worksheet -Cash, Food Stamp, and Medical Assistance Interview," is designed as a tool for the county agencies to use when CRIS-E is unavailable, for off-site interviews such as home visits, and telephone interviews when applicable. This form shall not be used by applicants/recipients. The form has been designed to mimic the CRIS-E screens to aid in the interview process and data entry. County agencies shall use the JFS 01846 as a guide for the interview and the applicant/recipient must sign the completed worksheet to attest that the information is correct.

Description of the new "Eligibility Information Worksheet / Nursing Home and Community Based Services Waiver"

The Eligibility Information Worksheet will be used by nursing home and HCBS workers as appropriate. This worksheet will be issued under separate cover by Ohio Health Plans.

Description of the revised "Your Rights and Responsibilities," JFS 07501:

The JFS 07501 "Your Rights and Responsibilities" has been formatted to resemble the style of the revised JFS 07200. A new paragraph on " Religious Agencies" has been added to the JFS 07501. This paragraph was developed in response to a new federal regulation commonly referred to as "Charitable Choice". Charitable choice encourages states to involve faith-based organizations in providing federally funded TANF benefits and services to eligible families. The CDJFS may have agreements with faith-based agencies to provide services to families who may be receiving PRC or act as work sites to families receiving OWF. The paragraph is designed to inform an assistance group member that he or she may elect to receive services or participate at a work site that is not faith-based and the CDJFS must provide another comparable agency as the work site or as the provider of services.

OWF cases are now subject to the state quality control review. Failure of the assistance group member to cooperate in the process could result in ineligibility for OWF for up to 3 payment months. This language has been added to the "Quality Control Review" paragraph on the JFS 07501. This penalty has been added to rule 5101:1-3-15.

Reproduction/Translation

The JFS 07100 is obsolete. The JFS 07200 and JFS 07501 will continue to be stored in the warehouse for ordering. The new JFS 01846 and the nursing home and HCBS worksheet will not be stored in the warehouse and will be available online to be reproduced by the county agencies.

The JFS 07200, and JFS 07501 will be translated as soon as possible following the publication of this FSTL/CAMTL. We will issue a CRIS-E view flash bulletin once the translated forms are available on the ODJFS internet and innerweb.

Food Stamp Certification Handbook Changes:

Rules 5101:4-1-03 and 5101:4-7-07 were reviewed in accordance with the Ohio Revised Code Section 119.032. Each state agency is required to review its rules a minimum of once every five years. The intent of the law is to ensure that rules are clearly written and that program requirements are accurate, up-to-date, and clearly expressed. To the extent possible, unnecessary paperwork will be eliminated and local agencies will be given increased flexibility. The purpose of a rule review is to determine whether a rule should be continued without amendment, be amended, or be rescinded, taking into consideration each rule's scope and purpose. Following are summaries of the proposed changes to these rules.

5101:4-1-03 - Food Stamps: definitions.

This rule was updated with current definitions to the JFS 07200 and the JFS 01846. There were seven definitions that were deleted as being obsolete. Other definitions were updated with correct terminology.

5101:4-2-01 - Food Stamps: application process.

The references to CAF and JFS 07100 were stricken. References to the JFS 01846 were inserted where appropriate. The references to a form number or abbreviated word were spelled out with the first reference in each rule.

5101:4-6-19 - Food Stamps: determining eligibility of supplemental security income (SSI) assistance groups (AGs).

The references to CAF and JFS 07100 were stricken. References to the JFS 01846 were inserted where appropriate. The references to a form number or abbreviated word were spelled out with the first reference in each rule.

5101:4-7-07 - Food Stamps: reapplication.

References to the JFS 07100 were stricken. References to the JFS 01846 were inserted where appropriate. Abbreviated words were spelled out the first time they were referred to in the rule.

Application Situations for Food Stamp Programs.

A new chart was added to the Appendix of the following rules: 5101:4-2-01, 5101:4-6-19 and 5101:4-7-07. The chart covers the application situations for use of the JFS 07200 and the JFS 01846.

Cash Assistance Manual Changes:

This letter transmits changes with the proposed effective date of May 1, 2005. If there are any changes made to the rules contained in this CAMTL during the JCARR review period, corrected rules will be sent out in the next CAMTL. This cover letter includes a summary statement of the policy changes. The clearance control number (CCN) assigned when the policy changes were placed in the clearance process is included for reference. The clearance control number is 5360.

Section 119.032 of the Revised Code requires a review of all state agency rules within a five-year period. The purpose of this review is to determine whether a rule should continue without amendment, amended or rescinded, taking into consideration the rule's purpose and scope. In addition, the intent of the review is to ensure that rules are clear and concise as written, program requirements are accurate and up-to-date, unnecessary paperwork eliminated, and when possible, local agencies given more flexibility.

Based upon the amount of changes and reformatting of the processing rules we determined that the existing rules 5101:1-2-01 and 5101:1-2-10 should be rescinded and replaced with new rules 5101:1-2-01 and 5101:1-2-10. Following are summaries of the proposed changes to these rules.

Chapter 1000

Rule 5101:1-2-01 The application process for Ohio works first (OWF), disability financial assistance (DFA) and refugee cash assistance (RCA).

This rule was reformatted to combine within one rule all application processing language. This reorganization will facilitate reference to the rule and does not substantively change most of the current policy with the exceptions noted below:

The JFS 07200 was revised and is now the only application used for OWF, DFA and RCA. The CAF/JFS 07100 will no longer be used for cash programs and all references to it have been removed. The new worksheet JFS 01846 will be used to capture data needed during home visits or when CRIS-E is unavailable.

Obsolete forms and forms not mandated have been removed from the items to be included in the application packet. This change is reflected in paragraph (C) of the rule.

Language regarding applications submitted electronically has been added to paragraph (H) (9) of the rule.

The interview requirement in paragraph (J) was changed from five working days to require that a face-to-face interview be scheduled as promptly as possible. This change was made to align with food stamp rule 5101:4-2-07.

A new section was added that lists the items to provide at the face-to-face interview. This change is reflected in paragraph (K) of the rule. These items are:

• JFS 08000 "Your Rights" (Brochure of right to apply, right to a state hearing and civil rights);
• "Voter Registration Form" and "Notice of Rights";
• JFS 07092 "Notice To Individuals Applying For Or Participating In OWF Concerning Good Cause For Refusal To Cooperate With Securing Child Support" if applicable;
• JFS 07357 "Grant Payment Method Authorization -Mandatory" or JFS 07344 "Grant Payment Method Authorization -Voluntary" as appropriate;
• A copy of the CRIS-E generated rights and responsibilities page or the JFS 07501 "Your Rights and Responsibilities".

Language related to the gathering of medical documentation and referring the case to County Medical Services was added to the responsibilities of the CDJFS contained in paragraph (L) of the rule.

Paragraph (N) has been changed. It now states "all information contained in the JFS 07501" and removes those individual listings that are part of the JFS 07501. The requirement to provide a photo ID was removed from the Ohio Revised Code and subsequently removed from this section. An explanation of the medication dependent covered group has been removed, as this is a medical program no longer connected with DFA. An explanation of the self-sufficiency contract and time limit requirements has been added to the list.

The previous section titled "Unavailability of CRIS-E system for interview" has been removed and replaced with new language that was added to paragraph (N). The unavailability of CRIS-E, face-to-face interview, home visits, and telephone interviews explained in this paragraph are also detailed in the new chart "Application Situations for Cash Programs" added to the JFS Charts appendix. When the CRIS-E system is unavailable for the interview, the CDJFS worker must now complete the JFS 01846 and enter this information into the CRIS-E system as soon as the system is available. The signed and dated JFS 01846 will satisfy the requirement of having signed the Printed Copy of Information (PCI). Language was removed from this section that required the PCI to be mailed to the individual to be signed and dated and the subsequent denial of benefits is no longer appropriate for failure to return the signed and dated PCI.

Rule 5101:1-2-10 Ohio works first (OWF)/ disability financial assistance (DFA)/ refugee cash assistance (RCA): the reapplication requirement.

This rule was reformatted to remove sections containing application processing procedures.

These procedures are now included in rule 5101:1-2-01.

Language related to the gathering of medical documentation and referring the case to County Medical Services was added to the responsibilities of the CDJFS contained in paragraph (B) (1) of the rule.

Language was added regarding the reapplication interview conducted as an interactive interview, home visit or phone interview as detailed in the new chart "Application situations for cash programs".

Reference to requiring a JFS 07200 when a new or additional category of cash assistance is requested had been removed from this rule. The signature on the PCI establishes the beginning date of cash assistance for that category. Language requiring the PCI be sent to the AG for signature and return has been removed.

CAM Appendix

JFS Forms

Two forms have been removed from the Forms appendix with this CAMTL. The following forms have been removed from the CAM because they have been obsoleted.

JFS 03607, Medical Information Release Form (Rev. 11/2000); and

JFS 07100, Application for Income, Medical, and Food Assistance (Rev. 4/2001).

JFS Charts

A new chart was added to the Forms appendix with this CAMTL. The chart covers the application situations in the application and reapplication process rules. The following chart was added:

Application Situations for Cash Programs (Effective 5/2005)

Training and Technical Assistance

Training and technical assistance needs to implement these rules will be minimal. Clarification regarding these rules will be available to county staff by ODJFS through the Bureau of County Oversight and Support, Program Policy Services staff.

Fiscal Impact

There should be little or no fiscal impact for the county agencies to implement this FSTL/CAMTL. With the elimination of the large out-of-date JFS 07100, "Application for Income, Medicaid, and Food Assistance," county agencies will now use the revised JFS 07200 for applications. When CRIS-E is unavailable or for occasional telephone or off-site interviews the newly developed worksheets will be utilized.

INSTRUCTIONS: FOOD STAMPS

INSTRUCTIONS: CASH ASSISTANCE