This letter transmits changes with the effective date of February 1, 2009. If there are changes made to any of the rules contained in this CAMTL during the JCARR review period, corrected rules will be sent out in the next CAMTL.

CHAPTER 1000

Ohio's electronic payment card

Starting February 1, 2009, we will offer Ohioans a new option for receiving their cash assistance benefits. The option is the Ohio EPPICard, a prepaid MasterCard debit card that can be used at ATMs, MasterCard member banks, and any retailer that accepts MasterCard such as grocery stores, retail establishments, and pharmacies. Food assistance benefits will still be delivered through the Ohio Direction Card. In August 2009, the Ohio EPPICard will become the primary method of issuance for cash assistance in the state, and paper warrants will be phased out.

Background

Over the past year, we have looked at ways to improve services to clients, and ease administrative costs. Electronic payment cards are a more secure and expedient method in which to deliver cash assistance benefits. Lost, stolen, or non-delivered paper warrants will be eliminated. Clients will receive benefits more timely than through the mail by paper warrant, can avoid any issues they may encounter to cash their warrant, will be able to use ATMs to access their benefits and will have thousands of locations at which they can use the Ohio EPPICard. We expect to experience a reduction of the cost of printing and mailing warrants and in time spent by the county departments of job and family services (CDJFS) dealing with time-consuming and antiquated processes to replace lost or stolen warrants and warrants not received in the mail.

We also expect that the new Ohio EPPICard will provide an enhancement in the delivery of benefits for clients as well. For clients moving from a paper warrant system of benefit delivery to the Ohio EPPICard, our clients will have the improvements of immediate access of their benefits, as well as increase in the security of benefit delivery.

Before implementing the new payment option, we conducted a survey with other states who issue benefits on an electronic payment card. Thirty states responded to the survey, providing us information on the impact of moving from a paper warrant system to an electronic payment card, fees that are assessed, problems reported by the users of the electronic payment card and feedback from the community and retailers.

We also reviewed the electronic payment card used to provide Unemployment Compensation and Child Support benefits to Ohio residents and spoke with staff in those offices. On October 20, 2008, we issued Office of Family Stability Letter #80 which provided details on the roll out of the Ohio EPPICard.

Policy

Currently, there are two methods of issuance for Ohio Works First, Disability Financial Assistance and Refugee Cash Assistance benefits, i.e. paper warrant or direct deposit (electronic funds transfer). Effective February 1, 2009, assistance groups in receipt of cash assistance benefits will have a new option to receive their monthly cash benefits on an electronic payment card.

At application and reapplication the CDJFS must review the options with the assistance group and provide them with informational material. During this voluntary enrollment period, if the assistance group elects to continue to receive their monthly benefit either through a paper warrant or by direct deposit, no action is necessary. If they choose to have their benefit issued on the electronic payment card, the CDJFS shall make the appropriate entry in the Issuance Method field on the AEFPY screen in CRIS-E. This entry will result in the mailing of the electronic payment card and informational material to the assistance group.

At any time during the voluntary period, the assistance group can elect to receive cash assistance benefits on the Ohio EPPICard, not just at application and reapplication.

During the voluntary enrollment period there will be instances where a paper warrant is issued even if the assistance group chooses to have benefits issued on the electronic payment card. These situations are:

(1)Supplemental or auxiliary benefits;

(2)Work allowance payments made to an individual who is not the assistance group payee;

(3)A benefit that is authorized on the electronic payment card, but does not receive a valid routing and account number from the vendor in time for processing.

In addition, during the voluntary period, if a direct deposit benefit is canceled, it will be reissued as a paper warrant.

Beginning August 1, 2009, the electronic payment card will become the primary method of issuance for cash assistance benefits and the paper warrants will be phased out over the six month period as assistance groups complete their reapplication. Additional details and the rule outlining the mandatory phase out will be issued prior to the August 2009 effective date.

New Rule 5101:1-2-70: Issuance of cash assistance benefits.

We have written a new rule to incorporate the policy on the three methods of benefit issuance:

• Electronic payment card;
• Electronic fund transfer (direct deposit);
• Paper warrant.

The rule contains the policy on the selection of a benefit issuance method, fees and replacement of the electronic payment card.

No changes have been made to rule 5101:1-2-80 of the Administrative Code, which contains the applicable policy on the issuance of benefits through direct deposit. In addition, rule 5101:1-2-55 of the Administrative Code is still applicable for the replacement process of paper warrants until they are phased out.

Use of the Card and Fees

Clients will have a number of options to access their benefits with the new Ohio EPPICard. Clients can use their Ohio EPPICard to make purchases at any MasterCard accepting business. Many businesses also provide "cash back" with a purchase. Clients who require cash for purposes other than purchases can also go to any MasterCard member bank teller or credit union location in Ohio or nationwide for withdrawal without a fee. Clients will also be able to use an ATM to access their benefits, but will incur a small fee for each withdrawal. ATMs should be used as an option of last resort to avoid incurring fees.

Fees are listed in the table below.

*There is no fee to select or change your PIN, call and report lost, stolen or damaged card, suspected PIN compromise or question a transaction.

Training

The Office of Family Stability County Support Section will provide training to all CDJFS in January 2009. Staff and client educational materials will be provided. We will also provide status updates at monthly video conferences.

Notification to assistance groups

In January 2009, current cash assistance recipients will receive an ad hoc notice announcing the voluntary phase. The notice will contain information the client needs to make an informed decision on choosing the new option. A second ad hoc notice will be issued in July 2009, announcing the phase out of the paper warrant and the two choices that clients will have to receive their benefits.

CRIS-E

CRIS-E system changes are currently in development. Detailed changes to the CRIS-E system will be issued via a view flash bulletin (CLVB) prior to the February 1, 2009, implementation date.

CHAPTER 2000

Section 119.032 of the Ohio 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 be continued without amendment, be amended or be 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 is eliminated, and, when possible, local agencies are given more flexibility.

Rule 5101:1-23-70 "Ohio Works First (OWF): Erroneous payments

This rule has been reviewed as a result of the five year rule review. In reviewing this rule, we focused specifically on the language regarding time frames under which a decrease in OWF cash assistance should occur.

Prior OWF policy about the effective date of the budget change was federally required under the AFDC program governing overpayment recovery. The prior federal policy required that the effective date of the budget decrease (or termination) be as of the first day of the month following the month in which the change occurred. This was applicable even if the change affecting the budget occurred on the last day of the month, which resulted in the creation of many overpayments due to the prior notice requirements for adverse actions.

Changes to this rule have been made to follow existing food assistance policy on the effective date of a decrease in benefits. Specifically, the new OWF policy regarding the effective date of the budget decrease or termination is effective with the month following the month in which the notice of adverse action announcing the decrease or termination expires. This change in OWF policy should have several positive results. First, it will make OWF erroneous payment policy consistent with similar food assistance policy. Second, because the new policy extends the time frame under which the change in the OWF benefits must be made to the month following the month in which the notice of adverse action expires, the incidence of OWF erroneous payments should be reduced. Additionally, the new policy change should reduce the requisite CDJFS administrative work involved in the calculation and collection of erroneous payments.

As a result, rule 5101:1-23-70 has been amended to include policy contained in food assistance rule 5101:4-7-01, which states, in part:

"…If the AG's benefit level decreases or the AG becomes ineligible as a result of the change, the county agency shall issue a notice of adverse action within ten days of the date the change was reported unless one of the exemptions to the notice of adverse actions in Chapter 5101:6-2 of the Administrative Code applies. When a notice of adverse action is used, the decrease in the benefit level shall be made effective with the allotment for the month following the month in which the notice of adverse action period has expired, provided a fair hearing and continuation of benefits have not been requested. When a notice of adverse action is not used due to one of the exceptions of rule 5101:6-2-05 of the Administrative Code, the decrease shall be made effective no later than the month following the change."

Other modifications to the rule are format related and are not substantive.

INSTRUCTIONS: