Effective April 1, 2010, Ohio's cash and food assistance programs will transition to twelve month certification periods for most assistance groups. Ohio Works First assistance groups which are "child only", without a work-eligible adult or minor head of household, will move to 24 month reapplication periods. Additionally, effective April 1, 2010, all food assistance households will be subject to simplified reporting for changes, which means that they are only required to report when their income exceeds 130% of the federal poverty guideline for their assistance group size or if an able-bodied adult without dependants (ABAWD) hours of employment fall below twenty hours per week. Reporting requirements for cash assistance are being changed to require the reporting of a change in the amount of gross monthly income of more than fifty dollars (increased from twenty-five dollars).

The cash and food assistance programs will also implement a new reinstatement policy. Effective April 1, 2010 county agencies can reinstate both cash and food assistance benefits without a new application when a case closes due to an eligibility factor, but the assistance group complies within thirty days of the termination.

If any changes are made to the rules contained in this transmittal letter during the Joint Committee on Agency Rule Review's review period, the corrected rule(s) will be sent out in a future Transmittal Letter.

Background:

In 2008, the Ohio Department of Job and Family Services Office of Families and Children began a concerted effort to review food assistance policy to improve efficiency and payment accuracy. As part of this effort, we conducted regional focus group sessions with county departments of job and family services to evaluate the need for improvements in Ohio's Food Assistance Program. In July 2008, we began working with the Rushmore Consulting Group to identify specific ways to improve Ohio's food assistance payment accuracy rate. In both instances, alignment of certification periods, and longer certification periods, were a recurring theme. Additionally, another one of the recommendations from the Rushmore Consulting Group was to expand simplified reporting (otherwise known as "semi-annual reporting") to all households, not just those with earned income.

Starting with the 2002 Farm Bill and expanded with the 2008 Farm Bill, federal law provided states with the option to move to twelve month certification periods and to expand simplified reporting to all households. In consultation with the United States Department of Agriculture (USDA) Food and Nutrition Service, representatives from county agencies, and other states, Ohio will now implement these options. Additionally, to efficiently utilize these policy options, we received a waiver from the USDA Food and Nutrition Service to allow workers to reinstate terminated benefits, instead of taking a new application, if an assistance group returns requested verifications or takes the required action within thirty days of the closure date.

With county agencies experiencing increasing caseloads and limited resources these changes should assist with caseload management and application processing. These changes should also improve program access by eliminating the requirement for recipients to be interviewed every six months and assist with further improving the state's food assistance payment accuracy rate.

New Policy: Food Assistance

Certification Periods

Previously, rule 5101:4-5-03, "Food Assistance: Establishing Certification Periods," required most assistance groups to have a six month certification period. The exceptions to this were assistance groups with all aged or disabled members with no earned income, assistance groups with unstable circumstances and assistance groups expecting a change that would make them ineligible to receive food assistance.

Effective April 1, 2010, all assistance groups will transition to twelve month certification periods at application and reapplication, with some exceptions. Assistance groups with all aged or disabled members with no earned income will continue to receive a twenty-four month certification. Assistance groups expecting a change that would make them ineligible to receive food assistance, migrant farm workers and homeless assistance groups may now receive a certification period of either four, five, six or twelve months. The certification period for these groups will be decided based on county discretion.

All new food assistance groups will be certified according to this new policy. All existing food assistance groups will transition to this policy at recertification.

Language has been removed regarding "shortening" the certification period. This rule now refers to "ending" the assistance group's benefits.

Reporting Requirements

Previously, rule 5101:4-7-01, "Food Assistance: Reporting Requirements During the Certification Period," limited simplified reporting requirements to assistance groups with earned income. These assistance groups were referred to as semi-annual reporting (SAR) assistance groups. SAR assistance groups were only required to report when their income exceeded 130% of the federal poverty guidelines for their assistance group size, and for assistance groups with an able bodied adult without dependents (ABAWD), there was an additional requirement to report if their work hours fell below twenty hours a week. All other assistance groups were on change reporting, which meant they had to report all changes within 10 days of the change and all changes to income over $50.

Effective April 1, 2010 all assistance groups are subject to simplified reporting. All assistance groups will now only be required to report when their income exceeds 130% of the federal poverty guidelines for their assistance group size, and for assistance groups with an able bodied adult without dependents (ABAWD), the additional requirement to report if their work hours fall below twenty hours a week. Assistance groups will be issued a one time notice advising them of their simplified reporting requirements prior to April 1, 2010. After April 1, 2010 assistance groups will be issued their reporting requirements on the notice of approval. To accommodate the expansion of simplified reporting, the JFS 04196 "Food Stamp Change Report for Assistance Groups with Earned Income" has been revised and renamed. The revised report will be titled "Food Assistance Change Reporting." The JFS 04196 will be used for all assistance groups. The JFS 07443 will be obsolete.

Additionally, as a requirement for simplified reporting, assistance groups with twelve or twenty-four month certification periods will be required to submit an interim report to provide updated information about their circumstances. Assistance groups with a twelve month certification period will receive an interim report in the fifth month of their certification period. The assistance group is required to complete and return the interim report prior to the 21st of the fifth month of certification. Similarly, assistance groups with a twenty-four month certification will receive an interim report in the eleventh month of their certification period and the report must be completed and returned by the 21st of the eleventh month of certification.

The county agency will be required to register the interim reports via CRIS-E. If the interim report has not been registered an alert will be issued informing the worker that the interim report should have been received. Assistance groups that do not return the report will be proposed for termination.

Reinstatement

Effective April 1, 2010 pursuant to rule 5101:4-7-01 county agencies will reinstate food assistance benefits without a new application when a case closes due to an eligibility factor, but the recipient complies within thirty days of the termination. This includes assistance groups whose benefits were terminated for failure to return an interim report. Benefits shall be prorated based on the day the assistance group provides the necessary verifications or takes the required action.

Benefits shall not be reinstated in the last month of the assistance group's certification period. If the assistance group returns requested verifications or takes a required action in the last month of their certification period the assistance group shall complete a new application.

New Policy: Cash Assistance

Reapplication periods

Previously, rule 5101:1-2-10, "Ohio Works First/Disability Financial Assistance/Refugee Cash Assistance: the Reapplication Requirement," required all cash assistance groups to have a six month reapplication.

Effective April 1, 2010 OWF and DFA assistance groups who previously received a six month reapplication will now receive a twelve month reapplication, and OWF child-only assistance groups who previously received a six month reapplication will now receive a twenty-four month reapplication.

Any OWF and DFA assistance groups expecting a change that would make them ineligible to receive cash assistance; migrant farm workers; and homeless assistance groups may now receive a reapplication period of either four, five, six or twelve months to align with the food assistance certification period. The reapplication/certification period for these groups will be decided based on county discretion.

Refugee cash assistance benefits will remain at a six month reapplication due to the time-limited nature of these benefits.

Reporting Requirements

Previously, rule 5101:1-2-20, "Ohio Works First, Disability Financial Assistance, and Refugee Cash Assistance:Verification and Reporting Requirements," required all cash assistance groups to report a change in the amount of gross monthly income of more than twenty-five dollars.

The rule is being amended to change the requirement to report a change in the amount of gross monthly income of more than fifty dollars. Due to fiscal constraints and different income eligibility criteria, cash assistance programs cannot adopt simplified reporting. Increasing the threshold over which a change must be reported, however, should improve efficiency and make reporting requirements less burdensome for recipients.

Additionally, to align with food assistance and improve efficiency of case processing, the interim report required for food assistance will be used for OWF and DFA assistance groups who are receiving food assistance. OWF and DFA assistance groups that do not complete and return the interim report under the required timelines will be proposed for termination of OWF or DFA benefits. The policy has been added to rule 5101:1-2-20.

Reinstatement

Effective April 1, 2010 the same reinstatement policy that is being implemented for the food assistance program will also be applied to the OWF and DFA programs. The county agency will reinstate terminated benefits without a new application if an assistance group returns requested verifications or takes the required action within thirty days of the closure date as long as the assistance group is not in the last month of the food assistance certification period and is otherwise eligible for cash assistance benefits. This includes assistance groups whose benefits were terminated for failure to return an interim report. However, cash assistance benefits shall not be reinstated if the assistance group is otherwise ineligible (e.g., serving a penalty period of ineligibility or a three-tier sanction).

Training

Training will be conducted by the Office of Family Assistance, Program Policy Services Unit in March. Questions about the new process may be directed to the TANF-FSTA mailbox.

CRIS-E

CRIS-E programming staff at ODJFS are working to make changes to the system to generate the interim report, to create a new screen to register the interim report and to create a new alert to notify a worker if an interim report is not received. The programming staff are also working to make the certification/reapplication period default to twelve months and are working to more efficiently allow the reinstatement of benefits without a new application if the eligibility factor is corrected within thirty days of the termination of benefits.

A CRIS-E View Flash Bulletin (CLVB) will be issued prior to the implementation date with more details.

INSTRUCTIONS:

The following chart identifies the material that should be removed from the Cash Assistance Manual and the material that should be added.

The following chart identifies the material that should be removed from the Food Assistance Certification Handbook and the material that should be added.