CAMTL 95 (Americans with Disabilities Act and Section 504 of the Rehabilitation Act)
Cash Assistance Manual Transmittal Letter No. 95
October 1, 2014
TO: All Cash Assistance Manual Holders All Food Assistance Certification Handbook Holders
FROM: Cynthia C. Dungey, Director
SUBJECT: Americans with Disabilities Act and Section 504 of the Rehabilitation Act

Background

The Ohio Department of Job and Family Services (ODJFS) and each County Department of Job and Family Services (CDJFS) are required to comply with the provisions of both the Amendments to the Americans with Disabilities Act of 2008 (ADAAA) and Section 504 of the Rehabilitation Act (504). The general requirements of the ADAAA/504 require ODJFS and each CDJFS to:

1.Provide an equal and meaningful opportunity to all individuals with disabilities to participate in, and benefit from, the programs it administers.

2.Not operate its programs in a way that has a discriminatory effect on individuals with disabilities.

3.Make reasonable modifications, where necessary, to avoid discrimination.

In order to ensure continued state and county compliance with the ADAAA/504, the ODJFS Bureau of Civil Rights (BCR) and the Office of Family Assistance (OFA) have worked with shareholders to review relevant state and county policies relating to individuals with disabilities.

Cash Assistance Manual: Chapter 1000

5101:1-2-01 "The application process for Ohio works first, disability financial assistance, and refugee cash assistance."

This rule describes the application process for the Ohio Works First, Disability Financial Assistance, and Refugee Cash Assistance programs. The changes include the requirements for:

  • A county agency to adhere to its Americans with Disability Act (ADA) Plan adopted in accordance with rule 5101:9-2-02 of the Administrative Code; and
  • A county agency to explain an individual's rights under the ADAAA/504 during the application interview.

5101:1-2-10 "The reapplication requirement."

This rule describes the reapplication process for the Ohio Works First, Disability Financial Assistance, and Refugee Cash Assistance programs. The changes include the following for:

  • A county agency to adhere to its ADA Plan adopted in accordance with rule 5101:9-2-02 of the Administrative Code; and
  • A county agency to explain an individual's rights under the ADAAA/504 during the reapplication interview.

Cash Assistance Manual: Chapter 2000

5101:1-3-11 "Ohio works first (OWF): appraisals, assessments, and self sufficiency contract."

This rule describes the process for appraising and assessing work eligible individuals and developing a self sufficiency contract in the Ohio Works First program. The changes include the following requirements:

  • A county agency must provide additional screening if an appraisal indicates that a work eligible individual has a physical or mental condition that substantially limits one or more major life activities; and
  • A self-sufficiency contract must include information about ADAAA/504.

5101:1-3-12 "Ohio works first: work activities."

This rule describes work activities in the Ohio Works First program. The changes include the requirement that assignments to work activities must be made in accordance with a county agency's ADA Plan and rule 5101:9-2-02 of the Administrative Code.

Food Assistance Manual: Chapter 2000

5101:4-2-07 "Food assistance: initial interview process."

This rule describes the application process for the food assistance program. The changes include the following requirements:

  • A county agency must adhere to its ADA Plan adopted in accordance with rule 5101:9-2-02 of the Administrative Code; and
  • A county agency must explain an individual's rights under the ADAAA/504 during the application interview.

Food Assistance Manual: Chapter 3000

5101:4-3-29"Food assistance employment and training: appraisal."

This rule describes the requirement that each individual applying for or in receipt of food assistance benefits that is not exempt from work registration, must be assessed to determine the best assignment for their skills and needs. The changes include the requirement that an employability plan developed as a result of the appraisal must include an explanation of the individual's rights under the ADAAA/504 and a description of each reasonable modification made for the individual (if any).

5101:4-3-30 "Food assistance employment and training program."

This rule describes the requirements for a county agency to develop an employment and training plan. The changes include the requirements for a plan to be adopted by a county agency to include an explanation of a participant's rights under the ADAAA/504.

Forms

JFS 03801"Ohio Works First Self-Sufficiency Contract"

This form may be used as a model or as an actual self-sufficiency contract in the Ohio Works First program. The changes include:

  • A statement about whether or not a reasonable modification is necessary in section E.
  • A statement about the ADAAA/504 in Section J.
  • Other technical corrections for clarity.

JFS 07501"Program Enrollment and Benefit Information"

This booklet contains information about various programs administered by ODJFS. The changes include the addition of ADAAA/504 information with the Civil Rights information beginning on page 12.

Instructions

When the Transmittal Letters are published, each Manual will be updated as follows:

  • Each amended rule will replace the previous version of the rule in the Manual.
  • Each amended form will replace the previous version of the form.

The rules and forms can be accessed at: http://emanuals.jfs.ohio.gov.