Background
The Food and Nutrition Act of 2008 provides a State option for Supplemental Nutrition Assistance Program (SNAP) applicants to submit and sign their applications over the telephone. In order to implement this process, the State must ensure that certain requirements and protections are in place. The Ohio Department of Job and Family Services (ODJFS) has established the following procedure for accepting applications and signatures over the phone that ensure compliance with the Act.
New Procedure
Effective February 1, 2017, a county agency may opt to accept a telephonic signature as part of an initial application and or reapplication made over the phone. Telephonic signatures cannot be required by a county agency; thus, an applicant's right to apply in writing or online must always remain available. Only counties that have the express permission of ODJFS may adopt the procedure to accept telephonic signatures for cash and food applications and reapplications described below.
Use of Standardized Scripts
ODJFS has developed standardized scripts for county agencies to accept initial applications and reapplications by phone. The scripts ensure that the application process includes:
- Federally required information (including information about application processing timeframes) is provided to the applicant;
- The uniform collection of the minimum application requirements (i.e., name, address, and signature); and
- Safeguards against identity theft.
The scripts specifically indicate what information has to be recorded during the application process, and concludes by leading the applicant into the interview to capture the remaining information necessary to determine eligibility and the appropriate processing standard (24-hours, 7 days or 30 days). The phone interview immediately proceeding the submission of the application should be conducted in the same manner as a scheduled phone interview would otherwise be conducted had a paper application been received.
Retrievable Audio Recording
The county agency must ensure there is ready access to the audio file containing the verbal assent of the applicant and that the audio file is retrievable and complies with federal records retention requirements in 7 CFR 272.1(f). The county agency must also ensure that there is a direct link between the audio and case files. For example, the county agency could meet this requirement by using a filename with a unique identifier (such as case name, case number, time, and date) or by adding a hyperlink to the audio file in the electronic case file.
Safeguarding
In order to meet the requirements of the Act, steps must be taken to prevent impersonation, identity theft, and invasions of privacy by individuals attempting to apply or reapply over the phone. Just as a county agency must do before discussing a pending or open case over the phone, the county agency must take steps to ensure an individual applying over the phone is who they claim to be. For current or former public assistance recipients, this information could be verified based on details in their current or former case; but for individuals never known to have received public assistance, the county agency must review information from reliable third party sources to confirm the identity of the caller. ODJFS has developed the attached guide to assist with identifying reliable sources of information. The inability to confirm the identity of the caller would not necessarily lead to termination of the interview, but the county agency would be unable to provide (but could receive and document) confidential information during the call and would need to verify information independent of the phone call.
Procedures for Correcting Application Information
As of February 1, 2017 all approval and denial notices will contain new language explaining how an individual can make corrections to the information listed in the notice (i.e. name, address, and SNAP budget information if applicable). The new language will give all applicants - regardless of whether they apply in writing, online or by telephone - ten days to contact the county agency to correct any information contained in the notice. Just as it would with any other allegedly incorrect information, if an individual contacts the county agency to correct an error or omission in the notice, the county agency must act upon the information in accordance with the rules of the Ohio Administrative Code.
Implementation
At this time, only those county agencies working with Shared Services in the Office of Change Management (OCM) may implement the procedure for accepting applications over the phone. County agencies not currently working with Shared Services should contact Doug Lumpkin (Doug.Lumpkin@jfs.ohio.gov) in OCM for more information about adopting this procedure.
Rule Updates
Although allowable under the current rules, ODJFS plans to revise rules in order to clarify the procedures for accepting telephonic applications and signatures and will update prior policy guidance and/or training materials as necessary.
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Intake- Telephonic Signature Script
If English is not your primary language, we can provide someone who can help you understand the questions during this application and in the interview. Do you need an interpreter? [If yes, get the interpreter before proceeding]
Once I obtain your name, address and signature over the phone, this application for cash and food assistance benefits will be dated XX/XX/XXXX. You will get an answer about your application within 30 days for cash or food assistance or within 90 days for Disability Financial Assistance.
You have the right to authorize another person to act on your behalf and will have a chance to add an authorized representative during this call.
The following will be recorded and serve as your application for benefits. Once you've signed your application, we will stop the recording, submit your application and begin the interview. During the interview you will be asked a series of questions to help determine your eligibility for cash and food assistance as well as questions to see if you are eligible to receive food assistance benefits within 7 days. You always have the right to submit an application in writing, however, once your telephone application is submitted over the phone, it will be treated exactly the same as a written application.
We will now begin recording…
Start Recording
If you are not registered to vote where you live now, would you like to apply to register to vote? [YES/NO]. [IF NO, PROCEED TO NEXT PARAGRAPH; IF YES, "A voter registration form will be sent to you following this interview. Follow the instructions on the form once received."]
By signing this application over the phone, you are certifying under penalty of perjury that the information or answers you provide for yourself and for everyone in your household in this application, during the interview, or in any reported change are complete and accurate to the best of your knowledge, including information provided about the citizenship or alien status for each household member applying for benefits.
By completing this application over the phone, you are confirming that you understand the following:
- Receive fair treatment without regard to race, color, national origin, disability, age, sex, and in some cases religion or political beliefs because this institution is an equal opportunity provider; and,
- Request a fair hearing, orally or in writing, before the Ohio Department of Job and Family Services if you disagree with any action on your application.
- Provide proof that you are eligible,
- Report changes in household circumstances as instructed,
- Not sell, trade, or give away your food assistance benefits and only using your food assistance benefits to buy eligible items.
- You understand and agree to provide documents to prove what you say during this call. To receive a deduction for the following expenses in the food assistance program, you must report and provide verification of: your rent or mortgage payment, utility and/or shelter costs, medical expenses if you are elderly or disabled, dependent care expenses, and legally obligated child or medical support paid to a non-household member. Failure to report or verify any of the above will be seen as a statement by your household that you do not want a deduction for that expense.
- That the county agency may contact other persons or organizations to obtain the necessary proof of your eligibility and level of assistance and/or in some instances, you may be asked to give consent to the county agency to make those contacts.
- That by signing this application and receiving Ohio Works First cash assistance, you are assigning to the State of Ohio any rights to all support owed to you and the minor children in the assistance group.
- That you will have to provide Social Security numbers and identify if someone is a US citizen for anyone that is applying for cash and food assistance.
- That if you are only applying for food assistance, you do not have to respond to questions about gender.
- That Title VI of the Civil Rights Act of 1964 allows us to ask for racial/ethnic (Hispanic or Latino) information. Providing this information is voluntary and is used for informational purposes only. If you do not want to give us the information, it will have no effect on your case but we will enter a response for you.
- That a telephonic signature has the same legal effect and can be enforced in the same way as a written signature.
What is your first and last name?
What is your address?
Do you agree and understand your rights and responsibilities and the information I've just provided? [YES/NO]
Do you want to submit this application for cash and food assistance over the phone?
[YES/NO]
Let me confirm your name and address [REPEAT NAME AND ADDRESS]. You have now completed an application for cash and food assistance that will be dated for today [TODAY'S DATE]. Now we will stop recording and begin the interview.
Stop Recording
Now that you have applied, let's continue with the additional questions needed to complete the interview and determine eligibility.
[Confirm identity of person on the phone]
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Recertification- Telephonic Signature Script
If English is not your primary language, we can provide someone who can help you understand the questions during this reapplication and in the interview. Do you need an interpreter? [If yes, get the interpreter before proceeding]
[Confirm identity of person on the phone]
Once I obtain your name, address and signature over the phone, this reapplication for cash and food assistance benefits will be dated XX/XX/XXXX. You will get an answer about your reapplication by the end of your current certification period.
You have the right to authorize another person to act on your behalf and will have a chance to add an authorized representative during this call.
The following will be recorded and serve as your reapplication for benefits. Once you've signed your reapplication, we will stop the recording, submit your reapplication and begin the interview. During the interview you will be asked a series of questions to help redetermine your eligibility for cash and food assistance. You always have the right to submit a reapplication in writing, however, once your telephone reapplication is submitted over the phone, it will be treated exactly the same as a written reapplication.
We will now begin recording…
Start Recording
If you are not registered to vote where you live now, would you like to apply to register to vote? [YES/NO]. [IF NO, PROCEED TO NEXT PARAGRAPH; IF YES, "A voter registration form will be sent to you following this interview. Follow the instructions on the form once received."]
By signing this reapplication over the phone, you are certifying under penalty of perjury that the information or answers you provide for yourself and for everyone in your household in this reapplication, during the interview, or in any reported change are complete and accurate to the best of your knowledge, including information provided about the citizenship or alien status for each household member applying for benefits.
By completing this reapplication over the phone, you are confirming that you understand the following:
- Receive fair treatment without regard to race, color, national origin, disability, age, sex, and in some cases religion or political beliefs because this institution is an equal opportunity provider; and,
- Request a fair hearing, orally or in writing, before the Ohio Department of Job and Family Services if you disagree with any action on your application.
- Provide proof that you are eligible,
- Report changes in household circumstances as instructed,
- Not sell, trade, or give away your food assistance benefits and only using your food assistance benefits to buy eligible items.
- You understand and agree to provide documents to prove what you say during this call. To receive a deduction for the following expenses in the food assistance program, you must report and provide verification of: your rent or mortgage payment, utility and/or shelter costs, medical expenses if you are elderly or disabled, dependent care expenses, and legally obligated child or medical support paid to a non-household member. Failure to report or verify any of the above will be seen as a statement by your household that you do not want a deduction for that expense.
- That the county agency may contact other persons or organizations to obtain the necessary proof of your eligibility and level of assistance and/or in some instances, you may be asked to give consent to the county agency to make those contacts.
- That by signing this application and receiving Ohio Works First cash assistance, you are assigning to the State of Ohio any rights to all support owed to you and the minor children in the assistance group.
- That you will have to provide Social Security numbers and identify if someone is a US citizen for anyone that is applying for cash and food assistance.
- That if you are only applying for food assistance, you do not have to respond to questions about gender.
- That Title VI of the Civil Rights Act of 1964 allows us to ask for racial/ethnic (Hispanic or Latino) information. Providing this information is voluntary and is used for informational purposes only. If you do not want to give us the information, it will have no effect on your case but we will enter a response for you.
- That a telephonic signature has the same legal effect and can be enforced in the same way as a written signature.
What is your first and last name?
What is your address?
Do you agree and understand your rights and responsibilities and the information I've just provided? [YES/NO]
Do you want to submit this reapplication for cash and food assistance over the phone?
[YES/NO]
Let me confirm your name and address [REPEAT NAME AND ADDRESS]. You have now completed a reapplication for cash and food assistance that will be dated for today [TODAY'S DATE]. Now we will stop recording and begin the interview.
Stop Recording
Now that you have applied, let's continue with the additional questions needed to complete the interview and redetermine eligibility.