FACT 75 (Staggered Certification Periods)
Food Assistance Change Transmittal No. 75
September 10, 2020
TO: All Food Assistance Manual Holders
FROM: Kimberly Hall, Director Ohio Department of Job and Family Services
SUBJECT: Staggered Certification Periods

Background: On March 9, 2020 Governor Mike DeWine declared a state of emergency for the entire state of Ohio (Executive Order 2020-01D) to protect the well-being of the citizens of Ohio from COVID-19.  Additionally, on March 13, 2020, President Trump declared a national state of emergency due to the COVID-19 pandemic.

The Families First Coronavirus Response Act authorized the United States Department of Agriculture, Food and Nutrition Services (FNS) to grant waivers to States to assist in managing the influx of applications. One of these waivers was to extend recertifications occurring in March – June 2020 by six months. Additionally, Ohio was approved to waive interim reports and interviews for initial applications during those months.

While FNS is pushing States to return to “normal order,” it recognizes the challenges they are facing regarding a substantial increase in recertifications. In response, FNS provided States with two new waiver options, in addition to current state options and pre-pandemic waivers already available.  States were required to submit a transition plan to FNS identifying which options and/or waivers they would be requesting to implement.

The Ohio Department of Job and Family Services (ODJFS) submitted a transition plan and received approval from FNS to implement the state option to stagger certification periods for cases recertified in October, November, and December 2020.  This will provide county agencies with the ability to reduce the number of recertifications every Fall and re-balance the number throughout the year.

New Procedure for October – December 2020:

Staggered Certification Periods

Ohio Administrative Code rule 5101:4-5-03 requires assistance groups to be assigned a twelve-month certification period. However, the rule also permits a shorter certification period when the county agency determines the assistance group has unstable circumstances, anticipated changes or is a migrant or seasonal farm worker. Under these circumstances, county agencies have always been allowed to assign either a four-, five- or six-month certification period consistent with their circumstances.

ODJFS is implementing the staggered certification option to allow county agencies flexibility. County agencies can choose to assign 6-month certification periods for assistance groups recertified in October, November, and December 2020, who would normally be certified for 12 months under rule 5101: 4-5-03. However, assistance groups where all adult members are elderly or disabled and have no earned income are still required to be assigned 24-month certification periods. When choosing to implement this option, the county agency must use objective criteria for selecting cases for a 6-month certification. Examples of objective criteria include, but are not limited to:

  • Cases that previously received a 6-month recertification extension;
  • Based on the last digit of the case number, or using odd or even numbers;
  • Based on the first letter of last names (e.g. A-M).

Journal notes will need to document the certification period assigned and criteria used to establish the certification period.

This staggered certification option is only available for recertifications that occur in October, November and December 2020.