FACT 78 (Interview and Interim Reporting Requirements and Extending Certification Periods)
Food Assistance Change Transmittal No. 78
October 14, 2020
TO: All Food Assistance Manual Holders
FROM: Kimberly Hall, Director Ohio Department of Job and Family Services
SUBJECT: Interview and Interim Reporting Requirements and Extending 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. In order to protect the lives, safety and health of Ohio’s citizens, various orders have been issued from the Governor and the Ohio Department of Health to limit social interaction. These orders include: prohibiting mass gatherings (100 or more people in a single room); closing schools; prohibiting visitors in hospitals and jails; closing restaurants and bars; encouraging businesses to allow employees to work from home as well as asking parents to keep children out of day care settings.

The Families First Coronavirus Response Act (Public Law 116-127) became law on March 18, 2020 and provided states the ability to seek waivers to expand flexibility of programs to ease the administrative burden of issuing Supplemental Nutrition Assistance Program (SNAP) benefits while under a state of emergency.

On October 1, 2020 the Continuing Appropriations Act, 2021, and Other Extensions Act became law and provides States with the option to extend recertifications by six months, and adjust interview requirements and stop interim report requirements without requiring waiver approval from the United States Department of Agriculture. Ohio is implementing these options.

New Procedures:

Initial Application Interviews

Effective immediately through December 31, 2020, a county agency can opt to not conduct an interview at initial application prior to approving SNAP benefits, provided the following are met:

  • The applicant’s identity has been verified; and
  • All other mandatory verifications in paragraphs (D) and (E) of rule 5101:4-2-09 of the Ohio Administrative Code (OAC) have been completed.
    • A county agency shall obtain documentary verifications (including electronic sources); if documentation is not able to be obtained, the county agency may use a collateral contact. If neither documentation nor collateral contact can be obtained, client statement may be used. Case notes must clearly document the verification used to make an eligibility determination.
  • A county agency is required to contact the applicant if any information on the application is questionable.
  • When a county agency is unable to contact the applicant, it shall schedule a telephone interview and send notice of the appointment to the applicant. The scheduled interview establishes a means of contact with the applicant to gather missing information not included in the application. If there is no contact with the applicant at the scheduled appointment time, the county agency must send a notice of missed interview (NOMI). If the applicant does not request to reschedule, the application shall be denied.

Applications processed under expedited procedures, which only require identity and social security number to be verified, still require a telephone interview to be completed in order to authorize benefits for a one or two-month certification period.

A county will need to inform Program Policy Services if it will implement this option, and for which months, by sending an email to TANF-FSTA@jfs.ohio.gov.

Face-to-Face Interview Method

Through December 31, 2020, when a county agency is conducting an interview, it is not required to conduct a face-to-face interview when an applicant requests this method. If a face-to-face interview is requested, the county agency can schedule it to be conducted by telephone. The client will be serviced through other available options during the pandemic.

Interim Reports

Interim reports are not required for assistance groups in October, November and December 2020. As a result, interim reports that were scheduled to be mailed in October have already been stopped and interims for November and December will also not be sent. Assistance groups remain subject to all other reporting requirements until their recertification.

Extending Certification Periods

All assistance groups scheduled to expire in November and December 2020, who have not previously received a 6-month extension of their certification period, will have their certification periods extended through May and June 2021 respectively. Assistance groups will be notified that their certification date will be extended, and they do not have to reapply and participate in the interview until May or June 2021. These updates will be made in Ohio Benefits accordingly.

If you have questions regarding any of the information please reach out to Program Policy Services by sending an email to TANF-FSTA@jfs.ohio.gov.