FACT 85 (Interview and Interim Reporting Requirements, Child Tax Credit and Emergency Allotments Update)
Food Assistance Change Transmittal No. 85
July 1, 2021
TO: All Food Assistance Manual Holders
FROM: Matt Damschroder, Interim Director, Ohio Department of Job and Family Services
SUBJECT: Interview and Interim Reporting Requirements, Child Tax Credit and Emergency Allotments Update

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.

On October 1, 2020 the Continuing Appropriations Act, 2021, and Other Extensions Act became law and provided States with the option to, adjust interview requirements and stop interim report requirements without requiring waiver approval from the United States Department of Agriculture.

Additionally, the American Rescue Plan Act of 2021 became law and contains changes regarding promoting economic security, specifically as it relates to the Child Tax Credit. Below is information on how this is to be treated for the Supplemental Nutrition Assistance Program (SNAP).

Please find corresponding updates below:

Updated Procedures:

Initial Application Interviews

Effective July 1 - September 30, 2021, 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

From July 1 - September 30, 2021, 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.

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.

Interim Reports

Interim reports are not required for assistance groups July 1 - September 30, 2021. Interim reports will not be sent in these months. Assistance groups remain subject to all other reporting requirements until their recertification.

Child Tax Credit

The American Rescue Plan Act of 2021 allows the Child Tax Credit to be issued in advance monthly payments to eligible families. These payments are to begin in July 2021. The Child Tax Credit, whether received as an annual credit or in the form of advance payments, is excluded from consideration as income in the month of receipt and as a resource for 12 months following receipt for SNAP purposes. A household would not be considered to have exceeded the income limit due to these payments because they are excluded, but receipt of these payments could affect a household’s eligibility after 12 months if the payments cause the household to exceed the resource limit, if applicable.

Program Update - Emergency Allotments

As outlined in FACT 84, the Ohio Department of Job and Family Services (ODJFS) received approval from Food and Nutrition Services (FNS)US Department of Agriculture to issue emergency allotments (EAs) to assistance groups (AGs) beginning March 2020 and ongoing until such a time as either the federal public health emergency declaration is rescinded or Ohio’s state of emergency ends. Although Ohio’s state of emergency ended on June 18, 2021, FNS has approved emergency allotments to continue through a statewide declaration by Interim Director Damschroder, effective through December 31, 2021. Emergency allotments may continue to be authorized on a monthly basis until the statewide declaration ends, or the public health emergency declaration is rescinded, whichever comes first.

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.