This letter transmits changes with a proposed effective date of May 1, 2009. If there are changes made to any of the rules contained in this transmittal during the JCARR review period, corrected rules will be sent out in a future transmittal.

We are proposing changes to the recertification process to allow county departments of job and family services to conduct telephone interviews at recertification without establishing the assistance group would experience a hardship if compelled to attend a face-to-face interview. These changes will apply to both the cash and food assistance programs.

Introduction

With the current economic climate and rising caseloads we are striving to improve program access, ease program administration and alleviate transportation costs for assistance groups. The option to conduct telephone interviews at recertification will promote more efficient use of an eligibility worker's time in a period of increasing caseloads and reduced resources. Additionally, allowing telephone interviews enables participants to more easily complete the recertification process.

In August 2008, USDA Food and Nutrition Service granted Ohio a waiver of the food assistance requirement in 7 C.F.R. 273.14(b)(3) and 273.2(e)(1) to conduct face-to-face interviews at recertification. The waiver allows county agencies to conduct telephone interviews at recertification unless the household requests a face-to-face interview, the household does not have a telephone, or the eligibility worker determines a face-to-face interview is appropriate to resolve eligibility issues with the household.

To implement the waiver we sought input from county departments of job and family services, the ODJFS Office of Research, Assessment and Accountability, and ODJFS Office of Ohio Health Plans. We also reviewed how other states implemented similar waivers.

Program Alignment

As a result of the flexibility afforded to us by the federal Temporary Assistance for Needy Families program, we decided to align the recertification/reapplication process for the cash programs (i.e. Ohio Works First, Disability Financial Assistance & Refugee Cash Assistance) with the food assistance program. Both the cash assistance rules and food assistance rules are included in this package. We also decided to include a clarification in the cash program rule to align the initial interview process with the food assistance program to allow for telephone interviews to be conducted on a case by case basis if the county agency determines the assistance group would suffer a hardship.

The Office of Ohio Health Plans recently announced that they will also be waiving the face-to-face requirement at recertification for the Medicaid Aged, Blind and Disabled population in September, at which time the cash assistance, food assistance and Medicaid programs will all be aligned.

Proposed Policy

Currently a face-to-face interview is required at each recertification for cash and food assistance. The approved waiver will allow all county agencies the option to waive the face-to-face interview and conduct a telephone interview unless the household, or its authorized representative, requests a face-to-face interview; the household does not have a telephone; or the eligibility worker determines a face-to-face interview is appropriate to resolve eligibility issues with the household. At the time of the recertification the county does not have to document a hardship condition; however, this waiver does not change the requirement to document hardship at the time an initial face-to-face interview is waived.

For food assistance, the assistance group must provide a newly signed and dated application for benefits at the time of application for recertification. Federal regulations allow states to use existing applications, a simplified version, or other methods such as annotating changes on the existing application form. Currently, assistance groups may submit a JFS 07200 "Request to Apply for Cash, Food Stamp and Medical Assistance" form prior to the end of the certification period, or sign and date the "Printed Copy of Information" form that is generated from CRIS-E during the face-to-face interactive interview.

For telephone interviews, we have proposed the use of a new form, JFS 07204 "Request to Reapply for Cash and Food Assistance." The use of this form alleviates the need to print out and send the assistance group a copy of the "Printed Copy of Information", which can be quite large, or another JFS 07200, which may cause confusion among staff regarding the status of the case. The JFS 07204 has been formatted to fit a standard window envelope for mailing purposes and is to be sent to the assistance group before or after the telephone interview has been conducted along with the following forms:

• "Your Rights and Responsibilities" (JFS 07501);
• "Voter Registration Form" (JFS 07200-VR) & "Notice of Rights";
• "Application/Reapplication Verification Checklist" (JFS 07105); and
• Self addressed stamped envelope for return to the county agency.

Timeframes and procedures for completing the recertification process for food assistance have not changed, and delayed processing requirements still apply. For cash assistance, if the assistance group fails to return the signed "Request to Reapply for Cash and Food Assistance" in a timely manner, the cash assistance case must be terminated.

CRIS-E

We are working with the Office of Information Systems to implement changes to the CRIS-E client scheduling system to allow for telephone interviews to be scheduled along with an accompanying notice which will notify the assistance group of the phone number at which they will be contacted along with the date and time of the telephone interview. A CRIS-E view flash bulletin (CLVB) will be issued prior to the implementation date with more details. County agencies are not required to use the CRIS-E client scheduling system, but must provide assistance groups with a notice in advance of the interview informing them of the time of the interview and the phone number at which they will be contacted. Also, for tracking and reporting purposes, county agencies electing not to use the CRIS-E client scheduling system must note in CLRC that a phone interview was completed.

Reporting Requirement

As a condition of the United States Department of Agriculture - Food and Nutrition Services (FNS) approving the face-to-face recertification waiver the state must prepare an interim report notifying FNS which counties elect to take advantage of waiving the face-to-face requirement at recertification. If your county elects to utilize this telephone interview option we ask that you notify Kara Wente at kara.bertke-wente@jfs.ohio.gov

Food Assistance Changes

1.5101:4-2-07 Food assistance: interviewing assistance groups

We have added a new paragraph (I) to allow for a telephone interview to be conducted at recertification. This paragraph also explains that the JFS 07204 "Request to Reapply for Cash and Food Assistance" will be sent after the telephone interview to capture the necessary signature for recertification.

2.5101:4-7-07 Food assistance: recertification

We have added language in this rule to explain that assistance groups must receive advance notice of their telephone interview. Assistance groups will receive a telephone interview notice that will include the phone number at which the caseworker will call for the interview. In this rule we also explain that the printed copy of information (PCI) does not have to be signed for the assistance group participating in a telephone interview; however, those still participating in a face-to-face interview must sign the PCI to fulfill the signature requirement at recertification.

Cash Assistance Changes

1.5101:1-2-01 The application process for Ohio Works First, Disability Financial Assistance and Refugee Cash Assistance

We have revised this rule to clarify that the face-to-face interview requirement for the initial application can be waived if a hardship condition exists. The hardship conditions include but are not limited to: illness; transportation difficulties; care of a household member; residency in a rural area; prolonged severe weather; or work or training hours which prevent the assistance group from participating in a face-to-face interview. The hardship criterion aligns with the food assistance policy in rule 5101:4-2-07 of the Administrative Code.

2.5101:1-2-10 Ohio Works First, Disability Financial Assistance, Refugee Cash Assistance: the Reapplication Requirement

We have revised this rule to clarify that telephone interviews can be conducted at reapplication. Language has been added to clarify that the beginning date of assistance is the date that the JFS 07204 is received by the CDJFS. Also, included in the revision are the required forms that are to be provided to the assistance group at reapplication. To reduce printing and mailing costs, and to avoid unnecessary duplication of effort, we have removed the following documents from this requirement:

• "Your Rights" (JFS 08000);
• "Notice to individuals applying for or participating in Ohio Works First regarding cooperation with the Child Support Enforcement Agency"(JFS 07092);
• "Grant payment method authorization - mandatory" (JFS 07357) or "Grant payment method authorization - voluntary (JFS 07344);
• "Domestic Violence: you have a right to be safe" (JFS 08024).

These forms are provided to all cash assistance applicants, but are not required to be provided at reapplication. County agencies may opt to provide additional information, such as the JFS 08024 domestic violence brochure, to assistance groups at reapplication but are not required to do so.

Medicaid

All Medicaid applications and redeterminations should proceed under Medicaid rules and processing will not change as a result of the change to the cash and food assistance recertification process. County agencies should not use the JFS 07204, "Request to Reapply for Cash and Food Assistance" for Medicaid redeterminations, and failure to return the form does not have any impact on eligibility for Medicaid.

Training

Training will be conducted by the Office of Family Stability, Program Policy Services Unit. Additionally, telephone interview training materials, tips and online materials will be available. Questions about the new process or about telephone interviewing skills training or materials may be directed to the TANF_FSTA mailbox or county agencies may call 1-866-886-3537 (Option 6) for technical assistance.

INSTRUCTIONS:

Cash Assistance:

Food Assistance: