Background
Ohio approved verbal signatures and an extension of certification
periods for the Comprehensive Case Management Employment Program (CCMEP) in Procedure
Letter #6, dated March 30, 2020, after 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 residents of Ohio from COVID-19. The State of Emergency was lifted
on June 18, 2021, and this policy flexibility ended on July 30, 2021.
Verbal Signatures
With the COVID-19 infection rate increasing over the last two months,
and local workforce development areas and CCMEP lead agencies continuing to adapt
to challenges arising from the COVID-19 pandemic, Ohio is renewing the policy flexibility
of accepting verbal signatures effective immediately for all volunteer CCMEP participants
who are not Ohio Works First (OWF) Eligible. If necessary,
case managers will have a period of up to 90 days to allow areas, lead agencies
and youth service providers more time to obtain an electronic signature,
photocopy of signature or wet signature for required documentation.
This CCMEP procedure letter confirms that verbal signatures by phone
are allowed for all volunteer CCMEP applicants/participants as long as they are
not an OWF Work Eligible. These volunteer applicants/participants
may verbally sign Individual Opportunity Plans (IOPs), CCMEP assessments, eligibility
applications (JFS 3002), and other required forms under Ohio Administrative Code
rule 5101:14-1-04, 5101:14-1-05, and WIOAPL 15-07.2, including the JFS 13186, Self-Attestation
and the JFS 13187 Citizenship Status/Authorization to Work Self Attestation. Case
managers must obtain an electronic signature, photocopy of signature or wet signature
for required documentation within 90 days of accepting a verbal signature.
These documents may thereafter be utilized as documentation for WIOA
Youth or CCMEP TANF eligibility criteria. Within this self- attestation, the individual
must document which specific elements of eligibility he or she is attesting (e.g.,
age, birthdate, authorization to work, income, barrier to employment, etc.) and
how he or she meets the eligibility criteria.
For any criteria where self-attestation is not permitted in accordance
with Attachment
A of WIOAPL 15-07.2 such as age/birthdate, source documentation
must be collected from the participant within 90 days or verified through another
source.
Case notes must be entered in Ohio’s workforce case management system
with specific dates of conversations, communication method, and details on what
documentation must still be collected. Verbal signatures should be documented in
Ohio’s workforce case management system in case notes using “On [Insert date] [Insert
client name] provided a verbal signature to the [Insert form name(s)] via [Insert
communication method]. A copy of the [Insert form name(s)] has been mailed to the
client. The reason a verbal signature was necessary is because [Insert reason/justification]”
Prior to accepting a verbal signature, case managers must read the
contents of the form including any rights and responsibilities. Following the acceptance
of any verbal signature(s), a copy of the relevant form must be mailed to the client.
Electronic Documents and Signatures
Please note that case managers may accept electronic documents and
signatures from clients. Any documentation gathered electronically must be done
in a manner that is secure and encrypted to protect a client’s personally identifiable
information (PII). Please refer to Section VI(D) of WIOAPL 15-07.2 for guidance on the handling and protecting
of PII.