Background:
The United States Department ofa*griculture, Food and Nutrition Service (FNS) issued guidance to assistSupplemental Nutrition Assistance Program (SNAP) State agencies planning forthe expiration of the federal public health emergency (PHE). Previous waiverauthority during the COVID PHE was a result of the Families First CoronavirusResponse Act (FFCRA) and allowed states to adjust issuance methods and applicationand reporting requirements while the PHE was in place. As the PHE comes to end,the FFCRA-allowed adjustments for states will also come to an end.
FNS recognizes thatstates may continue to require some flexibilities to aid in application processingwhen the PHE ends, especially due to Medicaid unwinding requirements which willimpact State workload capacity and resources. To further support SNAP Stateagencies and SNAP recipients, FNS is offering administrative waivers for up totwelve months for certain processes once the PHE ends. Additionally, States canchoose to implement these waivers before the PHE ends for up to 12 months toprovide flexibility in addressing the needs of caseloads and otheradministrative challenges.
Ohio applied for and was approved forthe administrative unwinding waiver for SNAP which allows the recertificationinterview to be waived at a county option. This waiver will begin in March 2023and will last for 12 months. Counties will have the choice to opt into the waiverfor the first six months of the waiver; then have the choice to opt in or outfor the following six months.
Please find corresponding updates below:
Updated Procedures:
Recertification Application Interviews
Effective March 1, 2023 – February 29, 2024, a county agency canopt to not conduct an interview at recertification prior to approving SNAPbenefits, provided the following are met:
- A JFS 07204 “Request to Reapply for CashAssistance, SNAP and/or Child Care” form (or equivalent in the Ohio BenefitsSelf-Service portal) has been received;
- The applicant’s identity has beenverified;
- All other mandatory verifications in paragraphs(D) and (E) of rule 5101:4-2-09 of the Ohio Administrative Code (OAC) have beencompleted.
- A county agency shall obtain verifications(including electronic sources); if documentation is not able to be obtained,the county agency may use a collateral contact. If neither documentation nor acollateral contact can be obtained, client statement may be used. Case notesmust clearly document the verification used to make an eligibilitydetermination.
- A county agency is required to contact theapplicant if any information on the application is questionable or ifverification is incomplete. Contact can be done through a phone call forquestionable information. Verifications must be requested by mailing a JFS07105 “Application/Reapplication Verification Request Checklist.”
- If an individual requests an interview, thecounty JFS office must complete an interview.
- Recertifications conducted through telephonic applicationswill still require an interview because of the nature of what is needed to becaptured during a telephonic signature. Since the signature for atelephonic application is a summary of what the individual attests to duringthe interview, the interview must still be conducted to gather the necessaryinformation to determine eligibility for the individual to be able to attest tothat information.
Choosing to Implement the Waiver
A county will need to inform Program Policyand Systems (PPS) if it will implement this option by sending an email to OFA-PPS@jfs.ohio.gov by the following dates:
- To opt in for the first6 months (March 2023 – August 2023), the county must notify PPS by January 20, 2023.
- To opt in or out forthe second 6 months (September 2023- February 2024), the county must notify PPSby July 20, 2023.
When opting into this waiver, it will apply to both SNAP andcash assistance programs. Action ChangeTransmittal letter #293 outlines this waiver option for cash assistance.
Oral Consolidated Notice and ReportingRequirements
Effective March 1, 2023 – February 29, 2024, since an interviewis able to be waived at recertification, the county is not required to providean oral explanation of work requirements to the assistance group atrecertification. The written JFS 07405 “SNAP Work Requirements Notice” consolidatednotice must still be sent.
Additionally, county agencies who have chosen to waiverecertification interviews are not required to verbally notify assistancegroups of how simplified reporting works and reporting requirements.
Requirement to Screen for SNAP Employmentand Training (E&T)
When a county opts to waive the recertification interviewrequirement, this does not waive the requirement that individuals are screenedfor participation for SNAP E&T. The county agency is able to identify workregistration exemptions based on age, receipt of disability, Ohio Works First(OWF) or unemployment compensation, and others that are identifiable based oninformation known in Ohio Benefits.
For other possible exemptions, like caring for a disabledindividual or pregnancy, additional questions were added to capture this on theJFS 07204 “Request to Reapply for Cash Assistance, SNAPand/or Child Care” form. Counties are required to view this information onthe JFS 07204 and if it appears an individual is required to participate, thecounty agency is required to schedule a SNAP E&T appraisal with theindividual.
Implementation:
The JFS 07204 “Request to Reapply for Cash Assistance, SNAPand/or Child Care” form has been amended to capture as much information aspossible in order for a caseworker to determine eligibility without needing tocontact the client. All SNAP recipients will be sent the amended version of theJFS 07204, not just the recipients in counties who have waived the interview.Ohio Benefits has been updated to include a table of counties who opt into theinterview waiver to ensure an appointment is not scheduled and a notice is notmailed.
If you have questions regarding any of the information, pleasereach out to PPS by sending an email to OFA-PPS@jfs.ohio.gov.
