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Question:
Can we accept verbal signatures during COVID-19 stay-at-home restrictions?
Answer:

Yes. Please see Procedure Letter #6 and ATL #271 regarding the Ohio Works First (OWF) program and CCMEP participants. Verbal signatures by phone are allowed for IOPs, CCMEP assessments, Eligibility applications (JFS 3002), and other required forms. Verbal signatures are also allowed for CCMEP participants as long as this is documented in case notes. This guidance also includes parent signatures for participants who are minors.

Verbal signatures should be documented in OWCMS in case notes using “On [Insert date] [Insert client name] provided a verbal signature to the [Insert form name(s)]. This verbal signature is in accordance with Action Change Transmittal Letter No. 271. A copy of the [Insert form name(s)] has been mailed to the client.”

Prior to accepting a verbal signature, case managers must read the contents of the IOP including rights, responsibilities and service/activity details. Following the acceptance of any verbal signature(s), a copy of the IOP, Eligibility application and/or CCMEP assessment must be mailed to the client.

For WIOA eligibility determination, the WIOA telephone eligibility verification form, JFS 13188, and the WIOA self-attestation form, JFS 13186 (which can be mailed) may be used to initially support eligibility documentation during COVID-19 stay-at-home restrictions. Additional remote methods to verify and document eligibility, specifically for items such age, birthdate, and citizenship, include systems such as Ohio Benefits. It’s best to avoid having individuals take photos and email in unless the case manager is certain they are using encrypted technology (to protect their personally identifiable information) which most participants are unlikely to have access to.

The case manager or applicant must document on the JFS 13188 or JFS 13186 which specific elements of eligibility are being attested (e.g., age, birthdate, authorization to work, income, barrier to employment, etc.) and how the applicant meets the eligibility criteria. A note should also be entered in OWCMS case notes with specific dates of conversations, communication method and details on what still must be collected. Although these forms can be used for many WIOA documentation requirements, source documents, per Attachment A of WIOAPL 15-07.2, must be collected as soon as possible after the stay-at-home period ends.

For TANF eligibility, the JFS 3002 allows individuals to self-attest income and family information. Any additional needed documents that cannot be verified via Ohio Benefits need to be collected as soon as possible after the stay-at-home period with a note entered in OWCMS case notes containing specific dates of conversations, communication method and details on what still must be collected.