Applicant File Review Process - regional

1. Applicant File Review Process - regional 2013 Updates

2. Overview Content of presentation

3. Background & Timeline Brief history & review of changes to the applicant file review process

4. Background/Timeline

5. Policy Changes & form updates 13-02 and 13-04

6. Purpose of updates/modifications • Clarified policy language • Streamlined file review process • Broke procedures down into more process-oriented steps • Modified forms • Removed redundant steps • Administrative forms shortened • Assessment forms include step-by-step process • Included more guidance within the forms

7. Chapter 1 – Section 1.4Center Responsibilities in admission process • Specific list of information to be kept in the Records Department tracking log used to track applicant files in review • Added sub-section R4 • “New Information Review of Applicant Eligibility” • “New Information – Age (EAR A) and Income Eligibility (EAR D)/Disability Status

8. Chapter 1 – Section 1.5Regional office role in admissions process Restructured section to now include distinct components of the Regional review process Added “Notifications of Application Disposition” Distinguished between “Appeals” and “Complaints”

9. Appendix 107 • Added substantial amount of additional process language • Step-by-step guidance provided • Added guidance on recommendation of denial with consideration for admission at an alternate center • Administrative forms included in appendices and separated into 2 different forms • Process requirements moved into the assessment forms

10. Appendix 108 • Appendices restructured • Added a step by step process guide for a center recommendation of denial and separated into 3 segments • Review of Center Recommendation of Denial Based Upon Health-Care Needs, Direct Threat Assessment or Disability Status • Review of Center Recommendation of Denial Based Upon New Information • Review Process for Recommendations to Attend an Alternate Center • “Regional Applicant File Review Process Form” added for tracking of files in regional review

11. Forms Health care needs, direct threat, recommendations of denial, referral to alternate center

12. Health care needs

19. If Recommending ALTERNATE CENTER...

20. Referral for Alternate Center Form is completed by the respective Regional Health Specialist. • If the RD or designee is in concurrence, then this information is given to the AC to assist in assigning the next center. • The second center receives the denial paperwork and recommendations of the first center and proceeds to complete its own clinical review.

21. Center Recommendation of Denial for New Information

22. Files submitted with the New Information form remain at the Regional Office for review

23. Center Recommendation of Denial for Health Care Needs, Direct Threat, or Disability Status

24. Files submitted with this form are forwarded to the Regional Administrative File Review Coordinator

25. Regional Applicant File Review Process Form

26. Applicant file review Red Flags

27. Application outcomes 27

28. Do you remember? Center Standards Officer (CSO) or Student Personnel Office (SPO) What position used to be very involved in file review pre 2011 changes but now only has limited involvement in the rare instances of a new information review? Why?

29. Withdrawal Process during Center File Review – no application disposition recommended yet • There are two occasions when the center may send an applicant file back to OA to process as a withdrawal. • Applicant requests withdrawal. • Document request and return file to the Outreach and Admissions if a recommendation of denial has not yet been made. • The center is unable to reach the applicant to conduct clinically-related interviews. • Document the attempts to contact including collaborations efforts with OA and return the file to OA.

30. Withdrawal Process during Center File Review – File is in Regional Review • If the file has been returned to the center to complete any portion of the applicant file review process and the center is unable to reach the applicant, even with the AC’s assistance, then the file must be returned to the person/office that sent the center the file and not back to OA • If file is returned to the center to complete a process issue, then return it to Debbie Jones, Administrative File Review Coordinator, directly • If the file is returned to the center to complete a clinically-related issue, then return the file to your respective Regional Office

31. Withdrawal process Red flags

32. What are some of the top reasons files are returned to centers to complete some missing portion of the file review process?

33. Applicant file review Pitfalls & Red Flags • Reasonable Accommodation • Failed to complete the interactive process when there is documentation of disability in the file even though the applicant did not specifically request accommodations • Accommodation considerations within the assessment process that are not based upon the applicant’s symptoms and behaviors that are presenting the barriers to enrollment; instead, the focus is on testing or other IEP documented accommodations related to participation in the program, if enrolled. • Suggesting extreme accommodations to the applicant during the interactive process

34. Applicant file review Pitfalls & Red Flags • Assessments • Submitting more than one assessment, both health care needs and direct threat, when recommending denial • Considering case management supports as accommodations • File documentation contains potentially conflicting clinical information that has not been addressed

35. Regional review of applicant files PRH 1: 1.5, Appendix 108

36. Regional Review Process for Center Recommendations of Denial – Appendix 108 All applicant files received in the Regional Office are received and logged in and the “Regional Office File Review Process Form” is initiated by the Regional Office File Review Coordinator and attached to the file for tracking and monitoring purposes.

37. recommendation of Denial – Direct threat or health care needs • Step 1: Applicant file is received at Regional Office and logged into tracking log. • Step 2: The Regional Office File Review Coordinator reviews the center recommendation of denial form to determine the type of denial. • If the center has completed the “Center Recommendation of Denial Form Based upon Health Care Needs, Direct Threat Assessment, or Disability Status,” the Regional Office File Review Coordinator forwards the file to the Regional Administrative File Review Coordinator to complete an administrative (i.e., process) review of the file. • Step 3: If incomplete, the Regional Administrative File Review Coordinator returns the file to the center with guidance and instruction as to what part(s) of the process must be completed and/or what documentation is needed.

38. Recommendations of Denial – Direct threat or health care needs • Step 4: The Regional Administrative File Review Coordinator forwards the file to the appropriate RHS(s) for a clinical review (i.e., mental health, medical, dental, TEAP). • Step 5: The RHS documents his or her support or disagreement with the center’s recommendation, and the file is submitted to the Regional Director for a final determination. • Step 6: The Regional Director, or designee makes a final decision on application. • If supports the center’s recommendation for denial, a written decision is completed and issued to the applicant with notification of the application outcome to both the AC and the Center. The AC provides the appropriate referral information to the applicant. • If rejects a denial recommendation, the applicant’s file is returned to the center for the applicant’s enrollment.

39. Recommendations of Denial – recommend alternate center • Step 1:The Regional Director or designee reviews the recommendations of the RHS regarding a center’s recommendation of denial stating that an applicant’s health care needs can be met in Job Corps but requires that the applicant be assigned to a center closer to the necessary supports and services. • Step 2: If the RHS concurs with the center’s recommendation and the Regional Director or designee concurs, the Regional Office forwards this file back to the AC for assignment to an alternate center. • The Regional File Review Coordinator ensures that the following documents are included with the applicant’s file: • The Health Care Needs Assessment completed by the previous center which should be stored in the “Medical” information envelope. This assessment is included for the alternate center’s clinical staff to review. • The “Referral to an Alternate Center Form” which is completed by the RHS and guides the AC in selecting an appropriate alternate center to consider. • The original center is notified that the Regional Office has upheld their recommendation. • If the Regional Director or designee overturns the center’s recommendation, the AC and the center are notified and the center directed to enroll the applicant and the review process ends.

40. Recommendations of Denial – recommend alternate center • Step 3: The AC reviews the “Referral to an Alternate Center Form” and contacts the applicant to discuss and determine which alternate center the applicant is going to be conditionally enrolled. • Step 4: The AC forwards the applicant file along with the information identified in Step 2 of this section to the alternate center. • Step 5: The alternate center completes a clinical assessment to determine if the center can meet the applicant’s health care needs and to assess the applicant’s current stability. • If the center finds that it can meet the health care needs of the applicant at their location, the center schedules the applicant for enrollment. • If the alternate center believes that the applicant’s health care needs exceed those of basic care even with the access to local supports and services, then the center must complete its own Health Care Needs Assessment and submits the file to the Regional Office for review.

41. Recommendations of Denial – recommend alternate center • Step 6: The Regional Office logs receipt of the file and forwards it to the RHS who conducted the original review of the previous center’s recommendation to consider an alternate center. • Step 7: The Regional Director or designee makes a final decision on the application. • If the RHS recommends overturning the alternate center’s recommendation of denial and the Regional Director, or his or her designee, concurs, then the AC and the center are notified and the center directed to enroll the applicant. • If the Regional Director, or designee concurs, a written decision regarding the recommendation of denial is completed and issued to the applicant with notification of the application outcome to both the AC and the center. The AC provides the appropriate referral information to the applicant.

42. Recommendations of Denial – NEW INFORMATION Step 1: The Regional Office receives the applicant file that has been recommended for denial and logs it into the Regional Office tracking log. Step 2: The Regional Office File Review Coordinator reviews the center recommendation of denial form to determine the type of denial. If the center has completed the “Center Recommendation of Denial Form Based upon New Information,” the Regional Office File Review Coordinator forwards the file to the Regional Office staff person or persons designated by the Regional Director to complete the review of the file. Step 3: If the center has not provided all the required information or documentation, the Regional Office staff person contacts the center and obtains the missing information.

43. Recommendations of Denial – NEW INFORMATION • Step 4: The Regional Office makes a determination on the recommendation. • If the determination is to overturn the recommendation of denial, the applicant’s file is returned to the center with guidance to resume the applicant file review process. The center may complete a health care needs or a direct threat assessment, if appropriate, and resubmit the file to the Regional Office for review. • If the determination is to uphold the center’s recommendation, a written decision regarding the recommendation of denial is completed and issued to the applicant with notification of the application outcome to both the Admissions Counselor (AC) and the center. The AC provides the appropriate referral information to the applicant.

44. REASONABLENESS ACCOMMODATION RECOMMENDATIONS OF DENIAL

45. Accommodation recommendation of denial

46. Accommodation recommendation of denial

47. Reasonableness considerations • Job Corps does not deny applicants solely based upon the need to provide accommodation. The RAC would need to • explore funding options, • identify equally effective alternatives, if possible • likely offer the opportunity to enroll without the benefit of accommodation

48. Storage & transmission

49. Storage & Transmission • Center Recommendation of Denial Form • Cover letters • Center Tracking Forms • Accommodation Recommendation of Denial Form, if applies • Health Care Needs Assessment • Direct Threat Assessment • 6-53 • Medical Records • Anything health-related • IEPs & 504 Plans • Any non-medical disability-related information

50. Age waivers