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Access Regional Responsibilities in the Applicant File Review Process.

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Presentation on theme: "Access Regional Responsibilities in the Applicant File Review Process."— Presentation transcript:

1 Access Regional Responsibilities in the Applicant File Review Process

2 PurposePurpose To provide training on the regional review process and the interaction between regional, health, and disability teams. 2

3 OverviewOverview Transmission of Protected Data File Review Process (in- brief) –Outreach & Admissions –Center Regional Review –Process & Forms –Examples 3

4 PRH Resources Chapter 1 –Exhibit 1-1 New information –Appendix 107 File review process –Appendix 108 Regional Review Process Chapter 6 –Appendix 605 Reasonable accommodation –Appendix 607 Transmission and storage of protected information 4

5 TRANSMISSION OF PROTECTED DATA Center & Regional Paperwork, Health & Disability Data 5

6 Transmitting Forms & Documents PRH 6: Appendix 607 – Transmission of Medical, Health, and Disability-Related Information If hard copies are being transmitted, put medical, health, and disability-related information in a separate file, and place that file in a sealed envelope that is clearly marked as containing such information. You may want to consider using numbers, rather than names, on the outside of such envelopes to identify whose records they contain. 6

7 7 FILE A Regional Office File Review Process Form FILE B Center Recommendation of Denial Form If transmitting the file, which file shows what we would NOT do?

8 8 # Regional Office # Disability Confidential # Medical Confidential

9 Confidential Folder Inventory Typically identifies protected information collected and placed within the sealed medical and/or disability information envelopes. –Should not be stapled or glued to the outside of the medical or disability information envelopes. 9

10 APPLICATION OUTCOMES Options for applicant file reviews 10

11 Application Outcomes Enrollment Ineligible (OA) Applicant withdrawal Recommendation for denial (Center) –Direct threat –Cannot meet basic health care needs Refer to another more appropriate provider Consider admission to another center –New information (Requalification of eligibility) 11

12 Applicant Withdrawal – Appendix 107 Applicant requests withdrawal –OA or Center staff, dependent upon when the withdrawal is requested, documents the request. –If the center has the file, it must be returned to the Outreach and Admissions office if a recommendation of enrollment or denial has not yet been made. 12

13 Applicant Withdrawal - Center Level If the center has requested additional documentation about an applicant and it does not receive that information, the center must make a decision on the information that is available to it. If the center is unable to reach the applicant to conduct clinically-related interviews, then the center would document the attempts to contact and the file would be returned to Outreach & Admissions. If the application has entered the regional review process, then the region will process the withdrawal, administratively or follow-up (whatever they choose to do). –If a file has been returned to a center for completion of the file review process, then it must be returned to the regional office, regardless of inability to contact the applicant. 13

14 APPLICANT FILE REVIEW AT THE OUTREACH & ADMISSIONS LEVEL Processing Applications to the Job Corps Program 14

15 ESSENTIAL ADMISSIONS REQUIREMENTS (EAR S ) AC makes determination of eligibility based upon EARs from Exhibit 1-1 of the PRH. Eligibility options: –Once the AC has completed the EAR process, if the AC makes a decision that the applicant meets the essential admissions requirements, a conditional offer of enrollment will be made and the applicant will be assigned to a center. –At any point an applicant does not meet a particular EAR, the admissions process is stopped and the applicant is informed that s/he is ineligible for the program. 15

16 Regional – Quality Review On a monthly basis, the OA provider must submit no fewer than 5 percent of files of applicants denied admission to the Regional Office for a quality review. The quality review does not take place before the applicant is notified of the denial. 16

17 APPLICANT FILE REVIEW AT THE CENTER LEVEL Processing Applications to the Job Corps Program 17

18 Assessments & Requalification 18 Appropriate members of the file review team determine if a health care needs or a direct threat assessment is necessary or if there is a need to revisit the eligibility factors.

19 Direct Threat A direct threat assessment should be completed whenever center believes that an applicant poses a direct threat to the health or safety of himself or others. Assessment done by clinician Must use the appropriate form –See Appendix 609 (forms and guidance) 19

20 Health Care Needs The Health Care Needs Assessment should be completed if there is a concern that the center cannot meet the basic health care needs of the applicant. Assessment done by clinician Must use the appropriate form –See Appendix 610 (forms and guidance) 20

21 Requalification of Eligibility If the center becomes aware of new information that the AC could not have reasonably known (i.e. health information, clinical interview, etc.) that indicates that the applicant may not be eligible, then the center would 21 –revisit the set of questions from Exhibit 1-1 about that particular EAR and they may not apply additional qualifications. –determine eligibility based upon the responses to the same set of questions asked previously by the AC.

22 Age/Income – Disability Status There is no longer an age “wavier” process. Age is processed as an EAR. AC will not determine applicant is a person with a disability. The center clinical staff will do this. –The AC does not review health and medical information, only places it in a sealed envelope with applicant file that is forwarded to center for review. Center reviews documentation of disability and if a person with a disability, the file review process continues. If the center determines that the applicant is not a person with a disability, then the center submits to the regional office for review. 22

23 File Review Team Consideration of Reasonable Accommodation Review RAC Recommendations Direct Threat/Health Care Needs –Consider if accommodations and/or modifications would remove the barriers to enrollment by sufficiently reducing the threat to below a level of direct threat or eliminating the direct threat or would remove the barriers to enrollment and make condition manageable at Job Corps as defined by basic health services in PRH Exhibit

24 Application Recommendation Determine recommendation of application Any applicant file recommended for denial for -direct threat -health care needs -new information will be forwarded to the regional office for a final disposition. 24

25 REGIONAL REVIEW Processing Applications Recommended for Denial 25

26 Regional Office File Review Process Form When a center submits a file to the regional office, the Regional Office File Review Coordinator should add a REGIONAL OFFICE FILE REVIEW PROCESS FORM to the top of the file. Serves as the tracking record for the file through the regional review process. 26

27 27 Complete this section using the information from the Center Recommendation of Denial Form. ☒

28 Regional Review Process Applicant files recommended for denial should arrive at the regional office with a CENTER RECOMMENDATION of DENIAL FORM in a separate sealed envelope marked “Regional Office.” 28

29 29 Date File Received from OA:2/1/12Center:Northlands JCC Applicant Name:John DoeID#: Regional Office:Boston Date Submitted to Regional office: 2/26/12 File Review Team Participants: Name:Harry HarrisonPosition:HWM/DC Name:Lisa LongwoodPosition:CMHC Reason for Recommendation of Denial: ☐ 1. Applicant poses a direct threat to self or others that cannot be alleviated with reasonable accommodation. If so, the completed direct threat assessment form found in Appendix 609 of the PRH is attached to this document. Skip to Section C. ☐ 2. The health care needs of an applicant is beyond what the Job Corps’ Health and Wellness program can provide as defined as basic health care in PRH Exhibit 6-4: Job Corps Basic Health Care Responsibilities and cannot be eliminated or reduced by reasonable accommodation or modification. If so, the completed health care needs assessment form found in Appendix 610 of the PRH is attached to this document. Skip to Section C. ☐ 3. The applicant is ineligible for Job Corps due to the review of new information that the AC could not have reasonably known. Complete Section B only. Applicant File Review Center Recommendation of Denial Section A:

30 30 Date File Received from OA:2/1/12Center:Northlands JCC Applicant Name:John DoeID#: Regional Office:Boston Date Submitted to Regional office: 2/26/12 File Review Team Participants: Name:Harry HarrisonPosition:HWM/DC Name:Lisa LongwoodPosition:CMHC Reason for Recommendation of Denial: ☒ 1. Applicant poses a direct threat to self or others that cannot be alleviated with reasonable accommodation. If so, the completed direct threat assessment form found in Appendix 609 of the PRH is attached to this document. Skip to Section C. ☐ 2. The health care needs of an applicant is beyond what the Job Corps’ Health and Wellness program can provide as defined as basic health care in PRH Exhibit 6-4: Job Corps Basic Health Care Responsibilities and cannot be eliminated or reduced by reasonable accommodation or modification. If so, the completed health care needs assessment form found in Appendix 610 of the PRH is attached to this document. Skip to Section C. ☐ 3. The applicant is ineligible for Job Corps due to the review of new information that the AC could not have reasonably known. Complete Section B only. Applicant File Review Center Recommendation of Denial Section A:

31 Direct Threat If the center has selected direct threat as the reason for the recommendation of denial, then the regional office would forward the file to the regional administrative file review support staff person. 31

32 32 Date File Received from OA:2/1/12Center:Northlands JCC Applicant Name:John DoeID#: Regional Office:Boston Date Submitted to Regional office: 2/26/12 File Review Team Participants: Name:Harry HarrisonPosition:HWM/DC Name:Lisa LongwoodPosition:CMHC Reason for Recommendation of Denial: ☐ 1. Applicant poses a direct threat to self or others that cannot be alleviated with reasonable accommodation. If so, the completed direct threat assessment form found in Appendix 609 of the PRH is attached to this document. Skip to Section C. ☒ 2. The health care needs of an applicant is beyond what the Job Corps’ Health and Wellness program can provide as defined as basic health care in PRH Exhibit 6-4: Job Corps Basic Health Care Responsibilities and cannot be eliminated or reduced by reasonable accommodation or modification. If so, the completed health care needs assessment form found in Appendix 610 of the PRH is attached to this document. Skip to Section C. ☐ 3. The applicant is ineligible for Job Corps due to the review of new information that the AC could not have reasonably known. Complete Section B only. Applicant File Review Center Recommendation of Denial Section A:

33 Health Care Needs If the center has selected health care needs as the reason for the recommendation of denial, then the regional office would forward the file to the regional administrative file review support staff person. 33

34 34 Date File Received from OA:2/1/12Center:Northlands JCC Applicant Name:John DoeID#: Regional Office:Boston Date Submitted to Regional office: 2/26/12 File Review Team Participants: Name:Harry HarrisonPosition:HWM/DC Name:Lisa LongwoodPosition:CMHC Applicant File Review Center Recommendation of Denial Section A: Reason for Recommendation of Denial: ☐ 1. Applicant poses a direct threat to self or others that cannot be alleviated with reasonable accommodation. If so, the completed direct threat assessment form found in Appendix 609 of the PRH is attached to this document. Skip to Section C. ☐ 2. The health care needs of an applicant is beyond what the Job Corps’ Health and Wellness program can provide as defined as basic health care in PRH Exhibit 6-4: Job Corps Basic Health Care Responsibilities and cannot be eliminated or reduced by reasonable accommodation or modification. If so, the completed health care needs assessment form found in Appendix 610 of the PRH is attached to this document. Skip to Section C. ☒ 3. The applicant is ineligible for Job Corps due to the review of new information that the AC could not have reasonably known. Complete Section B only.

35 New Information If the center has selected new information as the reason for the recommendation of denial, then the regional office would look at the specific Essential Admissions Requirements (EARs) to determine how to proceed. Proceed to Section B. 35

36 36 Ineligibility Determination: Check the EAR from PRH 1, Exhibit 1-1 for which the applicant was found to be ineligible for the program. ☒ A.Age ☐ H.Child Care ☐ B.Selective Service Registration ☐ I.Program Suitability ☐ C.Legal U.S. Resident ☐ J. Group Participation and Understanding of Rules ☒ D.Low Income ☐ K. Interference with Other Students’ Participation ☐ E.Education/Training/Family Needs ☐ L.Community Relations ☐ F. Authorization for Use and Disclosure of Health Information ☐ M. Court Involvement and/or Agency Supervision ☐ G.Parental Consent ☐ N.Maintenance of Sound Discipline Section B:

37 Age/IncomeAge/Income Is EAR “A” and/or EAR “D” checked off due to a question of disability status? –If yes, then forward the file to the regional file review support person for a recommendation. –If no, then the regional office will determine if the applicant is no longer eligible due to some new information related to EARs “A” and/or “D” 37

38 38 Ineligibility Determination: Check the EAR from PRH 1, Exhibit 1-1 for which the applicant was found to be ineligible for the program. ☐ A.Age ☒ H.Child Care ☒ B.Selective Service Registration ☒ I.Program Suitability ☒ C.Legal U.S. Resident ☒ J. Group Participation and Understanding of Rules ☐ D.Low Income ☒ K. Interference with Other Students’ Participation ☒ E.Education/Training/Family Needs ☒ L.Community Relations ☒ F. Authorization for Use and Disclosure of Health Information ☒ M. Court Involvement and/or Agency Supervision ☒ G.Parental Consent ☒ N.Maintenance of Sound Discipline Section B:

39 All Other EARs (i.e. not “A” or “D”) If any other EAR is checked off other than “A” or “D” due to a question of disability status, then the regional office performs a requalification review (i.e. re-reviews the eligibility status of the applicant) to determine if they remain eligible for the program or not. 39

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42 Administrative File Review A regional disability support staff conducts an administrative review of applicant files when the center has recommended denial –because the applicant is believed to pose a direct threat; –because the health-care needs of the applicant are believed to exceed those provided by the Job Corps program –because the clinical staff did not find the applicant to be a person with a disability (for applicants whose age exceeds those required for Job Corps enrollment and/or the applicant met the income eligibility requirement as a family of one). 42

43 Administrative File Review The administrative file review is to ensure that all required procedures have been completed and all required documentation is included with the request. –If the file review process is incomplete or the documentation is insufficient, the file will be returned to the center with instructions as to what part(s) of the process must be completed and/or what documentation is needed. Regional Offices will establish procedures for the review of files submitted for recommendation of denial based upon new information in accordance with all stated PRH requirements. 43

44 Regional Office File Review Process Form – Administrative Review 44 ☐ Yes ☐ No Returned to CenterDate Sent: Date Ret.: ☐ Yes ☐ No Returned to RegionalDate Sent: RHS: Date Sent: See attached comments Administrative Review:

45 Administrative File Review – Health Care Needs Assessment 45 The center’s recommendation for denial is one of the following: ☐ ☐☐ ☐ 1.The applicant’s health care needs are manageable at Job Corps as defined by basic health care services in PRH Exhibit 6-4, but require community support services which are not available near center. Applicant should be considered for center closer to home where health support and insurance coverage is available. 2.The applicant’s health-care needs are not manageable at Job Corps as defined by basic health-care services in PRH Exhibit 6-4. Applicant has health condition with current symptoms at a level that will interfere with successful participation in the program at this time. Deny entry and refer to other appropriate program/provider. ☐ Yes ☐ No ☐ N/A ☐ See comment s A.Did a licensed health professional complete the medical assessment as required by PRH 6, Appendix 610? ☐ Yes ☐ No ☐ N/A ☐ See comments A.If reason #1 for denial is checked, is there documentation in the file of center’s efforts to arrange for less frequent treatment in home state and/or to secure community support services near the center? ☐ Yes ☐ No ☐ N/A ☐ See comments A.Does the center or specific documentation indicate that the medical condition rises to the level of disability? If not, skip to F.

46 Clinical Review Once the administrative review is complete, the regional disability support staff person forwards the file to the appropriate regional health specialists for a clinical review (i.e., mental health, medical, dental, TEAP). The regional health specialist 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. 46

47 Regional Office File Review Process Form – Clinical 47 Reviewer: Date Rec’vd: ☐ Yes ☐ No Returned to CenterDate Sent: Date Ret.: ☐ Yes ☐ No Forwarded to RHS:Date Sent: ☐ Yes ☐ No Forwarded to RegionalDate Sent: ☐ Yes ☐ NoSupport Recommendation (see attached comments) Regional Health Specialist Review:

48 Regional Director’s Decision The Regional Director (or designee) makes final decisions on any applicant recommendations of denial. The Regional Director may –either uphold the file review team’s recommendation of denial or he or she may overturn it. If the Regional Office supports the center’s recommendation for denial, a written decision regarding the recommendation of denial must be issued by the Regional Office within 60 days of the date on which the file was received. If a Regional Office rejects a denial recommendation, and the applicant’s file is returned to the center for the applicant’s enrollment, that applicant must be scheduled for arrival based on the date on which the application first arrived on center, not the date that it was returned from the region. 48

49 Regional Office File Review Process Form – Final Disposition 49 Regional Director or Authorized Representative: ☐ Eligible for Enrollment*Date: ☐ IneligibleDate: ☐ Approved for EnrollmentDate: ☐ DisapprovedDate: ☐ Administrative - RO withdrawal of application**Date: ☐ Applicant requested withdrawal of application File Returned to CenterDate File Returned to OADate Regional Office Final Disposition:

50 File Flow Regional Office receives file and if Health Care Needs or Direct Threat, sends the file to disability support staff for an administrative review. Disability Support Staff either returns the file to the center for completion of the process, if necessary, and once complete sends that on to a regional health specialist. –If the concerns are mental health related, then it is sent to a Regional Mental Health Specialist. –If the concerns are medical/substance, it is sent to one of the two Regional Nurse Specialists who triage and then forward it on to one of the medical doctors, dentists, or substance health specialists. The Regional Health Specialists makes a recommendation to the Regional Director. 50

51 REASONABLENESS REVIEW Processing Accommodation Recommendations of Denial 51

52 Accommodation Reasonableness Complete reasonableness review if the center director believes that the provision of the requested/agreed upon accommodations are unreasonable. -Unduly costly -Result in a fundamental alteration to the program Complete the Accommodation Recommendation for Denial and Justification Analysis Documentation Form (See Program Instruction 11-16). 52

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55 Remember!Remember! 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 55

56 LET’S PRACTICE! Conducting a Requalification Review 56

57 New Information Case Study Student John Doe 57 Ineligibility Determination: Check the EAR from PRH 1, Exhibit 1-1 for which the applicant was found to be ineligible for the program. ☐ A.Age ☐ H.Child Care ☐ B.Selective Service Registration ☒ I.Program Suitability ☐ C.Legal U.S. Resident ☒ J. Group Participation and Understanding of Rules ☐ D.Low Income ☐ K. Interference with Other Students’ Participation ☐ E.Education/Training/Family Needs ☐ L.Community Relations ☐ F. Authorization for Use and Disclosure of Health Information ☐ M. Court Involvement and/or Agency Supervision ☐ G.Parental Consent ☐ N.Maintenance of Sound Discipline

58 Exhibit

59 Exhibit

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61 John Doe (cont.) 61 Please list the specific question from Exhibit 1-1 which the applicant was determined to be ineligible and list the applicant’s specific response to this question. I – Are you attending school? Are you taking medication? J – Can you work with teachers, follow directions? Identify the new information that the AC could not have reasonably known that was the basis for revisiting eligibility (i.e. document name and where the document was located, applicant stated during a specific interview, etc.).* IEP Summarize your findings. John exhibits threatening behavior in school setting and has needed to be placed in a therapeutic, restrictive setting to control his behavior. He continues to be unable to respect teachers authority. He could not answer basic questions – his mother answered for him. He could not control emotions while participating in phone interview.

62 CAUTION!!!CAUTION!!! You may not broaden, add, or expand the eligibility criteria beyond what is stated in Exhibit 1-1. The questions/criteria from Exhibit 1-1 are intended to elicit “up/down” responses (i.e. yes or no). 62

63 Exhibit 1-1 I. Program Suitability 1a. If the applicant has not graduated from high school: –The applicant wants to earn a high school diploma or GED and participate in career technical training (the applicant must indicate a desire to obtain both academic and career technical training); and –After graduation from Job Corps, the applicant intends to: a. Obtain employment; or b. Enter the military; or c. Continue his or her education. 1b. If the applicant is a high school graduate: –The applicant wishes to obtain career technical training; and –After graduation from Job Corps, the applicant intends to: Obtain employment; or Enter the military; or Continue his or her education. The applicant is able to complete/answer basic Job Corps application questions (e.g., birth date, address, phone number, last school attended, last grade completed) with or without reasonable accommodation. 63

64 Exhibit 1-1 J. Group Participation & Understanding of Rules The applicant appears to acknowledge authority. The applicant expresses or demonstrates willingness to follow directions. The applicant appears willing to live in a multicultural environment. The applicant appears willing to function as a part of a group. 64

65 J. Guidance Ask the applicant: Do you understand that if you are accepted into Job Corps, you will be expected to comply with the rules and regulations of Job Corps? For example, if you live on center, you will have to follow a curfew, your center may have rules about cell phone use, you may not be permitted to smoke on center, and you may be required to wear a uniform. Ask the applicant: Knowing this about Job Corps, are you willing to go forward with your application? 65

66 J. Guidance (cont.) Multicultural Environment: Applicant either expresses willingness or does not express active hostility to or dislike of living in a multicultural environment. Provide the applicant with an example of a multicultural environment. For example, ask the applicant: –Do you understand that if you are admitted to Job Corps that you will be living and working with members of various races, ethnic groups, political or religious affiliations or beliefs, sexual orientations, gender identities, and people with disabilities? Ask the applicant: Knowing this about Job Corps, are you willing to go forward with your application? 66

67 J. Guidance (cont.) Team Player: Ask the applicant: Do you understand that in order to succeed in Job Corps, you will need to function as part of a group? For example, you will share a dormitory room, you will be responsible for cleaning your living area, and you will need to rely on staff and other students to complete tasks and assignments. Ask the applicant: Knowing this about Job Corps, are you willing to go forward with your application? 67

68 Let’s Assess Does the center list appropriate/accurate criterion from Exhibit 1-1 on the Center Recommendation of Denial Form and/or did the center staff ask the questions as directed via Exhibit 1-1? 68 Please list the specific question from Exhibit 1-1 which the applicant was determined to be ineligible and list the applicant’s specific response to this question. I – Are you attending school? Are you taking medication? J – Can you work with teachers, follow directions? No. –Are you attending school or taking medication are not criteria from Program Suitability. –Can you work with teachers, follow directions is not a question from Group Participation.

69 What Now? What other information did the center provide that was critically important eligibility-wise? 69 Summarize your findings. John exhibits threatening behavior in school setting and has needed to be placed in a therapeutic, restrictive setting to control his behavior. He continues to be unable to respect teachers authority. He could not answer basic questions – his mother answered for him. He could not control emotions while participating in the phone interview. The center should have listed the specific question from EAR I. Program Suitability – Is the applicant able to complete/answer basic Job Corps application questions (e.g., birth date, address, phone number, last school attended, last grade completed) with or without reasonable accommodation?

70 Final Determination The center should have asked the exact same set of questions from EAR J and if any of the responses were not affirmative, listed those as well. So, the million dollar question: Is this applicant still eligible or not? –No, they would not be eligible based upon the EAR I: Program Suitability. However, the documentation is not drafted correctly and that is simply a training issue. 70

71 Other options? What else could have possibly been done if the applicant remained eligible? –There were very concerning behaviors noted in the narrative documentation of the IEP. –The individual was living in a therapeutic environment. –The individual became verbally aggressive to his mother during the interview. The center might wish to consider the need for either a Health Care Needs Assessment or Direct Threat Assessment to be completed. 71

72 72 Center submits file with supporting documentation and recommendation of denial to the regional office for review. Regional office logs receipt of the file and reviews reason for recommendation of denial. Reason is new information? Reason for denial is direct threat or health care needs? No Disability Review for Age and/or Income? Yes Yes No No Regional office staff will review and make determination in accordance with all stated PRH requirements. Reason for denial must be either due to (1)new information (2)direct threat or (3)health care needs. Regional office would return file requesting reason for recommendation of denial. Regional office forwards to regional disability support staff to conduct an administrative review. Yes

73 73 Regional office forwards to regional disability support staff to conduct an administrative review. Process complete? Administrative reviewer returns file to center with instructions for completing. No Yes Center returns file and additional information to administrative reviewer. Administrative reviewer moves file to appropriate regional health specialist for clinical review (i.e. mental health, medical, dental or TEAP), Regional health specialist makes recommendation to regional director. RD or designee concurs with recommendation to deny? Center notified to accept applicant, inform applicant of acceptance, and schedule and arrival date. (See Note 1) No Applicant notified of denial decision, provided information on appeal/complaint process. Yes

74 RESOURCESRESOURCES Job Corps and Partners 74

75 National Office Resources Health & Disability –Carol Abnathy - National Office of Job Corps (202) – –Johnetta Davis – National Office of Job Corps (202) – Outreach & Admissions –Wendy Manning – National Office of Job Corps (202) – 75

76 Questions/Concerns?Questions/Concerns? For clinical/health, dental, and substance-related questions –Regional Health Specialists For file review questions in the admissions or center, regional process –Regional Disability Coordinators For file review questions related to a specific file or case –Disability Program Analyst (Regional Administrative File Review Support Person) 76

77 Job Corps Disability – Process Resources 77

78 Job Corps Health & Wellness HCN/DT Resources 78


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