Applicant File Review Center Process January 2016

2 Policy/Background

The Team Applicant File Review Policies It is critical that you familiarize yourself with all of the Applicant File review (AFR) policies. Read, re-read, review, re-read and reference. 3 PRH Appendix 107 Chapter1 Section 1.4

AFR Standard Operating Procedure (SOP) Each center is required to have a written SOP for AFR. The SOP must describe the center’s AFR process in detail (i.e., how an applicant file is processed from the time it arrives on center until the applicant is either: accepted into the program and assigned a start date, or recommended for denial and a final disposition made by the Regional Office. 4 SOP Requirements: Method of tracking and logging of the file from arrival to the center to the final disposition Responsibilities and roles of File Review Team (FRT) members Procedures for reviewing an applicant file to include the allowable reasons for recommending denial of an application (see “Application Outcomes”) Procedures for reviewing and determining reasonable accommodation

Sample SOP Job Corps Disability Website Disability Frequently Requested Documents Sample Policies 5 Recommendation: Use the sample AFR SOP from the JC Disability Website!!!

6 Application Outcomes

7 Center enrolls applicant. ENROLLMENT Applicant’s health care needs exceed those of basic health care. RECOMMENDATI ON OF DENIAL Application Outcomes Applicant poses a direct threat to self or others. RECOMMENDAT ION OF DENIAL Applicant may no longer be eligible due to new information that the AC could not have reasonably known at the time of eligibility certification. RECOMMENDAT ION OF DENIAL

Withdrawals of Application Applicant is processed as a withdrawal: 1.Applicant states or puts in writing that s/he is no longer wishes to enroll in the program. 2.The clinical team cannot reach the applicant, even with the AC’s assistance, to complete the clinical interview or the DCs cannot complete the required interactive reasonable accommodation process. Center must contact the AC to check for possible new contact info/obtain status information. This contact must be documented. 8

Withdrawals of Application If the applicant file is in regional review and the file has been returned to the center to complete any portion of the AFR process: The center is unable to reach the applicant and the clinical team cannot reach the applicant, even with the AC’s assistance, to complete the clinical interview or the DCs cannot complete the required interactive reasonable accommodation process; the file must be returned to the person/office that sent the center the file and not back to AC. 9

AC Requesting Return of Applicant File in Center Review If the AC requests the center return an applicant’s file, should the center automatically do so? It depends… The center has custody of the applicant file and responsibility for making a decision on that individual’s application to the program. So, the center should only release a file back to the AC when it has been requested via appropriate policy allowances. Obtain written requests for the file via that you can retain as documentation of why the file was returned. ACs may do the same of you when you return files to them! 10

Documenting Inability to Contact Applicant Where? Up to you but somewhere within the applicant file Suggested: Use a case note page or sheet Include date of contact Medium of contact Outcome of contact Give a reasonable call back by date if able to leave a message 11

Inability to Contact Documentation Sample 1.“CMHC left message for applicant on 10/10/15 at 10:20 a.m. asking him to call regarding his application to Job Corps.” 2.“CMHC left message for applicant on 10/13/15 at 12:40 p.m. asking him to return call by 10/21/15 regarding his application to Job Corps.” 3.“HWM contacted AC, Moe Smith, via phone on 10/22/15 after center was unable to reach applicant and AC states he will make effort to contact applicant but that he has no new contact information available.” 4.“AC called HWM/DC on 10/24/15 and reports that he has attempted to reach the applicant and has been unable to do so as well.” 12

Timelines Processing Applicant Files

Timelines The applicant’s file must be processed within 30 calendar days from receipt by center. If the center reasonably can substantiate needing the file longer than 30 days to complete the file review process, then an extension request may be submitted to the respective Regional Office, specifically to the center’s Program Manager. 14

15 Applicant File Review (AFR) Tracking Records Department Responsibilities

Responsibilities of Records Staff in AFR The records department is the gatekeeper of all applicant files must maintain a single ongoing log that contains all the PRH requirements that must be tracked 16

Applicant File Review Log The log must contain: The date the file arrived on center To whom each file was sent and the position How long a file has been with a particular department or staff member How long the file has been on center Notes/explanation of any delays in the process The disposition of the file 17 Recommendation: Use the sample AFR Tracking Log from the JC Disability Website!!!

Potential Compliance Issues! Not tracking all of the required components that the PRH requires. Failing to clearly document tracking of applicant file review process. Amount of time applicant file is in review. Final disposition of the application process. Returning files to the AC improperly, whether requested by the AC or not. Collateral effects of this action may result in Bypassing the Regional Office review of applicant files. Potentially denying applicants a final adjudication of their application. Applications ending up at other centers requiring other clinical teams to process the applicant’s file. 18

Sample Disposition Statements Acceptable or not? File requested by the AC. File returned to the AC. Applicant has been arrested and is in jail so the file was returned to the AC. Returned to AC due to insufficient medical documentation (no subsequent entries). Applicant sent dated 8/20/15 and received by J. Moon, HWM, stating she no longer wished to enroll in Job Corps. File is being ret. to AC on this date to process as a w/drawal. 19

Sample Disposition Statements Acceptable or not? File sent to Regional Office (RO) on 8/30/15 as rec. of denial; File received back on 9/10/15 from RO to complete process; FRT nor AC could reach applicant so file is being ret. to AC on 9/20/15 to process as a w/drawal. Applicant is hospitalized. Applicant called center on 7/25/15 and spoke to N. Star, TEAP Counselor, stating that he had changed his mind and did not want to come to a smoke- free center. File returned to AC on 8/7/15 to process as a w/drawal. 20

Quick Check! How many “official” logs must the center maintain? Only one that contains all of the log requirements listed in the PRH! Is it acceptable to delete entries once an applicant is accepted or a file has been returned to the AC or a submitted to the regional office? No! The center must maintain ongoing records of its applicant file tracking documentation. May start a new log each PY but need to keep 2-3 years of records. 21

22 Best Practices

Use cover memos when returning files to AC.As you have learned, there are few reasons that a file may be returned to AC as per JC policy. Use a memo with these reasons listed, checking the specific reason and maintain this documentation. Maintain documentation to support reasons for returning files to AC, when available. If log says that that the AC requested a file to be returned, then print out the and maintain with the log documentation. If requested via phone, best practice would be to request an but document date and circumstances as to why AC was requesting file to be returned. 23

24 Sample Return to AC Memo

Process Teams Applicant File Review & Reasonable Accommodation AFR & RAC

Process Teams within AFR There are (2) process teams within the file review process: 1.File Review Team (FRT) 2.Reasonable Accommodation Committee (RAC) May include some of the same individuals on each team Typically fluid in composition Roles and functions are different 26

Center Applicant File Review Process PRH 1: 1.4, Appendix 107

28 Applicant File Review Process 3. File is received on center by the records staff who record the file in the records log and tracks its movement. Records forwards the sealed medical, health, or disability-related information unopened to the Health and Wellness Manager (HWM). STEP 1 STEP 2

29 3. Applicant File Review Process The HWM completes a review of the “Job Corps Health questionnaire (ETA 653)” and the medically related documentation to determine: The health care needs of the applicant and whether JC can meet those needs, and If the applicant presents a direct threat to self or others. The HWM determines who else may need to review the protected information based upon the determination of “need to know.” This is your File Review Team (FRT)! STEP 3 STEP 4

File Review Team (FRT) Review relevant parts of the applicant’s file based upon the Health and Wellness Manager’s (HWM’s) initial triage of the file and based upon a “need to know.” This is your clinical review! Make recommendations to the center director to accept or recommend denial of an applicant. Does NOT determine accommodation needs of the applicant. 30

Identification of the File Review Team Who should be the typical participants of the file review team? Center Mental Health Consultant (CMHC) reviews mental health-related information Center Physician reviews medical information Center Dentist reviews dental information TEAP Specialist reviews substance-related information Academic Manager reviews IEPs, 504 plans, educational reports including special education assessments 31

Identification of the File Review Team Which center positions should have a limited and infrequent role, typically, on the FRT team? Center Standards Officer (CSO or sometimes referenced as CSIO or SPO on some centers) Which center positions should not have a role on the center’s FRT related to the decision-making process of accepting an applicant or not? Counseling Manager Records Manager 32

33 Applicant File Review Process Applicant File Review Process If there is no health-care needs or a direct-threat assessment necessary, schedule the applicant for enrollment. The members of the FRT determine if a health care needs or a direct threat assessment is necessary or if there is a need to revisit the eligibility factors. STEP 5

Health Care Needs (HCN) and Direct Threat (DT) Assessments HCNA – Appendix 610 The HCNA should be completed if there is a concern that the center cannot meet the basic health care needs of the applicant MUST be completed by a clinician MUST use the required form and ensure it is the most current one DTA – Appendix 609 A DTA should be completed whenever center believes that an applicant poses a direct threat to the health or safety of himself or others MUST be completed by a clinician MUST use the required form and ensure it is the most current one 34

35 Appendix 609 Direct Threat Assessment

36 Appendix 610 Health Care Needs Assessment

Reasonable Accommodation in the Assessment Process Policy, Process and Considerations

38 Applicant File Review Process When completing the DTA or HCNA for an applicant with a disability, the reasonable accommodation committee (RAC) must convene to consider reasonable accommodation (RA). STEP 6

Reasonable Accommodation Committee (RAC) Review and discuss potential accommodations with the applicant as part of the Health Care Needs or Direct Threat Assessments. Recommends accommodations and modifications to the FRT. Does NOT make decisions about enrollment. 39

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Appendix 605 Reasonable Accommodation (RA) Process Who is a person with a disability? Has a physical or mental impairment that substantially limits a major life activity. Some conditions essentially always considered a disability. Term “substantially limits” should be construed broadly in favor of expansive coverage. Does not require extensive documentation. ONLY talking about RA related to the denial assessment process here!! 41

RA in the Assessment Process The DC and the applicant MUST be involved in the RA review as per the PRH. The DC is the coordinator of the reasonable accommodation process; therefore, this individual must lead this portion of the assessment process. Other clinicians may participate/make recommendations as they wish and as time permits and are strongly encouraged to do so. 42

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Potential Compliance Issues! If the applicant is a person with a disability, you must check one of the two boxes: RAC unable to ID… The following accommodations/modifications listed below… 44

RAC has been unable to ID any RA When do you think you should be checking this box? (Must always make the determination on a case by case basis.) True or False: The DC or RAC is able to identify RA but does not think they will be sufficient? Applicant is experiencing symptoms which impairs his/her judgment such that they could not reasonably participate in the decision-making process to determine RA even if given RA to assist with participation. Applicant has significant history of self-harm or self-harm attempts coupled with recent events that have been increasing in either frequency and severity or both. Applicant has single incident of self-harm with ER visit but no resulting hospitalization and no previous history. 45

Potential Compliance Issues! Applicant medication or medical care non-compliance, in and of itself is not a basis for not considering reasonable accommodations (RA). AFR typically is comprised of 2 main segments: 1.Compliance with the medical or mental health condition is the case management part (FRT function to consider) 2.Accommodation determination and consideration is the removal of barriers/access part (RAC’s function to develop, consider, and review with applicant) An applicant might not choose to take a certain med but could still benefit from an accommodation. The applicant still has to comply with core center rules, etc. For example, an applicant has swelling of the lower extremities and has not been following recommended medical protocols. There are still accommodations that can be considered. Whether they are sufficient enough to allow for enrollment is the completing clinician’s determination to make. 46

How to ID RA! 1.Look at the functional limitations or behaviors in item #3 of the HCNA or in item #1 of the DTA. 47

How to ID RA! 2.Now go to item #5 and ID RA related to each functional limitation/behavior checked in item #3 of the HCNA or #1 of the DTA. 48

Yes/No Boxes in #5 of Assessment Form Completing the check boxes: Checking “yes” means that the applicant was offered the specific accommodation and accepted it. Checking “no” means that the applicant was offered the specific accommodation and rejected it. Leaving the box blank means the accommodation was not offered and/or discussed because it was not appropriate or necessary. 49

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Potential Compliance Issues! Again, if the applicant is a person with a disability, ensure that the DC’s name, usually the HWM/DC, is listed in the RAC participant’s section. Technically, the RAC has to convene to decide that it cannot ID RA; otherwise, it could appear as if the clinician completing the assessment arbitrarily made the decision instead of the RAC. Remember, 2 teams – FRT and RAC! 51

52 Applicant File Review Process Then the licensed clinical professional completing the assessment considers whether or not accommodations would sufficiently remove the barriers to enrollment. The licensed clinical professional makes a final decision based upon the findings of the assessment. STEP 7 STEP 8

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Referral to an Alternate Center 54

Local Resources Consideration within HCNA Explore the local resources in the vicinity of the center to determine if the applicant’s basic health care needs could be met Document resources explored/considered and how needs could not be met, if that is the finding Contact the treating provider and discuss applicant’s needs and see if treating provider recommends less frequent treatment or monitoring Document efforts to arrange for less frequent treatment in home state Consider if health care needs possibly could be met if applicant were to attend a center closer to home where health support and insurance coverage is available 55

Quick Check! Is it appropriate to recommend denial with a referral to an alternate center: If you are completing a DTA? If the applicant’s insurance coverage is for a different state but the center does have adequate local resources? If the applicant’s basic HCN could be met an another center but the reviewing center can demonstrate that it does not have the appropriate local resources to serve the applicant? 56

57 Applicant File Review Process Any applicant file recommended for denial is to be forwarded to the Regional Office for review and final determination of the application status. STEP 9

Regional Review Preparing an Applicant File for Regional Review

Preparing a File for Regional Review If the center is going to recommend denial of the applicant, then it must 1.Complete the appropriate Center Recommendation of Denial Form (CRDF) 2.Place the CRDF form in a large envelope and label the outside as follows: Applicant’s ID # “Regional Office” 3.Place the assessment, health care needs or direct threat assessment, and all other medical/disability information into a large envelope labeled: Applicant’s ID # “Medical – Confidential.” 59

Regional Office Denial Packet Contents 60 # REGIONAL OFFICE # ADMISSIONS # MEDICAL CONFIDENTIAL

Center Recommendati on of Denial for HCN, DT & Disability Status 61

Regional Office Review Process for HCNA & DT Assessment Reviews When the center submits an applicant file to the Regional Office with a recommendation to deny based upon the applicant’s HCN or because the applicant poses a DT, there is an administrative review to ensure that required processes are followed, and a clinical review to make sure health documentation supports clinician's recommendation. If denial recommendation is upheld by the Regional Office, the review process is complete. If denial recommendation is overturned by the Regional Office, the applicant must be scheduled for arrival based on the date on which the application first arrived on center. 62

eFolders Program Instruction 13-25, “E-Folders Process for Denials” Print out the complete applicant file when sending the file to the Regional Office for review. This includes: All original admissions paperwork (i.e., AC’s certification of eligibility, court history, data sheet, etc.) All medical/disability documentation and forms Any other documentation that might exist within the applicant’s file 63

Let’s Review and Practice!

Policy Review Where in the PRH would you find: Center Responsibilities in the AFR Process Policy Center Guidance for the AFR Process Center Recommendation of Denial Form (CRDF) for Health Care Needs, Direct Threat and Disability Status Health Care Needs Assessment (HCNA) Direct Threat Assessment (DTA) 65 Reference Support: AFR Resource Chart Handout

What does all of the boxes being checked “no” mean? 66

Scenario 1: Are there any problems with the completion of the components below from the HCNA Form? 67

Scenario 1 Forms Correctly Completed 68

Scenario 2: Are there any problems with the completion of the components below from the HCNA Form? 69 Must be signed by the clinician completing the assessment! Could the clinician completing the assessment be the AM/DC? No

Scenario 3: Are there any problems with the completion of the components below from the HCNA Form? 70

Case Study – Facts Tarik CRDF is 4 pages long. FRT is comprised of: CMHC Records Manager CSO HWM/DC AM/DC Applicant is hospitalized. 71

Case Study – Facts Tarik 653 affirmative for schizophrenia, ADHD, substance addiction. Applicant has completed dual MH and substance treatment and is ready for release. Supporting documentation from the treatment facility has been provided. Applicant is an adult. 72

Case Study – Tarik What are some of the obvious process issues? CRDF is the wrong one. FRT is too broad. Which team members should not be a part of the FRT? 73

Case Study – Tarik What would you do with each potential consideration posed below? HWM/DC wants to send the file back to the AC since the applicant is hospitalized. The applicant is not available to speak to the center FRT despite the team’s efforts to set up a call to conduct the necessary interviews. Would the RAC need to consider accommodations for the substance addiction? 74

Resources Websites, Documents and Guides 75

76 Upcoming webinars! Coming January 19 & 21, 2016! 11 am ET and 3 pm ET Upcoming Webinars! LD 200 Part 2 of a 3 Part Webinar Series on Learning Disabilities ​ Diane Fairchild Humanitas Disability Consultant

Job Corps Disability Website 77

Job Corps Health & Wellness Website 78

Job Accommodation Network 79

Questions? 80