1. APPLICANT FILE REVIEW PROCESS - REGIONAL 2013 UPDATES

2. Content of presentation OVERVIEW 2

3. BACKGROUND & TIMELINE BRIEF HISTORY & REVIEW OF CHANGES TO THE APPLICANT FILE REVIEW PROCESS

4. BACKGROUND/TIMELINE 4

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 o Removed redundant steps o Administrative forms shortened o Assessment forms include step-by-step process o Included more guidance within the forms

7. CHAPTER 1 – SECTION 1.4 CENTER 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 1.5 REGIONAL 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 o Review of Center Recommendation of Denial Based Upon Health-Care Needs, Direct Threat Assessment or Disability Status o Review of Center Recommendation of Denial Based Upon New Information o 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

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19. IF RECOMMENDING ALTERNATE CENTER...

20. 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 21

22. Reason for Recommendation of Denial: The applicant is ineligible for Job Corps due to the review of new information that the AC could not have reasonably known at the time the applicant was deemed eligible. Please refer to Exhibit 1-1 of Chapter 1 of the PRH and identify the specific EAR(s) that you believe the applicant no longer meets. Note: If you believe the applicant is no longer eligible because of disability status related to EAR “A” (age) or EAR “D” (low income), then please complete the Center Recommendation of Denial Form – Health Care Needs, Direct Threat or Disability Status instead of this form. ☐ B.Selective Service Registration ☐ I.Program Suitability ☐ C.Legal U.S. Resident ☐ J. Group Participation and Understanding of Rules ☐ E.Education/Training/Family Needs ☐ K. Interference with Other Students’ Participation ☐ F. Authorization for Use and Disclosure of Health Information ☐ L.Community Relations ☐ G.Parental Consent ☐ M. Court Involvement and/or Agency Supervision ☐ H.Child Care ☐ N.Maintenance of Sound Discipline 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 23

24. 24 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 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. If so, the completed health care needs assessment form found in Appendix 610 of the PRH is attached to this document for consideration of a different center. Skip to Section C. ☐ 4.The applicant is ineligible for Job Corps due to age or income related to disability status (i.e. the applicant is over 24 years of age and the center does not believe s/he is a person with a disability or the applicant would no longer be considered a family of one for low income consideration because the center does not believe s/he is a person with a disability). Complete Sections B & C. Files submitted with this form are forwarded to the Regional Administrative File Review Coordinator

25. Regional Applicant File Review Process Form 25

26. APPLICANT FILE REVIEW RED FLAGS

27. APPLICATION OUTCOMES ReasonExplanation Enroll Center accepts and enrolls applicant Withdrawal Applicant requests application to be withdrawn Clinical staff are unable to reach applicant to complete the clinical interview or the accommodation process, when applicable Recommend Denial Applicant’s health care needs exceed those of basic care Applicant’s health care needs exceed those of basic care but may possibly be met at a center closer to applicant’s home area resources Applicant poses a direct threat to self or others Applicant is no longer eligible due to disclosure of new information that the AC could not have reasonably known at the time eligibility was certified Should be a fairly rare occurrence 27

28. DO YOU REMEMBER? 28 ▪ 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? Center Standards Officer (CSO) or Student Personnel Office (SPO)

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. o 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. o Document the attempts to contact including collaborations efforts with OA and return the file to OA. 29

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 30

31. WITHDRAWAL PROCESS RED FLAGS 31

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

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 33

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 34

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 45

46. ACCOMMODATION RECOMMENDATION OF DENIAL 46

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 47

48. STORAGE & TRANSMISSION

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

50. AGE WAIVERS

51. WHICH RECOMMENDATION OF DENIAL FORM DO YOU USE? Center Recommendation of Denial Form for Health Care Needs, Direct Threat or Disability Status 51

52. ATTACHMENT B – APPENDIX 107 52

53. The New Information Recommendation of Denial Form does not give you the option to select EAR A or D 53

54. SCENARIOS & REVIEW

55. NEW INFORMATION REVIEW CASE STUDY ▪ Applicant Mallory 55

56. NEW INFORMATION REVIEW CASE STUDY – APPLICANT MALLORY 56 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. J. Group Participation & Understanding of Rules 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.).* During interview with AC, the mother informed that Mallory had past behavioral problems but did not tell the AC that the behavior problems had resurged just before starting the admissions process. Summarize your findings. Mother wonders if daughter is trying to sabotage her own admission. Stated that the defiance had increased at home so much so that she and her husband had to hide in their room. Said that the daughter had decided that she could leave home when she wanted to and do what she wanted to and at school was telling teachers off, skipping classes, etc. Given Mallory’s history and recent behavioral issues (the latter of which were unknown to the AC), we do not think that applicant is an appropriate candidate for Job Corps.

57. LET’S REVIEW ▪ What do you do first in considering this information? Go to PRH 1: Exhibit 1-1 and find EAR J 57

58. Exhibit 1-1 Essential Admissions Requirements (EAR) 58

59. COULD THIS SCENARIO QUALIFY FOR A NEW INFORMATION REVIEW? ▪ Possibly – it depends Read through the AC’s information/notes to ensure that s/he was unaware of the recent behavioral issues. If that was known, then it is not new information and eligibility cannot be revisited. o If it was not known, how do you actually re-assess this particular EAR? ▪ Go back to EAR J and review the requirements and guidance. ▪ Guidance says: “Do you understand that if you are accepted into JC, you will be expected to comply with the rules and regulations of JC? For example, if you live on center, you will have to follow a curfew, there are rules about cell phone use, and you may not be permitted to smoke on center and you may be required to wear a uniform. Knowing this about JC, are you willing to go forward with your application? 59

60. COULD THIS SCENARIO QUALIFY FOR A NEW INFORMATION REVIEW? o If applicant responds to the question with a “yes,” then what? ▪ Proceed to the next question. o If applicant responds to question with a “no,” then what? ▪ Stop the interview. Complete the paperwork for a recommendation of denial based upon new information. If the AC did have knowledge of the recent behavioral concerns, then what are your options? o Complete either a health care needs or direct threat assessment, if appropriate. o If not appropriate, enroll the applicant. 60

61. APPLICANT ANGELA ▪ Student wears braces and had 1-2 months left in treatment with appointments every 4-8 weeks. ▪ “Agreement for Enrollment with Braces” form was signed. ▪ During clinical interview, applicant informs center that she is unable to afford her treatment at this time and had not removed her braces and did not wish to do so. 61

62. APPLICANT ANGELA ▪ What do you do? Complete a health care needs assessment, determine if recommendation of denial is in order, and submit file/recommendation to the Regional Office 62

63. APPLICANT JOSE ▪ Had diagnoses of depression, anxiety, intellectual disability, and pervasive developmental disorder ▪ Documented history of behavioral difficulties ▪ Exposure to too many people over a prolonged period of time becomes overwhelming ▪ When stressed, tics surface, and he paces ▪ Has difficulty reading social cues 63

64. APPLICANT JOSE ▪ A health care needs assessment was completed and the following accommodations were considered, agreed upon with the applicant and listed in the assessment: Extended time for testing Frequent breaks Proctor read tests ▪ Is this file likely to be returned to the center or not? Yes. The accommodations aren’t really addressing the behavior and symptoms that are presenting the barriers to enrollment. 64

65. RESOURCES

66. NATIONAL OFFICE RESOURCES ▪ Health & Disability Carol Abnathy, National Office of Job Corps o (202) 693-3283 o abnathy.carol@dol.gov Johnetta Davis, National Office of Job Corps o (202) 693-8010 o davis.johnetta@dol.gov

67. JOB CORPS DISABILITY WEBSITE 67

68. JOB CORPS HEALTH & WELLNESS WEBSITE 68

69. JOB ACCOMMODATION NETWORK (JAN) ASKJAN.ORG 69

70. QUESTIONS 70