P1. To establish procedures for applicant file review by centers.
P2. To establish procedures for the review of applicant health information.
P3. To ensure that all assigned students are contacted by the center prior to arrival.
P4. To establish procedures for assignment of applicants to centers in accordance with Regional Office procedures.
P5. To establish procedures for a Regional review process of applications recommended for denial.
R1. Overall Legal Requirements
a. A center is not permitted to revisit an Admissions Counselor’s (AC’s) determination that an applicant meets the eligibility requirements and is eligible for Job Corps, even if the center disagrees with the AC’s determination of the applicant’s eligibility qualification(s), except in the following limited circumstances:
1. The center receives new information that:
(a) Was not reasonably available to the AC at the time the applicant’s eligibility qualifications were established
(b) Indicates that the applicant offered enrollment may no longer meet one of the eligibility requirements
b. Apart from the circumstances described in 1(a) above, the center may review the information in the applicant’s file, such as on the Job Corps Health Questionnaire (ETA 653), the accompanying documentation that is medically related to the information on the questionnaire, or that the applicant has otherwise voluntarily disclosed, to determine the health needs of the applicant and/or to determine whether the applicant has a disability, mental health, or medical condition that likely poses a significant risk of substantial harm to the health or safety of the individual or others.
Only the categories of persons identified in Appendix 607, Transmission, Storage and Confidentiality of Medical, Health and Disability-Related Information, may be permitted to review, or have access to the applicant’s medical, health, or disability-related information.
R2. Applicant File Review Process
a. Responsibilities of Records Staff
The records department is the gatekeeper of all applicant files. The records department must maintain a single ongoing log that documents:
1. The location of every applicant file
2. How long the file has been on center
3. Who the file was sent to
4. How long the file has been with a particular department or staff person
5. The center’s recommendation regarding enrollment and/or an explanation of any final movements or actions taken related to a file (i.e., for example, an applicant contacted a center to request a withdrawal of application and file returned to OA since file is not in regional review)
For those files sent to the Regional Office for review, the records department must document the date the file was sent, to whom it was sent, and the final disposition of the record.
b. Responsibilities of Center File Review Team
The Health and Wellness Manager (HWM) completes a review of the Job Corps Health Questionnaire (ETA 653) and supporting documentation to determine which center staff is needed to conduct a review of each applicant’s file. These staff comprise the center’s File Review Team (FRT). The center FRT must include the HWM and the Disability Coordinator (if a student with a disability) and may include other staff such as the Center Mental Health Consultant, physician, Trainee Employee Assistance Program (TEAP) Specialist, and/or the dentist.
c. Center Procedure
Each center is required to have a written procedure describing the center’s process for reviewing applicant files. This procedure should describe in detail how an applicant file is processed, from the time it arrives on center from the OA contractor, until the applicant is accepted into the program and assigned a start date, or recommended for denial and a final disposition is made by the Regional Office. 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.
While each center file review procedure may have unique aspects, all center procedures must incorporate the following requirements:
1. Location where files are sent and logged in upon arrival to the center and the method of tracking the movement of the file to include an explanation of the center’s disposition of the file (see R2.a [above])
2. Responsibilities and roles of applicant FRT members to include the HWM, the center clinicians, and the center’s Disability Coordinator(s) which usually will include the center’s HWM
3. Procedures for reviewing an applicant file to include the acceptable reasons for recommending denial of an application
4. Procedures for reviewing and determining reasonable accommodation
5. Procedures for processing application withdrawals both before and after submitting a file for regional review
6. Timeframe the center establishes to complete the file review process to ensure it meets the PRH required timeframe of 30 calendar days
7. Storage, transmission and maintenance of the applicant file information (see PRH Appendix 607, Transmission, Storage and Confidentiality of Medical, Health and Disability-Related Information)
See section, “Standard Operating Procedure,” in Appendix 107, Applicant File Review Guidance-Center Process, for detailed descriptions of the requirements listed above.
R3. Review of Health Information
a. The HWM conducts the initial review of the health documentation in the individual applicant’s folder, including Job Corps Health Questionnaire (ETA 653) and the medically related supporting documentation that has been submitted with it, to:
1. Explain the health care needs of the applicant.
2. Determine whether Job Corps can meet the health-care needs of the applicant.
3. Determine if the applicant presents a direct threat to self or others.
4. Obtain consent for required routine medical assessments and/or consent to receive basic health care services.
b. Health-Care Needs Assessment
A health-care needs assessment may be conducted for an applicant if the center clinical staff believes that one of the following applies:
1. The health-care needs may not be manageable as defined by basic health care services in PRH Exhibit 6-4, Job Corps Basic Health Responsibilities.
2. The health care needs may be manageable but may require community support services that are not available near the center of assignment; the applicant should be assigned to a center where these needs can be met.
In the instance that a center has recommended the applicant’s health-care needs can be met in Job Corps if the individual were located at a center where needed resources and supports were available, the applicant’s file is routed through the typical regional review process with the following additional steps:
(a) If the center’s recommendation is supported by the Regional Health Specialist (RHS) and approved by the Regional Director or his or her designee, then the Regional Office returns the file, including the completed Health-Care Needs Assessment from the initial center, to the AC to contact the applicant and assist in identifying the new center.
(b) The new center completes a review of the documentation and confirms the current status of the applicant and then documents the contact and assessment in the progress notes narrative and includes in the medical file.
(c) If the center’s recommendation is to accept the applicant, the center notifies the AC and the Regional Office, and schedules the individual for arrival. If the center’s recommendation is to deny the applicant, then the center notifies the AC and forwards the file back to the Regional Office for a second clinical review by the appropriate RHS.
(d) If the RHS recommends overturning the center’s recommendation of denial and the Regional Director, or his or her designee, concurs, then the center is notified that the applicant must be scheduled for enrollment. If the RHS concurs with the center’s recommendation and the Regional Director, or designee concurs, then the applicant is notified of the disposition of his or her file, the file is returned to the AC, and the center notified of the Region’s decision.
See Appendix 610, Health Care Needs Assessment, for specific guidance on conducting a health care needs assessment. See section “Review of Applicant’s Health Care Needs by the Alternate Center” in Appendix 107, Applicant File Review Guidance-Center Process, and section, “Review Process for Recommendations to Attend an Alternate Center” in Appendix 108, Applicant File Review Guidance-Regional Process, for detailed descriptions of the requirements listed above.
c. Direct Threat Assessment
In the case of an applicant, a direct threat assessment may be conducted:
1. Whenever Job Corps believes that a known or apparent disability or medical condition poses a direct threat to the health or safety of the individual or others. This typically will occur after the applicant has received conditional assignment to a Job Corps center and has completed the Job Corps Health Questionnaire (ETA 653).
2. If the specific information that has been received about that particular applicant indicates that he or she may have a medical condition or disability that:
(a) Poses a significant risk of substantial harm to the health or safety of the individual or others
(b) Cannot be eliminated or reduced by reasonable accommodation or modification
If the specific information in the folder appears to meet the standards described above, the HWM will forward the applicant’s information to the licensed health provider employed by the center for a detailed direct threat assessment.
For specific guidance on conducting a direct threat assessment, see Appendix 609, Individualized Assessment of Possible Direct Threat.
R4. New Information Review of Applicant Eligibility
a. The AC determines an applicant’s initial eligibility (i.e., meets the eligibility requirements) to enroll in the Job Corps program. The files of eligible applicants are forwarded to the center in which the applicants have been conditionally assigned so that the center may complete clinical reviews. The center File Review Team or its individual members only may revisit the determination that an applicant is qualified for admission (i.e., an applicant’s eligibility status) if:
1. There is new information presented that the AC could not have reasonably known at the time the applicant’s qualification for admission was established.
2. The new information indicates that the applicant offered enrollment may no longer meet eligibility requirements (see R1.a [above]).
b. If new information is present that indicates that an applicant may no longer be eligible to enroll in Job Corps, the center File Review Team must complete the following steps:
1. Identify the specific eligibility requirements that the applicant no longer is believed to meet as per the criteria listed in Exhibit 1-1, Eligibility Requirements.
2. Re-apply the listed criteria for each of the specific eligibility requirements in question. Ask the applicant any questions outlined within the guidance information in Exhibit 1-1, Eligibility Requirements, for the specific eligibility requirement. The questions must be stated in the same way they are written in Exhibit 1-1, Eligibility Requirements, and as they were originally asked by the AC. Their content may not be broadened or modified.
3. If the applicant provides a negative (e.g., “no”) response to the specific questions previously asked by the AC from Exhibit 1-1, Eligibility Requirements, then the applicant is no longer eligible and the application process is stopped. If the applicant responds with a “yes” response, then the application process continues.
For example, in Exhibit 1-1, Eligibility Requirements, within the guidance for Criterion 7, Group Participation, the AC was instructed to ask: “Do you understand 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?” This question is informational only and is asked to confirm the applicant’s understanding of the Job Corps environment before proceeding with the actual eligibility question specific to the eligibility requirement which is, “Knowing this about Job Corps, are you willing to go forward with your application?” The applicant would have responded with a “yes” to have been found eligible previously by the AC.
If new information surfaces or is provided during the center’s review that the AC could not have reasonably known that may now indicate that this applicant is no longer eligible under the “Group Participation” eligibility requirement, then the center File Review Team must ask the exact same questions of the applicant as those originally asked by the AC for that specific eligibility requirement (i.e., “Do you understand 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? Knowing this about Job Corps, are you willing to go forward with your application?”)
4. If the applicant is determined to no longer be eligible, then the center completes the Center Recommendation of Denial Form and submits it, the applicant file and the supporting documentation to the Regional Office for review.
c. New Information–Age (Criterion 2), Income Eligibility (Criterion 3), and Disability Status
1. In general, ACs may not ask whether an applicant is an individual with a disability or about the nature and severity of a disability prior to conditional enrollment in Job Corps. At two points in the process of determining eligibility, however, ACs may invite an applicant to disclose whether he or she has a disability:
(a) If the applicant is, or will be, over 24 years old on the date of enrollment, the maximum age limit (Eligibility Requirement-Criterion 2) may be waived if he or she is a person with a disability.
(b) If the applicant would not meet the low-income requirement unless the applicant is considered a “family of one” (Eligibility Requirement- Criterion 3) because of disability.
2. The AC does not determine whether or not an applicant is a person with a disability. Appropriate center staff will do this since the AC does not review health and medical information. The AC will gather the documentation and place it in a sealed envelope with the applicant file that is then forwarded to the center for review.
(a) The center reviews the documentation of disability. If the documentation supports that the applicant is a person with a disability, the applicant file review process continues.
(b) If the center determines that the applicant is not a person with a disability, then the center completes and submits the “Center Recommendation of Denial Form” along with the applicant’s file and submits to the Regional Office for review.
R5. Determination of Ineligibility or Failure to Meet Other Eligibility Requirements After Enrollment
If, after an individual is enrolled in Job Corps, new information is received that is credible and reliable and that indicates that the individual does not meet the eligibility criteria for the program, appropriate members of the File Review Team will review the new information and determine, based solely on that information, whether or not the individual remains eligible for the program. If the team determines that the individual has become ineligible and recommends that the individual be removed, the file, the Applicant File Review Form (see Appendices 107, Applicant File Review Guidance-Center Process, and 108, Applicant File Review Guidance-Regional Review Process), and supporting documentation must be sent to the Regional Office for review prior to removing the individual. The individual should remain on center until he or she is officially separated, unless he or she poses a risk to himself/herself or others or would interfere with the delivery of services to other students. See Section 1.5, R1 for information about the Regional Office’s role in the process.
R6. Pre-Departure Center Contact
Centers will contact assigned students prior to scheduled arrival to welcome them, and provide information about the center, reiterating behavioral standards.
R7. Arrival Scheduling
a. Accurately project arrival needs and issue arrival requests to the ACs in accordance with Regional Office procedure.
b. Ensure that the application folder is complete and contains all required documentation upon arrival at center. The center will contact the AC to obtain missing or incomplete documentation.
c. Schedule timely assignment, for first available opening on center, of applicants referred by ACs, to ensure maintaining center at capacity.
d. Where reasonable accommodations will be provided, ensure that the accommodations are in place before arrival. However, failure to provide timely accommodations will not excuse undue delay in an applicant’s arrival, and may be the basis for a discrimination complaint.
e. Provide timely travel authorization and arrival information to ACs and other appropriate parties, as required.
f. Meet and greet arrivals at the designated time on the center or at the determined travel termination point.