1.5 Center Applicant File Review

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R1. Center Applicant File Review 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 202, 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. Requirements for the Center Applicant File Review 

a. To ensure equal opportunity for all applicants, including those with disabilities, all centers are required to follow the same applicant file review process. This process will be described in an SOP (see Exhibit 5-1) that describes in detail how an applicant file is processed, from the time it is received from the admissions 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.

b. The applicant’s file must be processed within 30 calendar days from receipt by center. If the center reasonably can substantiate needing longer than 30 days to complete the file review process, then an extension may be discussed with the respective Regional Office Project Manager.

c. 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

2. Responsibilities and roles of applicant file review team members to include the Health and Wellness Director, the Center Clinicians, and the center’s Disability Coordinator(s) which usually will include the center’s Health and Wellness Director

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 Appendix 202)

​See Chapter 1, Section 1.5 R1, R3, R4 and Form 1-07​.

a. Responsibilities of Records Staff

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 Outreach and Admissions (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 Director (HWD) 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 HWD 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 Section 1.5, R3.a)

2. Responsibilities and roles of applicant FRT members to include the HWD, the center clinicians, and the center’s Disability Coordinator(s) which usually will include the center’s HWD

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 Appendix 202, Transmission, Storage and Confidentiality of Medical, Health and Disability-Related Information)

See section, “Standard Operating Procedure,” in Form 1-07, Applicant File Review Guidance-Center Process​, for detailed descriptions of the requirements listed above.

a. The HWD 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 Exhibit 2-4, 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 Form 2-05, 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 Form 1-07, Applicant File Review Guidance-Center Process, and section, “Review Process for Recommendations to Attend an Alternate Center” in Form 1-08, 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 HWD 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 Form 2-04, Individualized Assessment of Possible Direct Threat​​.