BPM006628_Exhibit_A_-_Arizona_State_Plan_for_Refugee_Resettlement.pdf

STATE OF ARIZONA

Katie Hobbs Governor

Designated State Agency

Angie Rodgers Cabinet Executive Officer

ARIZONA STATE PLAN FOR REFUGEE RESETTLEMENT

Submitted: August 2023

Public comments concerning this plan should be addressed to:

Arizona Department of Economic Security Division of Aging and Adult Services

Arizona Refugee Resettlement Program P.O. Box 6123, Mail Drop 6287

Phoenix, Arizona 85005

The intent of the Refugee Act of 1980 and subsequent amendments is for refugees to become economically self-sufficient and to be successfully resettled as soon as possible after their arrival in the United States (U.S.). The State of Arizona recognizes that refugees and other Office of Refugee Resettlement (ORR)-eligible beneficiaries (hereafter referred to as “refugee/s” for all general references to eligible groups) face many obstacles and challenges to reaching these two overarching goals. The Arizona State Plan for Refugee Resettlement (State Plan) sets forth coordinated assistance programs, services, and activities designed to provide support for refugees in Arizona as the endeavor to achieve these two overarching goals.

The State Plan (Plan) provides information on the types of coordinated assistance programs, services, and activities to be developed and administered by the State, and the characteristics of individuals to be served under the provisions of Section 412 (a) (6) B of the Immigration and Naturalization Act and the Refugee Act of 1980, as amended. Services will be directed toward the following federal goals:

▪ Promote economic self-sufficiency for refugees within the shortest possible time after arrival in the State or grant of qualifying status through coordinated and effective use of support services, cash, and medical assistance.

▪ Contribute to the effective resettlement of refugees within the shortest possible period after arrival in the State or grant of qualifying status through coordinated and effective use of support services and Cash and Medical Assistance (CMA).

I. ADMINISTRATION

A. Organization

1. In compliance with 45 Code of Federal Regulations (CFR) Part 400 § 400.5 (a), and Policy Letter (PL) 16-01 the Arizona Department of Economic Security (ADES/Department) has been designated by the Governor as the single State Agency responsible for the administration of this State Plan (Attachment G-1).

2. In compliance with 45 CFR Part 400 § 400.5 (d), ADES has authorized the State Refugee Coordinator (SRC) within the Department to oversee the Arizona Refugee Resettlement Program (RRP), who is designated with the responsibility and authority to ensure coordination of public and private resources in refugee resettlement in the State. The current SRC is Charles Shipman.

3. The State Refugee Health Coordinator (SRHC) resides within RRP as staffed by the Refugee Health Manager. The current SRHC is Juliana Shepherd Davis.

4. ADES and RRP Organizational Structure:

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ADES provides Arizonans with employment and rehabilitation services, financial and nutritional assistance, and related “safety net” services for those in need. ADES’ Mission is making Arizona stronger by helping Arizonans reach their potential through temporary assistance for those in need, and care for the vulnerable, with the True North that all Arizonans who qualify receive timely ADES services and achieve their potential. RRP resides within ADES’ Division of Aging and Adult Services (DAAS). To provide effective services to qualifying refugees and other eligible beneficiaries in Arizona, key staff members are designated in other ADES Divisions and have unified their authorities in a coordinated Departmental effort to assist the SRC. For example, dedicated staff of the Family Assistance Administration (FAA) within the ADES Division of Benefits and Medical Eligibility (DBME) process applications for benefits for newly arrived refugees, such as Temporary Assistance for Needy Families (TANF), Supplemental Nutrition Assistance Program (SNAP), Arizona Health Care Cost Containment System (AHCCCS). DBME’s specialized training and knowledge of policies and eligibility requirements facilitates the eligibility determination process. Additionally, private vendors for the ADES Division of Employment and Rehabilitation Services’ TANF Jobs Programs work with refugee families receiving TANF Cash Assistance (CA) to promote compliance with required work search activities.

In addition to the SRC, key RRP management, programmatic, and administrative staff assist with meeting statutory responsibilities for the overall management and operation of RRP, such as planning; coordination; policy and program development and implementation;

monitoring; consultation and public outreach and education; addressing public inquiries and media requests; data collection, analyses, and management; reporting; and travel.

Professional staff hold statewide responsibility for RRP Programs and are the contact persons and representatives for local forums, Local Resettlement Agencies (LRAs), Mutual Assistance Associations/Ethnic Community-based Organizations, and other key stakeholders.

RRP may receive administrative support from other staff of DAAS, ADES, and other State personnel to carry out ORR-funded project-specific tasks. In compliance with Federal Regulations and State Letter 12-13, these costs will be charged to the Refugee Cash and Medical Assistance (RCMA) Grant and may be charged to other grant sources should RCMA become unavailable.

5. The State will conduct quarterly convenings with representatives of State and Local governments, as well as with private stakeholders to better coordinate services for populations served through the State’s refugee-specific programs. Quarterly Meetings will take the form of working groups that will be comprised of representatives of state and individuals from local governments, human services and benefit agencies, law enforcement, and school districts all being invited to separate working sessions with RRP and the LRAs. In these convenings RRP will provide most up-to-date arrival data with stakeholder feedback solicited about program design, capacity, and challenges or successes and will create the opportunity for LRAs to do the same.

In addition to Quarterly Meetings, RRP will also provide Quarterly Educational Sessions (QES) and Semi-annual Public Information Meetings. In the QES, Refugee 101s are provided to parties interested in working within the Resettlement Network. The Refugee 101s provide basic overviews of the U.S. and local refugee resettlement systems and four

Arizona State Plan for Refugee Resettlement FFY 2024 Page 3 main program funding areas: Reception and Placement (R&P), the Voluntary Agency Matching Grant Program (MGP), Preferred Communities (PC), and Refugee Support Services (RSS). The information is designed to provide a foundation on the fundamentals of refugee resettlement operations so that subsequent consultation meetings allow for targeted project discussions to take place. In the Semi-annual Meetings, RRP will present the data on the services provided by RSS funding and create a platform for all interested parties to give updates on their program or ask questions of RRP or the LRAs. The Semi-annual Meetings are public and designed to distribute information widely amongst populations interested in working with resettlement.

RRP will engage with program administrations and direct service staff at partnering social service agencies and conduct joint critical path diagramming. This will support operationalizing the responsibilities of each party so that direct service workers in each respective field understand the process flow for serving joint clients. To engage in substantive evidence-based program design and optimization, RRP will engage in the following providers with RRP partners in each service area.

a. Data Handshake: RRP and the partnering service agency will exchange service data on joint refugees as allowable under data sharing agreements to identify the scale of interaction among mainstream systems and refugee clients.

b. Systems Mapping: RRP and partnering service providers will develop direct service diagrams showing a client’s progression from refugee-specific services into mainstream services.

c. Service Mapping: RRP and partnering service providers will attempt to map individual client’s journeys through services to identify any discrepancies between intended systems mapping and actual services refugees receive. Particular attention will be paid to Limited English Proficient meaningful access provisions of the Civil Rights Act of 1964.

d. Policy Remediation: During this process, RRP will engage with mainstream service providers to identify and suggest changes to respective sectors’ policies that may unintentionally prolong or prevent refugees from obtaining service goals.

During this process, RRP will address partnering service agencies’ concerns and, should a concern be raised about services or issues outside RRPs funding jurisdiction, such as those for R&P or MGP, RRP will invite the party responsible for the service area to provide input on the topic as part of the policy remediation discussion(s).

6. Program and fiscal oversight for Refugee Cash Assistance (RCA), Refugee Medical Assistance (RMA), Medical Screenings, and RSS and RSS Set-Aside Programs is managed primarily by RRP with assistance from ADES support units. RMA, Medical Screening, and the RSS Refugee Health Promotion (RHP) Set-Aside are managed by the SRHC within RRP.

Arizona’s RCA is administered under a Public Private Partnership (PPP) model. All Arizona LRAs operating under a U.S. Department to State R&P Cooperative Agreement are

Arizona State Plan for Refugee Resettlement FFY 2024 Page 4 contracted to conduct intakes and monthly redeterminations to enroll and assist refugees with the self-sufficiency process. One LRA is contracted to distribute RCA. Monitoring for RCA compliance is accomplished through a three-phase methodology.

Refugee Support Services (RSS) and RSS Set-aside contracts are provided through several contractors in Arizona, including LRAs, and other community and mainstream refugee serving providers. RSS monitoring operates through a two-phase methodology:

Phase One: Contracted service provider data will be collected monthly via Arizona Refugee Resettlement Program Online Data System (ARRPODS) desk monitoring and analyzed for deficiency. Deficiencies will be addressed in monthly Directors’ call with contracted service providers and tallied for official monitoring.

Phase Two: RSS and RSS Set-aside funded contracts will be physically monitored biennially for fiscal, human resource, and programmatic compliance. The composite desk and physical monitoring report will be provided to contractors with a corrective action plan requested, as needed.

Newly executed Federal Fiscal Year (FFY) 2023 RSS Employment/Case Management contracts under RSS Afghanistan Supplemental Appropriation (ASA) funding operate under rate-based payment methodology for allowable service data. RSS will use a three-phase monitoring approach for all the RSS and RSS Set-aside contracts from FFYs 2023 through 2024.

RMA is fully administered by RRP, including intake, eligibility determination, benefit card issuance, claims processing and payments, and provider and member communications. There are no subrecipients and monitoring is conducted by the Arizona Auditor General’s Office and ORR.

Medical Screening services are currently subcontracted to two entities; one under a direct contract with Revive Community Health and the other under an Intergovernmental Agreement (IGA) with the Maricopa County Department of Public Health (MCDPH). Revive Community Health operates two screening clinics, one each in Tempe and Tucson, Arizona for refugees in Maricopa and Pima Counties, respectively. MCDPH operates a screening clinic in Phoenix, Arizona. Contract monitoring occurs every other year, with the last monitoring in 2022. Monitoring activities include onsite visits from RRP and the DAAS Contracts Unit, Refugee Chart checklist reviews for activities on the Centers for Disease Control and Prevention (CDC) Guidance for the U.S. Domestic Medical Examination for Newly Arriving Refugees (CDC Guidance) components, in-person interviews with program staff, a Contract Compliance Review (CCR) that includes a fiscal component, a programmatic component, and a supplementary information checklist completed by the subcontractor prior to the monitoring visit. To ensure contract compliance, RRP also performs desk monitoring for required monthly narrative and aggregate data reports and the ARRPODS service entry data. Since the COVID-19 Pandemic onset in 2020, all onsite monitoring has been conducted virtually.

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RHP service contracts are monitored every other year. Monitoring activities include onsite visits by fiscal and program managers, refugee case note reviews, in-person interviews with program staff, a CCR - including a fiscal section, a program section, and a supplementary information checklist completed by the subcontractor prior to the monitoring visit. RRP also performs desk monitoring of the contractually required narrative and aggregate data reports received from the contractors and the ARRPODS service entry data to ensure compliance with contract requirements.

7. RRP verifies the immigration status of all refugees receiving services offered through its programming. Apart from RHP, refugees must be entered into ARRPODS prior to the initiation of any service being offered under RRP funding. An application for services is developed for each refugee with their supporting eligibility documents uploaded. RRP staff then check each application to verify that refugees meet one qualifying immigration status and with supporting documentation required pursuant to the Status and Documentation Requirements for the ORR RRP PL. Once eligibility has been verified, RRP staff remove the master lock in ARRPODS, and contractor staff may physically enter work done for clients.

Should an application not pass initial screening, RRP will work with the relevant service provider to try and obtain the correct information. Should the refugee or service provider be unable to provide the correct immigration documentation, the client's profile will remain locked in ARRPODS, and service providers may not physically enter work on the client.

In addition to the ARRPODS verification, as part of their intake process each refugee signs a written declaration, under penalty of perjury, certifying that they are an eligible ORR beneficiary.

8. RRP ensures the safeguarding of refugee information through a multi-pronged strategy.

ARRPODS is considered the sole repository of refugee information under RRP contracts. At the initiation all contractors’ sub-contractors must sign Data Share Agreements (DSAs) with the State to gain access to the database. DSAs are unique to the contract type and operate under the premise of ensuring that RRP funded activities data may only be used for the purpose of creating required reports per ORR and RRP contract requirements. Data may not be permanently stored outside of ARRPODS.

Access to ARRPODS is controlled by RRP and contracted agencies’ staff may only gain access to the information via an account created by a designated RRP ARRPODS administrator. Only staff identified as working on RRP contracts in official budgets may have access to ARRPODS. When a staff member leaves a contracted agency, the provider must notify RRP so that RRP may deactivate the account. Accounts automatically time-out after three months of inactivity to ensure that only those staff who need routine access to refugee level data have such access.

Within ARRPODS, data is protected by a hierarchical permission set. At the top-level staff at contracted agencies may only see information created by individuals who work on the same contract. Data is stratified based on contract type. Biographical refugee information may be shared across contractors through the initiation of service referral within ARRPODS when a refugee has a valid Statement of Understanding (Release of Information [ROI]) signed and

Arizona State Plan for Refugee Resettlement FFY 2024 Page 6 verbal consent granted to send the referral. Service specific information may only be shared with partnering RRP contractors in ARRPODS when refugees grant verbal consent. Verbal consent must be granted for each individual service task to be shared. Refugees must be made aware of what service data is being transferred, to whom it is being transferred, and for what purpose. Tasks are shared from case worker to case worker when they work in joint care teams and are not visible to agencies as whole.

9. ARRPODS is considered the primary system of record for RRP. ARRPODS is a Salesforce-Based System that acts as an electronic case file system. RRP contracted caseworkers enter service data directly into a web-based portal. All refugees and services rendered to them are documented in ARRPODS. Only two service categories, RHP and Services to Older Refugees (SOR), have service providers outside of ARRPODS for FFY 2024. RRP is working with service providers to identify methodologies that support transitioning to ARRPODS or to provide data transfers that meet ARRPODS requirements throughout the year.

With ARRPODS, RRP possesses service level data that can be filtered to meet the reporting requirements of the ORR-5/6 and other reports. Utilizing ARRPODS is a cornerstone of all awarded RRP contracts since its inception and RRP will continue to make it the sole source of information as legacy contracts are retired and replaced.

RRP analyzes ARRPODS data monthly for contract compliance. Additionally, RRP successfully started the transition of direct service contracts from service budget contracts to rate-based contracts where payment will be rendered to contractors based on data observed in ARRPODS to ensure that ORR regulations and contract requirements are followed and guarantee that providers enter all relevant service data into ARRPODS. Throughout FFY 2024 AZ RRP will continue this transition with moving over non ASA and ASUAA contracts to rate based as well.

RRP also directly receives monthly narrative and aggregate reports from Medical Screening contractors with information required in the ORR-5 and ORR-6. This information is not collected in ARRPODS due to privacy concerns with handling personal medical information and the technical inability for providers to share sensitive health information directly with RRP without LRA staff having visibility. RRP reviews the Medical Screening reports for accuracy against service reports in ARRPODS.

RRP receives monthly refugee service activity and narrative reports in excel spreadsheet format directly from RHP contractors through secure email.

10. RRP Headquarters Location: The Arizona Department of Economic Security, Central Office, 1789 West Jefferson Street, Phoenix Arizona 85007.

11. All RRP funding sources that do not specify required providers will be awarded pursuant to the Arizona Procurement Code. Among these processes is the Request for Proposal (RFP), a competitive bidding process open to all vendors that bid in the Arizona Procurement System.

Only service areas required by ORR to have prescribed service providers, such as the PPP

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Program, will pursue direct contracts under a Competition Impracticable (CI). The ADES Procurement Chief reviews such requests and approves or disapproves pursuant to Federal or State policy.

RRP currently has one IGA and one direct contract with two Medical Screening providers.

One direct contract involved an FFY 2022 RFP process, and that contract will continue through FFY 2024 with the intent to renew.

12. Non-Applicable to Arizona.

13. Non-Applicable to Arizona.

B. Assurances. 45 CFR 400.5

1. The State will comply with the provisions of Title IV, Chapter 2 of the Refugee Act (8 U.S.C.

§ 1522), and official issuances of the ORR Director.

2. The State assures that it will meet all the requirements in Part 45 CFR Part 400.

3. The State will comply with all other applicable federal statutes and regulations in effect during the time that it is receiving federal funding.

4. The State will amend the State Plan as needed to comply with standards, goals, and priorities established by the ORR Director.

5. The State assures that assistance and services funded under the State Plan will be provided to refugees without regard to race, religion, nationality, sex, or political opinion.

6. The State assures that it will convene, not less often than quarterly, meetings where representatives of LRAs, local community service agencies, and other agencies that serve refugees meet with representatives of state and local governments to coordinate the appropriate services for refugees in advance of the refugees’ arrival. Such meetings shall include outreach and invitation to, at a minimum, public school officials, public health officials, welfare and social service agency officials, and police or other law enforcement officials, for jurisdictions in which refugees resettle.

7. The State assures that it will act in accordance with 45 CFR §§ 75.351-75.360 and 400.22(b)

(2) regarding subrecipient monitoring and management.

8. The State assures that it will act in accordance with 45 CFR §§ 75.371-75.380 for remedies for subrecipient noncompliance.

II. ASSISTANCE AND SERVICES

A. CMA

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1. CMA benefits are provided for refugees who are not eligible for state Medicaid. CMA is coordinated with support services in a manner that promotes employment; namely, employable refugees must enroll in employment services and comply with work search requirements as conditions of eligibility to receive CA. All refugees who receive RCA are eligible for RMA. In addition, refugees who present Medicaid ineligibility documents due to income and fall under 200 percent of the Federal Poverty Level (FPL) are eligible to apply for RMA through their respective LRA to continue receiving RMA through their twelfth month after arrival in the U.S. or grant of qualifying status.

2. Such CMA benefits as RCA and RMA are applied for and managed through ARRPODS.

Each LRA may make an application for benefits though ARRPODS and has visibility to whether a refugee is currently receiving CMA benefits. When subrecipient end users are required to document the fulfillment of contractual duties, ARRPODS displays the status of each CMA benefit directly and emails all application creators about status changes, with RRP interfacing with and approving benefit applications.

3. To apply for CMA benefits, ORR eligible beneficiaries may go to any LRA operating in Arizona or to one of RRPs Phoenix or Tucson offices to apply for CMA benefits. Should the refugee live in a remote locale to an RRP office or LRA, a telephonic application may be considered.

4. ORR eligible populations access such community services as childcare, older adult services, and other support programs though the same enrollment mechanisms as the general Arizona population. RSS case management time is often utilized to support clients’ understanding and completing of the enrollment processes.

5. English Language Training (ELT) is often a constituent goal of refugees’ Self-Sufficiency Plan (SSPs) for removing barriers to employment. Depending on a client’s English learning needs, an EP might contain ELT attendance as an action step to increase skills towards employability. ELT curriculum throughout the State is designed to promote early employment acquisition. Such training/classes are available to all ORR-eligible beneficiaries.

RRP funded ELT focuses primarily on supporting entering and retaining employment and, secondarily, to increase clients’ English-speaking levels over a longer-term to improve their likelihood of employability and economic self-sufficiency.

6. As part of direct service contracts being developed in FFY 2024, RRP will be prescribing a threefold service delivery paradigm as follows:

a. Stabilization: Direct use of ORR resources to ensure a case situation upon exiting R&P, MGP, or PC Program. Service providers attempt to prevent deterioration of the state established in the proceeding service Program.

b. Education: Individualized Knowledge Transfer to refugees’ efforts that seek to assist refugees with understanding the use of non-monetary resources leveraged by the RRP contracted caseworker to stabilize the clients’ circumstances.

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c. Monitoring: The refugee has agency over direct service operation under normal supervision of an RRP contracted caseworker.

The Education and Monitoring phases of service delivery are designed to support continuity in the progression of clients’ service delivery under their own management/agency, once refugee-specific services are terminated due to the priority provision of services listed in 45

CFR § 400.147.

B. RCA and Employment Services - 45 CFR 400 Subparts E and F

1. The State of Arizona will administer the RCA Program and its accompanying TANF payment differential through a PPP model as outlined in the ORR PL 21-04 “Guidance for Public-Private RCA Programs” issued on December 16, 2019 and applicable Dear college letters.

2. In Arizona, most refugee resettlement occurs in the Phoenix and Tucson Metropolitan Statistical Areas (MSA). LRAs operating in these MSAs hold the service mandates for conducting intake and monthly re-determinations for all refugees they resettle are contracted to serve in those MSAs, including those refugees resettled outside of the U.S. Department of State, Bureau of Population, Refugees and Migration (PRM) approved 100-mile R&P radius.

Additionally, in FFY 2024, RRP will onboard a new service provider that is not an LRA to process and adjudicate primarily Welcome Corps and Cuban or Haitian entrants throughout the state. The International Rescue Committee (IRC) of Phoenix will hold responsibility for issuing all RCA payments for refugees resettling in Arizona. IRC maintains the capacity to create and distribute bank cards to all refugees receiving services under Arizona’s RCA PPP Program.

3. Meaningful language access to relevant materials will primarily be facilitated through language appropriate caseworkers. Each contractor will maintain sufficient capacity for the primary groups of refugee arrival languages that they sponsor and resettle. For refugees speaking languages of lesser diffusion, contractors will utilize professional language services that observe recognized standards of practice for language interpretation and translation, to ensure that every refugee receives the same accurate information in a manner understandable to the client. In addition to the use of compatible spoken language services, either in-person or telephonic, PPP will ensure that all relevant documents are translated into the top ten refugee languages with the top ten languages being reassessed quarterly to meet current language needs. Should a client's overseas-generated R&P Biodata reflect a refugee language need falling outside the existing translated document set, the clients’ sponsoring LRA will be responsible for notifying RRP so that translated documents are available in refugees’ languages prior to their RCA enrollment. Clients may also request interpretation at any point of their RCA enrollment, and RRP will make refugee language-compatible translated documents available.

Refugees’ understanding of all information presented on plans must be confirmed by a refugee signature. RRP will run normalized monitoring to ensure that all required enrollment and participation documents indicate refugee acknowledgment with a valid refugee signature, Arizona State Plan for Refugee Resettlement FFY 2024 Page 10 documentation of the interpretation/translation method(s) used, and a verification signature of contractor staff certifying that, to the best of their knowledge, the information was provided in a linguistically compatible manner. This process will ensure that contractors are consistently providing a standard of necessary, meaningful language access and standard of care.

4. The State does not consider the State Department’s R&P transitional assistance as income in TANF determination; thus, TANF payment levels are not affected.

5. The State will adhere to the fair hearing standards and procedures outlined in 400 § 400.83/54. The full hearing process is available in RCA-PPP Policy Manual to be distributed upon client request. Basics of the process include:

a. Clients are required to attest, in writing, to the accuracy of case information at the time of application.

b. Should a client wish to contest an administrative decision made by the program, they will first register a complaint and go through the resolution procedure with their PPP contractor. The PPP contractor will hold an informal meeting to address the dispute, and notify the client of their right to appeal to RRP if they are dissatisfied with the contractor's decision. To conduct the informal hearing, the PPP Supervisor must conduct a literature review of the federal regulations, RRP PPP Scope of Work, RRP Policy Manual, RRP Use Case Manual, and written client attestations. The PPP Supervisor will inform the client of their decision within 12 business days of receiving the complaint. They shall take action to remedy the situation within the confines of their abilities in ARRPODS or notify a RRP staff member of the correction should their decision be in alignment with the client's grievance.

c. Should the client be dissatisfied with the outcome of the informal meeting with their PPP contractor, they may submit an appeal to RRP within 15 business days of receiving the decisions from their PPP contractor provided. Designated RRP staff who are not involved in the normalized determination of PPP benefits will then schedule an administrative review conference with the client or the client’s authorized representative within ten calendar days of the appeal request. At the administrative review conference, the client or the client’s authorized representative may present the pertinent evidence for which the appeal was based.

d. RRP staff will provide a written decision to the client within 12 calendar days from the date of the administrative review.

e. All actions taken to stop or modify payment amounts will be preceded by a letter sent no later than ten business days before the action is taken.

f. The formal administrative action shall be rendered within 60 days from the date of the request of a formal administrative hearing.

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6. In compliance with the general requirements of 45 CFR Part 400 § 400.75, refugees are subject to all RCA work participation requirements pursuant to their EP, unless otherwise exempt for one of the following reasons:

a. Incapacity, when determined by a physician or licensed or certified psychologist and verified by a caseworker that a physical or mental impairment, by itself or in conjunction with age, prevents the individual from engaging in employability activities. A health or mental health practitioner stating that the refugee is unable to participate and giving a timeframe for duration of the exemption or review of the exemption will complete the verification.

b. A pregnant woman in the last three months of her pregnancy is exempt from job search. She is exempt from all employability activities for 12 consecutive weeks following the birth of her baby. Medical verification of the last trimester of the pregnancy is required.

c. A parent with a child or children when there is no childcare available. Documentation stating that the family is unable to access the Arizona Child Care Assistance Program or other childcare programs will be reflected in the case file. This exemption applies only to one adult per household.

d. A caretaker of a child who is unable to care for themselves under standards and precedent set by the Arizona Department of Child Safety (DCS). This exemption applies only to one adult per household. In the case that ADES child care was denied, or a household is placed on a waiting list, documentation proving the case was rejected will need to be obtained before an exemption can be made. This exemption applies only to one adult per household.

e. Caretaker of a totally dependent person due to medical or mental health issues is exempt from employability activities if a medical or mental health provider has indicated that this person needs full-time care. This exemption applies to only one adult per household.

f. Working at least 30 hours a week in unsubsidized employment that is expected to last at least 30 days. This exemption continues to apply if there is a temporary break in full-time employment expected to last no longer than ten workdays.

g. Under age 16; or under age 18, but a full-time student (as defined in the TANF Program).

h. Participation in the Job Corps is considered a valid work search activity.

i. Age 65 or older and not receiving any Social Security benefits.

j. A victim of domestic violence where working or participation in employability activities will put them at further risk of harm.

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k. An ORR eligible Cuban or Haitian entrant client without work authorization may be considered exempt from work search requirements until such time as they obtain the legal right to work pursuant to Policy letter 19-06.

l. An ORR eligible client who falls under the first-tier priority provision of services under 45 CFR § 400.147 and whom RRP verifies cannot enter into employability services provided under RSS funding within one month of enrollment in CA. RRP shall have sole authority to authorize this exemption. Prior to utilizing this provision, RRP will engage in technical assistance meetings with ORR to explore other options. The exemption shall only be used on a temporary basis and will be removed as soon as an available provider, either RSS or publicly or privately funded, is found to cover the service gap.

m.Any refugee who has applied for an I-765 Employment Authorization Document (EAD) but has not yet received their EAD.

7. Non-Applicable to Arizona.

8. Non-Applicable to Arizona.

9. The State Administered RCA PPP Program will determine eligibility and payment levels pursuant to 45 CFR 400.50 and 400.60 as follows:

a. Eligible refugees may receive the RCA or TANF differential for a maximum of 12 calendar months from the date of eligibility, which is the date a refugee received a qualifying immigration status. The date of PPP enrollment is determined by the date a refugee signs a completed PPP Cash Benefits application, or the date on which a refugee is denied TANF benefits and is unable to successfully reapply within the ORR eligibility time frame. The PPP enrollment date is used to calculate the first month benefit payments may be issued.

■ A refugee has 30 days from the date that the PPP application is signed to provide all required documents and to sign all required forms. If a refugee does not complete the application process within 30 days, the application will be denied and subject to reapplication pursuant to 45 CFR § 400.50.

b. Initial RCA eligibility is determined by PPP contractors. Each contractor follows the following process to ensure eligibility for RCA and TANF PPP differential refugees:

▪ Collect Signed Application documents and verify TANF enrollment.

i. All refugees wishing to apply for PPP benefits, RCA or the PPP TANF differential, must present either in-person or virtually to an agency operating a PPP contract.

ii. All refugees that present to a PPP contractor and are remote to designated RSS Providers are still eligible for remote and virtual PPP enrollment and must comply

Arizona State Plan for Refugee Resettlement FFY 2024 Page 13 with employability requirements.

iii. At the time of presentation, the PPP applicant must sign documentation attesting to all program conditions which would render them eligible for PPP.

iv. All cases with minor children who present for PPP enrollment at an PPP contractor will need to sign the appropriate enrollment documentation, affidavits of household size, and a declaration they are not planning to apply for other CA Programs. The cash benefit application will need to be completed once the refugee receives TANF determination.

v. While the TANF application is pending completion, the caseworker will direct the refugee to the ADES FAA for TANF determination prior to any PPP benefits being issued.

vi. Upon successful enrollment into TANF, the refugee must present their positive ADES case number, as well as either a CA Notice of Benefits letter or Electronic Benefit Transfer Card with granted permission to the case worker to verify account status.

vii. If a TANF applicant or client was denied TANF CA, the applicant may be eligible for RCA if the denial was for the following reasons:

1. Applicant was found ineligible through no fault of their own; and

2. The Applicant is not able to reapply for TANF within their 12 month PPP TANF Differential Payment Program eligibility time frame.

viii. If a TANF client or applicant is determined eligible for RCA, RRP must be the entity to enroll the client into RCA benefits.

ix. If a client enrolled into RCA is determined to be eligible for TANF, the PPP caseworker will need to close the client’s cash program and work with the client to establish TANF benefits and enroll them into the PPP TANF differential.

▪ Conduct Intake.

Each PPP Contractor will follow the outlined process in determining eligibility and enrollment of sponsored refugees for the PPP:

i. Provide PPP applications to all refugees wishing to apply for the RCA benefit or presenting for the PPP TANF differential.

ii. Attempt to find the refugee if they are entered into ARRPODS, and verify they are marked as an eligible ORR beneficiary.

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iii. If the refugee has not already been entered into ARRPODS, PPP Staff will create a profile, uploading appropriate documentation confirming eligibility under relevant ORR PLs on admissible status and immigration documentation, and creating an ORR benefits application in ARRPODS.

iv. Upon confirmation of ORR eligibility status by RRP, the PPP intake worker will ensure that the refugee meets the RCA/PPP enrollment criteria, collect all written affidavits of household size, budget, and income, and will review the Benefits and Client Responsibilities (B&R) document and ascertain whether the refugee consents to the enrollment in the CA programming pursuant to the requirements detailed in

Procedure and all other PPP documentation the B&R, and review the Grievance with the refugee. The B&R shall serve as the enrollment document delineating the benefits to be paid and the responsibilities of application. If refugees are enrolling into RCA, the case worker will have the refugee sign the above documents, including the B&R. The PPP intake worker will then begin the PPP Program in ARRPODS. In cases of TANF enrollment, a PPP caseworker will create a cash benefit application and have refugees sign the above documents, except the B&R until TANF benefits are issued. When the refugee is marked eligible for TANF benefits and presents an ADES Case Number, refugees will meet with a PPP staff member for an intake, sign the B&R, and enroll into ARRPODS for TANF PPP differential payments.

v. If the refugee does not have a sponsoring LRA, the refugee will need to seek assistance and be enrolled into employment services with an RRP employment provider.

▪ Enrollment.

If the refugee consents to the B&R, the PPP caseworker shall obtain the signatures of each adult member of the case providing consent for enrollment. Enrollment shall consist of the following:

i. Start the Refugee Cash Program in ARRPODS by creating a Cash Program Object Record for every member of the case. RCA and TANF cases will be made in accordance with the Affidavit of Household Size contained in the application documents.

ii. A refugee has 30 days from the date that the PPP application is signed to provide all required documents and to sign all attestations to household size, budget, and income. If a refugee does not complete the application process within 30 days, the application will be denied and subject to reapplication.

iii. In cases of TANF enrollment, the PPP intake workers follow the same RCA enrollment steps but begin the TANF Program in ARRPODS for refugees with TANF eligibility enrollment documents and an ADES Case Number. TANF cases are established based on the household size and composition identified in the PPP

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Household Affidavit, and may change based on client attestation that household members have been added or subtracted from the household unit, per the completion of a new Household Affidavit. Should a refugee not be eligible for enrollment into the TANF Program for a non-procedural reason but still meet the established RCA enrollment criteria, the TANF denial documentation will be required to be enrolled into RCA.

▪ If a refugee on TANF presents to a PPP caseworker and is already receiving TANF benefits, PPP caseworkers may backdate payments from the date they enrolled into TANF provided this date does not predate the grant of status for ORR services. If the backdating is more than two months prior to application, the PPP caseworker will notify RRP. RRP will finalize the enrollment and backdate the PPP TANF differential program to the appropriate date.

i. Contact the refugee’s primary employment specialist and notify them of the refugee’s enrollment and that an EP is required to be developed.

ii. Contact the refugee’s primary case manager and notify them of enrollment.

iii. Create an initial cash case budget detailing the basic household expenses. This initial budget shall be substantiated by budget affidavits acquired in the enrollment process.

Refugees receiving RCA will have a monthly income eligibility redetermination done through the assessment of the cash units’ budget and the point in time employment records contained in the ARRPODS. Refugees will remain on RCA as long as their budgets present a net negative income or reach their 12 month time limit pursuant to their grant of qualifying status. Monthly payments are authorized by the PPP contractors for their refugees based on a client's continued compliance with their SSPs. ARRPODS automatically checks for the completion of activities assigned to refugees in their SSPs.

When refugees have active tasks assigned to them and RSS-funded case workers indicate that they are in good standing with the plan, a positive payment status is established in the database. This positive payment status allows the PPP caseworkers to then approve the payment to each case. Should an active SSP task not be detected or a refugee not be in good standing with their plan pursuant to the established fair hearing standards, ARRPODS will not allow an RCA payment to be made. RCA payments will be held until such time that an eligible beneficiary comes into compliance, or until two months of no contact has elapsed, at which time CA is terminated for non-compliance.

c. After consultation with the LRAs, RRP established the RCA income standard in relation to an RCA case budget. As long as an RCA case maintains a net negative income and is within 12 months of their ORR eligibility date, the client will remain eligible for RCA.

Net negative income is defined as the basic expense needed for the maintenance of household exceeding available employment income. RCA caseworkers will create the case budget pursuant to the budget affidavit. The client must sign an income attestation confirming that no income was received at the time of CA application. The PPP

Arizona State Plan for Refugee Resettlement FFY 2024 Page 16 caseworker will inquire with the client monthly about changes in income as part of the monthly recertification process. Clients are only required to provide evidence of employment (e.g., pay stubs, bank statements) or an updated income affidavit once entering employment. Should a client not enter employment, the original income affidavit is considered accurate and the initial budget is maintained. For purposes of the CA basic maintenance of household, variables are defined as follows:

▪ Housing costs.

▪ Utilities costs.

▪ Basic transportation costs.

▪ Communication technology costs.

▪ Laundry and necessary household supplies.

▪ Medical costs not covered by State Medicaid and pursuant to physician/psychiatrist care directives.

▪ Documented childcare costs exceeding the rates provided by the State.

The cost of the aforementioned items is set as the cost of the accommodation/goods as established under R&P. Should a refugee not wish to utilize the accommodations/goods obtained by their sponsoring LRA, or should they not have a local sponsoring LRA, then the cost of expenses shall be capped at 25 percent above the maximum of the Interquartile Range (IQR). The data set to be utilized to calculate the IQR will consist of cases arrived during the past FFY and that are equivalent in size and resettled though an LRA. In circumstances where a refugee(s) arrives with substantive resources verified as accessible by a caseworker, they shall be made eligible for RCA when it is ascertained that the sum accessible to the refugee(s) is less than that required to maintain a household until entering employment. The sum required to maintain a household until income is obtained is defined as the monthly expenses established in the budget multiplied by the average amount of time it takes a refugee to obtain employment from their Arizona entry date, or six months in instances where the Arizona entry date to entering employment timeline surpasses six months.

On a monthly basis, ARRPODS will automatically collect employment placement data entered by the RSS contracts and compare that data against the monthly budget set by the caseworkers for RCA recipients. Once a positive income state has been verified, RCA recipients will be required to provide income verification to PPP caseworkers who will compare the post-employment earned income of the case to the cost of the maintenance of the household as established in the redetermination process. Clients are required to show proof of employment and income within 30 days of the change. Acceptable documentation includes paystubs, bank statements, or employer income verification (either by phone or email).

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If clients are unable to show proof of employment and income, caseworkers will attempt to obtain employment and income verification from employers directly. If the above documents are not able to be obtained, clients will need to complete the Client Income Attestation Form. This form will be signed under penalty of perjury, verifying hourly wages and weekly hours worked, or any other forms of income that are not related to employment. If proof of income and employment is obtained, a Client Income Attestation Form will no longer be needed. If clients are hired under a contract basis or do not earn a consistent wage, they will need to specify the previous monthly income and/or projected monthly income. If the above methods for employment and income verification are unsuccessful and 30 days have lapsed since the change in employment or income, benefits will not be paid until employment and income can be verified.

If any cash program member or an employer hides information or provides false information resulting in clients receiving benefits to which they are not entitled, that person will be subject to overpayment recovery.

Clients will maintain full benefits until they have actually earned sufficient income from employment to assume the full payment of their monthly expenses. Once a positive income state is identified for the case, the client will retain benefits for the month it was identified and the month immediately following. After this time period, the client(s) shall be terminated from the RCA PPP Program. If the case enters a positive income state prior to the average elapsed time from Arizona entry to employment acquisition for the past FFY, the case will receive an income disregard incentive. The income disregard incentive allows a refugee to remain on RCA until the average amount of time from Arizona entry to employment acquisition has elapsed. Once the average amount of time from Arizona entry to employment acquisition has elapsed the termination process described will commence. The average time from Arizona entry to employment acquisition will be calculated from ARRPODS records for the past FFY. For FFY 2023, the current time from Arizona entry to employment entry stands at 3.5 months and for the purposes of this timeframe, this number will be rounded to four months. This timeframe shall be re-calculated annually. The income disregard will be capped at six months.

RRP and the LRAs choose to tie the income eligibility of RCA cases to the case budget to ensure stability in housing and basic needs. The provision of CA to maintain household stability allows for the case to meaningfully participate in the SSPs and EPs without interruption and subsequent regression caused by basic needs not being met.

Traditional income thresholds set at a certain percentage do not always consider outlier cases and lead to situations where refugees may lose stability in basic housing needs, thus altogether stopping or causing a refugee to regress in their progress towards self-sufficiency. The State TANF income eligibility standards are as follow:

▪ One hundred thirty percent of the current…