1820 Work Activities | TANF
Georgia Division of Family and Children Services |
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Policy Title: |
Work Activities |
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Effective Date: |
October 2024 |
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Chapter: |
1800 |
Policy Number: |
1820 |
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Previous Policy Number(s): |
MT 76 |
Updated or Reviewed in MT: |
MT-78 |
Requirements
A recipient of cash assistance who has a work requirement must participate in specific work activities for a minimum number of hours per week in order to move towards full-time employment.
Basic Considerations
The main purpose of meeting work requirements is to move an individual towards full-time employment as soon as possible and to preserve months of potential TANF eligibility.
A recipient of cash assistance who has a work requirement is expected to participate in work activities at a level consistent with full-time employment (i.e., 40 hours per week) when such participation is determined by the agency to be appropriate.
A week of participation is defined “as five days of work or work activity, to be consistent with the standard work week of five working days and two weekend days.
The case manager must give special consideration to the client’s remaining months of potential TANF eligibility, or TANF clock, when considering which work activities will contribute to the attainment of the client’s goal. Hours of participation may be in one activity or in a combination of activities.
Participation in specific core (primary) activities is required. Participation in additional non-core (secondary) activities is allowed if the client is participating for a minimum number of hours in core (primary) activities.
A non-core (secondary) activity may only be included as part of a TANF Family Service Plan (TFSP) - Work Plan if:
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the client is already meeting federal work requirements by participating in other countable core (primary) activities or
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the case manager determines its inclusion as part of the TFSP - Work Plan is necessary to prepare the client for participation in a countable activity for a limited time, with consideration of the TANF clock.
Refer to Chart 1820.1 - Work Activities at the end of Section 1820 regarding designation type of activity.
Hours of Participation
When appropriate the case manager can and should schedule a work eligible recipient of cash assistance to participate in work activities at a level consistent with full-time employment (i.e., 40 hours per week).
Such participation is to ensure that work-eligible individuals meet their hourly work requirements providing some leeway, should a client miss hours due to some unforeseen circumstances.
The minimum average hours per week a work-eligible, single-parent or pregnant woman must be engaged in work activities is 30 hours per week. At least 20 of the 30 hours per week must be attributable to one or more core (primary) activity. After an individual meets the basic level of participation in a core (primary) activity, a non-core (secondary) activity may be used to count toward the 30-hour minimum standard.
The number of hours required for each activity per week must be specified in the TFSP - Work Plan.
Hours of participation in countable work activities are totaled on a weekly basis. For keying purposes, actual hours of participation must be entered including all decimal places. When calculating the WPR, rounding can be used. Fractions of an hour are rounded up if one-half hour or more or rounded down if less than a half-hour. However, the calculation of FLSA hours for participation in activities is never rounded up.
Actual hours of participation for a month are totaled and divided by the number of weeks in the month to determine whether a client has met the federal averaged weekly standard of hours of participation.
Single Custodial Parent with Child Under Age Six
A single custodial parent or caretaker relative with a child under age six will count as engaged in work if he or she participates for at least an average of 20 hours per week in a core (primary) activity.
Pregnant Teen or Teen Parent Head of Household
A pregnant teen or teen parent (under 20 years of age) head of household who does not have a high school diploma or GED is counted as meeting work activity requirements in a month if s/he:
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maintains satisfactory attendance and progress at a secondary school or the equivalent during the month, or
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participates in education related to employment for an average of at least 20 hours per week during the month and achieves satisfactory attendance and progress
If education related to employment does not average at least 20 hours weekly, the client will not have met participation requirements.
Participation in these activities supersedes any requirement to participate in other work activities. However, other activities like employment should be encouraged.
In order to move these clients as quickly as possible to employment and to preserve their TANF months, when appropriate, employment and other work activities should be included in their TFSPs. |
Only actual hours of participation should be entered. If the work eligible pregnant teen or teen parent has met the conditions defined above; they will be considered to have met the participation requirements.
Two-Parent Assistance Units (AU)
A two-parent AU is defined as an assistance unit that includes all families with two natural or adoptive parents (of the same minor child) who are work eligible individuals and living in the home, unless both are minors, and neither is a head-of-household.
An individual in a two-parent AU counts as engaged in work for the month if:
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an individual and the other parent in the family are participating for an average of at least 35 hours per week in one or more core (primary) activities OR
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An individual and the other parent will be considered as engaged in work for the month if an individual and the other parent are participating for an average of at least 30 hours per week in one or more core (primary) activities and an average of 5 hours per week in one or more secondary activities.
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If receiving federally funded childcare assistance, then the individual and the other parent must be participating in one or more core activities for a combined average of 55 hours per week OR
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If receiving federally funded childcare assistance, then the individual and the other parent must be participating in one or more core activities for a combined average of 50 hours per week and 5 hours per week in one or more secondary activities.
Countable Core (Primary) Activities
For those clients who are determined job-ready, the following core (primary) activities may be appropriate:
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Unsubsidized employment
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Subsidized employment (public)
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Subsidized employment (private)
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Job search and Job readiness assistance,
For those clients who are determined near job-ready or not job-ready, the following core (primary) activities may be appropriate:
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On-the-job training (OJT)
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Work experience (WEX)
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Community service programs
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Vocational educational training
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Provision of childcare services to an individual who is participating in community service.
Hours of participation in work experience and community service program activities are limited in accordance with Fair Labor Standards Act (FLSA) guidelines.
Refer to 1349 Work Requirements for additional information regarding Work Eligible Parents.
A client who is participating in any of the core (primary) work activities listed above can also receive credit for hours of participation in certain other work activities under specific circumstances.
Countable Non-Core (Secondary) Activities
A work-eligible parent from a single-parent household or pregnant woman who is participating in core (primary) work activities for an average of at least 20 hours per week, and clients from a two-parent household who are participating in core (primary) work activities for a combined average of at least 30 hours per week, may participate in one of the following non-core (secondary) activities for the remaining hours required to meet federal work participation requirements:
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Job skills training directly related to employment
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Education directly related to employment or
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Satisfactory attendance and progress at a secondary school or in a course of study leading to a certificate of general equivalence.
If a 2-parent household receives federally funded child-care assistance and are participating in core (primary) work activities for a combined average of at least 50 hours per week, they may participate in one of the activities above for the remaining 5 hours to meet federal work participation requirements.
Non-Countable (Other) Activities
All recipients may participate in the following activities if they are meeting the required number of hours in their core (primary) work activities alone or in combination with the three non-core (secondary) activities.
Hours of participation in the following activities cannot count, either alone or when combined with any core (primary) or non-core (secondary) work activities, toward meeting the federal work participation rate requirements:
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Job search and Job readiness assistance after the six-week or the equivalent number of hours limit has been reached,
Hourly equivalent for the purpose of the six-week limit is 120 hours for a single custodial parent with a child under six and 180 hours for all other work-eligible individuals. The hourly equivalent for the purpose of the 12-week limit is 240 hours for a single custodial parent with a child under six and 360 hours for all other work-eligible individuals. -
Vocational educational training in excess of the 12-month limit
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Job readiness training which is independent of job search activity
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Assessment
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Mental health counseling/treatment (after the six-week limit)
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Addictive disorders counseling/treatment (after the six-week limit)
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Life skills training (after the six-week limit), and
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Parenting skills training.
Under the Deficit Reduction Act of 2005, Mental Health Counseling/Treatment, Addictive Disorders Counseling/Treatment, Life Skills Training, and Parenting Skills Training can be classified as a core (primary) activity if entered under Job Search/Job Readiness activity. |
Many Mental Health and Addictive Disorder treatment approaches include countable work activities. These programs should be considered first when developing a TFSP - Work Plan.
A client can be assigned to participate in one or more of the activities listed above instead of a countable work activity. However, a non-countable (other) activity may only be included as part of the TFSP - Work Plan if:
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the client is already meeting federal work requirements by participating in other countable activities, or
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the case manager determines its inclusion as part of the TFSP- Work Plan is necessary to prepare the client for participation in a countable activity, for a limited time, with consideration of the TANF clock.
Verification and Documentation Criteria for Credited Hours
Hours of participation in all work activities (countable and non-countable) must be verified. Typically, verification must be obtained by receipt of Form 516, Record of Attendance and Performance Report, Form 517, Record of School Attendance and Performance Report, or Form 495, Job Search Record.
When employment is reported and the combination of employment hours and income are enough to cause TANF ineligibility, client statement may be accepted for work participation hours for an employment activity. |
This information must be submitted to the case manager monthly depending on the reporting requirements for each activity. Other written or verbal confirmation of hours from the vendor or the institution where the activity was performed may also be submitted/accepted. If verification of work participation hours is received verbally, documentation must be added in Case Notes to include:
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Name of the vendor and/or person that verified the work participation hours
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Phone number of the vendor and/or person that verified the work participation hours
The participant is ultimately responsible for providing verification of attendance and performance by submitting Forms 495, 516 or 517 to the case manager. Failure to provide verification may result in the onset of the conciliation and/or the sanction process. Refer to the work activity guidelines for explanations or variations in the verification requirements.
Holidays
Under federal guidelines Georgia gives TANF participants credit for holiday and excused absences in unpaid work activities. A participant may be credited with hours of participation in a work activity other than employment in the event of a federal or state holiday.
The federal and state holidays identified for the TANF Program are: New Year’s Day, Martin Luther King Jr.'s Birthday, Memorial Day, Independence Day, Labor Day, Veteran’s Day, Thanksgiving Day, the day after Thanksgiving Day, Christmas Day, and the day after Christmas Day.
Holiday hours cannot be credited for an employment activity such as unsubsidized employment, subsidized employment (public or private), or on-the-job training.
Excused Absences
Georgia also gives TANF participants credit for excused absence in unpaid work activities.
The countable excused hours of participation cannot exceed more than 80 hours in the preceding 12-month period and no more than 16 hours of which may occur in a month.
Work activities for which a client can be credited for hours of non-participation are work experience, community service programs, job search/ job readiness, vocational training, and providing child-care services to an individual who is participating in community service programs.
To count an excused absence as actual hours of participation, the individual must have been scheduled to participate in a countable work activity for the period of the absence.
Situations that may be considered for these excused absences include the following:
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a temporary medical condition or illness which is obvious or otherwise substantiated,
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a family crisis or personal crisis,
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domestic violence issues,
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a natural disaster or weather emergency,
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lack of transportation,
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lack of childcare, or
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a court-required appearance.
Participants are required to report absences immediately to their case managers. The case manager makes the determination as to whether the situation meets the criteria for an excused absence, requests any documentation needed, and documents their decision in the participant’s file and on a tracking document.
The excused absence hours cannot be credited for paid activities such as: On-The-Job Training, Subsidized Employment (public or private), Unsubsidized Employment and Self-Employment.
Verification and Documentation Criteria for Excused Hours
Immediately upon receiving absenteeism information, the case manager must verify and document the reason why, on a specific day or for a specific period, a client could not report to a work activity site or attend a class. This information should be documented in Case Notes in the Integrated Eligibility System (IES).
If the reason meets any of the criteria specified above, the case manager can include excused hours for which the client would have participated in the countable activity in accordance with the client’s normal pattern for work activity participation.
Fair Labor Standards Act (FLSA) Deeming
Georgia has adopted a “mini” Supplemental Nutrition Assistance Program (SNAP), which will enable the State to count the value of SNAP benefits when calculating hours of participation for activities that are subject to the Fair Labor Standards Act (FLSA).
Georgia uses FLSA deeming for work-eligible individuals who participate in work experience or community service programs. However, deeming does not include Childcare for Community Service program. We calculate the number of hours for deeming purposes by dividing the monthly TANF grant by the appropriate minimum wage and the monthly SNAP allotment by the appropriate minimum wage and then the results are added together.
A participant who is engaged in work experience or community service programs for the maximum hours allowed under the FLSA calculation and this calculation falls below the 20 hours per week of participation will be considered deemed meeting for the 20 hours per week of participation for that core activity.
This participant must also be engaged in an additional 10 hours per week of core (primary) non-FLSA or non-core (secondary) work activities to meet the federal participation guidelines and to move the individual towards employment as quickly as possible.
A single custodial parent with a child under six does not have to participate an additional 10 hours as they are considered meeting work participation at 20 hours weekly. |
The staff needs to carefully monitor participation in these activities. The actual hours of participation in a core work activity must be entered in the system.
FLSA Calculations
If a SNAP AU includes members who receive TANF and members who do not receive TANF, staff will count the entire SNAP benefit toward the TANF work requirement, unless a SNAP work program requirement such as workfare (SNAP Education & Training - E&T) is also being based on the SNAP benefit. In that case, the benefits would be prorated with the SNAP Benefits of the TANF household counted toward the TANF work requirement and the SNAP benefits of the other members counted toward the SNAP work requirement. Benefits would not be double counted toward both requirements.
The hours based on the TANF cash assistance grant and the hours based on the SNAP allotment must be calculated separately. The composition of the TANF AU may be different from the SNAP AU. When doing calculations, fractions of an hour are retained to 1/100th of a whole number and dropped after the TANF and SNAP hours are added together. Fractions of an hour cannot be rounded up.
In order to provide the participants with a consistent weekly schedule, we divide the monthly FLSA hours by four, keeping in mind that there will be some months that have five weeks. Therefore, the number of allowable hours must be reviewed monthly and recalculated whenever necessary.
The maximum number of hours that can be permitted in a month is the sum of the TANF hours and the SNAP hours. Refer to the example below:
Example:
TANF = $280 per month ÷ $7.25 = 38.62 hours per month
SNAP = $526 per month ÷ $7.25 = 72.55 hours per month
Total number of hours = 38.62 + 72.55 = 111.17
The FLSA hours of work activity permitted for the month in the above example would be 111 hours.
If the participant misses some hours of participation in one week, the hours can be made up in another week of the same month not to exceed the FLSA limit.
If the averaged actual weekly hours of participation allowed under the FLSA calculation falls below the 20 core hours of participation per week, over the course of a month, the work eligible adult will be considered deemed meeting the 20 hours per week of participation for that core activity.
However, if this participant is a single custodial parent with no child under six or a pregnant woman with no dependent children, the participant must be engaged in an additional 10 hours of non-core or non-FLSA work activities in order to meet the full 30-hour federal participation guidelines.
In an AU in which more than one participant has a work requirement, the total FLSA hours cannot exceed the number of allowable hours derived by using the formula above.
General Guidelines for Work Activities
The DFCS case manager must follow the general guidelines listed below when placing a client in activities:
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Whenever job ready, employment should be the client’s mandatory work activity.
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Whenever possible, participation in activities specified in the TFSP–Work Plan should be at a level consistent with full-time employment, i.e., 40 hours per week.
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Whenever possible, the case manager must assign the client to work activities that count towards the federal work participation rate and move the client towards full-time employment.
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A non-core activity may only be included as part of the TFSP-Work Plan if:
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the client is already meeting federal work requirements by participating in other countable activities.
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the case manager determines its inclusion as part of the TFSP is necessary to prepare the client for participation in a countable activity, for a limited time, with consideration of the TANF clock.
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The number of hours required for each activity must be specified in the TFSP-Work Plan.
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A participant who already has a marketable job skill must not be trained to develop another skill but must be placed in a job appropriate for existing skills.
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A participant must meet the number of hours required and meet the satisfactory progress requirements for each activity to which s/he is assigned.
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A participant who fails to meet activity requirements without good cause has committed a material violation. The commission of a material violation can result in the imposition of a sanction against the assistance unit.
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A participant must provide verification of participation in activities.
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Whenever possible, a participant must be referred to providers who provide services at no cost to DFCS.
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A participant who attends a private school may receive support services. We must not refer a client to a private school unless the required course of study is unavailable from a government school.
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No tuition will be paid for post-secondary activities for which assistance through Pell or HOPE grants is available.
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When near job-ready, a client may be referred for education or training only when the education or training program to which a referral is made provides preparation for a job that is currently available in the local labor market or that is expected to be available in the future.
General Guidelines for Submission of Hours of Participation
Verification of work participation hours completed must be submitted to the case manager every month. This report is due by the fifth calendar day in the month following the report month. If the report month has a fifth Monday, the report is due by the tenth calendar day in the month following the report month. Forms 516, 517, 495, and 809 can be used to verify work participation. This list is not all-inclusive.
Activity Descriptions, Requirements, and Guidelines for Countable Core (Primary) Work Activities
Listed below are countable Core (Primary) work activities.
Unsubsidized Employment
Unsubsidized employment is full or part-time employment in the public or private sector that is not subsidized by TANF or any other public program. Unsubsidized employment must be given first consideration for any client who is job ready.
Guidelines for Unsubsidized Employment
The TFSP-Work Plan must require unsubsidized, full-time employment for a client who is already working in unsubsidized part-time employment and does not have barriers to full-time employment.
Full-time, unsubsidized employment must also be required if the client is unemployed but has been assessed as having the capability of obtaining immediate full-time employment.
Generally, full-time, unsubsidized employment will indicate the participant is soon ready to exit TANF. Therefore, a participant who is employed full-time but earns less than minimum wage is under-employed. The focus of the TFSP-Work Plan should be to increase earnings, benefits and job retention, in order to maximize earnings, prior to ending TANF.
Verification of Hours of Employment
When a client obtains unsubsidized employment, hours of employment may be verified by the employer’s statement or by other written information provided by the employer. Client statement can only be accepted for self-employment.
When employment is reported and the combination of employment hours and income are enough to cause TANF ineligibility, client statement may be accepted for work participation hours for an employment activity. |
As they become available, check stubs or other wage verification may be used to verify hours of employment. If the client’s hourly rate of pay is known, hours can be determined based on gross earnings.
Information already contained in the eligibility case record that has been used to verify earned income may be used to verify hours of employment.
Subsidized Employment (Private or Public)
Subsidized employment is employment in private or public sector for which the employer receives a subsidy, or (b) a predetermined percentage is paid to the employer from TANF or other public funds to offset some or all of the wages and costs of employing a TANF recipient.
In Georgia, the recipient’s wages are subsidized through grant diversion or cash reimbursement for a maximum period of six months. The intent of diverting a client’s TANF grant to a potential employer is to provide an incentive for the employer to hire the client.
Subsidized employment placements are intended to, but are not required to, provide permanent, full-time jobs to individuals who are job-ready and/or near job ready, but who may lack the work history necessary to find unsubsidized employment
In addition to paying the participant a competitive salary, the employer must pay benefits that are comparable to those received by regular employees in similarly classified positions.
Refer to sections 1825, 1826, and 1827 of the policy manuals to learn more about subsidized employment.
Guidelines for Subsidized Employment
A subsidized employment participant is granted employee status for the duration of the Subsidized Employment Agreement (SEA) and receives the benefits available to a regular employee of that employer.
A participating employer must:
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provide full-time employment, defined as no less than 30 hours of work per week, pay a salary consistent with what would be paid to another employee in a similar job with similar experience
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provide a written list of supplies, equipment and work clothing required of new employees
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agree to receive the diverted TANF grant or pre-assessed percentage as a direct deposit
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coordinate training with partner agencies
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not displace a regular employee with a subsidized placement
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not hire for a subsidized position because of a strike or lockout, and
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make all efforts to retain the participant in a regular, salaried position unless there is good cause for dismissal. Good cause reasons for dismissal include, but are not limited to:
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economic reasons requiring a reduction in force by the employer
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frequent absences from work by the employee
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disruptive or inappropriate behavior by the employee
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the employee’s inability to perform at an acceptable level.
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When a client is dismissed from a subsidized position, the case manager must decide if good cause for dismissal exists. If the dismissal is due to the client’s behavior, the case manager should begin the conciliation/sanction process.
An employer who fails to continue the successful participant’s employment without good cause will not be granted subsequent contracts. Before the agency can enter into subsequent contracts with an employer, participants who have previously been laid off must be recalled.
The client must receive a rating of satisfactory or better from the participating employer. The employer may submit Form 516, Record of Attendance and Performance Report to the case manager every month. This report is due by the fifth calendar day in the month following the report month. If the report month has a fifth Monday, the report is due by the tenth calendar day in the month following the report month.
Failure to pay all or a portion of wages owed to the employee constitutes a breach of the SEA and terminates the agreement immediately. The employer cannot receive additional subsidies, and DFCS may recover diverted payments made for months for which the employee was not paid fully for wages earned.
The participant is paid at a rate equal to that of a regular employee in the same position with the same responsibilities.
The participant must be available for immediate employment. Hiring is solely at the discretion of the employer.
Responsibilities for Subsidized Employment Placements
DFCS is responsible for publicizing to its client population and to local businesses that subsidized employment is available. The agency is also responsible for recruiting employers to participate. These responsibilities may be carried out directly by DFCS or may be delegated to partner agencies.
The case manager is responsible for conducting an assessment and determining the job readiness level of the client. It is expected that job-ready and near job-ready clients will be placed in unsubsidized employment.
Both before and after a placement has been made, the case manager is responsible for the provision and monitoring of support services that are needed in order for the client to successfully continue in the subsidized placement.
The case manager must meet with the client prior to the latter’s placement in a subsidized job to ensure that all needed support services are in place. The case manager must also monitor the agreement to ensure the employer complies with the terms of the SEA.
The case manager is responsible for making subsequent referrals for in-depth assessments that are deemed necessary based on an identification of additional barriers to employment that may not have been detected prior to the initial subsidized job placement.
The case manager or other assigned staff is responsible for overseeing the development of job sites and for establishing agreements with participating employers so that certain criteria are met. Staff assigned to develop subsidized employment sites must complete Form 200, TANF Subsidized Employment Agreement for each site developed.
While the actual development of sites and the establishment of agreements with participating employers may be done by staff from partner agencies and not by the case manager, the case manager does have the final responsibility for ensuring that the work performed by partner agencies is consistent with TANF policies and goals.
A participating employer will receive a subsidy to offset a portion of the cost of the client’s salary for the duration of the subsidized placement. If the client’s job performance is satisfactory, the employer is expected to offer the client permanent employment.
Prior to placement in a subsidized position, the client must meet with the case manager and representatives from any participating partner agencies in order to ensure that needed training and support services are identified.
Monitoring of Subsidized Employment Placements
All subsidized employment job sites are to be monitored monthly. The case manager or other assigned staff must make an on-site visit during the first month of placement.
Subsequent monthly contacts may be made in person or by telephone.
Contacts are intended to verify that the employer is providing training appropriate to the participant’s abilities to perform the basic duties of the job. Monitoring contacts must be documented in the participant’s case record.
Though staff from partner agencies may complete the actual monitoring function, the case manager has the final responsibility to ensure that the monitoring is performed on an ongoing basis.
Orientation for Subsidized Employment
A prospective participant must attend a subsidized employment orientation session in which the case manager explains the following:
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participant criteria
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employer criteria,
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diversion of the entire TANF grant to the employer, and
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potential eligibility of Work Support Program payments.
A trial budget will have to be completed to show the amount of earnings required to reduce the AU’s grant amount to zero.
Verification of Hours of Subsidized Employment
Prior to placement in a subsidized position, the case manager or the contracted staff must meet with the client and with the participating employer to discuss requirement to verify hours of employment. This requirement is to ensure that the client receives needed training, abides by the rules of employment and the agency provides all support services identified in the TFSP-Work Plan or identified later during participation in the activity.
The hours of subsidized employment may be verified by:
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the employer’s statement,
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written information provided by the employer,
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copy of a check received by the client, or,
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by dividing gross pay by the hourly rate if it is known to the agency.
Information already contained in the eligibility case record that has been used to verify earned income may be used to verify hours of employment. However, the case manager must document the source of verification for that month.
Termination of Placement
If the client fails to participate, or the employer does not provide needed training to the client, appropriate procedure will be followed.
Refer to 1825 Subsidized Employment General Requirements for detailed policy.
Work Experience (WEX)
A work experience (WEX) is a work activity performed in return for public assistance, that provides an individual with an opportunity to acquire the general skills, training, knowledge and work habits necessary to obtain employment.
The purpose of work experience is to improve the employability of those who cannot find unsubsidized full-time employment. If previous attempts to obtain unsubsidized or subsidized employment have been unsuccessful, the client should be referred for a work experience placement.
Guidelines for Work Experience
Work experience placements are intended to provide training to an individual who is near job-ready and who needs to develop or improve the job skills and work habits necessary to succeed in a regular job environment.
Work experience placements can be made with either a public sector employer or a private sector non-profit or for-profit employer. It is expected that placements in WEX for more than 3 months would only be acceptable in settings that are expected to turn into full-time employment.
The work experience participant is not an employee of the work site provider and is not paid for hours of participation by the employer.
The work experience site sponsor is expected to offer training opportunities with appropriate supervision within an environment that generally replicates that of regular employment. The sponsor must be made aware that job coaching, and mentoring may be needed to help the participant succeed.
The work experience site sponsor must provide a detailed description of the activities in which the client will participate. The sponsor must also comply with the requirements specified for the sponsor on Form 482, the TANF Work Experience Agreement Form.
The sponsor is responsible for providing reasonable accommodations to work experience participants who have varying job skill levels or who may have physical or mental disabilities.
A client referred for placement at a work experience site must be regarded by the case manager as having the ability for performing the tasks that will be required of a participant and that appropriate accommodations will be provided. A client must not be referred to sites where overnight travel or travel over unreasonable distances will be required.
Requirements for Hours of Participation
A work experience participant is subject to FLSA guidelines. A participant is therefore restricted to a maximum number of hours per month of participation in this activity.
The maximum number of hours permitted is determined by dividing the amount of the AU’s regular TANF cash assistance and the AU’s SNAP allotment by the minimum wage.
The hours based on the cash assistance grant and the hours based on the SNAP allotment must be calculated separately. The composition of the TANF AU may be different than the SNAP AU. Staff should count the entire SNAP benefit toward the TANF work requirement, unless the SNAP work program requirement such as SNAP E&T is also being based on the SNAP benefit. Benefits would not count twice toward both requirements.
In that case, the benefits would be prorated with the SNAP Benefits of the TANF household counted toward the TANF work requirement and the SNAP benefits of the other members counted toward the SNAP work requirement. Benefits would not be double counted toward both requirements.
When doing calculations, fractions of an hour are retained to 1/100th of a whole number and dropped after the TANF and SNAP hours are added together. Fractions of an hour cannot be rounded up.
The number of allowable hours must be reviewed monthly and recalculated whenever necessary.
The maximum number of hours that can be permitted in a month is the sum of the TANF hours and the SNAP hours. Refer to the example below:
Example:
TANF = $280.00 per month ÷ $7.25 = 38.62 hours per month
SNAP = $526.00 per month ÷ $7.2 = 72.55 hours per month
Total number of hours = 38.62 + 72.55 = 111.17
The FLSA hours of work activity permitted in the above example would be 111 hours for the month.
If the participant misses some hours of participation in one week, the hours can be made up in another week in the same month not to exceed the FLSA limit.
If the averaged actual weekly hours of participation allowed under the FLSA calculation falls below the 20 core hours of participation per week, over the course of a month, the work eligible adult will be considered deemed meeting the 20 hours per week of participation for that FLSA activity.
However, if this participant is a single custodial parent with no child under six or a pregnant woman with no dependent children, the participant must be engaged in an additional 10 hours of non-core or non-FLSA work activities in order to meet the full 30-hour federal participation guidelines.
Responsibilities for Work Experience Placements
The case manager is responsible for conducting an assessment and determining the job readiness level of the client. Special consideration must be given to the client’s goals and his or her TANF clock when making work experience placements.
The case manager is responsible for ensuring that both the sponsor and the participant understand the terms and conditions of the work experience agreement.
When an agreement has been reached with a potential sponsor, the sponsor and the case manager must sign Form 482, the TANF Work Experience Agreement form. A client can only be assigned to a work experience site if an agreement has been signed with a sponsor.
The county DFCS office must maintain a central file of all work experience agreements. A copy of the agreement form must be provided to the client and to the sponsor.
After placement at a work experience site is arranged, the case manager is responsible for the provision and monitoring of support services that are needed prior to and during the client’s participation in the activity.
Consequently, before the client’s placement in the work experience activity, but after the assessment has been completed, the case manager must meet with the client as well as staff from any partner agencies that may be involved in the placement process to ensure that all needed support services are in place. Before placement, ensure that all needed support services are specified in the TFSP - Work Plan.
Additional joint staffing must be conducted as needed throughout the duration of the work experience placement.
The case manager is responsible for making subsequent referrals that are deemed necessary based on the identification of additional barriers to employment that may not have been detected prior to the initial work experience placement.
Verification of Hours of Participation in Work Experience
The case manager or other assigned staff is required to verify hours of participation in a work experience activity.
The case manager must verify hours of participation at least monthly. This verification can be:
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a statement by the site supervisor, or
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Form 516 completed and signed by the site supervisor.
Documentation of monthly verification of WEX hours in the case record is required. The case manager, however, may choose to verify hours on a weekly or bi-weekly basis.
The participant must receive a rating of satisfactory or better from the work experience site supervisor. Form 516, the Record of Attendance and Performance Report form must be submitted monthly. This report is due by the fifth calendar day in the month following the report month. If the report month has a fifth Monday, the report is due by the tenth calendar day in the month following the report month.
Monitoring
The number of hours required for the work experience placement must be reviewed at least every 30 days. Changes must be documented. A change in the number of hours of participation must be indicated on the Form 516, Record of Attendance and Performance report and communicated to the client and to the work experience site supervisor.
The case manager is responsible for monitoring the progress of each work experience participant and for verifying that the employer is providing training appropriate for the participants, enabling them to perform the basic duties of the work experience assignment.
It is the case manager’s responsibility to determine if the client has received the maximum benefit from the placement and whether the client should be moved to a different activity.
All work experience sites are to be monitored on a regular basis. The case manager or other assigned staff must make an on-site visit during the first 2 weeks of placement.
Subsequent contacts must be made on a regular basis, the frequency to be determined by the county. Monitoring contacts must be documented in the participant’s case record.
Grievance Procedures
A work experience participant must contact the case manager if there is a problem at the site in need of resolution.
Complaints from regular employees of the work experience sponsor should be made in writing to the local DFCS office. Valid complaints include, but are not limited to, the displacement of a regular employee by a work experience participant, or the assignment of a work experience participant to a regular position during a legal strike or other job action.
Placement Termination
A sponsor may terminate a work experience placement at any time by completing the appropriate line on the TANF Work Experience Agreement form and submitting it to the case manager within five calendar days of termination. If the termination is initiated by DFCS, as much advance notice as possible must be given to the sponsor.
On-the-Job Training
On-the-Job Training (OJT) is paid training in the public or private sector that is given to an employee while s/he is engaged in productive work that provides knowledge and skills essential to the full and adequate performance of the job.
Any paid training, whether provided off-site or at the work site, fits the definition of on-the-job training.
The goal of OJT is to provide training for a client who has been hired for a particular job but who may nevertheless lack some of the skills required for adequate job performance. Through a contractual arrangement or other form of agreement, the sponsoring entity pays to an employer reimbursement of up to 50% of a participant’s wages for the employer’s verified costs of providing the training and additional supervision that is related to the training.
The division, a partner agency or other organization may enter into an agreement with an employer to provide OJT to TANF recipients.
The sponsoring entity is responsible for developing an OJT site and for providing the case manager or other assigned staff with documentation of the participant’s daily attendance and performance.
The employer is responsible for developing a training plan and agrees to retain the employee upon successful completion of the training plan.
Guidelines for OJT
The duration of OJT must be limited to what is appropriate to the job for which the participant is being trained. The OJT plan must take into consideration the client’s goals, TANF clock, education, prior work experience, existing job skills, and the requirements of the job.
Discrepancies between a client’s job skills and the skills required for the job for which the client is being considered must be identified prior to the signing of an OJT contract.
Funds provided to an employer are intended for training activities that are in addition to those that would otherwise be available to other employees.
A sponsoring entity must not enter into on-the-job training agreements with an employer who has received payments under previous agreements but who has failed to provide on-the-job training participants with continued long-term employment as regular employees with wages, benefits and working conditions at the same level and to the same extent as other employees working a similar length of time and doing the same type of work.
No financial assistance can be provided for OJT that involves political activities.
Each employer receiving financial assistance to provide OJT must maintain records which determine the amount of assistance received and the purposes for which the assistance is expended.
The OJT participant must receive a rating of satisfactory or better from the work site supervisor.
Verification of the Hours of Participation in OJT
Verification of the work participation hours in OJT is required. This verification may be provided by submitting:
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Form 516, The Record of Attendance and Performance Report, or
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Statement by the supervisor of the entity sponsoring the OJT.
The verification of participation must be provided to the case manager monthly. The case manager may choose to document this information in the case record weekly or bi-weekly.
Job Search and Job Readiness Assistance
Job Search (JS) and Job Readiness (JR) Assistance is the act of seeking and obtaining employment, preparation to seek and obtain employment, including life skills training, and substance abuse treatment, mental health treatment, or rehabilitation activities.
Job readiness assistance involves two activities:
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preparing an individual to obtain employment, such as preparing a resume or job application, interviewing skills, instruction in workplace expectations, life skills training, and
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substance abuse treatment, mental health treatment or rehabilitation activities.
For such treatment/rehabilitation to count as job readiness, the need for them must be determined by a qualified medical, substance abuse or mental health professional.
Job search includes looking for suitable job openings, contacting potential employers, applying for vacancies, and interviewing for jobs. Job search may be done on an individual basis, or it may be done as part of a group process. The DFCS case manager determines whether the individual participation, group job search, or a combination of both, is most appropriate for a participant.
The case manager’s determination is based on assessments of participants' skills, their need for support, the setting most likely to be productive for the participants, and the availability of group job search.
In general practice, participants engage in self-directed job search. The case managers contact the participant as well as with potential employers to validate active participation in job search activity.
Participants document their job search by indicating the time spent on each individual job contact. This may include resume preparation, interviews, and phone calls. Verification of job search compliance whether self-directed or through contracted services is maintained in the case record. Participants must keep all appointments and comply with all job referrals.
The participation is verified by submitting Form 495, Job Search Record and Form 516, Record of Attendance and Performance Report to the case manager. These forms are due to the case manager monthly.
Guidelines for Job Search and Job Readiness
Under section 45 CFR § 261.34 federal rules have placed a limit of six weeks participation in job search/job readiness activities in a preceding 12-month period.
The Final TANF Rule allows states to convert the six weeks of job search/ job readiness activities to hours. However, there is still a maximum limit of four consecutive weeks as a countable (core) activity.
For the purpose of the six-week limit on participation, a week is defined as 20 hours for a single custodial parent with a child under age 6, and 30 hours for all other work eligible individuals, which is 120 or 180 hours for the six-week limit per preceding 12-month period.
Each time an individual reaches 20 (or 30) hours, a week is used. Due to the maximum 4 consecutive week limit, a recipient can do no more than 80 hours for a work-eligible individual with a 20-hour average weekly work requirement or 120 hours for a work-eligible individual with a 30-hour average weekly work requirement consecutively.
Following the above guidelines, the recipient must participate in another core (primary) and/or non-core (secondary) work activity for 20 or 30 hours during the 5th week while JS/JR is suspended. Then the recipient may participate for any additional hours left up to the six-week limit in job search alone or in job search combined with job readiness training as countable activities.
In determining the 4-week consecutive participation, a week consists of seven consecutive days. Any hours of participation in JS/JR during the course of a 7-day period triggers a week of the 4-week limit.
The 6-week limit applies to each participating individual. Therefore, in a 2-parent household if both parents are considered work eligible and participate in a work activity, each parent can report up to 180 hours for the six-week limit of JS/JR in the preceding 12-month period for each work eligible individual.
The preceding 12-month period refers to the current month for which the data is reported and the 11 previous months. The preceding 12-month period may include one or more periods of participation in the 12 months period.
Under the final rule the six-week limit is converted to hours and operates like an accrual system. Each time an individual reaches 20 hours (or 30 hours), a week is used.
The number of hours of participation in JS/JR activities is determined by the age of the youngest child in the AU. When the age of the youngest child changes, the hours of participation must change also.
For example: The month the youngest child turns 6, the AU’s weekly hours of participation increases from 20 to 30 hours and the maximum limit increases from 120 to 180 hours for the six-week limit of JS/JR for the preceding 12-month period.
Similarly, if an AU without a child under six years of age expands to include such a child, its average hourly requirement per week would drop from 30 hours to 20 hours.
Applicant job search weeks do not apply towards this limit. Job search and job readiness activities in excess of six weeks do not count toward the participation rate, but clients may still receive support services for job search and/or job readiness training when these are combined with non-core or other non-countable activities. Form 516, The Record of Attendance and Performance Report, may be submitted to verify attendance in job readiness training classes, substance abuse/addictive disorders treatment programs, mental health treatment programs, life skills training or rehabilitative activities. |
Form 495, Job Search Record, may be used to verify hours of participation for job search activities. Documentation of Hours of participation in JS/JR activities in the case record is required monthly. The case manager may choose to verify hours of participation on a weekly or bi-weekly basis.
“Needy State”
A state may qualify to count participation in Job Search/Job Readiness Assistance activities for up to 12 weeks if the state meets the definition of a “needy State”. The 6- week limit on job search and job readiness assistance can be extended to 12 weeks in a fiscal year if a state has an unemployment rate at least 50 percent greater than the unemployment rate of the United States, or if the State meets the definition of “needy State” under the Contingency Fund provisions of the law. (See sections 407(c)(A)(i) and 407(c)(1)(A) of the Act.)
Under the statute, a State may count up to 12 weeks of participation in job search and job readiness assistance for an individual participating in those activities only in a month in which the State qualifies as “needy” or the unemployment rate is at least 50 percent greater than the national unemployment rate in that month.
There are two ways for a State to qualify as a “Needy State,” one based on its unemployment rate, the other based on increases in its SNAP caseload. (See section 403(b)(5) of the Act.) Here is a general description of the two triggers:
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Unemployment Trigger — the average unemployment rate for the most recent 3-month period is at least 6.5% and at least 110% of the State rate for the corresponding 3-month period in either of the two preceding calendar years.
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SNAP benefits Trigger (as determined by the Secretary of Agriculture) — the monthly average number of participants for the most recent 3-month period is at least 110% of the State’s monthly average caseload for FY 1994 or FY 1995, whichever is less, had the immigrant and SNAP provisions of the Personal Responsibility and Work Opportunity Reconciliation Act of 1996 (PRWORA) been in effect in those years.
A State can predict whether it will qualify due to high unemployment using its own trends and projections of SNAP participants and unemployment rates. A State making such a determination with respect to the SNAP benefits trigger should be sure to use the average of the most recent month and the two preceding months in comparison to the threshold for the most recent month.
Supervision
The DFCS TANF staff or a contracted vendor provides supervision on a daily basis. Daily supervision does not necessarily mean daily contact, but it does mean that a responsible party has daily responsibility for oversight of the individual’s participation. This may occur through direct face-to-face contact, telephone calls, e-mails, and/or faxes.
Through daily supervision the case managers and contracted vendors determine and ensure that the participants are appropriately engaged in Job Search and Job Readiness activities.
Community Service Programs
Community Service Programs are structured programs and embedded activities in which TANF recipients perform work for the direct benefit of the community under the auspices of public or nonprofit organizations.
Community service programs must be limited to projects that serve a useful community purpose in fields such as health, social service, environmental protection, education, urban and rural development, welfare, recreation, public facilities, public safety, and childcare.
Community service programs are designed to improve the employability of recipients not otherwise able to obtain employment.
Counties must consider, to the extent possible, the prior training, experience and skills of a recipient in making appropriate community service assignments.
Community service programs may not include activities that meet the definition of another allowable TANF work activity. Community service programs must include structured activities that both provide a community service and also improve the employability of the participants.
It should be noted that when a person is able to perform job responsibilities, s/he must participate in structured work activities that will lead to employment.
The goals of this activity are to provide a service to the community while also developing the client’s jobs skills. This is an activity that should be carefully assessed for its development of the client’s skills and the motivation to progress in his/her job readiness level.
Guidelines for Community Service Programs
Clients will not be allowed to perform community service activities that do not meet criteria listed above.
Examples of community service activities include but are not limited to the following:
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volunteering at a soup kitchen
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volunteering with a Meals-on-Wheels program
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volunteering at a shelter
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volunteering at a school
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volunteering at a church or other religious institution
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tutoring in a structured, supervised, environment.
The case manager must discuss the number of remaining months of potential TANF eligibility, and the impact community service programs may have on the client being able to achieve the goals established in the TFSP-Work Plan.
Requirements for Hours of Participation
A community service participant is subject to FLSA guidelines. A participant is therefore restricted to a maximum number of hours per week of participation in this activity.
The maximum number of hours permitted is determined by dividing the amount of the AU’s regular TANF cash assistance and the AU’s SNAP allotment by the minimum wage.
The hours based on the cash assistance grant and the hours based on the SNAP allotment must be calculated separately. The composition of the TANF AU may be different than the SNAP AU. Staff should count the entire SNAP benefit toward the TANF work requirement unless a SNAP E&T work program requirement such as workfare is also being based on the SNAP benefit.
In that case, the benefits would be prorated with the SNAP Benefits of the TANF household counted toward the TANF work requirement and the SNAP benefits of the other members counted toward the SNAP E&T work requirement. Benefits would not be double counted toward both requirements.
When doing calculations, fractions of an hour are retained to 1/100th of a whole number and dropped after the TANF and SNAP hours are added together. Fractions of an hour cannot be rounded up.
The number of allowable hours must be reviewed monthly and recalculated whenever necessary.
The maximum number of hours that can be permitted in a month is the sum of the TANF hours and the SNAP hours. Refer to the example below:
Example:
TANF = $280.00 per month ÷ $7.25 = 38.62 hours per month
SNAP = $526.00 per month ÷ $7.25 = 72.55 hours per month
Total number of hours = 38.62 + 72.55 = 111.17
The FLSA hours of work activity permitted for the month in the above example would be 111 hours. If the participant misses some hours of participation in one week, the hours can be made up in another week of the same month not to exceed the FLSA limit.
If the averaged actual weekly hours of participation allowed under the FLSA calculation falls below the 20 core hours of participation per week, over the course of a month, the work eligible individual will be considered deemed meeting the 20 hours per week of participation for that FLSA activity.
However, if this participant is a pregnant woman or single custodial parent with no child under six, the participant must be engaged in an additional 10 hours of non-core or non - FLSA work activities in order to meet the full 30-hour federal participation guidelines.
In an AU in which more than one recipient has a work requirement, the total FLSA hours cannot exceed the number of allowable hours derived by using the formula above.
Sponsor Requirement
A work site sponsor must agree to meet the requirements listed below in order for the case manager to approve the work site. The sponsor must:
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provide a description of the types of activities in which the participant will be involved,
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provide for the health and safety of the participant while on the work site,
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provide the participant with all supplies necessary for the performance of the assigned tasks,
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provide daily supervision of worksite activities and bi-weekly documentation of hours of participation for each participant,
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agree not to involve a participant in partisan political activity,
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not discriminate against any participant on the basis of race, color, religion, gender, age, national origin, or physical or mental disability, or
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agree not to allow the participant to work more hours than the total scheduled hours indicated on Form 516, the Record of Attendance and Performance Report.
Verification of Hours of Participation
Verification of Hours of Participation in Community Service Program must be provided monthly to the TANF agency. Participant’s sign in sheets, the provider’s activity log or Form 516, Record of Attendance and Performance Reports can be accepted to verify hours of participation.
Documentation of Community Service Program hours in the case record is required monthly.
The case manager may choose to verify hours of participation on a weekly or bi-weekly basis. |
Termination of Community Service Programs
When a community service program placement is terminated by the sponsor, the sponsor must complete the Placement Terminated information on Form 195, the Community Service Agreement and submit a copy of the form to the case manager within three business days of termination.
If DFCS must terminate a placement, the case manager must notify the sponsor in writing, providing notice as far in advance as possible.
Provision of Child Care to an Individual Participating in Community Service Programs
Childcare for Community Service is providing childcare to enable another TANF recipient to participate in a community service program. The work eligible individual providing childcare services receives no pay. This activity must be a structured program designed to improve the employability of individuals who participate in this activity.
The client must provide childcare for the number of hours specified on Form 195, the Community Service Agreement. The participant is responsible for ensuring that Form 516, Record of Attendance and Performance Report is submitted to the case manager each month.
A client can be placed in the activity of providing childcare for another TANF recipient in community service programs only when other work activities are not available to the participant.
Childcare is not available for the client who is acting as a childcare provider. Transportation assistance can be provided only if the participant must travel to provide the service.
Support Services
The client is responsible for making the arrangements necessary to become the childcare provider for another TANF recipient whose work activity is community service.
Guidelines for Provision of Child Care to an Individual Participating in Community Service Programs
For a client who is approved as a childcare provider to another TANF recipient participating in a community service program, being a childcare provider for a TANF recipient becomes the client’s community service activity. The TANF recipient for whom childcare is provided is the sponsor.
Placements are made via Form 195, the Community Service Agreement that specifies the placement begin date, the hours to be worked, and the name of the child being cared for and the duties of the participant. The case manager must approve the placement. When completing Form 195, the Community Service Agreement:
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note that the sponsor is the participant for whom childcare is being provided, and
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list the name of the child for who care is being provided.
Verification of Hours of Participation
Verification of hours of participation is required on a monthly basis. The parent of the child is responsible for completing Form 516, Record of Attendance and Performance Report and the participant providing the childcare is responsible for submitting this form on a monthly basis to the case manager.
The case manager may choose to verify hours of participation on a weekly or bi-weekly basis. |
Supervision
The parent of the child is responsible for monitoring the success of this activity daily. A DFCS staff person will complete an on-site visit once a week.
Placement Termination
When the sponsor terminates a community service placement, the sponsor will complete the Placement Terminated information on Form 195, the Community Service Agreement and submit a copy of the form to the case manager within three business days of termination.
If DFCS must terminate the placement, the case manager must notify the sponsor in writing, providing as much advance notice as possible.
Vocational Educational Training
Vocational educational training (not to exceed 12 months with respect to any individual) are educational programs that are directly related to the preparation of individuals in current or emerging occupations. This activity may also include a bachelor’s degree, advanced degree program, associate degree program, instructional certificate program, industry skill certifications, and other post-secondary education activities.
Education leading to a baccalaureate or advanced degree may also be assigned as a non-core activity under Job Skills Training, if it is directly related to a specific job or occupation. This activity may include both customized and general training to prepare an individual for employment, including literacy and language instruction. |
Certain vocational rehabilitation programs incorporate educational components that would fit within the definition of vocational educational training.
For example, part of an individual’s vocational rehabilitation program could be to complete a certificate in computer programming from a community college. Such a program would be part of an organized educational program and would be directly related to preparation for employment.
Guidelines for Vocational Educational Training
Vocational educational training in excess of twelve months does not count toward the participation rate, but a participant may be supported in vocational education in combination with a countable work activity.
The twelve-month limit is cumulative, not consecutive.
The Participants in vocational educational training activities are required to maintain an average of 2.0 GPA.
Verification of the GPA may be provided through grade reports, quarter/semester registration information, monthly attendance reports, or a certificate or diploma.
The required 2.0 GPA is based on a 4-point grading system. If the participant is attending a school on a different grading system, require the grade that is equivalent to a “C”. |
Verification of Participation in Vocational Education
Form 516, Record of Attendance and Performance Report or Form 517, Record of School Attendance and Performance Report may be used to verify attendance and performance and is due to the case manager monthly.
The case managers may choose to call the school or provider to verify attendance and performance on a weekly or bi-weekly basis.
The case managers are required to document the name, title and telephone number of the person who provides hours of participation and performance if other attempts to get other documents have not worked.
Distance Learning
Distance learning is not a new or a separate stand-alone work activity. It can be incorporated in other core or non-core activities. The Deficit Reduction Act of 2005 has allowed the use of distance learning or online education for work eligible TANF recipients who are experiencing some limitations to meet TANF work requirements. The purpose is to provide all possible support to enhance their strengths that will lead to their self-sufficiency and the family’s success.
Distance/on-line learning can be effectively used in vocational training, GED, or other educational activities, including but not limited to learning and developing the following skills:
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Resume writing
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Strategies for researching employers and careers
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Networking skills coaching
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Interview preparation
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Job Search Skills Workshops online
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Career Management Coaching
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Career Counseling skills
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Skills and Values Assessments
Hours of participation in distance learning programs can be monitored manually or electronically by the class instructor.
Form 516, Record of Attendance and Performance Report or Form 517, Record of School Attendance and Performance Report may be used to verify attendance and performance and is due to the case manager monthly.
If needed the DFCS case manager can contact the participating program provider to verify the attendance and performance of a participant. The case manager must document the name, title and telephone number of the persons who provides this verification.
Homework Time
A client can receive credit for supervised homework time in some educational activities if the homework time can be monitored and verified (manually or electronically) by the class instructor. Total maximum homework time counted for participation cannot exceed the hours required or advised by an educational program.
Study time is the time (expressed in hours) that a student is actively engaged to complete learning activities for a program of study. This can include monitored activities such as: study sessions, research, homework, and other activities completed outside of class for the course. |
Form 516, Record of Attendance and Performance Report or Form 517, Record of School Attendance and Performance Report may be used to verify attendance and performance of the participant monthly. Attendance must be submitted to the case manager monthly.
If needed the DFCS case manager can contact the participating program provider to verify the attendance and performance of a participant. The case manager must document the name, title and telephone number of the persons who provides this verification.
The case manager may choose to verify hours of participation on a weekly or bi-weekly basis. |
Activity Descriptions, Requirements, and Guidelines for Countable Non-Core (Secondary) Work Activities
Job Skills Training Directly Related to Employment
Job skills training directly related to employment is training or education for job skills required by an employer to provide an individual with the ability to obtain employment or to advance or adapt to the changing demands of the workplace.
This activity may include both customized and general training to prepare an individual for employment, including literacy and language instruction.
This activity can also include bachelor’s degree programs, advanced degree programs, associate degree programs, instructional certificate programs, industry skill certifications, and other post-secondary education activities.
Under the Deficit Reduction Act of 2005, this activity is classified as a non-core (secondary activity). Some vocational educational classes can be considered job skills training if they are directly related to a specific job or occupation. Job skills training is not subject to a durational limit but is only countable when combined with 20 hours a week of a core activity such as subsidized or unsubsidized employment, including work study.
Guidelines for Job Skills Training Directly Related to Employment
The goal of such training is to place the client in a job for which s/he has been trained. The participant in job skills training must meet the standards established by the training provider.
Verification of Attendance in Job Skills Training Directly Related to Employment
The contractor or the job skills training provider provides verification of actual hours of participation on Form 516, Record of Attendance and Job Performance Report, which is submitted to the case manager monthly.
The case managers may choose to call the school or provider to verify attendance and performance on a weekly or bi-weekly basis. |
Termination of Placement
When the sponsor terminates a Job Skills Training placement, the sponsor will inform the case manager within three business days of termination. If DFCS must terminate the placement, the case manager must notify the sponsor in writing, providing as much advance notice as possible.
Education Directly Related to Employment
Education directly related to employment in the case of a recipient who has not received a high school diploma, or a certificate of high school equivalency is education related to a specific occupation, job or job offer. This includes courses designed to provide the knowledge and skills for specific occupations or work settings but may also include adult basic education and English as a Second Language (ESL).
The goal of such training is not a diploma or certificate of equivalency, but employment.
Guidelines for Education Directly Related to Employment
Under the Deficit Reduction Act of 2005, this activity is classified as a non-core (secondary activity).
A work eligible individual who is 20 years of age or older without a high school diploma or its equivalent and who participates in education directly related to employment activity can receive credit for classroom hours if s/he is also participating in countable core (primary) activities for an average of at least 20 hours per week during the month.
Case managers should use every opportunity to schedule 30 or more hours of work-related activities. In so doing, the case manager would assist the client in his/her progression towards sustained employment.
A single custodial parent head of household who is less than 20 years of age or a pregnant teen head of household without a high school diploma or its equivalent and who participates in education directly related to employment activity, will be considered as met if s/he participates for an average of at least 20 hours per week during the month.
Although participation in other work activities is not required for a single custodial parent head of household under 20 years of age or a pregnant teen head of household, and there is no penalty if the recipient does not participate in other work activities, the case manager may encourage the client to participate in other activities if doing so has no adverse effect on the recipient’s schoolwork.
During breaks in the school year, there are no other work requirements for the single custodial parent head of household under 20 years of age or the pregnant teen head of household if the client intends to return to school when the new school year is scheduled to begin.
The number of hours credited to the client while school is in session continues to be credited during breaks, holidays and vacations.
The aforementioned client may choose to work during breaks in the school year or even during the school year but cannot be required to do so.
Refer to Distance Learning and Homework Time, for consideration of work participation hours not spent in class.
Verification of Participation in Education Related to Employment
Form 517, the Record of School Attendance and Performance Report, or Form 516, the Record of Attendance and Performance Form may be used to verify attendance and performance and submitted to the case manager monthly.
The case managers may choose to call the school or provider to verify attendance and performance on a weekly or bi-weekly basis. |
Satisfactory Attendance at Secondary School
Satisfactory attendance at secondary school or in a course of study leading to a certificate of general equivalence, in the case of a recipient who has not completed secondary school or received such a certificate means regular attendance, in accordance with the requirements of the secondary school or course of study, at a secondary school or in a course of study leading to a certificate of general equivalence, in the case of a work eligible individual who has not completed secondary school or received such a certificate.
This activity is designed to enable the student to earn a high school diploma. It can also enable the student to participate in a course of study leading to a certificate of general equivalence.
Guidelines for Satisfactory Attendance at Secondary Education
Under the Deficit Reduction Act of 2005, this activity is classified as a non-core (secondary activity).
A pregnant woman or single custodial parent who is 20 years of age or older and has no high school diploma or its equivalent, and who attends secondary school or equivalency classes can receive credit for classroom hours if s/he is also participating in countable core (primary) activities for an average of at least 20 hours per week during the month.
Case managers should use every opportunity to schedule 30 or more hours of work-related activities. In so doing, the case manager would assist the client in his/her progression towards sustained employment.
A single custodial parent head of household who is less than 20 years old or a pregnant teen head of household, and has no high school diploma or its equivalent, and who attends secondary education or GED classes is considered as met if he or she maintains satisfactory attendance at a secondary school or the equivalent during the month.
Although participation in other work activities is not required, and there is no penalty if the recipient does not participate in other work activities, the case manager may encourage the recipient to participate in other activities if doing so has no adverse effect on the recipient’s schoolwork.
During breaks in the school year, there are no other work requirements for the single custodial parent head of household under 20 years of age or a pregnant teen head of household if the client intends to return to school or GED class when the new school year or next GED session is scheduled to begin.
The number of hours credited to the client while school is in session continues to be credited during breaks, holidays, and vacations.
The client must meet the attendance requirements established by the school. Meeting these requirements is a part of the client’s TFSP–Work Plan.
If attending high school, the participant must obtain passing grades in order to remain in this activity. The school determines the standard for a passing grade. If attending GED classes, the participant must progress at least one grade per quarter in order to remain in this activity. This requirement may differ from requirements established by the school.
Refer to Distance Learning and Homework Time for consideration of work participation hours not spent in class.
All support services can be provided as needed, though transportation can be provided only if it has been verified that needed transportation is not available through the school.
Verification of Satisfactory Attendance at Secondary School
Form 517, the Record of School Attendance and Performance Report, or Form 516, the Record of Attendance and Performance Form may be used to verify attendance and performance and submitted to the case manager monthly.
The case managers may choose to call the school or provider to verify attendance and performance on a weekly or bi-weekly basis. |
Activity Descriptions, Requirements and Guidelines for Other Non-Countable Activities
English as a Second Language
English as a second language (ESL) is education designed to provide a client with skills in speaking, reading, or writing English that are consistent with the requirements of the client’s employment goal. Due to changes in the Federal guidelines, ESL will now be included under the non-core (secondary) activity Education Directly Related to Employment.
All hours of participation must be entered under Education Directly Related to Employment activity for the participation hours to be considered as countable hours with another core (primary) activity with at least 20 average hours per week during a month.
Basic Education and English as a Second Language (ESL) can also be considered for a vocational educational assistance activity if it’s necessary and a regular part of the training program.
Guidelines for ESL
Assignment to this activity must only be made for a client whose ability to participate in countable work activities may be hampered by the client’s lack of English proficiency. ESL is considered an “Other” non-countable activity.
Participation hours entered under English as a Second Language (ESL) will not count towards the Federal work participation. |
Verifications of Hours of Participation
Form 516, Record of Attendance and Performance Form or Form 517, Record of School Attendance and Performance Record may be used to verify attendance and performance and submitted to the case manager monthly.
The case managers may choose to call the school or provider to verify attendance and performance on a weekly or bi-weekly basis. |
Addictive Disorders (AD) Counseling and/or Treatment
Addictive Disorders (AD) counseling or treatment is designed to help a client overcome a dependence on or addiction to drugs and/or alcohol.
Due to changes in the Federal guidelines, AD will now be included under the core (primary) activity – Job Search and Job Readiness Assistance for up to six weeks (or 12 weeks). All hours of participation must be entered under Job Search and Job Readiness Assistance activity in order for them to be considered as countable hours.
Participation hours entered under Addictive Disorders Counseling/Treatment activity are not countable and will not be applied to the Federal work participation. |
Guidelines for Addictive Disorders Counseling and/or Treatment
Assignment to this activity must only be made for a client whose ability to participate in countable work activities may be hampered by the client’s dependence on or addiction to drugs or alcohol.
A client who is assigned to Addictive Disorders counseling or treatment instead of to a work activity must participate for the number of hours specified by the provider and adhere to all standards established by the provider for persons receiving counseling or treatment.
Support services, including transportation, childcare and payment for incidental expenses can be provided to the participant as long as participation in counseling or treatment continues.
Termination of Placement
The provider must report termination of the participant from the program within three business days of termination.
The case manager must have the client sign a release of information prior to making a referral to the training provider. The original is sent to the provider, with copies being retained by the client and by the case manager. The case manager is responsible for ensuring that the client understands what signing a release means, and the release’s implications.
Verifications of Hours of Participation
Verification of hours of participation is required. The provider determines satisfactory progress on the part of the participant. Satisfactory or unsatisfactory progress is to be reported via Form 516, Record of Attendance and Performance Report, which is due to the case manager on a monthly basis following the month of participation.
The case managers may choose to call the school or provider to verify attendance and performance on a weekly or bi-weekly basis. |
Life Skills Training
Life skills training is intended to help a client develop the skills necessary to manage activities that typify what is considered as normal daily life, enabling the client to function in society. In the judgment of the case manager, the client may not possess the skills to sufficiently manage his/her household, finances, or time so as to benefit from participation in work activities.
Due to changes in the Federal guidelines, Life Skills Training will now be included under the core (primary) activity Job Search and Job Readiness Assistance for up to six weeks (or 12 weeks). All hours of participation must be entered under Job Search and Job Readiness Assistance in order for them to be considered as countable hours.
Participation hours entered under Life Skills Training activity are not countable and will not be applied to the Federal work participation. |
Guidelines for Life Skills Training
A client who is assigned to life skills training instead of to a work activity must participate for the number of hours specified by the training provider and adhere to all standards established by the provider for a trainee.
Support services, including transportation, childcare and payment for incidental expenses can be provided to the participant if training continues.
Verification of Hours of Participation
Verification of hours of participation is required. The provider determines satisfactory progress on the part of the participant. Satisfactory or unsatisfactory progress is to be reported via Form 516, Record of Attendance and Performance Report which is due to the case manager on a monthly basis following the month of participation.
The case managers may choose to call the school or provider to verify attendance and performance on a weekly or bi-weekly basis. |
Termination of Placement
When the provider terminates a Life Skills Training placement, the sponsor will inform the case manager within three business days of termination.
If DFCS must terminate the placement, the case manager must notify the provider in writing, providing as much advance notice as possible.
Parenting Skills Training
Parenting skills training is intended to help a client develop the skills necessary to effectively care for his/her child. Parenting Skills training is an ‘Other' non-countable activity. In the judgment of the case manager, the client may not possess the skills necessary to adequately manage and care for his/her child. These skills must be regarded by the case manager as being so deficient that the client’s participation in work activities is potentially detrimental to at least one child in the AU.
Guidelines for Parenting Skills Training
A client who is assigned to parenting skills training instead of to a work activity must participate for the number of hours specified by the training provider and adhere to all standards established by the provider.
Verifications of Hours of Participation
Verification of hours of participation is required. The provider determines satisfactory progress on the part of the participant. Satisfactory or unsatisfactory progress is to be reported on Form 516 - the Record of Attendance and Performance Report, which is due to the case manager monthly following the month that follows the month of participation.
The case managers may choose to call the school or provider to verify attendance and performance on a weekly or bi-weekly basis. |
Welfare to Work
Welfare-to-Work (WtW) is not a work activity. It is a funding stream through which services are provided by various agencies. The services provided through WtW are intended to assist a client in participating in federally recognized work activities for the requisite number of hours.
Use the following chart to determine which work activities count toward the federal work participation rate:
Chart 1820.1 - Work Activities
Activity | Designation | Countable ? |
---|---|---|
Unsubsidized employment |
Core |
Yes |
Subsidized employment (private) |
Core |
Yes |
Subsidized employment (public) |
Core |
Yes |
Work experience |
Core |
Yes |
On-the-job training (paid training whether on-site or off-site) |
Core |
Yes |
Job search (JS) and Job Readiness (JR) Assistance (up to 4 weeks, with an additional 2 weeks not more than once in the preceding 12 months.) |
Core |
Yes |
Community service programs |
Core |
Yes |
Vocational Educational Training (12-month lifetime limit) |
Core |
Yes |
Providing child-care services to an individual who is participating in a community service program |
Core |
Yes |
Job skills training directly related to employment |
Non-Core (countable if client is already participating in core (primary) activities for at least 20 hours per week and shows good or satisfactory progress. |
Yes |
Education related to employment |
Non-Core (countable if client is already participating in core (primary) activities for at least 20 hours per week and shows good or satisfactory progress. |
Yes |
Secondary school attendance or GED classes |
Non-Core (countable if client is already participating in core (primary) activities for at least 20 hours per week and shows good or satisfactory progress. |
Yes |
Assessments |
Other |
No |
Job search and job readiness assistance (after 6-week limit or 12-week limit is reached) |
Other |
No |
Addictive Disorders or Mental Health Counseling and/or Treatment, (See section 1820 for countable considerations) |
Other |
No |
Life skills training (See section 1820 for countable considerations) |
Other |
No |
Parenting skills training (See section 1820 for countable considerations) |
Other |
No |
Vocational educational training (after 12-month limit is reached) |
Other |
No |
Job readiness training independent from countable job search |
Other |
No |
English as a Second Language (ESL) classes |
Other |
No |
College (See section 1820 for countable considerations) |
Other |
No |