Title: Welfare Transition
1Welfare Transition
- Work Activity Definitions
- August 2007
2PRWORA
- Personal Responsibility and Work Opportunity
Reconciliation Act (PRWORA) of 1996 - Changed welfare from an entitlement into a work
program - 12 work activity categories were named
- The work activity categories provided by the
federal government under this Act did not have
definitions, states determined what services and
activities would be allowed under each category
3Deficit Reduction Act
- In 2006, the Deficit Reduction Act reauthorized
the original TANF block grant - Directed Secretary of Health and Human Services
(HHS) to publish regulations - States were defining the work activities
differently - Some states allowed very broad definitions, which
allowed a lot of different services as countable
work activities - For example, caring for a sick family member or
going to substance abuse treatment was considered
community service in some states - The states were not being compared equally based
on the work activity definition differences
4Deficit Reduction Act
- Regulations must ensure consistent measurement of
work participation rates by - Defining work activities and what types of
services were allowable to receive credit for
hours under work activities - Defining who is required to participate in work
activities and will be included in the work
participation rates, work eligible - Establishing equal and stringent supervision and
documentation requirements for all states
5Deficit Reduction Act
- Interim Final Regulations
- Required each state to develop work activities
consistent with definitions based on the federal
definitions of the work categories - Required each state to submit a work verification
plan - Required the states plan to be approved and
implemented by September 30, 2007
6Deficit Reduction Act
- The States Work Verification Plan must
- Describe all of the services included under each
work activity - To receive credit for hours participating in the
work activity, the services must meet federal
definitions - Describe how countable hours are identified,
credited and proven - Describe the supervisory process for each unpaid
activity - Describe documentation requirements for each
activity - Describe monitoring and internal controls
7Participation Rates
- States are required to engage all work eligible
TANF recipients in the employment and training
program - States are to engage participants in work
activities that help the participants reach their
goals and ultimately self-sufficiency - Success is gauged by the percentage of
participants that actually attend certain
activities - Engaged in specific countable work activities
- Engaged in a specific number of hours in core
activities - May be engaged in additional hours in core plus
activities once the core requirement is met for
the family
8Participation Rates
- The number of hours required in a core activity
depend - On the family type
- The participation rate being calculated
9Credit for Participation Rates
- All Family Rate
- 20 hours in core activity(ies)
- 30 hours total
- Inclusions
- All two-parent families
- All single-parent families
- Exclusions
- Subject to sanction
- Single parent family with a child under 12 months
(time limited) - Exceptions
- Child under the age of six requires only 20 hours
total (all in core activities)
- Two-Parent Family Rate
- If subsidized childcare is received and neither
parent is disabled - 50 hours in core activity(ies)
- 55 hours total
- Subsidized childcare is not received and neither
parent is disabled - 30 hours in core activity(ies)
- 35 hours total
- Exclusions
- Families with a parent that has a documented
limitation/disability lasting greater than 30
days and entered in OSST as a medical deferral
lasting greater than 30 days - Subject to sanction
10Participation Rates
- The State must prove that half of all families
with a work eligible adult receiving assistance
are participating in work activities that are - Designed to engage the parent in reaching goals
- Designed to engage the parent in gaining skills
- Designed to move the family from welfare to work
11Participation Rates
- The State must demonstrate that 90 percent of
two-parent families with work eligible adults
receiving assistance are participating in work
activities that are - Designed to engage the parents in reaching goals
- Designed to engage the parents in gaining skills
- Designed to move the family from welfare to work
12What is Assignment Versus Credit?
- The PRWORA (from which the Federal Regulations
are derived) - Requires a family receiving cash assistance to be
engaged in a work program - Further limited to work eligible individuals in
2006 - Requires work eligible individuals in a family
receiving cash assistance to engage in work
activities defined under Federal Regulations - Gives states credit for engaging a work eligible
participant in a minimum number of hours in
certain work activities defined by the Federal
Regulations
13What is Assignment Versus Credit?
- We assign participants to activities based on
- Goals
- Needs
- Work activity definition/requirements
- A participant cannot be required to do more than
40 hours per week based on Florida Statutes - We do not assign hours based on what the
participant may get credit for under deeming
(Community Service/Work Experience)
14What is Assignment Versus Credit?
- We assign participants to hours in work
activities to ensure participants are moving in
the right direction - Most RWBs require that each work eligible parent
complete between 35 and 40 hours per week
15What is Assignment Versus Credit?
- But what do we get credit for?
- Engaging families in the minimum number of hours
in work activities - Based on family type
- Recording that the families completed the minimum
number of hours in countable work activities - Retaining documentation that the families
completed the minimum number of hours in
countable work activities
16Assignment Versus Credit?
- We record what a participant actually completed
based on - The number of supervised hours a participant
actually completes - The number of supervised hours recorded on signed
documentation - Deeming requirements (Work Experience and
Community Service only) - Sometimes a participant completes more than (s)he
is assigned - Sometimes a participant is credited with more
hours than they actually completed (Deeming)
17(No Transcript)
18Assignment Versus Credit?
- Critical elements for accountability
- Participants need to
- Recognize the assigned activities
- Recognize assigned hours
- Recognize and understand expectations to complete
steps to achieve goals - Hourly requirements
- Must be in writing
- Must be agreed on by both parties
19Question
- The participant has not come to an appointment.
This is his first meeting/orientation. The
requirement is not in writing. Can he still be
held accountable for not attending?
20Answer
- Yes
- There will be some circumstances when a
requirement may not be in writing and signed in
the IRP - Orientation letter
- Appointment letter
- Activity agreed on over the phone after a
counseling contact
21Answer
- However, if we meet with the participant,
requirements should be reviewed, put in writing,
agreed on and signed by both parties - Written requirements demonstrate an agreement
with the participant - Written requirements provide a reminder for the
participant
22Assignment Versus Credit?
- Case managers should discuss with participants
how to document their hours using time sheets,
pay stubs, job search forms, etc. - Case managers should review with participants
- How to fill out the document
- How to secure signatures from the correct party
- What information is required for the document to
be accepted - When the documentation is due
23Assignment Versus Credit?
- Case managers should encourage participants to
complete required hours - Case mangers should encourage participants not to
exceed hours required for the program - Especially for worksite activities
- The RWB may opt to create a disclosure document
regarding completing hours above the number
assigned by the RWB
24Work Activities
FAIRPAY!
Need Work!
25Work Activity Categories
- Twelve federal work activity categories
- Unsubsidized Employment
- Subsidized Private Sector Employment
- Subsidized Public Sector Employment
- Work Experience
- Job Search and Job Readiness Assistance
- Community Service Programs
- Vocational Educational Training
- On-the-Job Training
- Providing Childcare
- Education Directly Related to Employment
- Job Skills Training Directly Related to
Employment - Satisfactory Attendance in a Secondary Education
Program
26Work Activity Categories
- Federal core activities
- Unsubsidized Employment
- Subsidized Private Sector Employment
- Subsidized Public Sector Employment
- Work Experience
- Job Search and Job Readiness Assistance
- Community Service Programs
- Vocational Educational Training
- On-the-Job Training
- Providing Childcare
27Work Activity Categories
- Federal core plus activities
- Job Skills Training Directly Related to
Employment - Education Directly Related to Employment
- Satisfactory Attendance at a Secondary School or
in a Course of Study Leading to a GED
28What Counts for Teens?
- Teens without a diploma or GED and are under age
20 will be included in the numerator of the
participation rate if they are a - Single parent family
- And satisfactorily attend a GED or diploma
program each week - And participate in 20 hours a week in Education
Directly Related to Employment - Two-parent family
- And both satisfactorily attend a GED or diploma
program each week - And both participate in 20 hours a week in
Education Directly Related to Employment
29Question
- Can the teen parents without a GED or diploma
participate in different activities (for a
two-parent family)? - One parent may be in a GED program and the other
in 20 hours of Education Directly Related to
Employment - The activity is based on the participants age,
receipt of a high school diploma or an
equivalency diploma, and the participants goals
30Work Activity Definitions
31Unsubsidized Employment
- Is a full or part-time job in the public or
private sector - Wages are paid by the employer and are not
subsidized by any public program - Included in this definition are
- Employers who receive tax subsidies for hiring
lower income individuals - Individuals who are self-employed
- Includes
- Employers claiming a tax credit
- Labor in exchange for services (in-kind work)
- Self-employment
32Unsubsidized Employment
- Hours spent in unsubsidized employment are
assumed to be supervised based on wages - Employment verification must be received prior to
recording the job on the Skill Development screen
- Documentation verifying employment must include
wages at hire, hours at hire, start date,
employers name, etc.
33Unsubsidized Employment-Self Employment
- The individual is both the employee and employer
- May include in-kind work (work for services
rendered, rent, etc.) - Countable hours are determined by
- Dividing the individuals documented income
(gross income less business expenses) by the
higher of the Florida or federal minimum wage - Case managers cannot take a participants
statement of hours and pay when recording
self-employment
34Subsidized Employment
- The employer receives a subsidy from TANF or
other public funds to offset wages and/or costs
of employing a recipient - Private subsidized employment means the subsidy
comes from a private entity or program - Public subsidized employment means the subsidy
comes from a public entity or program - Types of subsidized employment include
- Work supplementation
- Incentive payments
- Third party contractor
- Supported work for individuals with disabilities
- Work study (public only)
35Subsidized Employment
- Must be supervised daily
- Supervision is assumed based on documentation of
pay for all subsidized employment - If employment is subsidized by TANF funds, the
participant must be supervised daily and hours
must be documented by the designated supervising
party - Justifies the use of TANF funds
- Documents the hours completed to support the use
of funds - Daily supervision must be documented and
submitted no later than every two weeks
36On-the-Job Training
- Is training provided to a paid employee while
(s)he is working full-time - The employer or an educational institution
provides training to the participant to gain
skills for job position - The employer (or education institution on behalf
the employer) receives a subsidy - The employer is expected to retain the
participant as a regular employee (without a
subsidy) after training is completed
37On-the-Job Training
- The difference between Subsidized Public or
Private Employment is the focus of the activity - OJT is paid training while working full-time
38On-the-Job Training
- Contracts must be developed for TANF funded OJT
programs - Expectation of retaining employee upon completion
- Job title of the participant
- Goals of training and employment
- Skills required to learn for the job position
- Reasons for immediate termination
- OJT begin and end dates
- Parties responsible for supervising progress and
documenting participation
39Work Experience
- Is defined as structured work in exchange for
public benefits (specifically cash assistance and
food stamps) - It is engagement with an employer for individuals
who - Are not able to gain employment and lack work
experience - Must provide an opportunity to gain
- General employability skills
- Work habits necessary for obtaining employment
- Training
- Specific job knowledge
40Work Experience
- Prior to placement
- Work experience providers must be evaluated to
match the participant - With a position that is related to his/her goals
- With an employer who has related needs
41Work Experience
- Work Experience must be
- Intensely supervised
- Designated by a contract or agreement
- Work Experience may be performed with
- A public or private not-for-profit entity
- A public or private for-profit entity
42Work Experience
- Displacement
- Employers must notify their employees of their
rights - To report and dispute displacement from
employment as a result of Work Experience or
Community Service - How to report acts of displacement
- Cannot fire a paid employee to fill the position
with a Work Experience participant - Cannot fail to fill an open position to use a
Work Experience participant
43Work Experience
- The contract regarding the participants worksite
must include - Party(ies) responsible for supervising the
participant on a daily basis - Party(ies) responsible for signing time
sheets/documentation of completed hours - The contract for the participants worksite
participation should include - Job title
- Clear job description
- The connection between the worksite and the
participants goals
44Work Experience
- Work experience contracts must also include
- Performance benchmarks
- What will the participant be required to achieve
prior to completion? - What skills the participant must gain during the
Work Experience? - What are the expectations of the employer?
- Goals
- Outcomes
- Time limits
45Work Experience
- Hours assigned for the month
- Cannot be greater than the calculation
- Cash assistance amount Food Stamp Allotment /
the higher of the two minimum wage (Florida or
federal) - Hours the participant is required to complete
each week must be included in the IRP - Currently, the monthly total may be further
divided by 4.3 to assign weekly hours and develop
a schedule - Those hours must be agreed on by the participant
and career specialist - Should be written in the steps-to-self-sufficiency
46Work Experience
- Hours assigned/calculated should be included in
the case notes - Hours assigned must be entered on the activity
screen (weekly) - Because the benefits may change monthly, the
hours assigned to a worksite must be reviewed and
updated monthly - Update the steps to self-sufficiency
- Update case notes
- Update the Skill Development screen
47Community Service Programs
- Are structured programs at not-for-profit
organizations - Projects must serve a useful community purpose in
one of the following fields - Health, social services, environmental
protection, education, urban and rural
redevelopment, welfare, recreation, public
facilities, public safety and childcare - Must be designed to improve employability/help
participant reach employment goals
48Community Service
- Displacement
- Employers must notify their employees of their
rights - To report and dispute displacement from
employment - How to report acts of displacement
- Cannot fire a paid employee to fill the position
with a Work Experience participant - Cannot fail to fill an open position to use a
Work Experience participant
49Community Service
- The contract regarding the participants worksite
must include - Party(ies) responsible for supervising the
participant on a daily basis - Party(ies) responsible for signing time
sheets/documentation of completed hours - The contract for the participants worksite
participation should include - Job title
- Clear job description
- How the worksite serves a useful community
purpose
50Community Service Programs
- Hours assigned
- Cannot be greater for the month than the
calculation allows - Cash assistance Food Stamp allotment / the
highest of the federal or State minimum wage
51Community Service
- Hours the participant is required to complete
each week must be included in the IRP - Currently, the monthly total may be further
divided by 4.3 to assign weekly hours and develop
a schedule - Those hours must be agreed on by the participant
and career specialist - Should be written in the steps-to-self
sufficiency - Should be entered in the case notes
52The Gift of Deeming
- Applies only to the worksite activities
- Work Experience
- Community Service
- Has three principle components
- Core hours based on the family type
- Calculated monthly hours at the worksite for the
family - Actual hours completed at the worksite(s) by the
family
53Deeming
- A family may be given credit for the core hours
- Currently, the JPR screen records weekly hours.
The family may be given credit for all core hours
if the family completes all required hours for
the week - Some regions have developed local operating
procedures to give the family core credit for
completing required hours during the month - The procedure must be written
- All staff should follow the local procedure
54Deeming-Assigning versus Credit
- Credit
- Family completes all required hours for the week
or month - The required hours are based on the calculation
- The career specialist enters the core hours on
the JPR screen for the weeks/month based on the
family type - The career specialist enters a case note
including - Calculated hours for the month and the week
- The hours completed
- The number of hours deemed
- Assigning
- Family is assigned hours based on the calculation
- Two-parent family may share hours or one parent
may complete all hours provided the parent is not
required to complete more than 40 hours per week - No family must be required to complete more than
the hours calculated - No individual must be required to complete more
than 40 hours per week
55Deeming-Assigning versus Credit
56Monthly Deeming
- Some RWBs may implement monthly deeming
- This allows the RWB to maximize deeming based on
the number of weeks in the month the participant
will engage in a worksite rather than dividing by
an average number of weeks in the month of 4.3
57Monthly Deeming
- The calculation for monthly deeming is
- Cash assistance combined with the monthly Food
Stamp allotment divided by the higher of the two
minimum wages (Florida or federal) - This total number of monthly hours is then
divided by the number of weeks left in the month
or the number of weeks the family will
participate in work activities - This allows for make-up hours to be completed in
a week if hours are missed in another week
provided a participant is not required to
complete more than 40 hour per week
58Monthly Deeming-Example
- I met with the family on May 21, 2007 to begin
the work activity process, Participant 1 has just
finished the assessment process - P1 is in need of work experience and has
clarified her employment goals, so she is a good
candidate for our work experience program - P1 is a single parent and will complete all the
work activities for her family
59Deeming-Assigning versus Credit
- Carla received 241 in cash and 181 in food stamps
for June 2007 - Based on the calculation, Carla is required to
complete 63 hours at a worksite for this month - Because one week of June 2007 is over and there
are only four weeks in June 2007, there are only
three weeks for Carla to complete the 63 hours
for the month - The 63 hours are divided by three weeks
- Carla is assigned to 21 hours a week for the next
three weeks at a worksite and 15 hours in
computer classes designed to help her gain skills
to become a secretary (based on her goal) - If she does all of her hours and provides the
appropriate documentation, what do we enter on
her JPR screen?
60Deeming-Assigning versus Credit
- We would enter her exact education hours (15
hours) - If she completes her required worksite hours for
the month, we can enter either - the core hours of 20 per week or
- the monthly total the last week of the month
- Monday must be in the same month (June 2007)
- Four Mondays in June at 20 core hours each week
is 80 hours for the month
61When is Deeming not Appropriate?
- The family is assigned to fewer hours than the
calculation requires - The family does not complete all required hours
even though the hours were assigned based on the
calculation - In all these situations, the JPR screen should
reflect the actual hours completed
62Quirks of Implementation
- The JPR screen records weekly hours not monthly,
so how do we record this? - RWBs must develop Local Operating Procedures
- Some regions have stated they would deem monthly
(LOP required) - Otherwise, regions must deem weekly until OSST is
updated to accommodate monthly deeming
63Question
- But, her education hours will be 15 per week
(completed) combined with 80 hours at a worksite
(total deemed) - This is over 40 hours a week, are we breaking the
law?
64Answer
- No, the RWB did not assign over 40 hours per week
- The participant received credit for over 40 hours
per week based on the deeming provisions
65Job Search and Job Readiness Assistance
- The act of seeking or obtaining employment, as
well as learning how to find a job - Orientation to the world of work
- Learning how to complete an application
- Applying for jobs
- Resume development
- Interviewing skills
- Learning about appropriate dress
- Career planning
- Soft skills (including job retention skills)
66Job Search and Job Readiness Assistance
- May include
- Workshops
- Classroom activities
- Working with job developers
- Job matching and receiving job referrals
- Access to resource centers
- Submitting applications and resumes
- Completing follow-up calls
- Attending interviews
67Job Search and Job Readiness Assistance
- May include
- Substance abuse treatment
- Mental health treatment
- Rehabilitative activities
- Only for individuals
- Who are certified to need care by a professional
and - Who are otherwise employable
- Meaning the participant has no other major
barrier to employment except one of the above-
mentioned items
68Question?
- Does the medical professional have to sign off on
every hour in treatment? - No
- Every hour must be verified by a responsible
party - Depends on the activity
- AA meeting leader
- Therapy counselor
- Other counselor
69Job Search and Job Readiness Assistance
- Hours in treatment are recorded as job search
hours - Remember-weeks in job search are time limited
- Weeks of job search are limited to four
consecutive weeks in a FFY or six cumulative
weeks in a FFY
70Job Search and Job Readiness Assistance
- So, use time in Job Search and Job Readiness
Assistance wisely - Job Search and Job Readiness Assistance
- Is not a back-up activity
- Is not an activity for those that are not ready
to seek and obtain employment
71Job Search and Job ReadinessDiscussion
- Supervision
- HHS has stressed that Job Search and Job
Readiness Assistance must by supervised daily by
a responsible party - Career specialist
- Contracted provider
- Teacher or program administrator
- Job development staff
- Etc.
72Job Search and Job ReadinessDiscussion
- Credit for hours
- HHS has stated that the State may not enter hours
for credit on the JPR screen unless the hours in
Job Search and Job Readiness Assistance are
supervised daily and are documented hour for hour
73Vocational Educational Training
- Prepares the participant for employment in
current or emerging occupations through organized
training - Gives the participant knowledge and skills to
perform a specific occupation - Must be State approved training in Floridas
vocational technical centers, community college
and proprietary schools
74Vocational Educational Training
- Currently does not include
- Baccalaureate or other advanced degrees
- Unsupervised homework
- May include
- Basic skills remediation if it is embedded in the
vocational program - Participants dually enrolled in GED and
vocational program can only receive credit for
vocation hours under this category
75Vocational Educational Training
- Participants engaged in Vocational Educational
Training that will be included in the
participation rate must - Be supervised daily
- Have documentation signed demonstrating daily
supervision
76Question?
- So what does it include now?
- Programs established for
- Vocational institutions
- Trades
- Employers (customized training) organized by a
vocational or educational institution - Certifications
77Job Skills Training Directly Related to
Employment
- Education or training to obtain skills required
by an employer so the participant can - Advance
- Adapt to the changing demands of the workplace
- Obtain employment
78Job Skills Training Directly Related to
Employment
- May include
- Customized training for an employer
- Or
- General training that prepares an individual for
employment with an employer
79Job Skills Training Directly Related to Employment
- This may include
- English proficiency instruction or other language
instruction, if necessary, to enable the
participant to perform a specific job by an
employer - Must be explicitly focused on skills needed for a
job or combined in a training program
80Job Skills Training Directly Related to Employment
- How do we know what an employer needs?
- Customer surveys that the RWB may already be
using - Commerce
- Consortiums
- Written surveys
- Direct engagement by employer services
- Engagement by job development staff
- Information secured through job descriptions
- Information in Employ Florida Marketplace
81Education Directly Related to Employment
- Limited to participants who do not have a high
school diploma or GED - Education directly related to a specific
occupation, job or job offer - May include adult basic education, language
instruction, or education leading to a GED when
required by an employer
82Education Directly Related to Employment
- Individuals engaged in an activity under this
category must be making satisfactory progress to
receive credit for the participation rate
83Education Directly Related to Employment
- If there is a secondary education component
- Satisfactory progress using standardized tests
(e.g., TABE) for programs including basic
education elements must be used - The participant must take a pre-test or a test to
establish a baseline once the participant enters
the WT program - The assessment must be administered using
appropriate methods - Avoid over assessing
- Avoid manipulating scores by changing the level
of the TABE drastically - Record test type and results on Plan Development
screen
84Education Directly Related to Employment
- If the education is employment/job specific and
does not contain basic education components - Secure progress from instructor on a regular
basis - This is in addition to attendance
- This must include progress towards completing
training with a certificate and skills to secure
employment
85Education Directly Related to Employment
- Remember, this activity may be used for a
participant that does not have a high school
diploma or a GED - The participant will be counted if (s)he engages
in the activity for a minimum of 20 documented
hours per week - This activity may count as full-time
participation for teens without a high school
diploma or GED - Teens must also demonstrate satisfactory
attendance
86Satisfactory Attendance at aSecondary School
- Regular attendance at a secondary school or in a
course of study leading to a certificate of
general equivalence - Is limited to participants without a high school
diploma or GED - Participants must attend classes regularly
- GED or secondary diploma
- Regular attendance is based (for teens) on the
educational institutions definition of
satisfactory attendance
87Satisfactory Attendance at aSecondary School
- May include other literacy education if required
to secure a high school diploma or a GED - May include adult basic education directly
related to obtaining high school diploma or GED
88Satisfactory Attendance at aSecondary School
- Individual must be making satisfactory progress
- Satisfactory progress using standardized tests
(e.g., TABE) for programs including basic
education elements must be used - The participant must take a pre-test or a test to
establish a baseline once the participant enters
the WT program
89Satisfactory Attendance at aSecondary School
- The assessment must be administered using
appropriate methods - Avoid over-assessing
- Avoid manipulating scores by changing the level
of the TABE drastically - Record test type and results on Plan Development
screen
90Providing Childcare Services
- Participant provides childcare for another
participant who is completing Community Service
hours - Staff must communicate with each individual by
telephone or in person to provide supervision and
offer any assistance that may be helpful - Evidence of daily supervision must be maintained
by staff and retained in the case file
91Providing Childcare Services
- The Community Service participant must maintain
his/her own time sheet for worksite hours to
demonstrate the number of hours completed at a
worksite and the number of hours a childcare
provider was needed - The Community Service participant or parent must
sign off on the Childcare Providers timesheet
documenting the number of hours childcare was
provided
92Providing Childcare Services
- Hours for providing childcare cannot be greater
than the completed Community Service hours - Does not include two-parent families watching
their own children
93- If you have any questions, comments, or
concerns, please contact the Welfare - Transition Team through the Agency for
- Workforce Innovations Call Center at
- 1-866-352-2345
An equal opportunity employer/program. Auxiliary
aids and services are available upon request to
individuals with disabilities. All voice
telephone numbers on this document may be reached
by persons using TTY/TDD equipment via the
Florida Relay Service at 711.