Welfare Transition Q & A's

WELFARE TRANSITION Q AND A's

       through 08/15/01

 

Allowable Costs

1.     Question:  I have been told that under WT we can help out participants with rental assistance so they do      

        not get evicted, etc.  What if a participant was staying with relatives as he/she was not able to get a

        place of his/her own and had to place household goods and belongings in a storage unit.  Would it be

        allowable to help the participant with the cost of the storage unit under the idea of rental assistance?

 

Answer:  Paying for a storage unit is not an allowable cost.  As defined in the FLORIDA On line Manual, 2415.51.04, Three Tier Payment Standard, Tier 1 allows the following shelter obligations:  mortgage payment, rent, room and board, etc. as an expense item, but not a storage unit rental.

 

Cash Severance

2.     Question:  Can RWB authorize or back date request to a month that participant is eligible for a Cash

        Severance payment if recipient is not eligible for Temporary Cash Assistance (TCA) in month of     

        payment?

 

Answer:   No.  If the individual is no longer receiving TCA nor eligible for TCA in the month of the payment request, even if they have met all of the other cash severance eligibility criteria, DCF will not authorize a cash severance payment nor will they approve payment if application has been back dated.  Florida statute (445.026) provides for severance payment "in lieu of" TCA.  If client is not eligible for ongoing TCA, then they do not meet the "in lieu of" requirement.  DCF, through local procedures should inform the regional workforce board representative that the participant is ineligible and that the severance payment will not be issued.

 

3.      Question:  If the participant was TCA sanctioned/receiving for children only and in the month that the

sanction was lifted (for compliance) she was ineligible due to earnings from a new job, can we authorize the cash severance payment on the basis that her children had been on TCA the previous month?

 

Answer:  No, since the earnings made the family ineligible for ongoing temporary cash assistance, the participant does not meet the "in lieu of" ongoing TCA criteria required in order to receive a cash assistance severance payment.  Section 445.026, F. S., provides that an individual who meets the cash severance criteria may choose to receive a lump-sum payment "in lieu of" ongoing cash payments.

 

4.      Question:  Why does the cash assistance severance form (WFI 2286) refer to the lifetime limit when the DCF policy refers to the "periodic" limits, e.g., 24/60, 36/72 or extension of limits?  This looks like a discrepancy either in the policy or the form.  Which is it? And, if it is a discrepancy, especially in the form, are the Workforce Boards aware of it?

 

Answer:  The form is being revised to be consistent with AWI policy.  The revised form (AWI 2286) should be available for distribution by October 1, 2001

 

Child Care - Minimum Requirements

 

5.      Question:  Can the local 4 C agency reject a child care authorization because the WT participant is not    

         making minimum wage or not working full-time?

 

Answer:  No.  There is no regulation or policy that requires families to be earning minimum wage, have a minimum income level, or be working a minimum number of hours before they qualify for subsidized child care assistance.  Federal and state laws, regulations, and program policy provide subsidized child care for TCA and Transitional program participants in order that they obtain or maintain employment if they meet all other eligibility requirements.  The local 4 C program should be serving all child care referrals/authorizations from the RWB as long as they meet all other income and eligibility requirements, e.g., less than 185% of federal poverty level (FPL) for TCA participants or 200% of FPL for Transitional Child Care (former TCA participants and Up-front Diversion Applicants).

 

Child Care - Special Needs

 

6.      Question:  What is the age range for subsidized child care for children with special needs?

 

Answer:  As defined in section 445.023, F.S., special needs children between the ages of 13 and 17 may be eligible for subsidized child care if funds are available and child meets eligibility criteria as provided in Section 402.3015, F.S.  This is a self-referral process (participant presents themselves directly to child care agency) and requires a minimum of twenty hours of weekly employment and income below 200% of the federal poverty level.

 

Countable Income - for TCA eligibility

 

7.      Question:  Does WIA On-the-job training (OJT) count as income for TANF?

 

Answer:  Yes, income earned from OJT is counted in the TANF budget for eligibility purposes.  OJT is considered subsidized employment.  However, income received for participation in Work-Study at a college is not counted, even though it is also considered subsidized employment, since it is funded with Title IV funds, which are not counted as income.

 

Diversion Services - Eligibility

 

8.      Question:  Since unemployment compensation is considered in establishing TANF eligibility, should it    

         not also be considered in establishing diversion eligibility?

 

Answer:  Yes.  Up-front Diversion requires that a participant be potentially eligible for TCA and unemployment compensation payments are considered unearned income when determining TCA eligibility.  Thus, unemployment compensation payments would be included as income for determining eligibility for Up-front Diversion.

 

Hardship Extension

 

9. Question:  Who has authority for determining the 20% Hardship Extensions, the department (DCF) or the RWBs?

 

Answer:  Section 414.105 (6), F. S., Time Limitations of Temporary Cash Assistance, provides that the department (DCF) in cooperation with Workforce Florida, Inc. shall establish a procedure for approving hardship extensions.  DCF has delegated the authority for recommending approval or denial of hardship extensions to the RWBs via Rule 65A-4.201, Criteria for Hardship Extensions to Assistance Time Limitations and  Time Limit Extension policy, P00-08-0103, issued August 3, 2000.  This policy provides that the RWBs may grant hardship extensions for up to 20 percent of the average monthly temporary cash assistance caseload.  (Included in the 20% are pending SSI cases). DCF will publish the yearly average TANF caseload in September of 2001.

 

Relocation - Up-front Diversion

 

10. Question:  In a case where an Up-front Diversion participant has been determined potentially eligible for a Relocation Assistance payment by RWB staff and the appropriate paperwork has been submitted to DCF for payment, is DCF staff required to complete a TCA eligibility determination prior to issuing the payment or should they just issue the payment as requested by RWB?

 

Answer:  The RWB staff is responsible for determining eligibility for relocation payment as stated on the first page of AWI policy.  Eligibility is based on income as reported on the initial application.  However, if DCF reviews the information and determines that the client does not meet eligibility criteria, they will not issue the payment and will inform the RWB of the outcome.

 

Sanctions - Transitional Services

 

11. Question:  If a participant is sanctioned, finds employment, complies to have sanction lifted and goes to DCF to reapply but is not eligible for TCA now due to earned income, is the participant eligible for transitional services including child care?

 

Answer:  Individuals are not eligible for transitional services during the sanction period.  However, if the individual complies to have the sanction lifted, then subsequently reapplies for TCA and is denied because of earned income, transitional benefits should be provided.  Eligibility for child care is contingent upon the participant having income under 200% of the  Federal Poverty Level.  Eligibility for transitional benefits would begin the date the participant was no longer eligible for cash as a result of the sanction.  This might mean that the participant "lost" one or more months of their two-year transitional benefit  period.

 

Support Services - Exempt Individuals (including SSI recipients)

 

12. Question:  If a single parent is receiving SSI and their children are receiving TANF, is the individual eligible for support services?

 

Answer:  As provided in Section 414.045 (b) (3), F. S., "Parents or caretaker relatives who are excluded from the cash assistance group due to receipt of SSI may choose to participate in work activities.  An individual who volunteers to participate in a work activity but whose ability to participate in work activities is limited shall be assigned to work activities consistent with such limitations. An individual who volunteers to participate in a work activity may receive child care or support services consistent with such participation."  The participant would ask the DCF PAS to refer them to WTP as a volunteer (code 57 on AGPI).

 

Support Services - Provider

 

13. Question:  Who do we enter as the provider for support services on OSST?

 

Answer:  The entity that is paying for the service is the provider.  For example, the gas station is not the transportation provider, the entity providing the gas money/voucher is the provider.

 

Teen Parents

 

14. Question:    What is the number of hours that a teen parent (WTP) can participate in a GED program for participation purposes.  

 

Answer:  Federal regulations and policy establish 20 hours minimum in a basic countable activity, and 40 hours maximum in any combination of activities.  Teen parents are required to participate in countable work activities.  The countable work activities are expanded for Teen Parents and include:  GED Prep/High School and Education Directly Related to Employment (prior to OSST, SVC 721 and 712).  Satisfactory attendance must be monitored.

 

15. Question:  What is the work activity requirement for Teen Parents who are high school students when they are out for summer break?

 

Answer:  The existing WAGES handbook (not yet updated) includes policy regarding summer break.  On page 7-7, it states:

"A teen parent who is participating in a secondary education program is not required to participate in other program activities during normal school breaks such as winter and summer vacations except in the following circumstances:

A. A teen parent must attend summer school if required by the educational institution.

B. Additional educational activities may be required during summer vacation to prevent dropping out or to enable the teen parent to catch up with her peers.  It is recommended that this determination be made in coordination with the education liaison."

The teen parent can, however, be placed in activities over the summer if the activity is considered an appropriate goal towards self-sufficiency.  This can include teen parent pregnancy prevention activities.

If the activity is part of the teen's plan (IRP), and the teen is in non-compliance, sanctions should be initiated.  

During the summer, if the teen is in less than 30 hours of activity, a deferral "other" should be opened in addition to any potential hours in order to excuse any one in less than 30 hours of activity.

 

To Do's

 

16. Question:  Does an "end sanction" To Do from FLORIDA indicate that the case can be reopened or is the worker supposed to wait for a "reopen" To Do?

 

Answer:  The end sanction To Do can come because of the following reasons:  the client gained an exemption; the case was closed by agency error; or in response to notification of penalty resolution (compliance or good cause).  If the participant gained an exemption or was closed due to agency error, do not reopen the case until a To Do is received from FLORIDA.  

If the To Do is in response to notification of resolution, a reopen To Do should be received within 3 working days.  If not, you should contact DCF via phone or FLORIDA regarding case status.  Until you get a response, continue serving the client using Case Notes for tracking activity.  There is no effect on the participation rate until the first month following receipt of the reopen To Do.

 

Transitional Education and Training (TEd)

 

17. Question:  Can former TCA recipients continue receiving TEd if they are not employed?

 

Answer:  Yes, as long as they are actively seeking employment.  Section 445.030, F.S., Transitional education and training provides the following:  In order to assist former recipients of temporary cash assistance who are working or actively seeking employment in continuing their training and upgrading their skills, education, or training, support services may be provided for up to 2 years after the family is no longer receiving temporary cash assistance.  This section does not constitute an entitlement to transitional education and training.  If funds are not sufficient to provide services under this section, the board of directors of Workforce Florida, Inc., may limit or otherwise prioritize transitional education and training.  Therefore a former TCA recipient must be actively seeking employment or be employed to continue receiving TEd.  Documentation is required for the Job Search activity.

 

Transitional Services - Child Care (TCC)

 

18. Question:  As a requirement of the Diversion program (for families making less than 200% of federal poverty level), does a child care provider have to be certified under Early Childhood Services program or can an individual keep a child in their home while parent works.

 

Answer:  Before child care services can be provided to any eligible participant including participants in the Diversion Services program, the regional workforce board must complete the Child Care Application and Authorization form and refer the participant to the local Community Child Care Coordinating (4 C) agency.  The State Child Care Program office which oversees this program has contracted for the provision of child care services with the 4 C agencies that are located in every region of the state.  The local 4 C agency then contracts with local child care providers for the provision of subsidized child care for their area.  

In-home Child Care is allowed.  As provided by federal regulation, 45 CFR 98.30 and State Child Care policy, parents have a choice as to their child care provider.  If the participant chooses to have child care provided by someone in their home, then the local 4 C Screening Coordinator would need to screen the in-home provider to ensure the safety of the child and then determine the subsidized amount of payment allowed.  If the in-home provider is approved to provide child care, the 4 C agency would pay for child care services using a voucher.  If there is a difference in the amount of the subsidized payment and the amount charged by the in-home provider, the participant would have to pay the difference.

 

   19. Question:  If a family is only getting Transitional Child Care, do you have to leave the case open on  

 OSST or can you close the case?

 

Answer:  You must leave the OSST case open for as long as the client is receiving TCC and enter Transitional Child Care under Skill Development.  (In order to change the Registration Status on OSST to Transitional, go to Case at a Glance/Demographic Information/OSST Registration Status, and click on Transitional).  This is important for reporting purposes as activities/services are reported from open cases.  The OSST system will not allow you to enter services on a closed case.

 

20. Question:  Under the Diversion program, if a client loses their job can they still get child care?

 

Answer:  Yes.  As provided in the state's Child Care policy, the Diversion client can continue getting subsidized child care for up to 30 days after they lose their job in order to seek employment.  

As included in the revised DCF Child Care Rule, 65A-4.218, and the Up-front Diversion statute, 445.017, F.S., the Diversion client would be eligible for Transitional child care for up to 2 years as long as they were trying to obtain (actively seeking) employment or to maintain employment and as long as their income remained below 200% of FPL.

 

21. Question:  A participant opts off with no earned income and subsequently gets a job, reapplies with DCF and is ineligible due to earned income.  Is the participant eligible for TCC?

 

Answer:  With earned income under 200% of the FPL, the participant is eligible for up to 2 years of TCC.  The first month of TCC eligibility would be the month the participant did not receive TANF (opted off in this case).

 

Transitional  Services - OSST

 

22. Question:  How do you record transitional ancillary services on OSST?

 

Answer:  There are 3 choices on OSST for transitional support services:   transitional transportation, child care, and counseling.  These can be found under Skill Development/Service Plan on OSST. Transitional training and education (TEd) can be found under Skill Development/Skill Development/Training.  Medicaid is a transitional support offered by DCF.  A SIR will be submitted to add "Employment related support services" to OSST  (revised 9/10/01).

 

Two-Parent Family - In-Home Care

 

23. Question:  In a two parent family where one parent is incapacitated, if the other parent wants to participate in a work activity can they get in-home care for the incapacitated parent?

 

Answer: DCF will refer only one parent if they have approved the TCA under ADCI, or both parents if they approve the TCA under ADCR.   The RWB will provide child care and any other services for the parent who is participating.  In-home care for the incapacitated person may be provided in order for the other parent to participate or volunteer as funds of the local RWB permit.

 

Two-Parent Family - Sanctions

 

24. Question:  In a 2-parent household, if the wife has been sanctioned at the first level and complies but then two weeks later the husband does not comply, at which level should his sanctioning begin - at the first or second level?

 

Answer: Sanctions are attached to individuals, not households, regardless of the fact that the sanction affects the entire household.  Each mandatory WT participant is required to participate or will be found non-compliant.  The level of non-compliance is determined singularly.  In the above question, the husband would be sanctioned (if he had no prior sanctions) with a level one penalty.

 

Two-Parent Family - Work Requirements

 

25. Question:  How many hours is a two-parent family required to participate in work activity/education and training?

 

Answer:  The federal requirement for two parent households is 55 hours per week if receiving subsidized child care, or 35 hours per week if not receiving subsidized child care.

 

Up Front Diversion

 

26. Question:  When tracking an applicant who has accepted an up-front diversion payment (from DCF), is it tracked under Skill Development/Services, or should the case be closed since they are not able to re-apply for TCA for three months unless an emergency is demonstrated?  Also, if they accept transitional services, are they tracked as up-front diversion, since it was an up-front diversion service, or as transportation specifically?

 

Answer:  Those who receive up-front diversion payment should be coded under Skill Development/Services.  Anyone who is receiving services, should continue to have an open OSST case; in the case of up-front diversion, they should be coded transitional in the OSST Case at a Glance/Demographic Information/Registration Status.  In addition, any transitional services or transitional education  that up-front diversion recipients receive to obtain or maintain employment should be coded in the appropriate category (e.g. transportation, child care, education and training).

 

Welfare Transition Scholarship and Mentoring Program

 

27. Question:  What is the Welfare Transition Scholarship and Mentoring Program and who is the contact person for this?

 

Answer:  The Welfare Transition Scholarship and Mentoring Program is a prepaid scholarship program for children of TCA or former TCA recipients.  A Memorandum of Understanding has been developed between WFI, Inc., Department of Children and Families, and the Florida Prepaid Scholarship program to identify eligible children by county and region and provide prepaid scholarships to selected individuals.  The Take Stock in Children group manages the Scholarship program for the State of Florida.  The coordinator and contact person for this program is  Tracy Pataka, telephone number 904-821-8087.

 

Work Activity - Counting and Reporting Requirements

 

28. Question:  How many hours is an individual required to participate in work activity/education and training?

 

Answer:  The federal requirement for single parent households is 30 hours per week. The maximum number of hours per week is 40.  (Sec 445.024 (2), F.S.)  The federal requirement for two parent households is 55 hours per week if receiving subsidized child care, or 35 hours per week if not receiving subsidized child care.

 

29. Question:  How many weeks do you count Job Search activities for federal reporting purposes?

 

Answer:  Under Section 407 (c) (2) of the Personal Responsibility and Work Opportunity Reconciliation Act, Job Search and Job Readiness activities cannot be used to count towards meeting the federal participation rate for more than a total of six weeks during the federal fiscal year.  No more than four of those weeks can be consecutive.  If an individual only participates in job search for 3-4 days of one week out of the six weeks, the partial week can be counted as a full week for that one time only.

 

However, this does not mean that a participant could not be assigned to job search for more than six weeks.  If the hours spent in job search/job readiness for any week are used to bring the participant up to the minimum number of hours required for the month to meet the participation rate, it is counted as a week.  If they did not have enough hours during the month to count in the numerator, none of the hours spent in job search will count towards this limitation.  

 

For example, the participant needs 120 hours for the month to count in the numerator.  112 hours came from Community Work Experience and 8 came from job search during one week.  In this case, one week has been used.

 

Another example, the participant needs 120 hours for the month.  She has 60 hours from Job Search for two weeks, but no other hours for the month.  Since she will not count in the numerator, the two weeks spent in job search will not count towards the federal limitation on this activity.  

 

30. Question:  How many hours of study time can be counted in a Basic Education activity?

 

Answer: Basic Education is defined as GED/HS/ABE/ESOL.  State statute allows time spent in a classroom to be matched with study time (Sec. 445.024 (l-m).  State guidance provides for a one-to-one match.  A participant who spends 10 hours in the classroom will earn 10 hours of study time that will count towards the work activity requirement.  Students should also combine other countable activities such as job skills training or work experience with time spent working towards a GED towards countable hours.

 

31. Question:  What is RWB Career Manger's responsibility regarding supervision of participants attending school?

 

Answer: Participants must submit verification that they are attending class and progressing satisfactorily.  The Career Manager will review the participant's progress at least monthly and update the OSST system accordingly.

 

32. Question:  If a client is working 40 hours a week doing maintenance at her apartment as in-kind services to pay her rent, can the 40 hour of maintenance work be considered a work activity for TANF work requirements?

 

Answer:  Yes.  It is entered on OSST as unsubsidized employment.  To calculate the wage for employment, divide the value of the service being received, in this case the rent amount, by the minimum wage and then divide the resulting figure by 4.3 weeks to get the number of hours counted towards their work activity.   This type employment cannot be counted as Work Experience because that has to be performed at a not-for-profit agency.

 

Example:  The value of the participant's rent is $600.00.  To calculate hours of work activity, divide $600 by $5.15 (minimum wage) which calculates to 116.50 hours divided by 4.3 weeks equals 27 hours per week. She would have to be assigned to an additional 3 hours per week in another activity, e.g., education, job search, etc., to meet the minimum 30 hours per week participation rate. Unless this employment is preparing the participant for self-sufficiency, encourage the participant to participate in the maximum number of hour's (40) in order to upgrade skills, and eliminate barriers in the remaining months of their time limit.

 

33. Question:  Can you use study time for educational activities other than GED?

 

Answer:  As provided in Section 445.024 (1) (m), F.S., a participant may earn study credits equal to the number of actual hours spent in formal training per week, but the total number of hours earned for actual hours spent in formal training and studying may not exceed a one to one ratio.  Study hours may be earned for GED preparation, adult basic education, and English language proficiency training.

 

34. Question:  Do we now assign Basic Education activity hours differently as there is an hour for hour study time?

 

Answer:  The number of hours assigned to an educational activity can now include study time.  For example, if the participant is attending 5 classes a week, each class for 3 hours, they are in the classroom for 15 hours a week.  They will be given participation credit for an additional 15 hours for study time.  Therefore, their assigned hours would be 30.  If their documentation for any given week is less than 15 hours in the classroom, for example 12 hours in the classroom, 24 hours would be documented on the JPR screen (12 hours for the classroom and 12 hours study time).

 

Work Activity - Less than minimum wage

 

35. Question: How do you calculate wage and hours for people working for commission?  For example, the customer is working 50 hours a week (215 hours per month) and earns $350. a month in a real estate office.  This comes to $1.62 an hour.  If she makes a sale, she will get commission, but so far she hasn't.

 

Answer:  We came up with this solution after many discussions by different workgroups.  If our customers are working for less than minimum wage we don't want to tell them that they must quit the job, however, we will do the calculation to determine how many hours of participation we can credit them with, based on minimum wage.  If the calculation comes out to 15 hours, then we must assign them to do an additional 15 hours to bring them up to the 30-hour minimum.  It is up to the customer to determine whether or not they want to continue with the employment that is less than minimum wage.  We are trying to get them to a point of self-sufficiency in a limited time period.  Working less than minimum wage will not do this.  We are basically only assigning the customer to do 30 hours per week based on minimum wage.  

 

In the above question, the salary is $350. a month.  To calculate the hours of work activity, divide the $350 by $5.15 (minimum wage) which calculates to 67.96 hours divided by 4.3 weeks equals 16 hours per week.  The customer would have to be assigned to an additional 14 hours per week in another activity to meet the minimum 30 hours per week participation rate.

 

Allowable Costs

 

1. Question: Can RWB use TANF funds for co-pay for mental health services for a

child receiving Medicaid?

 

Answer:   No. If Medicaid is used to pay for the counseling services, the services are classified as medical.  TANF cannot be used to fund medical services therefore TANF can not be used for co-pay.

Child Care

 

2. Question:  Participant fights with child care providers.  After the second provider

reports the fighting incident, the local 4C Agency refuses to provide day care services to her until she takes anger management and domestic violence classes.  WT has agreed to pay for the costs of those classes for the individual but classes are in the evening and there is no child care available from 4 C provider or relatives and friends.  As the participant appears to be sabotaging their child care, must we allow a deferral due to lack of child care?

 

Answer:  If all attempts to accommodate the participant's child care needs have been made and child care is still not available, the participant will need to be deferred.  The provider would need to follow up with an alternate plan, including ongoing research for counseling for the participant keeping in mind her child care needs.

 

Hardship Extension

 

3. Question:  Does a Hardship Extension need to be initiated for participants who

leave due to earned income or who opt off?

 

Answer:  Hardship extension determinations are made for 1) those participants who have six months remaining of their TCA time limits and who are receiving TCA (or who are sanctioned with a protective payee); and/or  2) Former participants applying for TCA who had no months remaining on their time clock but had not been denied a hardship extension in the past.   

Individual Responsibility Plan (IRP)

 

4.  Question:  Is an IRP required for everyone?

 

Answer:  An IRP is required for everyone receiving TCA.  If an individual is receiving Transitional Services/Education and Training (TEd) funded by the RWB, it is up to the RWB to develop a local operating procedure detailing when a plan is required.

 

5. Question:  When should the IRP be initiated?

 

Answer:  It should be initiated within 30 days of the receipt of the new case,  reopen or transfer to do.

 

Non Countable Work Activity

 

6. Question:  When is a participant required to repeat Orientation?

 

Answer:  A RWB should develop a local operating procedure specifying when/at what intervals participants should be required to attend Orientation based on the provider's curriculum and how often the curriculum is updated.

 

Relocation

 

7. Question:  Can a TCA participant who has exhausted their lifetime TCA benefits

receive Relocation Assistance if they apply as an applicant?

 

Answer:  No.  The individual must meet all factors of eligibility for TCA.  If they have used their lifetime benefits, they would not meet all factors, e.g., be potentially eligible for TCA.  However, if they have never been denied a Hardship Extension, they could request one and, if approved for one and receiving TCA they could then apply for Relocation Assistance.

 

8. Question:  What is state policy on monitoring relocated families?

 

Answer:  Based on new revisions to the Relocation Guidance, within three months of the relocation the former RWB designee is required to administer a survey to all relocated families to determine the adequacy and quality of services they received after relocating. The receiving RWB is required to provide all transitional benefits for which the participant is eligible (based on availability of funds) and monitor the family based on local protocol.  State guidance also recommends that the RWB provider contact child care providers in the new location to ensure that subsidized space is available, if needed.

 

Sanctions

 

9. Question:  A pre-penalty is ended with an outcome of compliance and a second failure occurs within 30 days.  Waiting the required 3 working days to allow good cause to be reported puts you outside the 30 day window, how should this be handled?

 

Answer:   A second failure within 30 days is the key. Allow 3 working days and then request a sanction if good cause is not determined.

 

10. Question: Can a participant who has a minimum sanction period for a 2nd or 3rd

level have the sanction lifted prior to the end of the minimum sanction period?

 

Answer:  No.  They cannot comply to have the sanction lifted prior to the end of the minimum sanction period.  However, there is nothing in policy that prevents you from scheduling them for an appointment on the first day following the minimum sanction period if they indicate they would like to comply.  NOTE:  If good cause is demonstrated, the sanction can be lifted at any time.

 

Example:  A level 3 sanction is imposed for a minimum of three months, August 01 through October 31.  The earliest the individual can comply is November 1.  You can send them an appointment letter for November 1 to ensure that they be seen that day.  If they fail to keep the appointment, the sanction would remain in effect.

 

11. Question:  Can a participant on a 2nd or 3rd level sanction receive support

services in order to comply?

 

Answer: Yes, however compliance cannot begin nor can support services

be provided until the minimum penalty period has been served.

 

12. Question:  If a person has a 2nd or 3rd level sanction and has served the minimum penalty period and would like to comply  but is now physically unable to comply what do we do?

 

Answer:  Once the minimum penalty period has been served, the sanctioned individual can request to comply.  Compliance can include verification of medical incapacity.  The sanction can be lifted if verification is provided and participant can be deferred on the alternative plan.

 

Support Services

 

13. Question:  On OSST how are support services for children tracked?

 

Answer:  On the Skill Development page, under Services, you can use any of

the services currently in the dropdown box, however, the only ones identified

specifically for children are Children - Medical Care, Children - Remedial Medical

Care, and Welfare Transition Child Care. You could also assign one of the

Benchmark codes to be used for this purpose. Once you select a service to be provided, you will click on the child's name that you want to provide the service for, under Service Recipients - In House, which is on the same screen. This ties the service to the child. You could also select transportation, if you are providing transportation services for the child. Any of the services in the dropdown box can be selected and tied to an individual child. This is not true for training or activities, only services.  If the region has ongoing training or activities that they provide to WT children, it might be helpful to attach a service benchmark to a training provider for internal tracking.

 

14. Question:  How do you edit a cost that has been added to a service and get a

 tracking number?

 

Answer:  After you have added a service/training/activity you will automatically get a screen titled Cost Detail. The first entry on that screen is the Tracking Number. If you add the cost at a later date, you would go to the hyperlink for the service/training/activity and click on the dollar amount shown.  Then click on the appropriate hyperlink for that item's edit. You will then get the Cost Detail screen to add the cost and the tracking number.

 

Temporary Cash Assistance

 

15. Question:  If a participant has received an overpayment and DCF has referred

the case to benefit recovery, can the participant still receive relocation, cash

severance, and other services?

 

Answer:  Yes, as long as the participant remains eligible for TCA or transitional services.   The participant would have to repay the overpayment either through a monthly reduction in their cash assistance if they are still on TCA or through periodic payments made to the Benefit Recovery provider if they are no longer on TCA.

 

Transitional Services

 

16. Question:  How many hours is a participant required to work to be eligible for

 TCC?  

 

Answer:  There are no minimum work hours required to be eligible for TCC.  TCC is authorized for the verified work hours and reasonable time to and from child care/home.

 

17. Question:  A former participant's case was closed due to employment. She is no

longer working but is actively participating in SNAP E&T and Work Readiness.  As her

sister is incarcerated, the participant has custody of her 10 month old niece for whom she is receiving TANF (her needs are not included in the grant).  Is the

participant eligible for Transitional Child Care while seeking employment?  What

if she has gained employment but needs child care to work.  Can we offer child

care assistance or TCC?

 

Answer:  If your participant left TCA with earned income, has a dependent relative in the home, and is actively seeking employment or has found employment, she is eligible for TCC as long as her gross income is under 200% of the federal poverty level.  (The Child Care coordinating entity will make that determination.)  The two-year clock for TCC started the month the participant became ineligible for TCA.

 

18. Question:  Who authorizes Transitional Child Care?

 

Answer:  It depends on where the participant requests the child care.  RWB providers authorize TCC for employment and education.  If the participant returns to DCF, they can authorize TCC for employment.

 

19. Question:  Does the two-year TCC time frame start over if the TCC recipient

goes back on TCA and then closes TCA again with earned income?

 

Answer:  Yes.  The participant would be eligible for a new two-year

authorization.

 

Two-Parent Family

 

20. Question:  If one parent is employed and one is looking for employment, is the

family eligible for TCC?

 

Answer:  Yes. If TCA is closed due to earned income, opting off w/earned income, increased child support, or time limits ending, TCC is available for participants who are working or seeking employment.  In a two-parent household, if one parent is employed the family may receive TCC so that the other parent may job search.

 

21. Question:  If one parent is employed, how long can the other parent job search

before becoming ineligible for child care services?

 

Answer:  Technically, there is no time limit for the job search (within the 2-year TCC time-limit), however, the job search activity must be a documented diligent job search.

 

22. Question:  If one parent is employed and the other parent is attending school, is

the family eligible for TCC?

 

Answer:  TCC/Ted would be available if there is an approved plan in place (documented on the IRP) that included education as a goal toward the family's self-sufficiency.  In addition, the family must have a demonstrated need for the TCC.

 

Up Front Diversion

 

23.  Question:  Who is eligible for Up Front Diversion?

 

Answer:  As an alternative to receiving cash assistance, families who qualify for TCA may receive Up Front Diversion.  RWB designees must review each family's situation on a case-by-case basis and respond to emergency needs. Two screening tools are used for determining eligibility for Up Front Diversion: AWI 2073A determines if Up Front Diversion is likely to be effective, and AWI 2073B determines if the family is likely to be eligible for TCA.

 

24. Question:  What does Up Front Diversion include?

 Answer:  Up Front Diversion includes:

· Linking applicants with job opportunities

· Offering services such as childcare and transportation as an alternative to welfare

· Screening families to respond to emergency needs

· Offering a one-time payment of up to $1000 per family

 

The services offered may vary based on the family's circumstances and what they need to overcome their current situation so they can focus on finding or keeping a job.

 

25. Question: What is the turn-around time for the Up Front Diversion payment?

 

Answer:  Recognizing that Up Front Diversion is designed to help families cope with emergencies, payments should be authorized within five working days after DCF receives the authorization (CF ES 2075) from the RWB designee.

 

26. Question:  Can a family receive TCC if they only receive services in the Up

Front Diversion program?

 

Answer: Yes. If a family is eligible and is diverted through the Up Front Diversion program with the provision of services (e.g. car repair, mortgage payment, utility payment) only, they are eligible to receive two years of TCC.   Any other diversion support service would be considered short-term and available for up to 4 months.

 

27. Question: Who pays for Up Front Diversion?

 

Answer: Using TANF funds, the Department of Children and Families issues the Up Front Diversion payment of up to $1,000. The two years of Up Front Diversion TCC is paid for by the State Partnership for School Readiness Child Care program.   All other services, i.e. car repair, utility payments, mortgage payments, are paid for by the RWB.

 

28. Question: Can a family who is sanctioned qualify for Up Front Diversion?

 

Answer: Sanctioned families are not eligible for TCA and therefore are not eligible for Up Front Diversion. State policy requires that RWB designees must verify that the family is not currently under sanction. Families with current sanctions must serve out their sanction period and be in compliance before they are eligible for

 

Up Front Diversion.

 

29. Question:  What is meant by income as existed on the date of application for Up

Front Diversion?

 

Answer: If the participant has no earned income on their date of application but has earned income that will begin after the date of application (e.g., the same month) then do not count the anticipated income to determine income for Up Front Diversion.  On the other hand, if the participant has earned income that begins on or before the date of application, count that income when determining eligibility for Up Front Diversion.

 

Work Activity

 

30. Question:  If a participant is assigned over 30 hours of activity, and the activity

is documented on the IRP, can they be sanctioned if they only comply 30 hours

to meet the federal participation rate?

 

Answer:  Yes.  While the minimum participation rate is 30 hours per week for participation rate purposes, the participant is required to follow their Plan (IRP), which can include up to 40 hours of activities per week.

 

31. Question:  How many hours of participation can be counted for vocational

education?

 

Answer: The number of actual hours spent in the classroom count towards the 30 minimum hours.  The one for one study hours do not apply for vocational education.  NOTE:  15 hours may be considered full-time for the educational institution, however it is not the 30 hours required for participation.

If the person is coded Vocational Education (as a primary activity), (with the 12 month countable restriction), supervised study hours are an option.  For example, a librarian can sign their time sheet verifying they were in the library "x" number of hours a week.  A lab or study group can be verified by a lab attendant or instructor.  These hours can be counted toward the required 30 hours.

If supervised study time is not available, you might want to assign the participant to Work Experience combined with education.   The participant could be placed in a work site for the calculated hours (possibly the school they are attending if appropriate or a non-profit agency, etc) or in the department of their major.  They may still need some supervised study hours to meet the 30 hours.  NOTE:  This is entered as one activity (Work Experience combined with education) on OSST.  Do not enter the educational portion of this activity separately.

 

32. Question:  If a participant is attending a GED program that requires 30 hours a week, with a one to one match for study time of 30 hours, should 60 hours of participation be entered on the JPR screen if the 30 hours of classroom time are verified?

 

Answer:  Yes.  Participants are only required to participate for a maximum of 40 hours a week in a work activity/education.   There are no maximum number of hours that can be entered on the JPR screen.  JPR entry is based on actual and earned hours of participation.

 

33. Question:  If a participant is assigned to a CSWE/WE work-site and the site closes for a holiday, is it appropriate to count the regularly scheduled hours for participation?

 

Answer:  Yes.  Federal Regulations state that if an employee is paid, it is counted as time worked.  Therefore, if it is a paid holiday, the participant can be credited the time as hours participated.

 

34. Question:  Can a Community Service Work Experience (CSWE) participant be

placed with a For-Profit Service Employer?

 

Answer:  No.   CSWE participants may only be placed with a public or private non-profit employer.

 

35. Question:  Are there any limitations on which tasks a CSWE participant can

perform?  If we have a CSWE participant in our office, can we have them sign an

understanding of confidentiality and allow them to file, do computer data entry, etc?

 

Answer:   A statement of confidentiality would be a minimum requirement.  There are no state guidelines on this.  It is up to each region to develop a local operating procedure.  This procedure might include a job description and expectations.

 

36. Question:  How many hours of participation can be counted for Job Search?

 

Answer:   In the more populated areas each job contact/job application is equal to two hours of participation.  If the participant lives in a rural area and needs to drive greater distances to job search then each job contact/application is equal to four hours.

 

For example, for the minimum of 30 hours, 15 job contacts would need to be assigned (two hours per contact) per week for populated areas.  In order to count four hours per contact, the RWB would need to designate the area as rural in their WT State Plan.

 

37. Question: When do you close services on OSST if participant no longer receives

TANF due to earnings?

 

Answer:  If the TANF case is closed due to earnings, all services, except employment, should be closed on OSST on the last day of the month that the participant receives TANF.  Verification of income should be obtained, and the JPR screens updated.  The case would then be changed to transitional and any transitional services being provided (transportation, TCC, etc.) would be opened.  

If the TANF is canceled due to a sanction being imposed, all services and the OSST case would be closed on the date the to do was created.

 

38. Question:  When should Job Search be opened/closed?

 

Answer:  The "actual start date" (entry in this field generates JPRs when it is for

a countable activity) should be entered when it has been documented that the participant actually started Job Search or any other activity.  Job Search/other activity should be closed when the Job Search/other activity is completed or when it is appropriate for the participant to be assigned to another activity.

 

39. Question:  How long can Job Search be counted/how do we determine if the 4/6 weeks of Job Search has been used for the year?

 

Answer: It only counts towards the 4/6 week maximum if the week was used to meet participation for the month. Example: participant completes 30 hours of Job Search for the first week of the month; completes 25 hours of Voc Ed for the second week; 30 hours of Voc Ed for the third week, and 20 hours for the fourth week of the month. She did not have enough hours (120) to count towards the participation rate for the month, therefore, the full week of Job Search did not count towards the federal limit of 4/6 weeks (the Federal Fiscal year is October 1st through September 30th).

Another example: Individual participated 35 hours per week in employment for three weeks of the month, and participated in Job Search for 30 hours one week. This week would count as one week towards the federal limit because those hours were needed for this participant to be included in the numerator for the month.

 

Worker's Comp Provider - revised 1/3/02

 

40. Question:  Who is the Worker's Comp provider for TCA participants placed in

Community Service Work Experience/Work Experience program activities (CWEP/WEP)?

 

Answer:  Per section 445.024 (1) (d), F. S., CSWE/WE participants are considered state employees for Worker's Compensation purposes.  AWI has contracted with Protegrity to be the Worker's Comp Provider for CWEP/WEP participants.   The Worker's Compensation Claims Manager for the Florida Account can be reached at 800-883-4000 (ext. 2350).   The RWBs do not need to make reference to their local provider when making claims.  They need only state that the claimant is a state employee.