JET Program Delivery, Allowable Activities, and TANF

Work Participation Requirements

February 5, 2010

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Presenter Introductions

Don Childs, Specialist, Welfare Reform Section, Bureau of Workforce Transformation (BWT), Department of Energy, Labor and Economic Growth (DELEG)

Lisa MacLeod, Analyst, Welfare Reform Section, BWT, DELEG

Nate Oliver, Analyst, Welfare Reform Section, BWT, DELEG

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Glossary of Common Terms

• Temporary Assistance for Needy Families (TANF) – Federal Program and funding source for public assistance

• Jobs, Education and Training (JET) – Michigan’s workforce development program for public cash assistance recipients

• Department of Human Services (DHS)• Family Independence Program (FIP) –

Michigan’s cash assistance benefit program• Fiscal Year (FY) – October 1 to September

30, used for JET Funding allocations and federal reporting periods

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• The JET Program provides employment-related services, training, and supportive services to help participants obtain and retain employment and gain greater self-sufficiency

• Federal regulations require that 50 percent of all families receiving public assistance meet certain participation requirements to avoid reductions in program funding levels (penalties)

JET And Work Participation

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Bridges and OSMIS Reminders• Bridges and OSMIS communicate with each other about

case status– Data needs to be accurate and current in both systems – lack of data can lead to case closures, and errors in

case action

• All data entry and work must be completed in OSMIS and Bridges and not be handled through previous “work around” processes – Bridges will not know when actions have been taken

outside Bridges or OSMIS and may cause errors in case action

• Timely Referrals Issue– MWAs officially instructed not to serve clients whose

referral status does not appear on OSMIS– Bridges needs to send the electronic referral to OSMIS

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Timely & Accurate Data Entry

• Timely and accurate entry of data onto both the OSMIS and the FSSP is key to the success of JET clients and correct participation rates

• DHS staff views material on OSMIS and

FSSP

• Such information has also proven important in triages and case hearings

• Providing detailed documentation and case notes will lead to better file review results

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Entry of Actual Hours of Participation

• MWAs must enter JET participants’ actual hours of participation into the OSMIS within two calendar weeks of the end of each weekly period

• Actual hours must be supported and verified by the appropriate documentation as specified in BWP PI 06-34 and its changes

• Data needs to be entered on the MIS within 2 days after obtaining it

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Engagement Activities

• Appropriate and effective assessments, and discussion with clients are essential for assigning the most suitable/beneficial participation activities

• Completion of the FAST and FSSP are helpful for identifying barriers

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Barriers • DHS handles those clients with deferrals,

who continue to count; barriers needed to be addressed as quickly as possible so clients can return to JET

• Clients asked to identify barriers on applications and the FAST, but do not always do so– First mention of barriers may be at the MWA– The MWA needs to communicate with DHS

workers and JET Coordinators to begin resolution before non-compliance occurs

– Often helpful to identify barriers in the Case Notes

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JET Supportive Services• Supportive services may be provided to

all JET participants at anytime during their enrollment in JET, except for transportation allowances

• Supportive services are to be provided through the 180-day job retention period

• Supportive services beyond the 180-day retention period may be provided at the MWA’s discretion and funding availability

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Supportive Services Provisions

• Record supportive services with monetary limits (Car purchase, car repair, clothing, relocation, and transitional) on the OSMIS

• Do not use funds to pay any fines or penalties, such as those associated with a driver’s license reinstatement nor any fees for daycare enrollment

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Supportive Services – Auto Purchase and Repairs

• Up to $2000/ lifetime limit on purchase• $900/12-months for repairs• Participant employed and meeting

participation requirements (MWA Local Policy)

• Participant employed 30 days for purchase (MWA local policy)

• Participants who are not on a bus line receive preference for purchase (MWA Local Policy)

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Supportive Services – Transportation Assistance

• Actual Cost for Public Transportation • Not Less than 20 cents per mile and not

more than 40 cents per mile for private vehicle use

• Volunteer Drivers must be reimbursed at the same rate that DHS volunteer drivers are reimbursed

• Local Policy: Auto Insurance - per calendar year ($250 full coverage, $150 PLPD)

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Supportive Services – Clothing Allowances

• $500/12-months limit• Clothing as required for participants

assigned to work projects and as needed for employment may be provided

• Allowable items: interview clothing, work gloves, work boots, work shoes, hard hats, personal safety items, protective/special clothing, uniforms, and other clothing as needed to participate in training and/or clothing considered “job appropriate”

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Supportive Services - Relocation

•$1500 per Move •Must be meeting federal work

participation requirements (MWA Policy), and

•Must have employment offer at least 50 miles away (MWA Local Policy)

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Supportive Services – Non-DHS

Employment-Related Medical Expenses• No limit specified

• Certain services defined as medical services by the DHS

• To overcome barriers to employment or training

• Example: Employment-related photocopies, completion of medical needs forms, employment-related general medical or physical examination by an MD or DO; employment-related immunizations and tests required as an employment t and training condition( I.e., drug testing or vaccinations).

• Must be meeting federal work participation requirements (MWA Local Policy)

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Supportive Services - Additional

One Time Work-Related Expenses• Payments for professional license

fees (auto trade certification, etc.),

• Purchase of professional tools, business start-up expenses, etc.

• Other needs for seeking, obtaining or retaining employment

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Case Management andSupportive Services

Discussion

Comments, Questions, or Concerns__________________

Up next: Work Participation Overview

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Work Participation Origins

• Deficit Reduction Act (DRA) of 2005 reauthorized TANF and required strict work participation in particular activities for certain hours

• The US Department of Health and Human Services developed TANF regulations to implement directives of DRA

• Affected individuals, activities and required hours are federally mandated and cannot change in state policy

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Work Participation Activities

• Federal Regulations classify activities as core or non core

• Core activities focus primarily on employment, looking for employment, and gaining work skills

• Non-core activities involve education and training

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Core Activity CategoriesNote: Please reference PI 06-11 and changes

• Unsubsidized Employment

• Subsidized Employment

• On-the-job Training (OJT)

• Job Search & Job Readiness Activities (JSJR)

• Work Experience (WEP)

• Community Service (CSP)

• Vocational Educational Training (VET)

• Providing Daycare for other participant doing CSP

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Non-Core Activity Categories

Note: Please reference PI 06-11 and changes

• Job Skills Training Directly Related to Employment

• Education Directly Related to Employment

• High School Completion or GED Preparation

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Work Participation Calculations

• Work Participation is reported on a monthly basis

• Monthly work participation requirements based on the federal weekly required hours (20,30,35, 55 etc.)

• Weeks start on Sunday and end on Saturday• Multiply person’s federal weekly

requirement by number of weeks in month – 4 or 5 to determine total required hours

• Weeks are counted in month that majority of days fall (4 days)

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Required Hours of Federal Participation

Family Type Minimum Hours

Required/Week

Required Core Hours

Remaining Hours

(Non-Core or Core)

Single parent, with child under 6

20 20 None

Single parent, with children over age 6

30 20 10

Two parents, w/o federally-funded child daycare

35 30 5

Two parents with federally-funded child daycare

55 50 5

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Monthly Required Hours

Federal Weekly Hours

4-Week Month Total

Hours

5-Week Month Total

Hours

20 80 (All 80 Core)

100 (All 100 Core)

30 120 (80 Core, 40

Non-Core)

150 (100 Core, 50

Non-Core)

35 140 (120 Core, 20

Non-Core)

175 (150 Core, 25

Non-Core)

55 220 (200 Core, 20

Non-Core)

275 (250 Core, 25

Non-Core)

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FY 2010 Month Designations

Four Week Months Five Week Months

October 2009 (10/4 - 10/31)

December 2009 (11/29 - 1/2)

November 2009 (11/1 - 11/28)

March 2010 (2/28 - 4/3)

January 2010 (1/3 - 1/30)

June 2010 (5/30 - 7/3)

February 2010 (1/31 - 2/27)

September 2010 (8/29 - 10/2)

April 2010 (4/4 - 5/1)

May 2010 (5/2 - 5/29)

July 2010 (7/4 - 7/31)

August 2010 (8/1 - 8/28)

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Types of Hours• Planned hours remain on system & reports,

but may not be considered and entered as actual hours

• Required Hours are the total number of hours that must be completed in core and non-core activities to meet participation requirements

• Actual Hours are all hours completed in work participation activities that are documented, verified and recorded

• Countable Hours are Actual Hours that apply toward meeting federal participation requirements and are reported to the feds

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Actual vs. Countable Hours

• All Countable Hours should be Actual Hours, but not all Actual Hours are Countable

• Countable Hours include all requirements: activity types (core and non-core), limitations (hours of JS/JR, months of VET), etc.

• Example: Could have 30 Actual Hours of GED Prep, but without requisite core requirements, 0 Countable Hours

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Countable Hours and Participation Requirements• Countable Hours must equal or exceed

Required Hours to meet federal participation requirements

• Actual Hours are tracked and reported to indicated levels of engagement

• Countable Hours include time spent in all Core Activities, so a combination of hours in several activities can be used to meet participation requirements

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Michigan’s Work Participation Rates

• Required Work Participation Rate is 50%

• FY 2007 Work Participation rate was 27.9%

• FY 2008 Work Participation Rate was 33.9%

• FY 2009 Work Participation Rate is 28.42% as of January 13, 2010

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2007-2009 Participation Rates

05

101520253035404550

Reporting Month

Wor

k Par

tici

pation

Rat

e 2007 2008 2009

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Selected JET Activities on MIS

Activities CAI Total Statewide Total

FY 09 Attended

7,910 91,408

FY 09 Activities

17,077 191,171

JS/JR 6,422 (37.6%)

78,358 (41%)

Employment 2,345 (13.7%)

36,486 (19.2%)

Core E &T 2,423 (14.2%)

12,257 ( 6.4%)

Non-Core E & T

114 (0.67%)

5,662 ( 2.9%)

Triage 2,981 (17.5%)

39,034 (20.4%)

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Additional 2009 Activities on MIS

Activities CAI Total Statewide Total

OJT 0 (0%) 127 (.07%)

Subsidized Emp.

122 (0.71%) 695 (0.36%)

CSP 1,497 (8.8%) 8,421 (4.4%)

WEP 844 (4.9%) 3,361 (1.8%)

Inactive/Deferred

329 (1.9%) 6,764 (3.5%)

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FLSA Warnings• The Fair Labor Standards Act (FLSA) limits

amount of time per month in WEP and CSP• Divide FIP cash grant amount by higher of

state or federal Minimum Wage (state is at $7.40) to determine maximum monthly hours

• $403/$7.40 ~ 54 hours per month $492/$7.40 ~ 66 hours per month $597/$7.40 ~ 80 hours per month

• Hours above calculated limits are illegal

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Work Participation Discussion

Comments, Questions, or Concerns

__________________Up next: Some Participation

“tips and tricks”

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JSJR Time Limits

Limits are based on participants’ weekly federal participation requirements

JSJR time limits apply to the preceding 12-month period (a rolling 12-month period)

Participant Total Countable JSJR Hours, per preceding 12-month period

Single parent with child under 6

240 hours(20 hours x 12 weeks)

All other participants

360 hours(30 hours x 12 weeks)(360 hours may be counted for each work eligible individual in a two-parent family)

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JSJR Time Limits4-Consecutive Week Rule• Countable JSJR time is limited to 4 consecutive

weeks• Once an individual has participated in 4 consecutive

weeks of JSJR, that individual’s JSJR time may not count again until 1 full week after the end of the 4th consecutive week (the 6th week)

• A week is defined as the 7-day period between Sunday and Saturday

• For the purposes of the 4-consecutive week rule, any amount of time in JSJR in a week will exhaust a full week of the 4-consecutive week limit

• Hours of JSJR in 5th consecutive weeks will not be counted towards participation requirements, nor be applied toward the individual’s 240/360 hour limit

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Week 1 Countable

Week 2 Countable

Week 3 Countable

Week 4 Countable

Week 5 Not countable

Week 6 Countable

Week 7 Countable

Week 8 Countable

Week 9 Countable

Week 10 Not countable

Week 11 Countable

Week 52

Four Consecutiv

e Weeks

Etc.

Up to 240

hours (or

360) per 12 month

s

Countable JSJR Time

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Using Countable Study Time

Example

• Individual is enrolled in a VET program that consists of 4 hours per week of classroom seat time

• Educational institution recommends/expects 3 hours per week of study time per classroom hour

• May not count more than 12 total hours of study time (4 hours class time x 3 hours study time) towards their participation requirement

• May count 4 hours of unsupervised study time towards participation requirements

Weekly Class Time 4 Hours

Unsupervised Study Time

4 Hours

Supervised Study Time

8 Hours

Total Countable VET Time

16 Hours

12 hour max

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Distance Learning Activities

• Distance learning may be counted towards educational activities if documented properly

• MWAs must provide documentation from the educational institution explaining how hours of participation in distance learning are monitored

• The periods must be verifiable by the educational institution as periods in which progress was made

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Blending Participation Activities

• Core hours do not have to be completed before non-core hours

• Hours completed in activities are averaged monthly, and not weekly absolute values. For example: [25+15+22+18=80]

• Combinations of activities may be used to meet participation requirements – all core hours don’t have to be done in one activity

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Basic skills/ESL as a Component of VET

• Basic skills or ESL under vocational educational training does not need to be “of limited duration”, within the 12 month/lifetime limit of VET

• Must still be an integrated, necessary element of the program

• Example: Basic math done simultaneously with technical training for a turbine mechanic program

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Activities with Multiple Definitions

• Definitions of some allowable activities meet the definitions of other activities

• Carefully categorizing activities can maximize countable participation time and minimize use of durational limits

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Example: Training Activities as CSP

• Clinical training in a hospital that is part of a licensed practical nurse training program could meet the definition of a CSP and be categorized as such.

• This avoids using time from the 12 allowable months of Countable VET

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Barrier Removal in Employment Activities

• Barrier removal activities, such as substance abuse treatment, mental health treatment, and rehabilitation activities, may count as unsubsidized or subsidized employment, if:

• An integrated part of the employment

• The participant is paid for all hours in such activities

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Excused Absences

• Countable excused absences tracked on an hourly basis

• 80 hours of excused absences are countable per 12 month period. No more than 16 of these hours may be counted in a month

• Additional hours of excused absences may be granted, however the additional hours would not be countable towards federal participation requirements

• Excused absence policy applies to participation in unpaid work activities only, not any paid activities

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Counting Excused Absences

• To count an excused absence or holiday as actual hours of participation, the individual must have been scheduled to participate in the work activity for the period of absence

• MWAs will be required to record excused absences and holiday time on the OSMIS

• Excused absence and holiday hours apply toward the activities for which the client was scheduled to participate

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Increasing other Employment Activities

• Subsidized Employment and OJT activities use has been very limited

• Neither activity has limits on the duration of participation, nor requirement for assured employment after trial period

• While expensive and complex these activities have fewer participation and verification requirements than education, WEP or CSP

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Additional Participation Requirements

• Individuals who meet federal participation requirements but not additional requirements still help participation rate

• Work participation requirements above federal minimums may promote progress toward self-sufficiency goals

• MWAs must ensure that federal minimum hourly requirements are being met prior to assigning additional hours

• Always analyze cost versus benefit of assigning hours above federal minimums

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Compliance Issues

• Balancing additional hours of activities, minimum federal participation requirements and non-compliance triggers is important

• If a Case Conference is needed ask for one with DHS, do not schedule a Triage

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Discussion and Future Questions

Please continue to direct technical Please continue to direct technical questions to Career Alliance questions to Career Alliance Administration first…Administration first…