JET Program Delivery, Allowable Activities, and TANF Work Participation Requirements

1. JET Program Delivery, Allowable Activities, and TANF Work Participation Requirements February 5, 2010

2. 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

3. 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

4. JET And Work Participation • 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)

5. 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

6. 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

7. 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

8. 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

9. 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

10. 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

11. 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

12. 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)

13. 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)

14. 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”

15. 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)

16. 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)

17. 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

18. Case Management andSupportive Services Discussion Comments, Questions, or Concerns __________________ Up next: Work Participation Overview

19. 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

20. 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

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

22. Non-Core Activity CategoriesNote: 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

23. 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)

24. Required Hours of Federal Participation

25. Monthly Required Hours

26. FY 2010 Month Designations

27. 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

28. 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

29. 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

30. 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

31. 2007-2009 Participation Rates

32. Selected JET Activities on MIS

33. Additional 2009 Activities on MIS

34. 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

35. Work Participation Discussion Comments, Questions, or Concerns __________________ Up next: Some Participation “tips and tricks”

36. 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)

37. JSJR Time Limits 4-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

38. Countable JSJR Time Up to 240 hours (or 360) per 12 months Four Consecutive Weeks Etc.

39. 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 12 hour max

40. 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

41. 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

42. 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

43. 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

44. 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

45. 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

46. 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

47. 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

48. 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

49. 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

50. 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