Kansas Department of Social and Rehabilitation Services
Gary Daniels, Secretary

Integrated Service Delivery - Candy Shively, Deputy Secretary (785) 296-3271

Economic and Employment Support - Bobbi Mariani, Director (785) 296-3349
....Enriching lives today and tomorrow

MEMORANDUM

This memo provides implementation instructions and information for the following October 1, 2006 policy changes in the Kansas Economic and Employment Support Manual (KEESM):

1. TAF

Hardship - See Summary of Changes item VII, 2 and 3, and Sections 2242 and 2243.

Under Federal direction, adults are limited to 60 months of TAF assistance. However, states are allowed a provision to continue to serve up to 20% of our population under the Hardship provisions. The following changes are included in sections 2242 and 2243 of the October KEESM revision:

1. Limited English Proficiency (LEP) issues have now been addressed in the Hardship protocol.
   
   
2. EES program administrator or designee must approve lifetime closures when the worker wants to initiate case closure because the customer is not cooperating with Work Programs.
   
   
3. Hardship criteria have been reduced from 7 elements to 6. The reference to second or subsequent penalties has been removed.
   
   
4. Re-establishment of eligibility criteria has been expanded to include hardship item #5 (CFS involvement with an open Social Services plan).
   
   
5. When a case is closed in or after the 60th month, the case is closed permanently, unless one of the hardship criteria #1-5 is met or if the case was closed for non-cooperation with CSE. This policy change includes cases that are closed for no review, employment, non-cooperation of Work Programs, etc. No penalties are applied for cases over 60 months.

The following examples illustrate these changes:

1. Case closed for no review - new application - Mary Smith has been receiving TAF assistance off and on, for 81 months. A few parts of the Hardship Protocol have not been completed. Mary did not complete her August review and her case automatically closed for that reason. Mary applies again in October. Her worker denies the case due to the 60 month time limit. If Mary meets one of the hardship criteria 1-5, she may regain eligibility. If Mary meets a hardship criteria and then is later found not cooperating with Work Programs, her case would close if the EES program administrator or designee grants approval of case closure. (Under previous policy, her case would be reopened, if all other eligibility requirements were met, as the case was not specifically closed for the 60 month time limit.)
   
   
2. Case closed for earned income - new application - Joe Brown received assistance for 65 months. He was cooperating with the Work Programs and found employment. His TAF was closed because of earned income. The 60 month time limit was not addressed on the closure notice. Joe reapplied a couple of months later. His case was denied because he had exceeded the 60 time limit. Joe is not eligible for TAF again, unless he meets ones of the hardship criteria 1-5. (Under previous policy, his case would be reopened, if all other eligibility requirements were met, as the case was not specifically closed for the 60 month time limit.)
   
   
3. Case closed for non-cooperation - new application - Sammy Jones and Donna Johnson have mutual children. Sammy has received assistance for 37 months and Donna has received assistance for 61 months. Donna is cooperating with the Work Programs. However, Sammy, is not cooperating with the Work Programs. Good cause was not found and the case was also staffed with an ISD team. Because the Hardship protocol was not completed, the case was presented to the EES program administrator or designee for approval to close the case. The approval was granted and case closed. In order for either Sammy or Donna to be TAF eligible, they must both individually meet one of the hardship criteria. If Sammy and Donna separate, eligibility is based on the individual months of TAF assistance.
   
   
4. LEP not addressed - case exceeds 60 months - Cho Chang does not speak English. There are no SRS or community supports in place to determine whether Cho has other barriers besides her Limited English Proficiency that prevent sustainable employment . Choc has received TAF for 81 months. She remains eligible for TAF until SRS has developed and made available appropriate services. (This is not a change from previous policy.)
   
5. Case closed over 60 months - now PI receives SSI - Tammy Wyant received assistance for 72 months. Her case was closed for no review. She began receiving SSI. She has now reapplied so that her children can receive TAF benefits. Under current policy, Tammy would be coded ‘OU’ and her children ‘IN’. The assistance given to her children does not count toward the 60 month time limit, and as such, no hardship coding is needed. (This is not a change from previous policy.)
   
   
6. Case closed for fraud - new application - Wilma Turner received assistance for 67 months and was found to be permanently disqualified because of Fraud. The case closed for loss of contact. She is now applying for assistance for her children. Her case could be reopened, if she meets one of the first five hardship criteria. She would be coded ‘DI’ and her children ‘IN’ on SEPA. (This is not a change from previous policy, other than the expansion of the hardship criteria to include hardship #5.)
   
   
7. Undocumented non-citizen at 60 months - Maria Sanchez is an undocumented non-citizen. She receives TAF for her 3 children, born in the United States. When the case is approaching 60 months, the case manager will review the case to determine if any hardship criteria exists. If at review, none is found, then the case would be permanently closed at the end of the 60th month.
   
8. Case closed under previous policy - new application - Susan Small received 65 months, before her case closed on August 31, 2006 for failure to complete the review process. The 60 month time limit was not mentioned on the closure notice. Susan reapplies for assistance on October 12th. If Susan does not meet any of the hardship criteria, the application is denied because the case has exceeded the 60 month lifetime limit.

2. TAF and Food Assistance

Penalties - See Summary of Changes item VIII, A, 1 and Sections 3511.1, 3511.2 and 2165.1.

Effective with the October 2006 KEESM revision, there is no longer a two-month minimum time period for second and subsequent penalties for Work program (KEESM 3511.1. and 3511.2) and CSE penalties (KEESM 2165.1). The penalty notices are removed from KsCares and the KAESCES penalty notices have been amended to reflect the change in policy. Current JOPR and PRAP coding for CSE and Work Programs will continue to be used, for case management and tracking purposes.

In TAF/FS households, the work program penalties can be cured when the customer completes the assigned activity or activities specified by the EES case manager. The household remains ineligible for TAF assistance and the individual remains ineligible for food stamps until engagement is demonstrated by completing the stated requirements. The individual must commit to the Work programs and demonstrate engagement before TAF eligibility can be reinstated. CSE penalties for TAF benefits can be cured at the time the customer completes the activity or activities assigned by the CSE case manager. No penalties shall be applied to food stamps household members for failing to cooperate with CSE. However, for both TAF and CSE penalties, the recipient shall not receive an unwarranted increase in food stamp benefits because of a TAF penalty. The TAF benefit will be reflected as countable income for the food stamp budget the first month following the month of TAF closure. If the household member does not cooperate in the month following the month of TAF case closure, the FS case shall be rebudgeted for the next month by removing the TAF benefits as countable income (KEESM 2552).

The individual will be given the opportunity to cure the penalty at the earliest opportunity. There will be times when the first opportunity is not for several weeks. If the first opportunity is not until at least 8 weeks from when the customer contacts the agency seeking to cure the penalty, then the case manager and customer can negotiate an alternative solution which must demonstrate active and consistent engagement. The “Declaration of Cooperation and Self-Responsibility Plan” form (ES-4311) is no longer an appropriate use for TAF customers. The “Declaration of Cooperation and Self-Responsibility Plan” form may continue to be used for Food Stamp customers to cure a Food Stamp comparable penalty when they are no longer wanting TAF. The “Declaration of Cooperation and Self-Responsibility Plan” form may also continue to be used in Potential Employment provisions (KEESM 3540).

As described in KEESM 1423 and 3522, if the customer cooperates during the month following the month of closure, TAF and Food Stamp benefits are to be reinstated without proration. A new application is not needed in these circumstances.

If the TAF customer cures the penalty after the month following the month of closure, a new application and interview is needed. TAF eligibility will be determined from the application date and the individual must cooperate by the end of the 45 day processing time frame.

For ongoing Food Stamp cases, the individual will be added back to the food stamp case the month following the month of cooperation, unless cooperation occurs within the month following the month of closure. This applies to new and ongoing cases effective October 1, 2006. Staff are not expected to contact closed or currently penalized cases. However, if the individual contacts SRS, the case manager will explain how to cure the penalty and eligibility will be determined following the above procedures.

The following scenarios illustrate the new policy:

1. Customer fails to show for two initial Work Programs appointments - Penalty notice sent with cure activity listed in the body of the penalty notice and case closed November 30, 2006. Penalty can be cured by attending appointment. Customer calls and an appointment is scheduled for December 10th. Customer attends and TAF case is reopened for December and the TAF December benefits are not prorated. Customer is also added back to FS case effective December 1st, 2006.
   
   
2. Same situation as above, but customer doesn’t come in until January 20, 2007 - A new application is received January 20th. The customer attends the work programs appointment on Feb. 2nd, and the penalty is cured. TAF benefits will be prorated from the application date of January 20th. Customer will be added back to FS case effective March 1, 2007.
   
   
3. Customer was scheduled for psychological evaluation on Jan 12, 2007 - Customer calls day of appointment and states child is ill and she is unable to keep her appointment. Appointment is rescheduled for Feb. 05, 2007. Customer again does not show, and good cause is not found. Worker sanctions case and case is closed Feb. 28, 2007. On March 14th, customer calls. New appointment is scheduled for April 2nd. Since there will be a 30 day break in assistance, the worker informs the customer that a new application is needed. TAF benefits will be pro-rated from the new application date.
   
   
4. April 2007, High School parent drops out of school without good cause - Worker applies penalty and case is closed May 31, 2007. On June 6th, customer contacts worker wanting to cure penalty. Since penalty can not be cured within 8 weeks, the worker assigns customer to local parenting class. Worker clearly states that 2 week participation is needed to cure penalty. Parenting class starts June 10th. Customer cures penalty on June 24th. TAF is reopened June 1st and customer is added back to FS for month of June.
   
   
5. A second Work Programs penalty is applied with case closing September 30th, 2006 - The notice sent on September 10th stated that the case will be closed during the months of October and November. Customer contacts the case manager on October 6th. The case manager explains the new policy and how to cure the penalty. The customer cures the penalty on October 29th and benefits are reinstated without requiring a new application.

3. SUCCESSFUL FAMILIES

All TAF work program (WP OP status) cases need to be reviewed by December 31 for the following factors:

• Assure all 2-parent cases in our reporting universe meet the 2-parent definition.
  
  
• Assure that the work program assessment (or minimally the Work Readiness Screening) been completed and WOPA updated.
  
  
• Assure that the work component assignment reflects the new work component definitions. Integrated Service Team staffings can be a critical component in reviewing case status and planning for future work program activities with ISD and other partners. Whenever possible, it is recommended that the work program customer participate in this staffing. (Reminder: This staffing should include reviewing possibilities for work assignments that would enhance the ability to meet work participation requirements. Regardless of the outcome however, the overall goal is to address the individual’s needs.)
  
  
• Update scheduled hours of work participation for employed TAF customers based on the 6 month projected income methodology by the next progress review.

1. Work Readiness Screening/Engagement -

See Summary of Changes, item VI., A, 2 and 5 and Sections 3100.1 and 3130.

All TAF mandatory and exempt cash assistance applications with PI’s coded IN on SEPA received on or after October 1, 2006 need to have the Work Readiness Screening (Appendix E-15) completed and discussed with the applicant prior to TAF approval. Both parents in two-parent cases need to comply with the Work Readiness Screening requirement. The Work Readiness Screening is considered “complete” when each item on the form has been discussed with the TAF applicant. This could be a face-to-face or phone conversation and needs to occur regardless of the method that the application was received (i.e., mail-in, on-line, dropped off at the office). The conversation needs to include the plan to move toward self-sufficiency and the reporting and supervision/verification requirements. Some customers will be assigned to appropriate available activities at this time.

If the applicant is assigned to an appropriate available activity and fails to comply with that assignment while the application is pending, there is ineligibility for TAF until the failure ceases (See KEESM 3511.1). If the applicant fails to comply with the Work Readiness Screening requirement, the TAF application will be denied (KEESM 2120). This eligibility requirement applies to exempt and mandatory TAF applicants.

Important Note: In all counties, food stamp eligibility shall not be affected by failure of the TAF applicant to complete the Work Readiness Screening. The state cannot add an eligibility requirement for purposes of the Food Stamp Program. Therefore, failure of an applicant to provide the form cannot affect food stamp eligibility. Since the manual for 10/1/06 states the form is mandatory for FS in FS E & T counties, an errata will be issued to correct this error.

All ongoing TAF work program cases will need to be reviewed between October 1 and December 31. If the complete work program assessment has not been completed on an ongoing case, the Work Readiness Screening or the complete work program assessment will need to be done by December 31. If the Work Readiness Screening is completed by 12/31/06 on an ongoing case, it will still be necessary to do the complete work program assessment within 90 days of the Work Readiness Screening. Customers may be mailed a Work Readiness Screening and have 2 office visit or phone appointments scheduled to discuss Work Readiness on the same notice. Ongoing TAF recipients who fail to comply with the Work Readiness Screening requirement or the complete work program assessment process without good cause will be assessed a work penalty and a comparable will be applied to the accompanying food stamp case (KEESM 2550).

A new denial code, WS, is being added to KAECSES to track the impact of this policy change.

Once a Work Readiness Screening has been completed, the individual’s work readiness needs to be determined again when the TAF cash case has been closed and the individual reapplies for assistance. This determination may be made by either having the individual complete another Work Readiness Screening or documenting the review of the current Work Readiness Screening in the file.

The following examples illustrate these changes:

1. New application - Mandatory - Sue applies for TAF cash assistance and food stamps in a non FS E & T county on October 5, 2006. She is a single mother with 2 children, ages 10 and 7. Her Food Stamp application is expedited. She is given a Work Readiness Screening form when she picks up her application. This SRS office has specialized work program staff who are reviewing the Work Readiness Screening with clients. Sue completes the initial eligibility interview but does not provide answers to the Work Readiness Screening or have the conversation with the work program worker. TAF cash application is denied, FS eligibility shall continue.
   
   
2. New application - Exempt - Alice applies for TAF cash assistance and food stamps on October 15, 2006. She is a single mother with a 6 month old child. She is given a Work Readiness Screening form when she picks up her application. She completes the Work Readiness Screening and discusses the form with the eligibility worker during the initial eligibility interview. Work program services and expectations were discussed with Alice. She indicates that she understands she will become mandatory for work programs when her child turns one but she is not interested in volunteering at this time. Alice meets eligibility requirements and TAF/FS application processed.
   
   
3. New application- Ineligible adult - Mrs. Smith is an undocumented non-citizen with 2 children (born here in the United States). Mrs. Smith does not complete the Work Readiness Screening, as it is not an eligibility requirement for ineligible adults (persons coded “DI” on SEPA). Mrs. Smith meets all other eligibility requirements and the application is approved.
   
   
4. New application - Two- Parent - Mr and Mrs Jones, a two-parent family, applies for TAF on November 1. Two Work Readiness Screening forms are given to Mr. Jones when he drops off the application. Mr. Jones comes in for the initial eligibility interview on November 7. His Work Readiness Screening is completed at that time and he turns in Mrs. Jones’ form but she does not come to the interview. Several documented attempts are made to contact Mrs. Jones to discuss her work readiness. A notice is sent to her scheduling times for an office or phone interview on November 14 or November 18. Mrs. Jones does not contact or come in for the interviews. The TAF application is denied on November 23 and the food stamp application is approved (if not already approved for expedited benefits).
   
   
5. Ongoing TAF mandatory - Client currently in EAP for 30 hours per week . When this case is reviewed during October, it is noted that the complete work program assessment is not documented in the case record. The worker mails the Work Readiness Screening and schedules the client for 2 office or phone interview appointments to come in and discuss work readiness. The client fails to respond to the notice. The TAF case is closed 11/30/06 and a work penalty is established. A comparable penalty is applied and the person is removed from the FS case effective 12/1/06. The TAF grant is counted for the December benefit month per 2552.
   
   
6. Mandatory TAF applicant assigned to a work activity and fails to comply with the assignment - Josie applies for TAF cash assistance on October 16, 2006. She comes into the office for the initial interview and work readiness screening on October 23. Based on the screening, she is assigned to 20 hours per week of Job Search beginning on October 23. She is to turn in her job contacts weekly with the first report due October 30. When the worker is ready to process the application on November 7, no job contacts reports have been returned. TAF application is denied. Josie is ineligible until the weekly job contact requirement is met. FS is approved unless it has already been approved for expedited benefits. (FS applicants cannot be required to job search per KEESM 3100.)
   
   
7. TAF case closes and Individual Reapplies for cash assistance - TAF applicant in November 2006 completes Work Readiness Screening and is approved for TAF. Complete work program assessment is done in January. TAF cash case is closed April 30, 2007 for excess earned income when the client gains full time employment. The Work Program case remains open for extended services. In July 2007, the former TAF recipient loses her job and re-applies for TAF cash assistance. At that time, the applicant’s work readiness needs to be reviewed in order to determine whether she should be assigned to a work activity as an applicant. She may either fill out a new Work Readiness Screening form or the applicant and worker can update and document the original form completed in November 2006.

2. Assessment Process -

See Summary of Change, item VI, A, 6 and Sections 3120 and 3130.

The complete work program assessment process has been modified to promote consistency statewide and emphasize the importance of the process. Complete work program assessments done on or after October 1, 2006 need to comply with this modified process. This includes the use of the Self-Assessment form in Appendix E-6. This form is to be utilized consistently statewide. Regions may not use a modified version.

The need to redo the complete work program assessment is to be considered when there is break of 30 days or more in work program services. The decision should be documented in the case record.

If there are no local resources available, it may not be possible to complete the work program assessment for individuals with limited English proficiency.

The following examples illustrate the policy intent:

1. LEP - The Region does not have resources available to assist in the administration and interpretation of CASAS, LD and SASSI for a Limited English Speaking person. This situation should be documented in the case record.
   
   
2. When the complete work program assessment may need to be re-done - Ongoing work program case. The complete work program assessment was completed in 2005. TAF cash case closes on March 31, 2007. Work program case remains open until June 30, 2007 when it is closed at the client’s request. When the client reapplies for TAF cash assistance in October 2007 a new Work Readiness Screening is completed and the decision is made that a new complete work program assessment is not needed. That decision is documented in the case file.

Please note that additional clarifying examples will be included in a Q & A’s from the Formula for Success Training Events, which will be issued when completed.

3. Work Component Monitoring and Verification Requirements -

See Summary of Changes, item VI, A, 7 and Section 3300.1.

(Information in this section is based on Work Verification Plan to be submitted by September 30, 2006. Further modifications to policy and procedure may be necessary based on Federal review and comment on the Work Verification Plan.)

All work component activity must be supervised on a daily basis. Daily supervision is defined as consistent guidance and regular monitoring of progress by either a contracted service provider, community service/work site supervisor, or EES staff.

Documentation of actual hours of work participation is required. Actual hours of work participation must be entered on SESP for cases selected for the TANF Report Sample.

For TAF cases selected for the TANF Sample, documentation/ verification of the actual hours in the report month and the Checklist will be maintained in EES Central Office. This documentation is to be filed by Sample Month. Actual hour documentation for cases selected in the TANF Sample will need to be retained for at least 3 years. Additional information on this process will be provided during October 2006. Documentation for actual hours for cases not participating in the TANF Sample may be filed in the individual case record.

Job Search supervision and documentation may be provided by a contracted employment service provider. When EES staff are directly providing supervision for self-directed Job Search activities, the Employer Contact Record (ES 4306) will be used to document the work participation activity and actual hours on a weekly basis. Ten percent of the job contacts reported on the ES 4306 are to be randomly verified on a monthly basis. In general, hours of participation are to be counted as follows:

Face-to-Face Interview = 2 hours
Mail Applications = 1 hour
Drop-off Applications = 1 hour
Internet Applications/Resume = 1 hour

The above formula for counting work participation may be increased in documented situations (e.g., excessive travel time in rural communities).

For education and training activities, the Kansas Board of Regents will be asked to define hours of study needed to assure good and satisfactory progress as defined by the institution for each 3 hours of class time. Hours will be a total for scheduled class hours plus study hours for those making good and satisfactory progress.

Work participation is allowed for holidays and excused absences, when the individual is participating in an unpaid work activity.

• Holidays are defined as any day(s) that the individual cannot report to the work site or educational/training facility because the facility is not open and days of religious observance.

• Excused absences may include but are not limited to: school appointments; medical appointments for self, children and other family members; court appointments; case manager appointments; job interviews; dealing with loss of child care arrangement; housing related issues; or other absences accepted by the employer/work site. 80 hours of excused absences is allowed in a Federal Fiscal Year (October thru September). There is a maximum of 16 hours of excused absence per month per individual. All excused absences will be tracked.

Monthly scheduled hours of employment will be projected forward for 6 months initially and recalculated at review. Scheduled hours of employment work participation should be updated to reflect the 6 month projection for employed TAF clients at the next progress review.

The following examples illustrate these changes:

1. Study Time - Ongoing TAF customer (over age 20) is currently working on her GED. She participates in class for 6 hours per week. Based on information from the education institution, she should be studying 1 hour for every hour of class time. She is making good progress on her GED work. 12 hours per week is to be shown as scheduled hours in the SAS component on SESP. If this case is selected in the sample, 12 hours per week is to be reported as actual hours.
   
   
2. Holiday - TAF customer is in Vocational Education and attending the Vocational Technical school. Her case is pulled in the TANF Sample for the report month of December 2006. Her case shows 20 scheduled hours of participation per week. The Vocational Technical school is closed for the last 2 weeks in December for Christmas Vacation. Those 2 weeks count as 20 hours per week of participation based on our holiday policy.
   
   
3. Excused Absence - TAF customer is participating in Supervised Community Service for 20 scheduled hours per week (4 hours per day/5 days per week). She reports that she was unable to attend her assignment for two days in November because of she had to go to court for truancy issues for her 15 year old child. In December we find out that her case was pulled for the TANF sample for the November report month. The agency would allow for 8 hours of excused absences for the month of November.
   
4. Employment - TAF customer is part-time employed and working on her GED. Her KsCares case shows 20 hours per week of scheduled employment and 10 hours per week of GED. Her case is selected in the TANF Sample for the month of November before it has been reviewed. The hours of employment reported for the month of November may be the actual hours worked in November or the projected hours based on the last 30 days of reflective earnings. The agency should utilize the method that maximizes participation.

4. Vocational Education/Job Skills Training/Education Directly Related to Employment/Attendance at Secondary School Review and Reauthorization Guidelines - See Summary of Changes, item VI, A, 8 and Sections 3300.2.
   
   All cases currently coded JST (Job Skills Training) and VOC (Vocational Education) need to be reviewed between 10/1/06 and 12/31/06 to determine how the activity fits into the new work component definitions. The case should also be reviewed to determine if the current training plan meets the approval criteria/ good and satisfactory definition.

In reviewing training plans to determine whether employment is in a Demand Occupation, review the Career Info link on the Kansas Job Link homepage and your Local Workforce Investment Areas listings of Demand Industries and Positions providing a reasonable expectation for obtaining a self-sufficient wage.

Please note that some training plans approved by SRS/EES partners are deemed to be approved for TAF/FS E & T work program customers. Those partners include: Vocational Rehabilitation Services; Workforce Investment Act (WIA); and Kansas Board of Regents (KBOR) Workforce Development Loan and Waiver programs. At this time, EES will consider plans approved by VR as Vocational Education hours of participation.

Only hours reported as actual hours on the TANF Sample will apply toward the 12 month lifetime limit.

The following examples illustrate these changes:

1. TAF applicant - with a child under age 6 is in her junior year of college working on a Baccalaureate degree and doing work study for 20 hours per week. She meets all eligibility requirements. 20 hours of EMP is set up on SESP. The EES Regional Program Administrator may consider approval of college plan on a case-by-case basis. If approved, support services would be available for this approved activity.
   
   
2. Exempt ongoing TAF - Customer is in last year of social work Baccalaureate program. Customer is doing an unpaid practicum (at SRS) and wants to volunteer for work programs and get child care to support the practicum participation. This practicum will be considered work experience for work participation purposes. Support services would be available for this work activity. The EES Regional Program Administrator may considered approval of her college plan. If approved the hours of college would be consider Vocational Education for work participation purposes and support services would be available for this approved activity. Only the months in VOC when the case is pulled in the TANF Sample would count toward the 12 month lifetime limit.
   
   
3. Self-Initiated - On 12/01/06, Alice applies for TAF for herself and 4-year-old daughter. She is attending LPN training at the Vo Tech and has 6 months remaining in her program. She is making good progress. She receives a PELL grant to cover the cost of the Vo Tech. When the Work Readiness Screening is reviewed, her training plan is approved. SESP shows VOC for 20 scheduled hours per week. Only the months in VOC when the case is pulled in the TANF Sample would count toward the 12 month lifetime limit.
   
   
4. Self-Initiated - On 8/15/07, Connie applies for TAF. She has two children, ages 7 and 8. She has completed one year toward her Associate Degree in Paralegal and will begin her last year in 2 weeks. She is making good and satisfactory progress. When the Work Readiness Screening is reviewed, her training plan is approved. SESP shows VOC for 20 scheduled hours per week. In order to meet the work participation requirement, Connie will need to participate 30 hours per week. Other options, such as part-time employment or work study, are discussed with her. She will pursue work study.
   
   
5. Self-Initiated Plan not approvable - Mary applies for TAF on 8/10/07. She has two children, ages 8 and 10. She is entering her Sophomore year in college, has not declared a major, and is on academic probation. When the Work Readiness Screening is reviewed, her current training situation is discussed with her. She does not have career plans and appears to be going to school for the financial aid. Her training plan is not approvable. She will need to meet the work requirements in order to be eligible for assistance. Job Search may be an appropriate assignment for her while she is in applicant status.
   
   
6. Plan not approvable - During the review of this ongoing TAF case in November 2007, the customer expresses an interest in CNA training. This customer has 40 months of TAF. She has received 6 work program penalties for failing to follow through on job search and work experience assignments. She is currently in EAP for 30 hours. Her inability to follow through on previous assignments needs to be considered in reviewing the request for training, and training would not be an approvable plan at this time. A work site assignment in a medical setting might be a good alternative. Vocational testing or Job Fit profile (soft skills assessment) might be another good next step to pursue. Training may be considered at a later date if the customer demonstrates the ability to follow through on assignments.

5. Work Components - See Summary of Changes, item VI, A, 9 and Sections 3310, 3320, 3330 and Appendix T 1.

The following work components are in effect October 1, 2006:

Primary Work Components

Unsubsidized Employment (EMP)
Subsidized Public Employment (SPB)
Subsidized Private Employment (SPR)
Work Experience (WXN)
On-the- Job Training (OJT)
Supervised Community Service (SRV)
Vocational Education (VOC)
Job Search/Job Readiness (JSR)

Secondary Work Components

Job Skills Training (JST)
Education Related to Employment (ERE)
Secondary School Attendance (SAS)

Components Not Countable for Federal Work Participation

Alcohol and Other Drug Assessment and Treatment (AOD)
Assessment (ASE)
Children and Family Services (CFS)
Disability and Employment Services (DES)
Early Head Start (EHS)
Head Start (HST)
No Appropriate Component (NAC)
Mental Health Care (MHC)
Orientation, Assessment, Referral Safety (OAR)
Physical Health Care (PHC)
Post Secondary Education (PSE)
Refugee Employment Services (RES)
Social Security Applicant (SSA)
Workforce Investment Act (WIA)

The KsCares Work Program Activity Table will be changed to reflect how work components will be counted for federal reporting purposes effective October 1,2006.

The following components will no longer count for Federal work participation credit and will be completely removed from the KsCares Table effective 12/31/06. Staff need to review cases in these components and move customers to appropriate, available components. Beginning September 25, monthly printouts of EAP and SPP customers will be distributed to assist staff in this review.

Employment Assessment Process (EAP)
Pilot Project (PPR)
Special Project (SPP)
Remediation (REM)

The September 25 printout will contain all TAF individuals in EAP and SPP components scheduled to end after December 31, 2006. The October and November printouts will provide updates to assist staff in moving these individuals into other available components. In addition, the transportation authorizations for all individuals in EAP and SPP will end December 31, 2006.

SPP review: Regions need to review their current Special Projects to determine how the work activities fit into the new work component definitions. Between 10/1 and 12/31, KsCares should be updated to reflect the realistic number of scheduled hours in work components for the former Special Project.

Example: Arbor Jet is currently a Special Project offering 3 Phases of work activity. The first 4 week activity phase is Job Search/Job Readiness (JSR); the 2nd phase is Work Experience (WXN) and generally lasts 1 month; the 3rd phase is 60 days of job retention/career advancement and would now be coded as On-the-Job Training (OJT).

The following current components will be converted automatically to new components on October 1, 2006:

ABE = ERE
WXP =WXN
JRM =OJT
IND = JSR
JCM =JSR
ESL =ERE
ERW=JSR
GRP=JSR
COR =EMP
GED = SAS
HIS = SAS

The above old components which are being converted automatically will be deleted from KsCares after the conversion.

As staff review all work program cases between October 1 and December 31, 2006, the component changes/modifications need to be considered on individual cases. Also staff need to either set a worker alert or end the component assignment at 6 months in order to comply with the 6 month progress review requirement (will be incorporated in KEESM January revision).

Following is guidance to consider during the review of work program cases:

Alcohol and Other Drug Assessment and Treatment (AOD) - Health Care Policy (HCP) is currently developing plans for providing countable work activities to our TAF customers with substance abuse barriers to employment in as many circumstances as possible. Providers are also developing systems for supervising, documenting and verifying actual hours of work activity for federal reporting purposes. EES staff need to communicate with RADAC and/or Solutions Intensive Case Managers to determine current activities of AOD customers as cases are reviewed between 10/1 and 12/31. KsCares will need to reflect the actual work components and realistic scheduled hours. As AOD customers are pulled for the TANF Sample, EES staff will need to update KsCares to reflect actual hours of documented/verified work participation during the report month.

Unsubsidized Employment (EMP) - For the first 3 months of Self-Employment, the individual’s statement of the number of anticipated employment hours will be accepted until there is sufficient information to document the self-employment income and hours. After the initial 3 month start up period, an average of anticipated countable income will be based on at least 3 calendar months of income which are reflective of the individual’s income pattern. Countable income is calculated based on gross income minus actual expenses or a standard 25% deduction for business costs. The customer may choose whether the actual expenses or the standard deduction is used. Once a tax return has been filed on the self-employment, the average may be based on the most recent year’s income tax return or the most recent three months of earnings. Once the countable income has been determined, the hours of participation will be determined by dividing the countable income by the federal minimum wage.

The scheduled hours for all employment activities (Unsubsidized Employment; Subsidized Public and Private Employment; and OJT) should be updated to reflect the new projected income/hour methodology at the next progress review. When these cases are selected in the TANF Sample, the reported hours should either be based on the projected income/hour methodology or actual hours for the report month.

Work Experience (WXN) - Cases currently in Work Experience should be reviewed to determine if the hours calculated on the cash and food stamp benefit are correct. Assignments based on the cash and food stamp benefit calculation are deemed to meet the 20 hour primary component requirement. If there are individuals on the food stamp case that are not on the TAF cash case, the food stamp benefit is to be prorated to determine the TAF household’s amount for the work participation hour calculation.

Example: FS benefits is $400 for 8 persons, only 4 of which are on TAF. The FS benefit to include when determining the work participation hours would be $200. ( $400 divided by 8 = $50 X 4 = $200.)

Supervised Community Service (SRV) - Customers currently participating in Community Service need to be reviewed to determine if they meet the new definition. There also needs to be a review of the scheduled hours to determine if the scheduled hours are based on the TAF cash and food stamp benefit amount divided by the federal minimum wage. If there are individuals on the food stamp case that are not on the TAF cash case, the food stamp benefit should be prorated to determine the TAF household’s amount to be used for the work participation hour calculation.

Job Search/Job Readiness (JSR) - SESP should reflect realistic scheduled hours of Job Search/Job Readiness activity. The 4/6 week time limits only apply to the weeks that are reported for federal reporting purposes in the TANF Sample. Assignments should reflect what is the best plan for the individual.

Example: Customer is coded in JSR for 20 scheduled hours per week in October in substance abuse treatment. For the first 2 weeks in November ,she is coded in 20 hours per week in SRV because she is participating in a community service activity at the treatment facility. The last 2 weeks of November she is in 20 scheduled hours per week of group job search. Starting in December she is in self-directed job search and is coded in JSR for 0 scheduled hours per week. She is pulled for the TANF sample report in December. The documented, verified hours of job search in December can be reported as work participation.

Vocational Education (VOC) - SESP should reflect realistic scheduled hours of Vocational Education activity. The 12 month per lifetime limit only applies to the months that are reported for federal reporting purposes in the TANF Sample. Assignments should reflect what is the best plan for the individual.

Example: Client is coded for 25 scheduled hours per week
in December 2006 thru May 2007 in VOC. In April 2007 this case is selected in the TANF Sample. Actual hours of 22 hours per week for the report month are verified, documented, and reported. Only April 2007 counts toward the 12 month lifetime limit for VOC.

Children and Family Services (CFS) - EES and CFS staff need to review current activities of mutual TAF clients. Discussion may include a review of the family’s current work activities and whether it is appropriate to assign additional work activities to assist in meeting the work participation requirements. The KsCares case needs to reflect the realistic scheduled hours in actual work components.

Disability Employment Services (DES) - EES and RS staff need to review current activities of DES customers. Discussion may include whether it is appropriate to assign additional work activities to assist in meeting the work participation requirements. The KsCares case needs to reflect the realistic scheduled hours in actual work components.

Example: DES customer is currently in her sophomore year of a baccalaureate program approved by RS. RS, EES and the customer discuss whether additional work activities (i.e., work study) are appropriate at this time. The customer is participating 20 hours per week in classroom and study time per week, and it is agreed that the baccalaureate program is all the customer can handle currently. KsCares SESP is coded: DES “0" hours, VOC for 20 hours. EES will provide support services for the RS approved plan.

Head Start and Early Head Start (HST/EHS) - EES and Head Start/Early Head

Start staff need to review the current activities of HST and EHS customers. Discussion

May include whether it is appropriate to assign additional work activities (including increasing classroom volunteer hours and/or policy council participation) to assist in meeting the work participation requirements.

Post Secondary Education (PSE) - EES staff should review cases currently in the PSE component. Effective October 1, this component will no longer count for federal reporting purposes. The review should include determining whether the plan is working toward a baccalaureate degree. If the individual is in the last 12 months of a baccalaureate program that is approved by the Regional Program Administrator, SESP should reflect the number of weekly scheduled hours in VOC. If the baccalaureate program is not approved by the Regional Program Administrator, SESP should reflect PSE for 0 hours. The review should also include looking at other possible appropriate work activities for the individual which may increase the likelihood of meeting work participation requirements. Possibilities may include work study or part-time employment.

Workforce Investment Act (WIA) - EES staff should review cases currently in the WIA component with our WIA partners. This review should include looking at the current work activities in the WIA plan and recording those activities on SESP for the realistic number of scheduled hours. This review may also include assessing the possibility of additional work activity assignment to enhance the possibility of meeting the work participation requirement.

6. Miscellaneous

The successful implementation of TANF Reauthorization relies heavily on the coordination with our internal and community partners. Each Region will need to develop a local plan that addresses local coordination and implementation of TANF Reauthorization provisions. These Regional TANF Reauthorization Local Plans need to be submitted to Diane Dykstra in EES Central Office by November 1, 2006. The Plan guidance is attached.

Attachments:

Attachment A: TANF Reauthorization Regional Implementation Plan Guidance

Attachment B: KsCares Changes

Attachment C: TANF Participation Report Changes

Attachment D: Table of Work Experience hours based on cash/food stamp benefit amounts in $25 increments

Attachment E: Processing TAF Report Deadlines for FY07

Attachment F: Summary of KSCARES/KAECSES Code Card Pen and Ink changes

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