Kansas Economic and Employment Support Manual

3330 Components Not Countable for Federal Work Participation - The components in this section provide valuable services to clients but are generally not countable toward meeting the Federal TANF work participation rates. These component designations may be used to help EES staff monitor caseload activity.

The following components in this section identify partners who are working with mutual customers: AOD, DES, EHS, HST, MHC, OAR, and WIA. When one of these cases is pulled in the Sample for the TANF Report, EES staff need to work with the client and the partner staff to document the actual work participation activity in primary and/or secondary components and hours for the sample month. (Note: OAR participation will always be "0" hours and actual activity hours in OARS is not documented in the Sample.) Staff need to work with partners to assure understanding of the need for effective communication of supervision, verification, and documentation information.

3330.1 Alcohol and Other Drug Assessment and Treatment (AOD) - TAF Only - The SASSI test must be administered during the SRS assessment process by a Solutions Recovery Care Coordination (SRCC) counselor when possible. The TAF participant will meet individually with the SRCC or qualified assessment counselor to review the assessment results, sign a release of information to SRS(ES-4412), and determine if an assessment is needed, and if so will assist in scheduling an appointment at that time. SRCC will provide to the EES case manager the clinical interpretations ES-4413.

1. For those individuals who are not initially identified as in need of services,     EES staff will continue to monitor participant’s behavior. If the participant meets at least one of the following criteria during the current period of participation, the EES case manager will refer participant to SRCC via the SRCC case manager turnaround form ES-4414.
   
   
   1. Two or more affirmative indications from Work Readiness Screen or Self Assessment Tool.
       
   2. Well-documented incidence of intoxication while in the SRS office.
       
   3. Dismissal from employment or any work program activity for substance abuse related causes.
       
   4. Any substance abuse related legal problems that carry current consequences (i.e., probation, diversion, loss of license, etc.).
       
   5. Client admission or medical diagnosis that an alcohol and/or drug related problem with abuse or dependency exists.
      
      
   6. Repeated failures of not showing for appointments or not following through with assessments.
      
      
   7. Positive drug screen at work placement.
      
      
   8. Indications on the psychological evaluation or Vocational Assessment of possible substance abuse.<
   
   
   Decisions to not refer participants to SRCC when one of the above criteria is met must be clearly documented in the case record.
   
   EES case managers can mandate TAF participants, who are without medical coverage, to participate in substance abuse treatment activities. EES case managers are responsible for assisting those participants in obtaining Medicaid whenever eligible. If the participant does not cooperate in obtaining medical coverage, the EES case manager will determine if a subsequent Work Program failure has occurred and a Work Program penalty should be established.
   
   Once referred, if a TAF participant refuses to participate in or follow through on the SRCC plan, the EES case manager will determine if a Work Program failure has occurred and if a penalty should be established. It is recommended that a multi-disciplinary team, including SRCC, discuss the situation and review the options with the TAF participant before a penalty is applied.
   
   
2. The Solutions Recovery Care Coordination (SRCC) System will provide screening, assessment, multi-disciplinary care management, and individualized care coordination to TAF participants with substance abuse problems. SRCC and the treatment providers will document the activities that fulfill the primary work requirements to the EES case manager on the ES-4322.1. This will include the participant’s progress toward self-sufficiency in reaching recovery goals.
   
   This plan will include the following work activities within a treatment and/or substance abuse service setting:
   
   
   1. Recovery Support Volunteer (Community Service) Dailey activities within the treatment facility that are defined as Community Service. This would include but is not limited to:
      
      
      • Kitchen duties,
      • House-keeping or other custodial duties,
      • Recovery/relapse prevention activities for the treatment community.
        
        
   2. Peer Support Mentor (Work Experience) Tasks or assignments with in the treatment facility assisting peers in treatment activities. This would include but is not limited to:
      
      
      • Helping a person with barriers in reading proficiency to process and understand written assignments and information,
      • Participate in orientating new persons in treatment to schedules and expectations of treatment, and
      • Assisting a person in performing community jobs and assignments by providing an orientation to the responsibilities of that job,
        
        
   3. Peer Support Mentor II (Work Experience) The participant may be responsible for assigning, reviewing, or supervising the completion of tasks and assignments of peers in performance of responsibilities.
      
      
   4. Peer Support Coach (Work Experience) In this job, the participant who was becoming stable in treatment/recovery development could take on a more active role in assisting others in treatment. Their activities would include but are not limited to:
      
      
      • Serve as a group leader in helping the counselor by providing educational assignments to the group that might reflect life skill improvement,
      • Serve as discussion leaders for educational groups,
      • Assist peers in treatment in barrier reduction/problem solving related to transportation, step work, and other barrier-reduction strategies,
      • Serve as a recovery buddy in supporting a new peer in attending their first AA/NA meetings by going over meeting schedules, helping them locate transportation, explaining the operations and procedures of what to expect in attending self-help meetings,
      • Develop and present of a relapse prevention plan to the treatment group,
      • In an outpatient setting they would have the responsibility of calling peers that missed appointments or treatment to support their return to treatment.
      • Additional activities would include case management, education/training, supervision, recording/ documentation.

   
   NOTE: See 3310.8 for consideration of short-term substance abuse treatment as a Job Readiness work component.

3330.2 Assessment (ASE) - TAF Only - This component designation should be utilized when a client is participating in the assessment process and not participating in any other activity.

3330.3 Children and Family Services (CFS) - TAF Only- This component should be utilized when the family is working with Children and Family Services (CFS) staff. The plan developed by the CFS staff will be considered the client's work component requirement.

3330.4 Disability Employment Services (DES) - TAF Only - EES staff should consider the following criteria in determining whether to make a direct referral to RS for vocational rehabilitation (VR) services:

• The client is interested in pursuing employment; and
   

• The client has a physical or mental disability and/or functional limitations have been identified; or
   

• The client was a participant in special education services during secondary education.

See Appendix Item #E-12, EES Screening Tool for Referral to Rehabilitation Services.

EES clients who do not meet these criteria may be referred directly to the RS Career Development Centers (CDCs) or to a private contractor for further assessment; or referred directly to their physician for a definitive medical report.

RS maintains an open application process for VR services. Clients who do not meet the direct referral criteria listed above may apply directly if that is their informed choice.

Available medical, psychological or employment records will be included with the referral to RS. Documentation may include but is not limited to: medical statement, prescription, letter from doctor, psychological/psychiatric evaluation or DDS Claim form. See the Miscellaneous Forms Section for an example of a Definitive Medical Report letter used by Rehabilitation Services staff.

EES clients who are referred to RS for VR services will complete the eligibility determination process. Eligible clients will then be placed in a priority category to determine access to services according to the RS Order of Selection policy. EES should continue to make referrals to RS even though the client may be placed on a waiting list for VR services. For EES clients who are eligible for VR services and on a waiting list, the RS counselor will provide recommendations to EES for employment-related activities that the client should participate in while on the waiting list. Such activities may include, but are not limited to: psychological evaluation; vocational assessment; ABE/GED; referral to contracted employment services, or medical evaluation. These activities would be purchased with TAF funds and incorporated into the consumer’s Self-Sufficiency Agreement (SSA). Once an individual is removed from the waiting list, RS will promptly advise EES of the change in status. RS and EES staff will coordinate to determine how to proceed with service delivery based on the client’s informed choice and progress toward employment at that time.

The plan developed by RS staff will be considered the client's work component activity.

EES will generally provide support services for mutual clients participating in VR services. However, local staff have flexibility to address special circumstances to meet the individual client's needs.

Refer to Appendix, Item R-4 for Procedural Best Practice information.

It is appropriate to share information on mutual clients on a need-to-know basis and the EES/RS Monthly Communication Report (Appendix R-5) is available to facilitate communication.

NOTE: See 3310.8 for considered of short term rehabilitation services as a Job Readiness work component.

3330.5 Head Start (HST) and Early Head Start (EHS) - TAF Only - Head Start and Early Head Start participation enhances children’s physical, social, emotional, and intellectual development; supports parents’ efforts to fulfill their parent roles; and helps parents move toward self-sufficiency. Activities may include weekly home visits, parent meeting presentations, classroom volunteer and participation on policy councils. Family Partnership Agreements are established and describe family goals, responsibilities, time tables and strategies for achieving these goals as well as progress in achieving them.

NOTE: EES staff need to work with Head Start and/or Early Head Start to determine if any activity may be considered supervised Community Service. Classroom volunteer and participation on policy councils may be considered Supervised Community Service for federal work participation reporting.

A local Memorandum of Agreement (MOA) between Head Start/Early Head Start and EES to establish partner roles is encouraged. The local plan for sharing information and the use of the Turn-Around Communication/Referral form may be described in the MOA. The MOA may also describe the local plans to share Self-Sufficiency Agreements and Family Partnership Agreements.

The Turn-Around Communication/Referral Form Between EES and Head Start/Early Head Start ( Appendix C-20) will promote the exchange of information and document the referral to the other agency. Either EES or HS/EHS may initiate the form.

3330.6 Mental Health Care (MHC) - TAF Only - This component is appropriate for clients who are working with a mental health provider to resolve family or personal barriers to employment. This component assignment should reflect the number of weekly scheduled hours that the client is participating in activities with the mental health provider that are directed toward removing the employment barrier.

NOTE: See 3310.8 for consideration of short-term mental health treatment as a Job Readiness Work component.

(See 1728 for more information regarding EHS)

3330.7 No Appropriate Component (NAC) - TAF Only - In some instances, it will be determined that there is no appropriate component assignment for a mandatory TAF or food stamp recipient. This component may also be used to identify two parent households meeting the Federal participation requirements with 35 hours per week of participation because no SRS child care is being paid. In those instances, the individual should be placed in the NAC component for 0 hours. Utilization of this component will facilitate tracking of these individuals.

3330.8 Orientation, Assessment, Referral, Safety (OAR) - TAF Only - EES contracts with the Kansas Coalition Against Sexual Assault and Domestic Violence (KCSDV) to provide domestic violence and sexual assault services for TANF clients to fulfill the Family Violence Option basic requirements of 42 U.S.C. 402(a)(7) basic requirements. See http://www.kcsdv.org.

This component addresses the impact of Domestic Violence/Sexual Assault (DV/SA) which is defined as acts on the part of perpetrators that result in:

• physical acts resulting in, or threatening to result in, physical injury;
   

• sexual abuse, sexual activity involving dependent children, or threats of, or attempts at, sexual abuse;
   

• mental abuse, including threats, intimidation, acts designed to induce terror, or restraints on liberty; or
   

• deprivation of medical care, housing, food or other necessities of life.

The evidentiary criteria in the good cause section (3530 (10) ) should be referenced in determining the existence of DV/SA as a barrier to employment.

Local area SRS staff are responsible for the following:

1. Provide an environment that facilitates confidential disclosure by applicants and recipients who are victims by use of posters, written and verbal safety assessments, brochures, and verbal presentations by DV staff which are all vehicles for notification. Provide all applicants and recipients with basic information about family violence in multiple places and levels in the SRS office and system. Opportunities for victims to disclose that they are victims should be frequent, confidential, clearly voluntary, and easy to access.
    

2. Screen and identify, as early as possible, individuals who have applied for or are receiving assistance to determine current or past history of DV/SA, while maintaining the confidentiality of such individuals. TAF Recipients who are exempt from work program requirements may volunteer to receive OARS services. Initial screening shall be completed before placement in any component; ongoing screening should occur during routine contacts.
   
   All TAF recipients referred to the DV/SA service provider will be placed in the OAR component on KsCares at the time of referral. SESP should be coded "0" hours in OAR.

OARS advocates will inform OARS participants that the following information affecting SRS benefits or services must be shared by the client directly to the EES case manager: Changes of address, household composition, income and employment. Even though this information may be shared with the OARS advocate, the OARS participant remains responsible for reporting to EES. In order to emphasize the client's responsibilities and facilitate the process, OARS advocates will ensure that clients read and sign the form titled "OARS Confidentiality Agreement" at the initial meeting with participant. A copy of the signed OARS Confidentiality Agreement will be sent to the EES case manager for the EES case file. When an OARS client agrees to have the advocate share information with the EES case manager, the Authorization for the Release of Specified Information Which Affects Eligibility for SRS Benefits, will be signed and a copy will accompany the information being shared to become part of the EES case file.

The OARS Confidentiality Agreement and the Authorization for the Release of Specified Information Which Affects Eligibility for SRS Benefits are available in the KEESM Miscellaneous Forms Section.

 

3. Local OARS Service Providers are responsible for the following:

   1. Complete an OARS Program Assessment on all TAF to assess for appropriate OARS placement.  Upon acceptance into the OARS program, the OARS Advocate will complete an OARS Service Plan to assess for appropriate OARS activities that provide alternatives to normal program requirements and reflect appropriate services for victims of DV/SA that protect victims from any immediate dangers, stabilize their living situations, and explore avenues for achieving economic independence.  An OARS Service Plan Revision Form will be completed at a minimum of every six months. Teamwork and communication between the OARS Service provider, EES staff, and other involved employment service providers is essential.
      
      
   2. Verify OARS placement and on-going compliance through documentation via the OARS Turnaround and Monthly Status Report forms. Joint client interview/meetings should occur when appropriate or at a minimum of once each year.  Exceptions to this shall be rare and shall center on client's explicit statement desiring not to share personal and confidential information, not on client's reluctance to share case-specific information needed to assure accurate TAF benefit levels.
      

NOTE:  The completed OARS Assessment, OARS Service Plan and Revised OARS Service plan are confidential documents to be kept in the OARS file.
 

4. To meet the federal guidelines, the assessment service plans must be developed by a person trained in DV and must follow these guidelines:
   
   
   NOTE: DV/SA staff and EES staff who have received either the one-day or web-based training are considered "persons trained in domestic violence" for these purposes.
    

5. • OARS plans will constitute all or part of the EES Self-Sufficiency Agreement (SSA);
      

   • The plans will identify the specific program requirements from which the individual is excused;
      

   • The plans will reflect the alternative services chosen as a result of the individualized assessment and any revisions indicated by subsequent redeterminations; and
      

   • The plans will be safety-focused and, where appropriate, contain employment goal.
      

5. To meet the component requirements, OARS participants are required to participate in the development and execution of a plan that includes appropriate and safe activities. Following safety planning, local DV/SA staff should team with the EES case manager to refine the SSA to reflect placement or removal from components and to provide the necessary EES support services. The need to continue the OAR assignment is assessed minimally at six month intervals. For those cases with an assigned DV/SA staff person, DV/SA staff will be responsible for monitoring OARS component activities, determining OARS compliance and/or completion, and reporting component changes to EES through team consultation and via the OARS turnaround form.
    

6. Support services including child care, transportation, and special services allowances can be provided during the time that the individual is participating in the OARS component. EES staff will evaluate requests for supportive payments based on the individual's need and relationship to ensuring safety (thereby facilitating work). Special expenses of victims such as rent and utility deposits, legal fees, and moving expenses may be covered as needed. However, once safety is assured, individuals are expected to meet basic needs from their income.
    

7. Penalties will not be applied for failure to comply with OARS work component activities. OARS participants who do not follow through with OARS activities will be reassessed and, if appropriate, reassigned to OARS activities or, if no longer desiring OARS participation, reassigned to other work program activities. Penalties may be applied in cases where individuals do not respond to appointment letters. In these situations, case managers should make thorough efforts to determine if good cause due to DV/SA exists.

On-site OARS advocate services will not be provided for crisis situations involving DV/SA who are not eligible for TAF work program services. The individuals will be referred to the local subcontractor agency to receive DV/SA crisis services. The on-site advocate is available for scheduled multi-disciplinary team meetings held by other agency divisions such as Children and Family Services in those cases where the victim/participant is also an TAF recipient. For scheduled case staffings where the participant is not a recipient, the team may contact the local DV/SA agency for assistance.

3330.9 Physical Health Care (PHC) - TAF Only - This component should be utilized when the client is working on specific health barriers. This may be an appropriate assignment for a pregnant client whose pregnancy is limiting employment or work program participation activities.

3330.10 Post Secondary Education - TAF Only - College courses may be approved if short term, job focused, and skills specific. Courses directed at an associate or baccalaureate degree are not approvable except by the EES Program Administrator on a case-by-case basis. Courses directed toward a post graduate degree are not approvable at all. See 3300.2.

3330.11 Refugee Employment Services (RES) - TAF Only - A KsCares case would be opened for all mandatory TAF refugees. Mandatory TAF refugees are required to meet work related requirements.

In areas where a Refugee Funded Social Service Agency (RFSSA) is available, mandatory TAF refugee recipients (including those refugees in the U.S. over 5 years) should be referred to the RFSSA for services. RFSSA's would be considered available if there is a RFSSA in the immediate area and the RFSSA has the capability of providing social services to the refugee, e.g., sufficient staff and staff time. Refugee participants working with the RFSSA would not be required to job search. Refugee participants working with the RFSSA should be coded in the Refugee Employment Services (RES) component. Acknowledgment of the referral from the RFSSA indicates that an Employability or Self-Sufficiency Plan has been developed.

In areas that do not have a RFSSA available or the RFSSA is not capable of providing services to the refugee, the mandatory TAF refugee would be required to meet work related requirements by participating in job search and/or other appropriate components.

EES staff will provide allowable support services for mutual mandatory TAF refugee clients. The RFSSA will be responsible for determining non-compliance and penalty cure for mutual TAF and RE clients. If the recipient appeals a work penalty decision, EES staff would prepare the appeal summary based on information from the RFSSA. Both the RFSSA staff and EES staff should attend the hearing.

3330.12 Social Security Applicant (SSA) - TAF Only - This component should be utilized when a client has applied for either SSI or SSDI disability benefits. Mandatory recipients with a permanent condition prohibiting participation and/or employment may apply for SSI and/or SSDI in conjunction with participation in other appropriate components unless the assessment information specifically indicates the recipient should not work. If the assessment information specifically indicates that the recipient should not work, no additional component assignment is made during the SSI/SSDI application process. This component assignment may be "0" scheduled hours or the actual number of weekly scheduled hours in the disability application process.

3330.13 Workforce Investment Act (WIA) - TAF Only - When a client is referred to WIA, the KsCares Work Program case should be open and the Self-Sufficiency Plan (SESP) would indicate that the individual is in the WIA component for 0 scheduled hours. The start date of the WIA activity should be the date of the SRS referral to WIA services. When the EES staff is notified that the client is participating in WIA services, SESP should be modified to reflect the actual WIA activity and hours of participation.

TAF and Food Stamp applicants may already be participating in WIA at the time of application for assistance. The WIA plan will be supported by EES staff. [See 3300.2 (2)].