WIA ELIGIBILITY POLICY

CWP Policy/Procedure -                                                      

Topic:  WIA Eligibility Policy

Number: 02-05                                    Effective Date: 7/1/2005; Update  4/30/2010

Applies to: CWP Service Providers

Approved by: CWP Chief Operating Officer

Other Policy references: CTDOL AP 00-07 change 1; AP 00-08; AP 00-16 Clarification1,

Change 3, AP 00-21 Change 5, AP 07-06, AP 00-16 Clarification 2, CWP WIA Customer Registration and Flow Guidance

PURPOSE

This policy establishes that WIA programs operated in the North Central Workforce Region, under the administration of the Capital Workforce Partners (CWP), will follow the established policy and protocols in CTDOL AP 00-07 change 1; AP 00-08; AP 00-16 Clarification 1, Change 3, AP 00-21 Change 5, AP 07-06 to document and determine eligibility of applicants for WIA reportable services.   

PROCEDURE

1.  The WIA Title I WIA Service Providers will follow CWP policy, WIA Registration and Customer Flow Policy, 01-05.  This policy and procedure may be modified to accommodate any changes in eligibility determination required by CTDOL.

2.  WIA Service Provider staff will utilize CTDOL Eligibility Administrative Policy Memo’s referenced above at http://www.ctdol.state.ct.us/wia/memos/memos-eligibility.htm to document and determine eligibility for WIA Core and Intensive services and WIA Youth services.  General eligibility for registered or reportable Core services include:

• Social Security number documentation

• Citizenship or verification of eligibility to work in the United States documentation

• Selective Service documentation for males 18 - 25 years of age or older

• Age documentation

Eligibility for Adult and Dislocated Worker intensive services will additionally include the following documentation for priority of service NOTE:  United States Veterans who meet one or more of the listed priorities will always have priority over non-veterans for service:

• Unemployed or under-employed Adults (18 years +) who are residents of municipalities in the North Central Region and are low income (70% of LLSIL); eligibility will be determined and documented in CTWBS by the WIA Title I Contractor

• TANF clients able to benefit from WIA services;

• Unemployed or under-employed adults who are residents of the North Central region and have family income in the preceding 12 months that is at or below the minimum level of self-sufficiency as determined by the Performance Evaluation Committee, and as defined as having an income that is at or below 150% of the Federal poverty guidelines; eligibility will be determined and documented in CTWBS by the WIA Title I Contractor.

• North Central dislocated workers where training or intensive services will minimize wage decline and result in earnings that meet the WIA wage standard.

• Dislocated workers identified under a federal or state discretionary grant

For Dislocated Worker eligibility, the following procedure will be used:

1.  The Department of Labor staff will complete the revised WIA 5 form and will attach the required supporting documentation for any boxes that are checked off on the WIA 5. CTDOL Memorandums AP 00-16 Change 3 and AP 00-21 both include a list of the acceptable documents used for the certification of dislocated workers.  All supporting documents will be noted in the “Verification” section of the WIA 5.

2.  When certifying dislocated workers it is imortant to give consideration to the current economic environment, including the lack of available jobs and the numbers of highly skilled people applying for jobs. In general, the chances of someone being able to return to their previous industry or occupation in a reasonable amount of time, is more unlikely than it would have been a year ago.

            If there is uncertainty as to whether or not to certify someone in Category A, based on “is unlikely to return to a previous industry or occupation” it is recommended that they be certified due to the current economic environment. This guidance is to be used until further notice.

3.  WIA Title I staff will enter the eligibility documentation into CTWBS once all documents are forwarded from the Connecticut Department of Labor.

4.  Dislocated Worker Certifications are valid for six months from issuance.

For Youth the following eligibility guidelines will apply:

1.  Per the 1998 Workforce Investment Act Section 101 (13), youth served must be between the ages of 14 and 21, low income (@ 70% of LLSIL or 100% of Federal Poverty level as defined in the CTDOL AP 00-07) and have one or more of the following risk categories:

• basic skills deficient

• a school dropout

• is homeless, a runaway or a foster child

• pregnant or parenting

• linked with the juvenile justice system (offender)

• is an individual who requires additional assistance to complete an educational program, or to secure and hold employment as defined by CWP’s “Special Assistance Categories”

2.  Special Assistance Categories

Youth who come from low-income families and do not possess any one of the risk factors identified, may participate in programming if they need additional assistance due to one of the following:

• child of parents without college degrees

• youth whose family’s first language is not English

• a high school graduate who is unemployed or underemployed

• youth who has substantial barriers to employment as identified by school or medical personnel, including disabilities

• former foster child

• child placed in custody of other relative (i.e., grandparent, aunt/uncle, etc.)

• child of single parent

• student with less than C average on most recent report card

• youth who lacks transportation, defined as: youth does not have access to a reliable vehicle during program hours AND public transportation is not available to and from program location and worksites during all program hours

3.  Up to 5% of the youth served each year may not be low income if they have one of the following risk factors:

• school dropout

• basic skills deficient

• at least one grade level below the grade level appropriate to the individual’s age

• pregnant or parenting

• possess one or more disabilities, including learning disabilities

• homeless or runaway

• offender

• facing serious barriers to employment, defined as:

• family’s first language is not English

• first generation high school graduate

• has substantial barriers to employment as identified by school or medical personnel

• former foster child

• child placed in custody of other relative (i.e., grandparent, aunt/uncle, etc.)

Requests to enroll youth who are not low income must be approved by CWP.

NOTE:  United States Veterans who meet the eligibility requirents of the WIA Youth program will always have priority over non-veterans for service.

Documentation of low income and risk factors must be presented and documented to substantiate enrollment.  Such documentation may include any of those documents listed in AP-00-21, including, but not limited to, official school correspondence, documentation from a medical professional, or another referring case manager.  Self-attestation may be used to document factors for which third-party documentation is not available.

3.  All eligible WIA participants, youth or adult, must be registered with documentation of eligibility, per the WIA Regulations, Section 664.215, prior to being served in reportable services.

4.  Customers who are certified eligible for WIA services will be provided through orientation or individual counseling, information on the full array of services that are available through the WIA programs funded by CWP, and by partner programs that are available through other, non-WIA funding.  Customers will be considered for reportable core individualized services, training programs and Individualized Training Account (ITA) scholarships based upon the criteria for priority of service defined in the CWP Registration and Customer Flow Policy 01-05.

5.  Customers who are not certified eligible for WIA services will be provided referrals to other non-reportable Core and non-WIA services and/or programs that meet their basic skills, employment or training needs.

Income Determination and Documentation Procedure

For purposes of WIA Adult and WIA Youth eligibility determination, family income will be calculated and documented using this procedure.

The WIA Family Income Worksheet must be completed for every WIA Adult and WIA Youth applicant following these steps.

• Determine the income review period and record its start (to) and end (from) dates on the worksheet.  The income review period is the 26 weeks prior to the WIA application date.

• Identify all family members and list them on the WIA Family Income Worksheet Part I; age and relationship to the applicant must be recorded.   See CTDOL AP 00-08 for the definition of family.

• Determine the income source(s) within the income review period for each family member and record the sources on the worksheet.

• Obtain documentation of each source of income listed for inclusion in the applicant file; use the WIA Eligibility Documentation Guide issued with CTDOL AP 00-21 to determine acceptable documents.    Where documentation is not available, obtain a detailed statement from the applicant (or parent for minor applicants) or third party.  Use the WIA Self-Certification form to record the statement, which must describe the source, time period, frequency, and amount of income throughout the income review period.

• Determine the sources of income that must be included in total family income; excluded income sources must be documented but not calculated or annualized.  See CTDOL AP 00-07 Change 1 for the definition of family income.

• Calculate annualized income for each family member using the WIA Family Income Worksheet Part II.  Consider the type of income and available documentation and determine calculation method to be used: average pay method or year-to-date method or intermittent work/other income method.

• Record the total annualized income for each family member on the WIA Family Income Worksheet Part I and calculate total annualized income for the family. 

Low Income Determination

• All WIA forms must be complete and signed before low income determination can be made.  The WIA Foreign Income Worksheet must be signed by the applicant, by the intake staff person, and by the parent/guardian when the applicant is a dependent.  When an interpreter has translated for the applicant, the interpreter must sign the WIA Foreign Income Worksheet as well as the WIA Intake Form.

• Consult the income guidelines for low income (70% of LLSIL) and self-sufficiency standard levels (Adult applicants only). 

• Maintain all forms and supporting documents with the WIA Title IB Intake Form in the applicant/participant file.

Special Procedure for Calculating Foreign Income

When an applicant’s income during the income review period includes foreign earnings or benefits, this special procedure must be followed, using the WIA Foreign Income Worksheet to document the process.

• Identify the country where the income was received and record on the worksheet.  When applicant has had income in more than one foreign country, a worksheet for each country must be completed.

• Identify the type of currency earned, and record on the worksheet.

• Determine the income review period and record its start (to) and end (from) dates on the worksheet.  The income review period is the 26 weeks prior to the WIA application date.

• Determine the time period within the income review period in which the applicant had foreign income, and record the start (to) and end (from) dates of this period on the worksheet.  The start date will be the same as the start date of the income review period and the end date will be the last date that the applicant and/or family members had foreign income.

• Calculate the number of weeks in the foreign income period and record on the worksheet.

• Identify all family members and list them on the WIA Foreign Income Worksheet; age and relationship to the applicant must be recorded.  See CTDOL AP 00-08 for the definition of family.

• Identify all sources of income for each family member and record on the worksheet.

• Use the WIA Family Income Worksheet Part II to calculate annualized income for each family member in the foreign currency.

• Record the annualized income for each family member on the WIA Foreign Income Worksheet in the foreign currency, and calculate the total annualized family income in the foreign currency.  

Currency Conversion Process

• Determine the effective date for currency conversion and record on the worksheet.  This will be the last date that the applicant and/or family members had foreign income.

• Go to the OANDA Currency Converter at http://www.oanda.com/currency/converter/ .

• Select the appropriate foreign currency under “Currency I Have” and enter the total foreign income  as the amount; select U.S. Dollar currency under “Currency I Want”.

• Enter the effective date for conversion and select +/- 4% Typical Cash Rate.

• Print the currency converter screen that displays the results for inclusion in the applicant file.

• Enter the amount displayed under “Currency I Want” as the Total Family Income in U.S. Dollars on the WIA Foreign Income Worksheet.

Source Documentation

• Obtain the applicant’s detailed description of the foreign income and its sources, recorded in the WIA Self-Certification form.  The applicant statement should also indicate whether the family had U.S. income during the income review period.

• Obtain documentation of the foreign income, using the WIA Eligibility Documentation Guide issued with CTDOL AP 00-21 to determine acceptable documents.  The documentation must be included in the applicant file.

• When documentation is not available, the WIA Self-Certification must provide sufficient detail to support the income calculation for all family members.   The certification must include, for each family member, the dates, sources and amounts of income throughout the foreign income review period, and must be signed by the applicant and by the intake staff person. 

Additional Income

When an applicant had both foreign income and U.S. income during the income review period, the WIA Family Income Worksheet Parts I and II must be completed, and the U.S. income must be added to the foreign income to determine the applicant’s total annualized family income.  The final income calculation must be summarized on the WIA Foreign Income Worksheet.

Low Income Determination

• All WIA forms must be complete and signed before low income determination can be made.  The WIA Foreign Income Worksheet must be signed by the applicant, by the intake staff person, and by the parent/guardian when the applicant is a dependent.  When an interpreter has translated for the applicant, the interpreter must sign the WIA Foreign Income Worksheet as well as the WIA Intake Form.

• Consult the income guidelines for low income (70% of LLSIL) and self-sufficiency standard levels (Adult applicants only). 

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