1003-3          WORK VERIFICATION

The Alaska Work Verification Plan was written in 2008 as a response to the Federal Office of Management and Budget to ensure that Alaska was defining work activities consistently. The activity descriptions below follow the definitions provided in the Work Verification Plan. Work activity data may only be entered into CMSCase Management System once a WSPWork Services Provider has followed the documentation and verification standards for "Core" and "Work Support" activities. There are no verification standards for non-countable activities. Progress and challenges regarding participation in all activities should be included in the monthly activity debriefing conversation between the client and case manager and must be documented in a CLNOClient Notes in CMSCase Management System.

1003-3 A.      CORE ACTIVITIES

Core Work Activities are federally defined. These activities always count towards the federal participation rate.

1. Paid Employment

1. Code - WK
2. Description: Paid Employment (Activity Code WK) is federal defined as unsubsidized employment. Paid employment refers to work done for an employer that may be paid as an hourly rate, a salary, or commission based earnings. In-kind income, see ATAP MS 758-2, may also be coded as Paid Employment (WK).
3. Verification: The documentation provided by the employer to determine the hours of unsubsidized employment is also used for verification purposes. New verification is required every six months and following any reported changes in hours of employment. Employer provided statements, including documented telephone contacts, will include the date of contact, start and/or end date of the job, participant's name, actual hours of work, name of the employer, and the name, position and phone number of the person verifying hours. The caseworker will document the information obtained from the employer in the case file.  Pay stubs may also be used for verifying Work.  The hours must be reported in the month the work was completed.  WSPWork Services Providers must document the hours completed in the pay period.  The calculation for the hours must be included in the Work Activity Verification CLNOClient Notes.

Example:

Pay period 5.1.22 - 5.15.22 78 hours @ $15.00
Pay period 5.16.22 - 5.31.22 96 hours @ $15.00

Total hours: 174 hours 

or

Pay period 4.30.22 - 5.13.22 78 hours @ $15.00
Pay period 5.14.22 - 5.27.22 80 hours @ $15.00
Pay period 5.28.22 - 6.10.22 80 hours @ $15.00

238 hours/6 weeks (weeks total in the pay periods) =    40 hours per week * 4.33

Total hours: 173 hours   

Once documented and verified, the hours worked as reported by the employer may be projected for up to six months if they represent continuing circumstances. This is done by determining the average hours per week, multiplying weekly hours by 4.33 and counting this number of monthly hours for up to six months. New documentation is required for the seventh month following any reported change in hours of employment. Case managers may consider aligning their reverification with an eligibility recertification. Actual hours must be verified for the first and last months of employment.

2. Self-Employment

1. Code - SE
2. Description: Self-employed individuals may have their own business or they may be working as independent contractors and are not considered an employee of a business or organization. It is generally a for profit venture of which the participant is the owner. Self-employment (SE) hours are based on the earnings calculated by the Division's eligibility caseworker staff using the adjusted gross income, see ATAP MS 759-6, divided by the Federal minimum wage. The actual hours worked are not reported for participation purposes.

Some time preparing to open a self-employment venture may be countable towards participation hours.

Note:

It may be valuable for a case manager to note actual hours for case management purposes to assist in planning for other activities and self-sufficiency progression.

3. Verification: When self-employment (SE) income is received on a regular basis, the verification of the hours of self-employment is determined by dividing the participant's adjusted gross earned income by the federal minimum wage.

If the eligibility caseworker has not documented the adjusted gross income, the case manager will follow the policy and process the eligibility caseworker would use to make this determination in order to count hours of work participation, see ATAP MS 759-6. This process provides a degree of accuracy sufficient to determine eligibility for program benefits and it is considered adequate to calculate the hours of participation in self-employment activities. The information used to calculate the hours of participation is documented in the case file and in CMSCase Management System client notes and the work activity page.

3. Seasonal Work

1. Code - SW
2. Description: Seasonal Work is paid employment in an industry that operates for only part of a year.
3. Verification: The documentation provided by the employer to determine the hours of seasonal unsubsidized employment is also used for verification purposes. New verification is required every six months and following any reported changes in hours of employment. Employer provided statements, including documented telephone contacts, will include the date of contact, start and/or end date of the job, participant's name, actual hours of work, name of the employer, and the name, position and phone number of the person verifying hours. The caseworker will document the information obtained from the employer in the case file.

4. Business Work Experience (BWE)

1. Code - WX
2. Description: BWEBusiness Work Experience is unpaid work in the private or for profit sector that provides an individual with an opportunity to acquire the general skills, training, knowledge, and work habits necessary to obtain paid employment. The purpose of work experience is to improve the employability of those who cannot find unsubsidized employment. BWEBusiness Work Experience placements are short-term, not to exceed three months, and are intended to allow a client to test jobs that are related to their occupational goals. The placement also provides clients with an opportunity to develop and improve workplace ethics, to establish relevant and transferable work skills, and to develop contacts and references in the business community.  Per the Fair Labor Standards Act (FLSA) clients cannot be required to participate in BWEBusiness Work Experience hours that are in excess of the amount of their ATAPAlaska Temporary Assistance Program benefit divided by the Alaska state minimum wage. See http://dpaweb.hss.state.ak.us/main/manual/cwe/WorkExperienceGuide.pdf for more details about the BWEBusiness Work Experience opportunity and required documentation. Additional information about work experiences is available in WSPM 1005.
3. Verification: The site supervisor must approve and sign an hour and attendance form for BWEBusiness Work Experience participants. The form will be submitted to the case manager every two weeks. Case managers will pursue the client's timesheet from the BWEBusiness Work Experience site if it has not been provided timely. Case managers also periodically contact the BWEBusiness Work Experience site supervisor to identify and address performance issues. This information is retained in the case file.

5. Community Work Experience (CWE)

1. Code - CW
2. Description: CWECommunity Work Experience participants acquire job skills, recent work experience, network with potential employers, and contribute valuable services to their communities.  Participants acquire knowledge, skills, and work ethics that employers find beneficial when seeking new employees.  Whenever possible the work assigned includes work duties that match the participant's vocation interests and enhance their skills and ability to find paid employment.  Placements can be established in non-profit organizations with 501 (c) (3) status such as religious, charitable, civic, cemetery, recreational, and educational organizations.  Placements can also be established at Federal, State, or local government agencies, including public school districts.  Court mandated community services may be countable under CWECommunity Work Experience.  Per the Fair Labor Standards Act (FLSA) clients cannot be required to participate in CWECommunity Work Experience hours that are in excess of the amount of their ATAPAlaska Temporary Assistance Program benefit divided by the Alaska state minimum wage. See http://dpaweb.hss.state.ak.us/main/manual/cwe/WorkExperienceGuide.pdf for more details about the CWECommunity Work Experience opportunity and required documentation. Additional information about work experiences is available in WSPM MS1005.
3. Verification: CWECommunity Work Experience sites will have a designated supervisor who signs an hour and attendance form which is submitted to the case manager every two weeks as verification of participation. Case managers will pursue the client's timesheet from the CWECommunity Work Experience site if it has not been provided timely. Case managers also periodically contact the CWECommunity Work Experience site supervisor to identify and address performance issues. This information is retained in the case file.  Individuals participating in AmeriCorps, VISTAVolunteers in Service to America, and MASSTMature Alaskans Seeking Skills Training programs will be coded as a CWECommunity Work Experience placement and must include both the CWECommunity Work Experience site and placement agreement. All rules related to CWECommunity Work Experience placements apply.

6. Subsistence

1. Code - C2
2. Description: Subsistence activities are defined as the non-commercial, customary, and traditional harvest of wild, renewable resources for use as food, shelter, fuel, clothing, tools, crafts, or transportation, and that contribute directly to the common good of the community and achieve a useful purpose. This is accomplished through the distribution of harvested resources throughout the community using traditional and customary social networks. Subsistence activities are considered work activities when paid employment or other community work experience placements are unavailable.
3. Verification: Subsistence activities must be verified by an agency or organization that oversees the performance and distribution of the subsistence harvest.

Note:

Subsistence work activities are intended to be an allowable work activity when they are done in partnership with a native Employment Works (NEW) grantee (there are active partnerships between ATAPAlaska Temporary Assistance Program and APIA [Aleutian Pribilof Island Association], Kawerak and MIC [Metlakatla Indian Community].)

7. Job Start

1. Code - WS
2. Description: Subsidized employment is employment in the private or public sector for which the employer receives a subsidy from ATAPAlaska Temporary Assistance Program or other public funds to offset some or all of the wages and costs of employing a recipient.
   
   The two types of subsidized employment countable in Alaska are:

• Work study programs where students are employed by and receive wages from a public or private educational institution.
• Job Start, the subsidized employment program operated by the Division of Public Assistance. This program uses the amount of an ATAPAlaska Temporary Assistance Program recipient's benefit to offset a portion of their wages. The Job Start program requires that participants in subsidized jobs are provided a minimum of 35 hours of work per week. Job Start positions typically last from three to six months. The position cannot last more than 12 months. Employers participating in the Job Start program are required to complete an initial work site agreement that stipulates the hours the client will be employed. This agreement is used to determine countable hours. Additional information about Job Starts is available in WSPM MS 1005.

3. Verification:  The documentation provided by the employer to determine the hours of unsubsidized employment is also used for verification purposes. New verification is required every six months and following any reported changes in hours of employment. Employer provided statements, including documented telephone contacts, will include the date of contact, start and/or end date of the job, participant's name, actual hours of work, name of the employer, and the name, position and phone number of the person verifying hours. The caseworker will document the information obtained from the employer in the case file.  

8. On-the-Job Training

1. Code - OJ
2. Description: OJTOn-the-Job Training is training in public or private sector employment that is given to a paid employee while the person is engaged in productive work and where the individual gains knowledge, skills, and abilities essential to the full and adequate performance of the job. The Division of Public Assistance OJTOn-the-Job Training program reimburses participating employers in an amount equal to 50% of the participating employee's wages for the costs of training the OJTOn-the-Job Training participant. The wages the participant receives in the OJTOn-the-Job Training position are used to calculated Temporary Assistance eligibility and benefits.

• Employers participating in the OJTOn-the-Job Training program are required to work with the client and case manager to develop an individualized training plan for the client. The plan is designed to provide the participant with knowledge, skills, and abilities.

3. Verification: The documentation provided by the employer to determine the hours of unsubsidized employment is also used for verification purposes. New verification is required every six months and following any reported changes in hours of employment. Employer provided statements, including documented telephone contacts, will include the date of contact, start and/or end date of the job, participant's name, actual hours of work, name of the employer, and the name, position and phone number of the person verifying hours. The caseworker will document the information obtained from the employer in the case file.  

9. Vocational Education

1. Code - VE
2. Description: Vocational education and training includes organized educational programs which are directly related to the preparation of individuals for employment in current or emerging occupations that require education and training necessary to ensure the success of participants. This activity may lead directly to certification or endorsement of specific skills, to an Associates of Applied Science (AAS) degree, or to a baccalaureate or advanced degree. Typically, this service is provided by vocational education and technical schools as well as educational institutions offering endorsements, certificates, or degrees for vocational education and training related to in-demand occupations. Vocational education and training may also be provided by grantees or contractors delivering curricula reviewed and approved by the state (see chart below).

When pursuit of Adult Basic Education, Adult GEDGeneral Education Diploma classes or remedial education and instruction in Vocational English as a Second Language (VESL) is required by a vocational education provider as part of the client's education plan, those activities provided by the educational institution are considered vocational education.

Distance delivered vocational education and training is only allowed when the training program includes mechanisms for providing reports that document progress and the time the student is accessing the online training program.

Clients can engage in vocational education activities for up to 12 cumulative months during the time on ATAPAlaska Temporary Assistance Program. After they have exhausted their 12 months of education time, VE activities will no longer count towards the client's participation hours. Sometimes it is in the client's best interest to continue educational activities even if they have exhausted their 12 month limit.

3. Verification:

• Classroom Participation: Actual hours of classroom instruction as well as lab work, unpaid intern or externships, supervised study sessions and other supervised secondary activities assigned as part of the job skills training program are considered countable. Participants submit to their case manager and attendance form that is completed by the instructor, study hall monitor, or activity supervisor.
• Unsupervised Study Sessions: Unsupervised study can only be counted in activity hours if the class or program requires students to do homework. The case manager documents program expectation of homework with a class syllabus or by collateral contact with school or instructor. If the class or program requires students to do homework then one hour of unsupervised homework for each hour of class time is countable. The total homework time counted for participation cannot exceed the hours of attendance required or advised by the education program. Clients provide a monthly homework log documenting their unsupervised study time which must be kept in the case file.

• Distance Delivered Education: Distance delivered programs are only allowed when the training program includes mechanisms for providing reports that document progress and the time the student is accessing the online training program. The client submits a monthly report from the educational provider that documents progress and the time the student is accessing the online training program.

10. Structured Work Search

1. Code - J3
2. Description: Structured work search includes participation in job clubs or case manager guided activities designed to orient participants to work search expectations and to provide support and guidance for job seekers. Individuals engaged in work search are required to register for work with the Department of Labor and to participate in employability assessments. These are vocational assessments and/or screenings for learning needs/disabilities, mental health, substance abuse, or domestic violence. Work search entails researching employment opportunities, preparation and submittal of applications, attending interviews, and interview follow-up with prospective employers. Case managers may assign a specific number of direct contacts with employers based on the local job market and the work experience, skills, and abilities of the participant.

Note:

If a 40 hour per week assignment to work search is not possible or appropriate, given the economic conditions and availability of work in the community, the case manager must assign alternate activities that are achievable considering the local circumstances.

3. Verification: Attendance records maintained by job club session facilitators serve to verify participation in the activity. Job search activities are verified through review of the job search log and interactive debriefing sessions with the participant's case manager. The case manager will make random checks of reported employer contacts if the information appears questionable. Case managers document this information in the case file along with the actual time necessary to debrief clients on job search experience and provide coaching and additional job leads.

Note:

Hours in which a self-employed individual is preparing to open their business may be countable. Individuals are required to maintain a log of activities related to preparation for self-employment. The log will note actual time on tasks and provide contact information for individuals or organizations (e.g., financial institutions, licensing, the Small Business Administration, etc.) the participation is working with to initiate the self-employment activities.

11. Vocational Counseling

1. Code: VC
2. Description: Activities in which an employment counselor helps participants understand themselves in relation to a vocational situation are considered Vocational Counseling. This may include time spent gathering documentation and applying for vocational education, skill and interest inventory assessments, aptitude tests, and exploration of career options.
3. Verification: Vocational counseling activities are verified through contacts with individuals and organizations identified on the participant's activity log. Hours may also be verified by written statements from contacts verifying the participants time spent on tasks. The information obtained is documented in the case file.

12. Substance Abuse, Domestic Violence Counseling, Mental Health and Medical

1. Codes: B1, B4, B5, and B6
2. Description: Screening for and/or treatment of a substance abuse (B1), domestic violence counseling (B4), mental health (B5) and medical issues (B6) may be countable. Clients selected for screening because of demonstrated challenges to self-sufficiency, and those who discloses issues, may be referred to a state approved licensed service provider for assessment. The assessment may result in referral to a state approved licensed treatment provider when warranted by the severity of the client's condition and the condition's impact on the person's employability.
3. Verification: Hours of participation in treatment programs, rehabilitation services, and employability assessments are verified through documentation from the provider licensed by the state to conduct assessments and provide treatment or therapy. This information is retained in the case file.

When a case manager determines or a client discloses that he or she has a specific barrier to employment, or the client persistently demonstrate an inability to meet self-sufficiency objectives and milestones necessary to prepare for employment, the case manager may refer for screening and/or assessment to an approved provider (e.g., licensed by the state to provide the service). When documentation from the provider is obtained showing that treatment is necessary, treatment hours are countable.

Hours of countable participation may only include:

• Hours in family assessment and evaluation; 
• Individual, group, and family therapy; and,
• Mental health/substance abuse case management.

Services for substance abuse, domestic violence, mental health and medical can only be counted as a Core Activity if the client has been screened by a licensed provider and treatment has been recommended. Treatment must be related to the client's ability to enter or increase other work activities. Hours outside of the established criteria will not count toward the participation rate and should be coded as "B3, Remediation of Other Barriers." 

1003-3 B.      WORK SUPPORT ACTIVITIES

Work Support activities promote and support rapid attachment to the workforce, job retention, and wage progression. These activities can be the primary activities for unemployed clients or can be assigned concurrently with work to ensure employed clients are looking for better jobs. Work support activities can ensure clients develop skills that lead to better jobs through advancement and retention. Work support activity hours count towards the federal performance rate only after the client has completed 20 hours per week of core work activities. Work support activities should be assigned on an FSSPFamily Self Sufficiency Plan in conjunction with core work activities, unless there is substantial, documented reason to assign work support activities alone.
 

1. Job Skills Training

1. Code - P3
2. Description: Job Skills Training may include post-secondary level education that is short-term and linked to a current or emerging occupation. It improves the knowledge, skills, and abilities and individual needs to obtain, retain, or advance in employment or to adapt to the changing demands of the workplace. Job skills training may address skill sets required by a specific employer or those that are recognized as general skills needed to be successful in a broad range of jobs or occupations. Basic Education and ESLEnglish as a Second Language may count as job skills training. Work activities which can be counted as Vocational Education (VE) also may be counted as Job Skills Training (P3) when the case manager determines that the training is directly linked to emerging or demand occupations.
3. Verification: Job skills activities are verified through contacts with individuals and organizations identified on the participant's activity log. Hours may also be verified by written statements from contacts verifying the participants time spent on tasks. The information obtained is documented in the case file.

2. English as a Second Language

1. Code - F3
2. Description: English as a Second Language encompasses education and instruction necessary to ensure participants can successfully pursue and gain employment and successfully retain jobs and advance in the workforce. It includes Adult Basic Education instruction in the skills of reading, writing, and mathematics necessary for a participant to be a productive employee, English as a Second Language, and Workplace Literacy.
3. Verification: English as a second language related activities are verified through contacts with individuals and organizations identified on the participant's activity log. Hours may also be verified by written statements from contacts verifying the participants time spent on tasks. The information obtained is documented in the case file.

3. Education Directly Related to Employment

1. Code - I1
2. Description: Education Directly related to Employment encompasses education and instruction necessary to ensure participants can successfully pursue and gain employment and successfully retain jobs and advance in the workforce. It includes Adult Basic Education instruction in the basic skills of reading, writing, and mathematics necessary for a participant to be productive employee, English as a Second Language, and Workplace Literacy.
3. Verification: Education directly related to employment activities are verified through contacts with individuals and organizations identified on the participant's activity log. Hours may also be verified by written statements from contacts verifying the participants time spent on tasks. The information obtained is documented in the case file.

4. GED Preparation and Adult Basic Education

1. Code - E6
2. Description: Adult ATAPAlaska Temporary Assistance Program recipients, who have not received a high school diploma or its equivalent, may also be assigned this activity if it includes regular attendance in a course of study provided by an approved education program that least to a general educational development (GED) examination diploma. Distance delivered education is only allowed when the training program includes mechanisms for providing reports that document both progress and the amount of time the student is accessing the online training program.
   
   Proctored testing and examinations, monitored study time, including documented time with tutors, are included as part of this activity. If the class or program requires students to do homework then one hour of unsupervised homework for each hour of class time is countable. The total homework time counted for participation cannot exceed the hours of attendance required or advised by the education program. Adult Basic Education and English as a Second Language (ESL) instruction are included as part of this activity if required as a prerequisite.

3. Verification:  GED preparation and Adult Basic Education activities are verified through contacts with individuals and organizations identified on the participant's activity log. Hours may also be verified by written statements from contacts verifying the participants time spent on tasks. The information obtained is documented in the case file.

5. GED Preparation, Minor and Teen Parent

1. Coded - E5
2. Description: This activity is primarily assigned to minor parents who have not completed high school or a course of study leading to a diploma through the state's general educational development (GED) examination. The Division defines a minor parent as an individual who is under the age of 18, not married and not emancipated. Teen Parents are 18 or 19 years old.
3. Verification: A minor parent is considered to be maintaining an adequate level of school attendance when:

• The individual is enrolled in and regularly attending a secondary school or appropriate training program.
• Attendance, as verified by an official of that school or program, is adequate to meet graduation or program certification requirements.While the actual hours of attendance must be entered into the Work Activity Screen in CMSCase Management System, the student must have a minimum of 4.33 hours (i.e. if the student is participating in high school education hours for 1 hour per week) coded to meet the monthly performance rate. 

Note:

Minor parents must maintain an adequate level of school attendance in a secondary school or other appropriate training program unless the minor parent:

- Has a high school diploma or a GEDGeneral Education Diploma;
- Has a dependent child under 13 weeks of age; or,
- Can show good cause for not attending school.

6. High School Completion

1. Code - HS
2. Description: This activity is primarily assigned to minor parents (ATAP MS 770-3) who have not completed high school or a course of study leading to a diploma through the state's general educational development (GED) examination. The Division defines a minor parent as an individual under the age of 18 years old who is neither married nor emancipated.
3. Verification: A minor parent is considered to be maintaining an adequate level of school attendance when:

• The individual is enrolled in and regularly attending a secondary school or appropriate training program.
• Attendance, as verified by an official of that school or program, is adequate to meet graduation or program certification requirements.
• While the actual hours of attendance must be entered into the Work Activity Screen in CMSCase Management System, the student must have a minimum of 4.33 hours (i.e. if the student is participating in high school education hours for 1 hour per week) coded to meet the monthly performance rate. 

Note:

Minor parents must maintain an adequate level of school attendance in a secondary school or other appropriate training program unless the minor parent:

- Has a high school diploma or a GEDGeneral Education Diploma;
- Has a dependent child under 13 weeks of age; or,
- Can show good cause for not attending school.

1003-3 C.      NON-COUNTABLE ACTIVITIES (FAMILY SUPPORT ACTIVITIES)

Family support activities specific impediments to employment or to job retention and advancement. These activities may also address other challenges to achieving self-sufficiency. Family support activities may be assigned concurrently with core and work readiness activities to address issues that may impede success in the workplace.

For clients temporarily excused from participating in core and work readiness activities, family support activities can engage the family in meaningful activities that promote self-sufficiency. These activities address meeting family needs to ensure that their transition to employment and self-sufficiency will be successful. The justification for the inclusion of non-countable activities on the FSSPFamily Self Sufficiency Plan must be clear.

While there are no verification standards for these activities, the hours entered in the Work Activity Screen must be well documented.

1. Remediation of Other Barriers

1. Code - B3
2. Description: Remediation of other barriers includes activities which address challenges to employment. Substance abuse, counseling, domestic violence counseling, mental health or physical health hours can be counted as B3 if the client has exhausted the allowable time for those activities or the client does not or cannot provide verification allowing those activities to be counted as a core activity. Activities may include addressing poor housing or homelessness, child care, transportation, child custody, and legal issues.

2. SSI / SSDI

1. Code - B7
2. Description: All clients who are currently applying for or appealing for SSISupplemental Security Income / SSDISocial Security Disability Insurance benefits should have SSISupplemental Security Income / SSDISocial Security Disability Insurance coded as an activity. Hours in which a client is gathering or submitting documentation for their social security application or appeal can be counted. The hours of participation recorded on the Work Activity screen will reflect actual hours of activity and may be zero if the client was not required to complete any tasks in the application or appeal process that month.

3. Post-Secondary Education

1. Code - P1
2. Description: College level education that is not included in the approved curriculum, is beyond the 12 month allowable timeframe or does not meet the verification requirements of Vocational Education work participation activities.

4. New Referral

1. Code - NR
2. Description: This code is designed to identify new clients and track the length of time between referral to an assigned WSPWork Services Provider and client engagement with their case manager in FSSPFamily Self Sufficiency Plan development. The start date should be the date that DPADivision of Public Assistance refers the client to their assigned case manager (or service provider agency). The code remains until the case manager enters an end date indicating that they have developed an FSSPFamily Self Sufficiency Plan with the client on that day. This code may only be used when the client is in the referral process.

5. Not Participating

1. Code - NP
2. Description: Clients who are not excused from participation (do not have good cause) and not engaging in assigned work activities are subject to penalty. The start date for this code should be the day the case manager determined the client was not participating. Case managers must follow policy and procedure to contact the client to determine good cause, evaluate the appropriateness of assigned activities, attempt to re-engage the client and penalize as appropriate, see ATAP MS 723-1 and ATAP MS 723.

6. Gap in Participation

1. Code - S2
2. Description: A gap in participation is an approved temporary break in work activity. Case notes and other supporting documentation should verify the client is excused from work activity. Approved temporary breaks (less than one month) may be documented in CLNOClient Notess. For breaks in excess of one month, the client should be exempt from work activity, and be appropriately coded as such, due to care for an infant, disabled child or relative, or medical incapacity, i.e., Health Status Report form (TA 10) on file, see ATAP MS 730-2.