Make use of assessment within an allowable activity as hours in that activity, before the participant engages more fully

in the activity.

 Assessment Comment: Several commenters recommended that the definition of various work activities include the assessment of participants skills. Response: Our work activity definitions permit assessment of an individual s suitability for a particular work activity.

Transmittal No. TANF-ACF-PI-2008-02 TANF-ACF-PI-2008Date: March 20. 2008 SUBJECT: Questions and Answers on the Final TANF Rule, Page 8: Assessment 1. Is there a timeframe for how long an assessment can last in any work activity? What is the documentation standard required to show that the assessment is related to the activity? Answer: No, there is no timeframe but the individual must be engaging in assessment activities, not simply waiting to be placed or assessed. A State should document hours in the same way it documents any other unpaid activity.

 2. If an assessment for the work activity for which she was scheduled to begin, finds that an individual is not suitable can the assessment period still count under the planned work activity? Answer: Yes.

 Employability Skills Training, or some other training, or even other parts of KeyTrain s career services curriculum, may form an assessment for work experience, community service, etc.

 Katie discovered yesterday that KeyTrain has a section called Career Clusters . It is basically lessons that help the learner explore different career fields such as Agriculture/Food, Government/Public Education, Marketing and Sales, etc. There are 16 of these career clusters. These lessons also contain quizzes similar to the career skills. You can get the same reports you can with the career skills.

 In addition to the Career Clusters in KeyTrain, you could use CareerScope as part of an assessment for work experience, community service, or subsidized employment. Or how about assessing career focus in preparation for job skills training or a vocational education program?

Suppose someone is considered for a clerical work experience: Microsoft Office online training done in the Service Center could form part of an assessment of suitability for this type of work experience.

 There are many assessment modules that could be developed from materials we have purchased or that are available for free online. They need to have a logical/reasonable connection to assessing suitability for the allowable activity.

 Caution: If assessing suitability for a paid work activity, such as subsidized employment, do not use the assessment hours as part of a projection calculation. Only actual employment can be projected.

 Q: How expansively or narrowly should we define suitability ? A: In the absence of a definition of suitability, we can define it fairly broadly.

 Q: Assessment is not one of the activities mentioned for Employability Skills Training in the state policy. Does that matter? A: No. The policy is not relevant to this question. Employers note that soft skills are a very important measure of new employees success in any job. Therefore, KeyTrain career services training modules may form an assessment for a number of work activities.

 Q: How should the timesheet be coded to reflect that it is assessment? A: There is no special coding of the timesheet needed. For example, an assessment for suitability for work experience, should code the timesheet as work experience.

 Q: How far would we dare stretch assessing a participant for multiple activities? A: Don t abuse it, but multiple assessments are allowed in federal regulation.

 Q: Could we start work experience assessment prior to cash opening so we could count it as a non-JS/JR core activity if FIP is nonopened retroactively? retroactively? A: Yes, that would be appropriate. If documented on a timesheet, it could be counted as job readiness or, in the case of retroactive FIP, could be used as work experience.

 Counties that are not already using timesheets (rather than job search sheets) for Job Club will want to do so to maximize the potential of assessment. assessment. Yes, it will create more documents, but it will also increase work participation. participation. Case managers will need to exercise care that more documents do not result in errors in MIS. MIS.

 Capture the maximum allowable hours for work experience and community service. Assign the maximum hours available for the activity. If the participant is assigned JS/JR, we could move hours from JS/JR to absence hours under the other activity, such as work experience or community service. This would save JS/JR hours and possibly increase countable core hours.

 TANF Final Rule, Page 6784:

we note that States can count short absences from various activities to participate in, for example, a job search activity under the excused absence policy.

 TANF Final Rule, Page 6811: States should report hours of excused absences as hours of participation in the activity from which the individual was excused. For example, if an individual were participating in a community service program but needed to be excused for two hours to go to a job interview, the State should report those excused hours as hours of community service, not as hours of job search and job readiness assistance.

Federal Interim Rules, page 37466 states: the individual must have been scheduled to participate in an allowable work activity for the period of the absence that the State reports as participation.

 For example: Some case managers do not assign the full hours of work experience allowable for a month, and therefore we often end up 1-3 hours short of the maximum hours 1(of the grant divided by minimum wage).

If properly assigned and documented, some hours of JS/JR could be moved to work experience as excused absence.

PI06PI06-34, change 9, states: In order to count an excused absence or holiday as actual hours of participation, the individual must have been scheduled to participate in the work activity for the period of absence that the MWA reports as participation time. So how can this assignment be documented to prove that it has been scheduled? scheduled?

 First, in assigning work experience, the case manager needs to assign all allowable hours. Second, the case manager must take control of scheduling in the following sense:
The case manager can make a note on the timesheet, and initial the note, that the hours were scheduled showing date and time they were scheduled. In addition, an excused absence form, with the elements required by policy, would round out the needed documentation. Next

 Remember, the hours excused from Remember, JS/JR must not be reported as JS/JR in MIS. This would accidently report an unallowable duplication of hours.

 It is always permissible to report fewer hours in MIS than you have documentation for, BUT it is never permissible to report more hours in MIS than you can prove with your documentation!

 Start using the activity titled Providing Child Care Services to an Individual Who is Participating in a Community Service Program (Activity 37)

 TANF Final Rule, Page 6795: In the final rule, we have clarified that this is an unpaid activity and must be a structured program designed to improve the employability of individuals who participate in it.

 TANF Final Rule, Page 6796: We have clarified in the final rule that this activity is both unpaid and structured to improve an individual s employability. The degree of supervision and methods for reporting hours would depend on how the State structures this activity.

 TANF Interim Final Rule, Page 37462: Training, Training, certification or mentoring will help make the activity meaningful and could be a first step toward the provider s employment in the child care field.

 In developing the state policy, DeLEG basically just copied from the federal regulations and therefore has left the possibilities wide open for the development of this activity.

 Since regulation allows training in child care for this activity to count as the activity, we could add a Child Care/Child Management Training component in the service center each week and count as this activity for core hours. Or, we could arrange with a community partner to provide child care related training off-site. off-

 In addition, the training would benefit the participant s family and improve the chances the participant will be successful in balancing work with home responsibilities.

 Kimberly provides this CAUTION: We can include child management training as part of this training, however, the focus must be on child care such as would take place in caring for other people s children. Although related and overlapping topics, they are not the same.

 We will develop or adopt a child care training curriculum. Until that is completed, we will begin to provide training in Job Club. You may involve community resources, as appropriate, or provide the training yourself. When finances allow, job club instructors may assist in delivery of this training.

 Q: What would be the minimum requirements to count as a structured program to improve employability ? A: There are no minimum requirements. But we do need to have program that is structured with intent to improve employability. employability.

 Kimberly worked with Head Start for many years and she has agreed to use some of her contacts to assist us in developing a program that is structured and which would give credibility to our program. Jenn has several years of experience in a child care center and will lead a workgroup to develop this program.

 Develop some activities off-site with offmost supervision through daily telephone or email contact plus occasional on-site visits. on-

 Kimberly cautions us to be very careful with what I am about to share. It involves situations where supervision is not physically present on a frequent basis. Although not prohibited, we need to be confident in our evaluation/assessment that the actual hours are authentic and the participant is progressing in a meaningful way.

 Therefore, situations which are questionable must be reviewed with your supervisor before implementation.

TANF Final Rule, page 6781: Daily supervision means that a responsible party has daily responsibility for oversight of the individual s participation, not necessarily daily, in-person contact with the participant. inThe goal of such supervision is to ensure that individuals are participating and making progress in their assigned activities.

 A work site sponsor, classroom instructor, contracted service provider, communitycommunity-based provider, job search instructor, treatment provider, or even a TANF agency employee could fulfill that role.

 In addition, the supervision need not involve in-person contact, but can be by telephone or inelectronic contact where those methods are suitable. suitable. Daily supervision as described above is a central part of the final rule. It ensures that individuals who participate in work activities make progress in their assigned activities.

Here is an example I discussed with Kimberly: A participant is working for a tax service, and must be present in the office during pre-set prehours. However, the participant is only paid for time when the participant is serving a customer or working on a customer s taxes. The participant is allowed by the employer to study tax law and do online job search when she has no customers to wait on.

Could the participant s be given credit for her online job search and tax study? Yes, it is possible.

 Q: How would this be documented? A: On a timesheet or timesheets.

 Q: In this example, could the supervisor at the tax service be accepted as the immediate supervisor for these hours with the case manager as the secondary supervisor? A: It would be best if both someone from the tax service and a case manager signed a timesheet, but both signatures would not be required.

 Q: How frequently would in-person, on-site inonsupervision by the secondary supervisor (case manager) need to be? A: It would depend a lot on the case manager s evaluation of the participant and situation. Although it would not be required, it would certainly be recommended that it be a minimum of biweekly.

 It has been suggested to Kimberly that paid work experience policy be simplified? Kimberly has agreed to look at this option for next fiscal year.

 For example: For participants who have used up their JS/JR hours, and are currently doing work experience, it would be helpful to use paid work experience [which is a form of subsidized employment] to make up the rest of their core hours.