WORKFORCE DEVELOPMENT BOARD
EMPLOYMENT AND TRAINING CONSORTIUM
WORKFORCE DEVELOPMENT BOARD
Carmen Pittenger
President
Tony Bosbous
Vice President
Dave Ramsay
Treasurer
Jeff Holt
Secretary
ADMINISTRATIVE BOARD
Nancy Morrison
Chair
Don McLean
Vice Chair
Gwen Worley
Executive Director
TO:
Potential Deliverers for Welfare Reform Programs
FROM:
Michigan Works! - E.U.P. Employment & Training Consortium
DATE:
July 19, 2013
RE:
Transmittal of the FY 2014 PATH Request for Proposal (RFP) Packet
for Eastern UP Welfare Reform Programs
PATH stands for “Partnership. Accountability. Training. Hope.” It is Michigan’s
Welfare Reform program designed to assist welfare recipients in meeting their
Federal participation requirements, making a transition to unsubsidized
employment, and eventually eliminating their dependence on public assistance.
Michigan Works! - E.U.P. Employment and Training Consortium is requesting
proposals for the delivery of the FY 2014 PATH Program, which begins October 1,
2013. In accordance with the Workforce Development Agency, State of Michigan,
deliverer selection procedures, the Consortium is hereby transmitting this packet to
organizations interested in submitting a proposal. An electronic copy is available
on the website at www.michworks-upnorth.org.
Proposals received at the Sault Ste. Marie Consortium office on or before
4:00 p.m. on August 22, 2013, will be considered. An Intent to Bid noticed must be
submitted by August 1, 2013. Organizations submitting a proposal shall be
notified of the exact meeting date, time, and location at which their proposal will be
reviewed.
In accordance with the Americans With Disabilities Act, the information contained
in the Request For Proposal will be made available in alternative format (large
type, audio tape, etc.) upon special request received by this office.
Organizations interested in submitting a proposal should note the following:
Funding Available for
Tri-County Area:
JET: $250,000*
Due Date and Time:
August 22, 2013
4:00 p.m.
Submittal Place:
Michigan Works!
1118 E. Easterday Avenue
Sault Ste. Marie, MI 49783
*Planning Allocation
1118 E. Easterday Avenue Sault Ste. Marie, Michigan 49783 (906) 635-1752 Fax # (906) 635-0115 TTY Relay 1-800-649-3777
www.michworks-upnorth.org miworks@eupworks.org
“An Equal Opportunity Employer / Program”
“Auxiliary Aids and Services Are Available to Individuals with Disabilities”
WELFARE REFORM PROGRAMS: PATH
Proposal Specification Packet
Part I.
GENERAL INFORMATION
A.
Purpose
The purpose of this packet is to present the requirements for
consideration of proposals to be contracted under the Michigan
Works! - Eastern Upper Peninsula Employment and Training
Consortium. PATH stands for Partnership. Accountability. Training.
Hope. The primary purpose of the PATH program is to assure that
applicants and recipients of public assistance in Chippewa, Luce
and Mackinac Counties perform their required hours of participation
in work-related activities as mandated by the federal Temporary
Assistance to Needy Families Act. The long-term goal is to assist
welfare recipients to obtain the services and training that will help
them achieve self-sufficiency. PATH is described in Policy
Issuance 12-14. Please note that this policy describes the program
for Fiscal Year 2013. The policy for Fiscal Year 2014 will be
provided to interested bidders when it becomes available. The
sources of funding for this program are derived from State and
Federal funds administered through the Workforce Development
Agency, State of Michigan.
If other AWelfare Reform@ programs are initiated by the State of
Michigan, and such programs have the same or similar target
populations, referral systems, and/or coordination mandates, the
Consortium will give first right of refusal to the selected contractor
for the period covered by the resulting contract, with additional
terms to be negotiated. It is expected that, to ensure effective
coordination, the Food Assistance Employment & Training (FAE&T)
program will also be administered by the PATH contractor. The
FAE&T program is generally funded at less than $20,000. It is
described in Policy Issuance 12-17.
B.
Administrative Entity
E.U.P. Employment & Training Consortium
1118 E. Easterday Avenue
Sault Ste. Marie, MI 49783
Telephone: (906) 635-1752
FAX:
(906) 635-0115
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C.
Contact Person
Gwen Worley, Executive Director
E.U.P. Employment & Training Consortium
1118 E. Easterday Avenue
Sault Ste. Marie, MI 49783
Telephone: (906) 635-1752
FAX:
(906) 635-0115
D.
Period of Performance
The contracts awarded pursuant to responses received from this
specification packet will be for Fiscal Year 2014, which runs from
October 1, 2013 through September 30, 2014, including applicable
post-program reporting.
The Consortium reserves the right to extend the awarded contract
through FY 2015 and FY 2016, pending continued PATH funding
and satisfactory performance in each preceding year.
E.
Technical Assistance to Proposers
Appropriate Consortium staff will be available to provide technical
assistance as required to develop responses to the RFP.
Organizations are, however, responsible for the content and for the
development of their own application. Persons preparing
responses to the RFP will be allowed access to all appropriate
regulations, Federal Management Circulars, published reports,
instruction letters, contracts and any other in-house data and other
related materials to aid in the development of their proposals.
Persons developing responses to this proposal are invited to utilize
these resources at their convenience at the main Consortium office
during regular office hours. Materials may not be removed from the
Consortium=s office. Copies may be provided at a cost of $.12 per
page.
F.
Proposals Submitted
In order to be considered for funding, proposals must be submitted
to Michigan Works!, 1118 E. Easterday Avenue, Sault Ste. Marie,
MI 49783.
ii
Because the proposal(s) will be evaluated on the basis of the
responses to all of the appropriate statements in the Proposal
Application Form, it is mandatory that the proposal be submitted in
the format of this package. In addition, the submitting agency may
be contacted by members of the Consortium staff or Workforce
Development Board to request amplification or clarification of the
information included in the proposal. This may include an on-site
visit to the requesting agency=s facilities, arranged in advance with
the proposer.
Proposal offerors should be aware that funding will be dependent
upon the continuing availability of PATH funds, contractor
performance and determinations of needs, services, activities and
delivery methods.
All proposals funded under this proposal will be funded under
authority granted by the Workforce Development Agency, State of
Michigan.
Proposals received after the date and time specified in the cover
memorandum will not be considered for funding. Proposals must
be complete, typewritten, technically accurate and in a sealed
envelope clearly marked "FY 2014 PATH Program” at the time of
submittal. Each proposal will be reviewed as submitted. After a
proposal is submitted, it may not be modified prior to review. The
cover memorandum, instructions and general proposal
stipulations are not to be submitted with the proposal. The
Proposal Cover Sheet on Page A-1 is the first page that has to be
returned.
If a proposal is selected for funding, the Consortium will negotiate
with the proposer to correct any technical deficiency prior to and as
a condition of contract award. A proposal may be withdrawn from
consideration for funding if the proposer transmits such a request in
writing to the Contact Person.
Three legible copies of the proposal must be submitted. Two
copies may be photocopies of an original; one copy must have
original signatures. Any differences between the original and the
copies are at the liability of the proposer.
Once submitted, proposals become the property of Michigan
Works! - E.U.P. Employment and Training Consortium. None will
be returned to the proposer.
iii
G.
Review Process
The contents of proposals submitted in response to this
specification packet will be disclosed to members of the Consortium
staff responsible for reviewing proposals, the Workforce
Development Board and the Consortium=s Administrative Board.
After selection of proposals for contract award, all proposals
become public information.
Proposals will be evaluated against other proposals. Proposals will
be reviewed and evaluated for cost effectiveness, responsiveness
to the specification packet, and potential program effectiveness.
H.
Review Criteria
The following areas will be assigned points, based on the
proposer=s written response to proposal criteria, as well as any
on-site findings and/or previous performance with similar programs.
1.
RFP Indicators (20 points)
The proposals will be evaluated on performance indicators
as follows:
a.
b.
c.
d.
e.
f.
2.
Federal required participation level
Entered employment rate
Wage at placement
Follow-up employment rate (90 day)
Cost per entered employment
Case closure due to income
Apparent Ability (20 points)
Consideration will be given to the bidder=s apparent ability
and/or experience to achieve proposed standards and the
reasonableness of the standards.
3.
Administrative (20 points)
Consideration will be given to (1) organization and staffing;
and (2) efficiency of administrative and fiscal procedures.
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4.
Cost Effectiveness (20 points)
The proposals will be evaluated on overall cost
effectiveness.
5.
On-site Monitoring (20 points)
All proposal offerors will be judged on the basis of on-site
findings. The on-site visit may examine such things as
adequacy of facility, accounting system, management
information system=s capability, and evidence of ability to
achieve desired outcomes.
I.
Contract Award
The award of any contract based on proposals received in
response to this specification packet is contingent upon the E.U.P.
Employment and Training Consortium receiving adequate funds for
the PATH Program from the Workforce Development Agency,
State of Michigan. The E.U.P. Employment & Training Consortium
reserves the right to award a contract without further negotiation of
proposal content or budget. Therefore, proposals must be
complete and technically correct at the time of submittal.
Issuance of this specification packet does not obligate the E.U.P.
Employment & Training Consortium to award a contract or to
procure a contract for services or supplies. The E.U.P.
Employment & Training Consortium reserves the right to reject any
and all proposals received in response to this specification packet.
Any cost incurred by the proposer prior to the commencement date
of a contract may not be paid from contract funds, and will not be
reimbursed by the E.U.P. Employment & Training Consortium.
Part II.
FUNDING
A.
Availability
The FY 2014 planning allocation for PATH for Chippewa, Luce and
Mackinac Counties has not been determined. It is, however,
expected to be approximately $250,000. Final allocations may be
increased or decreased by the Workforce Development Agency,
State of Michigan, depending on Michigan=s total PATH budget
and local formula factors.
v
Contractors will be expected to modify their programs to
accommodate funding changes upon written notification by
Michigan Works! - E.U.P. Employment and Training Consortium.
Contractors will be responsible for providing equitable levels of
service in each of the three counties, relative to the numbers of
referrals made by each county Department of Human Services
(DHS). Historically, Chippewa County referrals comprise
approximately 75 percent of the total; Luce County contributes
approximately 12 percent and Mackinac County is responsible for
approximately 13 percent of the referrals.
Historically, Chippewa County has referred approximately 480
welfare recipients, Luce County referred approximately 75, and
Mackinac County has referred about 85. The active case load
levels and numbers of new applicants will determine actual
referrals. For planning purposes, the bidder should expect
approximately 640 referrals. All referrals to PATH must be
served.
The provision of supportive services is dependent upon a thorough
assessment of the individual participant=s barriers and needs. No
participant is entitled to supportive services. Such services are
described in state policy and are to be used to assist the participant
toward reaching self-sufficiency.
B.
Liability
All programs and services to be operated under this RFP will be
funded through PATH in Chippewa, Luce and Mackinac Counties.
Agencies and organizations will be expected to participate in the
operation by contributing basic management and supervisory
services to the maximum extent feasible. Once a contract is issued
to a proposal bidder, that organization becomes fully responsible
for administration of the program activities and expenditures of
PATH funds according to the Federal Regulations, and other
policies or regulations established by the State of Michigan and
Department of Health and Human Services. No subcontracting is
allowed. Each organization will be liable for any disallowed or
illegal expenditure of funds or program operations conducted under
their contract. Disallowed or illegal costs will be subject to
repayment to the Consortium by the contractor. Reductions of the
budget level may be considered during the course of the contract if
and when a contractor fails to meet expenditure, participant and/or
outcome goals. Funding for all programs is contingent upon the
availability of PATH resources.
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C.
Accounting Records
Each contractor must maintain acceptable accounting records. An
adequate system of managing funds and for keeping back-up data
to support expenditures for later audit purposes is the full
responsibility of the contractor. No organization will be contracted
to deliver funded services or activities unless the organization or
agency can provide the Consortium with an acceptable accounting
manual, or a statement from a Certified Public Accountant (CPA)
that its accounting system meets generally accepted standards of
accounting, or has had its accounting system reviewed and
approved by the Consortium.
Additionally, contractors expending federal financial assistance of
$500,000 or more are to be audited in accordance with the
Standards of OMB A-133 as applicable.
Part III.
STIPULATIONS
A.
Indemnification/Assurances and Certifications
Organizations submitting proposals must be willing to sign a
contract which will provide a full indemnification and hold harmless
any liability of the Consortium or its governing bodies for any
activities conducted by the contract agency. Since the contract
format does not permit second-tier agreements, the contractor will
thus be solely responsible for activities and services performed
under the contract. This contract includes a full statement of
responsibility for reimbursing the Consortium for any costs or
expenditures which are disallowed in an audit, or for any other
claims which might be made against a program operator by a
PATH participant or other interested party.
B.
Equipment, Furniture and Materials
Organizations responding to the RFP are required to keep the
purchase of large items of capital equipment and materials to a
minimum. Michigan DCD Policy Issuance No. 05-03 provides
information on the proper method for charging such costs. If any
items or equipment, furniture, or materials which are designed to
last more than one year or which cost more than $500 per unit are
to be included in the grant, a specific list of all such items to be
purchased with PATH funds including the item, the make, the
model, and the unit cost must be included in the program
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application. Contractors who purchase non-expendable PATH
funded materials or equipment will be required to maintain a
separate inventory on such equipment. Items having a cost of less
than $500 will be considered expendable supplies and will be
classified as office supplies or other expendable items as
appropriate. The contractor will be responsible for these items, but
they need not be inventoried.
Any non-expendable items which are purchased outright with
PATH funds will remain the property of the Consortium and may
not be altered, moved or disposed of without advance written
permission from the Consortium. In all instances, purchase of nonexpendable property with a unit price of $500 or greater must have
prior written approval from Michigan Works! - E.U.P. Employment
and Training Consortium.
C.
Nondiscrimination and Equal Employment Opportunities
Proposal offerors who are awarded a contract shall not discriminate
against an employee, or applicant for employment, with respect to
hire, tenure, terms, conditions or privileges of employment, or a
matter directly or indirectly related to employment or participation
because of race, color, religion, national origin, age, sex, disability,
height, weight, marital status, political affiliation, beliefs or
citizenship.
Contractors will be required to post such information at their
location(s) and ensure that all employees or applicants are aware
of this information. In addition, contractors will be required to adopt
an Equal Opportunity Policy no less stringent than the one adopted
by the Consortium. Before contracts are executed, contractors will
be required to either provide their EEO policy statement or provide
evidence that their organization has officially adopted the
Consortium=s EEO policy statement.
D.
Supplemental Nepotism Clause
No member of the family of a person in an administrative capacity
shall be enrolled in the programs and activities of the E.U.P.
Employment and Training Consortium or its subcontractors. There
should not be even the slightest appearance of favoritism on the
part of board members or program administrators.
viii
The proposal offeror must assure that during the time period of the
proposed program no individuals who are members of the
immediate family of the governing board of the organization are
hired for PATH-funded staff positions. This clause holds for any
individual related to persons in an administrative capacity for the
Consortium, its Administrative Board and the Workforce
Development Board. Immediate family is defined as: wife,
husband, son, daughter, mother, father, brother, brother-in-law,
sister, sister-in-law, son-in-law, daughter-in-law, mother-in-law,
father-in-law, step-parent, step-child, grandparent, grandchild, aunt,
uncle, niece, and nephew.
E.
Prevention of Fraud and Program Abuse
To insure the integrity of PATH programs, special efforts are
necessary to prevent fraud and other program abuses. Fraud
includes deceitful practices and intentional misconduct, such as
willful misrepresentation in accounting for the use of program funds.
AAbuse@ is a general term which encompasses improper conduct
which may or may not be fraudulent in nature. While the PATH
laws and regulations are specific, possible problem areas could
include the following: conflict of interest, kickbacks, commingling of
funds, charging fees to participants or employers, nepotism, child
labor, political patronage, political activities, sectarian activities,
unionization and anti-unionization activities/work stoppages and
maintenance of effort. Proposals which are found to violate the
abuse standards will not be funded. Bidders who receive contracts
will be required to report immediately any violations in these areas
or in problem areas which may later be defined.
F.
Selection/Enrollment of Participants
Organizations operating a program, service or activity in this RFP
will be required to enroll DHS referrals. The responsibility for
maintaining documentation as to the eligibility for those participants
enrolled lies with the contractor. The enrollment of ineligible
participants, or the failure to quickly terminate ineligible participants
discovered at a later date, may result in disallowed costs which the
contractor must reimburse to the Consortium from non-PATH
funds.
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G.
Reporting
The organization approved to administer and deliver the PATH
program will be subject to an extensive set of reporting
requirements as developed by the Consortium. These reports will
be submitted as necessary to carry out the Consortium=s required
schedule of reporting to the State of Michigan and to carry out
monitoring and evaluation of programs as mandated by the PATH
program and its regulations.
H.
Monitoring
The Consortium will be monitoring, auditing and evaluating
Consortium programs and activities throughout the grant period.
The contractor must allow Consortium staff or its agent full access
to all files and records directly related to PATH funds, participant
case files, accounting files and records, and to any related files and
records associated with proper accounting of such funds and
participants.
I.
Cost Reimbursement Programs
PATH costs which are billed have to be allocated or prorated
among these cost categories: Administration, Direct Client
Services, Post-Employment Training, and Supportive Services. No
more than 8 percent of the grant may be used for Administration.
Supportive services must be reported in the following categories:
Auto Purchase, Auto-Related Expenses, Public Transportation, and
Other Supportive Services.
A detailed line item budget is required with this proposal. See Part
VIII.
Billings for reimbursement contracts will be honored upon receipt of
acceptable documentation for allowable line item expenses.
Part IV.
PROGRAM DESCRIPTION
PATH was designed to provide Family Independence Program (FIP)
applicants and recipients with employment-related services, training and
supportive services to obtain and retain employment. MWA contractors
are required to serve referred all FIP applicants and recipients.
x
In partnership between Michigan Works! and the Michigan Department of
Human Services, a blended approach will be used to help welfare
applicants/recipients become self-sufficient and permanently attached to
the labor force, based on the workforce needs of Michigan’s current
emerging economy. Contractors are expected to establish and maintain
a connection to the labor market for cash welfare recipients, while offering
educational and training opportunities to increase the participant=s
income, therefore, reducing or eliminating their family=s need for public
assistance. As this RFP is written, the primary goal for JET participants is
to assure that they are meeting the federally required hours of
participation in work-related activities. Contractors must ensure that work
participation requirements for one- and two-parent families on Temporary
Assistance to Needy Families (TANF) assistance are met.
The PATH program design differs from preceding welfare reform
programs in that it requires FIP applicants to engage in a 21-day Applicant
Eligibility Period (AEP) to demonstrate their commitment to program
objectives prior to their cash welfare case being opened. Referred
applicants will address barriers to employment and complete job-related
assignments as determined by the PATH case manager, who reports AEP
completion through the State’s automated management information
system. See Policy Issuance 12-20, Change 2.
All referrals to PATH will be electronically generated by the county
Department of Human Services. Individuals must report to an orientation
conducted by staff from the DHS. Referrals will be scheduled for a
mandatory program orientation. During the AEP, applicants will complete
a Family Automated Screening Tool (FAST), an Individual Service
Strategy (ISS). In addition, participants must complete a Family Self
Sufficiency Plan (FSSP) within 60 days of their case opening. The
contractor is responsible for assessing each JET participant and
developing an in accordance with Policy Issuance 06-10. The ISS must:
1.
Set forth an employment goal and a plan for achieving the required
hours of participation in work related activities and moving the
participant into unsubsidized employment;
2.
Set forth the obligations of the participant;
3.
To the greatest extent possible be designed to move the participant
into whatever unsubsidized employment the participant is capable
of handling as quickly as possible, and to increase the responsibility
and amount of work the participant is to handle over time;
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4.
Describe the services which will be provided to the participant so
that the participant will be able to obtain and keep unsubsidized
employment; and
5.
Include the assessment score from an approved test, i.e., WorkKeys®.
The required weekly hours of participation are up to 40 hours per week in
Michigan. For purposes of 90-day retention, the minimum required weekly
hours for each FIP family size depends on the number of parents in the
family:
a.
Single-parent family with a child under the age of 6 ...................... 20
b.
Single-parent family without a child under the age of 6 ................. 30
c.
Non-custodial parents ................................................................... 30
d.
Two-parent family not utilizing federally funded child day care ..... 35
e.
Two-parent family utilizing federally funded child day care ........... 55
The contractor must maintain documentation for the 20/30/35/55 hours of
work participation per week by each client as appropriate.
The State of Michigan, in attempting to construct a welfare reform program
model that incorporates federal regulations and state priorities, has laid
out several goals and objectives which are designed to eventually
decrease reliance on public assistance and increase self-sufficiency. The
following objectives are of high priority:
1.
Participants must meet required hours of participation in workrelated activities.
2.
Participants must obtain unsubsidized employment for up to 40
hours per week at minimum wage.
3.
Participants will retain employment for a minimum of 180 days.
4.
Participants will achieve case closure due to income.
Since one objective of PATH is unsubsidized employment, any activity in
which a participant is enrolled should be part of a plan that leads to
unsubsidized employment. Allowable activities are described in
WDASOM Policy Issuance 06-11, Change 8. Note the combinations of
core and non-core activities allowed, and the attendance documentation
xii
required. In conjunction with initially testing the job market, new referrals
will be enrolled in a structured job readiness training component to assist
them in understanding employer expectations and focusing on the positive
aspects of employment and job retention.
Ongoing case management services are required. PATH participant
cases receive follow-up at 180 days after employment, and not less than
once every 90 days thereafter, for the duration of the participant=s
enrollment in PATH. See Policy Issuance 12-10, Change 1.
Participants who are fulfilling their Family Independence Contracts may be
referred to training programs funded under the Workforce Investment Act
(WIA). If enrolled in WIA, they must continue to fulfill their obligations
under the PATH program.
Referrals to PATH are made electronically through the remote access
Michigan Works! Management Information System. Hardware and
software will be provided by Michigan Works! - E.U.P. Employment and
Training Consortium.
Referrals back to DHS will only be made if a) the individual continues to
disregard the obligations of his or her Family Independence Contract (i.e.,
misses two assignments, purposely sabotages job search efforts, etc.), or
b) after repeated efforts to secure employment are made, evidence is
presented which indicates that the person is not employable at this time.
In the second case, DHS may elect to provide intensive intervention or
assist the individual in applying for a more appropriate form of
maintenance income (social security disability or supplemental security
income, for example). Participants who are demonstrating a good faith
effort will not be referred back to DHS. Mandatory three-way meetings or
triages, between the PATH case manager, the DHS case manager and
the participant are triggered by three re-referrals to PATH.
Attendance in PATH activities must be documented. The contractor will
adhere to participation requirements described in Policy Issuance 06-11,
Change 8. Contractor staff may have to appear at DHS sanction
hearings, so attendance documentation is extremely important.
PATH services will be delivered from Michigan Works! service centers, or
in cooperation with the county DHS office. Providers of PATH services
will be partners in the delivery of workforce development activities through
the Michigan Works! system, and should be prepared to participate
accordingly.
xiii
The contractor is responsible for providing case management services to
all PATH participants. This includes client support such as assisting with
essential needs, providing direction, helping with any training processes
and general life skills counseling. Continued case management is to be
provided not less than once every 90 days after the 180 day follow-up, for
the duration of the participant’s enrollment in PATH and receipt of FIP
payments. Documentation is required.
All case closures due to income should be considered Extended Family
Independence Program (EFIP) cases upon the case closure due to
income notification. Refer to Policy Issuance 12-10, Change 1.
Supportive services are available to assist PATH participants in attending
approved activities, securing employment and covering initial employment
costs. DHS policies and limitations must be followed whenever supportive
services are provided. Supportive Services are described in Policy
Issuance 06-33 and changes. Locally established limits will be used. The
payment of any expenditure for supportive services requires prior
approval. Contractors should expect to issue same-day checks, if
necessary, or make arrangement with vendors for direct billing.
Costs for child care will remain with the Department of Human Services.
Specific instructions on the provision of PATH activities and services are
available from the Michigan Works! office in the form of Policy Issuances,
issued by the Workforce Development Agency, State of Michigan.
Part V.
References
PATH Policy Memorandums, issued by the Workforce Development
Agency, State of Michigan, currently:
99-22 and subsequent changes
99-41 and subsequent changes
99-47
00-28 and subsequent changes
00-29
02-06
02-36
03-38
Work First Documentation
Serving FIP Applicants
Drug Testing
Deferrals from Work First
Confidentiality
Financial Reporting
WtW Eligibility
Fiscal Reporting & Financial
Management
Monitoring & Cost Allocation
ISS
Allowable Activities
Supportive Services
05-03
06-10
06-11 and subsequent changes
06-33 and subsequent changes
xiv
09-05
09-30
11-37
12-10, Change 1
12-14
12-17
12-20, Change 2
12-29
Welfare Reform Management
Information Guide
Equal Opportunity Policy
Grievance Policy
Case Management
FY 2013 JET Planning
Instructions
FAE&T Program Policy
Guidelines
21-Day Application Eligibility
Period
Procurement
Services Manual Bulletins, issued by the Michigan Department of Human
Services
Eastern U.P. PATH/JET Grant Plans
PL. 104-193, Personal Responsibility and Work Opportunity Reconciliation Act
of 1996
P.A. 223 of 1995, Welfare (MCLA 400.57f), effective March 28, 1996
Family Support Act of 1988, PL.100-485, Titles II, III, IV, V and VI
Social Welfare Act 280, P.A. 1939, as amended (MCLA 400.55a and 400.56f)
Title IV-F of the Social Security Act (PL. 74-271), as amended
45 Code of Federal Regulations (CFR)
Michigan Administrative Code of Regulations (MACR) 400.3591 through
400.3596
Part V.
BASIC PROPOSAL CONTENT
A.
Format
Proposals must be submitted on the forms included in this packet.
Any additional pages must be typed on 8 2 inch by 11 inch white
paper. Pages should be numbered consecutively at the bottom
center of each page. A table of contents should be provided.
The only place the proposer=s name should appear is on the Cover
Sheet, unless specifically requested elsewhere. In the narrative,
please use Athis agency@ or Athis organization@. Proposal
evaluators will be able to judge proposals more objectively if they
are Ablind@ as to the submitting organization.
Narrative description should be specific to the point addressed.
When addressing a specific narrative topic, please provide a
heading identifying such. When submitting proposals, please use
the cover sheet followed by summary sheet (Attachments A & B);
xv
include additional attachments in order. Do not use a heavy text
cover or similar binding. Brochures or other presentations beyond
that sufficient to present a complete and effective proposal will not
be accepted.
B.
Information Not Available
In the event the Proposer is not able to provide information required
in the specification packet, the Proposer shall state so. Please
keep in mind that required information not provided within the
proposal will be viewed as a deficiency of the proposal; however,
this does not necessarily preclude the proposal from consideration
for funding.
Part VII.
WORK STATEMENT
Include as Section IV of the narrative, beginning your page numbering
with B-7.
A.
Assessment
Determine the types of services required by participants in order for
them to compete in the labor market. Indicate the number of
participants you intend to serve. Provide an assessment of the
current labor market and the jobs available for participants
transitioning from welfare to work.
B.
Program Goals
PATH is designed to establish and maintain a connection to the
labor market for individuals referred from the Michigan Department
of Human Services while offering education and training
opportunities and Job Search and Job Readiness (JS/JR activities
to increase the participant’s income, therefore reducing or
eliminating a family’s need for public assistance. Priority must be
placed on assuring that participants are meeting the federal
participation rates (hours per week) established as follows:
Single-parent family with a child under the age of six…………… 20
Single-parent family without a child under the age of six.............30
Two-parent family not using federally funded child day care....... 35
Two-parent family using federally funded child day care............. 55
xvi
Outcomes will be measured by the rate at which participants enter
employment, the cost per placement, the retention rate for those
placed in unsubsidized employment, and case closure rate due to
income.
C.
1.
What do you intend to accomplish by operating this
program?
2.
Specifically, what objectives will be addressed? Include life
skills as well as employability skills.
3.
If participants do not obtain employment, what will be done
to ensure that they comply with the terms of their Family
Independence Contract and required participation level?
4.
What methods will be used to promote Welfare Reform
programs to the business community? Explain your plans to
contact and visit employers in order to develop a rapport
between the program and the business community.
Work Plan
Develop a detailed description of the work to be done in the project.
These plans should minimally describe:
1.
2.
3.
4.
5.
6.
7.
8.
Services to be provided and activity to be accomplished
Schedule, location and action steps for accomplishing work
Results to be produced and time period for their
accomplishment
Work to be performed by individuals and units, including
assignment of responsibility
Administrative procedures to be followed
Monitoring arrangement, including frequency and check
points
Qualitative value that can be assigned to your project
Cost effectiveness value that can be assigned to your project
xvii
D.
Program Follow-Up
You will be responsible for conducting the required follow-ups on
each PATH participant, verifying employment and gathering
information of hours of work and wages earned. In addition to the
monthly reports which must be submitted, a final narrative report
will be required within 45 days of the end of the fiscal year. This
report should cover the strengths and weakness of the program
and include suggestions for improvement.
E.
Customer Satisfaction
Proposers shall submit a plan to assess the satisfaction level of the
participants enrolled in the program. An opportunity should be
available to participants to evaluate the various program
components, including the provision of supportive services.
Similarly, employers of PATH participants should be contacted for
feedback regarding the preparedness of their PATH employees to
succeed on the job. The information gathered is to be used
constructively for the continuous improvement of program design.
Explain how the private sector will be engaged in the delivery of the
program.
F.
Liability for Program Funds
The proposer will explain how their organization will assume the
financial liability for any disallowed or illegal expenditures
associated with the delivery of the PATH program.
Part VIII.
BUDGET
Complete the Proposed Program Delivery Budget (Attachment D).
Note that Michigan Works! - E.U.P. Employment and Training Consortium
will provide office space and utilities in each county, and that services are
expected to be delivered from these locations. Additionally, the hardware
and software required for the remote data entry system will be provided,
along with the dedicated phone line for transmission of PATH data.
Part IX.
OTHER REQUIREMENTS
A.
Complete the Certification Regarding Debarment, Suspension,
Ineligibility and Voluntary Exclusion (Attachment E).
B.
Complete the Certification Regarding Lobbying (Attachment F).
xix
Attachment A
Michigan Works! E.U.P. Employment and Training Consortium
PROPOSAL APPLICATION FORM
SECTION I: Proposal Cover Sheet
A.
General Agency Information (Information required in this section is in reference
to the agency submitting the proposal.)
Proposal submitted by:
B.
1.
Name of agency:
2.
3.
Address:
Name of contact person:
Title:
Phone:
Fax:
5.
Type of organization:
Private Non-Profit
Private for Profit
Other (Specify)
Government
School District
Certification
The certification statement below must be signed by an official authorized to bind
the offeror in a contract.
ACCEPTANCE OF THE CONDITIONS OF THE REQUEST FOR PROPOSAL
The
does hereby accept all
(name of agency submitting proposal)
the terms and conditions of the Request for Proposal and the subsequent format
enclosed therein, including the General Proposal Stipulations. The applicant also
certifies that the information in this application is correct to the best of its
knowledge and belief, that the organization is prepared to implement the project
as specified, and that the submission of this proposal has been fully authorized.
Signed:
Typed Name and Title:
Date of Signature:
A-1
C.
Organizational information
1.
Name & Title
List the name(s), title(s), addresses and phone numbers of all the owners,
members of the board of directors and other officers of the agency,
corporation or business.*
Address & Phone
* Indicate owners, members or officers who are present members of the E.U.P.
Workforce Development Board or the Administrative Board, with an asterisk (*).
Individuals who are known to be directly related to members of the Workforce
Development Board or the Administrative Board should also be noted.
2.
For corporations, attach a copy of a state charter.
A-2
PRE-BID NOTICE
ALL BIDDERS MUST COMPLETE THIS FORM AND RETURN IT TO THE E.U.P.
EMPLOYMENT AND TRAINING CONSORTIUM OFFICE BY MAIL OR FAX BY 4:00
P.M. ON AUGUST 1, 2013.
1.
Name of Agency:
Contact Person:
Phone:
2.
Do you intend to bid for PATH funds?
Yes
No
3.
Please list any potential conflicts of interest with members of the E.U.P.
Workforce Development Board and/or Administrative Board.
Workforce Development Board
Administrative Board
Jim Anderson
Mike Herbst
Kevin Ayotte
George Kinsella
Carol Barbacovi Muscoe
Don McLean
Carol Boger
Nancy Morrison
Andrea Bridgewater
Mary Lynn Swiderski
David Bulson
David Sudol
Ronn Farr
Tom Fornicola
Dave Goudreau
Andy Haapala
Jeff Hagan
Jeff Holt
Michelle LaJoie
Deb LaRue
Mike Mullin
Wayne Olsen
Brad Ormsbee
Patti Paris
Dave Ramsay
Susan Sliger
Chris Stabile
John Ufer
A-3
ATTACHMENT B
SECTION II: Proposal Summary
A.
Project Name:
B.
Total PATH Funds Requested:
C.
Geographic Area to be Served:
D.
Proposed Performance:
1.
Number of Participants to be Served:
2.
Percentage of Participants Meeting Federal
Work Requirement:
%
3.
Number of Participants to Terminate from Services:
4.
Number of Terminated Participants to Enter Employment:
Percentage Entering Employment:
5.
Average Cost per Participant:
6.
Average Cost per Entered Employment:
7.
Average Wage at Entered Employment:
8.
Follow-up (90 days) Employment Rate:
%
E.
Start Date:
End Date:
F.
Proposers who have had similar contracts in prior years shall report the
success of their projects using measurable criteria.
B-1
SECTION III: Narrative
A.
Provide a ONE PAGE SUMMARY of why your request should be funded and
what your PATH proposal is about. This summary should be written as if your
chief executive is explaining the program in PLAIN ENGLISH to Workforce
Development Board members, not Consortium staff. Please print in at least 12
point font.
B-2
B.
Integration
Provide a detailed description of all integration efforts.
B-3
D.
Management and Administrative Narrative
1.
Staffing - State the number and names of people currently employed in
regular full-time positions by the organization which will be charged
against the grant, or those performing work in-kind. Also, indicate by
county any additional staff that will be hired to implement the PATH
program.
2.
Conflict of Interest - Provide a statement certifying that no employee of
Michigan Works! - E.U.P. Employment & Training Consortium has
assisted in the development or preparation of this proposal. Moreover,
provide a statement certifying that the Proposer has not received any
information pertinent to any other organization's proposal for the FY 2014
PATH program.
B-4
3.
Past Performance - Describe your organization=s experience during the
previous three years in providing employment and training related
services. Be precise and specific, but include enough information for staff
and board members to determine the historic performance of the
organization.
4.
Compliance - Provide a statement certifying that there is no information
available to the Proposer showing noncompliance with programs
administered through the Workforce Development Agency, State of
Michigan or the Department of Human Services during the previous two
fiscal years; or if there is, include a copy of the follow-up corrections report
which corrected any deficiencies.
5.
Accounting Services
A.
Describe the capacity for your organization to issue same-day
payments for supportive services to PATH participants.
B.
Describe the capacity for your organization to submit monthly
expenditure reports by cost category in a timely manner.
B-5
C.
Has your agency been audited within the last three years?
Yes
No
If yes, include a copy of the most recent management letter and
audit opinion as an addendum.
Indicate what action has been taken in regard to the letters and
opinions.
D.
Indicate the agency=s experience over the last three years in
reference to the following items:
Yes
No
Grievance or complaints against the organization (not
including discrimination)
Lawsuits or judgments
Investigations for fraud, abuse, conflict of interest,
political activities, nepotism or any criminal activities
Default or breach of contract
Cancellation or non-renewal of contracts due to nonperformance or poor performance
Bankruptcy or receivership by this organization or a
parent organization
Discrimination complaints or rulings against the
agency
If yes was checked for one or more of the above, information must
be provided which indicates at a minimum:
a)
b)
c)
d)
e)
Date item checked was initiated
Party or parties involved with specific reference to
PATH,Work First, JET, JTPA, WIA or other Federal Funds
Brief description of the circumstances
Final disposition and date
A brief explanation if action is still pending
The information above must be included as an addendum and may be submitted as a
table if desired. Failure to include the above information or the omission of relevant
information may be grounds for not awarding a contract or canceling a contract if
awarded.
B-6
ATTACHMENT C
Certification of Signatory Authority
I,
, certify that I am the legal officer or
(Title)
. Possessing the authority of the organization
of
(Organization )
named herein to submit this document is derived from the following provisions (check
one):
Bylaws
Articles of Incorporation
Other (Explain):
I further certify that this document was duly authorized under such provision; and that
the person who signed this document on behalf of the organization had authority to sign
and submit it to Michigan Works! - E.U.P. Employment & Training Consortium on behalf
of the organization.
Signature
Typed Name
Title
Date
(Note: The signature provided above may not be the same as that provided on the
Proposal Cover Sheet--Attachment A.)
C-1
ATTACHMENT D
PROPOSED PROGRAM DELIVERY BUDGET
FOR PARTNERSHIP. ACCOUNTABILITY. TRAINING. HOPE. (PATH) PROGRAM
Completed budget items as they apply. Also complete the corresponding Budget
Backup sheets as they apply (Page D-2 through D-4 of this packet).
NAME OF ORGANIZATION
FUNDS REQUESTED
$
TOTAL DIRECT CLIENT SERVICES. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .$
1. Wages to be paid to staff
$
2. Fringe benefits for staff
$
3. Equipment used in
conjunction with training
$
4. Paper and desktop supplies
used in conjunction with
training
$
5. Participant training
$
6. Other (specify)
$
TOTAL TRAINING RELATED / SUPPORTIVE SERVICES COSTS . . . . . . . $
1. Auto Purchase
$
2. Public Transportation
$
3. Auto Related Expense
$
4. Other Support Services
$
TOTAL DIRECT ADMINISTRATIVE COSTS . . . . . . . . . . . . . . . . . . . . . . . . .$
1. Administrative wages
$
2. Administrative fringe
$
3. Equipment used in
conjunction with administration
$
4. Paper and desktop supplies
used in conjunction with
administration
$
5. Audit
$
6. Other (specify)
$
D-1
Backup for Line Item Budget
DIRECT CLIENT SERVICES
1.
Wages to be paid to staff
Percent of
Time to
Position
Salary
Per Week
Position Title
# of
Weeks
Total
a.
$
X
% X
=
b.
$
X
% X
=
c.
$
X
% X
=
d.
$
X
% X
=
e.
$
X
% X
=
TOTAL
$
2.
Fringe benefits for staff
Percent Rate
(If Applicable)
Benefit
Amount Rate
Applied To
Total
a.
F.I.C.A.
%
X
$
=
b.
Health Insurance
%
X
$
=
c.
Life Insurance
%
X
$
=
d.
Retirement
%
X
$
=
e.
Worker’s Compensation
%
X
$
=
f.
Unemployment
%
X
$
=
g.
%
X
$
=
h.
%
X
$
=
TOTAL
$
3.
Equipment (Lease/Purchase)
a. Lease
Units
Regular
Price/Month
# of
Months
Total
$
=
$
$
=
$
$
=
$
$
=
$
TOTAL
$
D-2
b. Purchase
Regular
Price
Units
Total
$
$
$
$
$
$
TOTAL
$
4.
Supplies
Description
Cost Per
Month
# of
Months
Total
$
$
$
$
$
$
$
$
TOTAL
$
5.
Participant Training
# of
Months
Description
Cost/Month
Total
OJT
$
$
Work Experience
$
$
Job Skills Training
$
$
Other
$
$
TOTAL
$
6.
Other
Description
Month
# of
Months
Total
$
$
$
$
$
$
$
$
TOTAL
$
D-3
SUPPORTIVE SERVICES
Supportive Services
Description
Total
a.
Auto Purchase
$
b.
Public Transportation
$
c.
Auto Related Expenses
$
d.
Other
$
TOTAL
$
D-4
ATTACHMENT E
_________________________________________________________________
Certification Regarding
Debarment, Suspension, Ineligibility and Voluntary Exclusion
Lower Tier Covered Transactions
_________________________________________________________________
This certification is required by the regulations implementing Executive Order
12549, Debarment and Suspension, 29 CFR Part 98, Section 98.510, Participants'
responsibilities. The regulations were published as Part VII of the May 26, 1988
Federal Register (pages 19160-19211).
(BEFORE COMPLETING CERTIFICATION, READ ATTACHED INSTRUCTIONS
WHICH ARE AN INTEGRAL PART OF THE CERTIFICATION)
(1)
The prospective recipient of Federal assistance funds certifies, by submission of
this proposal, that neither it nor its principals are presently debarred, suspended,
proposed for debarment, declared ineligible, or voluntarily excluded from
participation in this transaction by any Federal department or agency.
(2)
Where the prospective recipient of Federal assistance funds is unable to certify
to any of the statements in this certification, such prospective participant shall
attach an explanation to this proposal.
Name and Title of Authorized Representative
Signature
Date
E-1
Instructions for Certification
1.
By signing and submitting this proposal, the prospective recipient of Federal
assistance funds is providing the certification as set out below.
2.
The certification in this clause is a material representation of fact upon which
reliance was placed when this transaction was entered into. If it is later
determined that the prospective recipient of Federal assistance funds knowingly
rendered an erroneous certification, in addition to other remedies available to the
Federal Government, the Department of Labor (DOL) may pursue available
remedies, including suspension and/or debarment.
3.
The prospective recipient of Federal assistance funds shall provide immediate
written notice to the person to which this proposal is submitted if at any time the
prospective recipient of Federal assistance funds learns that its certification was
erroneous when submitted or has become erroneous by reason of charged
circumstances.
4.
The terms "covered transaction," "debarred," "suspended," "ineligible," "lower tier
covered transaction," "participant," "person," "primary covered transaction,"
"principal," "proposal" and "voluntary excluded," as used in this clause, have the
meanings set out in the Definitions and Coverage sections of rules implementing
Executive Order 12549. You may contact the person to which this proposal is
submitted for assistance in obtaining a copy of those regulations.
5.
The prospective recipient of Federal assistance funds agrees by submitting this
proposal that, should the proposed covered transaction be entered into, it shall
not knowingly enter into any lower tier covered transaction with a person who is
debarred, suspended, declared ineligible, or voluntarily excluded from
participation in this covered transaction, unless authorized by the DOL.
6.
The prospective recipient of Federal assistance funds further agrees by
submitting this proposal that it will include the clause titled "Certification
Regarding Debarment, Suspension, Ineligibility and Voluntary Exclusion - Lower
Tier Covered Transactions," without modification, in all lower tier covered
transactions and in all solicitations for lower tier covered transactions.
7.
A participant in a covered transaction may rely upon a certification of a
prospective participant in a lower tier covered transaction that it is not debarred,
suspended, ineligible, or voluntarily excluded from the covered transaction,
unless it knows that the certification is erroneous. A participant may decide the
method and frequency by which it determines the eligibility of its principals. Each
participant may but is not required to check the List of Parties Excluded from
Procurement or Nonprocurement Programs.
E-2
8.
Nothing contained in the foregoing shall be construed to require establishment of
a system of records in order to render in good faith the certification required by
this clause. The knowledge and information of a participant is not required to
exceed that which is normally possessed by a prudent person in the ordinary
course of business dealings.
9.
Except for transactions authorized under paragraph 5 of these instructions, if a
participant in a covered transaction knowingly enters into a lower tier covered
transaction with a person who is suspended, debarred, ineligible, or voluntary
excluded from participation in this transaction, in addition to other remedies
available to the Federal Government, the DOL may pursue available remedies,
including suspension and/or debarment.
E-3
ATTACHMENT F
CERTIFICATION REGARDING LOBBYING
CERTIFICATION FOR CONTRACTS, GRANTS, LOANS,
AND COOPERATIVE AGREEMENTS
The undersigned certifies, to the best of his or her knowledge and belief, that:
(1)
No federal appropriated funds have been paid or will be paid, by or on behalf of the
undersigned, to any person for influencing or attempting to influence an officer or
employee of an agency, a member of Congress, an officer or employee of Congress,
or an employee of a member of Congress in connection with the awarding of any
federal contract, the making of any federal grant, the making of any federal loan, the
entering into of any cooperative agreement, and the extension, continuation,
renewal, amendment, or modification of any federal contract, grant, loan, or
cooperative agreement.
(2)
If any funds other than federal appropriated funds have been paid or will be paid to
any person for influencing or attempting to influence an officer or employee of any
agency, a member of Congress, an officer or employee of Congress, or an employee
of a member of Congress in connection with this federal contract, grant, loan, or
cooperative agreement, the undersigned shall complete and submit Standard FormLLL, "Disclosure Form to Report Lobbying," in accordance with its instructions.
(3)
The undersigned shall require that the language of this certification be included in
the award documents for all subawards at all tiers (including subcontracts, subgrants
and contracts under grants, loans, and cooperative agreements) and that all
subrecipients shall certify and disclose accordingly.
This certification is a material representative of fact upon which reliance was placed when
this transaction was made or entered into. Submission of this certification is a prerequisite
for making or entering into this transaction imposed by Section 1352, Title 31, U.S. Code.
Any person who fails to file the required certification shall be subject to a civil penalty of not
less than $10,000 and not more than $100,000 for each such failure.
Grantee/Contractor Organization
Program/Title
Name of Certifying Official
Signature
Date
F-1
ATTACHMENT G
COST OR PRICE ANALYSIS
Pursuant to federal regulations regarding procurement and cost/price analysis, when a
cost analysis is necessary and there is inadequate price competition, the offeror shall
certify that to the best of its knowledge and belief, the cost data are accurate, complete,
and current at the time of agreement on price. Awards or modifications negotiated in
reliance on such data should provide the awarding agency a right to a price adjustment
to exclude any significant sum by which the price was increased because the awardee
had knowingly submitted data that were not accurate, complete or current as certified.
The undersigned certifies, to the best of his or her knowledge and belief, that the cost
data submitted in this proposal are accurate, complete and current at the time of
submission.
Name of Agency Submitting Proposal
Name of Certifying Official
Signature
Date
G-1
POLICY ISSUANCES
OFFICIAL
Emailed 09/08/06 (kb)
Bureau of Workforce Programs (BWP)
Policy Issuance (PI): 06-10
Date:
September 8, 2006
To:
Michigan Works! Agency (MWA) Directors and Field Services Regional
Managers
From:
Brenda C. Njiwaji, Director, Bureau of Workforce Programs (SIGNED)
Subject:
Individual Service Strategies (ISS)
Programs
Affected:
References:
All Programs funded through the Michigan Department of Labor & Economic
Growth’s (DLEG) BWP, excluding Wagner-Peyser 7(a), 7(b) and Trade
Adjustment Act of 1974, as amended
Personal Responsibility and Work Opportunity Reconciliation Act of 1996
Section 408(b)(1) and Section 408(b)(2)
Reauthorization of the Temporary Assistance for Needy Families Program,
Interim Final Rule, 45 CFR Part 261, et al.
Workforce Investment Act (WIA) of 1998, Sections 129(c)(1)(A)(B), and Section
134(d)(3)(C)
WIA of 1998, Title I, Part 664 (Youth Activities)
WIA, Final Rules 20CFR, Part 652, et al.
WIA Participant Management Information Guide
The Jobs for Veterans Act, PL 107-288
Rescissions: Office of Workforce Development PI 01-31, issued August 6, 2001
Background: BWP regulations require the preparation of an ISS for all affected programs
administered through the bureau. This PI introduces the requirement of an
electronic ISS to be completed for all affected program participants on the OneStop Management Information System (OSMIS).
Policy:
In consultation with a participant, the MWA must develop an ISS. It is
recommended the consultations be held in-person with the participant, however,
they may take place over the telephone or use other alternative communication
methods. The ISS must be completed within 30 days following enrollment into a
DLEG/BWP administered program. If the participant is a veteran, the
DLEG/BWP Field Services Division Local Veteran’s Employment
Representative (LVER) or Disabled Veteran’s Outreach Worker (DVOW) should
also be consulted. LVERs and DVOWs are required to develop and/or maintain
an ISS for veteran job seekers identified as receiving case management.
The ISS is now required to be completed electronically for all participants in nonexcluded programs and be maintained on the OSMIS. Please note participants of
excluded programs do not require an ISS unless dually enrolled in a non-excluded
program. All new participant files/documents should be on the OSMIS by April 1,
2007. The MWA offices will have until October 1, 2007, to convert all active
and/or existing ISS files/documents to an electronic version. There is no
requirement to maintain a hard copy formatted ISS in a participant file. However,
if a hardcopy is maintained, it is recommended the ISS contain signatures of both a
service center staff member (e.g., caseworker) and the participant. The ISS must
be continuously updated via electronic case notes reflecting all changes in services
received and records/documents kept. Additionally, the OSMIS must accurately
reflect when participants meet goals and objectives of the plan(s) or as changes
occur to stated goals and objectives. In addition, the procedures/techniques that
have been in place to complete an ISS will not change. However, the ISS must
now be completed electronically and maintained on the OSMIS.
The ISS sets forth a mutually developed plan between a participant and the
caseworker. The purpose of the ISS is to address barriers and assist the
participant in achieving employment/training goals. This will verify a participant
is aware of and understands the details of the mutually developed ISS. Final
approval of the ISS rests with the MWA worker. An acknowledgement copy of
the ISS must be provided to the participant.
Action:
MWA officials shall take the appropriate actions necessary to implement the
directives of this PI.
Inquiries:
Questions regarding this PI should be directed to Ms. Dell Alston at
(517) 241-4224.
The information contained in this PI will be made available in alternative format
(large type, audio tape, etc.) upon request to this office.
OFFICIAL
E-mailed: 02/01/13 (pv)
Workforce Development Agency, State of Michigan (WDASOM)
Policy Issuance (PI): 06-11, Change 8
Date:
February 1, 2013
To:
Michigan Works! Agency (MWA) Directors
From:
Gary Clark, Director, Office of Talent Development Services
SIGNED
Subject:
Allowable Activities in Meeting Work Participation Requirements
Programs
Affected:
Partnership. Accountability. Training. Hope. (PATH) [Formerly the Jobs,
Education and Training (JET) Program]
Rescissions: PI 06-11, Change 7 issued on July 5, 2011, and all previous versions of this policy
issuance.
References:
Reauthorization of the Temporary Assistance for Needy Families (TANF)
Program; Final Rule: 45 CFR Parts 261, et al., Federal Register, Volume 73,
Number 24, February 5, 2008
Reauthorization of the TANF Program; Interim Final Rule: 45 CFR Parts 261, et
al., Federal Register, Volume 71, Number 125, June 29, 2006
TANF Program; Final Rule: 45 CFR Part 260 et al., Federal Register, Volume
64, Number 69, April 12, 1999
Workforce Investment Act (WIA) of 1998: 20 CFR 652 et al., Final Regulations,
Subpart B, Section 663.700-663.710
Section 403(b)(5) of the Social Security Act
Social Security Act, 407(c)(2)(C)
State of Michigan Work Verification Plan, effective August 1, 2012
Background: This policy change is being issued to update the federal minimum required hours’
table to include a subset of the two-parent family type and corresponding required
hours. It also spells out the change to how MWAs will determine the maximum
hours of participation allowed in unpaid work activities. In addition, the
requirement to assign minor parents, without a high school diploma or General
Equivalency Degree (GED), to Satisfactory Attendance at Secondary School or in
a Course of Study Leading to a Certificate of General Equivalence has been
removed.
Policy:
PATH is designed to establish and maintain a connection to the labor market for
individuals referred from the Michigan Department of Human Services (DHS)
while offering educational and training opportunities and Job Search and Job
Readiness (JS/JR) activities to increase the participant’s income, therefore,
reducing or eliminating a family’s need for public assistance.
This policy defines the State of Michigan’s PATH allowable work participation
activities in accordance with federal regulations. These regulations are stipulated
in the (Reauthorization of the TANF) Program; Final Rule, dated February 5,
2008, with the effective date of October 1, 2008.
As recipients of federal funds, MWAs and their service providers are required to
comply with various regulations relating to non-discrimination, equal opportunity
(EO), and inclusion. The most critical of these regulations are:

Implementation of the Non-discrimination and EO Provisions of the WIA
of 1998

Section 504 of the Rehabilitation Act of 1998, as amended

Titles I and II of the Americans With Disabilities Act (ADA)

The ADA Accessibility Guidelines or the Uniform Federal Accessibility
Standards
In addition, priority will be given to assuring that throughout the system persons
with physical, mental, cognitive, and sensory disabilities will have programmatic
and physical access to all Michigan Works! Service Centers’ services and
activities. The commitment to adequately serving persons with disabilities
extends beyond the specialized services of vocational rehabilitation. To ensure a
universally accessible and inclusive system, each local service area is encouraged
to embrace the overall philosophy of Michigan’s One-Stop Inclusion Workgroup
Final Report.
For all activities, a reasonable workplace/training environment must be provided
and must comply with applicable health and safety standards. All work/training
placements must be non-discriminatory in nature and provide EO for all
participants.
The primary focus of PATH is to assist participants with reducing their
dependence on public assistance and movement toward increased self-sufficiency.
This is to be accomplished through participation in core and non-core activities as
outlined in this policy issuance and in Michigan’s Work Verification Plan. Lifeskills instruction, training or education, and other work-readiness activities that
promote employability skills may also be utilized. Although it is the
expectation that MWAs place a majority of participants into activities that
comply with meeting federal work participation requirements, MWAs have
the flexibility to place a limited number of eligible participants into extended
education/training activities. Such placements should lead to the elimination
of dependency on public assistance.
Participation in the subsequently described activities can begin upon an
individual’s referral to an MWA.
The DHS establishes the minimum required hours of participation for each
individual upon referral to the MWA based upon appropriately corresponding
federal and state criteria. The federal minimum required average weekly hours
for each family size are as follows:
Single-parent family with a child under the age of six ........................20
Single-parent family without a child under the age of six ...................30
Two-parent family not using federally funded child day care .............35
Two-parent family using federally funded child day care ...................55
MWAs must have single parent families (with or without a child under the age of
six) complete 20 hours of participation each week in at least one of the eight “core
activities” described in this policy to be counted as meeting federal participation
requirements. For two-parent families not receiving federally funded child day
care assistance, a total of 30 hours per week of the required 35 hours per week
must be spent participating in core activities. For two-parent families that are
receiving federally funded child day care assistance, a total of 50 hours per week
of the required 55 hours per week must be spent participating in core activities.
Any remaining hours of weekly participation requirements may be met through
participation in “non-core activities” or core activities.
Family Type
Single-parent with a
child under six
Single-parent w/o a
child under six
Two-parents w/o
federally funded child
day care
Two-parents with
federally funded child
day care
Minimum
Average Hours
Required/Week
Average Core
Hours
Required/Week
Remaining Avg Hours
Required/Week
(Core & Non-Core)
20
20
none
30
20
10
35
30
5
55
50
5
Please note that there are two-parent families in which one parent is a
Supplemental Security Income (SSI) recipient and the other parent is referred to
MWA with a single-parent family status. The DHS has clarified that the referred
parent has 30 required average weekly hours of participation no matter the age of
the youngest child in the home. The hours are broken down as follows:
Family Type
Single-parent who
is part of a twoparent family where
one parent is
receiving SSI
Minimum
Average Hours
Required/Week
Average Core
Hours
Required/Week
Remaining Avg Hours
Required/Week
(Core & Non-Core)
30
20
10
MWAs have the flexibility to require hours of participation beyond federal
minimum requirements when appropriate. Ultimately, however, MWAs must
focus on ensuring that as many participants as possible are meeting federal
participation requirements, in order for Michigan to meet the overall participation
rate required to avoid significant federal fiscal penalties. To assist with meeting
federal work participation requirements, the WDASOM suggests the MWA
require five additional hours per week.
Actual hours of participation are averaged over the course of a reporting month to
determine participation rates. For example, in a four week month, a participant
with a 20 hours per week participation requirement who completes 30 hours of
core activities per week for two of the weeks and 10 core hours per week for the
remaining two weeks (an average of 20 core hours per week) will be considered
to have met their federal participation requirement for that reporting month. Also,
in a four week month, a participant with a 30 hour per week participation
requirement may complete 40 hours of non-core activities in one week and 80
hours of core activities spread out over the other three weeks to meet federal
participation requirements.
The beginning and ending dates for each reporting month may be found in the
One-Stop Management Information System (OSMIS), in the “Participation Hours
Calendar.” This calendar may be accessed through the “Update/View Participant
Activities” page, the “Enter Actual Hours” page, or the “Actual Hours Status”
page.
The guidelines established in this policy issuance are to be used to ensure that
work participation requirements are being met in accordance with federal and
state standards.
Allowable Activities
PATH uses the definitions and guidelines for the allowable activities as outlined
in the Reauthorization of the TANF Program; Final Rule, and subsequently
described in Michigan’s Work Verification Plan. The allowable activities are
identified and defined following the guidelines listed below.
Appropriate assessments and evaluation must be developed and conducted in
conjunction with the DHS. Participation in basic skills education may only be
counted under the following allowable activities: Job Skills Training Directly
Related to Employment (non-core); Education Directly Related to Employment
(non-core); or Vocational Educational Training (VET) (core). Please note that
basic skills education may only be counted as VET if the basic skills education is
embedded as a minor element of the VET Program and is deemed to be necessary
by the educational institution, which must provide supporting documentation for
its need. Participants in basic skills education programs must meet the required
minimum number of hours in core activities to meet participation requirements.
Case management procedures including entry of actual hours of
participation into the OSMIS, documentation requirements for
substantiating actual hours recorded, and guidelines regarding excused
absences and holidays may be found in WDASOM PI 12-10, and its
subsequent changes.
The allowable activities are as follows:
Paid Work Activities
Unsubsidized Employment is a Core Activity. This means full or parttime employment in the public or private sector that is not supported by
TANF, state General Fund/General Purpose (GF/GP) funds, or any other
public program. Participation in unsubsidized employment is the
fundamental goal for all PATH participants to prepare for self-sufficiency
and public assistance case closure.
Self-employment may count as unsubsidized employment. Selfemployment may include, but is not limited to, domestic work and the
provision of childcare. The following formula must be used to determine
self-employment hours.
Monthly net business sales (gross revenues minus expenses) divided
by the federal minimum wage = total actual hours per month.
Hours of participation in barrier removal or other supportive activities, such
as substance abuse treatment, mental health treatment, and rehabilitation
activities may count as unsubsidized employment if the activities are an
integrated part of the unsubsidized employment and if the participant is paid
for all hours of participation in such activities.
Guidelines used for determining allowable self-employment activities and
allowable self-employment expenses must be consistent with the countable
self-employment income guidelines used by the DHS in determining TANF
eligibility. These guidelines can be found in DHS Bridges Eligibility
Manual 502 at http://www.mfia.state.mi.us/olmweb/ex/bem/502.pdf.
Subsidized Private and Public Sector Employment is a Core Activity.
This is employment for which the employer receives a subsidy from TANF,
GF/GP, or other funds to offset some or all of the wages and costs of
employing a participant. Work-study programs sponsored by educational
institutions may be included in this activity.
While there is no time limit to this activity, it is to be used only on a limited
basis. Subsidized private or public sector employment may be arranged
directly through the employer or through a placement agency. This activity
allows an employer the opportunity to observe how the participant functions
in a work environment. Participants must be supervised on an ongoing
basis, no less frequently than once each day in which the individual is
scheduled to participate.
While a participant is enrolled in this activity, the MWA must provide the
necessary supportive services to ensure that the participant is able to
successfully complete the probationary period.
Hours of participation in barrier removal or other supportive activities, such
as substance abuse treatment, mental health treatment, and rehabilitation
activities may count as subsidized employment if the activities are an
integrated part of the subsidized employment and if the participant is paid
for all hours of participation in such activities.
If the DHS closes the participant’s Family Independence Program (FIP)
case, and the placement of the participant into this activity was the result of
efforts made by the MWA, the participant may remain in this activity for the
remaining balance of their subsidized employment agreement.
On-the-Job Training (OJT) is a Core Activity. This activity consists of
training in the public or private sector that is given to a paid employee while
he or she is engaged in productive work. The training should provide the
knowledge and skills essential to the full and adequate performance of the
job. Any paid training, whether provided off-site or at the work-site may be
considered an OJT.
Participants receiving OJT will normally have contractual training periods.
An OJT contract must be limited to the period of time required for a
participant to become proficient in the occupation for which the training is
being provided. In determining the appropriate length of the contract,
consideration should be given to the skill requirements of the occupation,
the academic and occupational skill level of the participant, prior work
experience, and the participant’s individual employment plan.
Reimbursement of training costs may be provided to the employer from
external funding sources, which may cover up to 50 percent of a
participant’s salary. All participants must be supervised by an employer,
work site sponsor, or other responsible party no less frequently than once
each day in which the individual is scheduled to participate.
Payment may continue to be paid to the employer until the OJT contract
expires or is terminated by any party, even if the FIP case closes. The OJT
standards under Subpart B, Section 663.700 through 663.710 of the Federal
WIA Regulations will apply for all PATH participants.
Job Search and Job Readiness (JS/JR) Assistance
JS/JR is a Core Activity. This activity consists of the act of seeking or
obtaining employment; preparation to seek or obtain employment, including
life skills training; and substance abuse treatment, mental health treatment,
or rehabilitation activities. JS/JR activities must be supervised by the MWA
or another representative on an ongoing basis at least once each day in
which the individual is scheduled to participate.
The Job Search aspect means “the act of seeking or obtaining employment,”
which should encompass all reasonable job search initiatives. Job searching
includes making contact with potential employers by telephone, in person,
via the Internet, submitting resumes or e-mail applications to apply for job
openings and/or vacancies, and interviewing for jobs.
Job Readiness involves any activity that prepares individuals to obtain and
maintain employment. This entails activities that assist participants in
becoming familiar with general workplace expectations, and learning
behaviors and attitudes necessary to compete in the labor market. This
includes preparing resumes or job applications, training in interviewing
skills, instruction in work place expectations, and training in effective job
seeking. Please note that personal activities such as seeking childcare,
seeking housing, or seeking transportation are not countable work activities
under JS/JR or any other allowable activity.
Job Readiness may also involve substance abuse treatment, mental health
treatment, or rehabilitation activities. In order to count such activities as
part of JS/JR, a qualified medical, substance abuse, or mental health
professional, must provide written documentation of the need for
participation in such activities.
Travel time between interviews may be counted as JS/JR participation time,
but not the travel time to the first job search interview or the time spent
returning home after the last one.
Participation time spent in JS/JR prior to an individual becoming a FIP
recipient will not count towards the participant’s JS/JR time limit.
A maximum of 240 hours of JS/JR in the preceding 12 month period (a
rolling 12 month period) may be counted toward the participation
requirements of single custodial parents with a child under age six, and a
maximum of 360 hours of JS/JR may be counted toward the participation
requirements for all other individuals. Please note that a maximum of 360
JS/JR hours in the preceding 12 month period may be counted for each
work eligible individual in a two parent family. The total hourly JS/JR time
countable for a two parent family may not be combined and applied to one
parent (i.e., one parent may not do all 720 JS/JR hours).
Participation in JS/JR is also limited to four consecutive weeks and then a
one-week break is required. A week is the seven-day period from Sunday
through Saturday and any amount of time spent participating in JS/JR during
a week would exhaust one full week of the four-consecutive week JS/JR
time limit. Hours of participation in JS/JR in the fifth consecutive weeks
will not count towards participation requirements, nor apply towards the
individual’s 240/360 hours 12 month limit.
The JS/JR participation time must be tracked by the MWA to ensure that
countable participation time limits are not exceeded. The OSMIS will
provide a warning when reported JS/JR time approaches the participant’s
hourly limit for the 12 month period. Total JS/JR participation time
recorded may also be found on the Family Self-Sufficiency Plan (FSSP),
under the Countable Hours Option in the Main Menu
Caution should be used in reporting hours of JS/JR above participants’
average weekly federal participation requirements. Reported hours of JS/JR
that are over the participant’s core federal participation requirement will still
exhaust hours of the participant’s 240/360 hour limit for the 12 month
period. In addition, reported hours of JS/JR that are above the participant’s
total number of countable JS/JR hours (240/360) for the 12 month period
will still subtract time from a participant’s total annual countable JS/JR
participation time in future 12 month periods, due to the rolling 12 month
period.
When a participant has exceeded the annual JS/JR limit, additional time
spent in the activity should be reported as “other non-countable hours”
(ONCH) on the OSMIS. The Countable Hours Limits History Report,
found in the FSSP, may be used to determine when countable hours of JS/JR
will be available.
Unpaid Work Activities
Unpaid work activities are work assignments performed in return for
welfare. These assignments are not intended to create employee-employer
relationships. An MWA shall take into account the prior training,
experience, and skills of a participant along with employment and training
objectives when making appropriate assignments. The MWAs must
negotiate the terms for placement of participants into unpaid work activities
and must approve assignment location(s).
Participants in these activities must be supervised by a work site supervisor
or another responsible representative on an ongoing basis, at least once each
day in which the individual is scheduled to participate.
The MWAs shall periodically evaluate the effectiveness of these
assignment(s) to assess the participant’s readiness for full-time
Unsubsidized Employment.
A participant’s combined monthly hours of participation in Community
Service Program (CSPs), Work Experience Programs (WEP), and Providing
Childcare Services to an Individual who is Participating in a Community
Service Program may not exceed the amount of cash assistance the
participant receives per month divided by the state’s minimum wage, in
accordance with the Fair Labor Standards Act (FLSA). This monthly hour’s
value is determined by the DHS for each FIP case and is transmitted from
Bridges for display in the OSMIS as “FIP CS/WE Hrs.” or “FIP/FAP
CS/WE Hrs.” Participants are not eligible to participate in CSP or WEP
until an hourly value is displayed in one the fields as indicated below:
Two-Parent Family Provision
The “FIP CS/WE Hrs.” value is the maximum hours allowed for each FIP
case, not for each participant in a two-parent family. Thus, the combined
monthly participation of both parents in a two-parent family may not exceed
the hours displayed in either parents OSMIS record. (Example below: total
participation by both parents may not exceed 93 hours per month.)
Family Limit
DHS has obtained a waiver that allows certain Food Assistance Program
(FAP) grant amounts to be combined with the TANF funded FIP grant
amounts for the purposes of determining the maximum number of hours of
CSP and WEP to count towards meeting work participation. As stated
above, the formula to determine the FLSA limit is the quotient of the total
benefit amount divided by the state minimum wage. Adding FAP benefits
to the top of the equation produces a greater number of allowable hours.
This value as determined by DHS is transmitted from Bridges for display in
OSMIS as “FIP/FAP CS/WE Hrs.” for each participant eligible to engage
in the increased monthly CSP and/or WEP hours.
The OSMIS will provide a warning if the combined actual hours entered for
WEP participation and CSP participation in a month exceed the number of
allowable hours reflected in the “FIP/FAP CS/WE Hrs” field. Please note
this warning is only valid for the individual participant and will not be
accurate if both parents in a two-parent family are assigned to a CSP and/or
WEP activity.
The State of Michigan is the worker’s compensation insurer for FIP clients
while they are assigned to the unpaid work-related activities through the
MWA, per DHS Program Bridges Eligibility Manual 232 at
http://www.mfia.state.mi.us/olmweb/ex/bem/232.pdf.
Work Experience Program (WEP) is a Core Activity which is usually best
suited for individuals lacking previous employment experience and/or Job
Readiness skills which prohibit direct placement into Unsubsidized
Employment. The goal of the WEP is to improve skills, attitudes, and the
general employability of these individuals in order to maintain employment
once job placement occurs. This activity may include work associated with
the refurbishing of publicly assisted housing. WEPs may be created with
public sector, private sector, community-based, faith-based, or nonprofit
employers or work-site sponsors. If participants are placed into sites with
faith-based or political organizations, participation must be voluntary on the
part of the participant, and the work activity must be nonsectarian and
nonpartisan in nature.
Community Service Program (CSP) is a Core Activity where individuals
perform work for the direct benefit of the community under the auspices of
public or nonprofit organizations. CSPs must be designed to improve the
employability of participants otherwise unable to obtain full-time
employment. Time counted in CSPs may include training that is an integral,
embedded part of the CSP and of limited duration.
An MWA shall only place participants into nonsectarian or nonpartisan
activities. If participants are placed into sites with faith-based or political
organizations, participation must be voluntary on the part of the participant,
and the work activity must be nonsectarian and nonpartisan in nature.
Providing Childcare Services to an Individual who is Participating in
Community Service Program is a Core Activity that consists of providing
childcare to enable another participant to engage in a CSP. This is an
unpaid activity and must be a structured program designed to improve the
employability of individuals who participate in it. Training, certification, or
mentoring will help make the activity meaningful and may be a first step
toward the participant’s attainment of employment in the childcare field.
Please note that in a two-parent family, one parent cannot count as
participating by providing child care for his or her own child while the other
parent participates in a community service program.
Educational Activities
Participation in educational activities may be performed at the educational
institution or through distance learning. Hours counted for participation
through distance learning may not exceed the hours required or advised by
the educational institution.
Participants in educational activities must be supervised on an ongoing basis
at least once each day in which the individual is scheduled to participate.
A standard for measuring progress should be developed by the
training/educational institution in order to monitor participants’ progress.
Progress should be judged by mediums such as progress reports, report
cards, grade point average, or a time frame within which a participant is
expected to complete such education.
Study time may count toward participation requirements for educational
activities as long as the MWA obtains documentation from the educational
institution stating the homework/study expectations of the program. Study
time can include both supervised and unsupervised time. Unsupervised
study time is limited to one hour for each hour of class time. In addition,
participants may complete supervised study time up to the maximum
recommended expectation provided by the school. Supervised study time
must be performed in a formal study hall at the MWA or educational
institution where an MWA staff person or appropriate representative of the
educational institution can verify the participant’s hours of study. Total
study time (including unsupervised and supervised time) cannot exceed the
hours required or advised by the particular educational program.
For example, an individual who is enrolled in a training program that
consists of four hours per week of classroom seat time, whose educational
institution recommends three hours per week of study time per credit
hour/classroom hour, may not count more than 12 total hours of study time
(no more than four of which may be unsupervised) towards their
participation requirement.
Vocational Educational Training (VET) is a Core Activity that is outlined
in the following categories: Vocational Occupational Training; Condensed
Vocational Training; and Internships, Practicums, and Clinicals.
A.
Vocational Occupational Training (VOT) - An occupationally relevant
training component, directly related to a specific occupational field
or job, which may combine classroom, laboratory, and other
related activities.
B.
Condensed Vocational Training (CVT) - A short-term (not to exceed
six months) vocational training program requiring a minimum of 30
hours of classroom seat time per week.
C.
Internships, Practicums, and Clinicals - Full-time internships,
practicums, or clinicals required by an academic or training
institution for licensure, professional certification, course credit, or
degree completion.
All VET programs must be provided by education or training organizations.
Such organizations include vocational-technical schools, public and private
universities and colleges, community colleges, postsecondary institutions,
proprietary schools, non-profit organizations, and secondary schools that
provide facilities for a vocational educational provider’s use.
All VET activities should be organized educational programs that are
directly related to the preparation of individuals for employment in current,
emerging, or in demand occupations, as determined by the MWA. VET
programs should be limited to activities that provide individuals the
knowledge and skills to perform a specific trade, occupation, or other
particular vocation.
VET activities may include basic and remedial education and English-as-aSecond Language (ESL) components. The educational or training
organization providing the services must determine such activities to be a
necessary part of the training, and provide supporting documentation for its
need. Such education must be embedded within the VET activity as a minor
element of the program. Participation time in a baccalaureate or advanced
degree program may also be included in this activity.
A maximum of 12 months of participation in VET per participant per
lifetime can be counted towards federal participation requirements. The
months of VET participation reported may be found on the FSSP, under the
Countable Hours Option in the Main Menu.
VET activities that meet the definitions of other activities may be defined as
such, in order to maximize countable participation time. For example,
clinical training in a hospital that is part of a licensed practical nurse training
program could meet the definition of a CSP or WEP and reporting
participation in baccalaureate and advanced degree programs as Job Skills
Training Directly Related to Employment would also avoid exhausting the
12-month VET limit.
Please note that any amount of VET time reported in a month will be
counted as one month of the 12 month lifetime VET limit. Thus, if the 12
month lifetime limit of VET has not yet been exceeded, and VET hours of
participation in a month are minimal, it may be beneficial to record the
hours in OSMIS as ONCH or Job Skills Training Directly Related to
Employment (unless those hours were required for the person to meet their
participation requirement that month).
Hours of participation spent in VET that have exceeded the 12 month
lifetime limit should be reported on the OSMIS, despite not counting
towards participation requirements. This information will be collected and
may be beneficial in federal assessments of the state’s overall work
participation status, as these hours contribute information about the overall
engagement levels of participants.
Job Skills Training Directly Related to Employment is a Non-Core
Activity. It consists of training and education for job skills required by an
employer to provide individuals with the abilities to obtain or advance in
employment or adapt to changing workplace demands. Job skills training
can include customized training to meet the needs of a specific employer or
it can be general training that prepares individuals for employment. This
can include literacy instruction or language instruction when such
instruction is explicitly focused on skills needed for employment or
combined in a unified whole with job training.
Education Directly Related to Employment is a Non-Core Activity. This
activity is for work eligible individuals who have not received a high school
diploma or a certificate of high school equivalency. It involves education
related to a specific occupation, job, or job offer. The activity includes
courses designed to provide the knowledge and skills for specific
occupations or work settings, but may also include adult basic skills
education and ESL. Where required as a prerequisite for employment by
employers or occupations, this activity may also include education leading
to a General Educational Development (GED) or high school equivalency
certificate.
Satisfactory Attendance at Secondary School or in a Course of Study
Leading to a Certificate of General Equivalence is a Non-Core Activity.
Unlike “education directly related to employment,” this activity need not be
restricted to those for whom obtaining a GED is a prerequisite for
employment. The activity consists of regular attendance, in accordance with
the requirements of the secondary school or course of study at a secondary
school; or in a course of study leading to a certificate of general
equivalence, in the case of a participant who has not completed secondary
school or received such a certificate. The former is aimed primarily at
minor parents still in high school, whereas the latter is aimed at participants
of any age.
This activity may not include other related educational activities, such as
adult basic education or language instruction, unless it is linked to attending
a secondary school or leading to a GED.
Please review WDASOM PI 12-10 and its subsequent changes for a special
provision where this activity may be treated as a Core Activity for 18 & 19
year olds.
PROHIBITED
In all such instances where participants are placed into any of the allowable
work activities, they shall not be placed into vacancies created as the result
of layoffs, strikes, or bona fide labor disputes. While participants cannot
displace employees who were involuntarily terminated due to staffing
reductions, they may fill positions that occur due to attrition, as in cases
where former employees voluntarily vacated positions. Concurrence must
be obtained from the union prior to placement into vacancies if there is
union representation.
Action:
MWAs shall comply with this policy issuance in the implementation of PATH.
Inquiries:
Questions regarding this policy issuance should be directed to your Welfare
Reform state coordinator at (517) 335-5858.
The information contained in this policy issuance will be made available in
alternative format (large type, audio tape, etc.) upon request to this office.
Expiration
Date:
Continuing
PATH Allowable Activities in Meeting the Required Hours of Participation
(Applies to all Participants, Updated January 31, 2013)
1.
2.
3.
4.
5.
Unsubsidized Employment (Core Activity)
a. Full or part-time employment in the public or private sector, not supported by Temporary Assistance for Needy
Families (TANF) funds, state General Fund/General Purpose (GF/GP) funds, or any other public program.
b. Hours in barrier removal or other supportive activities, such as substance abuse treatment, mental health treatment, and
rehabilitation activities may count as unsubsidized employment if the activities are an integrated part of the
unsubsidized employment and if the participant is paid for all hours of participation in such activities.
c. Self-employment may count as unsubsidized employment.
d. The following formula must be used to determine actual hours of participation for the self-employed: Monthly net
business sales (gross revenues minus expenses) divided by the federal minimum wage equals monthly actual hours.
Guidelines for determining allowable self-employment activities and allowable self-employment expenses can be found
in Department of Human Services Bridges Eligibility Manual 502, at
http://www.mfia.state.mi.us/olmweb/ex/bem/502.pdf
Subsidized Public or Private Sector Employment (Core Activity)
 Job creation through public or private sector employment wage subsidies.
 Work-study programs sponsored by educational institutions may be included in this activity.
 Hours of participation in barrier removal or other supportive activities, such as substance abuse treatment, mental health
treatment, and rehabilitation activities may count as subsidized employment if the activities are an integrated part of the
subsidized employment and if the participant is paid for all hours of participation in such activities.
 If the participant’s FIP case closes, and the placement of the participant into this activity was the result of efforts made
by the MWA, the participant may remain in the activity for the remaining balance of their subsidized employment
agreement.
On-the-Job Training (OJT) (Core Activity)
 Training is conducted while participants are employed. Employer may be reimbursed for the training costs, which may
cover up to 50 percent of a participant’s salary.
 An OJT contract must be limited to the period of time required for a participant to become proficient in the occupation
for which the training is being provided.
 Payment may continue to be paid to the employer until the OJT contract expires or is terminated by any party even if
the FIP case closes.
Job Search and Job Readiness (JS/JR) Assistance (Core Activity)
 The act of seeking or obtaining employment, or preparation to seek or obtain employment.
 Job Readiness activities may include substance abuse treatment, mental health treatment, or rehabilitation activities if
determined to be necessary by a qualified medical or mental health professional.
 Personal activities such as seeking childcare, seeking housing, or seeking transportation are not countable work
activities under JS/JR or any other allowable activity.
 A maximum of 240 hours of JS/JR in the preceding 12-month period (a rolling 12 month period) may be counted
toward the participation requirements of single custodial parents with a child under age six, and a maximum of 360
hours of JS/JR may be counted toward the participation requirements of all other individuals.
 A maximum of 360 JS/JR hours in the preceding 12-month period may be counted for each work eligible individual in
a two-parent family.
 Participation in JS/JR is limited to four consecutive weeks and then a one-week break is required. A week is the sevenday period from Sunday through Saturday and, any amount of time spent participating in JS/JR during a week would
exhaust one full week of the 4-consecutive week JS/JR time limit.
 Hours of participation in JS/JR in the fifth consecutive weeks will not count towards participation requirements, nor be
applied towards the individual’s 240/360 hour 12 month limit.
 Participation time spent in JS/JR prior to an individual becoming a FIP recipient will not count towards the JS/JR time
limit.
Work Experience Program (WEP) (Core Activity)
 An unpaid work assignment, performed in return for welfare. May include work associated with the refurbishing of
publicly assisted housing.
 No specific time limit, but intent is for short-term participation that improves skills and general employability of
participants.
 A participant’s combined monthly hours of participation in WEPs and Community Service Programs (CSPs) may not
X
X
X
X
X
6.
7.
8.
9.
exceed the number of hours indicated in either the “FIP CS/WE Hrs.” field or the “FIP/FAP CS/WE Hrs.” field in
OSMIS, in accordance with the Fair Labor Standards Act (FLSA).
 The combined monthly participation of both parents in a two-parent family may not exceed the hours displayed in
either parents “FIP CS/WE Hrs.” field in OSMIS.
Community Service Program (CSP) (Core Activity)

CSPs must be structured programs in which individuals perform work for the direct benefit of the community under the
auspices of public or nonprofit organizations. CSPs must be designed to improve the employability of participants
otherwise unable to obtain full-time employment.

Time counted in CSPs may include training that is an integral, embedded part of the CSP and of limited duration.

A participant’s combined monthly hours of participation in CSPs and WEPs may not exceed the number of hours
indicated in either the “FIP CS/WE Hrs.” field or the “FIP/FAP CS/WE Hrs.” field in OSMIS in accordance with the
FLSA.

The combined monthly participation of both parents in a two-parent family may not exceed the hours displayed in
either parents “FIP CS/WE Hrs.” field in OSMIS
Providing Childcare Services to Individuals Participating in Community Service Programs (Core Activity)
 Providing childcare to individuals participating in a community service program.
 This is an unpaid activity and must be designed to improve the employability of individuals who participate in it.
 Training, certification, or mentoring will help make the activity meaningful and may be a first step toward the
participant’s attainment of employment in the childcare field.
 In a two-parent family, one parent cannot count as participating by providing child care for his or her own child while
the other parent participates in a community service program.
Vocational Educational Training (VET) (Core Activity)

Organized educational programs that prepare individuals for employment in current, emerging, or in demand
occupations.

Participation in the educational activity may be performed at the educational institution or through distance learning.
Hours counted for participation through distance learning may not exceed the hours required or advised by the
educational institution

Participation time in a baccalaureate or advanced degree program may be included in this activity.

Basic and remedial education and English-as-a-Second Language (ESL) may only count as part of a VET activity if
they are a minor component of the program and deemed to be necessary by the educational institution, which must
provide supporting documentation for its need.

Any participation time in this activity exceeding 12 months per individual shall not be counted towards federal
participation requirements or shall be recorded as Job Skills Directly Related to Employment.

Study time may be counted toward participation requirements for educational activities as long as the MWA obtains
documentation from the educational institution stating the homework/study expectations of the program. Study time
can include both supervised and unsupervised time. Unsupervised study time is limited to one hour for each hour of
class time. In addition, participants may complete supervised study time up to the maximum recommended
expectation provided by the school. Total study time (including unsupervised and supervised time) cannot exceed the
hours required or advised by the particular educational program.
A. Vocational Occupational Training (VOT) is an occupationally relevant training component, directly related to a specific
occupational field or specific job, which may combine classroom, laboratory, and other related activities.
B. Condensed Vocational Training (CVT) is a short-term (not to exceed six months) vocational training program requiring
a minimum of 30 hours of classroom time per week.
C. Internships, Practicums, & Clinicals are activities required by an academic or training institution for licensure,
professional certification, or degree completion, etc.
Job Skills Training Directly Related to Employment (Non-Core Activity)
 Job skills training focuses on educational or technical training that specifically helps individuals obtain employment or
advance in the workplace.
 Remedial education/basic math/ESL is allowable if it relates directly to employment or job training.
 Baccalaureate and advanced degree programs may be defined as Job Skills Training Directly Related to Employment.
Such programs must be applicable to an occupation that the MWA has determined to be in-demand.
 Study time may be counted toward participation requirements for educational activities as long as the MWA obtains
documentation from the educational institution stating the homework/study expectations of the program. Study time
can include both supervised and unsupervised time. Unsupervised study time is limited to one hour for each hour of
class time. In addition, participants may complete supervised study time up to the maximum recommended
X
X
X
O
expectation provided by the school. Total study time (including unsupervised and supervised time) cannot exceed the
hours required or advised by the particular educational program.
 Participation in the educational activity may be performed at the educational institution or through distance learning.
Hours counted for participation through distance learning may not exceed the hours required or advised by the
educational institution
10. Education Directly Related to Employment (Non-Core Activity)
 Education related to a specific occupation, job, or job offer.
 For work-eligible individuals who have not received a high school diploma or certificate of high school equivalency.
 Remedial education/basic math/ESL and GED preparation is allowable if it is related to a specific occupation, job, or
job offer.
 Study time may be counted toward participation requirements for educational activities as long as the MWA obtains
documentation from the educational institution stating the homework/study expectations of the program. Study time
can include both supervised and unsupervised time. Unsupervised study time is limited to one hour for each hour of
class time. In addition, participants may complete supervised study time up to the maximum recommended
expectation provided by the school. Total study time (including unsupervised and supervised time) cannot exceed the
hours required or advised by the particular educational program.
 Participation in the educational activity may be performed at the educational institution or through distance learning.
Hours counted for participation through distance learning may not exceed the hours required or advised by the
educational institution
11. Satisfactory Attendance at Secondary School or in a Course of Study Leading to a Certificate of General
Equivalence (Non-Core)
 Activity may not include other related educational activities, such as adult basic education or language instruction
unless it is linked to attending a secondary school or leading to a GED.
 Study time may be counted toward participation requirements for educational activities as long as the MWA obtains
documentation from the educational institution stating the homework/study expectations of the program. Study time
can include both supervised and unsupervised time. Unsupervised study time is limited to one hour for each hour of
class time. In addition, participants may complete supervised study time up to the maximum recommended
expectation provided by the school. Total study time (including unsupervised and supervised time) cannot exceed the
hours required or advised by the particular educational program.
 Participation in the educational activity may be performed at the educational institution or through distance learning.
Hours counted for participation through distance learning may not exceed the hours required or advised by the
educational institution
X – Any single or combination of those activities identified with an “X” can be used to meet the weekly minimum 20 required average
hours of participation in Core Activities. O – Those activities marked with an “O” are considered “Non-Core Activities” and they assist
participants with weekly required average hours greater than 20 to meet participation, in conjunction with Core Activities, and help
promote self-sufficiency
O
O
OFFICIAL
E-mailed: 04/01/13 (pv)
Workforce Development Agency, State of Michigan (WDASOM)
Policy Issuance (PI): 12-10, Change 1
Date:
April 1, 2013
To:
Michigan Works! Agency (MWA) Directors
From:
Gary Clark, Director, Office of Talent Development Services
SIGNED
Subject:
Case Management Manual
Programs
Affected:
Partnership. Accountability. Training. Hope. (PATH) [Formerly the Jobs,
Education and Training (JET) Program]
Rescissions: WDASOM PI 12-10
References:
Reauthorization of the Temporary Assistance for Needy Families (TANF)
Program; Final Rule: 45 Code of Federal Regulations(CFR) Parts 261, et al.,
Federal Register, Volume 73, Number 24, February 5, 2008
Reauthorization of the TANF Program, Interim Final Rule: 45 CFR Parts 261 et
al., Federal Register, Volume 71, Number 125, June 29, 2006
TANF Program; Final Rule: 45 CFR Part 260 et al., Federal Register, Volume 64,
Number 69, April 12, 1999
PA 471 of 2006, dated December 20, 2006 (Enrolled Senate Bill 1501)
State of Michigan Work Verification Plan, effective August 1, 2012
Social Security Act, 407(c)(2)(C)
Table of Contents
1.
2.
3.
4.
5.
6.
7.
8.
9.
10.
11.
Case Management
180-Day Job Retention
Extended Family Independence Program (EFIP)
Noncompliance Process
PATH Participants who are Unable to Participate due to Medical Reasons
Family Automated Screening Tool (FAST)
Family Self-Sufficiency Plan (FSSP)
Entry of Educational and Training Outcomes
Entry of Actual Hours of Participation
Deeming for 18 & 19-Year-Olds with Satisfactory Attendance at a Secondary School or
in a Course of Study Leading to a Certificate of General Equivalence
Deeming for TANF Funded Participants Who Complete the Allowable Community
Service Program (CSP)/Work Experience Program (WEP) Hours
12.
13.
14.
15.
Required Hours for Two-Parent Household Treated as Single Parent Due to Receipt of
Supplemental Security Income (SSI)
Acceptable Forms of Documentation
Data Verification
Found Ineligible Referrals
Background:
PATH is designed to establish and maintain a connection to the labor market for individuals
referred from the Michigan Department of Human Services (DHS), while offering educational
and training opportunities and Job Search and Job Readiness (JS/JR) activities, to increase the
individual’s income; therefore, reducing or eliminating a family’s need for public assistance.
This policy change includes the following:
1.
All references to the JET Program have been replaced with PATH.
2.
The scheduling of PATH orientation appointments and the corresponding report available
in OSMIS has been added to this policy.
3.
Noncompliance Process: This policy has removed the requirement for MWAs to
incorporate the standard language attached to WDASOM PI 12-10 when explaining the
noncompliance process to PATH participants. The automated triage scheduling process
and report function has been updated. In addition, a new section has been added to
OSMIS for entry and tracking of Noncompliance Warning Notices.
4.
Work Ready with Limitations Program Code (WL) has been added to this policy.
5.
Deeming for 18 & 19-Year-Olds with Satisfactory Attendance at a Secondary School or
in a Course of Study Leading to a Certificate of General Equivalence: Instructions and
additional examples have been added for two-parent family members involved in this
activity.
6.
Deeming for TANF Funded Participants Who Complete the Allowable CSP/WEP Hours
has been added to this policy.
7.
Acceptable Forms of Documentation for Paid Work Activities has been revised to include
a process for handling a gap in pay stubs.
8.
The OSMIS process has been updated in the Found Ineligible Referrals section of this
policy.
Policy: Case Management
This policy applies to all PATH participants including those individuals who have completed the
21-Day Application Eligibility Period (AEP).
MWAs must provide case management activities, as necessary, to assist participants in obtaining
employment at sufficient wage and hours to eliminate the need for Family Independence
Program (FIP) assistance. MWAs shall make every effort to place a minimum of 50 percent of
clients, who participate in PATH, in positions that provide wages of $8 per hour or more.
Examples of case management activities include:
•
Working with employers to develop career ladder programs and/or providing more
working hours to a participant,
•
Enrollment of participants into training programs, assessing needs for supportive
services,
•
Providing supportive services,
•
Consulting with the participant’s DHS Family Independence Specialist (FIS) to address
situational barriers, and
•
Using other community agencies for additional necessary services.
MWAs are to serve all persons applying for, or connected to, a FIP or EFIP case. Persons served
are to be electronically referred from DHS, and are to include FIP clients who are in their last
month of sanction and have reapplied for FIP. Case managers of PATH participants may
participate in home visits with DHS staff at the MWA’s discretion.
Bridges, the electronic data system for DHS, will schedule a PATH orientation appointment for
each person (AEP and Non-AEP) referred to the MWA. The DHS-4785, PATH Appointment
Notice, is sent to the participant and the orientation appointment information is transmitted to
OSMIS. The MWA may view a report containing the appointment information via the
“Orientation Appointments” link on the Special Functions header tab in the Welfare Reform
(WR) program section of OSMIS.
In addition, the ‘Appointment Office Name’ and ‘Appointment Date’ are auto-filled on the
participant’s WR registration screen.
Supportive services are to be provided in accordance with the Bureau of Workforce Programs
(BWP) PI 06-33, and its subsequent changes. MWAs are to provide supportive services to
participants, as appropriate, through the first 180-days of a participant’s employment (the 180day job retention period).
Please note: this also applies to those individuals whose FIP case closes due to income prior to
the end of the 180-day retention period. PATH participants receiving FIP payments beyond the
180-day retention period may be provided supportive services at the MWA’s discretion and
funding availability.
However, in accordance with BWP PI 06-33, and its subsequent changes, after the 180-day
retention period has been completed, public transportation allowances or private automobile
mileage reimbursement may only continue to be provided to those participants who are enrolled
in education or training activities.
MWAs are required to record all appropriate case note information in the OSMIS in a timely
manner. This includes identified barriers and steps taken to remove them, supportive services
records, and employment information from case management contacts.
Participant information required to be reported in the OSMIS; such as, activity data, beginning
and ending dates, participant status, and date attended orientation must be entered in the OSMIS
within two business days of obtaining the information with the exception of the Assigned to
Triage activity. The Assigned to Triage activity must be entered in OSMIS the same day the
Triage Meeting Notice is distributed.
180-Day Job Retention
The OSMIS will track and report 180-day job retention status based on the entry of consecutive
weeks of actual hours entered by the MWAs. Participants who have been placed into
employment must remain employed for 180 calendar days to be reported as completing 180-day
job retention requirements.
If there is a break of seven calendar days or less in a participant’s employment status, or a 14calendar day break occurs as a result of a cyclical layoff during the 180-day period, there is no
requirement to start the retention period over. In order for the original 180-day retention period
to remain uninterrupted, the individual must remain in the original employment activity in the
OSMIS. Within the Employment Activity in OSMIS, the original employment information
should be transferred to the comment box and the new employer information should be added to
the OSMIS fields.
Please note: the start date field must not be updated but the new start date should be documented
in the comment box.
If the break is more than seven calendar days, or more than 14-calendar days resulting from a
cyclical layoff, the 180-day job retention period must begin over from zero, and the individual is
to be placed into a new employment activity.
For the purposes of this policy issuance, a cyclical layoff is a layoff of 14-days or less that is
related to business or production cycles. The participant must return to work with the same
employer at the end of the layoff period. In the case of participants who work with temporary
agencies, the participant may return from the cyclical layoff to work at a comparable work site,
as long as he/she is an employee of the same temporary agency.
If an individual is still receiving regular FIP payments 180 days after obtaining employment, the
participant should not be terminated from the OSMIS. The MWA is to leave the participant
active in the OSMIS and continue to verify that work participation requirements are being met.
EFIP
The DHS will provide a payment of $10 per month for six months to individuals whose FIP case
would have otherwise closed due to earnings, if those individuals continue to meet federal
work participation requirements, per Section 57s of PA 471. The DHS extends the FIP case
and it becomes an EFIP case. Such case outcomes are captured as case closures due to income in
the OSMIS. All case closures due to income should be considered EFIP cases upon the case
closure due to income notification.
MWAs must ensure that EFIP recipients who are active with the MWA are meeting federal
participation requirements. If, based on a monthly average, an EFIP recipient’s hours of
employment are less than his/her federally required hours of participation, the individual must
participate in the additional allowable activities necessary for the participant to meet federal
participation requirements.
EFIP participants’ hours of participation should be verified and reported according to the
documentation requirements stipulated in the Acceptable Forms of Documentation section of this
policy (hours of participation in employment may be projected for up to six months).
If an EFIP participant changes employers, documentation from the new employer must be
submitted in order to project hours.
If an EFIP participant loses their job, due to no fault of their own, the MWA should re-engage
the client and notify the FIS. An EFIP recipient is noncompliant with work related activities and
requires the triage process only when he/she:
•
•
Quits a job without good cause
Is fired from a job for misconduct
•
Voluntarily reduces hours of employment without good cause
If an MWA is unable to obtain documentation to support an EFIP participant’s hours of
participation within four weeks of the notification of the case’s transfer to EFIP, the MWA
should terminate the EFIP participant from the OSMIS using the code “Refused EFIP Services”
and notify the FIS of the termination. If an EFIP participant declines MWA services, the MWA
should immediately terminate the participant from the OSMIS, using the code “Refused EFIP
Services” and notify the FIS of the termination.
Supportive services are to be provided, as appropriate, through the 180-day job retention period.
Please note that the six-month (180-day) period in which a participant receives EFIP payments
does not necessarily coincide with the participant’s 180-day job retention period. EFIP payments
begin upon the individual’s case closure to income, which often occurs at a point subsequent to
the person’s first date of employment (the beginning of the 180-day retention period). An EFIP
payment period that does not begin at the same point at which the 180-day retention period
begins is a result of the initial income from the person’s employment not having been sufficient
to immediately discontinue the FIP payments (and change to EFIP payments). MWAs are not
required to provide supportive services to individuals receiving EFIP beyond their 180-day job
retention period.
All EFIP cases in the OSMIS will be automatically terminated upon receipt of any “case closure”
notification subsequent to the case’s initial “case closure due to income” notification. Such
automatic terminations include case closures that occur due to six months of EFIP having been
provided, and other case closures (which may occur prior to six months of EFIP having been
provided). Accordingly, MWAs are to discontinue the provision of all case management
services, including the provision of supportive services, upon such EFIP case terminations.
Participants who move from EFIP payments back to regular FIP payments will continue their
current participation in the OSMIS. The MWA is not to terminate the existing referral, or
manually enter a new referral, in the OSMIS. The participant’s EFIP status will be changed to
“No” in the OSMIS and the participant will be listed on the “WF_EFIP_NO” report. The Work
First Participant Count in the OSMIS will be increased by one to reflect the new referral. MWAs
are to reassign allowable work participation activities to these participants, as appropriate.
Noncompliance Process
All non-AEP referred individuals who have attended orientation, and AEP referred individuals
who have completed AEP, are subject to the new noncompliance and reengagement procedures.
Noncompliance occurs when a participant does not complete assigned activities, does not call in
or show up for a scheduled work assignment, demonstrates a pattern of tardiness, or is otherwise
in violation of PATH without good cause. (Examples of noncompliance may also be found in the
DHS Bridges Eligibility Manual 233A, at
http://www.mfia.state.mi.us/olmweb/ex/bem/233A.pdf.)
Participants who are unable to attend a scheduled activity are expected to notify the appropriate
PATH/MWA staff prior to the time that the activity begins. Participants who do not have good
cause for failing to notify the appropriate PATH/MWA staff as required are considered
noncompliant. (Examples of good cause for noncompliance may also be found in the DHS
Bridges Eligibility Manual 233A, at http://www.mfia.state.mi.us/olmweb/ex/bem/233A.pdf.)
A determination of noncompliance cannot be made solely on the fact that a participant has
exceeded their countable excused absence hours.
The noncompliance policy must be thoroughly explained to participants during their required
PATH orientation.
When a participant is noncompliant with PATH, the following process is to be followed:
1st Act of Noncompliance: Issue a Noncompliance Warning Notice and
Reengage the participant
2nd Act of Noncompliance: If it has been less than 120 days since the first act of
noncompliance, issue a WR-243 or WR-244 Triage Meeting Notice. If it has been more than
120 days, issue a WR-241 Noncompliance Warning Notice and reengage the participant.
Noncompliance Warning Notice:
The day the MWA becomes aware of the first instance of noncompliance, the MWA must issue a
WR-241 Noncompliance Warning Notice and attempt to contact the participant in person or by
phone to schedule a reengagement appointment.
•
If the participant is at the MWA, the reengagement appointment is held at that time.
•
If the MWA reaches the participant by phone, the MWA must instruct the client to attend
a reengagement appointment at the MWA within the next two business days.
•
If the MWA is unable to reach the participant in person or by phone, the MWA must
mail, e-mail, or fax the completed notice to the participant that day. The mode of delivery
selected must be a standard method of communication between the participant and the
MWA. The reengagement appointment must be held within five business days.
If a participant notifies the MWA of a need to reschedule the reengagement appointment, the
MWA must follow its standard excused absence procedure to determine whether the participant
may reschedule.
In all cases, the original WR-241 Noncompliance Warning Notice form must be maintained in
the case file and a copy must be given to the participant.
Reengagement Appointment
During the reengagement appointment the MWA must at least:
•
Review the Noncompliance Warning Notice,
•
Address barriers to participation,
•
Restate the noncompliance policy, and
•
Offer the participant the opportunity to sign a WR-242 PATH Reengagement Agreement.
If the participant refuses to sign the reengagement agreement or fails to show up for the
appointment, the MWA must immediately generate a Triage Meeting Notice, as described on the
next page.
In all cases, the original PATH Reengagement Agreement form must be maintained in the case
file. A copy must be given to the participant if s/he attended the appointment.
Rescinding the Noncompliance Warning Notice
The MWA must rescind a Noncompliance Warning Notice if the participant can produce
documentation of good cause for the noncompliance. (Examples of good cause for
noncompliance may be found at DHS Bridges Eligibility Manual 233A, at
http://www.mfia.state.mi.us/olmweb/ex/bem/233A.pdf.)
The MWA may also choose to rescind a Noncompliance Warning Notice for a participant who
had a missed assignment, but was still able to complete his/her assigned hours for the month.
In order to rescind a notice, the MWA must indicate on the WR-241 Noncompliance Warning
Notice form that the warning is being rescinded. The warning may no longer be acknowledged;
however, the updated original notice must be retained in the case file. A copy of the rescinded
notice must be given to the participant.
Tracking Noncompliance Warning Notices in OSMIS
A new section titled ‘Non-Compliance Warnings’ has been added to the WR Program Section of
the OSMIS, to track the warning notices and associated reengagement appointments. A new
menu item has been added to the ‘Applicant Search’ menu.
Technical instructions for the Non-Compliance Warning section in OSMIS can be found in
Appendix I of this policy issuance.
Determining when to Assign a Participant to the Triage Activity
If there is a second instance of noncompliance within 120 days of a Noncompliance Warning
Notice, the MWA must immediately request a triage meeting, as described under the Triage
Meeting Notice section below.
Warning Notice and the MWA must request a triage meeting. The following are reasons to
assign a participant to the triage activity immediately:
•
•
•
•
Falsifying documentation related to work participation activities
Threatening, physically abusing, or otherwise behaving disruptively toward anyone
conducting or participating in an employment and/or self-sufficiency-related activity
Refusing suitable employment by:
Voluntarily reducing hours or otherwise reducing earnings.
Exception: This does NOT apply if the work participation program verifies the client changed
jobs or reduced hours in order to participate in a work participation program approved education
and training program.
•
Quitting a job.
Exception: This does NOT apply if the work participation program verifies the client changed
jobs or reduced hours in order to participate in a work participation program approved education
and training program.
•
*Firing for misconduct or absenteeism (not for incompetence)
Note: Misconduct sufficient to warrant firing includes any action by an employee, or other adult
group member, that is harmful to the interest of the employer, and is done intentionally or in
disregard of the employer’s interest, or is due to gross negligence. It includes but is not limited to
drug or alcohol influence at work, physical violence, and theft or willful destruction of property
connected with the individual’s work.
•
Refusing a bona fide offer of employment or additional hours up to 40 hours per week
A “bona fide offer of employment” means a definite offer paying wages of at least the applicable
state minimum wage. The employment may be on a shift; full or part-time up to 40 hours per
week; and temporary, seasonal or permanent.
Exception: Meeting participation requirements is not good cause for refusing suitable
employment, unless the employment would interfere with MWA approved education and
training.
Source: DHS BEM 233A
*This includes being fired, for misconduct or absenteeism, from a CSP or WEP activity.
Triage Meeting Notice
On the day that the MWA becomes aware of the 2nd act of noncompliance within 120 days, or
the participant commits one of the actions above, the MWA must:
•
Complete a WR-243 or WR-244 Triage Meeting Notice.
•
Place the participant into the “Assigned to Triage” activity in OSMIS and indicate the
reason for the triage. When entering the “Start Date” on the “Assigned to Triage” screen
in the OSMIS, the MWA must enter the date of the noncompliance which led to the
Triage Meeting Notice.


Provide the participant a copy of the completed notice in person, by postal mail, e-mail,
or fax. The mode of delivery selected must be a standard method of communication
between the participant and the MWA.
Examples for Processing Acts of Noncompliance
Example 1: The PATH participant does not attend the scheduled MWA appointment on
Wednesday nor did s/he call in good cause for nonattendance. A Noncompliance Warning Notice
was completed on the Wednesday to address the 1st act of noncompliance. The participant was
contacted by phone and instructed to attend a reengagement appointment on Friday. At no time
during the phone conversation or prior to the appointment on Friday does the participant provide
a good cause reason for the noncompliance on Wednesday. The warning notice information was
entered in OSMIS. The participant does not attend the reengagement appointment on Friday,
thus a 2nd act of noncompliance has occurred less than 120 days from the 1st act of
noncompliance and has to be addressed immediately with a Triage Meeting Notice. A Triage
Meeting Notice is completed and mailed to the participant on Friday and the participant was
assigned to the triage activity in OSMIS that same day with a start date of Friday.
Example 2: The PATH participant arrives at the MWA office on Monday to meet with the case
manager and turn in job search logs for the previous week. The participant had been assigned to
20 hours of job search but the logs only documented 5 hours of job search. The participant does
not provide a good cause reason for the noncompliance. A Noncompliance Warning Notice was
completed and given to the participant in person on Monday to address the 1st act of
noncompliance. As the client was at the MWA, the case manager was able to hold the
reengagement appointment at that time. The warning notice information was entered in OSMIS.
The participant remained actively engaged and at the end of the month had successfully
completed the monthly required hours of participation assigned. The MWA chose to rescind the
Noncompliance Warning Notice and updated OSMIS accordingly.
Scheduling the Triage Meeting
When the triage activity is entered in OSMIS, the request is transmitted to DHS, and Bridges
automatically schedules a triage appointment. The DHS-2444, Notice of Noncompliance, is sent
to the participant and the triage appointment data is transmitted to OSMIS. The MWA may view
the appointment information via the “Triage Appointments” link on the Special Functions header
tab in the Welfare Reform program section of OSMIS.
At the Triage Meeting
MWA involvement in the triage (i.e., in person or via telephone conference call) is a local
decision, so long as the DHS staff, MWA staff, and participant are able to be involved in the
communication process.
The MWA must bring the applicable case file copies of the participant’s Noncompliance
Warning Notice, PATH Reengagement Agreement, and Triage Meeting Notice for the
noncompliance in question.
If the DHS and MWA staff does not agree as to whether good cause exists for the
noncompliance, the case must be forwarded to the immediate supervisors of each party involved
to reach an agreement. The DHS supervisor makes the final determination of good cause.
Examples of good cause for noncompliance may be found in the DHS Bridges Eligibility Manual
233A, at http://www.mfia.state.mi.us/olmweb/ex/bem/233A.pdf.
If the participant is given a finding of good cause, the MWA must indicate the participant’s
newly assigned activities in the OSMIS. If good cause was not found or has not been determined,
the MWA is to wait for the interface from Bridges to send a case closure to the OSMIS before
entering a termination on the OSMIS.
Please note that a participant’s failure to attend a triage meeting does not automatically lead to a
determination of no good cause.
Post-Triage - Good Cause Found and Effect on the Noncompliance Warning Notice
If the participant is given a finding of good cause that also covers the infraction on the
Noncompliance Warning Notice, the MWA must rescind the Noncompliance Warning Notice, as
explained below.
Example: On a Friday, a participant fails to submit JS/JR logs. The participant is not at the
MWA, nor can they be reached by phone, the MWA mails the participant a Noncompliance
Warning Notice, notifying him/her of a reengagement appointment. The participant fails to show
for the reengagement appointment. The MWA issues a Triage Meeting Notice. At the triage, the
participant presents good cause documentation showing that s/he was in the hospital. If the
participant was hospitalized during the time for which the JS/JR logs were due, the
Noncompliance Warning Notice must be rescinded. If the good cause is only for the time of the
reengagement appointment, then the Noncompliance Warning Notice should not be rescinded.
Post-Triage PATH Appointment Notice
WR-245 Post-Triage PATH Appointment Notice has been created as a best practice for the
MWAs. The notice contains the time, date, and location of the reengagement appointment and is
to be signed by the participant, MWA staff, and DHS staff after a triage meeting in which good
cause is given.
A copy of the signed notice must be given to the participant and to the DHS staff. The original is
to be maintained in the case file.
Other Triage Information
Triage meetings are not required for the following OSMIS termination reasons:
•
•
•
•
•
•
•
Found ineligible after referral
Deferred
FIP case closure-Other
FIP case closure-Income
Refused EFIP Services
Participant Death
Institutionalized
MWAs are not required to participate in triage meetings for FIP (non-AEP) referrals who fail to
show or call for a PATH orientation. Referred individuals who fail to show or fail to contact the
MWA should not be activated in the OSMIS.
PATH Participants who are Unable to Participate due to Medical Reasons
30 Days or Less
PATH participants who are unable to participate for 30 days or less due to medical reasons are to
be placed in OSMIS, code 75; “Medical Inactive – 30 days or less.”
MWAs must give the participant a WR-231 Return to PATH Appointment Notice, which
schedules the participant to return or contact the MWA at the end of their medically excused
period. If the notice cannot be given to the participant in person, then the mode of delivery must
be a standard method of communication between the participant and the MWA, such as by postal
mail, e-mail, or fax. If the participant fails to return or make contact with the MWA as instructed,
this is an act of noncompliance. The MWA must follow the Noncompliance Process described in
this policy.
More than 30 Days
If an MWA receives information from a PATH participant that they are unable to participate in
PATH for more than 30 days due to medical reasons, the MWA must contact the local DHS for
a deferral determination and place the participant into OSMIS, code 80; “Pending Deferral
Determination.” The participant is not to be placed in a triage nor terminated from the
OSMIS while waiting for a deferral determination to be made.
If DHS makes a determination that the individual qualifies for a deferral, the participant will be
indicated as such in the daily OSMIS deferral file and will be terminated automatically from the
OSMIS. If DHS determines that the individual does not qualify for a deferral, the MWA must
reengage the participant and assign him/her to an appropriate allowable activity.
PATH Participants who are Work-Ready with Limitations (WL)
DHS has created a new program code (WL) for individuals that have been determined by the
Medical Review Team (MRT) as Work-Ready with Limitations. Participants coded as WL may
be referred to the MWA for participation in PATH. DHS will send a comment to OSMIS Case
Notes which identifies the participant’s limitations as defined by the MRT. The MWA must
abide by the limitations set by the MRT when assigning allowable activities and hours of
participation. A participant may not be triaged for not meeting work participation if they are
engaged at the level set forth by the MRT. An indicator has been added to the Welfare Reform
Header to signify that these individuals are Work-Ready with Limitations (Appendix I).
FAST
The FAST is a 50-question, web-based, participant self-assessment designed to identify the
participant’s strengths and barriers. The FAST is to be completed by the participant and takes
approximately 30 minutes to complete, depending on the individual’s reading and computer
skills. The participant’s responses to the questions will assist in the development of the FSSP.
All PATH participants must complete and submit a FAST within 30 days of the initial interview
with the FIS. Completion of the FAST is the participant’s responsibility. MWAs may assist with
participants’ completion of the FAST if they have the resources to do so. The FAST is available
to participants at www.michigan.gov/fast, in both English and Spanish. The client must select an
answer to every question even if they choose the response “skip.” When the client submits the
completed FAST, they will be given a confirmation number to document their completion of the
FAST. Participants with active FIP cases that were opened prior to FAST completion
requirements must complete a FAST at re-determination of FIP eligibility.
FSSP
The FSSP is a web-based service plan designed for multiple agencies to share data that pertains
to mutual participants. The FSSP is accessible to MWAs through the OSMIS. It is used to
collect, document, and report on participants’ participation in employment, education, and family
strengthening activities that will support success in self-sufficiency. Currently, the work
participation activities assigned to participants and actual hours of participation are collected
from the OSMIS and displayed on the FSSP the following day.
Please note that MWAs no longer need to enter the Contract Agreement Date on the FSSP. The
“Date Attended Orientation” that is recorded by the MWA in the OSMIS (the Contract
Agreement Date) will be automatically sent to the FSSP.
MWAs must continue to complete an Individual Service Strategy in the OSMIS for all
participants within 30 days of program enrollment, in accordance with the Bureau of Workforce
Programs PI 06-10.
Entry of Educational and Training Outcomes
MWAs must enter into the OSMIS all PATH participants’ educational and training outcomes
prior to termination/case closure. In the registration component of the OSMIS, case managers
will be required to indicate whether or not the participant obtained a high school diploma/GED,
an associate’s degree, other post-secondary degree, or other training credentials during
enrollment in PATH. All educational and training outcomes must be verified by the MWA prior
to being entered into the OSMIS.
Entry of Actual Hours of Participation in OSMIS
WDASOM PI 06-11, and its subsequent changes, specifies the requirements and limitations of
all allowable activities. Actual hours of participation in the allowable activities must be entered
into the OSMIS and supported by the appropriate documentation, as specified in this policy.
Planned hours may not be considered and entered as actual hours.
Actual hours must be entered into the OSMIS within two calendar weeks of the end of the week
in which the activity was completed, with the exception of self-employment which is calculated
and entered monthly. Each week is defined as Sunday through Saturday.
The beginning and ending dates for each reporting month may be found in the OSMIS, in the
“Participation Hours Calendar.” This calendar may be accessed through the “Update/View
Participant Activities” page, the “Enter Actual Hours” page, or the “Actual Hours Status” page.
Hours of participation in paid work activities may be projected for up to six months, with
appropriate documentation as specified in this policy.
Participants remaining countable participation time in Vocational Educational Training (VET)
and JS/JR may be found on the FSSP, under the Countable Hours option in the Main Menu.
In order to better track and record PATH participant engagement levels and to avoid
unnecessarily exhausting JS/JR or VET durational limits, the MWA must report hours of
participation as ONCH in the following situations:
•
When a participant does not meet federal work participation requirements for the month,
hours must be moved from actual hours to ONCH hours.
•
When a participant already has enough hours for the month, additional time spent in
JS/JR activity must be reported as ONCH.
•
When a participant has exceeded the annual JS/JR limit, additional time spent in the
activity must be reported as ONCH.
Please remember when moving JS/JR and VET hours to ONCH, any excused absence or holiday
hours must also be removed.
The Actual Hours Status Page, within the Update/View Participant Activities screen of the
OSMIS has also been updated to reflect hours entered as “Other Non-Countable Hours.” Actual
hours of ONCH will be transferred to the FSSP for inclusion on the Countable Hours Reports.
Please use the “Countable Hours” option on the Main Menu of the FSSP to access Countable
Hours Reports, which will display the actual hours of ONCH from OSMIS in the “Other” cell of
the “Actual Hours” row near the top of the page. The Countable Hours Limits History Report
may be used to determine how many JS/JR hours have been counted towards work participation
and the availability of JS/JR hours.
Technical instructions for the entry of actual hours into the OSMIS can be found in Appendix I
of this policy issuance.
The OSMIS does not allow changes to activity begin dates, activity end dates, or actual hours
data that is more than four months old. For example, actual hours data for the last week of June
cannot be changed after the last week of October.
Deeming for 18 & 19-Year-Olds - Satisfactory Attendance at a Secondary School or in a
Course of Study Leading to a Certificate of General Equivalence
Appendix I contains the technical instructions for the new activity in OSMIS titled “High
School/GED for 18/19 Year Olds.”
Participants, who are 18 or 19-years-old without a high school diploma or GED, are eligible for
this activity. Homeschooling is not allowed for this activity. The participant's age on the first day
of the month is the age designated for the individual for the whole month.
Example: If the participant turns 20 on October 10th he/she qualifies for the activity in October
but not after October.
Example: If the participant turns 20 on October 1st he/she does not qualify for the activity in
October or any month thereafter.
In both situations, additional participation in high school completion or GED must be recorded in
OSMIS under the appropriate non-core educational activity and all rules of that activity apply.
18 & 19-year-old single parents may be deemed to be meeting their federal minimum work
participation requirement solely through satisfactory attendance in high school, a high school
completion program, or a GED program.
If both 18 & 19 year-old parents from a two-parent family are enrolled in this activity, they
may be deemed to be meeting their federal minimum work participation requirement solely
through satisfactory attendance in high school, a high school completion program, or a GED
program.
For single parents and two-parent families where both parents are enrolled in this activity,
deeming is the act of treating satisfactory participation in either the non-core high school or GED
activity as a core activity that meets work participation.
If only one parent from a two-parent family is eligible and enrolled in this activity, he/she is
granted 20 core hours of participation (due to deeming) or the actual hours of participation each
week, whichever is greater. The family is still obligated to participate up to their remaining
required hours.
Example 1: A two-parent family without federally funded day care is required to participate 35
hours per week (30 core and 5 non-core hours), or 140 total hours for a 4-week month or 175
total hours for a 5-week month. One parent participates in a GED program for 8 hours per week
and the other parent is working for 15 hours per week.
Breakdown of how the Family Met Work Participation– 4-week month
32 hours = Actual participation in GED program (deemed as core hours)
48 hours = Deemed core hours (12 hours each week to bring up to 20)
60 hours = Actual participation in unsubsidized employment
140 hours =Total hours for the 4-week month (all core)
Breakdown of how the Family Met Work Participation – 5-week month
40 hours = Actual participation in GED program (deemed as core hours)
60 hours = Deemed core hours (12 hours each week to bring up to 20)
75 hours = Actual participation in unsubsidized employment
175 hours =Total hours for the 5-week month (all core)
Example 2: A two-parent family with federally funded day care is required to participate 55
hours per week (50 core and 5 non-core hours), or 220 total hours for a 4-week month or 275
total hours for a 5-week month.. One parent attends high school for 35 hours per week and the
other parent is working for 15 hours per week plus participating in Job Skills Training Directly
Related to Employment (JSTDRE) for 5 hours per week.
Breakdown of how the Family Met Work Participation – 4 week month
140 hours = Actual participation in high school (deemed as core hours)
60 hours = Actual participation in unsubsidized employment (core)
20 hours = Actual participation in JSTDRE (non-core)
220 hours =Total hours for the 4-week month (200 core and 20 non-core)
Breakdown of how the Family Met Work Participation – 5-week month
175 hours = Actual participation in high school (deemed as core hours)
75 hours = Actual participation in unsubsidized employment (core)
25 hours = Actual participation in JSTDRE (non-core)
275 hours =Total hours for the 5-week month (250 core and 25 non-core)
Satisfactory Attendance and Entry of Actual Hours
Satisfactory attendance is determined by the educational institution. If the participant does not
receive satisfactory attendance, the actual hours for the month will be treated as non-core hours
and deeming will not apply.
The MWA must enter actual hours in OSMIS and maintain acceptable documentation, as
described in this policy. Zero actual hours are acceptable if the educational program was not in
session due to a short-term break, such as winter holiday or spring break. Excused absences and
holiday hours will not be tracked for this activity.
At this time, the OSMIS will not submit hours to the FSSP so work participation reports will
reflect zero hours of participation. If the individual is selected in the TANF Data Verification
sample and participation is entered in OSMIS and properly documented, he/she will be counted
as meeting federal work participation.
Educational Programs Scheduled for Part of the Month
The following applies to single parents and two-parent families where both parents are
eligible and enrolled in this activity
If the high school or GED program ends before the end of the TANF month and the participant
had satisfactory attendance for all weeks the program was in session, they may be deemed as
meeting work participation for the month. The same holds true if the educational program started
after the beginning of the TANF month.
Example: An 18 year old single parent (or two 18 year-old parents in a two-parent family)
attended high school and the last day of high school is June 7th. The school verified the
participant(s) had satisfactory attendance for the week of June 3rd thru June 7th. The
participant(s) will be deemed as meeting work participation for June.
PATH requirements must resume during any full month which the participant is not assigned to
High School/GED for 18/19 Year Olds.
Example: A 19-year-old is participating in a traditional high school environment where classes
are not scheduled during the summer. The participant must be assigned to allowable activities at
the appropriate level to meet work participation during the month after the high school program
ends.
Deeming for TANF Funded Participants Who Complete the Allowable CSP/WEP Hours
DHS has obtained a waiver that allows certain Food Assistance Program (FAP) grant amounts to
be combined with the TANF funded FIP grant amounts for the purposes of determining the
maximum number of hours of CSP and WEP to count towards meeting work participation. The
Fair Labor Standards Act (FLSA) places a limit on the number of hours a participant can engage
in these unpaid activities. The formula to determine the FLSA limit is the quotient of the total
benefit amount divided by the state minimum wage. Adding FAP benefits to the top of the
equation produces a greater number of allowable hours. This value as determined by DHS is
transmitted from Bridges for display in OSMIS as “FIP/FAP CS/WE Hrs.” for each participant
eligible to engage in the increased monthly CSP and/or WEP hours. If OSMIS does not display
FIP CS/WE Hours or FIP/FAP CS/WE Hours for a PATH participant but does display an
Eligibility Date, the MWA may contact their local DHS office to determine the number of hours
the FIP case is allowed for community service or work experience programs.
If the “FIP/FAP CS/WE hours” displayed are less than the participant’s federally required
CORE hours and the individual completes that number of hours in CSP or WEP, the remaining
core hours may be “deemed.”
Deeming is the act of giving the participant credit for completing core hours when they were
unable to complete those hours due to the FLSA restriction.
Participants that qualify for deeming are not allowed to use excused absences or holiday hours
for the CSP or WEP activities. All hours of participation must be actual hours.
Example 1: During a 4-week month, a 20-hour participant (80 required core hours for the
month) has 72 “FIP/FAP CS/WE Hrs” allowed for the month (or 18 hours per week). For a 5week month, a 20-hour participant (100 core hours for the month) also has 72 “FIP/FAP
CS/WE Hrs.” allowed for the month. The participant is assigned and completes all 72 hours in
the CSP activity. The participant is deemed as meeting work participation for the month.
Breakdown of how Participant Met Work Participation – 4-week month
72 hours = Actual participation in CSP activity
8 hours = Deemed Core hours
80 hours =Total hours for the month
Breakdown of how Participant Met Work Participation – 5-week month
72 hours = Actual participation in CSP activity
28 hours = Deemed Core hours
100 hours =Total hours for the month
The MWA must enter a separate case note in OSMIS to indicate that the participant has been
assigned to CSP and/or WEP at the hourly level to satisfy deeming. (e.g., Jean is assigned to 72
hours of CSP for the month of February to qualify for deeming.)
If the participant was unable to complete the maximum hours allowed in a CSP and/or WEP
activity, deeming does not apply and individual must complete the required federal required
hours by participating in other core activities.
Example 1a: If the participant above only completed 60 hours in the assigned CSP activity,
deeming would not be an option and the participant would have to complete 20 hours of
participation in other core activities to meet work participation in the 4-week month.
The MWA should enter another case note to indicate that the participant had been assigned to
CSP and/or WEP at the hourly level to satisfy deeming but was unsuccessful so deeming is no
longer an option. (e.g., Jean was assigned to 72 hours of CSP for the month of February but was
unsuccessful and will not be deemed.)
Provision for Participants with 30 Average Weekly Required Hours
The provision of deeming only applies to the CORE required hours. Participants with a federal
requirement of 30 average weekly hours only have 20 core hours. The remaining 10 average
hours per week are designated as non-core hours, even though all 30 hours may be completed in
core activities
Example 2: During a 4-week month, a 30-hour participant (80 core hours and 40 non-core hours
total 120 total hours for the month) has 66 “FIP/FAP CS/WE Hrs” allowed for the month (or 16
hours per week). For a 5-week month, a 30-hour participant (100 core hours and 50 non-core
hours total 150 hours for the month) also has 66 “FIP/FAP CS/WE Hrs” allowed for the month.
The participant is assigned and completes all 74 hours in the CSP activity. The participant may
be deemed for meeting their requirement for the month as long as they also complete their 40/50
hour non-core requirement in other activities (core or non-core).
Breakdown of how Participant Met Work Participation – 4-week month
66 hours = Actual participation in CSP activity
14 hours = Deemed Core hours
40 hours = Actual participation in other activities (core or non-core)
120 hours =Total hours for the month
Breakdown of how Participant Met Work Participation – 5-week month
66 hours = Actual participation in CSP activity
34 hours = Deemed Core hours
50 hours = Actual participation in other activities (core or non-core)
150 hours =Total hours for the month
The MWA must enter actual hours in OSMIS and maintain acceptable documentation, as
described in this policy. At this time, the OSMIS will not recognize these participants as meeting
work participation; however if the individual is selected in the TANF Data Verification sample
and participation is entered in OSMIS and properly documented, he/she will be counted as
meeting federal work participation.
Required Hours for Two-Parent Household Treated as Single Parent Due to Receipt of SSI
A two-parent FIP household in which one parent is receiving SSI is required to participate an
average of 30 hours per week, regardless of the age of the youngest child in the family
Acceptable Forms of Documentation
All hours of participation reported as actual hours in the OSMIS must be verified every two
weeks with documentation which meets the requirements below and in the Documentation
Checklist within Appendix II. This policy also includes standard forms that must be used to
document actual hours of participation unless an exception is noted below. The MWAs may
create instructions for using the standard forms, as long as the instructions are printed on the
back of the form. On all forms the Michigan Works! logo may be deleted and a local MW! logo
may be inserted in its place. The MWA may also replace the title “MW! Staff” with a locally
recognized title. Several of the forms have more than one approved version to choose from.
Where signatures are required, electronic signatures may be accepted.
1. Paid Work Activities (Except Self-Employment)
•
•
•
Unsubsidized Employment (except Self-Employment)
Subsidized Private and Public Sector Employment
On-the-Job Training (OJT)
Paid work must be documented in one of the following ways:
•
With a pay stub, other official employer record detailing hours of work, or third party
verification, such as “TALX” which includes:
o
o
o
Participant’s name
Participant’s actual hours of participation
Name of the employer
OR
•
By a documented contact with an employer through one of the following methods:
o
A WR-201 or WR-202 Verification of Employment Hours form
OR
o
A signed written statement generated by the employer which includes:
Participant’s name
Participant’s actual hours of participation
Name of the employer
Name and contact information of the individual providing the information.
Note: Written statements from employers or completed WR-201 or WR-202 Verification of
Employment Hours forms must not be used as verification of participation hours, unless the
documentation was completed after the hours have actually been worked.
Projecting Hours for Unsubsidized Employment (excluding self-employment), Subsidized
Employment, and OJT
An MWA may report projected actual hours of employment participation for up to six months
based on current, documented actual hours of work, assuming hours worked will remain
constant. All documentation must conform to the requirements above. Projections are to be
generated as follows:
•
Calculate the average weekly hours worked during a minimum of two consecutive weeks
based on pay stubs, other official employer records detailing hours of work, or third party
verification services, such as “TALX,”
Example: If the participant is paid weekly, and if the MWA is using pay stubs to verify hours or
participation, the MWA would use two consecutive pay stubs to project hours. If the participant
is paid bi-weekly or monthly, only one pay stub is needed to project hours.
If there is a gap in the pay stubs, the MWA may calculate the missing pay period by using the
year-to-date information on submitted pay stubs.
OR
•
Project the average weekly hours based on a documented contact with the employer.
Reminder: Written statements from employers or completed Verification of Employment Hours
forms (WR-201 or WR-202) must not be used as verification of participation hours, unless the
documentation was completed after the hours have actually been worked.
Any time an MWA receives information that the participant's average actual hours of work have
changed, or no later than the end of any six-month period, the MWA must re-verify the client's
current actual average hours of work, and may report these projected actual hours of
participation for another six-month period.
2. Self-Employment
MWAs must collect copies of a participant’s documentation of gross business sales and
expenses, attach the copies to the completed WR-203 Self-Employment Cover Sheet, and
maintain this packet in the participant’s case file. Documentation may consist of personal checks,
business receipts, billing invoices, or accounting records. (Self-reporting by a participant without
additional verification is not sufficient documentation.)
The cover sheet includes the following formula:
Monthly net business sales (gross revenue minus expenses) divided by the federal minimum
wage equals Monthly Actual Hours.
Monthly Actual Hours divided by number of weeks in the month*, equals average Weekly
Actual Hours.
*The number of weeks in the month is defined by the Participation Hours Calendar in OSMIS (4
or 5).
Guidelines used for determining allowable self-employment activities and allowable selfemployment expenses must be consistent with the countable self-employment income guidelines
used by DHS in determining TANF eligibility. These guidelines can be found in DHS Bridges
Eligibility Manual 502 at http://www.mfia.state.mi.us/olmweb/ex/bem/502.pdf.
The MWA is required to request verification of expenses from the participant; however, if the
participant indicates they do not have any business expenses, then the MWA may not deduct
expenses from the gross revenue.
Projecting Hours of Self-Employment
Actual participation hours for self-employment may be projected for up to six months, assuming
hours worked will remain constant, based on one month of tax or income records. The hours
must be calculated and verified by using the self-employment formula and documentation
requirements above.
3. Job Search and Job Readiness (JS/JR) - OUTSIDE the Service Center
In order to count job search activities that a participant engages in outside the MWA service
center; participants must maintain a daily record of all employers visited or contacted by using
the Outside Job Search Contact Log (WR-204 or WR-205).
If travel time between interviews is included in reported JS/JR time, the MWA must verify that
the time is an accurate representation of the time required to travel between the locations.
The MWA must conduct random reviews of the listed employers on job search records to ensure
the validity of the reported participation hours.
4. Job Search and Job Readiness (JS/JR) - INSIDE the Service Center
The Activity Log (WR-206, WR-207, WR-208 or WR-209) is to be used to document the
participant’s time spent in JS/JR activities at the MWA service center or at another supervised
location, such as a substance abuse treatment appointment.
If the MWA has their own time keeping methods for JS/JR at the service center, such as time
cards or electronic monitoring, they may be used in place of the Activity Log, if it fulfills the
documentation requirements below:
•
•
•
Participant’s name
Actual Hours and dates of participation
Name, signature, and contact information of the MWA staff overseeing the activity
In order to count substance abuse treatment, mental health treatment, or rehabilitation as Job
Readiness activities, a qualified medical, substance abuse, or mental health professional must
provide written documentation of the need for participation in such activities.
5. Work Experience Program (WEP) and Community Service Program (CSP)
The Activity Log (WR-206, WR-207, WR-208 or WR-209) is to be used to document the
participant’s time spent engaged in WEP or CSP.
If the WEP or CSP site has their own record keeping methods such as time cards, attendance
records, electronic records or other official verification, they may be used in place of the Activity
Log, if it fulfills the documentation requirements below:
•
•
•
•
Participant’s name
Actual hours and dates of participation
Name of the work site
Name, signature, and contact information of the individual verifying the information
The Activity Log
Since the Activity Log is used to document both JS/JR inside the service center and WEP/CSP
activities, two activities can be documented on the same sheet OR each activity can be
documented on a separate Activity Log. Although documentation is only required to be
submitted bi-weekly, a new Activity Log is to be used each week.
6. Providing Childcare Services to an Individual Participating in a CSP
The Childcare Services for CSP Participant form (WR-210 or WR-211) is to be used to
document this activity.
7. Educational Activities
The Education Log (WR-212, WR-213, WR-214 or WR-215) is to be used to document the
activities below.
Performed at an Educational Institution or Through Distance Learning
•
Vocational Educational Training (VET)
•
Job Skills Training Directly Related to Employment
•
Education Directly Related to Employment
•
Satisfactory Attendance at a Secondary School or in a Course of Study Leading to a
Certificate of General Equivalence
If the educational institution has their own record keeping methods for the above activities such
as time cards, attendance records, electronic records, computer log-in/log-out times, or other
official verification it may be used in place of the Education Log, if it fulfills the documentation
requirements below:
•
•
•
•
Participant’s name
Actual hours and dates of participation
Name of educational provider
Name, signature, and contact information of the individual verifying the information
*If computer log-in/log-out times are used as documentation, the periods must be verifiable by
the educational institution as periods in which progress was made.
Alternative Documentation Process for Distance Learning
If the educational institution will not sign the participant’s Education Log (WR-212, WR-213,
WR-214 or WR-215) and the institution does not have its own record keeping method for
attendance for distance learning programs that meets the criteria above, the following process
may be followed:
If the MWA chooses to participate in the alternative documentation process, the participant must
provide evidence of work completed and progress made to the MWA at least every two weeks.
This evidence may be feedback from the distance-learning program or copies of work completed.
The MWA must monitor the participant’s progress and compliance by reviewing information
submitted by the participant and/or contacting the school. In addition, the MWA must be
available on a daily basis to the participant by telephone, e-mail, or face-to-face for any needed
guidance or oversight. The MWA will also sign the Education Log as the individual verifying the
information.
Study Time
A limited amount of supervised and unsupervised study time may be counted for these
educational activities. In order to count study time, the participant’s case file must contain
documentation of the educational institution’s homework/study time expectations. Total study
time hours (supervised plus unsupervised) may not exceed the homework/study time
expectations of the educational institution. In addition to these limitations:
•
Unsupervised study time entered may not exceed the actual time spent in classroom (seat
time).
•
Supervised study time must occur in a formal study hall at the MWA or the educational
institution, where an MWA staff person or appropriate representative of the educational
institution, can verify the participant’s hours of study on the Education Log (WR-212,
WR-213, WR-214 or WR-215).
8. 18 & 19-Year-Olds Attending High School or a GED Program
The 18 & 19-Year-Olds High School/GED Log (WR-216 or WR-217) is to be used to document
this activity.
Performed at an Educational Institution or Through Distance Learning
If the educational institution has their own record keeping methods such as time cards,
attendance records, electronic records, computer log-in/log-out times, or other official
verification it may be used in place of this log, if it fulfills the documentation requirements
below:
•
Participant’s name,
•
Actual hours and dates of participation,
•
Name of educational provider,
•
Name, signature, and contact information of the individual verifying the information, and
•
A statement from the educational provider that the participant has maintained satisfactory
attendance.
Documenting Excused Absences and Holidays
Excused absences and holiday policies apply to participation in the unpaid work activities
(JS/JR, WEPs, CSPs, Provision of Childcare Services to Individuals Participating in CSPs, VET,
Job Skills Training Directly Related to Employment, Education Directly Related to Employment,
and Satisfactory Attendance at a Secondary School or in a Course of Study Leading to a GED).
The approved holidays and excused absences may be reported as actual hours. In order to count
an excused absence or holiday as actual hours of participation, the individual must have been
scheduled to participate in the activity for the period of absence that the MWA reports as
participation time. MWA office closures, other than for holidays listed below, may be counted as
an excused absence for the participant.
Excused absences are limited to a maximum of 80 in the preceding 12-month period, no more
than 16 of which may occur in a month. The MWA has the discretion to allow additional
excused hours; however, they will not count towards federal participation requirements.
The MWA must document the following information in the case record:
•
•
•
•
•
Date of the absence
Reason for the absence
Approval or denial of the absence
Case manager initials or signature
Date of determination
The following are the approved holidays. A maximum of eight hours per holiday may be counted
towards participation requirements.
•
•
•
•
•
•
•
•
•
•
New Year’s Day
Martin Luther King Jr. Day
Memorial Day
Fourth of July
Labor Day
Veteran’s Day
Thanksgiving Day
Friday after Thanksgiving
Christmas Eve
Christmas Day
Example: If a participant is scheduled to participate in a WEP every Monday for four hours, the
participant may receive four countable hours of WEP for Labor Day without being required to
participate in the WEP that day.
Excused absences and holiday time must be recorded in the appropriate fields in the OSMIS.
Technical instructions for the entry of excused absence and holiday hours into the OSMIS can be
found in Appendix I of this policy issuance.
Excused absence or holiday hours reported as actual hours in the OSMIS, under either JS/JR or
VET, will be counted towards the durational limits associated with these activities. For example,
if the MWA reports three hours of excused absences from JS/JR, those three hours of excused
absence time will be counted towards both the participant’s countable JS/JR limit and the
participant’s countable excused absence limit. Durational limits on JS/JR and VET are detailed
in the WDASOM PI 06-11, and its subsequent changes, regarding Allowable Activities.
In order to preserve excused absence hours and the durational limits of JS/JR or VET, the MWA
must not enter excused absence hours in OSMIS that do not help meet work participation. If the
hours have already been entered the MWA must remove these hours. In these cases, the
participant would be excused from attendance and would not be considered a “no show.” The
MWA must document that the hours were approved, but not entered in OSMIS. In the same way,
the MWA must not enter holiday hours in OSMIS that do not help meet work participation.
Data Verification
The documentation requirements specified above are used to verify PATH participation in
allowable work activities. Documented actual hours are compared with participant’s assigned
participation requirements to measure Bureau of Workforce Transformation PI 08-21, and its
subsequent changes, which describe the TANF data verification process.
Found Ineligible Referrals
Please note the following automated OSMIS procedures regarding individuals who are “found
ineligible” by DHS subsequent to being referred.
If an individual is found ineligible for FIP benefits after being referred to the MWA, and the
individual has not attended orientation, the OSMIS will set the “Last Day to Attend” in the
OSMIS to the date the individual was found ineligible and will inactivate the record. No action is
required of the MWA.
If an individual is found ineligible for FIP benefits after being referred to the MWA, and the
individual has attended orientation and has not been terminated by the MWA, the OSMIS will
review the transaction file for service code 01, 14, 20, 30, 31, 32, 50, 72, or 73 without an End
Date. If there is an active service code of 01, 14, 20, 30, 31, 32, 50, 72, or 73, no further action is
performed by the system until OMSIS receives a new referral. At the time of the new referral
OSMIS will terminate the previous registration and accept the new referral. The MWA should
assess these cases and determine whether services should continue to be provided to the
individuals. If there is not an active service code of 01, 14, 20, 30, 31, 32, 50, 72, or 73, the
system will terminate the record as “WR_WF_INELIGIBLE.”
Action:
Inquiries:
Expiration
Date:
MWA officials shall take the appropriate actions necessary to implement the
directives of this policy issuance. Instructions for the entry of actual hours within
the OSMIS can be found in Appendix I to this policy issuance.
Questions regarding this policy issuance should be directed to your Welfare
Reform state coordinator at (517) 335-5858.
The information contained in this policy issuance will be made available in
alternative format (large type, audio tape, etc.) upon request to this office.
Continuing
OFFICIAL
E-mailed: 09/20/12(pv)
Workforce Development Agency, State of Michigan (WDASOM)
Policy Issuance (PI): 12-14
Date:
September 19, 2012
To:
Michigan Works! Agency (MWA) Directors
From:
Gary Clark, Director, Office of Talent Development Services
SIGNED
Subject:
Fiscal Year (FY) 2013 Jobs, Education and Training (JET) Program Plan
Instructions
Programs
Affected:
References:
JET
Reauthorization of the Temporary Assistance for Needy Families (TANF)
Program; Final Rule, 45 CFR Parts 261, 262, 263, and 265
Personal Responsibility and Work Opportunity Reconciliation Act
(PRWORA) of 1996
Rescissions:
None
Background:
The JET Program was established to assist welfare applicants/recipients and
low-wage workers to succeed in the labor market. JET places a strong
emphasis on helping welfare applicants/recipients stay employed, gain skills,
and advance rather than only emphasizing initial placement. The goal is to
help families find the resources they need to overcome obstacles and move up
career ladders to self-sustaining, lasting employment. Many interconnections
can be made in doing so, including linking employer, community, and faithbased solutions with the human service, education, and training systems.
The JET program is a partnership between the MWAs, Michigan Department
of Human Services (DHS) and WDASOM.
Policy:
PLAN INSTRUCTIONS
The Michigan Works! System Plan stipulations apply to the JET plan.
Together, MWAs and DHS offices shall develop plans to address JET
activities for the period of October 1, 2012 through September 30, 2013.
The JET plan shall consist of the following:
Section I. Plan Approval/Modification Request – which bears the signatures
of authorized chief elected officials and the Workforce Development Board
(WDB) chairperson.
Section II. Plan Narrative – which describes the services and/or planned
activities to be provided during FY 2013.
Section III. Budget Information Summary (BIS) – which includes BISes for
federal TANF and State General Fund/General Purpose (GF/GP). Separate
Grant Action Notices will be issued for each funding source. There has been
no decision made regarding whether there will be Workforce Investment Act
Statewide activity funding to support JET for FY 2013.
ALLOCATIONS
MWA allocations for FY 2013 are planning funds and will be contingent upon an
Interagency Agreement with DHS and State Administrative Board approval.
PROGRAM ELIGIBILTY
The JET Program seeks to provide Family Independence Program (FIP)
applicants and recipients with employment-related services, training, and
supportive services to obtain and retain employment. MWAs are required to
serve all FIP applicants and recipients.
The PRWORA established a five-year lifetime limit on receipt of federal
TANF assistance for adult-headed families. Starting October 1, 2011,
Michigan implemented a stricter enforcement of the federal 60-month time
limit, as well as executing the state’s 48-month lifetime limit. The begin date
for the Federal Time Limit is October 1, 1996, and the State Time Limit begin
date is October 1, 2007. The JET program will not provide any services to
JET participants once their case closes due to the client reaching either time
limit. However, if the case closed before the end of the month, the participant
is entitled to services until the end of the month.
PROGRAM DESIGN, GOALS, AND OBJECTIVES
For many Michigan residents, the biggest barrier to economic opportunity and
self-sufficiency is the lack of proper education and training. Beginning in Fiscal
Year 2012, the State began a redesign of JET. Design changes have been
incorporated into the program and further change will be incorporated during
Fiscal Year 2013.
The JET Program fundamentally changes the way families move off welfare
and toward self-sufficiency. Instead of telling those on welfare to “get a job –
any job,” the program encourages and supports them as they prepare for and
get a good job to provide long-term self-sufficiency for their families.
Local WDBs, MWAs, and DHS offices will provide a blended approach to
helping Family Independence Program (FIP) applicants/recipients become
self-sufficient and permanently attached to the labor force, based on the
workforce needs of Michigan’s current and emerging economy. By helping
FIP applicants/recipients get and keep good paying jobs, the state will increase
the number of families who are self-supporting and decrease the number of
families requiring public assistance.
The objective of the JET Program is to provide FIP applicants/recipients with
employment related services, training, and supportive services to obtain and
retain employment. Partners will have latitude in the design of JET local
service strategies to achieve this goal. MWAs should balance the flexibility
of individual program design allowed by state law, while ensuring that the
participant population as a whole meets federal work participation
requirement rates. Federal regulations require that 50 percent of all TANFfunded families meet participation requirements and that 90 percent of TANFfunded two-parent families meet participation requirements to avoid
reductions in program funding levels.
Although it is the expectation that MWAs place a majority of participants
into activities that comply with meeting federal work participation
requirements, MWAs have the flexibility to place a limited number of
eligible participants into extended education/training activities. Such
placements should lead to the elimination of dependence on public
assistance.
The State of Michigan allows MWAs to require work participation of up to
40 hours per week for all participants. However, the primary goal is for the
State of Michigan to meet the federal participation rates. The MWAs must
first ensure that the federal work participation requirements are being met by a
majority of the participants. The federal minimum required weekly hours for
each family size are as follows:
Single-parent family with a child under the age of six ..............................20
Single-parent family without a child under the age of six .........................30
Two-parent family not utilizing federally-funded day care .......................35
Two-parent family utilizing federally-funded day care .............................55
Two-parents with one parent receiving SSI, regardless the age of the
youngest child
30
MWAs must make every effort to place a minimum of 50 percent of clients
who participate in the JET Program into positions that provide wages of $8.00
an hour or more. Additionally, MWAs must make available to JET
participants guidelines on eligibility for training/education opportunities and
how training/education hours are applied toward work participation
requirements.
Federal Guidelines
The Federal Final Rule identifies eight components as “core” activities and
three components as “non-core” activities. Core hours do not have to be
completed before non-core hours. For single parents, 20 hours of
work-related activities must be spent participating in core activities. Twoparent families not receiving federally-funded child day care must spend 30
hours of the required 35 hours per week participating in core activities. Twoparent families receiving federally-funded child day care must spend 50 hours
of the required 55 hours per week in core activities. Core activities may also
be used to count towards remaining participation requirements. The
components are listed below:
Core Activities








Unsubsidized Employment
Subsidized Public or Private Sector Employment
Work Experience Program
On-the-Job Training
Job Search/Job Readiness Assistance
Community Service Programs
Vocational Educational Training (12-month lifetime limit)
Providing Childcare for an Individual who is participating in Community
Service
Non-Core Activities




Job Skills Training Directly Related to Employment
Education Directly Related to Employment
Secondary Education (attendance at high school for completion or
General Equivalency Degree (GED) preparation)
High School/GED 18 & 19 year olds
All JET plans must include descriptions of how the allowable core and
non-core activities will be utilized to serve participants. JET plans must also
include detailed explanations of how participation in activities will be
documented, verified, monitored, and/or supervised.
Documentation requirements for verification of involvement in work
participation activities are outlined in the Case Management PI 12-10.
Plans must describe how the MWA will provide work participation activities
that are in accordance with the Final Rule. The State of Michigan will utilize
the definitions and guidelines for the allowable activities as outlined in the
Final Rule. Please see the Allowable Activities PI 06-11 and its subsequent
changes, for the complete detailed definitions of all allowable work
participation activities.
21-Day Application Eligibility Period
Beginning on January 1, 2013, Michigan is requiring FIP applicants to
successfully complete a 21-Day Application Eligibility Period (AEP) and
orientation program at MWAs as a condition of eligibility for FIP benefits.
Separate policy will be released in October, 2012 detailing AEP structure and
requirements for MWAs.
Refugee Assistance Applicants
Starting in early November, 2012, selected MWA’s will be required to serve
FIP applicants and recipients who are refugees. Additional information will
be forthcoming to those MWAs required to serve this population.
PRIORITY OF SERVICE
MWA and DHS directors have latitude in the design of plans to meet the local
needs of the community and their participants. With this in mind,
implementation of a process/strategy is needed for conducting a
comprehensive assessment of local employer needs and identifying which
industry sectors and occupations are in greatest demand in the
community/region.
PROGRAM PLANNING AND COORDINATION
WDASOM and DHS will jointly provide policy and funding oversight for the
JET Program. A joint and coordinated planning process must be established
between the local DHS office, MWAs, and other state and community
partners to ensure that the needs of the participants are being met with all of
the available community, state, and federal resources. This review and
development process will result in a mutually agreed upon plan for delivery of
employment and training services. As part of that process, the partners will be
expected to engage community collaboratives, establish a joint MWA/DHS
local plan, link efforts with existing programs, involve community and/or
faith-based partners in the delivery of services, and use a team concept for
service planning/delivery. Co-location of staff is encouraged to the extent
possible.
During local plan development, partners will have flexibility in customizing
innovative education and training opportunities and work participation
activities that will best serve the participants in each region. It is expected
that, at a minimum, the established federal weekly participation rates will be
met.
MWAs and local DHS offices are to work together to jointly develop an
orientation method that will deliver information on JET employment and
education/training related activities to FIP applicants/recipients. The jointly
developed orientation should be designed to meet the needs of the local area.
The DHS remains responsible for sending out the JET appointment notices to
participants.
The supportive service agreement between the MWA and the local DHS
office shall be updated as needed, and kept on file at the MWA.
PROFIT
Profit is an allowable cost, payable only to commercial organizations and
must be negotiated as a separate element of each contract’s price. Profit rates
can be negotiated from 0 percent up to a maximum of 10 percent. Profit rates
can only be applied against the commercial organization’s personnel-related
costs (i.e., salaries, wages, and benefits) for the staff that contributed to the
organization’s unique capacity to manage and achieve the performance of the
contract. Factors to consider when negotiating profit are the complexity of the
work to be performed, the risk borne by the contractor, the contractor’s
investment, the amount of subcontracting, the quality of its record of past
performance, and industry profit rates in the surrounding geographical area for
similar work. Under cost reimbursement contracts there is little to no risk to
the commercial organization, therefore profit is usually not warranted. Profit
must be tied to performance and cannot be paid as a guaranteed fixed fee.
Profit is earned when performance outcomes are attained and is disbursed
when those outcomes are validated. Profit cannot be paid in addition to
performance payments or incentive payments.
USE OF TANF FUNDS
The MWA uses of TANF funds under this plan are subject to the following
provisions:

There will be no carry-in of unexpended FY 2012 TANF funds into
FY 2013.

There will be no carry-forward of unexpended FY 2013 TANF funds
into FY 2014.

General administrative costs are limited to 12 percent of the TANF
allocation for the fiscal year.
USE OF STATE GENERAL FUND/GENERAL PURPOSE (GF/GP)
FUNDS
MWA uses of state GF/GP funds under this plan are subject to the following
provisions:
Action:

There will be no carry-in of unexpended FY 2012 state GF/GP funds
into FY 2013.

There will be no carry-forward of unexpended FY 2013 state GF/GP
funds into FY 2014.

General administrative costs are limited to 12 percent of the state GF/GP
allocation for the fiscal year.

State GF/GP funds will be utilized consistent with TANF allow ability.
MWA directors must submit the JET Program Plan within 30 days of the
official date of this policy issuance to Vancep1@michigan.gov, and
ReutherS@michigan.gov.
One hard copy of the WDB Plan Approval/Modification Request requiring
original signatures must be submitted within 30 days of the official date of
this policy issuance to:
Mr. Brian Marcotte, Manager, Welfare Reform Section
Office of Talent Development Services
Workforce Development Agency/State of Michigan
Victor Office Center, 5th Floor
201 North Washington Square
Lansing, Michigan 48913
Inquiries:
Expiration
Date:
Questions regarding this policy issuance should be directed to your Welfare
Reform state coordinator at (517) 335-5858. The information contained in
this policy issuance will be made available in alternative format (large type,
audio tape, etc.) upon request to this office.
September 30, 2013
OFFICIAL
E-mailed: 02/25/13 (pv)
Workforce Development Agency, State of Michigan (WDASOM)
Policy Issuance (PI): 12-20, Change 2
Date:
February 25, 2013
To:
Michigan Works! Agency (MWA) Directors
From:
Gary Clark, Director, Office of Talent Development Services
Workforce Development Agency, State of Michigan
SIGNED
Subject:
21-Day Application Eligibility Period (AEP) for Family Independence
Program (FIP) Benefits
Programs
Affected:
Partnership. Accountability. Training. Hope. (PATH) [Formerly the Jobs,
Education and Training (JET) Program]
Rescissions:
PI 12-20, Change 1
References:
Michigan Compiled Law (MCL) 400.1 through 400.119b
Reauthorization of the Temporary Assistance for Needy Families (TANF)
Program; Final Rule: 45 CFR Parts 261, et al., Federal Register, Volume
73, Number 24, February 5, 2008
Reauthorization of the TANF Program, Interim Final Rule: 45 Code of
Federal Regulation (CFR) Parts 261 et al., Federal Register, Volume 71,
Number 125, June 29, 2006
TANF Program; Final Rule: 45 CFR Part 260 et al., Federal Register,
Volume 64, Number 69, April 12, 1999
PA 471 of 2006, dated December 20, 2006 (Enrolled Senate Bill 1501)
State of Michigan Work Verification Plan, effective August 1, 2012
Social Security Act, 407(c)(2)(C)
Background:
The State of Michigan has determined a 21-day time frame will allow for
MWAs to assess, evaluate, and more effectively prepare FIP applicants
to attain employment, meet federal work participation requirements, and
work toward self-sufficiency through PATH. FIP applicants who are
more effectively prepared to attain employment and achieve selfsufficiency through Michigan’s demand-driven workforce development
system are better able to fulfill employers’ needs for skilled and competent
workers.
This policy issuance rescinds and replaces PI 12-20, Change 1 to revise
directions for processing FIP applicants, whose FIP applications were
denied in error, so these applicants can continue or resume their 21-Day
AEP participation appropriately.
Policy:
21-Day AEP Overview
Effective January 1, 2013, Michigan is requiring FIP applicants to
successfully complete a 21-Day AEP at an MWA, as a condition of
eligibility for FIP benefits. Upon successful completion of the 21-Day
AEP, applicants continue with PATH participation.
Please note: FIP applicants participating in the 21-Day AEP at MWAs
will not be included in the State of Michigan’s measurement and reporting
of TANF work participation rates.
The 21-Day AEP consists of three weeks’ worth of assignments
individualized for each applicant’s needs. Week one begins the day the
applicant attends PATH orientation at the MWA. If PATH orientation is
held on Tuesday, week one goes from Tuesday to Monday.
 Weeks 1 & 2 Assignments are for barrier identification and resolution
activities, work readiness instruction, and Core and Non-Core
Allowable Activities appropriate to the applicant’s circumstances.
 Week 3 Assignments are for Core and Non-Core Allowable Activities,
plus any further barrier resolution activities and work readiness
instruction which applicants may still need.
FIP applicants need to complete all weekly assignments in order to fulfill
the requirements of the AEP. The quantity and extent of applicants’
weekly assignments need to be at levels which will simulate the
expectations of PATH (20, 30, 35, or 55 federally required hours per
week).
Please note: Federal required hours are only to be used for planning
purposes to provide a basis for numbers of weekly assignments.
Weekly assignments during AEP present effective opportunities to
resolve applicants’ barriers and prepare them for success in PATH,
and permanent employment. Therefore, completion of all weekly
assignments is the requirement for AEP and the tracking, recording or
otherwise measuring actual hours of participation is not necessary.
The goals of the 21-Day AEP at the MWAs are:
 Identify barriers and facilitate barrier resolution activities for
individuals who are not job-ready by providing effective case
management, necessary supportive services, work readiness instruction
and job search skills for the individuals to obtain employment;
 Familiarize applicants with PATH and work participation
requirements; and
 Prepare applicants for stable attachment to the labor force while
steering them toward sustainable employment which can provide
self-sufficiency.
For the 21-Day AEP, MWAs are required to:
 Familiarize applicants with the 21-Day AEP and PATH;
 Assess applicants’ competencies, skills and interests;
 Meet weekly with applicants;
 Develop, update and sign weekly assignment plans;
 Identify barriers and initiate barrier resolution activities, as necessary;
 Determine the need for and provision of supportive services;
 Monitor and document progress, as well as define achievements; and
 Record weekly outcomes and the AEP completion in the One-Stop
Management Information System (OSMIS).
21-Day AEP Structure
The 21-Day AEP primarily consists of customized assessment, barrier
identification and resolution activities, and work readiness activities/
instruction. FIP applicants with few barriers who are ready for immediate
employment will also need to have intensive job searching activities
during their 21-Day AEP.
FIP applicants must receive assessments of their skills and interests,
assistance with identifying barriers and time to address them, access to
life-skills and job readiness workshops, along with intensive case
management to assist with the long-term goal of finding and maintaining
sustained employment. As the applicants progress through the 21-Day
AEP, they will also be familiarized with PATH requirements. Weekly
assignments need to reflect the expectations of PATH, as quick and
feasible.
Supportive Services
MWAs are required to provide employment-related services, training and
supportive services for all FIP applicants and recipients. The AEP
participants are FIP applicants, therefore supportive services provided
during the AEP are allowable cost expenditures. Supportive services
provided during the AEP are to be entered in the OSMIS.
Week 1 Assignments for Applicants’ Required Hours (20, 30, 35, or
55)





Familiarize applicants with the 21-Day AEP and PATH,
Assess applicants’ skills and interests,
Identify barriers and initiate barrier resolution activities, as necessary,
Determine the need for and provision of supportive services, and
Provide work readiness instruction and begin job search activities.
Barrier resolution activities: These assignments must be made on a caseby-case basis depending on the barriers applicants identify and resources
available for assistance. Reasonable, but realistic, time should be allowed
to adequately address barrier issues. (Barriers may include but are not
limited to: transportation, childcare, housing, nutrition needs, legal
matters, utility services, and counseling, etc.)
Assignments: MWAs must provide the following minimum activities for
all applicants:
 21-Day AEP Introductory Presentation providing the AEP purpose,
goals and requirements
 PATH Orientation with goals, requirements, work participation, and
the noncompliance process
 Family Automated Screening Tool (FAST) and the Individual Service
Strategy (ISS)
 Assessment tests such as Test for Adult Basic Education (TABE) and
WorkKeys, as needed and appropriate.
 Weekly meeting with applicant and MWA to:
 Identify barriers and assess barrier resolution progress,
 Review & finalize the ISS plan, and
 Review FIP applicant’s progress for week one and determine
weekly completion status.
o The MWA needs to sign the completed Week 1 Assignment
Plan
 Collaborate to develop and sign the Week 2 Assignment Plan
 For applicants who are already enrolled in vocational education and/or
training activities, as well as applicants who are employed, MWAs
need to:
 Incorporate the education, training and/or employment activities
into the weekly assignment plan, and
 Recognize participation in the vocational education, training,
and/or employment activities as completed assignments.
 As appropriate and feasible, the applicant may also be assigned to, and
credited for, the following activities:
 Workshops
 Researching Community Service and/or Work Experience
opportunities
 Job Search
 Employment
 High School completion/GED preparation
 High School/GED for 18 & 19-year-old grantees
Week 2 Assignments for Applicants’ Required Hours (20, 30, 35, or
55)
 Review previously identified barriers and progress made in barrier
resolution activities and determine if any potential new barriers are
occurring
 Determine the need for and provision of supportive services
 Monitor progress and define achievements
Barrier resolution activities: These assignments must be made on a caseby-case basis depending on the barriers applicants identify and resources
available for assistance. Reasonable, but realistic, time should be allowed
to adequately address barrier issues. (Barriers may include but are not
limited to: transportation, childcare, housing, nutrition needs, legal
matters, utility services, and counseling, etc.)
Assignments: The MWA must offer the following minimum activities for
all applicants, as appropriate:
 Workshops such as:
 Job Search/Job Readiness
 Resume writing
 Interviewing skills
 Computer skills
 Career/life skills
 Assessment tests (if not already completed)
 FAST and ISS (if not already completed)
 Weekly meeting with applicant and MWA to:
 Review FIP applicant’s progress for week two and determine
weekly completion status.
o The MWA needs to sign the completed Week 2 Assignment
Plan
 Collaborate to develop and sign the Week 3 Assignment Plan
 For applicants who are already enrolled in vocational education and/or
training activities, as well as applicants who are employed, MWAs
need to:
 Incorporate the education, training and/or employment activities
into the weekly assignment plan; and
 Recognize participation in the vocational education, training,
and/or employment activities as completed assignments.
 As appropriate and feasible, the applicant may also be assigned to and
credited for the following activities:
 Researching Community Service and/or Work Experience
opportunities
 Job Search
 Employment
 High School completion/GED preparation
 High School/GED for 18 & 19-year-old grantees
Week 3 Assignments for Applicants’ Required Hours (20, 30, 35, or
55) in Core and Non-Core Allowable Activities
 Review previously identified barriers and progress made in barrier
resolution activities and determine if any potential new barriers are
occurring
 Determine the need for and provision of supportive services
 Monitor progress and define achievements
 Review the requirements of PATH and work participation
requirements.
Assignments: To prepare the applicant for entry into PATH, the applicant
must be assigned to one, or a combination, of the following Allowable
Activities, as appropriate for the applicant’s needs:
 Federal Core and Non-Core Allowable Activities:
 Employment
 Job Search/Job Readiness
 Vocational Educational Training
 Job Skills Training Directly Related to Employment
 Education Directly Related to Employment
 High School Completion/GED preparation
 High School/GED for 18 and 19-year old grantees
 Researching Community Service and/or Work Experience
opportunities
 For applicants who are already enrolled in vocational education and/or
training activities, as well as applicants who are employed, MWAs
need to:
 Incorporate the education, training and/or employment activities
into the weekly assignment plan, and
 Recognize participation in the vocational education, training,
and/or employment activities as completed assignments
 As appropriate, and if necessary, the applicant may also be assigned to
and credited for the following additional activities:
 Job Search/Job Readiness workshop(s)
 Resume writing workshop(s)
 Interviewing skills workshop(s)
 Continued assistance with barrier resolution activities
 Weekly meeting with applicant and MWA to:
 Review FIP applicant’s progress for week three and determine
weekly completion status, and
o The MWA needs to sign the completed Week 3 Assignment
Plan.
Please Note: Week 3 Assignments need to prepare applicants for
success in PATH and with work participation requirements; however,
completion of the Week 3 Assignments is still the requirement for the
AEP and tracking actual hours of participation is not necessary.
Example of a 21-Day Assignment and Workshop Curriculum Model
MWAs are suggested to have standard curriculums and estimated hours to
complete values for each of the assignments offered in their service
delivery areas. In order to establish plausible standards for their areas,
MWAs should develop their own customized curriculums and estimated
values for hours to complete curriculum components based on locally
available opportunities and service delivery capacities.
The following table provides an example of a general 21-Day AEP
curriculum and suggested hour assignment values potentially needed to
complete each assignment. MWAs are not required to follow the
example 21-Day AEP Curriculum Model below.
21-Day AEP Curriculum Model
[For demonstration purposes only]
Required Work Readiness
Activities/Workshops
Resume Writing
Interviewing Skills
MI Talent Connect Class
Job Search Class
Workplace Success/
Job Coaching Classes
Estimated Hour Values to
Complete each Assignment
2
3
2
3
Optional Activities, Services and
Assignments
Computer Skills
Financial Literacy
Mental Health Services (i.e.,
Counseling, Substance Abuse
Treatment)
Legal Matter Resolution
(i.e., Court, Probation, and Friend
of the Court Appointments)
Housing Issue Resolution
Childcare Resolution
Obtaining Legal Identification [ID]
(i.e., Driver’s License, State ID,
Birth Certificates, Social Security
Estimated Hour Values to
Complete each Assignment
3
3
6
4
5
5
4
4
Cards)
Transportation Resolution
GED Preparation
Remediation
English as a Second Language
Job Clubs
Life Skills (i.e., parenting,
motivation, nutrition, etc.)
4
5
4
4
3
4
MWAs and applicants would need to select a combination of assignments
appropriate to applicants’ circumstances for all three jointly developed
weekly assignment plans.
Example Use of Curriculum Model:
 During Week 1, an applicant requires the following assignments in
addition to introductory presentation, PATH orientation and
assessments: Computer Skills, Life Skills, and Financial Literacy.
 Then in Week 2, the same applicant is assigned to: Seek Mental
Health Services, Workplace Success/Job Coaching Classes,
Resume Writing, MI Talent Connect Class, and a Job Search
Class.
 Finally, in Week 3 the applicant is assigned to: Some additional
Workplace Success Classes, Interviewing Skills, Job Clubs, Job
Search Classes and Researching Community Service opportunities.
Considerations when creating all Weekly Assignment Plans
The MWA must recognize the time the following FIP applicants spend in
the activities described below as part of their Weekly Assignment Plans:
 Applicants who are employed,
 Applicants who are enrolled in vocational educational and/or training
programs, including GED prep,
 18 & 19-year-old grantee applicants that are attending high school fulltime, a high school completion program, or a GED program. The
High School/GED for 18 &19-year-olds activity is the assigned
activity for such applicants, and
 Applicants who are the non-participating parent in a 2-parent family.
The MWA must document “providing family childcare” on the nonparticipating parent’s Weekly Assignment Plan under “Other.”
Applicants’ weekly contact with the MWA must be scheduled with
consideration for their involvement in these activities and the MWA must
recognize the time spent in these activities as part of the applicant’s
Weekly Assignment Plans. Both the MWA and applicant still need to
develop and sign weekly assignment plans which incorporate these
activities and any additional assignments necessary and appropriate for the
applicant.
Weekly Assignment Plan Requirements
The MWA must use the “Week 1, Week 2, and Week 3 Assignment Plan
21-Day AEP” forms attached to this policy (Attachments A, B and C) for
all applicants. Both the MWA and FIP applicants must jointly develop
and sign Weekly Assignment Plans based on assessments of the
applicant’s skills and abilities, as well as the goals agreed to in the ISS.
Weekly Assignment Plans are to include activities which foster continuous
progress toward becoming work-ready.
Throughout the weeks of the 21-Day AEP, the applicant must document
completion of assignments as directed by the MWA. Applicants need to
use PATH participation forms to document assignment completion
whenever practical. Additional and/or supplemental documentation is
encouraged, especially for barrier resolution assignments (i.e., letters,
appointment schedules, payment notices, receipts, and office visit records,
etc.)
The MWA must provide the FIP applicant with copies of all signed
Weekly Assignment Plans and the originals must be maintained in the
applicant’s case file.
Unsigned Weekly Assignment Plans
If the applicant refuses to sign any Weekly Assignment Plan, then the
applicant must be offered the opportunity to speak with a supervisor for
managerial review. If the applicant still refuses to sign, it will be
determined that the applicant did not satisfactorily complete the weekly
assignment and thus the client did not complete the AEP. The MWA is to
complete the Weekly Assignment Plan indicating the refusal to sign and
detailing the issues surrounding the refusal. The MWA must offer the
applicant a copy of the form which reflects the applicant’s refusal to sign,
and document the applicant’s refusal in the OSMIS Case Notes.
Weekly Review Meetings and Weekly Completion Determinations
Applicants must submit documentation and/or verifications of assignment
completion at each weekly review meeting. Weekly review meetings are
to be held upon completion of each week. The weekly review meetings
may occur at the end of a completed week or at the beginning of the next
week, as appropriate.
Please Note: With approval from MWAs, applicants may have the
opportunity to finish assignments not completed in Week 1 or Week 2
during the next week. The option to complete unfinished assignments
is only available for Week 1 and Week 2 assignments, meaning a
Week 1 assignment may be completed during Week 2, and a Week 2
assignment may be completed during Week 3. Assignments carried
over for completion into the next week are additional assignments for
that week, and must be done along with the week’s regular
assignments. MWAs and applicants must jointly agree to carry over
an incomplete assignment to the next week. MWAs and FIP
applicants must jointly develop and sign new or revised Weekly
Assignment Plans, which incorporate carried over assignments.
During the weekly review meeting, the MWAs must determine whether
the applicant satisfactorily completed the week’s assignments. The MWA
must complete the Weekly Assignment Plan, provide a copy to the
applicant, and return the original to the case file.
If the MWA determined that the applicant did not satisfactorily complete
any Weekly Assignment Plan, the applicant must be informed they did
not complete the week’s assignments. If applicants disagree with a “did
not complete determination,” then they must be offered the opportunity to
speak with a supervisor for managerial review.
Please Note: MWAs are not required to inform applicants of their
completion status or provide copies of documentation, if applicants fail
to attend the weekly review meeting.
OSMIS Case Notes are required for the instances when applicants do not
satisfactorily complete the Week 1, 2 and 3 Assignments.
Applicant Misconduct
Applicants will immediately fail to complete the 21-Day AEP for the
following reasons:
 Threatening, or physically abusing anyone conducting or participating
in an employment and/or self-sufficiency-related activity; and
 Falsifying documentation related to the 21-Day AEP assignments.
The MWA must document the misconduct on the Weekly Assignment
Plan, and offer a copy to the applicant informing them they did not
complete the week’s assignments, which results in failure to complete
the 21-Day AEP. The applicant’s misconduct and failure to complete the
AEP also needs to be recorded in the OSMIS Case Notes.
MWAs need to inform the local Department of Human Service (DHS) of
the applicant’s misconduct.
Medical Excuse from the 21-Day AEP
When applicants present medical documentation from their medical
provider which supports their inability to participate in AEP for more
than 14 days, the MWA must:
 On the OSMIS, enter “No” for “AEP Completed?” status and select
“Did not complete due to Medical” in the “Reason Failed to Complete
AEP:” field;
 Notify the local DHS of the applicant’s need for a deferral
determination; and,
 Enter the OSMIS Case Notes regarding submission of medical
documentation and the notification of the DHS about it.
The applicant’s participation in AEP will immediately end and the
OSMIS will transmit the AEP Completed status to Bridges that night.
Applicant Transfers during 21-Day AEP
An Applicant may transfer to a different MWA during the 21-Day AEP.
Transfers are done with the “Transfer Registration to Different MWA” in
the Administrative Utilities section on the OSMIS. Please reference
Policy Issuance 06-30 for the participant transfer guidelines.
All Weekly Assignment Plans, supporting documentation, and case file
records need to be sent to the new MWA, so the applicant may continue
with the Weekly Assignment Plan on which they were participating. Both
MWAs involved in the transfer must facilitate the file and record transfer
process.
Extensions of the Last Date to Complete the 21-Day AEP
When applicants notify the MWA that they are unable to participate in
or complete their 21-Day AEP weekly assignments for fourteen or less
days due to unforeseen circumstances, the MWA may offer the applicants
the opportunity to extend their Last Day to Complete (LDTC) AEP.
Unforeseen circumstances which warrant an extension include:
 Temporary medical emergencies (less than 14 days) of the applicant,
their spouse or their dependents;
 Deaths in the applicant’s family; and
 Immediate relocation of the applicant’s primary residence.
MWAs need to make applicants aware that extension of the LDTC AEP
assignments will affect their receipt of FIP benefits.
The LDTC AEP may first be extended for one week (seven days) when
applicants are unable to participate in or complete their weekly
assignments. If the applicants’ inability to participate continues beyond
the first week extension, an additional, second week (seven more days;
fourteen days total) extension may be granted.
The “21-Day Application Eligibility Period Extension Request Form”
(Attachment D) is required to extend the LDTC AEP. Completion of two
Extension Request forms is required when an additional seven-day
extension (fourteen days total) is granted. Signature is required on all
extension request forms; applicants who requested extension over the
phone must sign the completed extension request forms upon their return
to the MWA to continue the AEP assignments. Extension request forms
must be kept in case files and applicants must be provided with
completed copies.
 Example: An applicant has a LDTC of 11/21/2012 and is offered a
one-week extension. The applicant’s LDTC AEP would be changed to
11/28/2012 on the OSMIS. If the applicant is offered a second oneweek extension, the LDTC AEP would be changed to 12/5/2012.
MWAs need to complete the following actions on the OSMIS for
extensions:
 Enter applicant’s new LDTC AEP [OSMIS will automatically display
the dates available for one and two week extensions], and
 Enter Case Notes regarding the extension request.
Applicants are to resume the 21-Day AEP participation at the point of
their last completed weekly assignment. Both the MWA and the
applicants must jointly make any necessary modifications to existing
weekly assignment plans, so that applicants may continue the 21-Day AEP
participation upon the end of their approved extension, when they are able.
OSMIS Data Entry
A 21-Day AEP section is on the OSMIS Welfare Reform Registration
Screen.
OSMIS Field Parameters
“AEP Participant?”: OSMIS will fill this read-only field with “Yes” or
“No” based on the Bridges referral file. The field indicates whether or not
participants are required to complete the AEP.
“AEP Begin Date”: OSMIS will fill this read-only field with the Date
Attended Orientation because the date attended orientation is the first day
of the 21-Day AEP.
“Last Date to Complete (LDTC) AEP”: OSMIS will set this date when
the “AEP Begin Date” is filled. The LDTC is first set to 20 days from the
“AEP Begin Date.”
“Prior Participation Denied in Error?:” OSMIS will fill this read-only
field with “Yes” or “No” based on the Bridges referral file. The field may
indicate those clients for whom a previous case denial/closure was sent in
error.
“Completed Week #1?” “Yes” or “No” is used to indicate whether or not
applicants completed their week one assignments.
“Completed Week #2?” “Yes” or “No” is used to indicate whether or not
applicants successfully completed their week two assignments.
“Completed Week #3?” “Yes” or “No” is used to indicate whether or not
applicants successfully completed their week three assignments.
“AEP Completed?” “Yes” or “No” is used to record whether applicants
successfully completed their 21-Day AEP requirements.
“Reason Failed to Complete AEP”: A reason is required for an entry of
“No” in the “AEP Completed” field. The following options are available:
 “Did Not Complete AEP”
 “Did Not Complete Due to Medical”
“AEP Transmitted to DHS on:” OSMIS will automatically display the
date when the “AEP Completed?” Status [“Yes” or “No”] is transmitted
to Bridges via the system interface files. The “AEP Transmitted to DHS
on:” field will be null until the transmission occurs.
Data Entry for Weekly Assignments
MWAs must enter in the OSMIS the completion status of the weekly
assignments by selecting “Yes” or “No” in the Completed Week 1, 2, and
3 fields, as indicated above.
When applicants complete and turn in their missing weekly assignments,
the MWA can change the status from “No” to “Yes” in any previously
entered “Completed Week #1 or #2” fields. MWAs can also change a
“Yes” status to “No” upon receipt of proof that assignments were not
actually completed.
Data Entry and Transmission of Completed 21-Day AEP
Data entry for all completion status fields must be within two days of the
LDTC because of the potential effects on the applicants’ FIP benefit
eligibility.
MWAs must enter the “AEP Completed?” status field by selecting “Yes,”
or “No.” When “No” is selected an entry is required in the “Reason Failed
to Complete AEP” field.
If the “AEP Completed” status is entered by the LDTC then the OSMIS
will transmit the status to Bridges that night. MWAs have two days
following the LDTC to enter the “AEP Completed” status on the OSMIS.
If the “AEP Completed” status is not entered by the second day, OSMIS
will determine the completion status as described below.
If any of the weekly assignment completion status fields are blank or
“No,” OSMIS will set the “AEP Completed” status to “No” and transmit
the “No” to Bridges. If all three weekly assignment completion status
fields are “Yes,” the OSMIS will set the “AEP Completed” status to Yes
and transmit it to Bridges.
The OSMIS will not transmit the “AEP Completed?” status to Bridges
prior to the LDTC, except when the “Did not complete due to Medical”
status and reason is entered. In this case, the “Did not complete due to
Medical” status and reason will be transmitted to Bridges that night.
Once the “AEP Completed” status has been transmitted to Bridges, it will
become read-only in the OSMIS.
AEP Completed Transmissions in Error
If an “AEP Completed?” “Yes or No” status is sent to Bridges in error, the
MWA needs to do the following: notify the local DHS and the local DHS
JET Coordinator of the error and correction required, and document the
situation in the OSMIS Case Notes.
FIP Applications Denied in Error
For FIP applications denied/or closed in error, OSMIS will receive new
referrals from Bridges. When Bridges sends a new referral for a FIP
applicant who had a previous application that was “denied in error,” the
OSMIS may display an indicator for “denied in error” on the Welfare
Participant History Screen. If the “denied in error” indicator is sent from
Bridges, a “Prior Participation Denied in Error?” field will also display
below the LDTC AEP. However, Bridges may also send new referrals
after a denial/closure in error without the “Prior Participation Denied in
Error?” indicator.
MWAs need DHS staff to verify a denial was in error on new referrals
received without the “denied in error” indicator before any corrective
actions occurs on the OSMIS. All FIP applicants whose applications were
denied in error (as verified by DHS) can resume their 21-Day AEP at their
last completed assignment and do not need to restart at Week 1. When
MWAs are aware of a “FIP Application Denied in Error” occurrence
before the OSMIS receives any new referrals from Bridges, FIP applicants
may be allowed to continue their participation in the AEP assignments.
In order to allow appropriate completion of 21-Day AEP for clients whose
FIP applications were denied/closed in error, MWAs need to complete the
following actions on the new referral:
 Verify with DHS staff the FIP denial/closure in error;
 Document in OSMIS Case Notes the DHS staff verification of the
error;
 Allow FIP applicants to continue participation in their AEP
assignments;
 Enter a “Date Attended Orientation” in OSMIS that is the new referral
date for clients who have stayed engaged in AEP assignments, or enter
the actual date Orientation was attended for clients who did not stay
engaged in AEP assignments.
 Re-enter in OSMIS previously recorded AEP Week 1, Week 2, and
Week 3 completion status data in the new participation record
following receipt of the new referral; and
 OSMIS administrative users change an applicant’s LDTC to an
appropriate date which recognizes previously completed assignments
and facilitates AEP completion promptly.
Action:
MWA officials shall take the appropriate actions necessary to implement
the directives of this policy issuance.
Inquiries:
Questions regarding this policy issuance should be directed to your
Welfare Reform state coordinator.
This policy issuance is available for downloading from the internet
system. Please contact Ms. Pam Vance at (517) 373-6234 for details.
The information contained in this policy issuance will be made available
in alternative format (large type, audio tape, etc.) upon special request to
this office.
Expiration
Date:
GC:NO:pv
Attachments
Continuing
Applicant refused to sign
Distribution of Signed Form: Original remains in case file and a copy must be
given to the applicant at the time of signing.
Local Michigan Works! Logo Here
Week 2 Assignment Plan
Jobs, Education and Training 21-Day Application Eligibility Period
FIP Applicant’s Name (printed)
______ _______
2‐Parent Family (Optional Data) Name of 2nd Parent:
MWA Staff Name (printed):
Recipient ID: __
_____
____________
_______
Date Plan Created: ______
______
Week Begin Date: ___________________ Week End Date: ___________________
Assigned Federal Hours of Participation (check one) □ 20 □ 30 □ 35 □ 55
MWA Staff: Check all Assignments that apply and Assign Hours:

















Assigned Hours:
Assignment Completed:
Job Search/Job Readiness workshop(s) [insert MWA specific info here]:
_____
□ YES □ NO
Resume writing workshop(s) [insert MWA specific info here]:
_____
□ YES □ NO
Interviewing skills workshop(s) [insert MWA specific info here]:
_____
□ YES □ NO
Computer skills workshop(s) [insert MWA specific info here]:
_____
□ YES □ NO
Career/life skills workshop(s) [insert MWA specific info here]:
_____
□ YES □ NO
________________________________________________________________________________________________
Assessment Tests [insert optional MWA specific info here]:
_____
□ YES □ NO
FAST (if not completed during week 1):
_____
□ YES □ NO
Individual Service Strategy (if not completed during week 1):
_____
□ YES □ NO
JET program requirements refresher:
_____
□ YES □ NO
Barrier Removal Activity(ies): [ document assignment below, i.e. childcare, housing, food bank, counseling]
_______________________________________________________________________________________________
______________________________________________________________
_____
□ YES □ NO
High school / GED prep [insert optional MWA specific info here]:
_____
□ YES □ NO
High school Completion/GED prep-Full Time, 18 & 19 year old grantees only: _____
□ YES □ NO
Community service and or Work Experience research:
_____
□ YES □ NO
Job Search Activities:
_____
□ YES □ NO
Employment:
_____
□ YES □ NO
Vocational education:
_____
□ YES □ NO
Other: _______________________________________________________
_____
□ YES □ NO
Next Appointment with MWA Staff: Date_______________ Time: ________ Location: _________________________
I agree to complete activities as assigned above, turn in my documentation as required, contact the MWA if I have
questions or need supportive services, and return for my scheduled appointment. I further understand that if I fail to
complete my weekly orientation assignments, (without an approved absence from the MWA Staff), my request for FIP
benefits may be denied.
FIP Applicant Signature
Date
MWA Staff Signature
Date
Distribution of Signed Form: Original remains in case file and a copy must be given to the applicant at the time of signing.
□ Yes □ No If No, MWA staff must explain in
detail below and supervisor must approve denial. [Attach additional explanation documents as necessary.]
__________________________________________________________________________________________________
__________________________________________________________________________________________________
__________________________________________________________________________________________________
MWA USE ONLY: Applicant satisfactorily completed weekly assignments
MWA Staff Signature
MWA Supervisor Signature
_____ _____ Date
Date
______
Final Distribution of Week 2 Assignment Form: Original remains in case file and a copy of the completed form with the Weekly Assignment
completion status finished must be given to the applicant
Local Michigan Works! Logo Here
Week 2 Assignment Plan
Jobs, Education and Training 21-Day Application Eligibility Period
FIP Applicant’s Name (printed)
______ _______
2‐Parent Family (Optional Data) Name of 2nd Parent:
MWA Staff Name (printed):
Recipient ID: __
_____
____________
_______
Date Plan Created: ______
______
Week Begin Date: ___________________ Week End Date: ___________________
Assigned Federal Hours of Participation (check one) □ 20 □ 30 □ 35 □ 55
MWA Staff: Check all Assignments that apply and Assign Hours:

















Assigned Hours:
Assignment Completed:
Job Search/Job Readiness workshop(s) [insert MWA specific info here]:
_____
□ YES □ NO
Resume writing workshop(s) [insert MWA specific info here]:
_____
□ YES □ NO
Interviewing skills workshop(s) [insert MWA specific info here]:
_____
□ YES □ NO
Computer skills workshop(s) [insert MWA specific info here]:
_____
□ YES □ NO
Career/life skills workshop(s) [insert MWA specific info here]:
_____
□ YES □ NO
________________________________________________________________________________________________
Assessment Tests [insert optional MWA specific info here]:
_____
□ YES □ NO
FAST (if not completed during week 1):
_____
□ YES □ NO
Individual Service Strategy (if not completed during week 1):
_____
□ YES □ NO
JET program requirements refresher:
_____
□ YES □ NO
Barrier Removal Activity(ies): [ document assignment below, i.e. childcare, housing, food bank, counseling]
_______________________________________________________________________________________________
______________________________________________________________
_____
□ YES □ NO
High school / GED prep [insert optional MWA specific info here]:
_____
□ YES □ NO
High school Completion/GED prep-Full Time, 18 & 19 year old grantees only: _____
□ YES □ NO
Community service and or Work Experience research:
_____
□ YES □ NO
Job Search Activities:
_____
□ YES □ NO
Employment:
_____
□ YES □ NO
Vocational education:
_____
□ YES □ NO
Other: _______________________________________________________
_____
□ YES □ NO
Next Appointment with MWA Staff: Date_______________ Time: ________ Location: _________________________
I agree to complete activities as assigned above, turn in my documentation as required, contact the MWA if I have
questions or need supportive services, and return for my scheduled appointment. I further understand that if I fail to
complete my weekly orientation assignments, (without an approved absence from the MWA Staff), my request for FIP
benefits may be denied.
FIP Applicant Signature
Date
MWA Staff Signature
Date
Distribution of Signed Form: Original remains in case file and a copy must be given to the applicant at the time of signing.
□ Yes □ No If No, MWA staff must explain in
detail below and supervisor must approve denial. [Attach additional explanation documents as necessary.]
__________________________________________________________________________________________________
__________________________________________________________________________________________________
__________________________________________________________________________________________________
MWA USE ONLY: Applicant satisfactorily completed weekly assignments
MWA Staff Signature
MWA Supervisor Signature
_____ _____ Date
Date
______
Final Distribution of Week 2 Assignment Form: Original remains in case file and a copy of the completed form with the Weekly Assignment
completion status finished must be given to the applicant