11-001.D.   San Diego County- WTW 24-Month Time Clock Questions and Answers

 

Table of Content

Section

Questions and Answers

11-001.D.1

Curing Sanction Retroactively and Orientation

11-001.D.2

WPR and Optional Core Activities during the WTW Clock

11-001.D.3

Young Child Exemption

11-001.D.4

SIPs and VTR

11-001.D.5

Earnings Reported by Sanctioned Individuals

11-001.D.6

WTW 29 Requirements

11-001.D.7

WTW Clock and Plan Development

11-001.D.8

Job Search Time Limit

11-001.D.9

CW 2205

11-001.D.10

WTW Plan for Employed Participants

11-001.D.11

WTW 2 for Exempt Volunteers

11-001.D.12

Prioritizing Client Contact

11-001.D.13

WTW Clock for 2-parent Families

11-001.D.14

ESL as Core Activity

11-001.D.15

Students Curing Sanctions Retroactively

11-001.D.16

Counting Exempt Volunteer Hours

11-001.D.17

Mid-month Changes and Their Impact on WTW Clock

11-001.D.18

WTW Clock and CW Time on Aid

11-001.D.19

WTW Clock and CW Time on Aid

11-001.D.20

WTW Plans Signed in December 2012

11-001.D.21

Curing Sanctions and Employment Hours from QR7/SAR7

11-001.D.22

Good Cause and WTW Clock

11-001.D.23

Job Search Sessions and WTW Clock

11-001.D.24

Timeframe to Modify a WTW Plan

11-001.D.25

ECM Timeframes for Curing Sanctions Retroactively

 

11-001.D.1
Curing Sanction Retroactively and Orientation
 
 
 
 
 
 
 
 
 
 
 
 
Top
 

Q. If a participant is sanctioned for failing to attend orientation (ORE) and they subsequently provide verification of work hours to cure the sanction, are they still required to attend ORE? Do they need to sign a WTW 29 (Plan to Stop a WTW Sanction)?

 

A. This client may be able to cure sanctions retroactively based on reported employment, but he/she still has to sign a new WTW plan, which includes Orientation/Appraisal.

 

See CPG 10-005 D. Appraisal for instructions related to the Appraisal of employed participants.

 

Although not required to cure sanctions for previous months, a WTW 29 will be required if the client wants to cure his/her current and future month sanction.

 

There are no changes to current non-compliance procedures which apply any time a participant fails or refuse without good cause to participate in assigned activities which are part of developing a plan.

 

11-001.D.2
WPR and Optional Core Activities during the WTW Clock
 
 
 
 
 
 
 
 
 
 
Top
 

Q. How can the county meet WPR if the ECM cannot require core hours within the 24 month WTW clock?

 

A. The ECM can explain to the client the benefits of participating in core activities, which include but are not limited to:

 

·         Acquiring the necessary vocational education, job skills, training and work experience which are essential in moving toward self-sufficiency, as well as removing barriers to employment

·         Un-ticking WTW Clock and preserving months to be used at a later time should the client be unable to participating in core activities

·         Planning educational activities to include core hours such as employment, work study, WEX, community services, etc. will help participants in their transition from being F/T students to becoming F/T employed and self-sufficient

 

Advising participation in core activities will improve the county WPR in addition to helping clients maximize their WTW services during their time on aid, which must be the ECM’s primary concern.

 

11-001.D.3
Young Child Exemption
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Top
 

Q. Since ABx44 exemption ended 12/31/12, how should we be processing the one-time Young Child exemption for those who qualify after 01/01/13?

A. The ECM will discuss the availability of the new Young Child exemption with any individual that meets the criteria for this exemption during the WTW Orientation/Appraisal/Evaluation appointment, or at any other stage of participation if deemed necessary.

The ECM will:

·         Document in CalWIN Case Comments that the Young Child exemption was offered and participant’s decision to use the exemption,  or to save it for future use, or to be used by the other parent (two-parent families)

·         Follow existing procedures to notify Eligibility staff of client’s request.

 

During the development of a new or modified WTW plan or during the Reengagement Evaluation appointment (or at any other stage of participation if deemed necessary), the ECM is required to explain to the participant that there are exemption criteria to which he/she may qualify.

 

Summary:

 

Exemption type

Description

Age

A child under age 16; or

An individual age 60 or over.

School Attendance

An individual age 18 and under, who is attending full time high school or a vocational/technical program.

Disability impairing employment and participation

An individual who has a medically verified disability impairing employment and participation, that is expected to last at least 30 days

Care of an Ill or Incapacitated Member of the Household

An individual whose presence in the home is required because of the illness or incapacity of another (aided or unaided) member of the household

Cal-Learn Participants

(See CPG 15-000 B.)

An individual who is required to participate in, is participating in, or is exempt from the Cal-Learn Program.

Care of a Child

A parent or other relative who has primary responsibility for providing care to a child 12 weeks of age or under.

New Young Child Exemption

effective January 1, 2013

A parent or other relative who has primary responsibility for providing care to a child from birth through age 23 months.

This exemption is limited to once-in-a-lifetime and will ONLY be applied at the discretion of the individual, as documented per their CalWORKs Exemption Request Form (CW 2186A).

See CPG 10-020 A.4 for more information and CPG 10-020 A.5 for two-parent households.

Domestic Violence Waiver

For more information regarding Domestic Violence and Good Cause determinations see CPG 40-100 O and CPG 10-020 B

 

See CPG 10-020 A. for additional exemptions.

 

11-001.D.4
SIPs and VTR
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Top
 

Q. For existing SIP participants, new CPG chapters indicated that the VTR 12-month lifetime limit will now be in effect as of 01/01/13.

 

Is there additional action needed by ECMs in order to notify existing SIP participants? Will the VTR 12-month lifetime limit begin after the clients sign a new plan and understand the changes?

 

A. There are no changes to the current definition of VTR and its lifetime limit of 12 months. See CPG 10-001 H. for definitions of Welfare-to-Work activities that meet CalWORKs federal standards.

 

If a client has already used his/her VTR 12 months by December 31, 2012, he/she will not be given a new 12-month VTR period after 1/01/13 or when a new or modified plan is signed after 01/01/13.

 

Therefore, if the student has already used his/her VTR 12-month lifetime limit, his/her participation in a SIP or other educational programs will be considered as ERE or ERT (non-core) as defined in CPG 10-005 H. WTW Activities.

 

The ECM will document in case record when VTR regulations are explained to the participant and when the VTR 12-month time limit is reached.

 

Note: VTR 12-month lifetime limit does not apply to individuals who are exempt-volunteers.

 

11-001.D.5
Earnings
Reported by Sanctioned Individuals
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Top
 

Q. How often will Employment Services staff be notified of any sanctioned participants who submit employment hours or earnings on his/her QR7/SAR7 or prior to his/her annual CW redetermination?

 

CPG 10-001-F states that the notification will only be done during the first quarter of 2013, but 2/20/13's County training stated that it will be done continuously. Please clarify.

 

A. Effective January 1, 2013, any reported earnings by a sanctioned individual must be reviewed to determine if sanction can be cured retroactively up to 1/1/2013.

 

Each month Eligibility Operations provides automated reports to identify:

·         Employment hours and/or earnings entered in CalWIN as reported by sanctioned individuals after 1/1/2013

·         Sanctioned individuals who may be able to cure sanctions based on reported employment hours and/or wages

 

Note: The ECM is required to contact sanctioned individual or employer to obtain employment hours for each month the sanction may be cured.

 

Automated reports do not eliminate Eligibility staff’s responsibility to notify the ECMs within the timeframes listed in CPG 10-001 F. WTW 24 Month Time Clock & Notification Requirements/Transitioning Process when a sanctioned parent/caretaker reports employment and/or earnings with their QR7/SAR7, or during their CW redetermination, or at any time within their CW certification period.

 

11-001.D.6
WTW 29 Requirements
 
 
 
 
 
 
Top
 

Q. PG 10-001 F states that, if a sanction is cured for current or prior months because the participant meets the new hourly requirements, then that "client is not required to sign a sanction curing plan".

 

However, the next section explains the curing process by stating that the EC must "provide a copy of the WTW 29 to the HSS who will use that information to determine the appropriate date for restoration of aid". Is the WTW 29 needed or not?

 

A. WTW29 is not required when sanctions are cured retroactively, but is required if the client is also curing a sanction for the current month.

 

11-001.D.7
WTW Clock and Plan Development
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Top
 
 

CPG 10-001-E stated that "A month may be un-ticked if a participant is assigned to Job Search, Job Readiness, Assessment, or developing a new or modified WTW plan".

 

Scenario #1:

In February 2013 a participant signs a modified WTW plan which includes core activities, which are expected to end as of April 15, 2013. The client meets with the ECM on 4/10/13. A reassessment is completed, and client signs a modified plan, which does not include core activities.  The 24-month clock does not tick for February, the month in which the client signed the plan, in addition to March because he/she is meeting weekly participation and core hour requirements.

Will the WTW 24-Month Time Clock tick or not tick for April 2013 in the following scenarios?

 

Q. Will the WTW 24-Month Time Clock tick or not tick for April 2013 in the following scenarios?

 

A. If in April this client participates in less than his/her required weekly core hours this month will tick because federal participation and core hour requirements will not be met each week. 

                         

Scenario #2:

A participant signed a modified WTW plan in February 2013 with 30 weekly hours in non-core activities, which are expected to end as of April 15, 2013. The participant meets with his/her ECM on 4/10/13. A reassessment is completed, and he/she signs a modified plan with 30 weekly hours in core activities.

 

The WTW 24-Month Time Clock clock will tick for March 2013 (no core activities). The 24-month clock will not tick for May 2013 (core activities).

 

Q. Will the WTW 24-Month Time Clock tick or not tick for April 2013, during which a reassessment was completed and a modified WTW plan was developed?

 

A. April also will not tick because during that month the client is developing his/her WTW plan.  

 

Scenario #3:

A participant signed a modified WTW plan in February 2013 for non-core activities, which are expected to end as of April 15, 2013.

The participant meets with ECM on 4/10/13. A reassessment is completed, and she signs an updated plan for different non-core activities.

 

The 24-month clock will tick for March 2013 (plan signed for non-core activities in February), and it will tick for May 2013 (plan signed for non-core activities in April).

 

Q. Will the WTW Clock tick or not tick for April 2013, month during which the participant completed reassessment, and a modified WTW plan was developed?

 

A. April also will not tick because during that month the client is developing his/her WTW plan. See scenario #2.

 

11-001.D.8
Job Search Time Limit
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Top
 
 

Q. CPG states that Job Search, Job Readiness, Mental Health Services, Substance Abuse Services and Domestic Abuse Services have a limit of "up to 4 consecutive weeks, which can be extended up to 12 weeks". Does this mean the limit is per activity, or is the limit for the total for all of the 5 activities?

 

A. Federal guidelines include Substance Abuse/Family Violence/Mental Health Services as part of Job Readiness (core activity) which is limited to 4 consecutive weeks and can be extended up to 12 weeks.

 

If Substance Abuse/Family Violence/Mental Health Services are still needed after the 12 week limit, participation in these activities would be allowed but the activities would be considered non-core activities as they would fall beyond the federal limit of “up to 12 weeks” for Job Readiness.

 

See CPG 10-001 H. for conditions which allow for Job Search extension beyond the federal time limits.

 

See CPG 11-001.A.for Job Search conditions which un-tick the WTW 24-Month Clock beyond the federal limit.

 

 

11-001.D.9 CW2205
 
 
 
 
 
 
 
 
 
Top
 

Q. The training on 2/20/13 stated that the CW2205 will need to be sent to any participants that might not have received this notice as of December 1, 2012.

 

Can our Scheduling Clerks send the CW2205 to participants that are being scheduled for Orientation (Intake/Appraisal)?

 

Can our Sanction Clerks send the CW2205 to all NONC/Sanction requests that they process? If "yes", please provide CW2205 for ResCare to use.

 

A. Yes, scheduling clerks and sanction clerks may send Informing Notice CW2205 if this is the procedure chosen internally by PCG and ResCare. CW2205 is available in CalWIN.

 

 

11-001.D.10
WTW Plan for Employed Participants
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 

Q. CPG 10-001-F states that "ECMs are required to develop WTW plans for all employed clients whose CalWORKs benefits are approved on or after 01/01/13".

 

Does this mean that a WTW 2 plan form needs to be completed for the employment activity? If so, this will negate previous directive that a WTW2 plan does not need to be signed if the participant's initial activity (and has no previous plans) is Full Time Employment. Is this correct?

 

A. CPG 10-005 G. WTW Plan states that all participants are required to sign a WTW Plan Activity Assignment (WTW2), except participants who are:

·         Exempt volunteers and choose to participate in WTW activities; and

·         Fully employed and whose only activity is full-time employment (FTE) or self-employment (SLE) at the time the development of the WTW Plan would be appropriate. 

 

This applies to existing CW recipients.

 

New CW recipients are required to sign a new plan even when they are full time employed.

 

11-001.D.11
WTW 2 for Exempt Volunteers
 
 
 
 
 
 
 
Top
 
 
 
 

Q. Are ABx44 exempt/volunteer individuals required to complete the "Total Hourly Requirements" section of the new WTW 2 plan form (located at bottom of page 1 of 4)?

 

A. The client is required to “initial” the Total Hourly Requirements section (bottom of page 1 of 4) to confirm that he/she understands that the WTW plan, which they signed as mandatory participants, will count toward the WTW Clock.

 

Exempt volunteers will not be required to “initial” that section because their plan will not count toward their WTW 24-Month Clock due to their exempt status.

 

 Once the client is no longer exempt, he/she will be required to sign a new plan as mandatory participant, therefore he/she would have to complete and “initial” the Total Hourly Requirements section.

 

11-001.D.12
Prioritizing Client Contact
 
 
 
 
 
 
 
 
 
 
Top
 
 

Q. Is there a prioritization flow that the county wants the ECMs to follow to contact all clients by June 30, 2013?

 

A. The following prioritization list is suggested:

·         Participants who have less than 24-months left on their CW TOA Clock

·         Participants who have more than 24 months left on their CW TOA Clock

·         Sanctioned clients who are now meeting weekly participation requirements (i.e. a single parent with child under 6 who is working 22 hours and was sanctioned because not meeting the 32 hours will now be in compliance with new 20 hour requirements and no longer sanctioned )

·         Sanctioned clients who are partially participating

·         Sanctioned clients with no participation hours.

 

Eligibility Operations provides automated monthly reports to facilitate the contact sequencing.

 

11-001.D.13
WTW Clock for 2-parent Families
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Top
 
 

Q. If in a 2-parent household one parent is meeting the participation requirements of 35 weekly hours based only on his/her hours and the second parent is not participating, how is the WTW clock affected for each parent?

 

A. Each individual has his/her own WTW Clock, which can tick or un-tick individually, if one of the conditions which stops the clock applies only to one of the parents.

 

These conditions, except for medically verified disability, will not change the participation and core hour requirements for a 2-parent family (35/30), if applicable only to one parent.

 

Medical disability is the only condition which will change the participation and core hour requirement for the non-exempt parent, who will be required to participate at the single parent level (20/30 hours) based on the age of the children in the home.

 

Parents can combine/share their weekly participation and core hours.

 

If the 2 parents are sharing hours and are meting...

Then the WTW Clock will...

Only weekly participation hours (35)

Tick for each parent, unless one parent is meeting a condition which stops the clock

Weekly participation and core hours (35/30)

Un-tick for both parents

 

 

11-001.D.14
ESL as Core Activity
 
 
 
 
Top
 

Q. Is English-as-Second Language (ESL) a core activity?

 

A. ESL meets the federal definition of Vocational Educational Training (VTR) which is a core activity with a 12-month lifetime limit when:

·         The participant’s educational history, appraisal and assessment shows a need for ESL classes to be included in their educational vocational training to ensure successful performance in a particular vocation. Example: Vocational ESL.

 

11-001.D.15
Students Curing Sanctions Retroactively
 
 
 

Q. Can sanctions be cured retroactively when clients reported attending college/school or participation in any other WTW activities?

 

A. Sanctions can be cured retroactively only based on verified employment/earnings reported by the client.

 

A student can cure sanctions retroactively only if he/she reported employment which meets weekly hourly participation requirements.

 

11-001.D.16
Counting Exempt Volunteer Hours
 
 
 
Top
 

Q. In a 2 parent household, one parent is exempt volunteer. Can we count his/her hours to meet weekly participation requirements?

 

A. Yes, both parents’ hours can be combined if the family is subject to the 2-parent participation requirements (35 weekly hours).

 

If one parent is exempt due to a verified medical condition, the other parent will be required to participate at the 1-parent level (20/30 hours depending on children’s age), therefore parents’ hours cannot be combined.

 

11-001.D.17
Mid-month Changes and Their Impact on WTW Clock
 
 
 
 
Top
 

Q. How do we track a month toward the 24-Month Time Clock when registration status (exemption, non-compliance, sanctions) or participation requirements in core or non-core activities changes during the month (example child turned 6)?

 

A. CDSS has clarified that, under certain conditions, Job Search and Good Cause will un-tick the WTW 24 Month Time clock if applicable to at least 50% of monthly participation hours. See CPG 11-001.A.

 

Regarding a single parent whose child turned 6, the ECM will change his/her WTW participation hour requirements from 20 to 30 weekly hours the month following the child’s birth.

 

11-001.D.18
WTW Clock and CW Time on Aid
 
 
 
 
 
 
 
 
 
 
Top
 
 

Q. Does the WTW 24-Month Time Clock add extra months to the client’s CW Time on Aid (TOA) Clock?

 

A. No. The CW TOA Clock and the WTW 24-Month Time Clock run at the same time. The WTW 24-Month Time Clock does not add months to CW TOA Clock.

 

Examples:

 

If client has...

Then he/she will have…

More than 24 CW TOA months

24 months on their WTW Clock and then he/she will be required to meet participation and core hours for the remaining CW TOA months

Less than CW TOA months (example 10 CW months)

Have 10 months on the WTW Clock  and then be CW timed-out

 

11-001.D.19
Arranging Child Care
 
 

Q. Would Assign Child Care (ACC) be a core activity?

 

A. No. Arranging Child Care (ACC) is not listed as being part of Job Search/Job Readiness which is considered a federal core activity within specified time limits.

 

11-001.D.20
WTW Plans Signed in December 2012
 
 
 
 
 
 
 
 
 
 
 
Top
 

Q. If a client signed a WTW plan in December 2012, does he/she has to sign a new plan?

 

A. If the client’s previous plan does not meet the new weekly participation hour requirements or the client wants to change the plan to include/exclude core activities, a modified plan must be developed and signed by the client.

 

If the client’s plan meets new requirements and the client agrees to keep his/her existing plan, then he/she will sign the new WTW 2 form at the next scheduled appointment.

 

Note: In both cases, the WTW 24-Month Time clock will start the first month after the date the modified plan is signed or the existing plan is agreed upon.

 

An exception would be if the participant has less than 24 remaining months of CalWORKs (CW) eligibility. In this case the WTW 24-Month Time Clock starts as of 1/1/2013.

 

11-001.D.21
Curing Sanctions and Employment Hours from QR7/SAR7
 
 
 
 
 
 
 
 
 
 
 
Top
 

Q. A sanctioned client reported earnings with the QR7/SAR7/SAR7, or at any other time, and he/she qualifies to cure sanctions retroactively to January 2013.

 

Can we use the employment hours from the QR7/SAR7 Data Month for each of the months that may be cured?

 

A. No. Each month would need to meet weekly participation requirements in order for the sanction to be cured. The ECMs would need to contact client/employer to obtain information/verification of hours worked each month, if not already available in the county’s imaging system.

 

Client is required to report gross earnings with his/her QR7/SAR7.

 

If gross earnings are available from the QR7/SAR7 but employment hours cannot be obtained from client/employer, the ECM can use the state minimum hourly wage to compute monthly participation hours, which then would be averaged weekly to determine which month can be cured based on the new weekly participation hourly requirements.

 

11-001.D.22
Good Cause and WTW Clock
 
 
 
 
Top
 

Q. Which are the Good Cause reasons which will stop the WTW Clock?

 

A. All Good Cause reasons for not participating, which are listed in    CPG 10-020 B. Good Cause for Not Participating will stop the WTW Clock.

 

As clarified by the state, in order to un-tick the WTW 24-Month Time Clock Good Cause must be applied in a month at least to 50% of the client’s monthly participation hours. See CPG 11-001.A.

 

 

11-001.D.23
Job Search Sessions and WTW Clock
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Top
 

Q. Does the WTW clock tick if client participates in a 2nd or 3rd session of Job Search/Job Readiness?

A. Participation in Job Search activities may stop the participant’s  WTW 24-Month Time Clock when any of the following conditions are met:

 

Condition # 1:

 

The client is participating in Job Search activities which are meeting the following federal core activity standards:

·         Activity is limited to four consecutive weeks, not to exceed:

o    6 weeks in a 12- month period; or

o   12 weeks in a 12-month period when California is considered a Needy State as per CPG 10-005 E.

Condition # 2:

 

Job Search activities are part of the development of the participant’s WTW plan.

Condition # 3:

 

The client’s WTW plan includes Job Search activities which are at least 50 percent (%) of the participation hours in the month:

·         This is allowed for two months in a 12-month period and

·         The client must first exhaust his or her Job Search federal allowance described under Condition #1

 

See CPG 11-001.A.

 

11-001.D.24
Timeframe to Modify a WTW Plan
 
 
 
 
Top
 

Q. Does the 90-day timeframe to develop a WTW plan apply to the modification of an existing plan?

 

A. CPG 10-005 G. WTW Plan states that participants are required to sign a WTW Plan after assessment, but not more than 90 days from the date that an individual’s eligibility for cash aid is determined or the date that the recipient is required to participate in WTW.

 

The 90-day timeframe to sign a plan applies to the date CalWORKs was granted for existing clients, or the date they were first required to participate, not to the date a plan is modified.  

 

11-001.D.25
ECM’s’ Timeframes for Curing Sanctions Retroactively
 
 
 
 
 
 
 
 
 
 
Top
 

Q. What is the timeframe for an ECM to evaluate if sanctions can be cured retroactively after a referral is received from Eligibility Staff regarding reported employment by a sanctioned individual?

 

A. The ECM is required to initiate the process of curing sanctions retroactively within 5 business days from the date the referral from the FRC/WTW Liaison is received.

 

This process may include contacting clients and/or employers to obtain and verify actual hours worked each week during the sanctioned month which is being re-evaluated.

 

Once a determination is made by the ECM, ECMs are required to notify the HSS to lift sanctions retroactively for specific months using the current communication procedures listed in CPG 10-005 J.ESR and Escalation Process.

 

The same processing timeframe would apply if a sanctioned client reports employment directly to the ECM.