| TO: | ALL COUNTY OFFICES |
| FROM: | JANEL R. LUCK, DIRECTOR |
| SUBJECT: | IMMEDIATE ENGAGEMENT FOR TEMPORARY ASSISTANCE APPLICANTS |
DISCUSSION:
Effective January 1, 2008, all Temporary Assistance (TA) applicants who are not exempt or excluded from work participation activities are required to begin the process to engage in work activities with the Division of Workforce Development (DWD) as an eligibility factor prior to approval of the TA application. This new policy is referred to as Immediate Engagement and is required by 13 CSR 40-2.370. All TA applicants who do not meet an exemption or exclusion from work participation activities must meet with a DWD Career Assistance Program (CAP) case manager and complete an Individual Employment Plan (IEP) prior to approval of the TA application or have good cause for not doing so.
Family Support Division (FSD) Responsibilities
FSD staff will complete an initial assessment at application and make the appropriate work participation requirement code entry on the TA Work Requirement (COMPACT/FM8B) screen in FAMIS. If the applicant meets an exemption or exclusion, the appropriate code is entered into FAMIS and the individual is not referred to DWD and is not subject to Immediate Engagement. The work requirement code Pending Assessment (code P) is used when the assessment has not been completed. Use this code until it has been established the individual is mandatory, exempt, or excluded from complying with work activities, but no longer than thirty (30) days. See Section 0255.005.00 for a list of exemptions from work requirement and Section 0255.010.00 for a list of exclusions.
At the application interview the Eligibility Specialist will be responsible for the following in addition to verifying the applicant meets all other Temporary Assistance application eligibility factors (Refer to General Information manual):
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Determine work participation status by completing an initial assessment.
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Explain Immediate Engagement - Participation in Immediate Engagement is a requirement to be approved for Temporary Assistance. Failure to participate will result in the application being rejected. Inform the applicant that a meeting with a CAP case manger is required to complete an assessment and an IEP. This meeting could take up to two (2) hours.
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Give the applicant an Immediate Engagement pamphlet
and answer any questions he or she may have. Link to the pamphlet to print copies of the pamphlet until the initial supply is received in the local office. Order additional supplies through the warehouse. -
Provide the applicant a Request for Information (FA-325) to contact a local Career Assistance Program (CAP) service provider and comply with Immediate Engagement within ten (10) days.
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Provide the applicant a copy of the area Career Assistance Program (CAP) listing. Circle the location nearest the applicant. Explain that the mandatory applicant can participate at any CAP service agency in the State of Missouri. Ask the applicant if there is any possibility he or she would need to visit a CAP service provider outside of the area, and if so give a statewide CAP listing to the applicant. The listings of CAP service providers are located on the FSD Intranet Site under Temporary Assistance, then Resource Links.
- Enter the correct work requirement code on the TA Work Requirement (COMPACT/FM8B) screen.
Applicant Referral to DWD
Beginning January 1, 2008, all TA applicants who are mandatory to participate in work activities will be referred to the DWD electronically. This includes applicants whose needs and income are included in the Eligibility Unit (IN) and who have one of the mandatory work requirement codes of D, T, F, and J entered by the Eligibility Specialist on the TA Work Requirement (COMPACT/FM8B) screen in FAMIS.
NOTE: Applicants with a pending application who applied with an application date prior to January 1, 2008, are not subject to Immediate Engagement.
Volunteers and applicants who meet an exemption, exclusion, or have a pending assessment will not be referred to DWD during the application process as they are not subject to Immediate Engagement.
The DWD CAP case manager sends FAMIS an electronic code of compliance or good cause when the applicant either complies with Immediate Engagement or the CAP case manager determines the applicant has good cause for not doing so. If compliance for Immediate Engagement or good cause is not completed within ten (10) calendar days of the TA application, until programming changes are completed in FAMIS the Eligibility Specialist will send the applicant a second Request for Information (FA-325) requesting all necessary verification to process the TA application.
If the applicant does not comply or does not have good cause for not complying, the TA application is rejected automatically by the FAMIS system on the thirtieth (30th) day with the rejection reason of failed to comply with Immediate Engagement (IME). The reason on the Claimant Action Notice (FA-150) will read, “Failed to comply with Immediate Engagement.”
Two Parent Eligibility Units (EUs)
A two parent eligibility unit for the purpose of Immediate Engagement is a household with two parents whose needs and income are included in the eligibility unit (IN) and who have been determined to be mandatory for work participation requirement (codes D,T, F, and J). Both parents will be referred electronically to DWD in the nightly batch. Only one of the parents must comply or have good cause not to comply with Immediate Engagement in order for the TA case to be approved. No further action is necessary by the other parent during application. Both parents are to be encouraged to participate. Once the TA application is approved there is no change in current policy regarding work participation requirements.
If one of the parents is exempt or excluded, the eligibility unit is not considered a two parent household for Immediate Engagement. The mandatory parent is referred to DWD and must comply or have good cause for non compliance prior to approval of the TA application.
Add-A-Person
A second parent added to an active TA case is NOT subject to Immediate Engagement.
When a second parent is added to a pending TA application, the second parent is subject to Immediate Engagement unless he or she meets an exemption or exclusion to work participation requirement. A payee who was exempt or excluded prior to the addition of the second parent may become subject to Immediate Engagement depending upon the circumstances. Look at the exemption code given to the payee to determine whether or not the exemption would still apply with the addition of a second parent in the household. The Request for Information (FA-325) must give the applicants ten (10) days to comply even if the deadline is after the 30th day from the application date.
EXAMPLE: Mom applies for herself and her daughter on January 14, 2008. Mom is exempt due to the child being 6 months old. The father of the child moves in the EU and the mom reports this to her Eligibility Specialist on February 1, 2008. A Request for Information (FA-325) is given to the applicant instructing both parents to comply with Immediate Engagement within 10 days. The TA application is not rejected for failing to comply with Immediate Engagement until after the Request for Information (FA-325) expires.
Career Assistance Program Role
TA applicants can go to the CAP service provider location of their choosing.
During the initial visit at the CAP service provider the TA applicant will be required to complete the following to be in compliance with Immediate Engagement:
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Assessment: The CAP case manager will complete an assessment with the TA applicant.
- Individual Employment Plan (IEP): The TA applicant and the CAP case manager will work together to develop the IEP. When the CAP case manager enters the compliance in Toolbox, the system will electronically send the compliance code to FAMIS that night.
The total time required to complete an assessment and an IEP with the CAP services provider should not exceed two (2) hours. If the applicant is unable to complete the process during the initial meeting, the CAP services provider will schedule another appointment with the TA applicant as soon as possible.
In rare cases, and when there is no other option available, the TA applicant will be allowed to complete the Immediate Engagement process over the telephone with the CAP case manager.
Good Cause
In certain situations, the TA applicant may be granted good cause for non-compliance with Immediate Engagement. To qualify as a good cause reason, the circumstances must prevent the TA applicant from complying within the 30 day application period. Therefore, a TA applicant may claim good cause initially, but with assistance from the FSD Eligibility Specialist or the CAP case manager, the TA applicant may be able to comply with Immediate Engagement within the allowed 30 day time frame. The TA applicant must work with the Eligibility Specialist or CAP case manager to pursue every option available for compliance, prior to the FSD or CAP case manager granting good cause. Good cause for non compliance with Immediate Engagement includes:
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Court required appearance or incarceration that prevents the TA applicant from complying with CAP. Documentation of court appearance or incarceration must be obtained from the applicant or from other sources.
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Emergency family crisis which renders participation unreasonable. The crisis must prevent the TA applicant from complying with CAP. Examples include, but are not limited to:
- The applicant's home is destroyed by fire resulting in temporary living arrangements.
- The applicant, applicant's child or other family member is seriously injured or ill.
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The applicant is a crime victim.
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Breakdown in transportation arrangements with no readily accessible alternate means of transportation that prevents the TA applicant from complying. This includes but is not limited to the following reasons:
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The applicant has no mode of transportation or limited transportation to the provider location and cannot meet the CAP case manager at another location; and the case manager is unable to meet at the applicant's home.
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Breakdown in child care arrangements or unavailability of child care for a special needs child. Explore this good cause reason with the TA applicant to determine if child care is required in order to comply with Immediate Engagement. Examples of reasons for needing child care are:
- Applicant is caring for an ill child and cannot find child care.
- Applicant feels it is inappropriate or problematic to bring the child(ren) with him/her and is unable to find suitable child care.
NOTE: TA applicants may bring their child(ren) with them when they visit a CAP service provider for the purposes of Immediate Engagement. This good cause reason may apply when the TA applicant feels that it is not appropriate or reasonable to bring his or her child(ren) to the CAP provider location.
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Lack of identified social services necessary for participation. The circumstances requiring social services and efforts to obtain the services must be documented on the TA Work Requirement Screen (COMPACT/FM8B). Examples include but are not limited to:
- Drug and/or alcohol abuse problem for which they have not been able to obtain counseling.
- Medical and/or mental health issues for which they have not been able to receive medical attention.
The applicant and his/her family do not have shelter and they have not been able to receive the necessary help to obtain shelter.
- DWD is not able to provide services within 30 days.
If a reasonable effort is made by the TA applicant, but the CAP service provider is not able to complete the assessment and IEP, the applicant will not be penalized.
EXAMPLE: Ms. Williams makes a Temporary Assistance application at the Osage County Office on Thursday January 17, 2008. Ms. Williams is determined mandatory to participate in Immediate Engagement. Based upon the CAP location listings it is determined that a CAP case manager is at the Osage County Family Resource Center on Thursdays from 8:00 AM to 3:30 PM. Ms. Williams goes to the Resource Center on the same day she applied with enough time allowed to complete the Immediate Engagement requirements. Ms. Williams waits for an hour because the CAP case manger is keeping an appointment with another TA applicant. The CAP case manger explains to Ms. Williams that she has appointments scheduled up until 3:30 that day but will make an appointment with her for the next Thursday. An appointment is agreed on for Ms. Williams on January 24, 2008, at 8:30 AM. On January 24, 2008, Ms. Williams does not keep her scheduled appointment. On January 28, 2008, a second Request for Information (FA-325) is sent to the applicant. Ms. Williams contacts her FSD Eligibility Specialist and explains that she went to the CAP service provider on January 17, 2008, but was not able to be seen and that the CAP case manager set up an appointment time to see her the next week. Ms. Williams explains that she was not able to keep the appointment on the scheduled day and time. The Eligibility Specialist contacts the CAP case manager and because Ms. Williams made a reasonable effort to comply with Immediate Engagement, a good cause reason that DWD is not able to provide services within 30 days is granted to Ms. Williams.
If the applicant claims good cause for not cooperating with Immediate Engagement during the application interview, the Eligibility Specialist must assist the applicant in contacting the CAP case manager to make that determination. If the applicant claims good cause after the date of application, either the FSD Eligibility Specialist or the CAP case manager can make the good cause determination and enter a good cause finding.
FAMIS System Changes
TA Work Requirement (COMPACT/FM8B) Screen
Immediate Engagement is shown in the FAMIS system on the TA Work Requirement (COMPACT/FM8B) Screen. The TA Work Requirement (COMPACT/FM8B) screen is now displayed in the controlled flow after the TA/MA Information (TAINFO/FM8D) screen and before the Supercase Eligibility Unit Summary (FM30) screen.
Two additional fields are added to the TA Work Requirement (COMPACT/FM8B) screen. The two fields are:
- Compliance/Good Cause Field, and
- Date Field
Compliance/Good Cause Field
The purpose of this field is to indicate if the applicant complied with Immediate Engagement or has good cause for not complying. Compliance/ Good Cause Codes include:
01 - Court Required Appearance or Incarceration
02 - Emergency Family Crisis
03 - Breakdown in Transportation
04 - Breakdown in or Unsuitable Child Care
05 - Lack of Identified Social Services
06 - DWD is not able to provide services within 30 days
99 - Complied with Immediate Engagement
NOTE: Compliance code 99 and the good cause reason code 06 “DWD is not able to provide services within 30 days” are not allowable entries by FSD staff. These codes may only be entered by DWD. An error message of: “BB01V_BE: System Code Entered-May Not Be Entered By User” will appear on the screen if these codes are entered on the screen by an FSD Eligibility Specialist.
Date Field
When FSD staff enters a good cause reason, the date the good cause was established is entered in this field.
When compliance or good cause is determined by a CAP service provider and entered into Toolbox, the date the overnight file is received will appear in this field.
The application will be approved automatically in five days if the applicant complies or has good cause and all other eligibility factors for TA are met and verified. If the applicant fails to comply and does not have good cause for not complying with the requirements of Immediate Engagement, FAMIS will take action to reject the TA application on the night of the 30th day from the date of application.
Technical Eligibility Detail (TECHDETL/FMM4) Screen
Immediate Engagement is added as an Eligibility Factor on this screen. To review the Immediate Engagement factor, enter an “S” on the command line and select PF6 Detail to go to the TA Work Requirement screen where the Work Requirement Indicator and the Compliance/Good Cause fields may be reviewed.
This screen will be updated based upon entries on the TA Work Requirement (COMPACT/FM8B) screen.
Reminders
A reminder will be sent to the Eligibility Specialist when FAMIS receives one of the six (6) good cause reasons entered in Toolbox. The reminder will read:
CODE DESCRIPTION
041 Good Cause for not complying with Immediate Engagement was determined by CAP case manager.
The Eligibility Specialist can then determine the specific good cause reason by going to TA Work Requirement (COMPACT/FM8B) screen.
NECESSARY ACTION:
- Review this memorandum with appropriate staff.