M E M O R A N D U M

IM-32  04/01/99  FOOD STAMP METP POLICY


SUBJECT:
FOOD STAMP MISSOURI EMPLOYMENT AND TRAINING POLICY

   FOOD STAMP MANUAL REVISION #10

   Section 1105.025.05, page 1105-16
   Section 1105.025.05.05, page 1105-16
   Section 1105.025.05.10, page 1105-19
   Section 1105.025.05.15, page 1105-20
   Section 1105.025.10, page 1105-21
   Section 1105.025.15, page 1105-22
   Section 1105.025.15.05, page 1105-23
   Section 1105.025.15.10, page 1105-25
   Section 1105.025.15.15, page 1105-25
   Section 1105.025.15.20, page 1105-26
   Section 1105.025.15.25, page 1105-27
   Section 1105.025.25, page 1105-28
   Section 1105.025.30, page 1105-29
   Section 1105.025.30.05, page 1105-30
   Section 1105.025.30.10, page 1105-30
   Section 1105.025.30.15, page 1105-31
   Section 1105.025.30.20, page 1105-31
   Section 1105.025.30.25, page 1105-32
   Section 1105.025.35, page 1105-33
   Section 1105.025.40, page 1105-34
   Section 1105.025.60, page 1105-39
   Section 1105.030.00, page 1105-39
   Section 1105.035.00, page 1105-39
   Section 1105.035.05, page 1105-40
   Section 1105.035.10, page 1105-41
   Section 1105.035.15, page 1105-41
   Section 1105.035.20, page 1105-42
   Section 1105.035.25, page 1105-42
   Section 1105.035.30, page 1105-43
   Section 1105.035.35, page 1105-44

   FORMS MANUAL REVISION  #9

   Revised METP 28, 28A, 29, 30, and 31

   Revised IM-101, Household Member Age 16-60 Assessment, and Instructions

 
DISCUSSION:
The Food Stamp Program supports working families.  The Missouri Employment and Training Program (METP) offers many opportunities to unemployed and under-employed food stamp participants.  This memorandum contains policy revisions and clarifications to the employment and training policy.  Changes include:
  •  changing the IM-101 to an assessment form,
  •  adding policy on how to complete the assessment, 
  •  adding Workforce Linkage to the Job Search Training component,
  •  adding a new section which provides guidance on referring mandatory work registrants to an employment and training component,
  •  implementing a new process for making referrals to JTPA,
  •  changing the conciliation period for noncompliance to ten calendar days, and
  •  removing policy regarding economic head of household designation.
All food stamp participants age 16 to 60 who do not meet an exemption or exclusion must be registered for work.  Some may be selected to participate in a component.

The Balanced Budget Act of 1997 imposed certain restrictions on the use of federal employment and training funds.  As a result, 80% of the employment and training funds we receive must be spent on work activities for able-bodied adults without dependents (ABAWDs) age 18 to 50.  At present, the only food stamp work components available to ABAWDs are:

  •  Adult Basic Education (ABE)
  •  Job Training Partnership Act (JTPA)
  •  Direct Job Placement (DJP)
  •  Missouri Jobs, Employment and Training (MJET)
The remaining 20% of the employment and training funds are to be spent on other mandatory work registrants.  Food stamp work components available to other mandatory work registrants are:
  •  Job Search, and Job Search Training (Workforce Linkage) through Employment Security
  •  DJP
  •  ABE
  •  MJET (in Southeast Missouri)
Assessment

For the Food Stamp Program, the Division of Job Development and Training is contracted to provide JTPA activities to only mandatory food stamp work registrants who are ABAWDs.  It is crucial that appropriate participants are referred.  In an effort to ensure appropriate referrals are made to each work component, we have developed an assessment process.  Attached to the hard copy of this memorandum is a flow chart designed to assist staff in assessing and referring mandatory work registrants. 

The assessment process is:

  •  to be completed for only those individuals age 16 to 60,
  •  used to correctly determine whether the participant is an ABAWD or other mandatory work registrant,
  •  to review previous work history,
  •  to determine level of education, and
  •  to determine the skills a participant may have.
The IM-101, Household Member Age 16-60 Assessment form, is revised to assist staff in assessing and referring mandatory work registrants to appropriate METP components.  Complete a section of the IM-101 (maximum of 4 per form) for each household member who is subject to the work registration requirement.  The IM-101 is designed to assist staff in obtaining information regarding each participant's education, literacy, work history, and job skills.  Use this information and the assessment and referral guidelines provided in IMNL to refer the mandatory METP participants to the work registration component that will most likely assist the participant in gaining needed job skills and employment.

New Section

A section has been added to assist staff when assessing and referring mandatory work registrants to an employment and training component (IMNL Section 1105.025.10).  All components are not available in each county.  Nor is it correct to refer each mandatory METP participant to any one of the components.  In some situations there may be no component to which a mandatory participant may be referred.

JTPA Referrals

For the Food Stamp Program only participants who are able-bodied adults without dependents age 18 to 50 with at least an eighth grade education may be referred to JTPA.  Entry of code "98" in FSU5 will generate the referral to JTPA.  A monthly listing of individuals coded "98" will be produced and sent to each Service Delivery Area (SDA).  The IM-101B should only be used to refer an ABAWD to JTPA when s/he has used his/her five non-work months and wishes to participate in JTPA to regain eligibility.

NOTE:  Code "98" will no longer automatically change to code "26" when the participant is enrolled in JTPA.

An IM-16 will be used by JTPA to notify the worker when a participant is called in and fails to comply.  Conciliation and sanctioning procedures should be followed upon receipt of a notice from JTPA that a participant has failed to comply.  To determine whether an ABAWD is participating in a JTPA activity at least 20 hours per week average, each county must contact their local SDA and develop a feedback process.  IMNL Section 1105.025.20.20 is revised to reflect these changes.

Workforce Linkage

The Division of Employment Security provides Job Search and Job Search Training (Workforce Linkage) in Boone, Buchanan, Dunklin, Greene, Jackson, St. Louis Counties, and St. Louis City.  Mandatory work registrants residing in counties surrounding those listed above and within a one hour drive from the DES office may also be called in to participate in METP activities.

Workforce Linkage is added to the Job Search and Job Search Training component.  It is being offered by the Division of Employment Security (DES).  Workforce Linkage offers participants training on career exploration, job market, applications and resumes, interviewing skills, and career enhancement and advancement.

METP Conciliation Period

The conciliation period is changed from five working days to ten calendar days to better coordinate Temporary Assistance and food stamp policy.  Section 1105.025.30.15 is revised to reflect this change.

The automated notices, METP-28, METP-28A, METP-29, METP-30 and METP-31 have been revised to reflect the change in the conciliation period.

Economic Head of Household

We no longer apply sanctions to the entire household when noncompliance occurs.  The household no longer needs to designate an economic head of household.  Section 1105.025.70 has been deleted.

Increase in the Number of Months Able Bodied Adults Without Dependents May Receive Benefits

Able-bodied adults without dependents age 18 to 50 may now receive food stamps in 5 non-work months in a 36-month period of time.  Section 1105.035.25 is revised to reflect this change.  Additional information regarding this change is being sent in a separate memorandum.  Do not apply this change until the policy memorandum is received.

Work Registration Code Change

Code "01" is redefined to, "cares for child/ren under age six."  Exemption code "17" is deleted.  Section 1105.025.05.05, Household Members Exempt from Work Registration, is revised to reflect these changes.

 
NECESSARY ACTION:
  • Review this memorandum with appropriate staff.

  •  
  • Implement changes outlined in this memorandum immediately.

  •  
  • File revised manual pages.

  •  
  • File copies of the revised METP-28, METP-28A, METP-29, METP-30 and METP-31 in the Forms Manual, IM-105, FSU5 Instructions, Appendix C.  Destroy copies of the obsolete METP-28, METP-28A, METP-29, METP-30 and METP-31.

  •  
  • Destroy the obsolete IM-101 dated 1/94.

  •  
  • File revised IM-101 and instructions in Forms Manual.
JKW
Distribution # 3

[ Memorandum Table of Contents ]


 
1105.025.00    WORK REGISTRATION (METP) - EMPLOYMENT AND TRAINING

Work Registration is required for persons aged 16 to 60, unless otherwise exempt.  Missouri Employment and Training Program (METP) is developed for mandatory work registrants to meet the work registration requirements.  METP Components are:

 1. Job Search Training (JST) (formerly known as Job Club),
 2. Job Search (JS),
 3. Missouri Jobs Employment and Training (MJET),
 4. Direct Job Placement (DJP),
 5. Job Training Partnership Act (JTPA), and
 6. Adult Basic Education (ABE).
Explain to the applicant the work registration requirements, employment and training components, participation requirements, and consequences of failure to comply.
 

1105.025.05      METP Assessment
IM-#32  April 1, 1999

During the application interview, assess each household member to determine:

1105.025.05.05        Household Members Exempt from Work Registration
IM-#32  April 1, 1999

Consider the following persons Exempt from Mandatory Work Registration:

 1. Someone who cares for a child under age six.  If the child has his/her sixth birthday within the certification period, the individual responsible for the care of the child is exempt for this reason until the recertification. (code 01)

  NOTE:  If a parent or another household member both claim the responsibility for care of the child under age six, the actual responsibility is determined by discussion with the applicant.  If there are two parents in the home each with dependent children, both are exempt due to care of their own children.  This includes stepparent situations.

 2. A household member under age 16.  A person becoming age 16 during the certification period, and not exempt, will be work registered at the next application.  (code 03)

 3. Someone who is disabled on a temporary or permanent basis for purposes of IM, Social Security, and SSI.  Receipt of temporary or permanent disability benefit from a private source is also acceptable verification.  Refer to Definitions. (code 06)


1105-16


  NOTE:  Denial or closure of the claimant's IM, Social Security, or SSI grant is not sufficient grounds alone for denial or closure of the household's food stamp benefits for failure to meet work registration requirements.  The claimant will lose his/her exemption from work registration on this basis and must be offered the opportunity to comply with the work registration requirements of the Food Stamp Program.

 4. A person who is 60 years or older.  (code 07)

 5. Someone required in the home to care for other members who are ill or incapacitated and no other appropriate member is available to provide needed care.  (code 09)

 6. A person working 30 hours or more per week, or receiving weekly earnings equal to the federal minimum wage times 30 hours.  (code 10)

  NOTE: Teachers, school professionals, and administrative school personnel do not have to register nor be employed during the summer months as long as they meet the above requirements.

 7. A full-time student in any recognized secondary, vocational or technical school, training program, or institution of higher education.  Students attending an institution of higher education must meet the student criteria.  (code 14)

  NOTE:  JTPA participants attending school must be coded mandatory METP participants.

 8. A person who is mentally or physically unable to work, but who is not disabled per food stamp definitions.  Refer to definitions.  These are household members who are mentally or physically incapable of engaging in gainful employment.  In determining physical or mental incapacity preventing employment, use personal judgment as the primary basis for decision.  If the household member is obviously unable to work, no documentary proof is necessary.  (code 15)

  NOTE:  GR participants meet this definition.

  Obtain a medical statement only if the person does not receive disability benefits from a public or private source, and their claim of incapacity is questionable.  Advise the household member claiming incapacity that a medical statement may be required from a physician or licensed or certified psychologist.  If the household member cannot furnish a medical statement, the county may request a medical examination by a designated doctor (the county can pay for it).  If this household member refuses to cooperate,


 1105-17



 
  close the case or reject the application and record the reason.

 9. The individual is subject to or is participating in Temporary Assistance case management activities.  The case management services can be provided by Self-Sufficiency Case Managers, Futures Case Managers, contracted providers or Welfare to Work agencies.  (code 16)

 10. The individual is receiving Unemployment Compensation.  This includes persons who have applied for but are not yet receiving benefits.  This person must be required to register for work as part of the unemployment compensation application process.  (code 19)

 11. The individual regularly participates in substance abuse treatment or rehabilitation program as a resident or non-resident.  (code 20)

 12. All individuals whose METP-related child care expenses are in excess of $200 per child under age two or $175 per child age two or over.  (If the charge for even one child exceeds these amounts, the household is entitled to this exemption.) (code 21)

 13. The individual is a half-time student in any recognized secondary, vocational or technical school, employment training program, Office of Refugee Resettlement Training Program or institution of higher education.  Use the school's definition of half-time student.  Students attending an institution of higher education must meet the student criteria.  (code 29)

  NOTE:  JTPA participants attending school must be mandatory METP participants.

 14. All individuals 16 or 17 years old, unless the head of the household.  Individuals 16 to 18 years old are either excluded or are a mandatory registrant.  They are mandatory if they are the economic head of household and not attending school half time or enrolled in an METP component.  (code 35)

 15. A person who is a VISTA volunteer participating in the program at least 30 hours per week and receiving minimal compensation.  (code 12)

 16. A household member age 16-19 who is attending school full time.  (code 04)


1105-18


1105.025.05.10        Household Members Excluded from Work Registration
IM-#32  April 1, 1999

Consider the following persons as work registered, but due to the impracticality of completing a successful job search, education, or training program, excluded from participation in an employment and training program component(s):

 1. Individuals with a temporary mental or physical disability that is expected to last less than 60 days.  Re-evaluate these persons at the end of 60 days.  Temporary disabilities include acute mental problem(s) or emotional strain (such as caused by the death of a family member) or any medical condition that hinders a person from working (such as a broken limb).  If the disability lasts more than 60 days, exempt the individual.  (code 05)

  NOTE:  If DES determines the individual has good cause that is expected to be more than 60 days, DES notifies DFS that work registration must be re-evaluated at the next recertification. 

 2. Individuals who are lacking transportation as in having no personal car, no available public transportation, and no other means of transportation to the DES office, a possible job site, or METP component activity.  (code 30)

 3. Individuals who are migrant or seasonal farm workers during the season of work.  (code 31)

 4. An individual who lives in a remote area defined as more than two hour round trip from home to DES, or other program component site.  Mileage may vary due to driving difficulty.  (code 08)

 5. A woman who is pregnant in the second and third trimester.  (code 11)

 6. Individuals who lack adequate child care.  The existence of a Protective Service case is sufficient to grant this exclusion.  (code 32)

 7. Individuals who have family problems requiring a parent to be in the home.  Family problems may be, but are not limited to, alcoholism of another family member, reported child abuse, or neglect, etc.  The existence of a Protective Service case due to child abuse or neglect is sufficient to establish this exclusion.  (code 33)

 8. Household members who have multiple impediments and are not qualified for an employment and training exemption/exclusion


 1105-19



 
  under any single item of the previous criteria, but are prevented from participation due to a combination of employment-related barriers or personal hardships (for example, participants with no permanent address due to a personal or natural disaster and in a temporary residence). Identify a minimum of two marginal impediments to employment and/or training.  Taken separately, the impediments are not sufficient reasons for exemption or exclusion but, taken together, represent a significant employment barrier or create a situation in which employment and training participation cannot be required without substantial personal hardship.  Use worker judgment in determining eligibility for this exclusion.  (code 34)
  EXAMPLE:  A woman who is a single head of household and has marginal language abilities or marginal mental deficiencies, and/or young children between the ages of 6 and 15, and/or questionable after-school arrangements for the care of her children, is a candidate for this exclusion criteria.

 9. Employment Security may make a determination of good cause of 60 days for individuals required to participate in Job Search, Job Search Training or Workforce Linkage.  This can only be entered by the Division of Employment Security. (code 18)

1105.025.05.15        Mandatory Participants Who Are Required to Register for Work
IM-#32  April 1, 1999

Individuals over the age of 15 and under age 60 (ages 16-59) who are determined to be physically and mentally fit must provide sufficient information to allow a determination of their employment status or job availability.  These individuals must register for work once every 12 months at the time of application and reapplication.

Household members required to work register must:
 

  • report, as requested, to an assessment interview, an employment and training program, and/or to a job site;
  • respond to a request for supplemental information regarding employment status or availability for work; and
  • participate in any component, if selected and assigned.


Of the mandatory work registrants, determine:

 1. Which household members are able bodied adults without dependents (ABAWDs) ages 18 to 50.  These individuals are:


1105-20


  a. persons who are physically and/or mentally able to work;
  b. persons who do not meet a work registration (METP) exemption; 
  c. persons who are not pregnant; or
  d. persons who do not live in a household with a child under age 18.
 2. Which household members are mandatory work registrants.


1105.025.10      Assessing and Referring Mandatory METP Participants
IM-#32  April 1, 1999 

Determine which METP components are available to the mandatory participants in the county in which they reside.  Make the most appropriate referrals by completing a Household Member Assessment (IM-101) with the applicant.  Entering the work registration code on the FSU5 approval transaction generates the METP referral to JTPA, MJET, and Employment Security.  Refer participants to ABE using the IM-101A.  DJP referrals may be made anytime there is an appropriate job opportunity for the individual.  The appropriate referral is determined by whether the individual is an ABAWD and the assessment (IM-101) completed on the participant.  A monthly system generated listing of mandatory work registrants is provided to the counties.  This listing may also be used to make DJP referrals. 

The following quidelines are provided to assist in determining the appropriate METP component for mandatory participants.

 1. Individuals who do not have a high school diploma, GED or they want to improve their reading or math skills:
  a. ABAWDs:
  •    JTPA (eighth grade education required)
  •    MJET (in St. Charles County and Southeast Missouri)
  •    ABE
  •    DJP (if individual has work history)
  b. Other Mandatory Work Registrants:
  •    MJET (in Southeast Missouri)
  •    ABE
  •    DJP (if individual has work history)
  •    ES (if individual has work history)
  •  2. Individuals who have a degree, certificate or license, or perhaps need very little (less than a year) education to complete a degree, certificate or license:
        a. ABAWDs:
      • JTPA (eighth grade education required) 
    1105-21

    •    MJET (in St. Charles County and Southeast Missouri)
    •    DJP
      b. Other Mandatory Work Registrants:
    •   DJP
    •   Employment Security (ES [in areas served by ES])
    •   MJET (in Southeast Missouri)
     3. Individuals who have worked in the last year but, are not currently employed:
      a. ABAWDs:
    •    JTPA (eighth grade education required)
    •    DJP
      b. Other Mandatory Work Registrants:
    •    ES (in areas served by ES)
    •    DJP
    •    MJET (in Southeast Missouri)
     4. Individuals who have not worked in over a year and have no specialized job skills:
      a. ABAWDs:
    •    JTPA (eighth grade education required)
    •    DJP
      b. Other Mandatory Work Registrants:
    •   MJET (in Southeast Missouri)
    •   DJP
    •   ES (in areas served by ES)


    Upon completion of a component, ABAWDs should be reassessed for possible enrollment into another component that will allow them to meet the work requirement if they wish to continue receiving benefits.

    Explain to the applicant, during the assessment, the importance of contacting his/her worker if s/he is called in to participate in a component and is unable to comply.  See Work Registration (METP) Noncompliance.
     

    1105.025.15      METP Components
    IM#32  April 1, 1999

    Upon completion of the assessment, refer the food stamp participant to the most appropriate component.

     1105-22



     

    1105.025.15.05        Job Search Training (JST [Workforce Linkage]), and Job Search (JS) Components
    IM-#32  April 1, 1999

    Job Search Training (Workforce Linkage) and Job Search are components operated by Division of Employment Security (DES) providing supervised employer contacts for mandatory work registrants. In Boone, Buchanan, Dunklin, Greene, Jackson, St. Louis County and St. Louis City, approval of the food stamp application and entry of work registration code "22" initiates referral to DES of individuals.  Mandatory registrants living in counties surrounding those listed above, who live one hour or less from the DES offices, may also be called in to participate.  DES begins the enrollment process by selecting participants and sending an automated call-in letter to the individual.  DES staff completes an assessment of the individual during the call-in interview.

    DES offers five Workforce Linkage workshops.  Work registrants called in to participate in Workforce Linkage must attend three days.  They may choose to attend all five days.

    Workforce Linkage Workshops include:

     1. Career Exploration in which the participants:
    •   select at least one short-term and one long-term goal;
    •   identify transferable skills they already possess; and
    •   develop an employability plan outlining the steps to be taken in order to achieve a chosen career goal.
     2. Job Market in which participants are:
    •   taught where and how to locate job openings for the kinds of jobs they desire;
    •   taught how to use Missouri WORKS!; and
    •   provided an opportunity to use Missouri WORKS! in the Resource Area.
     3. Applications and Resumes which provides the following:
    •   assists participants to identify a job objective;
    •   teaches participants to effectively complete job applications;
    •   analysis of critical questions;
    •   how to state strengths as tailored to the employment sought;
    •   different types of resumes, when each one should be used; and
    •   how to compose cover and thank you letters. 
     4. Interviewing Skills in which the participant is taught:
     1105-23
      •   how to have a positive job interview;
      •   how to deal with fears of the job interview process;
      •   appropriate attire, personal hygiene, body language, positive conduct during the interview, addressing tough questions and how to close an interview; and
      •   interview skills videotaping.  It provides insight into the participant's interview skills and identifies areas needing improvement.
     5. Career Enhancement and Advancement which is provided to:
    •   teach workplace ethics including punctuality, attendance, appropriate behavior toward co-workers and supervisors and workplace responsibility;
    •   teach participants problem solving methods to resolve workplace issues and retain employment; and
    •   assist participants in gaining information on ways to use their employment to achieve higher skill levels and/or create stepping stones to future goals.
    For Job Search, the registrant must make the required number of employer contacts over the 16-week period as follows:
     1. The number of weekly contacts which parallels the number of Federal Unemployment Insurance Work Search requirements established for each county.  The number of contacts required ranges from 12 to 16 and is determined by the county of residence.

     2. Report to DES for an interim evaluation of appropriateness of the contacts and compliance with the assigned number of contacts during the first four-week period or a determination of good cause for noncompliance.

     3. A minimum number of appropriate employer contacts during the second four-week period with the assigned number of contacts being made each week.

     4. Report to DES for a final evaluation of the appropriateness of the contacts and compliance with the assigned number of contacts made each week.


    A work registrant who is active within the JS component including JST can be requested to participate in a DJP employment interview and accept employment if available.  DFS staff should work cooperatively with DES to maximize employment activities.  For example, if a work registrant is attending Job Search Training through DES in the morning, schedule a DJP interview in the afternoon.

    If, during the assessment, DES determines that an individual has a barrier that was not identified by the caseworker and is expected to exist for more than 60 days, the caseworker is alerted when action is

     1105-24


    required.  Evaluate these individuals at the next recertification or approval to determine correct work registration status at the time. 

    DES provides intensive, personalized and enhanced job search services.
     

    1105.025.15.10        Missouri Jobs, Employment and Training (MJET) Program
    IM-#32  April 1, 1999

    MJET program is to assure that needy families obtain the education, training, and employment that will help them avoid long-term dependence.  Case management services are contracted through the Service Delivery Areas (SDA) or another appropriate agency.

    MJET is designed to provide case management services delivered by Private Industry Council (PIC) staff.  These services must conform to all regular food stamp employment and training work registration procedures including conciliation and sanctioning procedures for noncompliance.  MJET activities administered through the PICs will include such components as Job Search Training, Adult Basic Education, Job Skills Training, On-the-Job Training, Work Experience and Job Development and Placement.  Able bodied adults without dependents are targeted in the area served by the St. Charles County MJET.  This area includes St. Louis City and County, as well as Lincoln, Warren, St. Charles and Pike counties.  Other counties served by MJET are Cape Girardeau, Dunklin, Mississippi, New Madrid, Pemiscot, Scott and Stoddard.

    Food stamp staff in the above named counties are responsible for discussing MJET with all mandatory and exempt registrants to determine if any choose to volunteer.  Explain how a mandatory individual's failure to participate as required affects his/her food stamp benefits.  Food stamp staff are also responsible for applying sanctions due to noncompliance as determined by the MJET case manager.

    MJET staff are responsible for completing the initial assessment with the registrant.  This assessment evaluates educational, child care, and other supportive needs, as well as job skills, prior work experience, employability and a review of the family circumstances.  An individual employability plan is developed.  Status of registrants is reviewed by MJET staff and decisions made regarding noncompliance.  If a food stamp work registrant is actively complying with assessment and component requirements of the MJET program, s/he is not required to enter DJP components.
     

    1105.025.15.15        Direct Job Placement (DJP) Component
    IM-#32  April 1, 1999 
    Direct Job Placement (DJP) is an METP component activity performed by the local DFS county office.  It involves the direct referral of

    1105-25


    qualified, job-ready, mandatory food stamp work registrants, including ABAWDs, to known job openings within the local public and private job market.

    Direct Job Placement is an METP component that is based upon utilization of DFS staff in collaboration with key community leaders in the employment arena.  It is designed to afford the individual participant work opportunities that would normally not be available.  The intent is that greater numbers of individuals will become self sufficient and reduce reliance on governmental intervention through cash assistance or food stamps.

    If a work registrant is involved in the local county's effort in Direct Job Placement, s/he should not enter the MJET activity component without first completing the scheduled employment interviews.  If the individual is employed following the DJP interview, the work registration code is changed to reflect the current status.
     

    1105.025.15.20        Job Training Partnership Act (JTPA)
    IM-#32  April 1, 1999

    Refer only able bodied adults without dependents (ABAWDs), with at least an eighth grade education, to the JTPA component.  JTPA components included in METP are:

      •  Job Search Training,
      •  Vocational Training,
      •  On-the-Job Training,
      •  Work Experience,
      •  Job Development and Placement, and
      •  The Job Search Assistance program.
    The Job Search Assistance program includes job seeking skills training, job search assistance, and job club.  Because of the diverse activities available, JTPA activities are offered at different times and require different amounts of time to complete.

    County offices are responsible for assessing and determining that referral of an ABAWD to JTPA is appropriate.  Code the individual "98" in FSU5.  A monthly listing will be generated and mailed to the Private Industry Council (PIC) serving the county in which the participant resides.  JTPA personnel assess the training and work experience needs of individuals referred.  Based on this assessment, individuals are placed in the appropriate component.  If no openings are available, the individual is placed on a waiting list.  The applicant is called in when a slot is available.

    After the individual has met the participation requirements and completed the component, evaluate the individual for placement in another component. 

    1105-26

    The caseworker is notified when an individual satisfactorily terminates a JTPA program.  An example of a satisfactory termination is gaining employment.  Evaluation of work registration status and budget may be necessary when this type of notice is received.
     

    1105.025.15.25        Adult Basic Education (ABE)
    IM-#32  April 1, 1999

    The ABE component of METP consists of classes offered across the State.  Many students pursue their high school equivalency degree (GED).  ABE is also utilized for employment-related educational courses, reading or language skill improvement.  Improved reading, writing, and math skills can improve opportunities in the job market.  ABE is free to all Missouri citizens age 16 or over who are not now attending school and who do not have a 12th grade equivalent degree.

    Screen individuals for referral to ABE at the time of application or reapplication.  ABE accepts referrals for individuals aged 16 or older.  Sixteen/seventeen year old individuals who are mandatory work registrants can meet work registration requirements through ABE programs.  ABAWDs who are mandatory work registrants can meet METP requirements and the work requirement through ABE programs.  ABAWDs must be enrolled in ABE a minimum of 20 hours per week in order to meet the work requirement.

    Refer individuals directly to local ABE programs.  Each county works with local ABE personnel to determine vacancies in the classes.  ABE personnel assess the educational needs of the individual(s) referred.  This is the first step in tailoring the instruction to the student.  Based on this assessment, individuals are placed in the classes.

    Consider the individual to have completed the ABE requirement after:

     1. four months participation;

     2. GED receipt; or

     3. successful completion of the program as defined by ABE (some individuals enter ABE in order to pass entrance exams for other programs and are not striving toward receiving a GED).

    The individual may continue to participate after four months.  The participant will not be reimbursed. The individual will not be subject to sanction for noncompliance with the program.

    An individual completing the ABE program may be considered ready for another work component.  Once an individual has entered ABE, the individual must be reassessed at each recertification. 

    1105-27

    1105.025.20      Changes in Work Registration (METP) Status
    IM-#32  April 1, 1999

    If a mandatory participant reports a change, making the individual exempt or excluded from mandatory work registration, change and document work registration status within ten days.

    If an exempt or excluded individual becomes a mandatory participant, due to a change in circumstances, the following action is required:

     1. If the change was required to be reported, register the individual when notified.  Assess the participant following the guidelines previously stated.  All work registered household members must be provided information regarding the pertinent work requirements, the rights and responsibilities of work registered household members, and the consequences of failure to comply.  To meet this requirement, provide the new mandatory work registrant a program information pamphlet, "Food Stamps and Work."

     2. If the change was not required to be reported, register the individual at the next regular recertification.


    1105.025.25      Monthly Allowance
    IM-#32  April 1, 1999

    Mandatory or voluntary individuals enrolled in METP components are eligible for reimbursement of transportation expenses.  This allowance is NOT income for food stamp purposes.  The reimbursement amount is $25 per month for those individuals placed in a component except for participants in MJET who receive a $50 reimbursement.
     

     1. JS Monthly Allowance

      Individuals enrolled in JS are eligible to receive two reimbursement checks, one for each month they successfully participate in JS.  DFS has contracted with DES regarding disbursement of the checks.  DES mails the allowance for transportation at the end of the first four weeks of Job Search (See Job Search Training [Workforce Linkage] and Job Search).  Another transportation allowance is mailed at the end of the second four weeks.  There is a maximum allowance of $50.00 per participant.   Undeliverable transportation checks are returned to the DES State Office for processing.

     2. JTPA Monthly Allowance

      A person must participate, as required in his/her JTPA activity, to be entitled to a reimbursement check.  Reimbursement checks are system generated.


     1105-28



     
     3. ABE Monthly Allowance

      ABE participants are entitled to receive reimbursement for four months of participation.  Some individuals begin an ABE program but quit before meeting their goals.  If these individuals re-enter ABE at a later date, they are eligible for the reimbursement if they have not received four payments within that participation year.

      After the first copy of the referral form is received from ABE indicating the individual is enrolled in the program, authorize payment.  Information on this is used to authorize payment in the FSU5 interface system.  Authorize the reimbursement if the participant has not received four payments within that year of ABE participation in an ABE component through the current benefit authorization system.  The caseworker is advised 35 days from the enrollment date if no payment is authorized.

      Undeliverable ABE reimbursement checks are returned to the county office.  Either remail the check to the correct address or return the check to the Division of Finance.

     4. Direct Job Placement (DJP) Allowance

      Participants in the DJP component are eligible for reimbursement of expenses directly related to participation in METP not to exceed $25.00 monthly.  The reimbursement, up to $25.00 monthly, is for transportation and other costs (other than dependent care costs) related to specific job interviews and other employment activity.  Request reimbursement for a DJP component participant on a DOF-14 with an attached completed Request for Transportation Reimbursement form.

     5. Missouri Jobs, Employment and Training Allowance

      Participants in the MJET component are allowed $50 monthly for reimbursement of transportation and other costs as would relate to employment and training activity.  Case managers handle reimbursement requests for MJET component participants.

     6. Day Care

      Participants in a METP component (including DJP) may receive assistance for the payment of day care expenses.  The payments can only be made to licensed providers and are authorized through the child care system.  The maximum payment is $200 per month for children under 2 years and $175 per month for dependents 2 years and over.  The day care payments are only authorized for the actual time the


    1105-29



     
      participant spends completing a METP component.

      EXAMPLE:  The individual in a job search component may receive day care assistance for the time spent on the job search and for appointments at Employment Security.  If the individual looks for a job one hour each day, s/he may be authorized for the corresponding payment amount through a licensed vendor.

     7. Child Care Developmental Block Grant (CCDBG)

      Availability of CCDBG funds is an option to explore for participants in METP components such as Job Search Training, Job Search, DJP, MJET, etc.  Funding through this source is currently available and should be used to promote work and self-sufficiency to participants.


    1105.025.30      Work Registration (METP) Noncompliance
    IM-#32  April 1, 1999

    Mandatory participants who fail without good cause to comply with work registration requirements will be determined ineligible for participation in the Food Stamp Program.  This ineligibility will last for a period of time based on whether the noncompliance is the first, second, third or subsequent occurrence.  If the individual:

     1. refuses, at the time of application and reapplication to register for work;

     2. refuses, without good cause, to participate in an employment and training program;

     3. refuses, without good cause, to accept an offer of employment, provided the offer of employment meets the suitability criteria;

     4. refuses, without good cause, to provide sufficient information to allow a determination of his/her employment status or job availability;

     5. quits a job voluntarily and without good cause; or

     6. reduces, voluntarily and without good cause, his/her work efforts causing him/her to work less than 30 hours per week.


    1105-29a


    1105.025.30.05        METP Noncompliance For JST (Workforce Linkage), JS, DJP, MJET Components
    IM-#32  April 1, 1999

    The caseworker and the claimant are notified if the registrant has failed to comply with requirements of the component.  For JST (Workforce Linkage) and JS, the notification is an automated process with a system generated notice of noncompliance.  For DJP and MJET, notification is a manual process in which the caseworker sends a notice of noncompliance to the claimant.  In each instance, the notice specifies the requirement of work registration and instructs the claimant to contact DFS within ten calendar days to determine:

     1. if the noncomplying member meets an exemption,

     2. if the noncomplying member had good cause for failure to cooperate,

     3. the consequences of noncompliance, and

     4. the time period in which the member must comply.


    1105.025.30.10        METP Noncompliance For JTPA And ABE
    IM-#32  April 1, 1999

    Since JTPA and ABE are components of METP, mandatory persons referred must be sanctioned if they do not comply.  Noncompliance for JTPA and ABE are somewhat different from those of other METP components, they are shown as follows:

    Noncompliance for JTPA is identified as an individual who has:

     1. failed to enroll,
     2. failed to satisfy minimum requirements,
     3. terminated the program, or
     4. failed to comply without good cause.
    Noncompliance for ABE may occur at any point in the referral process.   The individual may not have successfully completed the first, second, third or fourth month of the ABE component.

    When notice is received that the individual has failed to comply with JTPA or ABE components, determine if the participant has an opportunity to cure the noncompliance.  For example: Is the program still available to the individual?  If not, the individual must be offered the opportunity to cure by complying with another METP component.  If the individual has the opportunity to cure by complying with JTPA or ABE and does not, determine if good cause exists.  (Refer to determining Good Cause for Noncompliance/METP for the reasons good cause is granted.)  Determine if the individual qualifies for an exemption.  If the mandatory individual does not meet an exemption or

    1105-30


    have good cause for noncompliance, and a component is available so s/he may cure the noncompliance, following conciliation, apply sanctions as shown under Work Registration Requirements Noncompliance Sanctions.
     

    1105.025.30.15        Work Registration (METP) Conciliation Period
    IM-#32  April 1 , 1999

    Compliance can occur at any point in the ten calendar day conciliation period.  When it is determined the registrant has cooperated, the noncompliance is cured.  DFS county office staff determine compliance for Direct Job Placement (DJP) components.  The PIC case managers determine compliance for MJET counties.  Employment Security makes the compliance determination for Job Search Training (Workforce Linkage) and Job Search components.  In situations where the compliance is determined by another agency, DFS is notified by the other agency. 

    The participant can meet an exemption from work registration and the noncompliance is cured.  When noncompliance is cured prior to sanctioning, the case is not closed nor is the noncomplying member removed.  Refer to Reapplication After Sanctioning for Work Registration (METP) for handling compliance if the certification expires during the ten calendar day conciliation period.

    There may be instances in which the noncomplying household member is sanctioned and it is later learned the individual complied within the ten calendar day conciliation period.  When this occurs, cancel close the case, if it was a case closing, or add the individual back to the case and issue restored benefits, if necessary.

    If the registrant does not comply, initiate the Notice of Adverse Action on calendar day 11 to remove the noncomplying member or close the case in single-person households.  If the registrant does not comply within time frames, take necessary action.  Notify the household of the change via a Benefits Adjustment Notice.
     

    1105.025.30.20        Resolving Noncompliance with Work Registration
    IM-#32  April 1, 1999

    Discuss the following information with the program participant.  The  cure for each question is shown.  Inform the household of the requirements of work registration (METP), the consequences of noncompliance, and the date by which the member must comply.

     1. Does the noncomplying member meet an exemption from work registration (METP)?

      Cure:  If the noncomplying member is exempt from work registration for reasons other than subject to or participating in Temporary Assistance case management


     1105-31



     
      activities or receipt of Unemployment Compensation, end the conciliation process.

     2. Did the noncomplying member have good cause for failure to comply with work registration (METP)?

      Cure:  DES determines good cause for the JST (Workforce Linkage) and JS components.  When the noncomplying member states s/he has a good reason for not cooperating with DES, send the noncomplying member back to DES.  Instruct the registrant to explain his/her situation to the DES counselor so good cause can be determined.  The counselor can pend the process to allow the claimant time to solve the problem.

      NOTE:  The noncomplying member must report to DES.  DES must notify the DFS office the claimant has complied before the noncompliance is cured.

      Good cause for noncompliance with a DJP, ABE or JTPA component is determined by the DFS caseworker.

     3. If in noncompliance with JTPA and ABE components, how can the noncompliance be cured?

      Cure:  If there is another slot available with JTPA or ABE, the individual may return for participation.  If not, claimant must be referred to Direct Job Placement  (DJP) or MJET (where offered).  A sanction cannot be imposed if there is no cure.

      NOTE: When an individual fails to comply with Temporary Assistance case management activities, follow the policy outlined under MEPT non-compliance for JST (Workforce Linkage), JS, DJP and MJET components.

    1105.025.30.25        Work Registration (METP) Noncompliance Sanctions

    Sanctions for noncompliance with work registration (METP) will be applied as follows:

     1. For the first failure-to-comply occurrence, sanction the individual until compliance.

     2. For the second failure-to-comply occurrence, sanction the individual for a minimum of three months or until compliance whichever is longer.  The participant is required to serve the three-month sanction. 
     3. For subsequent failure-to-comply (any failure-to-
    comply beyond the second failure), sanction the individual for


    1105-32


      a minimum of six months or until compliance, whichever is longer.
    If during a METP noncompliance disqualification period an individual meets an exemption from work registration requirements, the individual may resume participation in the Food Stamp Program if otherwise eligible.  Meeting an exemption ends this sanction for the individual.  The disqualification period does not resume if later the individual no longer meets an exemption.

    1105.025.35      Work Registration (METP) -- Suitable Employment
    IM-#32  April 1, 1999

    Do not consider employment suitable if:

     1. the wage offered is less than the applicable federal minimum wage (or training wage) or 80 percent of the federal minimum wage (or training wage) if minimum wage is not applicable;

     2. the employment offered is on a piece-rate basis and the average hourly yield the employee can reasonably be expected to earn is less than the wage described above;

     3. the household member, as a condition of employment/continuing employment, is required to join, resign from, or refrain from joining any legitimate labor organization;

     4. work offered is at a site subject to a strike or lockout at the time of the offer (this would not apply if the strike has been enjoined under the Taft-Hartley Act, or an injunction has been issued under the Railway Labor Act);

     5. the degree of risk to health and safety is unreasonable;

     6. the household member is physically or mentally unfit to perform the employment (this must be documented by medical evidence or by information from other sources);

     7. the employment offered within the first 30 days of work registration is not in the household member's major field of experience;

     8. the daily commuting time from the member's home to the job site exceeds two hours per day (the time does not include the transporting of a child(ren) to and from a child care facility);

     9. the working hours, or nature of the employment, interferes with the member's religious observances, convictions, or beliefs;


    1105-33


     10. unreasonable work demands/conditions exist, such as working without getting paid on schedule; or

     11. discrimination exists by an employer based on age, race, sex, color, handicap, religious beliefs, national origin, or political beliefs.


    1105.025.40      Determining Good Cause for Work Registration (METP) Components
    IM-#32  April 1, 1999

    1. To determine good cause, consider all circumstances, including information submitted by the household.  Good cause is:

     a. a circumstance beyond the members' control.  This can include, but is not limited to, illness or illness of another household member requiring the individual's presence in the home;

     b. a household emergency;

     c. the unavailability of transportation; or

     d. the lack of adequate child care for children who have reached age 6 but are under age 12.

    2. DES determines good cause for registrants in the JST (Workforce Linkage) and JS components.

    3. The caseworker determines good cause for registrants who do not comply with DJP activities, at the point of referral for JTPA, and anytime they are participating in the ABE component.  Refer to the DJP, JTPA, and ABE component descriptions for noncompliance procedures.  Registrants in these components who do not comply after beginning the component, are subject to disqualification penalties.
     

    1105.025.45      STRIKERS
    IM-#32  April 1, 1999

    A household member not working because of a strike or a lockout at his/her place of employment is not considered in violation of work registration requirements solely for that reason unless the strike is in violation of the Taft-Hartley Act or an injunction has been issued under Section 10 of the Railway Labor Act.  To enjoin a strike under the Taft-Hartley Act or Section 10 of the Railway Labor Act, the appropriate federal court must determine, upon petition of the President of the United States, that a strike or a threatened strike affecting an entire industry or a substantial part of it, jeopardizes the national health or safety or essential transportation service. 

    1105-34


    For example, in the case of the United Steel Workers of America vs. U.S., the Taft-Hartley Act was invoked.  In these situations, the entire household of the work registrant refusing an offer of employment at the struck plant is disqualified unless it can be shown that the striker is exempt from registration the day before the strike for a reason other than employment.  Even a limited issuance to the household could undermine the intent of federal legislation at a time of national crises and could prolong the strike enjoined by court order.
     

    1105.025.50      Work Effort Reduction
    IM-#32  April 1, 1999

    An individual who voluntarily and without good cause reduces his/her work effort, and after the reduction, is working less than 30 hours per week, is determined to be ineligible to participate in the Food Stamp Program.  These individuals are subject to the disqualification penalties outlined in Work Registration (METP) Noncompliance Sanctions.

    Explore situations in which the participant reports a change that indicates the number of hours worked per week have been reduced to less than 30 hours per week.  For example, a reported change in income may indicate a reduction in the number of hours worked per week.  Explore work effort reduction at application, recertification, and when a change is reported.

    If it is determined the participant voluntarily reduced his/her work effort to less than 30 hours per week, explore good cause.  See Determining Good Cause for Work Registration (METP) Components.  If the participant did not have good cause for the reduction, apply the sanctions outlined in Work Registration (METP) Noncompliance Sanctions.
     

    1105.025.55      VOLUNTARY JOB QUIT
    IM-#32  April 1, 1999

    Voluntary job quit provisions and sanctioning policies apply to all household members.  If any household member voluntarily and without good cause quits a job, that individual is subject to sanctioning.  The rest of the household remains eligible.
     

    1105.025.55.05        Job Quit Sanctions
    IM-#32  April 1, 1999

    Job quit is considered "a violation of" or "noncompliance with" work registration.  Apply the appropriate sanction for noncompliance with work registration.

     1105-35


    NOTE:  Persons registered and excluded from work registration are NOT excluded from the voluntary job quit provisions.
     

    1105.025.55.10        Voluntary Job Quit Determination
    IM-#32  April 1, 1999

    To make a determination of voluntary job quit:

     1. Determine if a voluntary job quit has occurred.

     2. Determine if the individual or situation is exempt from the voluntary quit provisions.

      Voluntary job quit does not apply and is not considered in the following situations:

      a. the individual is exempt from work registration requirements, except work registration employed 30 hours per week;

      b. the job did not involve working at least 20 or more hours per week OR the job did not provide weekly earnings equivalent to the federal minimum wage multiplied by 20 hours per week;

      c. the change in employment status is from reduced hours of employment while working for the same employer;

      d. a self-employment enterprise is terminated; or

      e. resignation from a job is at the demand of the employer.

      NOTE:  Consider federal, state, or local government employees dismissed from their jobs due to participation in a strike against the government entity as voluntary job quit without good cause.


    1105.025.55.15        Good Cause for Voluntary Job Quit
    IM-#32  April 1, 1999

    Determine if voluntary job quit was with or without good cause.  Good cause for leaving employment includes:

     1. Discrimination by an employer based on age, race, sex, color, handicap, religious beliefs, national origin, or political beliefs. 
     2. Work demands or conditions that render continued employment unreasonable, such as working without getting paid on


    1105-36



     
      schedule.

     3. Employment that becomes unsuitable by not meeting suitable employment criteria after the acceptance of employment.

     4. Employment is not considered suitable if the daily commuting time exceeds two hours per day.  Consider quitting a job to move to another location, including moves within the state, as good cause if commuting time exceeds two hours per day.

     5. Circumstances beyond the members control such as illness, illness of another household member sufficiently serious to require the presence of the member, unavailability of transportation, unanticipated emergency, and unsuitability of work.

     6. Acceptance by the member of employment, or enrollment at least half-time in any recognized school, training program, or institution of higher education that requires the member to leave employment.

     7. Acceptance by any other household member of employment, or enrollment at least half-time in any recognized school, training program, or institution of higher education in another county or similar political subdivision that requires the household to move thereby requires another member to leave employment.

     8. Resignations by persons under the age of 60 that are recognized by the employer as retirement.

     9. Acceptance of a bona fide offer of employment of more than 20 hours a week or in which the weekly earnings are equal to the federal minimum wage multiplied by 20 hours that, because of circumstances beyond the control of the member, subsequently either does not materialize or results in employment of less than 20 hours a week or weekly earnings of less than the federal minimum wage multiplied by 20 hours.

     10. Leaving a job in connection with patterns of employment in which the workers frequently move from one employer to another such as migrant farm labor or construction work.  Some circumstances may exist where households apply for food stamp benefits between jobs particularly in cases where work may not yet be available at the new job site.  Even though employment at the new site has not actually begun, consider quitting previous employment with good cause if it is part of the pattern of that type of employment.

     11. Lack of adequate child care for children who have reached age 6 years but are less than 12 years of age.


    1105-37


    1105.025.55.20        Applying Voluntary Quit Decision
    IM-#32  April 1, 1999

    Apply the voluntary quit decision to households in the following manner.
     

     1. Applying Household:  When a household files an application, determine if a currently unemployed household member, who is not exempt from work registration, has quit a job WITHIN the 60 days prior to the date of application.  If DFS discovers that the household has lost a source of earned income after application, but prior to certification, make a determination of voluntary quit.  However, the application cannot be delayed past the 30-day time frame to determine voluntary job quit if all other points of eligibility have been established.

     2. Participating Household:  When the household reports the loss of a source of earned income, determine if any household member voluntarily quit a job.  Determine job quit whenever a new member joins a certified household.

     3. Disqualified Member Changes Households:  If a person was disqualified in one household for voluntary quit and joins another household, the disqualification follows the individual.
      If a person is not a member of a food stamp household when the job quit occurs and then joins a certified household, voluntary job quit provisions apply to the individual.

    The job quit and the disqualification sanction follows the individual who voluntarily quit his/her job without good cause.

    Individuals who voluntarily quit a job without good cause are subject to the sanctions for noncompliance with work registration requirements. 
     

    1105.025.55.25        Claims Due to Voluntary Job Quit
    IM-#32  April 1, 1999

    When it is discovered after certification that a voluntary job quit occurred prior to approval, for the purpose of applying a sanction consider the case a participating household.  Do not do a claim.  Send a Notice of Adverse Action informing the household the individual will be disqualified for the appropriate sanction period depending on if it is the first, second, third, or subsequent occurrence.  Begin the penalty period with the first month after the Notice of Adverse Action expires.

    1105-38


    If a voluntary quit occurs or is determined in the last month of a certification period, apply the appropriate penalty period beginning with the day after the certification period ends. 
     

    1105.025.60      Reapplication After Sanctioning for Work Registration (METP)
    IM-#32  April 1, 1999

    If an individual requests reapplication while serving a work registration (METP) sanction, you must accept the application.  Reject the application as the individual is not eligible for participation in the Food Stamp Program.

    If a household containing a disqualified individual reapplies for benefits, determine eligibility according to Excluded Household Member Policy.

    If the individual requests reapplication during the ten-day conciliation, or prior to the expiration of the Notice of Adverse Action for proposed sanctioning, you must accept the application.  Pend the application and verify the noncompliance has been cured.  If the noncompliance is cured during the ten-day conciliation period, or prior to expiration of the adverse action notice, no sanction is applied.  The pended application is processed.

    If the noncompliance is NOT cured, reject the application.
     

    1105.030.00    OVERLAPPING DISQUALIFICATION

    If a household in which a member is assessed a disqualification period due to an Intentional Program Violation is also assessed a disqualification period due to a voluntary job quit without good cause, an overlap of disqualification periods may exist.  The two disqualification periods run concurrently.
     

    1105.035.00    WORK REQUIREMENT FOR 18 TO 50 YEAR OLDS
    IM-#32  April 1, 1999

    Individuals age 18 to 50 who are able bodied adults without dependents must also meet the work requirement.  Able bodied adults without dependents age 18 to 50 are defined as individuals who:

     1. are physically and/or mentally able to work;
     2. do not meet a work registration (METP) exemption;
     3. are not a member of a food stamp household with a child under the age of 18; or 
     4. are not pregnant.


    1105-39


    In order to receive food stamp benefits for more than 5 months in the previous 36 months, those same individuals must comply with the following 18 to 50 year old work requirement:

     1. work at least 20 hours per week (averaged monthly); 
     2. participate in JTPA or Trade Adjustment Act for at least 20 hours per week, or
     3. attend ABE at least 20 hours or more per week.
    NOTE:  Job Search Training and Job Search components of the Missouri Employment and Training Program are NOT considered acceptable work training programs for this provision.

    Missouri has been granted a waiver for certain counties and cities in which the unemployment rate is over ten percent or there are an insufficient number of jobs to provide employment for the individuals residing in the area.  Individuals in the 18 to 50 age group residing in any of these areas do not have to meet the 18 to 50 year old work requirement. 

    NOTE:  This waiver does NOT affect work registration policy. Mandatory work registrants must still meet all METP work registration requirements including participation in work components such as Job Search Training, Job Search and Direct Job Placement.
     

    1105.035.05      Exemptions to 18 to 50 Year Old Work Requirement
    IM-#32  April 1, 1999

    Exempt the following individuals from the 18 to 50 year old work requirement:

     1. Individuals, between the ages of 18 to 50, who are exempt from work registration requirements.  See Exempt from Mandatory Work Registration.

     2. An individual already determined disabled per food stamp definition (i.e. approved for SSI), no additional verification is needed.

      Obtain a doctor's statement to verify the exemption of an individual claiming to be physically or mentally unfit for employment who is not disabled per the Food Stamp Program definition (i.e. GR recipients, individuals with a pending application for Social Security, SSI, or VA with a disability), unless the disability is obvious to the worker.

      If the individual is unable to furnish a medical statement, the county may request a medical examination by a designated doctor and submit a DOF-14 for payment.

      Inform the individual if his/her application is approved

    1105-40


     
      while the disability determination is pending, and s/he is NOT determined disabled, s/he is subject to the 18 to 50 year old work requirement for the entire certification period.  The months the individual received benefits while not meeting the 18 to 50 year old work requirements, or meeting an exemption, are counted as non-work months.

      DO NOT REJECT THE APPLICATION IF VERIFICATION OF DISABILITY IS NOT RECEIVED.  If eligible on all eligibility factors, including the 18 to 50 year old work requirement policy, the application is approved.  The individual is subject to the 18 to 50 year old work requirement policy, requiring him/her to work or participate in a work program for at least 20 hours per week.

     3. An individual who is pregnant in any trimester.

     4. All individuals subject to the 18 to 50 year old work requirement policy who are included in a food stamp household with a child under the age of 18.

      Exemption code 50 is created to identify persons exempt due to the dependent child exemption.  Code 50 is specific to this policy.  It is NOT an exemption from work registration.


    1105.035.10      Evaluating Months For 18 to 50 Year Old Work Requirement Compliance
    IM-#32  April 1, 1999

    Evaluate whether the work requirement is being met at each (1) application, (2) recertification, and (3) anytime there is a change in household composition or earned income.  Determine whether or not the participant has complied with the work requirement as follows:

     1. Evaluate only the months in which food stamp benefits have been received.  Months in which benefits are prorated are not subject to this policy.

     2. Do not evaluate months prior to December 1996.


    1105.035.15      Definition of Work
    IM-#32  April 1, 1999

    1. Work is defined as paid employment or benefits in lieu of pay (i.e. working in exchange for board).  The value of the benefit (i.e. board) must equal 20 hours times (x) minimum wage (averaged monthly).  Gross income for a self-employed individual must equal 20 hours times (x) minimum wage.  An individual volunteering 20 hours per week would need to also be working in a job 20 hours per week for which s/he receives monetary compensation.

    1105-41


    2. Follow current policy for verifying income, hours, and rate of pay to project hours worked during the certification period.  Examples of verification include:

     a. completed IM-12 form (Employment Letter);
     b. written statement from the employer;
     c. copies of wage stubs; or
     d. phone call to the employer supported by recording in the case record.

     The hours worked per week must be included in the verification.  If the individual is self-employed (i.e. cleaning houses) the statement provided must include the hours worked.

    1105.035.20      Determining Hours Worked/Hours in a Training Program
    IM-#32  April 1, 1999

    1. At each application and recertification project the number of hours to be worked.  Use current policy for projecting anticipated income.  It is important to try to accurately predict whether an individual will meet the work requirement for each month of the certification period.  Enter appropriate data into the system.

    2. If it is learned that the hours worked or participated in a qualifying training program are different than the projected hours used to determine non-work months, adjust the system accordingly.  If, it is verified that the individual met the work requirement in a month previously considered a non-work month - delete that month from the system.

    3. At each recertification determine whether the 18 to 50 year old work requirement was met for all months in which food stamps have been received.  Verify, as necessary, actual hours worked or whether the participant participated in a qualifying training program during each of these months.

     Determine the hours worked per week by averaging the hours worked per pay period for the month.  Use the pay date to determine the pay stubs to count in that month.  For example, use any pay stubs with a pay date in December 1998, for the December hours worked computation.

     Verify the number of hours of participation in ABE, JTPA, or MJET by contacting the agency providing the training.

    1105.035.25      Identifying and Tracking Non-Work Months
    IM-#32  April 1, 1999

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    1. A month in which the individual receives food stamps while not meeting the 18 to 50 year old work requirement, is defined as a non-work month.  The individual may only receive food stamp benefits in 5 non-work months in a 36-
    month period.

    2. All months in which an individual receives food stamps, and does not meet the 18 to 50 year old work requirement, must be entered in the system and tracked.  This includes:

     a. all months, prior to recertification, in which food stamp benefits have been received while not meeting the work requirement;

     b. months in which, due to adverse action procedures, the individual receives an additional month of food stamp benefits while not meeting the 18 to 50 year old work requirement;

     c. months in which a change in circumstance was not reported timely; and

     d. any of the second three months in which an individual does not meet the 18 to 50 year old work requirement.


    1105.035.30      Regaining Food Stamp Eligibility
    IM-#32  April 1, 1999

    An individual may regain eligibility for one additional 3 out of 36-month period.  To regain eligibility once it has been lost, the individual must work or participate in a work program for 80 hours in a 30-day period.  The 80 hours of work or work program participation must be completed before the individual becomes eligible.

     1. For one person household situations, prorate food stamp benefits from the day the 80 hour requirement is met.  This can occur when an application for food stamp benefits is made in the month in which eligibility is regained.

     2. In households consisting of eligible individuals and ineligible individual(s), give benefits to the eligible members from the date of application.  Give benefits to the member in the process of regaining food stamp eligibility starting with the month in which the individual completes his/her 80 hours.  Obtain verification of the 80 hours of employment or training prior to approving the individual. 

     3. Once eligibility is regained, the individual (provided s/he meets all other Food Stamp Program eligibility factors) is eligible for food stamp benefits.  Eligibility continues as long as s/he continues to meet the 18 to 50 year old work requirement.

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    1105.035.35      Loss of Employment after Regaining Eligibility
    IM-#32  April 1, 1999

    A participant who again loses his/her job after regaining eligibility may only receive for one month period while not meeting the 18 to 50 year old work requirement.  This month period runs consecutively beginning when the participant reports the loss of employment (after meeting regaining criteria of working 80 hours in a 30-day period).

     1. The three-month period runs consecutively regardless of whether:
      a. An individual does or does not receive food stamp benefits during the additional three-month period (i.e. a job quit situation).

      b. An individual does or does not meet the work requirements during the additional three-month period (i.e. an individual obtains new employment in the second or third month).

     2. Start the second three consecutive month period with any month during which the individual receives food stamps after losing employment.  This occurs whether or not the loss of employment is reported timely.  Establish a claim for any months beyond the three consecutive months in which the participant was not eligible.

      EXAMPLE:  Mr. S. is subject to the work requirement.  He has regained food stamp eligibility by working 80 hours in a 30-day period.  Several months later, Mr. S's employment is terminated.  Mr. S. does not report the loss of employment for three months.  After reviewing Mr. S's work hours, it is determined that he received food stamps for four consecutive months while not meeting the work requirement.  Three of the four months are counted as eligible months.  (This can occur only one time in the 36-month period.)  A claim is established for the month in which the participant received food stamps while not meeting the work requirement.

     3. Individuals working 80 hours in 30 days, must have his/her eligibility explored at the time of reapplication.  If it is determined eligibility has been regained and the individual meets all other points of eligibility, s/he is again eligible for one three consecutive month period of food stamps while not meeting the work requirement.

      EXAMPLE:  Ms. W. is subject to but did not meet the work requirement for five months while receiving food stamps.  She is no longer receiving food stamps when she obtains full-time employment working 40 hours per week.  Ms. W.


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      works for 11 months and is terminated.  At that time, she reapplies for food stamps.  A review of Ms. W's work hours shows that she regained eligibility for food stamp benefits as she worked over 80 hours in the first 30 days when her employment began 11 months earlier.  Ms. W. is eligible to receive three consecutive months of food stamps while not meeting the work requirement.  Since she has not been receiving food stamps, her three months will start with her current application assuming all other eligibility criteria are met.  (A pro-rated month will not count as one of the three months.) 
     4. Following the additional month period, if the otherwise eligible individual meets the 18 to 50 year old work requirement each month, s/he is eligible to receive food stamp benefits.

     5. The "Job Quit" policy takes precedence over the 18 to 50 year old work requirement provision.  Anyone determined to have intentionally quit a job without good cause is subject to the policy regarding applicable sanctions. 

    1105.040.00    SOCIAL SECURITY NUMBERS

    Refer to the General Information Manual for additional procedures and information pertaining to SSNs.  Any household applying for or participating in the Food Stamp Program must provide the SSN of each household member or apply for one before certification.  Refusal or failure without good cause to provide or apply for an SSN results in disqualification of the individual for whom an SSN is not provided.

    NOTE:  Households that are expedited eligible do not have to comply with SSN requirements before receiving benefits for the first month of the certification period.  The household must comply before receiving any additional benefits.
     

    1105.040.05     Providing and Verifying SSNs

    If an individual has more than one SSN, the applicant must provide all the numbers.  If a household member does not have a number or cannot verify his/her number, explain the SSN application or replacement procedures to the applicant.  Do not delay the certification process pending SSN verification.
     

    1105.040.10      Social Security Number Application 
    Persons without an SSN must complete an application for an SSN prior to approval for food stamps.  Once an application for an SSN has been filed, the household member may participate pending notification of

    1105-45


    the SSN from the household or SSA.

    The Social Security Application Referral is verification that the claimant has applied for an SSN.  Persons listed on the referral cannot receive food stamps until verification is received that they have completed an application for an SSN, unless they have good cause.  Persons must apply for an SSN by the date specified on the referral.  Provide the applicant a reasonable number of days (5 to 15).
     

    1105.040.10.05        Failure to Comply

    If a household member refuses or fails, without good cause, to provide or apply for an SSN, that individual is disqualified from participation in the Food Stamp Program.  Disqualify only the individual for whom the SSN requirement is not met, not the entire household.

    Count the disqualified individual's earned and unearned income, less a prorated share, as unearned income to the remaining household members.

    Count the disqualified individual's resources in their entirety as resources for the remaining household members.

    Always explore good cause before disqualifying a household member.
     

    1105.040.10.10        Determining Good Cause

    In determining whether good cause exists, consider information from the household member and SSA, and case information.  Documentary evidence or collateral information that the household member has made every effort to provide the necessary information (such as proof of birth) to complete an application for an SSN is good cause.  Make every effort to assist the individual in obtaining these documents.

    NOTE:  Good cause does NOT include delays due to illness, lack of transportation, or temporary absences for persons able to mail the SSN application.  Good cause does include illness and lack of transportation if the person must apply in person.

    Record the good cause decision.
     

    1105.040.10.15        Action After Good Cause Determination

    If the entire household refuses to provide SSNs or fails to complete SSN applications determine:

     1. If good cause is established, authorize benefits for the month of application and the following month.  In order to continue receiving benefits, the household must show good


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      cause for each month until the SSN is provided or the application is completed.  Set a priority to investigate good cause each month until the SSNs are provided, the application is completed, or until good cause no longer exists.

      If after approval, good cause no longer exists, send a notice of adverse action.  If the household does not request a hearing, close the case the next work day after the notice expires.

     2. If good cause does not exist, assess whether the application can be rejected.  (Refer to Delays in Processing.)


    If an individual household member refused to provide an SSN or failed to complete the SSN application:

     1. If good cause is established, approve all the household members for the month of application and the following month.  In order for the household member who refused to provide an SSN or failed to complete the SSN application to continue to receive benefits, the member must show good cause each month until the SSN is provided or the SSN application completed.  Set a priority to investigate good cause each month until the SSN is provided, the SSN application is completed, or good cause no longer exists.

      If after approval, good cause no longer exists, disqualify the individual and send a Notice of Adverse Action.

     2. If good cause does not exist, approve the household, but disqualify the household member who refused to provide an SSN or failed to complete the SSN application.


    1105.040.10.20        No Good Cause and Ending SSN Disqualification

    If good cause does not exist, send a notice to inform the household who did not apply for or provide an SSN.  The notice must contain the following information:

     1. name of the disqualified person,

     2. reason for disqualification,

     3. eligibility and benefit level for the remaining household members, and

     4. action the household must take to end the disqualification.

    When individuals disqualified for failure to provide or apply for SSNs provide or apply for SSNs, they may become eligible for participation

    1105-46a


    in the Food Stamp Program.  Begin eligibility with the date of the notification of compliance.

    1105-46b