Arkansas Administrative Code, Division 20, Rule 016.20.98-017 - Title IV-A: State Plan Addendum - Welfare-to-Work Grant; TEA Policy 3600-3640; Forms DCO-1425 & DCO-1426 | Arkansas Administrative Code

3600 Welfare-to-Work(WtW)Grant Program

3607 Background and General Description of Program

On August 5.1997, the President signed the Balanced Budget Act Of 1997. This legislation amended certain Temporary Assistance for Needy Families Program (TANF) provisions of the Social Security Act and authorized the Secretary of Labor to provide Welfare-to-Work (WtW) grants to States and local communities for employment assistance to move the hard-to-employ TANF welfare recipients into unsubsidized jobs and economic self-sufficiency.

The objective of the WtW grant program is to provide additional resources to target hard-to-employ welfare clients and non-custodial parents within the State. The WtW legislation specifically includes certain non-custodial parents of TANF minor children. A non-custodial parent means a parent who is absent from the TEA child's household. (See TEA 3621 for more information regarding non-custodial parents.)

WtW activities must be coordinated with those undertaken through TANF. The WtW regulations provide the States and local governments with broad discretion to design and implement programs that meet the needs of the hard-to-employ clients in the individual States.

Although the WtW program is a part of the Arkansas TEA State Plan, the Employment Security Department (ESD) is the administrative agency for the WtW program. The State WtW grant funds are funneled through ESD from the Department of Labor to the local Service Delivery Area (SDA). At the local level, the Private Industry Council (PIC) administers the funds. However, because the WtW program is specifically for TANF families, close coordination and collaboration between the County DHS office and the local PIC is necessary for a successful program. The procedures described in the following sections are intended to be used as a basis on which to build an effective and coordinated WtW process at the local level.

3605 Welfare-to-Work Eligibility Requirements

The federal law specifies certain criteria an individual must meet in order to participate in the WtW program. Not every TEA recipient will meet this criteria. Therefore, a WtW eligibility determination must be made on each individual. The County DHS Office will be responsible for determining WtW eligibility and will certify to the WtW agency that each Individual referred meets the WtW criteria.

The WtW legislation targets those TANF (TEA) recipients who will have the most difficulty transitioning into employment. It divides such individuals into two groups:

(1) The hard-to-employ group; and

(2) The long-term dependence characteristics group. It also states that the WtW agency must spend at least 70% of its funds on the hard-to-employ group and not more than 30% on the long-term dependence-group. As a result, the two groups are commonly called the 70% group and the 30% group. The following sections describe the two groups in detail.

3610 Hard-io-Employ Provision (70% Group)

The WtW regulations mandate that 70% of the funds be spent on participants who are classified as hard-to-employ individuals. The law establishes three different categories of participants who may be served under the 70% provision. In order to participate in the WtW program in the 70% group, a participant must meet one of the following categories.

Category One - An individual must meet each of the following three eligibility criteria:

1. Is a current TEA recipient.

2. Must have at least two of the three following barriers to employment:

a. Has not completed high school or obtained a certificate of general equivalency, and has low skills in reading or mathematics (below grade level 10);

b. Requires substance abuse treatment for employment (as determined through the employment planning process); or c. Has a poor work history. NOTE: Poor work history is defined as having worked ho more than three consecutive months in the last 12 calendar months.

3. Has received cash assistance (TANF or AFDC, including assistance from another state) for at least 30 months, or will become ineligible for TEA assistance within 12 months.

70% Group Continued

Category Two - Non-Custodial Parent. (For more information refer to policy 3621).

Both of the following must be met:

1. The individual is a non-custodial parent of a TEA minor child.

2. The custodial parent of the child meets the three criteria of category one.

Category Three - The individual must meet both of the following criteria:

1. Is no longer receiving TEA assistance because (s)he has reached his or her lifetime limit on receipt of assistance.

2. Has at least two of the following employment barriers:

a. No high school diploma or GED and has tested below the 10th grade level in math or reading.

b. Requires substance abuse treatment for employment. -

c. Has a poor work history (employed no more than 3 consecutive months out of the last 12 months)

3615 Long-Term Dependence Characteristics (30% Group)

The WtW regulations mandate that 30% of the funds be spent on participants who have long-term welfare dependence characteristics. An individual is eligible in the 30% group if he or she meets any one of the following categories.

Category One - An individual must meet both of the following eligibility criteria:

1. Is a current TEA recipient.

2. Has a characteristic associated with long-term welfare dependence such as: has dropped out of school; has had a recent teenage pregnancy; has a poor work history (same definition as in the 70% group); or has other characteristics

30% Group Continued

determined at the local level to be a long-term dependence characteristic. (The WtW agency and the DHS office should work together to determine any such characteristics.)

Category Two - Non-Custodial Parent (For more information see policy 3621)

Both of the following must be met:

1. The individual is a non-custodial parent of a TEA minor child.

2. The child's custodial parent meets the WtW criteria of Category One. Category Three - The individual must meet the following two requirements:

1. Has reached his or her time limit on receipt of TEA assistance,

2. Has a characteristic associated with long-term welfare dependence as described under Category One.

3620 Welfare-to-Work Referral Process

Only individuals who meet the WtW Eligibility Criteria will be referred to the local Private Industry Council (PIC) for WtW services. TEA recipients who meet one of the categories under TEA policy 3610 or 3615 will be considered as appropriate referrals for WtW services. The TEA Worker will be responsible for determining which TEA recipients are referred for WtW services.

Each DHS County Office should coordinate with the local WtW agericy to establish a referral process that will meet each agency's needs. The referral process must include the use of Form DCO-1425 (Referral) and DCO-1426 (Certification). Beyond the use of these forms, however, any other referral and turnaround procedures are at local discretion.

Referrals for WtW services for TEA recipients will be made by completing form DCO-1425 and any other documents agreed upon locally. In addition, the WtW Eligibility Certification form (DCO-1426) will be attached to the referral form. An Employability Assessment and Educational Assessment will be conducted on each TEA WtW client prior to referral for WtW services and copies of those assessments will attached to the DCO-1426.. If the TEA case contains an assessment that was completed within the last six (6) months, then no hew assessment will be needed. Any other employment related information already obtained at the time of referral, such as copies of, the Skills Assessment, Employment Plan, Description of Supportive Services Provided/Arranged, or other information (e.g. latest narrative entry, EPU, etc.) will also be attached. NOTE: Some referrals may not have an Employment Plan since a WtW referral may be made before an Employment Plan is completed.

The WtW agency will use Section IV of Form DCO-1425 to report information regarding WtW activity to the DHS County Office.

3621 Non-Custodial Paren is

The non-custodial parent will be referred for WtW services by the Office of Child Support Enforcement (OCSE). Since the non-custodial parent's WtW eligibility is dependent upon the custodial parent's characteristics, the DHS County Office must make the WtW determination.

The OCSE will request a WtW determination on an non-custodial parent via the OCSE Welfare-to-Work Eligibility/Referral form. Upon receipt of this form from OCSE, the worker will determine a non-custodial parent's WtW eligibility. If eligible, the worker will complete the DCO-1426 and Section II of the OCSE referral form. A copy of the DCO-1426 and referral form will be returned to the local OCSE office while the original DCO-1426 and referral form is forwarded to the WtW agency. If the person is not eligible, the worker will so notify OCSE in Section II of the referral form. A copy of the referral form and the DCO-1426, If completed, should be filed in the corresponding TEA case record.

NOTE: The DHS worker's only involvement with the non-custodial parent will be the completion of the DCO-1426. The DCO-1426, Certification Form will not be given to the non-custodial parent, but will be sent directly to the WtW agency. WtW will report all non-custodial participation and non-compliance information directly to OCSE.

3625 Welfare-to-Work Activities

Allowable activities under WtW include the following:

1. Employment (Unsubsidized and Subsidized)

2. Community Service Programs

3. Work Experience Programs

4. Public or Private Sector Wage Subsidy Job Creation

5. On-the-job Training

6. Job Placement

7. Job Readiness

Some supportive services (e.g. transportation assistance, child care assistance, substance abuse treatment, etc.) are also available through WtW when otherwise not available. However, if such supportive services are available using TEA funds, the TEA Worker will authorize such services. NOTE: TEA funds may be used to pay for supportive services for TEA recipient WtW clients but not for non-custodial parents.

Post Employment Services are available under WtW for individuals who have entered employment. The purpose of Post Employment service is to help individuals maintain and/or enhance their employment. Services available may include,

Basic education,

English as a second language,

Occupational skills training, and

Mentoring.

Education and training activities are available only as Post Employment Services.

3630 Welfare-to-Work Participation

The DHS County Office should ensure that the local WtW agency is aware of the minimum participation requirements for TEA.

When a TEA recipient is engaged in WtW activities, the worker should report the recipient in a TEA activity (e.g. OJT, Work Experience. Subsidized Employment) that appropriately reflects the services being provided by the WtW agency.

3635 Follow-up and Monitoring of Participation Activities

Once enrolled by the local WtW agency, DHS will assume that the client is participating satisfactorily unless notified by the WtW agency that the client is not complying. Follow-up and monitoring procedures will be developed by the local DHS County Office and the local WtW agency.

3640 Non-Compliance

Non-compliance by a TEA participant will be reported by the WtW agency to the local DHS office. Once failure to comply has been reported, DHS will contact the client to give him or her an opportunity to explain why he or she failed to comply and make a determination of good cause, if appropriate. The procedures outlined in TEA 3500 will be followed for TEA clients who are referred to WtW and fail to comply with program activities.

NOTE: Non-compliance by a non-custodial parent will be handled by the WtW agency and OCSE.

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INSTRUCTIONS DCO-1425

Purpose

The DCO-1425 is used by the county DHS ofifice to refer an eligible TEA recipient to the Welfare-to-Work (WtW) agency for employment services. It is also used as a turnaround form for the WtW agency to report information regarding the individual's participation to the county DHS office.

Completion

The DHS worker will complete Sections I - EI. Section I is self-explanatory. In Section II, the worker will indicate any attachments to the referral form. Section III is self-explanatory.

The WtW agency will complete Section IV which is self-explanatory.

Routing --

The DCO-1425 will be routed to the WtW agency when the individual is referred for WtW services with a copy retained in the TEA case record until the turnaround form is received back from the WtW agency.

The WtW worker will route the form back to the TEA worker as soon as there is any information to be reported in Section IV.

The actual routing method, e.g., fax, mail, etc., and other coordinating factors will be worked out locally between the county DHS office and the WtW agency.

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INSTRUCTIONS DCO-1426

Purpose

The DCO-1426 is used by the DHS county office to certify that an individual is eligible for Welfare-to-Work (WtW) services.

Completion

The caseworker will complete the DCO-1426 to indicate in which WtW group and category the individual is eligible. Part A will be completed if the individual falls into the Hard-to-Employ (70%) group and Part B will be completed if the individual Is in the Long-Term Dependence Characteristics (30%) group. Only the Part (A or B) appropriate to the individual will be completed.

Routing

For TEA participants, the completed DCO-1426 will be attached to the DCO-1425 (Welfare-to-Work Referral & Participation Turnaround) and routed to the WtW agency. A copy of the DCO-1426 wiil be retained in the TEA case record.

For non-custodial parents, the completed DCO-1426 will be attached to one copy of the referral form received from the Office of Child Support Enforcement (OCSE) and routed to the WtW agency. A copy of the DCO-1426 will be retained in the corresponding TEA case record. (Do not send a copy of the DCO-1426 to the OCSE. Only the referral form received from OCSE will be returned to that office indicating whether the non-custodial parent was certified as WtW eligible.)

ADDENDUM 2

ARK. \NSAS

STATE PLAN FOR TITLE IV-A OF THE

iSOCLAL SECURITY ACT:

TEMPORARY ASSISTANCE FOR NEEDY FAMILIES

BLOCK GR\NT WELFARE-TO-WORK FORMULA GRANT

This addendum to the Arkansas Temporary Assistance for Needy Families (TANF) plan will provide Transitional Employment Assistance (TEA) to move hard to employ TANF recipients with significant employment barriers into unsubsidized jobs offering long term employment opportunities. These funds will provide welfare recipients with job placement services, transitional employment, job retention and support services to achieve the ultimate goal of long-term employment and economic self-sufficiency.

ANNUAL STATE PLAN UNDER SECTION 403 (a)(5) OF

THE TEMPOR.\RY ASSISTANCE FOR NEEDY FAMILIES

BLOCK GRANT \VELFARE-TO-WORK

FORMULA GRANTS

STATE OF ARKANSAS Submitted March U, 1998

FOR THE PERIOD OF

May L 1998-September 30, 1998, .,,,._._..

I. Welfare-to-Work Description

The Arkansas Employment Security Department (ESD) is the State Administrative Agency for the Welfare-to-Work Program. The Department of Human Services (DHS) is responsible for the Temporary Assistance for Needy Families (TANF) Program which in Arkansas is called Transitional Employment Assistance (TEA). These two agencies and others have worked closely in developing the state's implementation of welfare reform. The local Private Industry Councils (PIC) will continue these collaborative efforts in assisting welfare recipients to make the transition to gainHil employment.

A. Program Design

1. Forming successfial interagency linkages is important in a work first program to facilitate seamless movement of participants into and between activities and into employment. The state will promote and strongly encourage a broad-based coordinated response utilizing all the resources at the local level to assist the hard-to-employ welfare recipient and qualified noncustodial parents in finding sustained, unsubsidized employment.

DHS will certif[GREATER THAN]', and refer hard-to-employ TANF recipients and qualified noncustodial parents to the PICs through local agreements/arrangements. DHS W'ill provide copies of case history, assessments and supportive service needs, along with an eligibility certificate of all individuals referred. Potential participants will be directed to DHS for certification and referral to the PIC. DHS has financial responsibility for audit exceptions involving all ineligible referrals. Assessment will be conducted as follows:

(1) Medical/heahh screening services by the Department of Health, alcohol and other drug prevention, assessment and treatment services by the Bureau of Alcohol and Drug Abuse Prevention (AOD),

(2) Literacy by Adult Education and/or Literacy Council-All participants performing below 10th grade level will be referred to the local adult education program for academic skills improvement.

(3) Work Skills will be determined through a comprehensive process at the local level.

Case Management will be provided to individuals who need assistance before and after entering the labor force. Case Management is designed to take into account the "whole person," which facilitates closely coordinated delivery of services at the local level.

Local PICs will place eligible participants in a job and provide supportive services which are not otherwise available but are necessary to assist in the transition from welfare to work. This process will include transition skills, retention skills, rapid reemployment, advancement skills and supportive services which may include but are not limited to alcohol and other 'addictions for job retention.

The State's program goals Will be to:

reduce the number of families on welfare through full-time employment and/or continued, participation in program activities until off welfare;

increase employment among families on welfare through part-time or full-time employment and support for combining work and welfare;

increase the income of families through job placement and training in order to enable the client to become self sufficient; and to empower each client with the skills to maintain the job and advance within the position. In some cases, post termination services such as child care assistance, assistance with transportation, and employer mentoring, among other activities will be available to assist in the client's triumph over poverty. Other benefits to assist clients to become self sufficient through work pay are job search and job development geared to higher paying jobs, and more opportunity allowed for education or training that can increase earnings;

keep applicants from becoming long-term recipients through job search and to help applicants avoid re-enrolling in welfare, and place emphasis on getting people quickly into the program;

move long-term recipients into jobs through marketing work, teaching basic work habits, and providing supervised .wojk experience and job development for those unable to" find jobs on, . theirown;

increase the ability of qualified noncustodial parents to provide court ordered child support through job placement and other assistance as appropriate;

reduce recidivism through transitional benefits and support services for those who leave welfare and to help with obtaining work-related benefits such as earned-income credit, WOTC, and reemployment assistance for those who lose their job; and achieve long-term cost effectiveness through job search supplemented by other employment focused activities, more attention to serving long-term recipients, and focus on reducing recidivism.

The above goals will assure that appropriate activities and ser\'ices.are provided to help these participants achieve self-sufficiency.

2. Strategies:

The state will promote and strongly encourage welfare-to-work, activities that will assist participants to receive employment at wages that will ensure the achievement of self-sufficiency.

a. PICs are responsible for job placement. The PICs will describe in local plans how this task will be completed and how the coordination will take place with the local TANF agency. Employment Activities will include, but are not limited to, unsubsidized employment, subsidized private sector employment, subsidized public sector employment, work experience, on-the-job training, job search and job readiness activities, commumty service programs, vocational educational training, job skills training related to employment, education related to employment (if not HS or GED), secondary school or GED, trial jobs, job coaching, mentoring, job sharing, job retention skills and supportive services when otherwise not available. Trial jobs will be utilized when a client through assessment shows interest in several occupations, then a contract will be developed with employers offering the client an opportunity to try the job for a short time;

b. Contracts and other financial or non-financial agreements whh public, private, and/or other State entities for the provision of employment-related or other services will be utilized. PICs will utilize their curtent approved service providers, and/or RFPs to reach organizations not traditionally used for services such as faith-based organizations. These contracts atid/or agreements wiir include activities such as intake; preprogram assessment, including preprogram assessment to determine the client's need for supportive services and/or other available services; assessment and testing of qualified participants to determine job readiness; training needs, including on-the-job training or work experience, work-flex needs, job placement of qualified individuals with employers; post-employment services, including program follow-up activities during and after participation, especially in the areas of job retention, customer satisfaction, etc. Entry level positions may not necessarily be in demand occupations, but will lead to positions in demand or grovMh occupations or income levels which will lead to self-.sufficiency. Jobs will be created using wage subsidies to provide incentives for hiring by potential public or private employers.

Before receiving job placement vouchers, participants will sign an employment agreement and search for a job. Participants will have access to an array of services. Information will be provided on eligible service providers who can redeem the vouchers upon successful job placement and retention.

The agency providing the service to the client will be requested to complete the portion of the Job Voucher (JV) which relates to the service provided. The employer(s) will be required to return the JV to the issuing agency as proof of job placement in order for the employer to receive reimbursement.

Programs such as Work Opportunity Tax Credit (WOTC) will be used as an incentive for employers to hire those that they ordinarily would not hire. The Earned Income Tax Credit supplements the wages of qualified individuals by means of refiandable tax credit, "encouraging low wage workers to seek and maintain employment. These credits will be an important tool in the effort to encourage the placement and retention of welfare participants.

3. ESD will develop policies and procedures in collaboration with DHS and local PlCs to govern implementation of welfare to work activities. WtW funds will be used to provide necessary support when not otherwise available to include, but not be limited to, child care, substance abuse prevention and treatment services, Individual Development Accounts and transportation when these services are not otherwise available to the * participants. This will be determined through case management and assessment processes. A tracking system will be developed to provide. continuous monitoring of the client's progress by the case manager.

A common application and tracking system will be developed during the next two years which will include automated determination of eligibility, scanning of proof documents, validation of eligibility, and referrals. The results will be able to be injected into the information system so that services which are duplicated automatically will be rejected.

PICs will coordinate with local resources that provide supportive type services. If documentation shows local resources are unavailable to provide a particular support service, then WtW fiands may be used to contract for such services.

PICs will compile a list of local providers that provide or can provide supportive services, establish a contact person in the agency that has authority to commit the agency to expenditures for ser\'ices or to have knowledge that funds are not available to provide the services needed from the particular agency. When a contact is established, statements from the . contact must be placed in individual folders of participants stating that funds are not available by the local providers and WtW fiinds are utilized for the service. If services are provided from another funding source, it should be noted on the Individual Service Strategy for the participant.

4. The State has set the following goals:

a. placement in unsubsidized jobs,

b. Duration of 12 months placement in unsubsidized jobs,

c. 2% increase in earnings. (From wage at placement to wage at 12 months in work force) and d. ESD will include DOL performance measures as part of Arkansas' performance goals when they are published.

5. PICs established under the Job Training Partnership Act, in coordination with Chief Elected Officials, will administer the WtW program at the local level. The PICs will fully coordinate activities with all local TANF offices within the SD A. See Attachment "A" for the role and responsibility of the WtW administrative agency. See Attachment B for the role and responsibility of the TANF agency. See Attachment C for a list of the Private Industry Councils (PICs) and entities responsible for program administration.

WtW program implementation target date is May 1, 1998.

6. Policies/procedures regarding:

a. Identification and referral of participants - The Department of Human Services (DHS) will identify, certify, and refer eligible

. TANF recipients and qualified noncustodial parents tdlKe WtW

program operators. DHS will accept financial responsibility.for ... ...:,.

audit exceptions involving all ineligible referrals made by DHS and will maintain all eligibility documentation on referrals. DHS will forward a form/certificate to the Local WtW operator stating that the individual meets the eligibility criteria to receive WtW services.

b. Assessment and Case Management-Comprehensive case management will be used to help participants overcome barriers to sustained employment and to solve problems that occur on the job. An individualized service strategy must be in place for each participant, taking into account participant assessments, including the TANF assessment and the TANF individual responsibility plan. Intake, assessment, eligibility determination and case management will be incorporated into the program design of any allowable WtW activity.

PICs will closely coordinate with the local TANF agencies in ; providing assessment and case management to eligible participants. The State is in the process of determining whether one skills assessment instrument will be used for all programs. If it is decided that one will be used, it will be used for WtW purposes. WtW activities must be coordinated with activities through the TANF grant and other related resources. These include, but are not limited to, alcohol and other drug prevention, inter\'ention and treatment services, Child Care and Development Fund, the JTPA programs, State employment service, private sector employers, labor organizations, business and trade associations, education agencies, housing agencies, community development organizations, transportation organizations, community-based and faith-based organizations, disability community organizations and colleges and universities which provide some of the assistance needed by the targeted population.

Local TANF agencies will coordinate with PICs to assist in transitioning individuals from welfare- to- work and obtaining self-sufficiency by identifying barriers to employment on the front-end when possible, help individuals overcome those barriers and to obtain employment.

7. Monitoring will be conducted to ensure adequate fiscal controls and achievement of quality program outcomes for WtW participants as follows:

a. The State will conduct reviews to ensure that local PICs are expending at least 70% of the grant funds on individuals who are long-term welfare recipients (with 30 or more months o_f receipt), . or who face termination from TANF assistance within 12 months . ANDwho face two of three specified labor market deficiencies (lack of high school diploma or GED and low reading or math skills; requiring substance abuse treatment services for employment; or have a poor work history) or a noncustodial parent of a minor(s) whose custodial parent meets the criteria stated above.

Additionally, the State's monthly monitoring will ensure that not more than 30% of the grant funds are expended on individuals who have characteristics asisociated with long-term welfare dependence, such as school dropout, teen pregnancy, or poor work history, and who are either recipients of TANF assistance or- noncustodial parents.

The State will require each PIC which receives WtW fonnula funds to ensure adequate fiscal controls by requiring the establishment of separate fimd ledgers. The State's financial analysis will include review of these fund ledgers to ensure that the grant recipient has documented grant expenditures by cost category. With reference to contracts or vouchers for job placement services in the private sector supported by WtW funds, the State will require all such instruments to include provisions ensuring that at least one-half Q/2) of the payment occur only after an eligible individual placed into unsubsidized employment has been retained by the employer for six (6) months. Financial monitoring will include procurement activities, and the State will require all PICs to justify contracts and subcontracts with other organizations which utilize WtW. formula dollars as a funding source.

Regarding the use of these specific Federal funds, the State certifies its adherence to the common rule "Uniform Administrative Requirements for Grants and Cooperative Agreements to State and Local Governments," per the regulations at 29 CFR Part 97 .. PICs which provide WtW funding for authorized services with other entities or subcontractors, such as institutions of higher education, hospitals, and other nonprofit organizations, must require these organizations to certify compliance with Office of Management and Budget Circular A-110; as codified in the regulations at 29 CFR Part 95 . The State will ensure that all governmental and nonprofit organizations receiving WtW funds follow the audit requirements of Office and Management and Budget Circular A-133_,_regarding additional fiscal controls including audit requirements, as codified at -. 29 CFR 97.26 for governmental organizations and at 29 CFR 97.26 for institutions of higher education, hospitals, and other nonprofit .organizations. Each PIC will establish/provide to the State its internal policy prohibiting any PIC member from casting a vote on, or participating in any matter which would provide direct financial benefit to that member.

Program activities will be monitored to ascertain that funds are being expended to help move eligible individuals into long-term unsubsidized jobs by any of the following means: job creation through short-term public or private sector wage subsidies; on-the-job training contracts with publig or private providers of job readiness, job placement, and post-employment services; job vouchers for similar services; community service or work * experience; or job retention and supportive services such as, transportation services, substance abuse treatment sei*vices, child care and housing assistance. Program outcomes will be reviewed to determine whether the PIC has succeeded in ser\'ing eligible individuals in terms of (1) placement in unsubsidized jobs; (2) duration of such placements; and (3) increase in earnings.

b. Monitoring will be conducted monthly through desk reviews, and at least annually on-site. Monitoring will be conducted in partnership with DHS. Monitors from both agencies will function as review teams and/or will use the same procedures and policies in their individual monitoring visits.

c. Teclinical assistance will be provided as a tool for .corrective action and program improvement to address any program or.financial findings identified during monitoring. Technical assistance will also be provided to assist in implementing and/ordeveloping innovative programs.

8. The State will promote, strongly encourage and monitor coordination among WtW, TANF, JTPA, School-to-Work, Career Development Centers, Employment Ser\'ice, and other employment and training systems throughout the state to prevent duplication of services. WtW, TANF, and JTPA will be a triage which will have a shared single assessment, employment plan, and referral system which will preclude duplication of semces. When a Career Development Center is implemented within an SDA the triage concept moves into the career development center system and will have thesame capability to prevent duplication of services.

9. The state will promote and strongly encourage coordination with \ transportation pro\'iders to ensure that the transpdrtation.needs of.those moving from welfare to work are met. PICs will be encouraged to coordinate with local agencies that provide transportation services through agreements to allow WtW clients access to transportation. PICs will utilize buses provided by schools and faith-based organizations, taxi service, public/private buses, car pools, and other local resource agencies through agreements/arrangements to provide the transportation needs of those moving from welfare to work.

10. The State will promote and strongly encourage coordination with public and assisted housing providers and agencies, community-based organizations, faith-based organizations, public and private health and mental health and alcohol and other drug treatment service agencies, and. rehabilitation service agencies to provide needed services without duplication. ESD will solicit coordination and input through public notices and invitations to attend public meetings and other events, as well as through a request for proposals to provide services for special projects to assist long-term welfare recipients.

The PICs will utilize agreements/arrangements with local housing providers.

B. Distribution of Funds

Eighty-five percent (85%) of available funds will be allocated to the Private-Industry Councils of each of the ten Service Delivery Areas within the State, and fifteen percent (15%) of available flindswill be,retained by the State for welfare to work projects to help long-term recipients of assistance obtain unsubsidized jobs.

The following factors will be used in the State's formula to distribute funds to the substate areas:

Fifty percent (50%) of the funds will be allocated based on the number of individuals residing in each county who represents those individuals who exceed 7.5% of those individuals living in poverty. This information is compared to the state as a whole to arrive at each county's share. This information is provided by the U.S. Census Bureau.

Fifty percent (50%)) of the fijnds will be allocated based on the number of welfare cases which represent individuals residing in each county who is receiving and have received welfare assistance for the past thirty months compared to the total . number of welfare cases containing such individuals within the State .who meet the same criteria. Informationprovidedby the Arkansas Department of Human Services will be used for this factor. ."

No PIC within the State will receive less than $100,000.00 using the above factors (See Attacliment "F"). Funds will be allocated to PICs within 30 days from the receipt of the State's fund allotment.

C. Coordination and Consultation

Representatives from Employment Security Department and Department of Human Services met October 15, 1997, to discuss initial planning strategies. It was decided that ESD would write the plan with input from DHS, private industry. councils (local substate areas). Department of Transportation, state housing authority, community-based organizations, Bureau of Alcohol and Drug Abuse Prevention, Office of Child Support Enforcement (OCSE) and Vocational Rehabilitation. Each agency provided contact names and phone numbers in order to facilitate coordination of the plan. It was decided that DHS will provide the number of individuals who have been receiving welfare 30 or more months, by county, to use as a factor in the development of the formula. See attachment "E" for additional coordination efforts.

Notice of the availability of the State's and the PIC's proposed WtW plans for review and comment will be published in the statewide and local newspapers for a 3-day period, and at least 30 days before the proposed effective date. PICs will notify ESD of all comments received and actions taken as a result of those comments. ESD also will provide and make available to the public.any.comments received and actions taken on those comments.

The required newspaper announcement will include, at a minimum, the following;

a. A notice of the intent to make the plan available;

b. The date on which the proposed plan is to become effective;

c. A brief summary of the nature and purpose of the plan;

d. The location and hours that the proposed plan can be reviewed; and e. A contact name and telephone number to call for additional information.

All comments received are summarized. See attachment G

D. Expenditure of Funds.

1. . ESD will maintain an administrative cost rate of 15% through a_cost allocation process and desk review of monthly financial reports. The State will retain a minimum amount, if any, to administer the program with the PICs having the larger portion, the total will not exceed 15%.

2. The State will promote and strongly encourage the coordination of activities between the PICs and local TANF agencies to prevent the duplication of services. The State will ensure the coordination of WtW expenditures with TANF through a monitoring process conducted jointly by ESD and DHS.

E. Application for Waiver

Although the Governor will not apply for a waiver to have an agency other than a private industry council administer the funds provided under this award at this thiie, tiie Governor is implementing the following procedure to comply with 20 CFR 645.400(a)(2) of the WtW Regulations, which state in part. . . "if, during the operation of the local WtW program, the Governor determines that the PIC, or alternate agency which is administering the program, has not coordinated its expenditures with expenditures of funds provided to the. State under TANF, the Governor shall request a waiver after the second notice of failure to coordinate expenditures." An RFP process will be utilized to select an alternate agency to administer WtW funds for the area.

If the Governor opts to apply for the waiver, then the process w-ill continue as stated in 29 CFR 645.400 . The decision of the Secretary shall constitute final agency action.

II. 15% PROJECTS

The State will reserve 15% of the WtW funds for projects to assist long term recipients of assistance enter unsubsidized jobs and to administer the WtW grant. The main focus of these projects will be the work first strategy, transitional employment services, and job retention skills. A portion of these funds will be distributed to public, private nonprofit, and private for profit entities, including PICs, governmental entities, community-based organizations, and community development cooperations, through a request for proposal process. Also, a portion of these funds will be used to provide additional support for 85% funded projects operated by the PICs.

III. ESTIMATE OF MATCHING FUNDS

A. ESD estimates matching expenditures in the amount of $4,245,145.00 during the tlifee-year expenditure period for this grant. The Sources ofmatch aire anticipated . to be from state and local levels. The Arkansas General Assembly meets every two years and it will convene in January 1999. ESD will ask the General Assembly for a State appropriation of $4.25 million. PICs will be asked to identify in their plans the amount and sources of match they will provide and whether it will be cash or in-kind. A tracking policy is being written, and all match, in-kind and cash, will be required to be reported and accounted for. This will be an item monitored . regularly.

B. ESD will monitor WtW expenditures through monthly desk review of financial reports to ensure the State meets its projected match.

C. The State will use its matching funds for administration, to assist with acquisition of.hardware and software to track and monitor implementation of WtW, for

., capacity building for staft'persons working whh WtW eligible individuals, and for special projects, competitively awarded, to serve individuals eligible for WtW.

IV. FUNDING

Planned expenditures by quarters:

See Attachment D

V.

ASSURANCES

The State/Commonwealth of Arkansas, assures to the following requirements under Title IV-A of the Social Security Act.

PROGRAM ADMlNlSTR\TION/ACTIVlTIES

1. The State is an eligible State, pursuant to Section 402(a) for.the fiscal year. Stafutoiy

Citations: Section 402(a) and Section -t03(a)(5)(A)(ii)(}V).

2. The State assures that qualified State,expenditures (within the meaning of Section 409(a)(7) for the fiscal year will not be less than the applicable percentage of historic State expenditures (within the meaning of Section 409(a)(7) with respect to the fiscal year. Statutoiy Citations: Section -f03(a)(5)(A)(ii)(lO; Section 409(a)(7).

[That is, the State has met its TANF maintenance-of-effort requirement under Section 409(a)(7) for the fiscal year].

3. The State has consuhed and coordinated with the appropriate entities in the substate areas regarding the plan and the design of WtW services in the State.. Statutoiy Citation: Section 40S(a)(5)(A)(ii)(J)(cc).

4. The State will make available to the public a summary of the WtW plan. Statutory Citation: Section 402(c).

5. The state has agreed to negotiate in good faith with the Secretary of Heahh and Human Services with respect to the substance and fiinding of any evaluation under Section 413(j) and to cooperate whh the conduct of such an evaluation. Statutoiy Citations: Section 403(a)(5)(A)(ii)(l}I); Section 4}S(j).

6. The State shall not use any part of these grant funds, nor any part of state expenditures made to match the funds, to fulfill any obligation of any State, political subdivision, or private industry council to contribute funds under sections 403(b) or 418 or-any other provision of the SociaTSecurity Act or other Federal Law. Statutory citation: Section 403(a)(5)(C)(vi).

7. The State will return to The Secretary of Labor any part of the WtW funds that are not expended within 3 years after the date the funds are so provided. Statutoiy Citation: Section 403fa)(5)(C)(vii).

8. The State WtW program will be conducted in accordance with tlie WtW legislation, regulatory provisions, future written guidance provided by the Department, and all other applicable Federal and State laws.

9. The State will apply the TANF law and regulations to the operation of the WtW program, unless otherwise specified by the Department or defined in Section 403(a)(5) orthe applicable regulations.

10. The State assures tliat services under the WtW grant are provided to eligible participants only.

11. The State will maintain and submit accurate, complete and timely.participant.and financial records, as specified by the Secretary of Labor, and the Secretary of Health arid Human Services.

12. The State will establish a mechanism to exchange information and coordinate the WtW program operated by the State and PICs with other programs available that will assist in providing welfare recipients employment.

13. The State shall adhere to the.certifications required under TANF and .will meet TANF maintenance of effort requirements.

14. The State will comply with the uniform fiscal and administrative requirements of 0MB Circular A-102 as codified for DOL at 29 CFR Part 97.

15. The State will follow the audit requirements of The Single Audit Act of 1984 and 0MB Circular A-133.

16. The State will follow the allowable cost/cost principles of 0MB Circular A-87.

WORKER PROTECTIONS

1. The State will establish policies to enforce the provisions regarding nondisplacement in work activities under a program operated with funds provided under WtW.. Statutory

.CUation: Section 403(a)(5)(J)(l).

2. The State assures that the Health and Safety standards established under Federal and State law otherwise applicable to working conditions of employees shall be equally applicable to working conditions of other participants engaged in a work activity under a program operated with funds provided under WtW. Statutoiy Citation: Section 403(a)(5)(J)(ii).

3. The State will enforce the provision that an individual may not be discriminated against by reason of gender with respect to participation in work activities under a program operated with funds provided under WtW. Statutoiy Citation: Section 403(a)(5)(J)(iii).

4. The State shall establish and maintain procedures for grievances or complaints from participants and employees under t!ie WtW program. The procedures established will be consistent with the requirements of Section 403(a)(5)(J)(iv). Slatutoiy Citatkm: Section -I03(aj(5j(jj(iv).'.

5. The State shall establish and enforce standards and procedures to ensure against fraud and abuse, including standards and procedures against nepotism, conflicts of interest among individuals responsible for the administration and supervision of the State WiW program, kickbacks, and the use of political patronage.

6. The State w'ill comply with the nondiscrimination provisions of the laws enumerated at

Section 40 S(d), with respect to participation in work activities engaged in under the WtW program.

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VI. PROGR\M ADMINISTRATOR(S)

For the State/Commonwealth of Arkansas specify below which State Agency will be Grant Recipient, and which State agency will be the Administrative Agency and identify the individual who will be the Liaison for the Welfare-To-Work Program.

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ATTACHMENT A ROLES AND RJESPONSIBILITIES OF ESD

ESD will conduct program and financial compliance reviews with assistance from DHS ESD will coordinate the addendum to the state plan and submit to DDL ESD will be the fiscal agent for the Welfare-to-Work program ESD will be the reporting agency for all DDL required reports

ATTACHMENT B ROLES AND RESPONSIBILITIES OF TANF AGENCY

DHS will identify, certify hard-to-employ TANF recipients and qualified noncustodial parents, and refer to the WtW program operators

DHS will maintain all eligibility documentation referrals

DHS will provide all assessment information available upon referral to the local WtW program operator including identification of any supportive services being provided at time of referral

DHS wall accept financial responsibility for audit exceptions involving all ineligible referrals

DHS will provide a list of fianding available for supportive services, i.e., transportation, child care

DHS will promote and encourage the local TANF offices to coordinate and cooperate _, with the local PIC

Provide updated list of local TEAs throughout the State

JTEPA PICs

NORTHWEST

Mike Norton, Executive Director.

Northwest AR EDD

313 Hwy. 62-65, 41 2N

P.O. Box 190

Harrison, AR.72602-019a

Al West, JTPA Director

?h: 741-5404 Harrison

751-3250 Springdale FAX: 741-1905 Harrison

751-4482 Springdale 3-Mail: ACWEST@SPECSNT.COM

Cojantoas-Ssxstfiji:. Benton, Carroll, Boone, Marion, Baxter, Searcy, Newton, Madison, Washington

N. OJRTH__CENTEAL

Van Thomas, Executive Director White River PDD P.O. Box 2396 1652 W'hite Drive Batesville, AR 72501 Freda Wallis, JTPA Director Ph: 793-5233 793-5765 FAX: 793-4035 E-Mail: WRPDD@MAIL.CEI .NET

Izard, Stone, Cleburne, White, Sharp, Independence, Van Buren, Jackson, Woodruff

NORTHEAST

Sammy McGuire, Executive Director

Employment & Training Services, Inc.

2809 Forrest Home Road

Jonesboro, AR 72401

Ph: 932-1564

FAX: 932-5310

E-Mail: ETS@INET-DIRECT.COM

C.ojantiaaJSarxadjL Randolph, Clay, Lawrence, Greene, Craighead, Poinsett, Mississippi

CJLT. y_QE_LI3:TXE_RaC.K

Rick Colclasure

Director Community Programs

Room 220W

500 W. Markham

City Hall Annex

Little Rock, AR ,72201

Ph: 399-3424

FAX: 399-3425

E-M: UNKNOWN

.CaunL±jLas__S£Xvad_L City limits of Little Rock

John Martin, -Chairman Central KR PIC P.O. Box 300 115 Jefferson Lonoke, AR .7 2086 Ronney Larsen, ..Exec... Director Randy Boyd, JTPA Director . Ph: 676-2721 374-4669 Little Rock

376-4119 NLR

565-4170 CADC/Little Rock " -

778-7702 CADC/Benton FAX: 676-5020 E-Mail: CAPDD@AOL.COM

Counties Served: Lonoke, Monroe, Prairie, Saline, Faulkner, Pulaski Counties . Served: Lonoke, Monroe,

WKST CTTNTRAT. .

Pat Heusei, Executive Director

West Central AR PDD. Inc.

P.O. Box 21100

1820 Higdon Ferry Rd.

Suite D

Hot Springs, AR 71903

Jim Bardwell, JTPA Director

Ph:. 525-7577

FAX: 525-7677

E-Mail: PHEUSEL@HSNP.COM

rmmj-ieg Served: JohnSOn, Yell, Pope, Perry, Montgomery, Garland, Pike, Clark, Conway, Hot Spring

WEaTERN

Martha Holt, Administrator

'.-restern AR EDA

P.O. Box 1266

'500 Main Street

Van Buren, AR 72956

?h: 474-7061 V \

474-7093 Intake Office FAX: 474-4321 I-Mail: mholt@ftsmith. net

C.o. un±.i.es_-S.ezxeil:. Crawford, Scott, Sebastian, Franklin, Logan, Polk

S. QII XHHEST

lerry Sherwood, Executive Director

Southwest AR FDD

?.0. Box 767

600 Bessie Street vagnolia, AR 71753

Kathy Campbell, Director

ZTiployment & Educational Dev.

?h: 234-4030

FAX: 234-0135

I -Mail: swapda@state.ar.us

Counties ServedjL"Calhoun, Columbia, Dallas, Hempstead, Howard, LaFayette, Little River, Miller, Nevada, Ouachita, Sevier, Union -

EASJQERN.

Sharon Williams, Exec. Director

Eastern AR PI C

P.O. Box 1388

260 Shoppingway

West Memphis, AR 72303.

Ph: 735-6730 ,

FAX: 732-4995

E-Mail; .PICVENTURE@A0L.COM

Counties-Sarved: Cross, Phillips, Crittenden, St. Francis, Lee

SOUTHEAST

Glenn Bell, Exec. Director

Southeast AR EDD

P.O. Box 6806

721 Walnut

Pine Bluff, AR 71601

Ph: 536-1971

FAX: 536-7718

E-Mail: . GLENBSLL@EARTHLINK. NET

Counties Served: Grant, Arkansas, Lincoln, Bradley, Ashley, Desha, Jefferson, Cleveland, Drew, Chicot -

ATTACHMENT "D"

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ATTACHMENT E COORDINATION EFFORTS TO IMPLEMENT WELFARE-TO-WORK

November 18, 1997 - State faxed planning guidance for PICs to develop their local. Welfare-to-Work (WtW) plans

November 26, 1997 - Faxed the PICs a list of local DHS County

Administrators that administer.the TANF program

November 26, 1998 - Faxed DHS a list of JTPA. PICs . for

Coordination purposes

November 27, 1997 - Faxed the Bureau of Alcohol and Drug Abuse prevention a list of PICs for coordination purposes

December 12,'1997 - PIC WtW Draft Plans received at the State

December 30, 1997 - News release to announce WtW Training Seminar

January 9, 1998 - Faxed invitation and.agenda to PICs to invite their local partners to .the training seminar on WtW regulations

January 12, 1998 - State announced meeting to address the

.State's Draft Welfare to Work Plan

January 13, 1998 - Arkansas Career Opportunity Partnership

Cabinet met to discuss proposed statewide policies and procedures to implement the state's Welfare-to-Work program

January 20, 1998 - Faxed proposed State policies and procedures to implement WtW to the Arkansas Career . Opportunity Partnership Cabinet

January 22, 1998 - State and PICs met to discuss the proposed statewide WtW policies/procedures

January 26, 1998 - -Faxed to the PICs proposed policies and procedures discussed during the January 22, meeting for written comments

January 28, 1998 - WtW Regulations Training provided by DOL/DHHS

Regi on VI, sign-in sheet noting agencies in attendance are attached

January 28, 1998 - Provided copies of the State TANF plan to the

PICs

February 10, 1998 - The COPC met and approved the WtW statewide policies/procedures

, February .19,. 1998 '- .DHS provided .the number of welfare recipients by county to use in the State's 85% allocation formula

March 10, ,1998 - The COPC met discussed and.approved the

State's WtW plan

March 31, 1998 - The COPC met discussed and approved the State's WtW plan

State based on the .above coordination at the State and local level, .training and guidance provided by the State.

Attachment F

Welfare to Work Private Industry Council Allocations:
Central	#05-FY9S-WtW-9O	$ 826,311
Little Rock	#05-FY98-WtW-80	646,480
. Eastern	#05-FY98-WtW-31	1,427,263
Nonh Central	#05-FY98-WtW-20	537,648
Noiilieast	#05-FY98-WtW-30	755,593
Nonhwest	#05-FY98-WtW-10	415,685
Southeast	#05-FY98-WtW-40	1,258,814
Southwest	#05-FY98-WtW-50	860,958
Western	#05-FY98-WtW-60	424,345
West Central	#05-FY98AVtW-71	572,288

ATTACHMENT G

Summary of Comments:

o Concern on 6 month retention period.on placements, believes that employers would have issue with this time frame;

o Clarification on items/statements that were not clear to the reader, e.g. the assessment process, supportive services, program activities, case management, and goals;

o Will the State specify program outcomes;

o How long will certificates of eligibility be good for;

o Who will impose sanctions, if any;

o What system will be used to track clients;

0 Recognize, acknowledge, and address the necessity for serving "Noncustodial parent";

o Describe coordination with Rehabilitation Services;

o Reduce the State's share of administration to 2%

o Recognize, acknowledge, and address the necessity for

Alcohol and other Drug Prevention Intervention and Treatment Services;

o Placement goal of 65% is too high;

o When will funds be received by the PICs;

o Who will monitor and what will they monitor;,

o What are the performance, standards; .. ,.

o Will match be allocated to the PICs

Arkansas Administrative CodeAgency 016 - DEPARTMENT OF HUMAN SERVICESDivision 20 - Division of County OperationsRule 016.20.98-017 - Title IV-A: State Plan Addendum - Welfare-to-Work Grant; TEA Policy 3600-3640; Forms DCO-1425 & DCO-1426

Arkansas Administrative Code
Agency 016 - DEPARTMENT OF HUMAN SERVICES
Division 20 - Division of County Operations
Rule 016.20.98-017 - Title IV-A: State Plan Addendum - Welfare-to-Work Grant; TEA Policy 3600-3640; Forms DCO-1425 & DCO-1426