135.212 Vocational Educational Training and Postsecondary Education

Vocational Educational Training is defined as a specific curriculum of training provided by a contracted employment and training vendor, an accredited educational provider, or an accredited Internet-based educational institution that is intended to prepare the participant for a specific occupation.

Vocational education training is limited by the federal government to 12 countable months in a lifetime with respect to any individual. Pennsylvania chooses to allow individuals to claim good cause to participate in approved vocational educational training that are not federally counted such as noncore activities or activities that last beyond the 12-month limit. See Section 135.41, Good Cause Circumstances and Section 135.212 , Vocational Educational Training and Postsecondary Education , Six-month Extension Criteria .

A lack of general education, English proficiency, adult basic education, and postsecondary training/education have been identified as major barriers to recipient employability and ability to obtain jobs with family-sustaining wages. Pennsylvania aims to improve client access to education and training to improve employability. All cash assistance recipients, regardless of TANF/ETANF status, without a high school diploma or GED, regardless of age, may pursue HSE, (which includes GED exam, or High School Equivalency Test (HiSET)). Likewise, all cash assistance recipients in need of ESL or ABE may pursue English language training or adult basic education. In all instances, recipients will receive good cause to waive the requirement to fulfill additional core or noncore hours and activities. See Section 135.41, Good Cause Circumstances .

If the CAO indicates an individual’s interest in education or educational barriers on the individual’s AMR , a referral should be made to the appropriate contracted program . The provider may then enroll the participant in vocational education activities , including postsecondary education if it facilitates the short- and long-term goals indicated on the AMR The E&T provider will complete a service plan for the participant that indicates the anticipated start and end date of the vocational educational activity.

Vocational educational training and postsecondary education may only be counted in the federal Work Participation Rate (WPR) for 12 months in a lifetime. Any amount of education time used in a month counts as one month used.

When a TANF student is meeting their participation hours in core activity other than vocational educational , the educational time does not need to be counted against their 12-month federal limit. The educational activity in this instance should be coded Activity 38 on the ETP Project Enrollment screen. TANF clients who meet their hourly core RESET requirement in another approved activity may continue to receive SPALs to support their education activity.

For an individual who is choosing a post-secondary vocational education activity that is expected to last more than 12 months, they must utilize good cause (GC 87) to continue that activity to improve employability and facilitate the short- and long-term goals outlined on the AMR. The CAO and the individual will complete and attach the Vocational Education Extension Addendum to the AMR for any individual participating in a vocational educational activity past 12 months.

NOTE: The CAO may approve education plans for individuals regardless of how many months of TANF they have received.

V erification of participation is required. The contracted program will request and verify hours for each student prior to entering them into CWDS. In limited situations where the student is unable to participate in an accredited educational institution via a contracted program, the CAO will verify hours.

Due to changes in technology, a client participating in vocational educational activities on campus or online may have their hours of participation verified utilizing several different methods. Methods include:

The completion of the Employment and Training Activity Verification Form (PA 1895) when no other method of verification is available; OR

An approved contractor attendance sheet that contains the same data captured in the PA 1895; OR

Progress reports/grades from college; OR

Documentation of expected assignments and confirmation of completion and submission of assignments on a weekly basis; OR

Electronic communication with the instructor or college personnel to verify the student is attending class or completing required assignments and progressing satisfactorily; AND

· Documentation of the class schedule and accredited educational institution’s study policy if applicable.

The student may have hours verified by:

1. An instructor, or other college personnel, such as, but not limited to, a staff member in the registrar’s office, financial aid office, or academic department, may sign the PA 1895 to verify hours of participation on a weekly basis at minimum.

NOTE: Please contact the Bureau of Employment Programs if the job title of the college personnel who has verified hours of participation is questionable. Signatures may be physical or electronic.

2. An E&T program case manager when the E&T provider is facilitating the vocational educational activity.

3. Electronic time sheets, time clocks, swipe cards, or telephone time and attendance sheets to verify the hours of participation via the accredited educational institution or the E&T program.

The accredited educational institution’s study policy must be obtained and retained. This document identifies the number of study hours expected by the school.

In the rare instance where an individual is not enrolled with a contracted program, if adequate verification cannot be obtained, the CAO will schedule a compliance review appointment to secure verification of participation in the self-initiated vocational education/training activity.

The CAO will continue to follow the compliance review process when:

the individual has not provided the required attendance verification or the form verifies the individual is not participating in the self-initiated activity for the required number of hours

the CAO has information that the individual is no longer attending the educational/training activity

the contractor terminates the enrollment from the activity

If the individual responds to the compliance review, determine the appropriate next step based on the discussion with the individual. If the interview and case review reveals no good cause for the non-compliance, begin the sanction process.

Vocational educational training includes:

Attendance at a school offering a license, certificate, credential, or non-transferable associate’s degree designed to give the participant skills and knowledge necessary to perform the duties of a specific job or occupation.

Upgrades of an individual’s job-related skills including instructional certificate and credentialing programs that are awarded based upon completion or accumulated credits.

A ctivities including ESL intended to improve an individual’s proficiency in English and Adult Basic Education/Literacy (ABE) to increase literacy levels consistent with employment goals are counted toward participation in vocational educational training when integrated with the career-specific curriculum and embedded within a program that prepares the individual for employment. Standardized test scores from TABE (Test for Adult Basic Education), BEST (Basic English Skills Test) CASAS, and Work Keys are used to determine if ESL, ABE, or remedial education are necessary for the individual to prepare for employment.

Postsecondary education includes:

Attendance at a community college program that offers an associate’s degree or bachelor’s degree program intended to prepare the participant for a specific occupation.

NOTE: All TANF applicants or recipients who self-initiate into one of Pennsylvania’s 14 community colleges are required to be referred to KEYS if available.

Attendance at a four year college which offers an associate’s degree intended to prepare the participant for a specific occupation if a community college is not located within a reasonable distance.

Attendance at a four year college which offers a Baccalaureate degree intended to prepare the participant for a specific occupation.

NOTE: Nonspecific degree programs like liberal arts , general studies , and graduate degree programs cannot be approved or supported on the AMR. Exceptions exist when the school recommends the individual enroll as non-declared or general studies with the intent to enroll or transfer into a High Priority Occupation (HPO) program.

Cash assistance recipients, regardless of TANF/ETANF status, participating or interested in participating in post-secondary education at any college, university, or trade and technical school may now receive good cause to extend vocational education activities to 24 months in a lifetime, with the possibility of six-month extensions thereafter if they meet all extension criteria. The CAO must input code 87 into the good cause/tracking code field in eCIS for individuals that have exhausted the federal 12-month limit of vocational education to receive good cause to extend vocational education activities time-limits to 24 months in a lifetime with the possibility of six-month extensions thereafter if they meet all extension criteria. The CAO and E&T contractor must ensure the AMR is kept up to date to capture correct information.

Six-Month Education Extension Criteria

To qualify for six-month extensions, after 24 months of participation in a

vocational education activity, students must meet ALL conditions at the time of

extension eligibility determination:

Must be engaged in a degree or certificate program that will likely lead to

employment in a High Priority Occupation as defined by the Department of

Labor and Industry;

Must not be enrolled in any remedial courses;

Must have a cumulative Grade Point Average (GPA) of 2.0 or above*; and

Must have completed an average of at least eight credit hours per

semester.

NOTE: Post-graduate (for example, a master’s degree) vocational education

activities are not allowable activities for TANF/ETANF or SNAP E&T participants.

*For post-secondary educational programs that do not assign credits or GPAs, the

educational institution will be required to confirm that the individual is meeting satisfactory progress toward completion as defined by the institution.

All six-month extensions MUST be approved by the Bureau of Employment Programs (BEP). The CAO will send six-month extension requests for Cash E&T participants to RA-PWBEP.TANF@pa.gov and for SNAP E&T participants to RA- PWBEP.SNAP@pa.gov . The CAO must send the request with the individual’s most recent transcripts. BEP will take no longer than two business days to provide a response once all required information is received. The CAO must narrate the outcome and update the AMR/EDP if necessary.

NOTE: Individuals who do not meet all six-month extension criteria will be reviewed by BEP for good cause prior to making any extension denials.

Individuals participating in an educational activity can meet the core participation hours through a combination of course and study time hours.

If the individual does not meet the core participation hours the individual must participate in additional core activities unless they qualify for good cause . For a list of core activities see Section 135.2 , Employment and Training Activities .

During breaks that occur between semesters the student’s work participation requirement must continue to be met. Students who do not enroll in classes during the summer session must meet their hours of participation in other core work activities.

Defining Study Time Hours

Study time is the time that a student spends preparing for or completing course work assignments. A student may receive one hour of unsupervised study time for each one hour of class time with no additional verification needed other than the school’s study policy. Study time that is documented and monitored by the employment and training contractor or accredited educational provider can also be counted. Total study time hours , unsupervised and supervised, may not exceed the number of study time hours expected for the course as determined by the school ’s study policy . Count the combination of monitored and unmonitored study time toward participation hours.

Example: A TANF parent attends community college and participates in KEYS. The TANF parent is enrolled in 4 classes and has 12 hours of class time scheduled weekly.

The TANF parent is eligible for 12 hours of unsupervised study time per week. The TANF parent also meets with a tutor at the KEYS facilitator’s office 2 hours weekly for supervised study time.

The 12 hours of unsupervised and 2 hours of supervised study time equal 14 hours of countable study time; however, the institution The TANF parent attends has determined that 2 hours of study time weekly per class is expected.

The maximum study time for which The TANF parent can be credited is 8 hours weekly.

Distance Learning and Remote Participation

The options of remote E&T participation and distance learning are available for consideration by the E&T program upon request by a participant or when an individual’s circumstances make it the best fit. This includes any external factors that may preclude in-person participation such as, but not limited to, exhaustion of annual transportation SPALs, limited participation options in rural locations, and/or health risks/conditions for the individual or other household members.

Distance learning, including blended learning (hybrid of online and in-person classes), is remote participation in a vocational educational activity via an accredited educational institution or DHS contracted provider. The availability of local, in-person vocational education opportunities does not prevent an individual from participating in distance learning.

Remote E&T participation can be defined as using technology such as a telephone, computer, or other electronic device to engage in unpaid work-related activities. Remote participation also includes the provision of paper packets, workbooks, and assignments when internet access or a digital device is not an option or participant’s preference. This also refers to a blended approach of remote and in-person activities.

For both remote E&T and distance learning individuals may provide their own Internet access, OR Internet access may be provided by the accredited educational institution, E&T program, or other community resource.

All E&T providers in the commonwealth are expected to offer approved remote E&T activities, services, and case management to individuals. Remote participation as defined above, does not necessarily mean the individual will be participating online. The E&T program may provide workbooks, services, and case management in a variety of approved ways to ensure that participation is maximized. Lack of internet or digital device must not prevent an E&T referral. The E&T program is responsible to find alternative methods of providing and maintaining individuals in remote participation.

Verification of actual hours of participation is the responsibility of the E&T contractor. When an individual is engaged in remote E&T participation or distance learning, supervision is required to track and verify participation. Daily supervision is provided by the E&T program, the accredited educational provider, or an accredited educational institution on the days the individual is scheduled to participate. Daily supervision does not mean daily in-person contact. The supervision may be by telephone or electronic contact and ensures that the individual participates and progresses in assigned activities.

The CAO does not need to seek approval from the Bureau of Employment Programs (BEP) to allow students to take online classes or distance learning to meet their required hours of participation.

Remote Referrals and Enrollments

The CAO will refer a mandatory TANF or volunteer individual to an E&T program if that individual is not currently enrolled in a program. When referring a TANF individual to a program to participate remotely or via distance learning, the CAO will follow the referral policy outlined. See Section 135.11, RESET Enrollment Status, Program Referral Chart .

The process for data entry on an AMR will be the same whether the individual is participating in-person or remotely. The AMR will include all information to ensure the participant is able to contact the E&T program including program name, case manager (if known), phone number, address, and email address (if available). All E&T programs are required to conduct outreach prior to an individual’s enrollment date to ensure their needs are addressed for the purposes of participation.

Childcare and other SPALs are available for individuals participating remotely who have a verified need and are eligible for the SPAL type. If an individual requires a SPAL to support remote participation or distance learning activities and need is verified, process the SPAL per policy. This includes, but is not limited to, transportation SPALs to and from childcare locations even when the parent is participating remotely.

The E&T program will assess the individual’s needs and find local solutions to assist mandatory individuals to participate remotely when possible. In instances where they are unable, and the individual is engaged in an allowable activity (per ESA-20048-135) that requires a device. See Section 135.6 , Special Allowances for Supportive Services .

Second and Subsequent Training s

For the purposes of second and subsequent training policy, the CAO will not consider the following to be countable past trainings:

past trainings that were not supported under Pennsylvania’s TANF or SNAP E&T programs;

completion of high school, a high school equivalency program, or an adult basic education program;

completion of an English as a second language program;

completion of a career readiness program that provides only general work skills training, including but not limited to, WorkKeys®; or

any occupation skills program where all requisite coursework was not completed; or

any occupation skills program where all requisite coursework was completed but individual was unable to obtain the required certificate, licensure, or industry credential

Requests for training do not need to be submitted to the Bureau of Employment Programs (BEP) when the individual’s training history is limited to the above scenarios.

The CAO will consider a request to pursue a progressively higher credential in the individual’s field (e.g., CNA to LPN) to be a continuation of the prior countable training, rather than a new countable training. Requests for continuation do not need to be submitted to BEP for approval.

Obtaining BEP Approval

Requests for second and subsequent countable trainings must be submitted to BEP for approval. BEP will approve the request when the individual is pursuing an occupation listed on the local Workforce Development Area’s High Priority Occupation (HPO) list, as published by the Department of Labor and Industry ; AND

An individual is unable to become employed in their chosen field due to changes in physical or mental health status; OR

An individual no longer has the skill level or aptitude necessary to find employment in their chosen field; OR

An individual has a background that now prohibits employment in that field; OR

An individual is unlikely to find employment in that occupation in the area in which they reside that will end the individual’s dependency on TANF and SNAP benefits.

Example 1: A TANF recipient who received a cosmetology license prior to the receipt of TANF benefits requests to start schooling to become a CNA. This is an initial training request and does not require BEP approval. The individual is able to participate in the training.

Example 2: An individual who received their CNA license while a TANF recipient and is now receiving SNAP only wishes to continue education to become an LPN which will increase wage potential significantly. This is not a second training because the individual is continuing to pursue a progressively higher credential in the same field; this is considered a continuation of the first training and does not require BEP approval.

Example 3: An individual graduated from college in 2007 with an associate degree in Performing Arts while receiving TANF benefits. They cannot find work in their field of study. They are now receiving SNAP benefits and wish to seek further education to improve employability. The individual wishes to pursue a non-specific Liberal Arts degree. This second training request must be submitted to BEP.

Example 4: A TANF recipient receives a cosmetology license and obtains a job paying $10 per hour, which is enough to close the TANF budget, but not the SNAP budget. They use five months of vocational education time obtaining this credential. The recipient then requests to pursue a CNA. The CAO submits the second training request to BEP. BEP approves the request, because the individual was unable to find employment in the field paying a high enough wage to close the SNAP budget.

Example 5: The individual described in Example 4 is later charged with an offense that causes them to no longer be able to work in the medical field, reapplies for SNAP only, and now wishes to pursue a CDL. This subsequent training request must be submitted to BEP.

Example 6: An individual, receiving ETANF benefits, obtains their certificate for cosmetology while originally a TANF recipient. The only hairstylist in town shutters their doors and the individual cannot find employment. The recipient wishes to open their own shop and wants to take business class at the local community college. This subsequent training request must be submitted to BEP.

NOTE: Post-graduate (for example, a master’s degree) vocational education activities are not allowable activities for TANF or SNAP E&T participants regardless of DHS support in past trainings.

Submitting Second and Subsequent Training Requests

All second and subsequent training requests should be submitted to the BEP.

For Cash recipients contact: RA-PWBEP.TANF@pa.gov

For SNAP recipients contact: RA-PWBEP.SNAP@pa.gov

Please include case record information and pertinent details regarding the individual and their previous education. Please allow two business days for a response.

If BEP advises the second or subsequent training is not approved, t he citation for denying a second training is 55 PA Code 165.31(d) (1-6) .