Page 9

Vermont Department for Children and Families Reach First Rules Economic Services Division 2100 9

b. The Department shall prepare a written record of the participant's non-engagement. c. If the Department determines that the participant had good cause for non-engagement, the non- engagement process ends. d. If no good cause for non-engagement exists, the Department will initiate the conciliation process or, for participants ineligible for conciliation, the Reach Up sanctions process (Reach Up Services rule 2328) and transfer the household to Reach Up.

2116.2 Overt Refusal (08/01/2024, 23-32) a. Overt refusal occurs when, without good cause, a participant declares, verbally or in writing, an unwillingness to engage in Reach First services requirements. 1. The Department will ask the participant to put verbal refusals in writing and if they refuse, the verbal refusal will be accepted. b. The Department shall prepare a written record of the participant's non-engagement. c. If the Department determines that the participant had good cause for non-engagement, the non- engagement process ends. d. If no good cause for non-engagement exists, the Department will initiate the conciliation process (Reach Up Services rule 2327.1) or, for participant's ineligible for conciliation, begin the Reach Up sanctions process (Reach Up Services rule 2328) and transfer the household to Reach Up.

2117 Determination of Good Cause (08/01/2024, 23-32) a. The Department shall make a good-faith effort to contact the participant to determine whether there is good cause for the non-engagement. b. The Department may require the participant to provide documentation to support a claim of good cause. c. The Department will determine whether there was good cause for the participant's non- engagement. 1. The Department will determine that no good cause exists if the participant does not fully cooperate with the Department's attempt to establish good cause. d. The Department shall complete the good cause determination within 10 days of becoming aware of the participant's non-engagement.

2117.1 Good Cause Criteria (08/01/2024, 23-32) a. Circumstances beyond the control of the participant may constitute good cause for an individual's non-engagement. b. The good cause criteria listed in Reach Up Services rule 2326.2 constitute good cause for not engaging in Reach First FDP and participation requirements. 2118 Conciliation (08/01/2024, 23-32)

a. Conciliation is when the Department provides a Reach First participant an opportunity to re-engage with Reach First services requirements prior to being sanctioned and transferred to Reach Up.