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The W-2 Wisconsin Works program is one of Wisconsin's TANF Temporay Assistance for Needy Families programs and provides employment preparation services, case management, and cash assistance to eligible families. W-2 has the following paid placements: CSJ Custodial Parent of an Infant , W-2 T W-2 Transition , TEMP Trial Employment Match Program , CMC Custodial Parent of an Infant , and ARP At Risk Pregnancy . In addition, several unpaid placements provide case management and employment retention services.
Statutory provisions for W-2 are included in Wisconsin Statutes under Chapter 49, Public Assistance and Children and Family Services . W-2 Administrative Rules are found in DCF 101 , DCF 102 , DCF 103 , and DCF 120 of the Wisconsin Administrative Rules.
Contact and location information for each W-2 agency is available on the W-2 Agency Locator website .
W-2 Wisconsin Works agency must collaborate with individuals to identify needed resources, assign appropriate activities, and provide services that are:
Strengths-based;
Family-centered; and
Consistent with the individual’s interests and goals.
The agency must provide all services in a culturally and linguistically competent manner to ensure accessibility for all individuals, including but not limited to:
Qualified refugees;
Former refugees; and
Individuals with limited English proficiency.
W-2 policies are guided by the consistent application of the following Basic Assumptions:
Work is the best way for parents to support their families . Stable employment is a key factor of economic stability. W-2 assists parents with preparing for, securing, and maintaining stable employment. W-2 also provides assistance navigating the SSI Supplemental Security Income and SSDI Social Security Disability Insurance application process for parents unable to work due to a disability.
Family income should improve when parents work . W-2 is committed to helping parents find the best possible job. W-2 also connects parents with work supports (e.g. EITC Earned Income Tax Credit , FoodShare, BC BadgerCare , CS Child Support , and Wisconsin Shares Child Care) to help parents stay employed.
Consistent work is essential for parents to achieve economic stability . The path toward economic independence and stability looks different for everyone. W-2 is committed to assisting parents both before and after they secure employment. W-2 also connects interested parents to education and training before or after they find a job, to help parents improve their employability and opportunities for advancement.
W-2 participants are parents as well as job seekers . Working parents have multiple family and work obligations. W-2 collaborates with parents to identify and balance these obligations and assists parents connected to other programs or supports in integrating these activities into their family’s service plan.
Eligible parents must be willing to participate in exchange for W-2 benefits . Parents must participate to the best of their abilities to be eligible for W-2 benefits.
Families benefit from participating in W-2 . W-2 supports parents in defining their goals and provides information on available options and resources to meet their family’s individual needs. W-2 works with both custodial parents in a two-parent household and extends services to noncustodial parents when appropriate.
W-2 matches the needs of working parents with the needs of local employers . W-2 families are best served when the skills and interests of W-2 participants are matched with the needs of local employers within the community.
All W-2 Wisconsin Works agencies must have a staff member who performs the role of a Receptionist. This individual may perform other functions within the agency as well.
The role of the Receptionist is to meet with individuals as they enter the W-2 agency.
Receptionist must:
Inform individuals of all programs and services available through the agency.
Initiate the application process by generating the Application Registration form (See 1.4.2.1 ) for any individual that wishes to apply for or indicates an interest in learning more about the W-2 program.
Schedule an appointment with a RS Resource Specialist the same day or no later than the following working day using Client Scheduling in CWW CARES Worker Web .
All W-2 Wisconsin Works agencies must have a staff member who performs the role of a RS Resource Specialist . This individual may perform other functions within the agency as well.
The role of the RS is to understand an applicant's needs and assist in determining which programs or services are likely to support their efforts to find and maintain employment.
The RS will perform these primary functions:
Understand an applicant's situation and perform the initial review of need for employment-related services. The RS will: Ask the applicant what brought them into the office. Ask the applicant what they need to find and/or keep a job. Gather information through the WWP Wisconsin Work Programs Informal Assessment Driver Flow about the applicant's recent job search efforts, employment skills, work history, education, and potential barriers to employment or participation in work activities. Determine how the household composition and circumstances affect the applicant's ability to work or participate in work activities. Identify whether the applicant is in a crisis situation (e.g., homeless, victim of domestic violence, no food in the house, etc.) and the potential need for a Family Stabilization Payment. (See 9.3.1 ) Give the applicant a copy of the Domestic Violence Brochure (2614-P) . (See 1.4.6 ) Identify the need for any necessary accommodations to help the applicant complete the application process. Assess current child support case status and inform the applicant of the child support pass through policy for individuals in a W-2 Paid Employment Position A Community Service Job or W-2 Transition placement placement. (See 15.1.1 )
Inform each applicant about the services available and assist the applicant in determining what programs and services are likely to support their employment search. The RS must refer the applicant to any programs in which the applicant has indicated an interest. The RS must explain the: Services that are available through the W-2 program including: W-2 Employment Position placements; Individualized case management services; and Supportive services. Eligibility and participation requirements including: W-2 eligibility criteria; Participation requirements for W-2 payments; and W-2 Employment Position placements; W-2 24-month placement time limits and 48-month state lifetime limit. (See 2.10 ). Job Center Partner programs and other workforce development programs including: DVR Division of Vocational Rehabilitation ; UI Unemployment Insurance ; FSET FoodShare Employment and Training ; WIOA Workforce Innovation and Opportunity Act ; and Other employment programs and resources available through the Job Center of Wisconsin and within the community. Supportive service programs including: Foodshare; Wisconsin Medicaid and BadgerCare Plus; Wisconsin Shares Child Care Subsidy Program; EA Emergency Assistance ; WIC Women, Infants and Children ; WHEAP Wisconsin Home Energy Assistance Program ; and Any local housing assistance programs. Services available through the local CAP Community Action Program agency.
The RS may initiate the CWW CARES Worker Web interactive interview to record non-financial and financial information such as income, assets, and family composition.
As a condition of W-2 eligibility, the RS may: Assign up-front job search activities to an applicant. (See 2.9.2 ) Require an applicant to apply for other appropriate public assistance programs or resources. (See 2.6.1 )
At no point can the RS determine final eligibility or placement in a W-2 employment position. These are the responsibilities of the FEP Financial and Employment Planner based, in part, on the information collected by the RS.
CWW may refer applicants to the Child Support program via the CWW/ KIDS Kids Information Data System automated interface, based on information the RS enters on the CWW Absent Parent page.
State statute requires that each W-2 Wisconsin Works agency have at least one FEP Financial and Employment Planner .
The FEP must provide individualized case management services and supportive services for participants in W-2 Employment Position Community Service Job, Trial Employment Match Program, and W-2 Transition s.
The FEP must:
Be the primary case manager and hold the ultimate responsibility for the case, including correct eligibility determination for W-2;
Coordinate with other agencies to facilitate needed services such as mental health or substance abuse treatment, education, training, educational needs assessment Educational needs assessments determine if the individual needs, or would benefit from, education or training activities, including a course of study for the granting of a declaration of equivalency of high school graduation. In making this determination, the FEP must consider the following: • The information gathered on the applicant/participant’s current educational levels; • The level of education and training necessary to obtain full-time employment in the local labor market; and • The applicant/participant’s personal employment goals. , career assessment A broad spectrum of assessment tools that W-2 agencies, applicants, and participants use to obtain greater awareness about how an individual’s work styles, skills, and interests can be used to define a career path, assign meaningful activities, highlight strengths, identify training needs, and match the individual to employment opportunities , vocational evaluation/assessment Assessments which are conducted to help individuals living with a disability establish realistic vocational goals and a plan to achieve them. The vocational evaluation process is designed to assess the unique strengths, resources, and experiences of an individual in order to match that person’s abilities and preferences to appropriate work placements, jobs, or training programs. The process is interactive; the intent is for staff to learn about the participant and the participant to learn about themselves , and other formal assessments;
Meet with the applicant within five working days after the date the W-2 agency receives a signed Application Registration form; (See 1.4.2.1 )
Use the information gathered at the first meeting to determine eligibility and make a placement determination within seven working days of the first meeting.
The main functions of the FEP include:
Eligibility determination;
Assessment;
Employability planning;
Service referral; and
Ongoing case management.
The FEP must:
Determine eligibility for W-2 and JAL Job Access Loan s, including: Verifying information necessary to process the W-2 application; Scanning verification timely into ECF Electronic Case File ; Ensuring that all data is entered into CWW CARES Worker Web , CARES Client Assistance for Reemployment and Economic Support , and WWP Wisconsin Work Programs accurately and timely; and Ensuring that correct payments are issued in a timely manner.
Provide information on financial literacy, life skills, and workplace bests practices.
Complete an informal assessment (See 5.2.1 ), assessing for both strengths and barriers, including reviewing and updating information gathered by the RS Resource Specialist using the WWP Informal Assessment Driver Flow .
Determine whether a Formal Assessment The process of establishing: •The extent and severity of any disabilities or other conditions (e.g., domestic violence, learning needs, need to care for disabled child) that may interfere with normal functioning in an employment setting or with a persons’ ability to meet W-2 program requirements; • The effect of a disability or other potential barrier on the person’s capacity to obtain and maintain unsubsidized employment, participate in employment-related activities (e.g., employment training or education) or otherwise meet W-2 program requirements; •The need for supportive services, accommodations, auxiliary aids or communication assistance; •The conditions under which the person is capable of employment or employment related activities; •The need to make reasonable modifications to policies, practices and procedures when necessary to ensure equal opportunity for people with disabilities; and •The appropriateness of specific assignments in the W-2 program. by a qualified assessing agency is needed using the: WWP Informal Assessment A process to gather information about an individual and his or her family to determine the: •Individual's ability to become employed and remain employed; •Services and activities necessary for the individual to become employed and remain employed; •Appropriate placement of a participant on the W-2 employment ladder; •Need for further career assessment and planning; •Need for vocational evaluation; and •Need for a formal assessment of any disabilities or other employment barriers by a qualified assessing agency or individual. information; Educational Needs Assessment Educational needs assessments determine if the individual needs, or would benefit from, education or training activities, including a course of study for the granting of a declaration of equivalency of high school graduation. In making this determination, the FEP must consider the following: • The information gathered on the applicant/participant’s current educational levels; • The level of education and training necessary to obtain full-time employment in the local labor market; and • The applicant/participant’s personal employment goals. ; Career Assessment A broad spectrum of assessment tools that W-2 agencies, applicants, and participants use to obtain greater awareness about how an individual’s work styles, skills, and interests can be used to define a career path, assign meaningful activities, highlight strengths, identify training needs, and match the individual to employment opportunities ; and Any other information provided by the participant. (See 5.5.2 )
Consider barriers to employment in determining the level of employability, making placement decisions, and referrals to other services. Provide accommodations and modifications as needed to support full engagement in work activities or employment. (See 1.3.1 )
Assign reasonable job search activities prior to, or after, the determination of W-2 eligibility.
Determine placement in a W-2 employment position and the need for an Family Stabilization Payment. (See 19.3.1 )
Work with the participants to develop a W-2 EP Employability Plan based on their goals and assessment results, including an educational needs assessment, and career assessment.
Design a plan to move the participant to unsubsidized employment as quickly as possible and within the time limits of the W-2 program. Documenting requirements for assigned W-2 activities and incorporating Learnfare activity requirements as necessary. (See Chapter 6 )
Ensure applicants and participants have the necessary supportive services, accommodations, service aids, and communication assistance required to participate to the fullest extent possible upon program entry. (See the Job Accommodation Network webpage )
Assess participants' progress in their assigned activities and determine whether they have the hard and soft skills necessary to obtain and retain unsubsidized employment as quickly as possible after application.
Work with the participants to update the EP Employability Plan as needed based on the assessment progress and remaining months of eligibility.
Identify nonparticipation; determine good cause; and record participation, good cause, and make-up hours in WWP.
Explain policies governing eligibility, including the responsibilities and requirements outlined in the PA Participation Agreement . Secure the applicant’s signature on the PA prior to beginning a W-2 Employment Position Community Service Job, Trial Employment Match Program, and W-2 Transition . These policies include, but are not limited to: Explaining that failure to cooperate during the application phase may result in ineligibility; Providing information on the Fact Finding Process; Emphasizing that W-2 is a time-limited program (See 2.10 ); and Explaining the W-2 agency’s discrimination complaint process (See 1.4.6 ).
Refer applicants who supply questionable information for front-end verification. (See 13.2.1 )
Refer participants suspected of fraudulent activity for fraud investigation. (See 13.4.1 )
When necessary, refer individuals to other community services such as: Food pantries; Domestic abuse services; Homeless shelters; Literacy councils; Child welfare agencies; DVR Division of Vocational Rehabilitation ; and AODA Alcohol and Other Drug Abuse / mental health services.
Assure that final eligibility information for W-2 is transmitted to the child support agency, and that participants cooperate with their child support agency. The FEP must also review with the participant their child support assignment during eligibility reviews.
Explain and assess the Learnfare status for Dependent Child A person who resides with a parent and who is under the age of 18 or, if the person is a full-time student at a secondary school or a vocational or technical equivalent and is reasonably expected to complete the program before attaining the age of 19, is under the age of 19 (ren) in a W-2 Group An adult custodial parent, all dependent children with respect to whom the individual is a legal custodial parent and all minor children with respect to whom the adult individual’s dependent child is a custodial parent. W-2 Group includes any non-marital co-parent or any spouse of the individual who resides in the same household as the individual and any minor children with respect to whom the spouse or non-marital co-parent is a custodial parent. W-2 Group does not include any person who is receiving cash benefits under a county relief block grant program. This is also referred to as the W-2 Assistance Group (W-2 AG) and provide or arrange for Learnfare case management. Ensure enrollment and attendance for dependent child(ren) subject to Learnfare requirements. (See Chapter 16 )
Provide follow-up case management services for 12 months to participants who progress from a W-2 employment position to an unsubsidized position to encourage and support job retention and advancement. A participant may continue to receive follow-up case management services beyond the 12-month follow-up period when requested. (See 7.2.3 )
Maintain a working relationship with the Job Center partners and other agencies that provide workforce development programs.
Explain the W-2 lifetime limit and placement time limit policies. (See 2.10 )
Position participants to achieve the best outcomes possible within the time limits of the program by providing early access to barrier remediation and employment supports.
Communicate the importance of full engagement in activities and careful transition planning to maintain independence.
Ensure participants with long-term barriers to work are referred to alternative programming for services able to meet their individual needs.
All FEPs must be trained in accordance with state law and administrative rule. (See Wisconsin Administrative Rules, Chapter DCF 103 )
Public assistance workers, including financial and employment planners, are required by Wis. Stat. ss. 48.981(2)(a) and 48.981(2)(a)13 to report suspected child abuse and neglect.
Suspected child abuse and neglect includes suspicion of child abuse of an unborn child and includes the belief that abuse or neglect will occur.
To report suspected child abuse or neglect, a public assistance worker must contact either by phone or personally the local Child Welfare agency, the local sheriff, or local police department and provide the facts and circumstances contributing to the suspicion. Additional information regarding how to make a report of suspected child abuse or neglect can be found in Wis. Stat. s. 48.981(3) .
W-2 Wisconsin Works applicants and participants are often connected to other services within their community.
The W-2 agency is responsible for ensuring integration of services across programs and providers to reduce duplication of effort and improve employment opportunities and outcome for each participant and W-2 group.
To do this, the W-2 agency must establish and maintain effective relationships with the following partner agencies:
Public Workforce System;
Wisconsin Job Centers;
Public and Community Based Supportive Services;
Child Welfare; and
Income Maintenance (IM).
W-2 agencies must establish and maintain effective relationships with the following workforce providers and programs:
Job Service programs;
FSET FoodShare Employment and Training programs;
Refugee Employment and Training providers, and other services provided by VOLAG Voluntary Resettlement Agencies and MAA Mutual Assistance Associations ;
Workforce Development Boards and services provided through WIOA Workforce Innovation and Opportunity Act programs, including Youth, Adult and Dislocated Worker programs;
Adult literacy providers;
Adult job training administered by the Wisconsin Technical Colleges;
RISE Partnership for Wisconsin;
DVR Division of Vocational Rehabilitation ;
Veteran’s Employment Relations Teams;
CAP Community Action Program Agencies; and
Other local regional business associations, community-based organizations, and economic development programs.
The Wisconsin Job Center system is part of the workforce system led by Wisconsin's eleven independently operated, regional Workforce Development Boards .
Job Center partners include:
Job Service;
DVR Division of Vocational Rehabilitation ;
Technical colleges;
County human service agencies; and
Other community organizations.
JobCenterOfWisconsin.com , operated by the Wisconsin Department of Workforce Development and the Wisconsin Job Center system, is an online Wisconsin-centered employment exchange, linking employers across Wisconsin and bordering states with anyone looking for a job.
To find the closest Job Center or talk with a customer service representative, visit the JobCenterOfWisconsin.com contact page. JobCenterOfWisconsin.com is a free resource available 24/7 to both employers and job seekers.
W-2 participants are often connected to other local supportive services, many of which continue to be available to support participants after they move into unsubsidized employment.
W-2 agencies must establish, maintain, and coordinate effective relationships with the following community-based supportive services:
County and tribal programs, including FoodShare, BadgerCare Plus, Medicaid, CS Child Support , and Child Care Administration. (See 1.4.1 )
Community-based supportive services including, but not limited to: CAP Community Action Program agencies; Transportation services; Housing services; Domestic violence services; Mental health services; AODA Alcohol and Other Drug Abuse services; Emergency services; and Other services including volunteer organizations.
W-2 agencies must have a process for identifying families currently receiving services from both W-2 and Child Welfare programs to coordinate services across programs.
When a participant is involved in a Child Welfare family case plan, the W-2 EP Employability Plan should take those activities into consideration and ensure there is no conflict or overlap of services or assigned activities.
When the child(ren) in a W-2 Group An adult custodial parent, all dependent children with respect to whom the individual is a legal custodial parent and all minor children with respect to whom the adult individual’s dependent child is a custodial parent. W-2 Group includes any non-marital co-parent or any spouse of the individual who resides in the same household as the individual and any minor children with respect to whom the spouse or non-marital co-parent is a custodial parent. W-2 Group does not include any person who is receiving cash benefits under a county relief block grant program. This is also referred to as the W-2 Assistance Group (W-2 AG) are temporarily absent due to child welfare issues, W-2 agencies must meet the specific Child Welfare agency coordination requirements outlined in section 2.8.2.2 .
W-2 Wisconsin Works agency staff must:
Follow the guidelines set forth by the ADA Americans with Disabilities Act ; and
Be familiar with the civil rights standards in service delivery and resources available to ensure the W-2 program is accessible to, and accommodates, individuals with disabilities. (See the DCF Civil Right Compliance webpage )
If an individual discloses a disability, reasonable accommodations must be offered.
The FEP Financial and Employment Planner must incorporate into the participant’s EP Employability Plan all disability-related services and accommodations recommended through a formal assessment. (See 5.5.1.2 )
Reasonable accommodations must be offered to applicants who have a disability. Examples include:
Reading materials aloud to applicants who have a learning disability; and
Going to an individual’s home, or other mutually-agreeable location, to complete the W-2 application in-person.
W-2 agencies must:
Ensure participants have the necessary services and reasonable accommodations to successfully engage in assigned W-2 activities; and
Work with employers to put needed accommodations into place for participants transitioning to unsubsidized employment.
The W-2 agency is responsible for:
Identifying the need for the accommodation;
Identifying the accommodation itself; and
Ensuring the accommodation is provided at all assigned activities such as a basic education lab or a work experience site.
The Job Accommodation Network (JAN) is an online resource found at askjan.org that provides guidance on workplace accommodations and disability employment issues. Case managers may find JAN helpful when identifying and arranging accommodations for a participant.
JAN offers several ways to obtain confidential, personalized assistance, including by:
Phone;
Email; and
The Searchable Online Accommodation Resource (SOAR).
The FEP must work with the participant and their medical providers to identify any necessary accommodations.
Good cause must be accepted without requiring further documentation when a formal assessment indicates that an individual’s impairment may become acute, resulting in the need for the individual to be absent from assigned activities.
See 11.3.1 for more information on good cause.
Individuals with chronic conditions affected by environmental factors must be given good cause for nonparticipation when certain conditions exist, such as air temperatures below a certain degree or an air quality alert.
Examples of conditions affected by environmental factors include but is not limited to:
Respiratory problems;
Multiple Sclerosis;
Severe allergies; and
Other conditions.
EXAMPLE : Allie relies on public transportation to get to her W-2 assignments. Allie’s formal assessment says she has severe asthma made worse by prolonged exposure to cold. Allie must be given good cause for nonparticipation at times when air temperature would affect her condition.
Any individual may apply for W-2 Wisconsin Works online in ACCESS A client facing web portal that provides self-service, case specific information regarding an individual’s FoodShare, Medicaid, Wisconsin Shares, Wisconsin Works (W-2), and Job Access Loan benefits, including program eligibility information. or by contacting their local W-2 agency.
Applicants unable to complete an application in ACCESS, may contact their local W-2 agency to complete the application process. All applicants must complete the W-2 application to be eligible for W-2 services.
Applicants must apply at the W-2 agency that serves the geographical area in which they reside with the following exceptions:
An applicant who resides in an area served by a W-2 agency that services more than one geographical area may apply at any of that agency’s W-2 offices.
An applicant who is a victim of domestic abuse may apply at any W-2 agency.
An applicant who resides in a treatment facility without a primary residence to return to must apply at the W-2 agency that serves the geographical area where the treatment center is located. If the applicant maintains a primary residence and intends to return to it, the applicant must apply at the agency that serves the geographical area in which the primary residence is located.
An applicant who is homeless may apply in any geographical area, however, agencies should encourage them to apply in the geographical area in which they anticipate finding permanent housing.
W-2 agencies must coordinate with agencies providing Income Maintenance (IM) programs [FoodShare and Medicaid/BadgerCare Plus] to:
Ensure services delivered under W-2, FoodShare, and Medicaid/BadgerCare Plus programs are coordinated in a way that effectively serve the recipients of those services (Wis. Stat. s. 49.143(2)(d) ); and
Ensure procedures are in place to protect the application filing date for FoodShare.
IM Consortia and Tribal IM agencies are encouraged to co-locate staff at the W-2 agency to meet caseload needs and provide access to eligibility determination services for FoodShare and Medicaid/BadgerCare Plus.
If IM Consortia and Tribal IM agencies are not co-located, W-2 agencies must provide individuals who request FoodShare with:
A computer and the ACCESS website ( access.wi.gov ) if the individual wants to apply online.
The current agency phone numbers if the individual wants to apply by phone. IM agency phone number can be found on the Income Maintenance and Tribal Agency Contact Information webpage.
The paper FoodShare Wisconsin Registration form (F-16019A) if the individual does not want to apply online or by phone. If the individual opts for the paper FoodShare application, the W-2 agency must fax the completed form using the Income Maintenance and Tribal Agency Contact Information webpage to get the appropriate document processing unit fax number.
To request a W-2 Wisconsin Works application, an applicant can:
Submit a W-2 application online through ACCESS A client facing web portal that provides self-service, case specific information regarding an individual’s FoodShare, Medicaid, Wisconsin Shares, Wisconsin Works (W-2), and Job Access Loan benefits, including program eligibility information. ; or
Contact their local W-2 agency.
Initiating the W-2 Application Process
The W-2 application process begins on the date the applicant provides the agency with a signed Application Registration form (RFA)* that is generated from the CWW CARES Worker Web Print Application Registration page.
For online applications submitted via ACCESS, the process starts as soon as the online application is submitted.
If an applicant chooses to take an Application Registration form home to review, the Receptionist must explain that the application process cannot begin, and the application date cannot be set, until the agency receives the signed form.
Scheduling Appointments Through ACCESS
Before submitting a W-2 application through ACCESS, applicants will be presented with the option to select an available appointment time to meet with a FEP over the next five 5 working days. The FEP must meet with the applicant during their scheduled appointment time.
Scheduling an Appointment with the RS (Resource Specialist)
Applicants who submit an ACCESS application do not need to meet with an RS Resource Specialist .
Once the Receptionist begins the application process, the agency must schedule an appointment for the applicant with an RS on the same day or the following working day using the Client Scheduling feature in CWW.
See 1.2.2 for more detail on the role of the RS.
Maintaining Schedule Availability
Agencies must maintain their client scheduling availability in CWW for at least 10 working days into the future.
Appointment Scheduling for ACCESS Applicants
Applicants applying in ACCESS are responsible for scheduling an interview appointment with a FEP in ACCESS or by contacting their local W-2 agency.
If an applicant does not schedule an appointment in ACCESS or does not attend their appointment scheduled in ACCESS, the W-2 agency may contact the applicant to schedule an appointment.
If an applicant does not schedule an appointment in ACCESS or contact their local W-2 agency, the W-2 agency may deny the application after 30 days.
Creating a Request for Assistance (RFA)
The W-2 agency must create an RFA in CWW for all application types, including applications through ACCESS. For ACCESS applications, the application date is the date the ACCESS application was submitted.
Paper Applications Forms
Agencies must only use the paper Wisconsin Works (W-2) and Related Programs Registration form (14880) when:
CWW is unavailable and the applicant cannot wait for availability to resume; or
There is not sufficient time to generate the CWW Application Registration form before the W-2 agency closes to the public.
The W-2 agency must scan into ECF Electronic Case File the signed copy of the CWW-generated Application Registration form, or the paper registration form used if CWW was unavailable.
To initiate a W-2 Wisconsin Works request, the W-2 agency must enter the request via the CWW CARES Worker Web Record New Group Level Program Request on the Case Summary page to generate the CWW Application Registration form.
For detailed instructions on how to process W-2 requests, see the Request for Assistance (RFA)/Case Processes for W-2 desk aid .
There are times when an applicant is unable to personally complete the application forms. W-2 agencies must accept all forms, including the Application Registration form and online ACCESS application, from an applicant's legally responsible relative or guardian. For example:
Authorized Representative Situation Spouse A spouse can submit the Application Registration form or ACCESS application for their partner. Parent A parent can submit the Application Registration form or ACCESS application for their dependent child. Legal Guardian A legal guardian can submit an Application Registration form or ACCESS application for their ward. An Individual acting responsibly for an incompetent or incapacitated applicant An individual acting responsibly for an incompetent or incapacitated applicant can submit the Application Registration form or ACCESS application on their behalf.
When an applicant chooses to use an authorized representative, both the applicant and the authorized representative must sign the Authorization of Participant Representative form (2375) .
The authorized representative is responsible for submitting the signed Application Registration form or ACCESS application, as well as any required documents. The agency must not refuse an authorized representative unless the authorization itself appears to be fraudulent.
A written or electronic signature must be obtained for documents that are reviewed by external parties such as a release of information or Fact Finding documents.
Unless specified otherwise, all other documents submitted to the W-2 agency can be obtained with one of the four signature types listed below. W-2 agencies must provide the option to sign all documents in whichever acceptable signature method the applicant or participant prefers.
Written signature : The applicant physically signs the document.
Electronic signature : The applicant electronically signs the document via an electronic signature software.
Telephonic signature : The applicant telephonically signs the document during a recorded call using Genesys. Only documents with the language “or Telephonic Signature Interaction ID” in the signature box can be signed telephonically. For telephonic signatures for anything other than an eligibility review, FEPs must read whatever document is being telephonically signed, e.g., W-2 application, W-2 Participation Agreement, Employability Plan, etc., in order to record the agreement being made between the FEP and the participant. The FEP must read the language that is in the telephonic signature display in Genesys. The Telephonic Signature Interaction ID generated in Genesys must be documented on the signature line and in case comments.
ACCESS signature : Where specified in policy, certain signatures can be obtained as part of the application process in ACCESS.
The FEP must provide a signed copy of the document to the applicant or participant, regardless of signature type.
All interviews and meetings with an applicant or participant can be conducted in one of three ways below.
Applicants and participants have the option to choose whichever acceptable meeting format they prefer.
Acceptable meeting formats the W-2 agency must offer include:
In-person : The applicant or participant meets physically in-person with a W-2 agency worker.
Video cal l: The applicant or participant and a FEP use a video platform to meet where each person can see and hear one another.
Telephonically : The applicant or participant and a FEP use a telephone to meet.
W-2 agency workers must document in comments which meeting format was used.
Note : This meeting format flexibility does not apply to the Refugee Cash Assistance (RCA) Program.
Intake Interview
The applicant must complete an intake interview with the FEP Financial and Employment Planner within five working days of submitting the online ACCESS A client facing web portal that provides self-service, case specific information regarding an individual’s FoodShare, Medicaid, Wisconsin Shares, Wisconsin Works (W-2), and Job Access Loan benefits, including program eligibility information. application or a signed Application Registration form. Job Access Loan applicants must also complete the Job Access Loan Application (2482) .
Applicant Signature
All W-2 FEP Financial and Employment Planner Wisconsin Works and JAL Job Access Loan applicants and adults in the W-2 Group An adult custodial parent, all dependent children with respect to whom the individual is a legal custodial parent and all minor children with respect to whom the adult individual’s dependent child is a custodial parent. W-2 Group includes any non-marital co-parent or any spouse of the individual who resides in the same household as the individual and any minor children with respect to whom the spouse or non-marital co-parent is a custodial parent. W-2 Group does not include any person who is receiving cash benefits under a county relief block grant program. This is also referred to as the W-2 Assistance Group (W-2 AG) must sign the Application Summary at the end of the interview.
By signing the Application Summary, the applicant:
Attests that all information provided in the application is correct and complete; and
Attests to understanding and agreeing to some basic policies of the W-2 program, such as authorizing the W-2 agency to request and receive information from other sources, and understanding the fraud rules.
The agency must scan the signed copy of the Application Summary's Signature page into ECF.
Alternative Methods for Collecting Applicant Signature(s)
The FEP may conduct a home visit to secure the applicant signature(s) on the required forms. The FEP must document the home visit in CWW CARES Worker Web case comments.
The applicant must sign the Wisconsin Works (W-2) and Related Programs Application form (2471) if CWW is unavailable during the intake interview. This form is equivalent to the Application Summary page generated in CWW. The agency must scan the entire form into ECF.
The applicant must sign the Back-up Applicant/Participant Signature (11154) if the FEP is unable to print the Application Summary. To do this, the FEP must choose the Mail Summary option on the CWW Generate Summary page. The FEP must attach the signed Back-up Applicant/Participant Signature form to the mailed Signature Page when the participant returns it to the agency.
Completed Application
An application for W-2 is complete when the following has occurred:
The applicant has completed the intake interview with the FEP;
The FEP has entered all eligibility information into CWW; and
The applicant or authorized representative’s signature (See 1.4.3.2 ) on the CWW Application Summary that prints from the CWW Generate Summary page has been collected by the FEP.
Note : W-2 applicants applying in ACCESS will sign the application summary in ACCESS.
Within seven working days after the interview appointment the FEP Financial and Employment Planner must:
Determine W-2 eligibility; and
Assign the most appropriate W-2 placement for eligible applicants.
W-2 Wisconsin Works eligibility is determined using all financial and nonfinancial eligibility criteria. (See Chapter 2 and Chapter 3 ) When the applicant needs additional time to gather verification, the eligibility process may be extended up to 30 days from the date the agency receives the signed Application Registration form. (See 4.1.3 )
Two activities may be assigned by the RS Resource Specialist or the FEP as a condition of eligibility when appropriate:
Up-front job search activities (see 2.9.2 ); and
The requirement to apply for other appropriate public assistance programs. (see 2.6.1 )
To make the most appropriate placement decision, the FEP, with the applicant, must discuss and review the:
Informal assessment results (see 5.2 );
Educational Needs Assessment Educational needs assessments determine if the individual needs, or would benefit from, education or training activities, including a course of study for the granting of a declaration of equivalency of high school graduation. In making this determination, the FEP must consider the following: • The information gathered on the applicant/participant’s current educational levels; • The level of education and training necessary to obtain full-time employment in the local labor market; and • The applicant/participant’s personal employment goals. results (see 5.3 );
Career Assessment A broad spectrum of assessment tools that W-2 agencies, applicants, and participants use to obtain greater awareness about how an individual’s work styles, skills, and interests can be used to define a career path, assign meaningful activities, highlight strengths, identify training needs, and match the individual to employment opportunities s results (see 5.4 );
Progress made in up-front job search, if assigned (see 2.9.2 ); and
Any Vocational Evaluation/Assessment Assessments which are conducted to help individuals living with a disability establish realistic vocational goals and a plan to achieve them. The vocational evaluation process is designed to assess the unique strengths, resources, and experiences of an individual in order to match that person’s abilities and preferences to appropriate work placements, jobs, or training programs. The process is interactive; the intent is for staff to learn about the participant and the participant to learn about themselves or formal assessment results from the application process (see 5.1.1 ).
The FEP must make a placement determination within 12 working days after the date the agency receives the signed Application Registration form (five days to meet with the FEP and seven days for the FEP to make an eligibility determination and placement).
The placement determination time frame must not be extended to accommodate a longer job search, and the up-front job search requirement must not be used to delay an eligibility determination or placement. (See 2.9.2.2 )
Below are the application processing time frames:
Time Frame Required Action The same day or the following working day after an individual applies for W-2 Wisconsin Works by submitting the signed Application Registration form (See 1.4.2 ): A W-2 agency representative must schedule and hold an appointment between the applicant and a RS Resource Specialist . If this initial meeting is with a FEP Financial and Employment Planner , then no later than seven working days after this meeting, the FEP must determine W-2 eligibility and make the most appropriate W-2 placement for the applicant. No later than five working days after an individual applies for W-2 by completing the application in ACCESS or by submitting the signed Application Registration form: The W-2 agency must hold an interview between the FEP and the applicant. If the applicant applies using the signed Application Registration form, the agency must schedule this interview. If the applicant applies in ACCESS, the applicant must either schedule this interview in ACCESS A client facing web portal that provides self-service, case specific information regarding an individual’s FoodShare, Medicaid, Wisconsin Shares, Wisconsin Works (W-2), and Job Access Loan benefits, including program eligibility information. or by contacting their local W-2 agency. Agencies may contact applicants to schedule interview appointments. Note : W-2 agencies must provide availability in ACCESS for appointment scheduling within five days of the application being submitted and must maintain available intake appointments in CWW CARES Worker Web Client Scheduling for a minimum of the next 10 working days to avoid delays in appointment scheduling and application processing. No later than seven working days after the first meeting with the FEP The FEP must determine W-2 eligibility and make the most appropriate W-2 placement for the applicant.
The W-2 agency representative must schedule all appointments through Client Scheduling in CWW. If the agency extends the application time frame, agency staff must document the reason in case comments.
The agency may extend the application time frame for up to 30 calendar days from the application date for the following:
The applicant requests to reschedule the RS or FEP appointment; or
The applicant requests more time to submit verification.
EXAMPLE 1: Mariah arrives at the W-2 office on Thursday, March 10, at 4:00 p.m. She wants to apply for W-2 services but cannot stay to complete an application.
Mariah has several options:
She can return to the W-2 agency at a later date to apply.
She can wait a few minutes for the agency staff to generate the Application Registration form for her to sign and submit.
If Mariah chooses this option, the W-2 agency must:
Schedule a meeting with the RS the following day, March 11.
Schedule a meeting with the FEP no later than March 17 (five working days after the date the W-2 agency received the signed Application Registration form).
She can take a paper Wisconsin Works (W-2) and Related Programs Registration form (14880) with her and return it at her convenience.
If Mariah chooses this option, the W-2 agency must explain that the application process cannot begin until the agency receives the signed form.
If Mariah chooses to return the paper form on Friday, March 11, the W-2 agency must:
Schedule a meeting with her that day or no later than Monday, March 14 (the following working day after her application date of Friday, March 11).
Schedule a meeting with the FEP no later than Friday, March 18 (five working days after the date the W-2 agency received the signed Application Registration form).
EXAMPLE 2 : Noel visits a W-2 agency to apply for W-2. The following table outlines her application, eligibility determination, and placement timeline.
Event Date Action Application Submitted Thursday, March 10 Noel applies for W-2 in person. FEP Meeting Friday, March 11 Noel meets with a FEP who completes the CWW CARES Worker Web intake interview and pends Noel's application for asset verification. Verification Submitted Friday, March 18 The agency receives a copy of Noel's most recent bank statement. Eligibility Determination and Placement Tuesday, March 22 The FEP must determine W-2 eligibility and make the most appropriate W-2 placement as soon as possible but no later than March 22 (seven working days after the meeting with the FEP).
Certain forms and publications are required to be distributed at specific times during the W-2 Wisconsin Works application process. Below is a list of the forms and publications that are available if CWW CARES Worker Web is not functioning, along with a description of each form, and distribution guidance.
Form Description Building a Brighter Tomorrow: Benefits and Services Offered with Wisconsin Works (W-2) (11890-P) This brochure describes the benefits and services available at the W-2 agency in one page and must be given to every individual who requests assistance of any kind. W-2 agencies must have this brochure available at all office locations. At a minimum, W-2 agencies should supply greeters, receptionists, and resource specialists with this brochure to give to individuals they interact with. Giving Proof (2372-P) This publication describes types of documentation an applicant may need to provide to verify specific information needed to determine W-2 eligibility and must be given to the applicant at the time they inquire about W-2. Similar information is provided in ACCESS A client facing web portal that provides self-service, case specific information regarding an individual’s FoodShare, Medicaid, Wisconsin Shares, Wisconsin Works (W-2), and Job Access Loan benefits, including program eligibility information. for online applicants. W-2 Rights and Responsibilities (398-P) This brochure outlines a participant’s rights and responsibilities when participating in W-2 and RCA Refugee Cash Assistance programs. This brochure must be provided to participants and reviewed during the application process. Applicants must initial the signature page of the CWW Application Summary acknowledging they received this brochure. Wisconsin Works (W-2) Participation Agreement (10755) This form outlines participation requirements of a W-2 participant. During the application process, the FEP Financial and Employment Planner must provide this form to the applicant and thoroughly review it. The agency worker, applicant, and all adults in the W-2 Group must sign this form. The agency must give the participant a signed copy of the PA Participation Agreement and scan the original into ECF Electronic Case File . This form may be reviewed again during EP Employability Plan updates and W-2 reviews. W-2 agencies should review the PA with participants unclear on a participation requirement explained in the PA. Good Cause Notice (5600-P) This publication must be given to all W-2 applicants when they apply for W-2 and documented in CWW case comments. For applicants who applied in ACCESS, the W-2 agency does not have to provide the physical publication; applicants read and indicate their understanding in ACCESS. The Good Cause Notice must also be provided physically to participants and documented in CWW case comments: When a child is added to the W-2 Group An adult custodial parent, all dependent children with respect to whom the individual is a legal custodial parent and all minor children with respect to whom the adult individual’s dependent child is a custodial parent. W-2 Group includes any non-marital co-parent or any spouse of the individual who resides in the same household as the individual and any minor children with respect to whom the spouse or non-marital co-parent is a custodial parent. W-2 Group does not include any person who is receiving cash benefits under a county relief block grant program. This is also referred to as the W-2 Assistance Group (W-2 AG) ; When a parent leaves the W-2 Group; At reapplication for continued benefits; and If a participant disclose a circumstance that may meet the CS Child Support good cause criteria (See 15.6.1 ). See 15.6.1 for more information on the good cause notice language in ACCESS. For other relevant CS-related forms and publications, see Chapter 15 . Notice of Assignment: Child Support, Family Support, Maintenance, And Medical Support (2477) All W-2 applicants must receive this form. The W-2 agency must help the applicant understand how child support payments are assigned if they begin receiving child support payments while receiving W-2 services. (See 15.1.3 ) The agency must document the form was provided in CWW case comments. Domestic Violence Brochure (2614-P) The Domestic Violence Brochure must be provided at the appointment with the RS or when an applicant who submitted an ACCESS application interviews with the FEP. If the appointment with the FEP is virtual, the FEP must provide an electronic copy of the brochure during the intake appointment. For safety reasons, it is important that W-2 agency staff point out the brochure so that the applicant can decide if it is safe to keep. Including the brochure in a stack of other papers may put an individual at risk if they are unaware of it. TANF Electronic Benefit Transfer Transaction Restrictions Flyer (2947-P) The TANF Temporary Assistance for Needy Families Temporary Assistance for Needy Families EBT Electronic Benefit Transfer Restrictions Flyer must be provided to all W-2 applicants during the application process and at eligibility reviews. The flyer identifies specific merchant locations where TANF funded assistance cannot be accessed and specifies types of electronic benefit transfer transactions that are prohibited.
The W-2 Wisconsin Works agency is required to meet with participants to conduct a W-2 eligibility review at least once every six months. (See 1.4.2.4 ) If a participant initiates a review early but does not schedule a review appointment in ACCESS, the participant maintains their eligibility until the initial six-month review date. The FEP must extend the verification checklist due date. Renewals initiated by participants in error should be withdrawn and a case comment created explaining why. The FEP should also create a manual notice informing the participant of the withdrawal. See 1.4.6 for documents needed at review.
Scheduling Appointments Through ACCESS
Before submitting a W-2 review through ACCESS, participants will be presented with the option to select an available appointment time to meet with a FEP over the next five working days. The FEP must meet with the applicant during their scheduled appointment time.
Eligibility reviews must be conducted in person or virtually by phone or video call.
Maintaining Schedule Availability
W-2 agencies must maintain their client scheduling availability for participants to renew their benefits in CWW for at least 10 working days into the future. Each FEP should make enough review appointment slots available in Client Scheduling based on their expected caseload. The amount of appointment slots for review should be periodically adjusted on an ongoing basis in order to ensure participants generally have the ability to schedule appointments.
Appointment Scheduling for ACCESS Reviews
Participants renewing in ACCESS are responsible for scheduling an interview appointment with a FEP in ACCESS or by contacting their local W-2 agency.
If a participant does not schedule an appointment or no appointment times are available in ACCESS, the W-2 agency should attempt to meet with the participant no later than seven working days after a review is submitted in ACCESS. If a meeting is not possible, the agency must schedule a future appointment that is prior to the eligibility review due date.
If a participant does not meet eligibility requirements at the review, CWW will automatically close the case at the end of the review month. Verification documents received from participants must be current. See 4.1.2 for more information about eligibility verification.
Sometimes, a participant may not schedule a review after initiating the eligibility renewal in ACCESS. When that happens, the FEP should follow the following processing times because a verification checklist will be automatically generated and sent to a participant.
EXAMPLE: John has an initial six-month eligibility review month in December. John initiates a review on October 26 in ACCESS but does not schedule an appointment. At the end of December, if John has not attended a six-month renewal appointment, the case must be closed.
The W-2 agency representative must schedule all appointments through Client Scheduling in CWW.
If the agency extends the VCL review time frame, agency staff must document the reason in case comments.
During a virtual W-2 eligibility review, the FEP Financial and Employment Planner must review the participant’s eligibility information and notify them of all verification items and required forms that must be submitted.
After conducting a virtual W-2 eligibility review, the FEP must:
Summarize information from the interview;
Collect the participant’s signature;
Generate a current Case Summary; and
Send the Case Summary and other required forms to the participant unless they prefer to pick them up at the W-2 agency.
The FEP must discuss the participant’s confidentiality situation at each eligibility review to address any safety concerns. Confidentiality situation refers to any situation that makes the participant’s case confidential. (See 4.5.2 )
Applicants must meet both financial and nonfinancial eligibility criteria in order to be considered eligible for W-2 Wisconsin Works services or a JAL Job Access Loan .
See 3.1 for information on financial eligibility.
To be nonfinancially eligible for W-2 Wisconsin Works services and JAL Job Access Loan s for any month, an applicant or participant must meet the criteria listed below.
For eligibility information regarding minor parents, noncustodial parents, pregnant women, and pregnant women with at-risk pregnancies, see 7.5.2 , 7.5.1 , 7.5.3 , and 7.4.6 respectively. For information on verifying the criteria listed below, see Chapter 4 .
Be a Custodial Parent (CP) With respect to a dependent child, a parent (see definition of parent) who resides with that child and, if there has been a determination of legal custody with respect to the dependent child, has legal custody of that child . (See 2.3.1 )
Be 18 years of age or older.
Be a U.S. citizen or qualified non-citizen. (See 2.4.1 )
Be a resident of Wisconsin and, unless the applicant is a migrant worker, demonstrate an intent to continue living in the state.
Cooperate, unless good cause or other exceptions exist, with efforts to establish paternity of the Dependent Child A person who resides with a parent and who is under the age of 18 or, if the person is a full-time student at a secondary school or a vocational or technical equivalent and is reasonably expected to complete the program before attaining the age of 19, is under the age of 19 or children and secure and enforce child support orders.
This cooperation requirement extends to any W-2 Group An adult custodial parent, all dependent children with respect to whom the individual is a legal custodial parent and all minor children with respect to whom the adult individual’s dependent child is a custodial parent. W-2 Group includes any non-marital co-parent or any spouse of the individual who resides in the same household as the individual and any minor children with respect to whom the spouse or non-marital co-parent is a custodial parent. W-2 Group does not include any person who is receiving cash benefits under a county relief block grant program. This is also referred to as the W-2 Assistance Group (W-2 AG) member who is a custodial parent of a child whose paternity has not been established or who has a noncustodial parent. The requirements for custodial parents and noncustodial parents to cooperate with child support are outlined in 15.3.1 .
Assign the rights to any support or maintenance (child or family support) to the state when in a W-2 placement that requires it. (See 15.1.1 )
Provide all requested documentation within seven working days after receiving the request for information from the W-2 agency. (See 4.1.3 )
Have made a good faith effort, as determined by the W-2 agency on a case-by-case basis, to obtain employment and have not refused any bona fide offer of employment, including a job quit, within 180 calendar days immediately preceding application.
This condition only applies to applicants applying for one of the two W-2 Paid Employment Position A Community Service Job or W-2 Transition placement s and does not apply to ARP At Risk Pregnancy and CMC Custodial Parent of an Infant . The W-2 agency has the discretion to define when a bona fide offer of employment has been made and what demonstrates a good faith effort.
Have cooperated with the W-2 agency’s assistance with finding employment if the current application is within 180 calendar days of a previous application for W-2 services by the individual.
This condition applies only to:
Applicants applying for one of the two W-2 Paid Employment Position A Community Service Job or W-2 Transition placement s and does not apply to CMC and ARP; and
Noncooperation with the efforts of the W-2 agency to assist the individual in obtaining employment and does not pertain to every aspect of the application, such as providing income verification.
Not receive SSI Supplemental Security Income or state supplemental payments. If an individual has been determined eligible for SSI, they remain eligible for W-2 until they actually receive a SSI payment.
Not receive SSDI Social Security Disability Insurance If an individual has been determined eligible for SSDI, they remain eligible for W-2 until they actually receive an SSDI payment.
An adult disabled before age 22 may be eligible for child's disability benefits if a parent is deceased or starts receiving retirement or disability benefits.
The adult disabled before age 22 receives the benefit based on a parent’s Social Security earnings record.
The adult must be unmarried, age 18 or older, and have a disability that started before age 22.
FEPs must code this disability income as ‘SSDC’ in CARES Worker Web. For more information, see the Social Security Administration’s Disability benefits eligibility webpage .
Not participate in a strike on the last day of the month. If eligibility is determined prior to the last day of the month and the applicant is on strike, they are ineligible. If a participant in a W-2 employment position goes on strike, that participant becomes ineligible for W-2.
Cooperate in applying for other public assistance programs or resources that the FEP Financial and Employment Planner believes may be available to the individual. (See 2.6.1 )
Apply for or provide an SSN Social Security Number for all W-2 Group members, unless exempt. (See 2.7.1 )
Report changes in circumstances that may affect eligibility within 10 calendar days after the change, except for temporary absence of a child which must be reported within five working days. (See 2.8.1 )
Cooperate in providing information needed to verify school enrollment status or good cause for the Learnfare program for children ages 6-17 in a W-2 Group whose parent is placed in a TMP Custodial Parent Trial Employment Match Program , CSJ Community Service Job , or W-2 T W-2 Transition placement. (See Chapter 16 ) Cooperate in providing school enrollment status and expected graduation date for a Dependent 18-year-old A person who resides with a parent and who is 18, a full-time student at a secondary school or a vocational or technical equivalent, and who is reasonably expected to complete the program before attaining the age of 19. when the parent's W-2 eligibility is being determined based on that child as a dependent 18-year-old.
Cooperate with the requirement to search for unsubsidized employment throughout their participation in a W-2 employment position. This condition does not apply to CMC Custodial Parent of an Infant s, ARP At Risk Pregnancy s, or AmeriCorps VISTA volunteers. (See 2.9.1 )
Cooperate with providing eligibility information for other W-2 Group An adult custodial parent, all dependent children with respect to whom the individual is a legal custodial parent and all minor children with respect to whom the adult individual’s dependent child is a custodial parent. W-2 Group includes any non-marital co-parent or any spouse of the individual who resides in the same household as the individual and any minor children with respect to whom the spouse or non-marital co-parent is a custodial parent. W-2 Group does not include any person who is receiving cash benefits under a county relief block grant program. This is also referred to as the W-2 Assistance Group (W-2 AG) member(s).
Cooperate with providing information for quality assurance reviews.
Not be a fugitive felon. (See 42 U.S.C. 608(a)(9)(A)(i) )
Not be violating a condition of probation or parole imposed under federal or state law.
State in writing whether they have been convicted in any state or federal court of a felony that has an element of possession, use, or distribution of a controlled substance. (See 11.8.1 )
Have no other W-2 Group member participating in a W-2 employment position. This condition does not apply to an individual applying for a JAL Job Access Loan only.
Beginning on the date the individual has attained the age of 18, the total number of months in which the individual has actively participated does not exceed the 48-month state lifetime limit. (See 2.10.1 )
Have a medically verified pregnancy if they are pregnant with no other dependent children. (See 7.5.3 and 7.4.6 )
Only one W-2 Group An adult custodial parent, all dependent children with respect to whom the individual is a legal custodial parent and all minor children with respect to whom the adult individual’s dependent child is a custodial parent. W-2 Group includes any non-marital co-parent or any spouse of the individual who resides in the same household as the individual and any minor children with respect to whom the spouse or non-marital co-parent is a custodial parent. W-2 Group does not include any person who is receiving cash benefits under a county relief block grant program. This is also referred to as the W-2 Assistance Group (W-2 AG) may receive a W-2 payment for a Dependent Child A person who resides with a parent and who is under the age of 18 or, if the person is a full-time student at a secondary school or a vocational or technical equivalent and is reasonably expected to complete the program before attaining the age of 19, is under the age of 19 . If there is no legal custody or placement order, the Parent A parent is a: (1)Biological parent; (2)Person who has consented to the artificial insemination of his wife under s.891.40, Stats.; (3)Parent by adoption; (4)Man adjudged in a judicial proceeding to be the biological father of the child if the child is a non-marital child who is not adopted or whose parents are not married to each other; or (5)Man who has signed and filed with the state registrar a statement acknowledging paternity. with whom the dependent child resides is considered the Custodial Parent (CP) With respect to a dependent child, a parent (see definition of parent) who resides with that child and, if there has been a determination of legal custody with respect to the dependent child, has legal custody of that child . Dependent children must be included in the household where they reside.
In some situations, the primary residence of a dependent child may not be clear. If the primary residence of a dependent child is uncertain, court documents can be used to determine if there is a primary caretaker designated.
If there is joint legal custody of a child and the custody is split equally in half, the parents can be asked to decide which parent is considered the primary caretaker caregiver. If the parents cannot decide, the FEP Financial and Employment Planner should compare the parents' activities and responsibilities against the following list and determine which parent is making more decisions in caregiving for the child.
If the parents reside in different school districts, where does the child attend school? Who selected the school?
Who helps the child with homework or school-related tasks?
If there are tuition expenses for the child's education, who pays them?
If the child is enrolled in day care, who arranges for and pays these costs?
Who is responsible for taking the child to and from school or day care?
Which parent is listed as the emergency contact at the child's school or day care?
Who arranges medical and dental care for the child? Who selects the physician and dentist?
Who maintains the child's medical records?
Who initiates decisions regarding the child's future?
Who responds to medical or law enforcement emergencies involving the child?
Who provides food or clothing for the child when the child visits the other parent?
Who disciplines the child?
Who plays with the child and arranges activities?
Are more of the child's toys, clothing, or personal items kept at one parent's home than the other's?
FEPs must use the best available information to determine who is the custodial parent, and document in case comments the basis of the determination.
2.4.1.1 Presumptive Eligibility for Non-Citizens
2.4.1.2 Handling Missing or Questionable Immigration Documentation
2.4.1.3 Verifying Custodial Parent Relationships for Non-Citizen Children
2.4.1.4 SAVE
When applying for W-2 Wisconsin Works , all individuals in the W-2 Group An adult custodial parent, all dependent children with respect to whom the individual is a legal custodial parent and all minor children with respect to whom the adult individual’s dependent child is a custodial parent. W-2 Group includes any non-marital co-parent or any spouse of the individual who resides in the same household as the individual and any minor children with respect to whom the spouse or non-marital co-parent is a custodial parent. W-2 Group does not include any person who is receiving cash benefits under a county relief block grant program. This is also referred to as the W-2 Assistance Group (W-2 AG) must verify U.S. citizenship or qualified non-citizen status.
When verifying U.S. citizenship or qualified non-citizen status:
U.S. citizenship only needs to be verified once. (See 4.1.2 for allowable documentation.)
If an applicant is not a U.S. citizen or national, they must provide immigration documentation that the W-2 agency must verify through SAVE Systematic Alien Verification for Entitlements .
The Non-Citizen Eligibility Documentation Appendix lists documents that can be used to verify qualifying status. The W-2 agency cannot specify which type of document an applicant must present to show their immigration status.
All documents issued by United States Citizenship and Immigration Services (USCIS) The federal agency that oversees lawful immigration of foreign nationals who are temporarily or permanently settling in the U.S. See also INS. containing a photo serve as verification of identity and immigration status.
Once an applicant provides documentation identifying their status as a qualified non-citizen, they are presumptively eligible for W-2 until the FEP Financial and Employment Planner verifies their status through SAVE.
The FEP must not delay or deny the applicant’s eligibility for W-2 based on the applicant’s immigration status while verification is pending.
If an applicant’s immigration status has already been verified through the FDSH Federal Data Sources Hub , this is considered valid for W-2, and the FEP does not need to request additional documentation or reverify through SAVE.
A non-citizen’s immigration status may change over time. The table below outlines the required verification steps based on FDSH verification.
Scenario Required Verification The individual’s new immigration status has been verified through the FDSH. This is considered valid verification. The individual’s new immigration status has not been verified through the FDSH. The individual must provide immigration documentation of the new status and the FEP must verify it through SAVE.
FEPs should not update the immigration status code of individuals who were previously verified as a:
Refugee;
Asylee;
Cuban/Haitian entrant;
Individual granted withholding of deportation/removal;
Victim of trafficking; or
Iraqi or Afghan special immigrant.
Individuals in these statuses are exempt from the five-year ban on certain public benefits even if their immigration status later changes, and updating the immigration status code could cause the individual to incorrectly lose eligibility for the benefits. For example, a refugee whose immigration status changes to Lawful Permanent Resident should remain coded as a refugee.
The FEP must presume an applicant has the immigration status they claim until the applicant has the opportunity to present the appropriate documentation, when:
An applicant does not present documentation, and their status has not been verified through the FDSH; or
An applicant presents a document that: Does not appear to be official; Does not apply to the person presenting it; or Is expired.
If the applicant does not have documentation of their immigration status, the FEP should refer the individual to the local USCIS office to obtain it.
The FEP must make every effort to assist in obtaining the required documentation in cases where:
The participant is hospitalized or medically disabled;
The participant can demonstrate good cause for their inability to present documentation; or
Securing such documentation would constitute undue hardship for the participant.
Children of non-citizen adults receive their own USCIS documentation, which does not verify their relationship to family members. The FEP must verify custodial parent relationships of non-citizens using the same procedures used for U.S. citizens. (See 2.3.1 )
The Systematic Alien Verification for Entitlements (SAVE) is the federal system used to verify an applicant’s immigration status.
To acquire access to the SAVE system, W-2 workers must submit the CARES Automated Systems Access Request form (F-00476) to the CARES Security staff. Not all workers are allowed access to the SAVE system.
Workers can access SAVE through:
The Immigrant/Refugee Information page in CWW; or
The SAVE website .
Information for using this system and for verifying alien status is located in the CWW Process Help Manual .
The following qualified non-citizens (formerly referred to as “Qualified Aliens”) may be eligible for W-2 Wisconsin Works :
An alien lawfully admitted to the United States for permanent residence under the Immigration and Nationality Act (INA) Immigration and Nationality Act (INA)- The basic body of immigration law in the United States, which was created in 1952 and has been amended many times. The INA is a free-standing law, but is also contained in the U.S. Code. ;
An alien who is granted asylum under section 208 of the Immigration and Nationality Act;
A refugee who is admitted to the United States under section 207 of the Immigration and Nationality Act, including Special Visa Immigrants from Iraq and Afghanistan under section 1059 of H.R. 1815;
An alien who has been certified as a victim of trafficking;
An alien who is paroled into the United States under section 212(d)(5) of the Immigration and Nationality Act for a period of at least one year;
An alien whose deportation is being withheld under section 243(h) or 241(b)(3) of the Immigration and Nationality Act;
Cuban and Haitian aliens, as defined in section 501(e) of the Refugee Education Assistance Act of 1980;
An American Indian born in Canada who is at least 50% American Indian by blood, or an American Indian born outside of the United States who is a member of a federally recognized Indian tribe;
An alien who has been battered or whose child has been battered, who is no longer residing in the same household with the batterer, and who meets the requirements of 8 U.S.C. s. 1641(c);
An alien who is granted conditional entry pursuant to section 203(a)(7) of the Immigration and Nationality Act as in effect prior to April 1, 1980;
Amerasian Immigrants, as defined in section 584 of the Foreign Operations, Export Financing, and Related Programs Appropriations Act of 1988;
An alien who is lawfully residing and is one of the following: An armed forces veteran who received an honorable discharge that was not on account of alienage and who completed either 24 months of continuous active duty or the full period for which the individual was called, unless the individual received a hardship discharge under 10 U.S.C. s. 1173, early discharge under 10 U.S.C. s. 1171, or a discharge due to a disability incurred or aggravated in the line of duty. On active duty in the armed forces of the United States, other than active duty for training. The spouse of an individual described in subdivision a. or b., or the unremarried surviving spouse of an individual described in subdivision a. or b. if the marriage was for one year or more or the individual had a child in common.
An alien who is lawfully residing in the United States and authorized to work by United States Citizenship and Immigration Services (USCIS) The federal agency that oversees lawful immigration of foreign nationals who are temporarily or permanently settling in the U.S. See also INS. .
W-2 for qualified non-citizens is not paid with federal funds, so they are exempt from the 60-month federal lifetime limit. Qualified non-citizens are subject to the 48-month state lifetime limit and 24-month placement time limits.
WWP will automatically disregard federal months for qualified non-citizens if the individual:
Belongs to one of the qualified non-citizen groups listed above; and
Is coded as such on the Immigrant/Refugee Information page in CWW CARES Worker Web .
W-2 agencies must not manually enter a federal month of TANF Temporary Assistance for Needy Families assistance for any month a qualified non-citizen participates in W-2. (See 2.10.9 ) In a two-parent case where one parent is a qualified non-citizen and the other is a U.S. citizen, the U.S. citizen will only use months of federal TANF assistance when the U.S. citizen is in a paid placement.
Some foreign-born children, including adopted children, residing permanently in the United States acquire U.S. citizenship automatically if at least one custodial parent is a citizen. To be eligible, a child must meet the following requirements:
Have at least one U.S. citizen parent (by birth or naturalization);
Be under 18 years of age;
Be currently residing permanently in the U.S. in the legal and physical custody of the U.S. citizen parent;
Be a lawful permanent resident; and
If the child is the adoptive child of the U.S. citizen parent, the child must also meet the requirements applicable to adopted children under the Immigration and Nationality Act (INA) Immigration and Nationality Act (INA)- The basic body of immigration law in the United States, which was created in 1952 and has been amended many times. The INA is a free-standing law, but is also contained in the U.S. Code. , Section 101(b)(1).
Proof of citizenship verification is not automatically issued to children who acquire derivative citizenship Citizenship conveyed to children through the naturalization of parents or, under certain circumstances, to foreign-born children adopted by U.S. citizen parents, provided certain conditions are met. . A parent may apply for a United States Citizenship and Immigration Services (USCIS) The federal agency that oversees lawful immigration of foreign nationals who are temporarily or permanently settling in the U.S. See also INS. certificate of citizenship for the child or a passport for their child. If the parent does not present one of these documents for a child and there is no documentation issued by the USCIS proving citizenship status, the FEP Financial and Employment Planner can make a determination of derivative citizenship by verifying at least three requirements listed above. However, FEPs should encourage parents to obtain official documentation to avoid future citizen verification problems for the child.
Many non-citizens acquire citizenship over time. Therefore, the FEP Financial and Employment Planner should review non-citizen status at each eligibility review. However, citizenship only needs to be verified once. (See 4.1.2 )
Both Custodial Parents (CP) With respect to a dependent child, a parent (see definition of parent) who resides with that child and, if there has been a determination of legal custody with respect to the dependent child, has legal custody of that child and noncustodial parents are required to cooperate in good faith with the efforts directed at establishing child support and paternity for any minor child of that parent.
Each Custodial Parent (CP) in the W-2 Group An adult custodial parent, all dependent children with respect to whom the individual is a legal custodial parent and all minor children with respect to whom the adult individual’s dependent child is a custodial parent. W-2 Group includes any non-marital co-parent or any spouse of the individual who resides in the same household as the individual and any minor children with respect to whom the spouse or non-marital co-parent is a custodial parent. W-2 Group does not include any person who is receiving cash benefits under a county relief block grant program. This is also referred to as the W-2 Assistance Group (W-2 AG) must cooperate in good faith with efforts to:
Identify and locate an absent parent;
Establish paternity of any child of the custodial parent; and
Obtain support payments or any other payments or property to which that parent and any minor child of that parent may have rights to.
Each noncustodial parent in the W-2 Wisconsin Works Group must cooperate in good faith with efforts to:
Establish paternity of an alleged child of the noncustodial parent; and
Obtain support payments or any other payments or property the noncustodial parent may be responsible for.
For more information on child support cooperation, see 15.3.1 .
A FEP Financial and Employment Planner may require a W-2 Wisconsin Works applicant or participant to apply for and accept other public assistance programs or resources that may be available, prior to being determined eligible for W-2 services or during W-2 participation.
Other sources of public assistance or resources may include, but are not limited to:
Unemployment Insurance;
Worker’s Compensation;
Child Support;
Social Security Survivor benefits; and
Veterans benefits.
The requirement to apply for these other public assistance programs or resources must be provided to the applicant or participant in writing. The written notification must:
Include a due date by which the individual must apply for the program or resource; and
State that the individual may be ineligible for W-2 or a JAL Job Access Loan if they refuse to apply for or refuse to accept other public assistance programs or resources.
The W-2 agency may also encourage the applicant or participant to access, on a voluntary basis, other services which may help the applicant find employment. Examples of these services include WIOA Workforce Innovation and Opportunity Act programs and DVR Division of Vocational Rehabilitation programs.
Every W-2 Group An adult custodial parent, all dependent children with respect to whom the individual is a legal custodial parent and all minor children with respect to whom the adult individual’s dependent child is a custodial parent. W-2 Group includes any non-marital co-parent or any spouse of the individual who resides in the same household as the individual and any minor children with respect to whom the spouse or non-marital co-parent is a custodial parent. W-2 Group does not include any person who is receiving cash benefits under a county relief block grant program. This is also referred to as the W-2 Assistance Group (W-2 AG) member, including newborns, must provide a Social Security Number (SSN), or proof that they have applied for one, unless the individual is initially exempt.
An individual is initially exempt if they do not have an SSN, do not have a work authorization, and belong to one of the following qualified non-citizen groups:
Cuban/Haitian entrants, as defined in section 501(e) of the Refugee Education Assistance Act of 1980;
Certified, foreign-born victims of trafficking;
Parolees (alien paroled into the U.S. for at least one year under section 212(d)(5) of the Immigration and Nationality Act (INA) Immigration and Nationality Act (INA)- The basic body of immigration law in the United States, which was created in 1952 and has been amended many times. The INA is a free-standing law, but is also contained in the U.S. Code. );
Certain battered aliens who meet the requirements of 8 U.S.C. s. 1641(c); or
Any qualified non-citizen (see 2.4.2 ) who cannot apply for an SSN until their immigration status paperwork has been revised.
An initially exempt individual must continue working towards obtaining an SSN to remain eligible for W-2 Wisconsin Works . If assistance is needed, the W-2 agency must help the individual complete the process. (See 4.1.3 )
See 4.1.2 for recommended sources of allowable verification.
Once an SSN application date is verified, the individual has at least six full calendar months from the SSN application date to provide the SSN. The SSN must be provided by the end of the 13th full calendar month after the month of the SSN application date.
The FEP Financial and Employment Planner may collect the SSN at any point beginning in the seventh full calendar month and ending in the 13th full calendar month. This policy aligns with Health Care and FoodShare policy.
To support the policy of all three programs, beginning in the seventh full calendar month and ending in the 13th full calendar month, CWW CARES Worker Web will prompt the FEP or IM Income Maintenance worker to collect the SSN anytime the FEP or IM worker completes an:
Intake;
Review/Renewal; or
Program Add.
Note : The timeframe described above also applies to individuals who are initially exempt. For initially exempt individuals, the individual has at least six full calendar months from the W-2 Initial Exemption Date in CWW to provide the SSN. The SSN must be provided by the end of the 13th full calendar month after the month of the W-2 Initial Exemption Date in CWW.
EXAMPLE 1: Moira applies for W-2 in January 2025. The IM worker previously verified that her son Hashim’s SSN application date is February 10, 2024. Because the SSN application date is more than six full calendar months in the past at the time of the W-2 intake, CWW will prompt the FEP to pend for or enter Hashim’s SSN.
EXAMPLE 2: Moira applies for W-2 in January 2025. The IM worker previously verified that her son Hashim’s SSN application date is August 10, 2024. Because the SSN application date is less than six full calendar months in the past at the time of the W-2 intake, CWW will not prompt the FEP to pend for or enter Hashim’s SSN.
At the June 2025 W-2 review, the SSN application date will be more than six full calendar months in the past and CWW will prompt the FEP to pend for or enter Hashim’s SSN.
EXAMPLE 3 : Moira applies for W-2 in January 2025. The IM worker previously verified that her son Hashim’s SSN application date is August 10, 2024. Because the SSN application date is less than six full calendar months in the past at the time of the W-2 intake, CWW will not prompt the FEP to pend for or enter Hashim’s SSN.
In March 2025, the IM worker completes an IM renewal. Because Hashim’s SSN application date is more than six full calendar months in the past at the time of the IM renewal, CWW will prompt the IM worker to pend for or enter Hashim’s SSN.
EXAMPLE 4 : Moira applies for W-2 in January 2025. The IM worker previously verified that her son Hashim’s SSN application date is August 10, 2024. Because the SSN application date is less than six full calendar months in the past at the time of the W-2 intake, CWW will not prompt the FEP to pend for or enter Hashim’s SSN.
However, Moira informs the FEP that Hashim received his SSN. The FEP enters Hashim’s SSN into CWW and the SOLQ-I data exchange verifies Hashim’s SSN. The requirement that all individuals in the W-2 Group must provide an SSN has been met.
E XAMPLE 5 : Moira applies for W-2 in January 2025. The IM worker previously verified that her son Hashim’s SSN application date is November 10, 2024. Because the SSN application date is less than six full calendar months in the past at the time of the W-2 intake, CWW will not prompt the FEP to pend for or enter Hashim’s SSN.
Moira loses W-2 eligibility in April 2025 and reapplies for W-2 in June 2025. Because Hashim’s SSN application date is now more than six full calendar months in the past, CWW will prompt the FEP to pend for or enter Hashim’s SSN.
Note : Because a W-2 eligibility review is required every six months, the latest that CWW would prompt the FEP to pend for or enter the SSN is the 12th calendar month after the SSN application date or the W-2 Initial Exemption Date in CWW. Therefore, the latest possible verification deadline would occur in the 13th calendar month after the SSN application date or the W-2 Initial Exemption Date in CWW.
If the W-2 agency determines that a W-2 Group member has refused to provide or apply for an SSN, the entire W-2 Group is ineligible for W-2.
W-2 agencies must only use SSNs and personally identifiable information for the direct administration of the program. Each time a FEP Financial and Employment Planner requests an SSN, the FEP must inform the individual:
That disclosure is mandatory for eligibility determination;
How the agency will use the number; and
Under what statutory or other authority the agency is requesting the number.
See below for an example statement:
Provision of your SSN or cooperation in applying for an SSN is required to determine eligibility for Wisconsin Works (W-2). The number you provide to the agency will be verified for program management. Wisconsin Stat. s. 49.145 (2)(k).
To remain eligible for W-2, participants must notify the W-2 Wisconsin Works agency of a change in circumstance that may affect eligibility.
The following table outlines the required reporting timeframe based on the change in circumstance.
Change in Circumstance Required Reporting Timeframe Any change in circumstance that may impact eligibility, such as a change in Wisconsin residency, increased income or assets, etc. (See 2.2.1 ) 10 Calendar Day Any day of the week, including weekends and holidays. s The absence of a child. (See 2.8.2 ) Five Working Day Any day of the week except Saturday, Sunday, and CARES holidays. s
The agency must respond to reports in a timely manner and keep case data up to date.
Applicants and participants who meet all financial and nonfinancial eligibility requirements are eligible for all W-2 Wisconsin Works services even if the Dependent Child A person who resides with a parent and who is under the age of 18 or, if the person is a full-time student at a secondary school or a vocational or technical equivalent and is reasonably expected to complete the program before attaining the age of 19, is under the age of 19 (ren) is temporarily absent from the home provided the following four conditions are all met:
The child will not be, or has not been, continuously absent for more than three months and is expected to return to the parent’s household.
The child’s absence is not the result of removing the child under a dispositional order, which places custody of the child outside the home, indefinitely or for three or more months.
The custodial parent continues to exercise responsibility for the care and control of the child: for instance, the parent is responsible for decisions about the child’s education, healthcare, and any medical treatment, or travel while the child is out-of-home.
The applicant or participant must report the absence of a child within five working days.
The parent’s requirement to report the child’s absence to the W-2 agency within five working days begins the day the parent knows the child is absent from the home.
Note : The five-day notification period is a federal TANF requirement and the time frame differs from the W-2 10-day notice of change requirement.
The temporary absence of a child policy is not applicable if there is at least one dependent child remaining in the home because then the dependent child requirement is met for W-2 nonfinancial eligibility.
A case-by-case exception may extend the three-month temporary absence period to six months for child welfare-related absences if all of the following conditions are met:
The custodial parent is cooperating in and satisfactorily completing W-2 agency’s assigned activities.
The applicant or participant must report the child’s temporary absence due to child welfare issues to the W-2 Wisconsin Works agency within five working days. The five-day reporting requirement begins when the parent knows the child is absent due to child welfare issues. The W-2 agency will accept a report of a child’s temporary absence from the Child Welfare agency as a report from the parent. The W-2 agency must inform the parent if the Child Welfare agency reports a child’s absence on their behalf. If the Child Welfare agency is involved with the family, the W-2 agency worker must coordinate with the Child Welfare agency to implement communication procedures to meet the reporting requirements.
The Child Welfare agency confirms the child was removed from the home due to child welfare issues (note that juvenile justice involvement alone does not meet this requirement).
The parent maintains an appropriate home for the child as determined by the W-2 and Child Welfare agencies (e.g., the parent is not in a treatment center or other out-of-home placement).
The W-2 agency should contact the Child Welfare agency with any concerns about the safety of the home.
Note : The parent’s participation in out-of-home care for mental health, AODA Alcohol and Other Drug Abuse , or medical care for no longer than one month during the child’s absence from the home does not preclude eligibility based on temporary absence provided the home remains appropriate for the child based on determinations by the W-2 and Child Welfare agencies.
The Child Welfare agency’s permanency plan and any other Child Welfare agency plan states that the child is expected to be reunified with the parent in the parent’s household within six months and the child while in the out-of-home placement.
The child’s out-of-home placement type supports reuniting the child with the parent in the parent’s household within six months of the child’s temporary absence from the home (e.g., child is not in a pre-adoptive placement).
The custodial parent is cooperating with and is on track to complete all Child Welfare agency requirements for reunification.
For each month the child welfare exception is applied, the W-2 agency must:
Verify condition 1 above is met; and
Contact the Child Welfare agency to determine whether conditions 2-7 above are met.
The temporary absence policies for child welfare situations require significant communication and collaboration between the W-2 Wisconsin Works agency and Child Welfare agency.
The W-2 agency must develop and implement procedures to ensure ongoing communication and coordination with the Child Welfare agency, including, but not limited to:
Identification of families receiving services from both agencies;
Contact with the Child Welfare agency’s primary worker for the family a minimum of every other week, including more frequent contact when there are changes that may impact W-2 participation or goals developed with the Child Welfare agency;
Coordinating with the Child Welfare agency to include activities assigned by the Child Welfare agency for the parent’s reunification with the child(ren) as part of the parent’s W-2 EP Employability Plan , when the activities are approvable W-2 activities; and
Exchange of relevant information between both agencies to improve services and reduce duplication, including: Updates on out-of-home placement or legal orders impacting the custodial parents ongoing care and control of the child(ren); Sharing of assessment results; and Coordination of referrals to other resources (e.g., AODA, mental health support programs, community programs, etc.).
Confidential information should be shared in accordance with federal and state confidentiality laws.
An individual is not eligible for W-2 Wisconsin Works services under the temporary absence policy when an out-of-home child is in Kinship Care.
However, provided all policy requirements are met, the individual may be eligible for W-2 under the temporary absence policy if at least one out-of-home child is not in Kinship Care (e.g., foster care). (See 2.8.2 )
W-2 Wisconsin Works participants whose incarceration renders them temporarily unable to participate in work activities or retain care and control of their children will remain eligible for W-2 payments for up to 30 days, provided they remain otherwise financially and nonfinancially eligible.
The 30-day timeframe allows for short-term incarceration without having to disrupt a participant’s activities, payments, and child care by disenrolling and then re-enrolling them in W-2.
W-2 participants who experience incarceration for more than 30 consecutive days are not eligible for W-2 payment.
For more information on incarceration of W-2 participants including information on activity assignment, good cause, and the Huber program, see 11.7.1 .
When appropriate, The W-2 Wisconsin Works applicants may be assigned to search for unsubsidized employment as a condition of eligibility. This is often referred to as an “up-front job search.”
If an applicant fails to participate in up-front job search requirements without good cause, the W-2 agency may deny the individual’s application.
In addition, W-2 participants may be required to look for employment. If a W-2 participant fails to cooperate with employment search requirements without good cause, the W-2 agency may close the participant’s case. (See 11.5.1 )
The goal of up-front job search activities is to rapidly connect the applicant to sustainable employment.
Not all applicants are appropriate for an up-front job search. When deciding whether to assign up-front job search activities as a condition of eligibility, the RS Resource Specialist and the FEP Financial and Employment Planner must use the best available information. This includes information gathered through:
The informal assessment process;
The educational needs assessment Educational needs assessments determine if the individual needs, or would benefit from, education or training activities, including a course of study for the granting of a declaration of equivalency of high school graduation. In making this determination, the FEP must consider the following: • The information gathered on the applicant/participant’s current educational levels; • The level of education and training necessary to obtain full-time employment in the local labor market; and • The applicant/participant’s personal employment goals. ;
The career assessment A broad spectrum of assessment tools that W-2 agencies, applicants, and participants use to obtain greater awareness about how an individual’s work styles, skills, and interests can be used to define a career path, assign meaningful activities, highlight strengths, identify training needs, and match the individual to employment opportunities ; and
Any additional vocational evaluation/assessment Assessments which are conducted to help individuals living with a disability establish realistic vocational goals and a plan to achieve them. The vocational evaluation process is designed to assess the unique strengths, resources, and experiences of an individual in order to match that person’s abilities and preferences to appropriate work placements, jobs, or training programs. The process is interactive; the intent is for staff to learn about the participant and the participant to learn about themselves s or formal assessments obtained to date. (See Chapter 5 )
Assignment of up-front job search activities must be made on a case-by-case basis. W-2 agencies must not assign up-front job search without regard to an individual’s circumstances.
In two-parent households (see 14.1 ), either or both parent(s) applying for W-2 assistance may be assigned to up-front job search activities, depending on their individual circumstances.
W-2 workers should use the following table as a starting point for determining whether to assign up-front job search.
Applicants are likely to be appropriate for up-front job search if they: Applicants are unlikely to be appropriate for up-front job search if they: Have or can arrange access to safe and reliable child care; Have stable housing; Have access to safe and reliable transportation; Have a recent employment history; or Possess marketable skills in the current labor market. Do not have access to safe and reliable child care; Are unhoused and not ready to find immediate work; Do not have access to safe and reliable transportation; Have no employment history, have not been employed recently, or have a history of failed employment; Have barriers preventing them from entering the labor market, such as being 18- or 19-year-old and not having a high school diploma or GED; Are in a domestic abuse situation; Meet the characteristics of a W-2 T placement (see 7.4.2 ); or Are otherwise unprepared to begin work in the next 12 working days.
When assigning up-front job search activities, the W-2 agency must:
Record the assignment of up-front job search activities on the W-2 Up-Front Requirements CWW CARES Worker Web page;
Develop an individualized EP Employability Plan for all applicants assigned to up-front job search activities; and
Assist the applicant in their up-front job search activities.
(See the Activity Codes Appendix for up-front job search activity codes and definitions)
Examples of W-2 agency support in the up-front job search, includes but is not limited to:
Conducting career assessment and career exploration activities to help match applicants with appropriate job leads;
Developing job opportunities by identifying job openings, marketing applicants to employers, and securing job interviews;
Helping applicants create resumes and complete job applications;
Structuring employment searches to meet applicants’ needs, including independent job search, job club activities for peer support, and job lead sharing;
Providing job leads to businesses hiring individuals with the applicant’s skills; and
Maintaining regular communication with the applicant throughout the job search to review progress and offer support.
Individuals determined ready for unsubsidized employment may be assigned up-front job search and job readiness activities if they have:
Filed a W-2 application with a W-2 agency and do not have an open W-2 case with that W-2 agency or any other W-2 agency;
A pending W-2 case closure in CARES due to ineligibility, their W-2 placement has been end-dated, and they contact the same or a different W-2 agency to request assistance from W-2; or
Relocated into a new W-2 geographical area.
E XAMPLE : Laura’s CMC placement ended on June 5 and she returned to work. Her FEP offered follow-up case management services, but Laura declined.
Laura’s FEP enters her earned income into CWW and ends her W-2 placement. Laura’s W-2 eligibility is pending closed for June 30.
On June 25, Laura notifies the W-2 agency that she lost her job and submits a new request for W-2. Based on an assessment of Laura’s work history, education, and employment skills, the agency determines that it is appropriate to assign Laura to up-front job search before making a new placement determination.
The assignment of up-front job search activities may take place while the applicant is waiting to meet with the FEP and while the FEP is making the eligibility and placement decisions.
The FEP must not extend the application process past the 12 working days (five days to meet with the FEP and seven days for the FEP to make an eligibility determination and placement) to accommodate a lengthier job search. (See 1.4.4 )
W-2 agencies must not assign up-front job search activities if any of the following conditions exist:
A participant has continued ongoing W-2 eligibility in one agency. This includes circumstances where a participant’s CMC placement is ending, they are unemployed, and they meet eligibility criteria for a different cash assistance placement.
A CMF Case Management Follow-Up or CMF+ Case Management Follow-Up Plus participant contacts the FEP to request a paid W-2 placement because their employment has ended.
An individual is pregnant and applying for a CMC Custodial Parent of an Infant placement or an ARP At Risk Pregnancy placement.
An individual is an AmeriCorps VISTA volunteer.
A participant moves from one W-2 geographical area to another and neither W-2 eligibility nor the W-2 placement has ended.
A participant moves from one county to another county where both counties operate under one W-2 agency.
The FEP determines, on a case-by-case basis, whether an applicant has made a good faith effort to obtain employment by completing assigned up-front job search activities.
Throughout the application period, the FEP should check in with the applicant to determine how the up-front job search activities are going and offer support.
If the applicant is not completing the assigned activities, the FEP must:
Discuss the situation with the applicant;
Determine if any barriers exist; and
End up-front job search activities if barriers are identified that make the applicant unable to find employment in the application timeframe.
If no barriers are identified and the applicant does not provide good cause for failing to meet the up-front job search requirements, the FEP may deny the application. (See 11.3.1 )
If an applicant finds unsubsidized employment during up-front job search, the FEP must place the applicant in the CMF placement or the prorated CSJ Community Service Job placement. The FEP cannot place the applicant in CMF+ because only participants in a CSJ, W-2 T, or TMP placement may be placed in CMF+.
Applicants that find unsubsidized employment during up-front job search may be eligible for the following placements based on their weekly work hours:
Work Hours Per Week Eligible Placement Eligibility Requirements Employment Verification 30 hours or more CMF placement The applicant must meet nonfinancial eligibility requirements. (See 3.1 and 7.2.3.4 ) If employment verification is unavailable immediately, the FEP may use the applicant’s verbal statement to place them in CMF, develop the EP, and assign case management activities. (See 7.2.3.1 ) Less than 30 hours Prorated CSJ placement The applicant must meet both nonfinancial and financial eligibility requirements. (See Chapters 2 , 3 , and 7.4.1.5 ) The FEP must verify that the applicant has started work, confirm wages, and determine the expected weekly hours before assigning a prorated CSJ placement. (See 4.1.3 )
Note : Case closure policies in section 11.5.1 for failing to verify eligibility information do not apply to W-2 applicants. The case closure policies only apply to W-2 participants in open and ongoing W-2 cases.
E XAMPLE : Joseph has a history of employment as a marble finisher; however, his employer of five years went out of business. Joseph has a high school diploma, a valid driver’s license, and owns a vehicle.
On the fourth working day of up-front job search, Joseph informs his FEP that he interviewed with a local manufacturing company and was offered a full-time position starting the following working day.
Using Joseph’s stated employment and employment start date, the FEP conducts an informal assessment and identifies few to no known barriers to employment. After running eligibility, the FEP determines that Joseph meets all of the nonfinancial eligibility requirements for a CMF placement and explains the possible CMF+ stipend and the W-2 agency job retention incentives Joseph may be eligible for with continued employment.
Unless the participant is unable to work due to a disability and is applying for SSI/SSDI Supplemental Security Income / Social Security Disability Insurance , the activities assigned on the EP Employability Plan should be focused on helping that participant gain the skills and experience needed to secure and maintain stable employment. As such, most W-2 participants will be assigned to one of the following employment search activities:
ES – Employment Search
CE – Career Planning & Counseling
MO – Job Readiness / Motivation
LF – Life Skills
(See the Activity Codes Appendix for definitions of these activity codes)
Failure to comply with these activities may result in case closure for noncooperation with program requirements. (See 11.5.1 and 11.5.2 ) This requirement applies only to individuals in TEMP Trial Employment Match Program , W-2 T W-2 Transition , and CSJ Community Service Job placements and does not apply to individuals in a CMC Custodial Parent of an Infant and ARP At-Risk Pregnancy placements or to individuals who are AmeriCorps VISTA volunteers.
Time limits stress mutual responsibility between the W-2 Wisconsin Works program and participants.
W-2 eligibility is subject to three time limits:
Employment Position 24-Month Limit – W-2 participants can be placed in a W-2 Employment Position ( TEMP Trial Employment Match Program , CSJ Community Service Job , and W-2 T W-2 Transition ) for up to 24 months per position. (See 2.10.3 )
State 48-Month Lifetime Limit – W-2 participants can receive W-2 services for up to 48 months over their lifetime. (See 2.10.2 )
Federal 60-Month Lifetime Limit – Individuals can receive federal TANF Temporary Assistance for Needy Families cash assistance for up to 60 months. (See 2.10.9 )
The goal of W-2 participation is to help participants reach their employment and earnings goals and support growth toward economic self-sufficiency.
The 48-month state lifetime limit is the cumulative total number of months an individual, or any adult member of an individual's W-2 Group An adult custodial parent, all dependent children with respect to whom the individual is a legal custodial parent and all minor children with respect to whom the adult individual’s dependent child is a custodial parent. W-2 Group includes any non-marital co-parent or any spouse of the individual who resides in the same household as the individual and any minor children with respect to whom the spouse or non-marital co-parent is a custodial parent. W-2 Group does not include any person who is receiving cash benefits under a county relief block grant program. This is also referred to as the W-2 Assistance Group (W-2 AG) , has participated in or received benefits under, at least one of the following:
A W-2 Employment Position Community Service Job, Trial Employment Match Program, and W-2 Transition at any time during a month, including TEMP Trial Employment Match Program , CSJ Community Service Job , or W-2 T W-2 Transition even if the payment was reduced to $0.
Any TANF Temporary Assistance for Needy Families funded program in this state or any other state for which the participant received TANF cash assistance while in that program. (See 2.10.2.3 ) This includes Tribal TANF funds and some months in a CMC Custodial Parent of an Infant placement. (See 2.10.8 )
The AFDC Aid to Families with Dependent Children JOBS program from October 1, 1996, to W-2 implementation in September 1997. AFDC participation counts toward the 48-month state lifetime limit if the individual was: Included in the Standard Filing Unit in an open AFDC assistance group (including sanctioned adults); Age 18 or older; Coded with a JOBS registration code of mandatory (M), voluntary (V), or PFR Demonstration with a code of (P) or (R); and Enrolled in JOBS under experimental or non-experimental PFP, WNW, Experimental or Control PFR.
Months of participation in the CMF+ placement where a monthly $50 supplemental payment is received do not count towards the state 48-month lifetime limit. (See 7.2.3.5.1 )
The 48-month state lifetime limit applies to all adults in the W-2 Group An adult custodial parent, all dependent children with respect to whom the individual is a legal custodial parent and all minor children with respect to whom the adult individual’s dependent child is a custodial parent. W-2 Group includes any non-marital co-parent or any spouse of the individual who resides in the same household as the individual and any minor children with respect to whom the spouse or non-marital co-parent is a custodial parent. W-2 Group does not include any person who is receiving cash benefits under a county relief block grant program. This is also referred to as the W-2 Assistance Group (W-2 AG) .
Any month during which any adult in the W-2 Group participates in a W-2 employment position counts towards the individual’s 48-month state lifetime limit for both the parent in the placement and the non-placed parent. This includes:
Second parents;
Stepparents;
Adult SSI Supplemental Security Income / SSDI Social Security Disability Insurance recipients; and
Non-marital Co-parent With respect to an individual and a dependent child, a parent who is not married to the child’s other parent and is either an adjudicated parent or a parent who has signed and filed with the state registrar under s.69.15(3)(b)3, Stats., a statement acknowledging paternity s.
See 2.10.9 for information on what counts toward the 60-month federal lifetime limit.
In W-2 Groups with more than one adult member, the adult member with the greatest number of accumulated months determines the W-2 Group’s 48-month state lifetime limit.
When a new adult enters a W-2 Group, the group's total cumulative number of months increases if the new member has accumulated more months than the primary individual.
When an adult leaves a W-2 Group they take with them the months accumulated while in the W-2 group and any months they accumulated before joining the W-2 group.
EXAMPLE 1 : Mary is in a W-2 Group consisting of herself and her 4-year-old daughter. She has accumulated 30 months towards her 48-month state lifetime limit. Because she is the only adult in the W-2 Group, the W-2 Group is credited with 30 months toward the 48-month state lifetime limit.
John, Mary’s husband, moves in with Mary and joins the W-2 Group. John has accumulated 35 months toward his 48-month state lifetime limit prior to moving back in with Mary.
Because John has the greater number of months accumulated towards the state lifetime limit, the W-2 Group’s new total is 35 months towards the 48-month state lifetime limit.
EXAMPLE 2 : After ten months, John moves out of the home and exits the W-2 Group. At the time John left the W-2 Group, he and Mary had used an additional 10 months toward the 48-month state lifetime limit reaching a total of 45 months (35 + 10).
With John out of the W-2 group, The W-2 Group's new total is 40 accumulated months toward the 48-month state limit, reflecting:
Mary’s original 30 months before John joined the W-2 group; and
The 10 additional months accumulated while John was in the W-2 group.
John keeps his 45 accumulated months toward the 48-month state limit.
Dependent 18-year-old A person who resides with a parent and who is 18, a full-time student at a secondary school or a vocational or technical equivalent, and who is reasonably expected to complete the program before attaining the age of 19. s are considered to be children in the W-2 Group and are not subject to time limits.
Once a dependent 18-year-old turns 19 or graduates from school, the individual becomes an Excluded Adult An adult who resides with the W-2 Group, but who is not included by definition in the W-2 Group. and is no longer included in the W-2 Group.
If a dependent 18-year-old has a Dependent Child A person who resides with a parent and who is under the age of 18 or, if the person is a full-time student at a secondary school or a vocational or technical equivalent and is reasonably expected to complete the program before attaining the age of 19, is under the age of 19 and applies for services independent of their parents, they would form their own W-2 Group with their dependent child and become subject to the 48-month state lifetime limit.
Any adult in the W-2 Group An adult custodial parent, all dependent children with respect to whom the individual is a legal custodial parent and all minor children with respect to whom the adult individual’s dependent child is a custodial parent. W-2 Group includes any non-marital co-parent or any spouse of the individual who resides in the same household as the individual and any minor children with respect to whom the spouse or non-marital co-parent is a custodial parent. W-2 Group does not include any person who is receiving cash benefits under a county relief block grant program. This is also referred to as the W-2 Assistance Group (W-2 AG) is exempt from the 48-month state lifetime limit for any month in which they are living in a federally recognized American Indian reservation, an Alaskan Native village, or an Indian country occupied by an Indian tribe, if during that month the following applies:
At least 1,000 individuals were living on the reservation, in the village, or in the Indian country; and
At least 50 percent of the adults were unemployed.
In Wisconsin, TANF months accumulated in other states count toward the 48-month state lifetime limit.
When there is evidence that an applicant has received TANF cash assistance in another state, the FEP Financial and Employment Planner must:
Determine the number of months TANF cash assistance was received in the other state by contacting the appropriate agency or individual. Note that: Only months of TANF cash assistance received after September 1, 1996, count toward the 48-month state lifetime limit. If the contact cannot confirm that the assistance received in the other state was TANF, do not count the month(s). The months of TANF cash assistance received in the other state do not have to be verified in writing.
Enter the verified month and years that TANF was received in the other state in the WWP Time Limit Tracking application as OTF-Benefits from Another State. In the details field, the FEP must indicate the date verified and any other relevant information.
EXAMPLE : Annabelle moves to Wisconsin from Illinois and applies for W-2. When the FEP contacts Illinois, the case worker confirms that Annabelle received TANF benefits for 24 months in Illinois.
If Annabelle is found eligible for W-2, Annabelle will start in W-2 with 24 months accumulated toward her Wisconsin 48-month state lifetime limit.
If an individual who has received more than 48 months of TANF assistance in another state is eligible for W-2 but has used 48-months of their state lifetime limit, the FEP must determine eligibility for a state lifetime limit extension based on the time limit extension criteria at application.
When applying the time limit extension criteria, the FEP must:
Use information obtained during the W-2 informal assessment; and
Attempt to contact the other state for more specific information about the applicant.
If the FEP is unable to obtain additional information, the information gathered through the informal assessment must be used to determine eligibility for a time limit extension.
(See 2.10.6 for more information on time limit extensions.)
Participation in a TEMP Trial Employment Match Program , CSJ Community Service Job , or W-2 T W-2 Transition employment position is limited to 24 cumulative months. Each employment position has its own 24-month placement time limit and, therefore, a participant has 24 months in each of the placement types.
If the individual’s payment is reduced, even to $0, the month in the placement still counts toward the 24-month placement time limit.
See 2.10.8.3 for information on when participation in a CMC Custodial Parent of an Infant placement can count toward a 24-month placement time limit.
The 24-month placement time limit is determined by the employment position placement on the last working day of the month. If the W-2 placement on the last working day of the month is not a TEMP, CSJ, or W-2 T, the most recent employment position placement will determine the 24-month placement time limit.
A month counts toward the appropriate 24-month time limit even if the participant was in a TEMP, CSJ, or W-2 T placement for only a single day in that month.
EX AMPLE 1: John is placed in a CSJ on January 1. On January 28, John is placed in a W-2 T placement and remains in the placement through the end of the month.
The month of January will count toward John’s W-2 T 24-month placement time limit because that was John’s last placement in the month that is subject to a 24-month placement time limit.
January will not count toward John’s CSJ 24-month placement time limit.
EXAMPLE 2: Rebecca is placed in a CSJ placement on April 1. On April 4, Rebecca finds unsubsidized employment, is placed in a CMF Case Management Follow-up placement, and remains in that placement through the end of the month.
The month of April will count toward Rebecca’s CSJ 24-month placement time limit because Rebecca participated at least one day in April in a placement that is subject to a 24-month placement time limit.
EXAMPLE 3 : Lucy is placed in a CSJ on June 2. On June 29, Lucy loses W-2 eligibility and her case closes. The month of June will count toward Lucy’s CSJ 24-month placement time limit because Lucy participated at least one day in June in a placement that is subject to a 24-month placement time limit.
2.10.3.1 Restoring 24-Month Time Limits
The 2009-2011 Biennial Budget (2009 Wisconsin Act 28) eliminated the 24-month placement time limit for Trial Jobs, CSJ, and W-2 T employment positions, and, in some instances, CMC placements effective October 30, 2009.
The 2011-2013 Biennial Budget (2011 Wisconsin Act 32) restored the 24-month placement time limit for Trial Jobs, CSJ, W-2 T, and, in some instances, CMC placements effective January 1, 2012. The restored language is the same language that was eliminated under 2009 Wisconsin Act 28.
For a 26-month time period (November 2009 through December 2011), there were no 24-month employment position placement time limits. However, while the 24-month placement time limit was eliminated during this time period, the Department of Children and Families continued to count months that participants accumulated in these W-2 employment positions for both federal and state time limits (as applicable) in WWP and displays this count in the Time Limit Tracking module.
FEP Financial and Employment Planner s must explain to W-2 Wisconsin Works applicants and participants that W-2 Employment Position Community Service Job, Trial Employment Match Program, and W-2 Transition payments are time-limited.
FEPs and participants in paid placements should discuss and create a plan that matches participants’ employment goals, through building skills and training, which line up with opportunities in the local labor market.
At a minimum, the FEP must go over the participant’s time limit status:
At every eligibility review;
At every employability plan review; and
When assigning participants to a new paid placement.
For individuals in the CMD (case management denied) placement, policy requires that the FEP reassess monthly to see if the individual is appropriate for a time limit extension (see 2.10.6.8.1 ).
Time limit information is also included on Notices of Eligibility when eligibility reviews are completed.
The FEP Financial and Employment Planner must adjust an individual's time limit by subtracting the entire month of participation in the Time Limit Tracking application if a:
Participant voluntarily returns the full amount of a CSJ Community Service Job or W-2 T W-2 Transition payment within one year of the payment issuance date. The refund can be made in cash, by personal check, money order, or by returning the issued payment.
If the voluntarily returned payment is from a W-2 Paid Employment Position A Community Service Job or W-2 Transition placement participant who is sanctioned, see 2.10.9.1 for changing the Federal Indicator in the Time Limit Tracking Application.
W-2 Wisconsin Works payment is returned to the agency due to an undeliverable address and the participant does not pick up the check within 30 days.
Participant repays in full payments received from an overpayment caused by agency error or inadvertent participant error. When the entire overpayment is repaid, those months of eligibility must be restored.
See 2.10.9 for cases of IPV Intentional Program Violation , sanctioned participation, or fraud.
TEMP Trial Employment Match Program employer does not request a TEMP subsidy for a month of employment.
There are times when a month of participation will count toward an individual’s 48-month state lifetime limit and 24-month placement time limit, but the FEP must adjust the Federal Indicator so the month does not count toward the federal lifetime limit. (See 2.10.9.1 )
See 2.10.2.3 for adding month of eligibility when TANF Temporary Assistance for Needy Families is received from another state.
There may be opportunities for time limit extensions of the 24-month placement time limits and 48-month state lifetime limits for TEMP Trial Employment Match Program , CSJ Community Service Job , W-2 T W-2 Transition , and CMC Custodial Parent of an Infant participants. The W-2 Wisconsin Works agencies must work intensively with participants prior to and during time limit extension periods to help the participant overcome barriers or challenges.
For information on time limit extensions for CMC participants, see 2.10.8.4 .
W-2 agencies have decision-making authority for all time limit extension approvals and denials.
For the purposes of this section:
"Reasonable unsubsidized employment opportunity" means a job the participant could get that pays at least minimum wage and conforms to all applicable federal and state laws.
Making “all appropriate efforts to find unsubsidized employment” means that the participant has participated in all assigned activities.
All time limit extension decisions must be made on a case-by-case basis.
The W-2 agency must use the placement extension criteria listed in the following table to determine whether a 24-month time limit extension is appropriate.
Placement Extension Criteria Additional Notes TEMP Trial Employment Match Program The Participant has: Made all appropriate efforts to find unsubsidized employment; and Been unable to do so because the local labor market conditions preclude a reasonable unsubsidized employment. opportunity for that participant Since subsidized employment positions in TEMP specifically target high-quality, high-wage opportunities, the likelihood of extending a TEMP placement is typically rare. CSJ Community Service Job The Participant has: Made all appropriate efforts to find unsubsidized employment; and Been unable to do so because the local labor market conditions preclude a reasonable unsubsidized employment opportunity for that participant and, for the same reason, there are no TEMP opportunities available. See 2.10.6.3 for documentation required to approve a 24-month placement time limit extension for local labor market conditions. W-2 T W-2 Transition The Participant has: Made all appropriate efforts to find unsubsidized employment; Significant barriers that prevent participation in other W-2 placements or unsubsidized employment; and Completed a valid formal assessment. See 5.5 for more information on valid formal assessments.
All time limit extension decisions must be made on a case-by-case basis.
To be eligible for a 48-month state lifetime limit extension, a participant must meet at least one of the following 48-month state lifetime limit extension criteria listed in the following table.
Extension Criteria Details Required Documentation The participant has made appropriate efforts to find unsubsidized employment and has been unable to do so because the local labor market conditions preclude a reasonable unsubsidized employment opportunity for that participant. In order to approve a time limit extension based on local labor market conditions, the agency must demonstrate or document any one of the following circumstances: The inability of W-2 participants with similar skills or engaged in job searches in similar geographic and occupational areas, to find unsubsidized jobs; or The unavailability of jobs in labor market sectors that match the individual’s skills or are within a reasonable distance and travel time of the individual’s home, as supported by specific examples of layoffs in these labor market sectors or by labor market data published by the Wisconsin DWD or the US Department of Labor. See 2.10.6.3 for required documentation. The participant is unable to work because of a personal disability or incapacitation. Examples include: Physical health; Mental health; Cognitive limitations; Learning disabilities; Domestic abuse; or Substance abuse. A valid formal assessment must have been completed to approve. The participant is unable to work because they need to remain at home to care for a member of the W-2 Group An adult custodial parent, all dependent children with respect to whom the individual is a legal custodial parent and all minor children with respect to whom the adult individual’s dependent child is a custodial parent. W-2 Group includes any non-marital co-parent or any spouse of the individual who resides in the same household as the individual and any minor children with respect to whom the spouse or non-marital co-parent is a custodial parent. W-2 Group does not include any person who is receiving cash benefits under a county relief block grant program. This is also referred to as the W-2 Assistance Group (W-2 AG) . The W-2 Group member in need of care must have an incapacity so severe that without in-home care provided by the W-2 participant, the health and well-being of the W-2 group member would be significantly affected. A valid formal assessment must have been completed to approve. The participant has significant limitations to employment. Examples include: Limited academic skills; A learning disability; or Serious mental health challenges that impact their ability to obtain or retain unsubsidized employment, but do not meet SSDI or SSI eligibility requirements. A valid formal assessment must have been completed to approve. The participant has significant limitations to employment due to family-related challenges affecting a member of the W-2 Group. Examples include: Legal issues; Family crises; Housing instability; Homelessness; and Responsibilities related to a child’s school or medical needs. See 2.10.6.4 for required documentation. The participant is unable to work to due to current participation in a substance abuse treatment program. The program must be certified to provide treatment for substance abuse under ss. DHS 75.10 to 75.15 or psychosocial rehabilitation services as approved by the department. Additional documentation is not required. The participant’s W-2 group includes a member who has experienced domestic violence or extreme cruelty. This includes, but is not limited to, the use or attempted use of: Physical, sexual, verbal, psychological, economic, or technological abuse; or Any other coercive behavior committed, enabled, or solicited to gain or maintain power and control over a victim. Additional documentation is not required.
A W-2 agency may provide a 24-month placement time limit extension or a 48-month state lifetime limit extension on a case-by-case basis if the agency determines that a participant’s efforts to find unsubsidized employment have been unsuccessful due to the local labor market conditions.
Local Labor Market Time Limit Extension Approvals
In order to approve a time limit extension based on local labor market conditions, the agency must provide documentation or evidence supporting at least one of the following circumstances:
Limited employment outcomes for similar participants:
Specific examples show that other W-2 participants with comparable skills, or who are conducting job searches in similar geographic or occupational areas, are also unable to secure unsubsidized jobs.
Local job market decline in the participant’s field:
Published labor market data, or specific examples such as business closures or workforce reductions, demonstrate a local economic downturn or ongoing lack of available jobs in the labor market sectors that match the participant’s skills.
Lack of accessible job opportunities within a reasonable travel distance:
Published labor market data or specific examples, indicate a continued unavailability of jobs within reasonable participant travel time—defined as no more than 60 minutes travel time one-way, using available transportation, from the participant’s home to the employer, including travel time related to any necessary child care.
Documentation may include:
Case histories of other comparable participants (with any personally identifiable information removed);
Press coverage regarding the local job market or local business conditions;
Agency correspondence with historical or potential placement sites;
Current labor market data obtained from public or private sources; or
Products of current locally relevant labor market studies or research.
If the agency approves an extension based on local labor market conditions, FEP Financial and Employment Planner s should conduct assessments, including Career Assessment A broad spectrum of assessment tools that W-2 agencies, applicants, and participants use to obtain greater awareness about how an individual’s work styles, skills, and interests can be used to define a career path, assign meaningful activities, highlight strengths, identify training needs, and match the individual to employment opportunities s, with the participant and create an EP Employability Plan with assigned activities that focus on training to build skills valuable in the current local labor market.
In order to approve a 48-month state lifetime limit extension for a participant due to family-related challenges affecting the W-2 Group, the agency must have valid documentation.
Valid documentation of family-related challenges must reflect current circumstances. This includes:
Court, medical, criminal, child protective services, social services, psychological, school social worker, school guidance counselor, or law enforcement records regarding legal problems, family crisis, homelessness, children’s school or medical activities, or domestic abuse or physical or emotional harm to the parent or child;
Voluntary disclosure or identification from the Domestic Abuse Screener that the applicant or participant or group member is a survivor of domestic abuse or is at further risk of domestic abuse;
Written and signed statements from others with knowledge of the circumstances on which the family problems hardship claim is based, including, but not limited to, statements from public or private social services agencies providing services to the W-2 group, school counselors, domestic violence or homeless shelter service providers, attorneys, etc.;
Written statement by the applicant or participant; or
Any other supporting documentation, including formal assessments. (See 5.5 for more information on valid formal assessments.)
If the individual does not have a verified barrier, limitation, or family problem as required above or is not participating in all assigned activities, the FEP Financial and Employment Planner may deny a 48-month state lifetime limit extension.
The FEP must have a discussion with the participant about the possibility of a time limit extension no later than the month WWP Wisconsin Work Programs displays:
18 months for the 24-month placement time limit; and
42 months for the 48-month state lifetime limit.
If a person applies for W-2 with more than 18 months on a 24-month placement time limit or 42 months on the 48-month state lifetime limit, the discussion must take place at application.
When determining eligibility for an initial time limit extension, the FEP must:
Complete the W -2 Agency Time Limit Extension Approval Record (5214) or the W-2 Agency Time Limit Extension Denial Record (5215) form that corresponds with the decision;
Provide the participant with a copy of the completed form; and
Scan the completed form into ECF Electronic Case File .
The FEP must enter the time limit extension decision in the Time Limit Tracking module no later than the end of the month WWP displays:
20 months for the 24-month placement time limit; and
44 months for the 48-month state lifetime limit.
Note : This does not apply to applications received after WWP displays 20 months used for the 24-month placement time limit or 44 months used for the 48-month state lifetime limit.
Time limit extensions may be granted for six months from the first calendar day after the participant’s:
24th month for placement time limit extensions; and
48th month for state lifetime limit extensions.
If a participant is denied an extension or declines it, the FEP must continue to work with the participant during the period of time before their W-2 case closes to determine if circumstances have changed which would result in being granted a time limit extension.
After an initial 24-month placement time limit or 48-month state lifetime limit extension approval is granted, the W-2 agency can determine that a subsequent time limit extension period is necessary.
There is no limit to the number of subsequent time limit extensions a participant may receive.
The FEP Financial and Employment Planner must discuss the possibility of subsequent time limit extensions with the participant no later than the third month of the extension.
When determining eligibility for a subsequent time limit extension, the FEP must:
Complete the W-2 Agency Time Limit Extension Approval Record (5214) or the W-2 Agency Time Limit Extension Denial Record (5215) form that corresponds with the decision;
Provide the participant with a copy of the completed form;
Scan the completed form into ECF Electronic Case File ; and
Enter the extension decision into the Time Limit Tracking application no later than the month prior to the current time limit extension end month.
If the agency approves a subsequent extension, a participant’s activity assignment should reflect their assessment results, local labor market information, and anticipated time for the participant to be ready to work or referral to other programs.
The FEP Financial and Employment Planner must determine eligibility for a 48-month state lifetime limit extension rather than a 24-month placement time limit extension if a participant is going to reach either of the following within six months prior to reaching the 48-month state lifetime limit:
Their 24th month in a TEMP Trial Employment Match Program , CSJ Community Service Job , or W-2 T W-2 Transition ; or
The end of a 24-month placement time limit extension.
The FEP must then enter the 48-month state lifetime limit extension into the Time Limit Tracking application before the participant reaches the end of their 24th month or the end of a 24-month placement time limit extension.
EXAMPLE : Mary will reach her 24th month in a CSJ on July 29. While reviewing Mary’s time limit history in preparation for a time limit discussion, her FEP sees that Mary will reach her 48th month of her state lifetime limit on October 31. Because Mary will reach 48 months three months after reaching her 24th month, the FEP determines eligibility for a 48-month state lifetime limit extension and enters the 48-month state lifetime limit extension approval by July 29. This extends both the 24-month placement time limit as well as the 48-month state lifetime limit. Any subsequent time limit extensions will be made to the 48-month state lifetime limit.
The FEP Financial and Employment Planner must complete and submit the WWP Wisconsin Work Programs Informal Assessment Driver Flow if:
An initial 24-month placement time limit or 48-month state lifetime limit extension is going to be denied; and
The WWP Informal Assessment driver flow has not been completed within 12 calendar months prior to the participant’s 24th or 48th month.
The FEP cannot deny a time limit extension until the WWP Informal Assessment Driver Flow is completed and submitted.
If the WWP Informal Assessment indicates the need for a formal assessment, a time limit extension cannot be denied until the formal assessment is complete.
When a participant is denied a time limit extension or the participant declines a time limit extension for either the 24-month placement time limit or 48-month state lifetime limit, the FEP Financial and Employment Planner must offer the CMD Case Management Denied placement.
The CMD placement is a case management placement for individuals who have reached their time limit and are no longer eligible for a paid placement.
The goals of the CMD placement are to:
Help connect the individual to employment;
Connect the individual and family to services in the community; and
Reassess on a monthly basis whether the individual should receive a time limit extension.
To be eligible for the CMD Case Management Denied placement, the participant must meet W-2 Wisconsin Works financial and nonfinancial eligibility criteria, with the exception of exceeding the 24-month placement time limit or 48-month state lifetime limit.
Services provided to a CMD participant will depend largely on the:
Reason for the time limit extension denial or the participant’s decision to decline the extension; and
Participant’s placement at the time of the extension denial or decline.
Participants who were denied a time limit extension due to nonparticipation should be reassessed to determine which activity assignments will best match the participant's needs and help the participant increase participation. These assignments may be similar to those assigned during their W-2 employment position placement.
FEP Financial and Employment Planner s must meet with CMD Case Management Denied participants weekly.
Every 30 days, the FEP must meet with the participant (see 1.4.2.4 ) to review the CMD placement. During the meeting, the FEP must reassess the case to:
Determine whether the participant has consistently participated and reassess whether barriers to employment exist; and
Reconsider whether the individual is appropriate for a time limit extension.
The FEP must thoroughly document in PIN comments the details of the:
Weekly meetings;
30-day reassessment process; and
Reason(s) the participant is going to remain in the CMD placement, if that is the FEP’s decision.
When a participant is approved for a 24-month placement time limit or 48-month state lifetime limit extension, the FEP Financial and Employment Planner must continue to review the participant’s goals as part of ongoing case management and reinforce the objective of fulfilling employment goals within the time limits of the W-2 program. This includes:
Reviewing the EP Employability Plan with the participant frequently to ensure activities are making progress towards the participant’s goals;
Reviewing relevant labor market data to confirm that employment goals are in line with the job opportunities available in the local labor market;
Continuing to conduct informal assessment to determine whether potential barriers to employment exist and referring to formal assessment information as appropriate (see 5.2.1 );
Reviewing whether accommodations would support the participant and if they have the tools and resources needed to succeed at activities (see 1.3.1.2 ); and
Reviewing the Supportive Service Plan to ensure the participant has access to benefits and services which will support them as they work towards their employment goals and provide a plan for addressing needs and ensuring success following exit from the program. (see 9.2.1 )
The W-2 Wisconsin Works agency must process a W-2 application for anyone who requests W-2 services. This includes individuals who have previously reached their 24-month placement time limit or 48-month state lifetime limit.
If the applicant meets W-2 financial and nonfinancial eligibility criteria (as determined by the informal assessment) and has reached the 24-month placement time limit or 48-month state lifetime limit, the FEP Financial and Employment Planner must determine eligibility for a time limit extension at reapplication.
When applying the time limit extension criteria, the FEP must consider the applicant’s prior W-2 participation and current circumstances. If the FEP determines that the applicant does not meet the time limit extension criteria and plans to deny a time limit extension, the FEP must ensure that during previous W-2 participation:
The individual was properly screened and assessed; and
Accommodations and services necessary to address the participant’s barriers were provided.
For applicants who have reached either a 24-month placement time limit or 48-month state lifetime limit and no relevant formal assessment information is available, the FEP must:
Determine the best placement type to assign; and
Offer a time limit extension that allows for completion of any necessary formal assessments needed to support the time limit extension decision.
The CMC Custodial Parent of an Infant placement is for eligible parents with newborns. (See 7.4.5 )
Whether a participant’s time in a CMC placement counts against the 24-month placement time limit, 48-month state lifetime limit, or 60-month federal lifetime limit depends on the participant’s W-2 placement history and the timing of the child’s birth.
Time Limit Type CMC placement months count 24-Month Placement Time Limit Only if the: Child is born more than 10 months (304 days) after the date the individual was first determined eligible for AFDC Aid to Families with Dependent Children or a TEMP Trial Employment Match Program , CSJ Community Service Job , or W-2 T W-2 Transition placement; and Participant moved directly into a CMC from a TEMP, W-2 T, or CSJ placement. 48-Month State Lifetime Limit Only if the child is born more than 10 months (304 days) after the date the individual was first determined eligible for AFDC or a TEMP, CSJ, or W-2 T placement. 60-Month Federal Lifetime Limit Only when there is a W-2 T or CSJ placement immediately preceding the CMC placement.
CMC placement months count toward the 60-month federal lifetime limit only if the payment is considered ongoing cash assistance. The CMC payment is considered ongoing cash assistance when there is a W-2 T or CSJ placement immediately preceding the CMC placement.
CMC placement months do not count toward the federal lifetime limit when:
There is a gap after any previous W-2 Paid Employment Position A Community Service Job or W-2 Transition placement (CSJ or W-2 T) or there is no previous W-2 T or CSJ placement.
The individual moves to the CMC placement directly from a W-2 Wisconsin Works case management, TEMP, or ARP At Risk Pregnancy placement.
EXAMPLE 1 : Lanye was in a W-2 T placement for nine months before having a baby. She then moved directly into the CMC placement. Because she moved directly from a W-2 T placement to a CMC placement, the CMC months will count against the 60-month federal lifetime limit. Since Lanye had the baby less than 10 months after she was first determined eligible for the W-2 T placement, the CMC months will not count towards her 48-month state lifetime limit.
EXAMPLE 2 : Renee has never received W-2 or AFDC in the past. Renee applied for W-2 and was placed in an ARP placement. When Renee had her baby, she moved to a CMC placement. Because Renee has never been determined eligible for AFDC or a TEMP, CSJ, or W-2 T placement, the CMC months will not count toward the 60-month federal lifetime limit.
For more information on the 60-month federal lifetime limit, see 2.10.9 .
CMC placement months count toward the 48-month state lifetime limit only if the child is born more than 10 months (304 days) after the date the individual is first determined eligible for AFDC Aid to Families with Dependent Children or a TEMP Trial Employment Match Program , CSJ Community Service Job , or W-2 T W-2 Transition placement.
The 304-day period must be counted from the first W-2 Employment Position Community Service Job, Trial Employment Match Program, and W-2 Transition placement begin date.
CMC placement months do not count toward the 48-month state lifetime limit when:
The CMC participant’s child is born less than 10 months from the date the individual was first determined eligible for AFDC or a TEMP, CSJ, or W-2 T placement;
Eligibility was determined prior to October 1, 1996; or
The birth was the result of sexual assault or incest and the incest or sexual assault has been reported to a physician and law enforcement authorities.
E XAMPLE 1 : Rochelle was in a W-2 T placement for 24 months before having a baby. She then moved directly into the CMC placement. Because it has been more than 10 months since she was first found eligible for the W-2 T placement, the CMC months will count against the 48-month state lifetime limit.
E XAMPLE 1 : Julie, a former W-2 participant, has a child, applies for W-2, and is found eligible for CMC. She was first determined eligible for a CSJ two years prior to her current application. Therefore, the months in CMC will count against the 48-month state lifetime limit because her baby was born more than 10 months after she was first determined eligible for a CSJ.
2.10.8.3 24-Month Placement Time Limit
CMC placement months count toward a 24-month placement time limit only if the:
Child is born more than 10 months (304 days) after the date the individual is first determined eligible for AFDC Aid to Families with Dependent Children or a TEMP Trial Employment Match Program , CSJ Community Service Job , or W-2 T W-2 Transition placement; and
Participant moved directly into a CMC from a TEMP, W-2 T, or CSJ placement.
The 304-day period must be counted from the first employment position placement begin date.
Months will count against the 24-month placement time limit of the employment position placement from which they moved. The participant will be in a CMC placement, but the 24-month placement time limit months used will reflect their previous employment position.
E XAMPLE 1 : Matilda was in a CSJ placement for 24 months before having a baby. She then moved directly from the CSJ placement to the CMC placement. Because she moved directly from a paid employment position placement to a CMC placement, the CMC months will count toward the CSJ 24-month placement time limit.
E XAMPLE 2 : Latashia was in a CSJ placement, for one year and left the W-2 program. Two years later, she applies for W-2 and is placed directly in a CMC placement. Because Latashia did not move directly from a TEMP, W-2 T, or CSJ placement to the CMC placement, the CMC months will not count toward a 24-month placement time limit.
2.10.8.4 CMC Participant Time Limit Extensions
CMC participants are automatically eligible for the 24-month placement time limit and 48-month state lifetime limit extensions.
The FEP must enter a time limit extension covering the time until the child turns 8 weeks of age and review the CMC case prior to the end of the eight-week CMC time period, to determine if the CMC participant wants and is eligible for continued W-2 services.
If the participant would like additional W-2 services or cash assistance after the child turns 8 weeks of age, the FEP must follow normal eligibility determination policies, including time limit extension eligibility, if necessary.
Federal law allows states to establish their own lifetime limit for federal TANF Temporary Assistance for Needy Families cash assistance of up to 60 months. Wisconsin has established a 48-month lifetime limit for federal TANF cash assistance; however, the lifetime limit varies by state.
Regardless of which state federal TANF assistance is received, it is counted as part of the 60-month federal lifetime limit and Wisconsin’s 48-month lifetime limit.
Wisconsin calculates state and federal time limits differently. Not all months that count towards the 48-month state lifetime limit will also count toward the 60-month federal lifetime limit, and vice versa. For example, certain CMC Custodial Parent of an Infant placement months may only count toward the federal lifetime limit. (See 2.10.8 )
Only months of assistance that are paid for with Federal TANF funds (in whole or in part) count toward the federal lifetime limit. (See 9.4.3 )
A month counts towards the 60-month federal lifetime limit if the individual:
Receives an actual payment of $1 or more through participation in a CSJ Community Service Job or W-2 T W-2 Transition placement. (See 2.10.2.1 ) Months where the full payment was sanctioned to $0 prior to W-2 pulldown do not count towards the federal lifetime limit.
Note : If the placement on the last working day of the month is a TEMP Trial Employment Match Program placement ( TMP Custodial Parent Trial Employment Match Program or TNP Noncustodial Parent Trial Employment Match Program ), and there was a payment of $1 or more for a CSJ or W-2 T placement in the same calendar month, the month will also count toward the individual’s 60-month federal lifetime limit due to receipt of federally funded TANF cash assistance.
Months where a delayed payment is received count towards the month for which there was participation.
Receives a CMC payment and a W-2 T or CSJ placement immediately preceded the CMC placement. (See 2.10.8 for more information on time limits for CMC placements)
Receives transportation assistance while in an unpaid, case management only placement and certain conditions are met. (See 9.4.3 )
Received TANF cash assistance in any other state. (See 2.10.2.3.1 )
Is a parent in the W-2 Group An adult custodial parent, all dependent children with respect to whom the individual is a legal custodial parent and all minor children with respect to whom the adult individual’s dependent child is a custodial parent. W-2 Group includes any non-marital co-parent or any spouse of the individual who resides in the same household as the individual and any minor children with respect to whom the spouse or non-marital co-parent is a custodial parent. W-2 Group does not include any person who is receiving cash benefits under a county relief block grant program. This is also referred to as the W-2 Assistance Group (W-2 AG) and is married to the placed parent who receives an actual CSJ or W-2 T payment of $1 or more. Months do not count toward the 60-month federal lifetime limit if the individual is a Non-marital Co-parent With respect to an individual and a dependent child, a parent who is not married to the child’s other parent and is either an adjudicated parent or a parent who has signed and filed with the state registrar under s.69.15(3)(b)3, Stats., a statement acknowledging paternity and is not the parent in a W-2 placement during a month.
The individual is exempt from having months count towards the federal lifetime limit if the individual:
Is a qualified non-citizen or the placed parent in the W-2 Group is a qualified non-citizen. (See 2.4.2 )
W-2 payments made to qualified non-citizens are paid through state funds, not federal TANF funds; therefore, those months do not count towards the federal lifetime limit.
Lives or has lived on a federally recognized American Indian reservation, an Alaskan Native village, or an Indian country occupied by an Indian tribe during a month where at least 50% of the adults were not employed. (See 2.10.2.2 )
Received a $50 supplemental payment through participation in a CMF+ placement. Supplemental payments made to CMF+ participants are paid through state funds, not federal TANF funds; therefore, those months do not count towards the federal lifetime limit.
EXAMPLE 1 : Judy and Joan are married and have adopted a child. Judy is participating in a CSJ placement. For every month that Judy receives a payment for her CSJ participation, Joan also uses a month that counts toward both the federal 60-month limit and state 48-month lifetime limits.
EXAMPLE 2 : Melissa and Keith live together as Non-marital Co-parents and have two children. Melissa is in a W-2 T placement. For each month that Melissa receives a payment for her W-2 T participation, Keith will also uses a month that only counts toward the state 48-month lifetime limit. Because Keith is not married to Melissa, his months do not count towards his federal 60-month lifetime limit.
EXAMPLE 3 : A hmed and Julienne are married and have one child. Ahmed is a qualified non-citizen and is participating in a CSJ placement. Julienne is a U.S. citizen. For each month Ahmed participates in a CSJ placement, Julienne also uses a month which only counts toward the state 48-month lifetime limit. Because Ahmed is a qualified non-citizen and his CSJ payment is paid through state funds and not federal TANF funds, these months do not count towards Ahmed or Julienne’s federal time limits. If Julienne became the placed parent, those months would count towards her federal time limit, but they would not count towards Ahmed’s time limit because he is a qualified non-citizen.
EXAMPLE 4 : Hilda applies for W-2 on May 22. Her FEP places her in a W-2 T placement starting May 25. Hilda will receive a delayed payment in June for her May participation. In the Time Limit Tracking module, Hilda will use a W-2 T month for May and the month used will count toward both the state 48-month lifetime limit and federal 60-month lifetime limits based on her participation from May 25 to May 31.
The number of months for which an individual receives a TANF Temporary Assistance for Needy Families payment must equal the number of federal months used. If a discrepancy exists between payments received and federal lifetime months, the FEP, or the FEP Financial and Employment Planner ’s supervisor, must adjust the individual’s 60-month federal time limit by changing the Federal Indicator for the month of participation in the WWP Wisconsin Work Programs Time Limit Tracking application from “Yes” to “No” in the following situations:
An individual in a W-2 employment position voluntarily returns in full a payment that was sanctioned due to nonparticipation.
An individual repays in full an overpayment for W-2 payments they should not have received due to: Intentional Program Violation (IPV); Sanctioned participation that was not entered in a timely manner by the W-2 agency; or Fraud.
A system error in the Time Limit Tracking application caused an individual who meets the exemptions listed above to incorrectly use a month of their 60-month federal lifetime limit.
By updating the Federal Indicator, the month will still count towards an individual’s state and placement limit, if applicable, but will not count towards the federal 60-month lifetime limit.
For information on subtracting entire months of eligibility, see 2.10.5 .
A W-2 Wisconsin Works participant who is receiving RSUD Residential Substance Use Disorder treatment may remain eligible for W-2 if the participant is able to participate in activities and retain care and control of their children, provided they remain otherwise financially and nonfinancially eligible.
All applicants must meet both nonfinancial and financial eligibility criteria to be considered eligible for W-2 services or a JAL.
There are two exceptions:
Minor Parent A custodial parent under the age of 18. For Learnfare, a minor parent is either a custodial or a noncustodial parent under the age of 18. s Minor parents are eligible for case management services regardless of income or assets.
CMF Case Management Follow-Up or CMF+ Case Management Follow-Up Plus placements Participants in a CMF or CMF+ placement do not have to meet the financial eligibility requirements to be eligible for ongoing case management services.
W-2 financial eligibility is determined by both a gross income test and an asset test.
When testing prospectively for income and assets (see 3.2.2.1 ), the FEP must not combine months of income ineligibility and months of asset ineligibility to create two consecutive calendar months of financial ineligibility.
EXAMPLE:
February:
While participating in a CSJ Community Service Job , Judy receives $5,000 as a legal settlement on February 11 and reports this to her FEP on February 12.
Judy’s FEP enters the initial settlement as income in February and uses the bank statement Judy provides as verification.
March:
At Judy’s next appointment on March 15, Judy indicates that she spent $2,200 of the settlement in February and plans to spend the remainder in March.
Judy’s FEP enters the remaining $2,700 as an asset in March.
April:
Judy confirms on April 6 that she spent the remainder of the settlement and provides another bank statement as verification.
Judy is again under the income and asset limits for W-2 and remains eligible for her CSJ placement as she didn’t exceed either the income or asset limits for two consecutive months.
Month Event Income Limit Asset Limit Eligibility Status February Judy receives a legal settlement of $5,000 Over Under Eligible March Judy spends $2,200 of the settlement and has $2,700 remaining Under Over Eligible April Judy confirms the settlement was spent Under Under Eligible
If the total countable income (see 3.2.7 ) of the W-2 Group An adult custodial parent, all dependent children with respect to whom the individual is a legal custodial parent and all minor children with respect to whom the adult individual’s dependent child is a custodial parent. W-2 Group includes any non-marital co-parent or any spouse of the individual who resides in the same household as the individual and any minor children with respect to whom the spouse or non-marital co-parent is a custodial parent. W-2 Group does not include any person who is receiving cash benefits under a county relief block grant program. This is also referred to as the W-2 Assistance Group (W-2 AG) at application is less than or equal to 115% of the FPL Federal Poverty Level for the size of the W-2 Group, the group may be considered for all W-2 services or a JAL Job Access Loan .
See 3.2.8 for income that is disregarded.
The FPL changes in February of each year. These figures were effective February 1, 2026.
W-2 Group Size Annual 115% FPL Monthly 115% FPL 1 $18,360 $1,530 2 $24,888 $2,074 3 $31,416 $2,618 4 $37,956 $3,168 5 $44,484 $3,707 6 $51,012 $4,251 7 $57,552 $4,796 8 $64,080 $5,340 9 $70,608 $5,884 10 $77,148 $6,429 11 $83,676 $6,973 12 $90,204 $7,517 13 $96,744 $8,062 14 $103,272 $8,606 15 $109,800 $9,150 16 $116,340 $9,695 17 $122,868 $10,239 18 $129,396 $10,783 Each Additional Person Add $544
EXAMPLE : Jonathan applied for W-2 on May 5. Jonathan has a family size of three. The monthly 115% gross income limit for his family size is $2,618. At the time of application, his total income equaled $2,550 per month. Jonathan tells his worker that his $250 Unemployment Insurance will end effective June 30. In this example, Jonathan is financially ineligible for W-2 for both May and June and, unless Jonathan's income drops for some other reason, he would not be eligible for W-2 until July.
Available earned and unearned income is tested prospectively for W-2 Wisconsin Works eligibility. Prospective Income testing uses the best estimate of income and circumstances to determine what income will be received by the W-2 group each month.
To determine the best estimate of monthly earned income for individuals paid an hourly rate, and unearned income for the W-2 Group, a FEP Financial and Employment Planner must use the following table:
Payment Frequency Calculation If paid weekly Earned : (hourly rate) x (average hours per week) x (4.3 weeks per month) Unearned : (weekly amount) x (4.3 weeks per month) If paid biweekly Earned : (hourly rate) x (average hours biweekly) x (2.15 weeks per month) Unearned : (biweekly amount) x (2.15 weeks per month) If paid monthly Earned and Unearned : monthly amount (this includes self-employment and other averaged income) If paid twice monthly Earned and Unearned : (amount) x (2 times per month)
The FEP must not adjust the prospective income estimate due to missed work or an irregular increase in work hours. A W-2 Group must be prospectively ineligible for two consecutive months before the case closes.
The W-2 Group’s income affects eligibility only and does not affect the amount of the W-2 payment. The payment amount is determined solely by the employment position in which the adult is participating.
The FEP may only count income that is actually available for use by the applicant or participant.
Income is available when: the individual has a legal interest in it and has the legal ability to make it available for support and maintenance.
Income is considered unavailable when: the individual can reasonably document that it cannot be accessed for 31 or more days.
Unavailability may be documented through various methods including a letter from the source stating when the person will receive the income. Income is counted beginning in the first month it is received and thereafter. Income must not be counted until the amount and the payment date are known.
E XAMPLE: Kate has won a lawsuit filed on her behalf due to a car accident. Under the terms of the settlement, Kate will receive monthly payments for up to ten years. Kate has not yet received the first payment of the insurance settlement and she is not sure at this time when she will because the settlement was appealed by the insurance company. This income must not be counted until Kate knows when she will begin receiving the insurance settlement or when she actually begins to receive it, whichever is first.
A payment received must not be counted as an asset and income in the same month. (See 3.3.1 ) Current payments must be counted as income in the month received. Any amount remaining becomes an asset in the following months.
When income amounts vary, the W-2 Wisconsin Works agency must use an average. Irregular income must also be averaged over the period between payments. When the income amount or the frequency is inconsistent or unpredictable, the income may only be counted for the month in which it is received.
E X AMPLE: Bob applied for W-2 services and reports that he works for a local garage between 5 and 20 hours per month. In January, he received a paycheck for $169, in February he received $200, and in March he received $80. To create an average income amount, add together the three months of income (169 + 200 + 80 = 449), then divide the total income by the number of months (449/3 = $149.66). Compare the averaged income amount of $149.66 plus other sources of income against the 115 percent gross income test (See 3.2.1 ) to determine financial eligibility.
Lump sum payments are one-time payments of either earned or unearned income.
Some lump sum payments are intended to cover a specific period of time that extends to a future month, such as settlement income related to a specific injury. Some lump sum payments are intended to cover a specific period of time in the past, such as an Unemployment Insurance benefit back payment.
Unless it is disregarded income (See 3.2.8 ), lump sum income must be counted as follows.
Income received on a yearly basis or less often should be converted to a monthly amount. The agency should count only income that is predictable in amount and frequency, such as land contract income or income from a trust fund. Count the prorated income beginning in the month it is received.
EXAMPLE: Joan receives $900 every six months on a land contract. To create an average monthly amount, divide $900 by six months (900/6 = $150). Compare the averaged monthly amount of $150 plus any other sources of income against the 115 percent gross income test to determine financial eligibility.
If the lump sum payment is not intended to cover a specific period of time in the future or is intended to cover a period of time in the past, the income may only be counted as income for the month in which it is received and an asset for the following months. (See 3.2.3 )
E XAMPLE 1 : Ariana inherits $5,000 from her grandmother on February 16. Ariana receives a one-time check for the inheritance. Ariana’s FEP should count this as income for February, and as an asset for any month thereafter that Ariana keeps the inheritance balance in her account.
E XAMPLE 2 : While participating in a CSJ placement, Leslie received a retroactive $3,000 lump sum unemployment insurance payment on December 11, 2020.This lump sum provides payments retroactive for the week ending July 18, 2020 through the week ending November 7, 2020. Leslie’s FEP should count the lump sum as income for December, and as an asset for any month thereafter. The agency must not prorate this retroactive payment, because it is intended to cover a time period in the past and was not available to Leslie during the claimed months.
If the lump sum payment is intended to cover a specific period of time that extends to a future month, the income must be prorated over the period the income is intended to cover beginning in the month it is received.
EXAMPLE 3 : While participating in a W-2 T W-2 Transition placement, John wins a lawsuit settlement of $6,000 on November 18. The settlement states that the payment is intended to support John’s medical costs over the next six months in order to help him recover from an injury incurred while shopping at a local store. John’s FEP should average the $6,000 over six months, starting when John receives the payment in November.
Types of Contractual Income Proration Method Annual income (intended to provide support for the entire year) not paid on an hourly basis Must be prorated over 12 months. Non-Annual income (intended to provide support for only a portion of the year), not paid on an hourly basis Must be prorated over the period the income is intended to cover.
Contractual income that is paid on an hourly basis should be estimated in accordance with 3.2.2.
EXAMPLE 1 : Shanice works full-time at a public school as a Teacher’s Aide. She has worked in this position for the last 3 years and receives a 12 month contract every August. She earns $15,480 annually and has elected to receive her income over 12 months, even though she is only working September through June. She does not supplement her income during the summer. Shanice's FEP should average her income over 12 months: $15,480/12 =$1,290.
EXAMPLE 2 : Betty has worked for 5 years at a public school as a part-time nurse. She receives a contract for 12 months every August and has elected to receive her income from September through June. She earns $19,500 per school year. In the summer, she supplements her income with a job at the Girl Scout campgrounds in the first aid tent. Betty’s school income is not her annual income. Betty’s FEP should average Betty’s school income over the 10 months she has elected to receive it: $19,500/10 = $1,950.
EXAMPLE 3 : Tamika has been employed as a school bus driver for 3 years. She is paid by the hour. This employment stops at the end of the school year and resumes at the beginning of the next school year. Since Tamika is paid on an hourly basis, the income from her bus driving job must not be treated as contractual income.
Once determined eligible for W-2 Wisconsin Works , if the W-2 Group An adult custodial parent, all dependent children with respect to whom the individual is a legal custodial parent and all minor children with respect to whom the adult individual’s dependent child is a custodial parent. W-2 Group includes any non-marital co-parent or any spouse of the individual who resides in the same household as the individual and any minor children with respect to whom the spouse or non-marital co-parent is a custodial parent. W-2 Group does not include any person who is receiving cash benefits under a county relief block grant program. This is also referred to as the W-2 Assistance Group (W-2 AG) has an income amount expected to exceed the 115 percent gross income limit (See 3.2.1 ) for at least two consecutive months, the group becomes ineligible for W-2.
Participants must report any change in earned or unearned income within 10 calendar days of the occurrence. The FEP Financial and Employment Planner must redetermine the best estimate (See 3.2.2 ) for all income at each review, and when any change in the income’s source, rate of pay, or payment schedule has been reported.
Overpayment claims must be established only for untimely reports of changes.
All W-2 Group members’ earned and unearned income is counted in determining the 115 percent gross income test (See 3.2.1 ) unless specifically disregarded in 3.2.8.1 .
Count non-regular collections of arrears as an asset. (See 3.3.1 )
Any adult’s SSI Supplemental Security Income and/or CTS Caretaker Supplement payments must be counted as the SSI parent’s income.
Children’s SSI payments must not be counted in the W-2 Group’s income. (See 3.2.8.1 )
Retroactive CTS payments must be counted as income in the month it was received. Any amount of the payment remaining must be counted as an asset in the following month.
Income from temporary employment must be counted in determining W-2 financial eligibility. Examples of temporary employment includes but is not limited to:
Seasonal landscaper;
Delivery driver;
Substitute teacher;
Construction worker;
Nursing assistant, etc.
Self-employment income is earned directly from one's own business rather than as an employee with a specified salary from an employer. Self-employment income is reported to the IRS as:
Farm;
Self-employment;
Rental; or
Royalty income.
All self-employment income is earned income, except royalty income and rental income where the individual does not actively manage the property 20 or more hours a week.
The FEP must identify a self-employment business using the following criteria:
By IRS Tax Forms
By Organization Self-employment income can come from a business organized in one of three ways: A sole proprietorship is an unincorporated business owned by one person. A partnership exists when two or more persons conduct business. Each contributes money, property, labor, or skills, and expects to share in the profits and losses. Partnerships are unincorporated. An S corporation is a business that elects to pass corporate income, losses, and deductions through its shareholders. Shareholders report income and losses on their personal tax returns and are taxed at individual income tax rates.
By Employee Status Does not have federal income tax and FICA payments withheld from a paycheck. Does not complete a W-4 for an employer. Is not covered by employer liability insurance or worker's compensation. Is responsible for their own work schedule.
Any wages or salary that an individual receives from a corporation owned by another W-2 group member shall be considered wages from employment and not self-employment income.
The W-2 agency must count the gross receipts from farm and self-employment businesses. Gross receipts must not be adjusted based on expenses. Monthly farm and self-employment income must be calculated using:
IRS tax forms completed for the previous year; or
Average monthly anticipated earnings using the S elf-Employment Income Report (DHS 00107) .
Calculate self-employment income based on anticipated gross earnings using the Self-Employment Income Report Form (SEIRF) when:
The business was not in operation for at least one full month in the prior tax year;
The business has not been in operation for six or more months at the time of the application; or
There was a significant change in circumstances and the taxes no longer represent the current earnings.
FEPs must ensure the change is significant, and not just a normal fluctuation in the business, seasonal employment, or a circumstance that does not affect income over time. Examples of a significant change in circumstances include, but are not limited to:
The start of a business.
The owner sold a part or all of their business.
The owner is ill or injured and will be unable to operate the business.
There's a substantial cost increase causing less profit for each unit sold.
Sales are consistently below previous levels beyond normal sales fluctuations.
The business is consistently earning above previous levels beyond normal fluctuations.
Lawful permanent residents (LPRs) may be required by United States Citizenship and Immigration Services (USCIS) The federal agency that oversees lawful immigration of foreign nationals who are temporarily or permanently settling in the U.S. See also INS. to have a sponsor sign an affidavit of support to ensure the immigrant does not become a public charge. LPRs that have income available to them from their Sponsor A sponsor is a person who, or any public or private agency or organization that, executes an affidavit of support or similar agreement for an alien to ensure the alien does not become a public charge. The agreement is a condition of the alien’s entry into the U.S. , must have that income counted when determining W-2 financial eligibility.
Some non-citizens have both an agency sponsor and an individual sponsor such as a church or family member. These “sponsors” do not meet the USCIS definition of a sponsor if they have no legal obligation to provide financial support beyond the LPRs first month in the United States, and they do not have to ensure the LPR does not become a public charge.
Disregard sponsor’s income for the following groups:
Non-citizens granted asylum (asylees) under section 208 of the Immigration and Nationality Act (INA) Immigration and Nationality Act (INA)- The basic body of immigration law in the United States, which was created in 1952 and has been amended many times. The INA is a free-standing law, but is also contained in the U.S. Code. ;
Refugees who are admitted to the United States under section 207 of the INA;
Non-citizens paroled into the United States (parolees) under section 212(d)(5) the INA for a period of at least one year;
Non-citizens whose deportation is being withheld under section 243(h) of the INA;
Amerasian Immigrants, as defined in section 584 of the Foreign Operations, Export Financing, and Related Programs Appropriations Act of 1988; and
Cuban-Haitian entrants.
All earned and unearned income of all the W-2 Group An adult custodial parent, all dependent children with respect to whom the individual is a legal custodial parent and all minor children with respect to whom the adult individual’s dependent child is a custodial parent. W-2 Group includes any non-marital co-parent or any spouse of the individual who resides in the same household as the individual and any minor children with respect to whom the spouse or non-marital co-parent is a custodial parent. W-2 Group does not include any person who is receiving cash benefits under a county relief block grant program. This is also referred to as the W-2 Assistance Group (W-2 AG) members is counted in determining the 115 percent gross income test (See 3.2.1 ) with the exception of the income listed in this section. Income listed in this section is disregarded either in whole or under limited circumstances.
The agency must disregard the following income in determining the 115 percent gross income test:
Child Support Income : Regular collections of current child support, maintenance payments, family support (combination of child support and maintenance) or regular collections of child support arrears.
Tax Refunds : The agency must disregard as income the entire amount of any federal income tax refund in the month received. This includes federal tax refunds that result from federal over-withholding and from tax credits. Agencies must also disregard as income the portion of a state tax refund resulting from the state EITC in the month received. (See 3.3.4 )
Loans and JAL Job Access Loan s : Any loan unless available for current living expenses. If available for current living expenses, loans must be counted as assets even if there is a repayment schedule. JALs must be disregarded.
Reverse Mortgage Loan Proceeds (1993 Wisconsin Act 88): Payments made to a borrower must be treated as proceeds from a loan and not as income. Undisbursed funds must be treated as equity in a borrower’s residence and not as proceeds from a loan.
W-2 Placements : Payments from these placements: W-2 TEMP Trial Employment Match Program ( TMP Custodial Parent Trial Employment Match Position , TNP Noncustodial Parent Trial Employment Match Position ), CMF+ Case Management Follow-Up Plus , TSP Stipends for Noncustodial Parents , CSJ Community Service Jobs , W-2 T W-2 Transition , ARP At Risk Pregnancy , and CMC Custodial Parent of an Infant .
Jail or Prison Income : Income earned while incarcerated from a jail or prison job. Note : this does not include income earned while participating in the Huber Program.
In-Kind Income : Any gain or benefit that is not in the form of money paid directly to the household such as, meals, clothing, housing, and garden produce.
Vendor Payments : Vendor Payment Payment made on behalf of the household by a third party to another source s, such as rent paid by a community organization on the household’s behalf.
Kinship Care : Kinship Care payment for the needs of a non-legally responsible relative child who is not included in the W-2 Group.
Foster Care : Foster Care payments for the needs of a foster child who is not included in the W-2 Group.
Earned Income and SSI Supplemental Security Income payments of a Dependent Child : Income earned by a Dependent Child A person who resides with a parent and who is under the age of 18 or, if the person is a full-time student at a secondary school or a vocational or technical equivalent and is reasonably expected to complete the program before attaining the age of 19, is under the age of 19 in a W-2 Group, and any SSI payments the dependent child receives.
Federally Funded Benefits : Any income or resources distributed under the following federal laws are disregarded: Agent Orange Settlement Fund: Payments received from the Agent Orange Settlement Fund or any other fund established in settling "In Re Agent Orange product liability Settlement Fund litigation MDL No. 381 (EDNY)". Apply this disregard retroactively to January 1, 1989, and continue to disregard as long as payments are identified separately. Radiation Exposure Compensation Act: Payments from any program under the Radiation Exposure Compensation Act (PL 101-426) paid to compensate injury or death resulting from exposure to radiation from nuclear testing ($50,000) and uranium mining ($100,000). Apply this disregard retroactively to October 15, 1990. Continue to disregard as long as payments are identified separately. Nazi Persecution Victims: Payments under PL 103-286 to victims of Nazi persecution. Benefits for Children of Vietnam Veterans Who Are Born with Spina Bifida: Payments under PL 104-204 paid to any child of a Vietnam veteran for any disability resulting from spina bifida. Benefits for Children of Vietnam Veterans Born with Birth Defects other than Spina Bifida: Payments received under PL 106-419 for children with birth related disabilities other than spina bifida who were born to women veterans that served in Vietnam during the period February 28, 1961 to May 7, 1975. Crime Victims Fund: Any amount of crime victims compensation received under section 1403 of the Victims Crime Act of 1984 (42 U.S.C. 10602). Benefits include, but are not limited to, those paid under the: Antiterrorism and Effective Death Penalty Act of 1996. Crime Victims Compensation Program (Chapter 950, Wis. Stat.) National Flood Insurance Program: Payments under PL 109-64 provided for flood mitigation activities with respect to a property. Medicare Prescription Drug, Improvement and Modernization Act: Drug subsidies and drug discounts received as a benefit under this law. Nutrition Program Benefits : National School Lunch Act (PL 79-396) Food Stamp Act of 1977 (PL 88-525) Child Nutrition Act of 1966 (PL 89-642). This program includes WIC Women, Infants and Children . Tribal Settlements : Indian Tribes; Sub-marginal Lands (PL 94-114) Disbursement of Minor’s Share of Judgment Funds (PL 95-433) Lands Held in Trust for the Benefit and Use of the Pueblo of Santa Ana (PL 95-498) Lands Held in Trust for the Benefit and Use of the Pueblo of Zia (PL 95-499) Shoalwater Bay Indian Tribe, Dexter-by-the-Sea Claim Settlement Act (PL 98-432) Chippewas of Lake Superior (PL 99-146) Saginaw Chippewa Indian Tribe of Michigan Distribution of Judgment Funds (PL 99-346) Chippewas of the Mississippi (PL 99-377) Michigan Indian Land Claims Settlement Act (PL 105-143) Section 707, Title VII Miccosukee Settlement (PL 105-83) Mississippi Sioux Tribes Judgment Fund Distribution Act of 1998 (PL 105-387) Claims Resolution Act of 2010 (PL 111-291): All proceeds received from the Cobell v. Salazar Class Action Trust Case settlement under this act must be disregarded as income in the month received and as a countable asset for one year from the date of receipt. Miscellaneous Federal Benefits : Housing Act of 1949 (PL 81-171) Older Americans Act (PL 89-73), including Title V - Community Service Employment for Older Americans Uniform Relocation Assistance and Real Property Acquisition Policies Act of 1970 (PL 91-646) Robert T. Stafford Disaster Relief and Emergency Act (PL 93-288) Housing and Community Development Amendments of 1978 (PL 95-557); however, wages from the act may be counted as income. Low Income Energy Assistance Act of 1981 (PL 97-35) Old Age Assistance Claims Settlement Act (PL 98-500) Workforce Innovation and Opportunity Act (PL 113-128) Program of Initial Resettlement (PIR) grant cash income (45 CFR 400.66) Pandemic Emergency Assistance Funds established by the American Rescue Plan Act of 2021 (Including the Living Independently through Financial Empowerment (LIFE) Program) (PL 117-2) Payments from the Chafee Program for Successful Transition to Adulthood for youth who aged out of foster care.
Educational Aid : The following educational aid or resources are disregarded: Scholarships for tuition and books: Scholarships received for tuition and books, including scholarships from public or private organizations. Student Financial Aid: Any student financial aid received under any state program or federal program. This includes the following aid received under the Higher Education Act of 1965 (PL 89-329). Basic Educational Opportunity Grants (BEOG or PELL grants) Presidential Access Scholarships (Super PELL grants) Supplemental Educational Opportunity Grants (SEOG) State Student Incentives Grants (SSIG) Federal Direct Student Loan Program (Formerly GSL and FFELP) Supplemental loans for students Robert T. Stafford Student Loans PLUS loans for parents Federal Consolidated Loan Program Federal Work Study Funds TRIO Grants (disadvantaged youth grants) Upward Bound Student Support Services Robert E. McNair Post-Baccalaureate Achievement Robert C. Byrd Honors Scholarship Program College Assistance Migrant Program (CAMP) High School Equivalency Program (HEP) National Early Intervention Scholarship and Partnership Program Montgomery GI Bill for Active Military, Reserve Military and Veterans Veteran’s Education Assistance Program (VEAP) Carl Perkins Loans (formerly NDSL) Indian Vocational Education Program Native Hawaiian Vocational Education Program State Vocational and Applied Technology Programs which include: State Program and State Leadership Activities Displaced Homemakers, Single Parent, and Single Pregnant Women programs Sex Equity Program Programs for Criminal Offenders Secondary School Vocational Education Program Postsecondary and Adult Vocational Education Program State Assistance for Vocational Education Support Programs by Community Based Organizations Consumer and Homemaking Education Program Comprehensive Career Guidance and Counseling Program Business-Labor-Education Partnership for Training Program National Tech-Prep Education Program State-administered Tech-Prep Education Program Supplementary State Grants for Facilities and Equipment and Other Program Improvement Activities Community Education Employment Centers Program Vocational Education Lighthouse Schools Program Tribally Controlled Post-secondary Vocational Institutions Program Vocational Education Research Program National Network for Curriculum Coordination in Vocational and Technical Education National Center or Centers for Research in Vocational Education Materials Development in Telecommunications Programs Demonstration Centers for the Training of Dislocated Workers Program Vocational Education Training and Study Grants Program Vocational Education Leadership Development Awards Program Vocational Educator Training Fellowships Program Internships for Gifted and Talented Vocational Education Students Program Business and Education Standards Program Blue Ribbon Vocational Education Program Educational Programs for Federal Correctional Institutions Vocational Education Dropout Prevention Program Model Programs of Regional Training for Skilled Trades Demonstration Projects for the Integration of Vocational and Academic Learning Program Cooperative Demonstration Programs Bilingual Vocational Training Program Bilingual Vocational Instructor Training Program Bilingual Materials, Methods, and Techniques Program
Gifts : The agency must disregard as income the entire amount of the gift. A gift is: Received unconditionally, without a purpose specified for the use of the money; Not received due to legal obligation; and Not received as repayment for goods or services.
Some income may be disregarded under limited circumstances:
AmeriCorp VISTA: Disregard AmeriCorps VISTA Volunteers in Service to America income unless the VISTA agency director verifies that volunteers are receiving the equivalent of minimum wage. If the VISTA volunteer is receiving minimum wage or more, count the VISTA income in determining gross income.
Operation Fresh Start: Disregard Operation Fresh Start income unless the agency director verifies that participants are receiving the equivalent of minimum wage. If the Operation Fresh Start participant is receiving minimum wage or more, count the income in determining gross income.
Indian Tribal Judgment Funds Use or Distribution Act (PL 93-134): Disregard per capita shares and income of $2,000 per year or less.
Rehabilitation Act of 1973 (PL 93-112): Disregard wages, allowances, or reimbursements for transportation or personal assistance services costs paid to reasonably accommodate an employee, such as a vehicle modification made to accommodate a disability or a payment by DVR Division of Vocational Rehabilitation to support a rehabilitation plan.
If the total countable assets of the W-2 Group An adult custodial parent, all dependent children with respect to whom the individual is a legal custodial parent and all minor children with respect to whom the adult individual’s dependent child is a custodial parent. W-2 Group includes any non-marital co-parent or any spouse of the individual who resides in the same household as the individual and any minor children with respect to whom the spouse or non-marital co-parent is a custodial parent. W-2 Group does not include any person who is receiving cash benefits under a county relief block grant program. This is also referred to as the W-2 Assistance Group (W-2 AG) at application are equal to or less than $2,500 in combined Equity Value The wholesale value or a value estimated by a sales representative at a local business minus any encumbrances that are legal debts. , the group may be considered for all W-2 services or a JAL Job Access Loan .
Only assets that are actually available for use may be counted.
An asset is available : if the person has a legal interest in it and has the legal ability to make it available for support and maintenance.
An asset is unavailable : when the individual can reasonably document that it cannot be accessed for 31 or more days.
A payment may not be counted as an asset and income in the same month. Count income in the month received and any amount remaining as an asset in the following months.
Crowdfunding payments must be counted as an asset in CARES Worker Web (CWW) as soon as funds are generated and available in the crowdfunding account, unless the individual can reasonably document that it cannot be accessed for 31 or more days.
Equal shares of jointly held accounts and property should be deemed available to each person whose name is listed as an owner.
Once eligible for W-2 Wisconsin Works , if the W-2 Group An adult custodial parent, all dependent children with respect to whom the individual is a legal custodial parent and all minor children with respect to whom the adult individual’s dependent child is a custodial parent. W-2 Group includes any non-marital co-parent or any spouse of the individual who resides in the same household as the individual and any minor children with respect to whom the spouse or non-marital co-parent is a custodial parent. W-2 Group does not include any person who is receiving cash benefits under a county relief block grant program. This is also referred to as the W-2 Assistance Group (W-2 AG) ’s assets are expected to exceed $2,500 for at least two consecutive months, the group becomes ineligible for W-2. Participants must report any change in assets within 10 calendar days of the occurrence.
The FEP Financial and Employment Planner must enter only changes in assets over $100 when notified. At review, the FEP must incorporate all reported changes in assets regardless of amount.
EXAMPLE 1 : Maya’s father dies and he leaves her his car. The Equity Value The wholesale value or a value estimated by a sales representative at a local business minus any encumbrances that are legal debts. of the car is $13,000. Maya intends to keep the car. While $10,000 of the equity value is disregarded, the remaining $3,000 equity value puts Maya $500 over the $2,500 asset limit. Maya reports taking possession of the car on February 10th. When Maya’s worker runs eligibility on February 10th, Maya fails the W-2 Wisconsin Works asset test for the months of March and April and Maya’s case will close effective February 28th.
EXAMPLE 2 : Carolyn received her tax refund of $2,505 on April 16th. She expects to use most of the money to pay past bills and other living expenses. She may continue in her CMU Case Management Underemployed placement as it is not expected that her assets will remain over the $2,500 limit for two consecutive months. The agency may ask Carolyn to send in her bank statement both months to check if she is over the asset limit for two consecutive months.
EXAMPLE 3 : Amy is participating in a CSJ Community Service Job placement and is taking classes to become a childcare provider. She wants to start a childcare program in her neighborhood but does not have the start-up money. She starts a crowdfunding campaign to raise funds. Her goal is to raise at least $4,000. She informs her FEP on January 6, that she has started a crowdfunding account, and calls her FEP each week the account gains $100 or more to report the amount. By February 1, she raises $1,836. Amy’s FEP counts the $1,836 as a liquid asset in CWW CARES Worker Web for February, and Amy remains under the asset limit. The crowdfunding account continues to grow and generates $2,743 by March 1. This puts Amy over the asset limit for March. Amy’s FEP must continue to review her financial eligibility to determine if she remains under the income and asset limits. If Amy’s crowdfunding account has the same amount or more by April 1, Amy would be ineligible for W-2 in May because she would be over the asset limit for two consecutive calendar months (March and April). If the FEP determines that she is over the asset limit, Amy’s case would close on April 30.
The equity value The wholesale value or a value estimated by a sales representative at a local business minus any encumbrances that are legal debts. of all assets not specifically disregarded must be counted.
EXAMPLE : Susan owns a coin collection worth $5,000. She also has a legal debt against the collection in the amount of $3,000. In this case, $2,000 shall be counted as an asset.
The value of the W-2 Group’s primary home serving as the homestead An abode and lands used or operated in connection with it. for the W-2 Group An adult custodial parent, all dependent children with respect to whom the individual is a legal custodial parent and all minor children with respect to whom the adult individual’s dependent child is a custodial parent. W-2 Group includes any non-marital co-parent or any spouse of the individual who resides in the same household as the individual and any minor children with respect to whom the spouse or non-marital co-parent is a custodial parent. W-2 Group does not include any person who is receiving cash benefits under a county relief block grant program. This is also referred to as the W-2 Assistance Group (W-2 AG) shall be excluded as an asset when the home is valued at 200% of the statewide median value or less.
FEPs shall count any home valued at more than 200% of the statewide median home value as an asset.
The home should be disregarded as an asset, regardless of home value, when any of the following hardship criteria are met:
No member of the W-2 group has the legal right to sell the home. For example: The home is subject to pending legal process(es); The home is jointly owned with a person not in the W-2 Group and does not consent to selling their share;
The W-2 Group had a recent sudden loss of income due to death, divorce, separation, or non-payment of support;
The W-2 Group includes an incapacitated group member; or
The W-2 Group is or has been subject to domestic abuse or is at risk of further domestic abuse; or if the home is jointly owned with the abuser, and the abuser is not a member of the W-2 Group.
FEPs shall determine the W-2 Group’s home value using a reliable source, such as:
Home value produced from an appraisal, realtor, or a recent final sale value; and
Online valuation tools, such as Zillow , or Real Estate Maximums, RE/MAX .
FEPs shall compare the W-2 Group’s home value to 200% of the previous year’s year-to-date statewide median home price, as reported by the Wisconsin Realtor Association’s (WRA) Wisconsin Housing Statistics.
Navigate to the Wisconsin Housing Statistics year-to-date median price data and multiply it by two to determine if the individual’s home is valued at more than 200% the statewide median home value.
The home value shall exclude the value of land used for agricultural purposes.
In urban situations, the homestead usually consists of a house and lot. A home can consist of a house and more than one lot when the lots adjoin one another.
In farm situations, the home consists of the house and buildings together with the total acreage property upon which they are located and which is considered part of the farm. In situations where the land is on both sides of a road, it is still considered a part of the home.
E XAMPLE 1 : Carmon is applying to W-2 in August of 2022 and reports being a homeowner. Their FEP finds that Carmon does not meet any of the home value hardship criteria and enters Carmon’s home address into Zillow which reports the home is valued at $350,000. Carmon’s FEP cross references the Wisconsin Realtor Association’s data for median home price using the 2021 year-to-date data, which is $240,000. 200% of the 2021 median home value is $240,000 x 2 = $480,000. Since Carmon’s home is valued at less than 200% of the statewide median home value, their home is disregarded as an asset.
EXAMPLE 2 : Alex is applying to W-2 in August of 2022 and reports being a homeowner. During application, Alex self-reports escaping a domestic violence situation to their FEP. Regardless of the value of Alex’s home, the home is disregarded from the asset test due to meeting hardship criteria.
EXAMPLE 3 : Zara is applying to W-2 in August of 2022 and reports being a homeowner. Their FEP determines Zara does not meet any of the home value hardship criteria. Zara provides documents from an appraisal she had done a year ago reporting her home is valued at $500,000. Using the year-to-date data for 2021 median home price, 200% of the 2021 median home value is $240,000 x 2 = $480,000 Zara is ineligible for W-2 because her home’s value is greater than 200% of the statewide median home value and does not meet any hardship exemption criteria.
FEP Financial and Employment Planner s must disregard the first $10,000 of combined equity value The wholesale value or a value estimated by a sales representative at a local business minus any encumbrances that are legal debts. of the W-2 Group’s vehicles. FEPs must count any equity value amount over $10,000 as an asset to be tested against the $2,500 asset limit.
FEPs must not increase a vehicle’s equity value by adding value for low mileage or items such as optional equipment or mobility devices. FEPs may use either of the following sources to verify vehicle value:
Kelly Blue Book ; or
J.D. Power New and Used Car Prices .
E XAMPLE : Chrystal's FEP checks Kelly Blue Book and verifies Chrystal's car has a market value of $6,700. However, Chrystal verifies that there is a lien recorded on the title for an outstanding amount of $4,000. The equity value of the vehicle is $2,700 (6,700 - 4,000 = 2,700).
The vehicles listed below with a ”No” must not be counted in the asset test. (See 3.3.1 )
Common Vehicles Asset Non-motorized Camping Trailer No Trailer Home No Moped Yes Motorized Golf Cart Yes Motorized Boat Yes Non-motorized Boat No Non-motorized, Nonfarm Livestock Trailer No Junk Car Yes Airplane Yes Snowmobile Yes Motorcycle - any number of wheels Yes Motorized Riding Garden Mower No Log-skidder No Farm Truck, Tractor, or Other Farm Vehicle used directly to produce income No Farm Tractor - Nonfarm Use Yes
Household and personal effects are exempt unless they are of unusual value.
IDA Individual Development Account s are funded by the Office of Community Services under the Assets for Independence Act (AFIA).
IDAs are designed to help individuals and families with low-income accumulate assets and build financial stability. In an IDA program, an eligible individual signs a savings agreement with a participating agency to save earned income for a specified purpose. The participant's savings are put in a segregated bank account and matched with program funds. The savings and match can only be withdrawn and used for purposes specified in the program.
The match funds reserved for a participant in an IDA account, and the accrued interest for the participant's savings and the match, are not available to the participant and, therefore, are disregarded as assets for W-2 eligibility.
If a W-2 agency uses AFIA funds to establish IDAs, the participant's savings in those IDAs are disregarded as an asset for W-2 eligibility.
The agency must disregard as an asset the entire amount of any federal tax refund for a period of 12 months from the date of receipt. The federal tax refund is considered disregarded income in the month received. (See 3.2.8.1 )
If a case is failing for exceeding the countable asset limit, the W-2 agency must ask the individual if they have received a federal tax return in the previous 12 months.
The W-2 agency must take the following steps if the individual reports a federal tax return:
Subtract the federal tax return amount from the amount of the individual’s existing countable assets, enter the corrected amount into CWW, and run eligibility;
Enter a case comment explaining the adjustment to countable assets;
Verify the tax return amount (see 4.1.3 ); and
Scan any relevant documents into ECF.
If the W-2 agency subtracts the federal tax refund from multiple countable assets, W-2 agencies must specify in case comments the amount of the federal tax refund that was disregarded from each countable asset.
E XAMPLE 1 - APPLICANT
On April 2, 2011 Jackie applies for W-2. She provides a bank statement indicating she has a checking account with a $3,000 balance.
The FEP must take the following actions:
Enter the $3,000 checking account into CWW;
Complete the driver flow; and
Run eligibility.
The CWW Eligibility Run Results page indicates that Jackie failed W-2 eligibility with a 024 reason code (countable assets are over program limits). Because Jackie failed W-2 eligibility for exceeding the asset limit, the FEP must ask Jackie if she received any state or federal income tax refunds in the past 12 months. Jackie tells the FEP that in February she received both a $1,000 state income tax refund and a $2,000 federal income tax refund, but she doesn’t have verification with her.
The FEP must take the following actions:
Subtract the $2000 federal tax refund from the CWW checking account entry;
Change the verification for the asset Type and Asset Amount to ? – NOT YET VERIFIED;
Request Jackie to provide verification of her federal tax refund amount, and the date she received it;
Enter a case comment indicating the amount and reason for the subtraction; and
Run eligibility.
Note : the FEP does not need to take any action on the state refund because Jackie received it two months ago and state EITC payments are only disregarded as income and assets the month they are received.
Jackie returns the following week with verification that she received a $2,000 federal tax refund on February 15.
The FEP must take the following actions:
Change the verification for the Asset Type and Asset Amount to indicate the type of verification Jackie provided; and
Run eligibility.
E XAMPLE 2 - ONGOING CASE
On April 10, Laticia calls to report she just received a $1,000 federal income tax refund and a $430 state income tax refund. The state income tax refund is the result of the state EITC. Both the full federal income tax refund and the state income tax return that is the result of the EITC are disregarded as income in the month received.
The FEP must take the following actions:
Enter a case comment in CWW identifying: The amount of the tax refunds, The dates Laticia received them; and Information on why the tax refunds were disregarded.
Follow the appropriate income tax disregard policy if Laticia fails W-2 eligibility for exceeding the asset limit in subsequent months.
The W-2 Wisconsin Works agency must verify nonfinancial and financial information provided by the W-2 applicant or participant to determine whether the individual qualifies for, or remains eligible for, W-2 services or a Job Access Loan.
The chart below provides a list of eligibility criteria along with suggested sources of allowable verification. The list of sources to verify an eligibility item is not exhaustive, but provides a sampling of the possible sources.
FEP Financial and Employment Planners s must verify the following only once per lifetime of the case: (See 4.1.4 )
Identity;
Social Security number;
Birth date; and
Citizenship.
FEPs must verify other eligibility criteria at every eligibility review and when new information is reported or received through a data exchange. FEPs must conduct eligibility reviews at least once every six months. If valid verification documentation already exists via data exchange or in the Electronic Case File (ECF), do not request additional verification.
For example, if a legible copy of the applicant's current lease is in ECF, rather than pend the case for additional verification of Wisconsin residency, FEPs must use this existing documentation to verify Wisconsin residency.
Eligibility Criteria Suggested Sources of Verification ECF Code Identity (verify identity only for all adults in the W-2 Group and only once) Driver’s License State Issued ID Card Student ID Card U.S. Government ID Card Military ID Card Native American ID Card or other tribal membership documentation issued by a Federally recognized Tribe Any photo ID document issued by United States Citizenship and Immigration Services (USCIS) The federal agency that oversees lawful immigration of foreign nationals who are temporarily or permanently settling in the U.S. See also INS. U.S. Passport Enhanced Driver's License Any unexpired immigration document Any other reliable document that verifies identity ID DX (DATA EXCHANGE) code when entered by CARES Client Assistance for Reemployment and Economic Support in the Identity Verification field SC (SSI 1619b SSDI OR MEDICARE) code when entered by an IM Income Maintenance Worker in the Identity Verification or Identity MA Verification field. If the code is entered only in the Identity MA Verification field, the FEP will need to enter the code in the Identity Verification Field. DE (DATA EXCHANGE) code when entered by an IM Worker in the Identity Verification or Identity MA Verification field. If the code is entered only in the Identity MA Verification field, the FEP will need to enter the code in the Identity Verification field. **SAVE database Not applicable Birth Date (verify birth date only once) Certified copy of Birth Certificate (must be marked “For Administrative Use”) Hospital Birth Record Driver’s License U.S. Passport State Issued ID Card Certificate of Naturalization (must be marked “For Administrative Use”) Certificate of Citizenship (must be marked “For Administrative Use”) Native American ID Card or other tribal membership documentation issued by a Federally recognized Tribe CARES birth query (Wisconsin births only) Any unexpired immigration document Any other reliable document that verifies birth date ID **State Online Query Internet (SOLQ-I) data exchange ( SSA Verification field is V - VERIFIED) NB (Continuously Eligible Newborn) code when entered by an IM Worker MB (Medicaid Birth Claim) code when entered by an IM Worker Not applicable Wisconsin Residency Residency refers to a person's true, fixed, and permanent home where a person intends to remain indefinitely and to which a person has the intention of returning, whenever absent. Applicants and participants must verify Wisconsin residency unless they are homeless, migrant workers, or newly arrived in Wisconsin. “Residence” is different from “address.” (verify residency at application and thereafter only if questionable) Reminder : Do not require residency verification for homeless or migrant assistance groups newly arrived to the area. For all other W-2 Groups, verify residency for the primary person. Landlord inquiry or current lease Utility bill for water, gas, electricity, or telephone that includes name and Address Address refers to the actual place where the household resides. • Applicants and participants must provide an address unless they are homeless, migrant workers, or newly arrived in Wisconsin. Verification of address is not required. • A household does not have to reside in a permanent dwelling. • A household may use a general delivery or PO box address. “Address” is different than “residence.” Mortgage receipt Subsidized housing program approval Weatherization program approval Signed statement from a shelter or individual providing temporary residence SUE Pay check stub including name, address, employer’s name, address and phone number EI Wisconsin Driver’s License Wisconsin ID Card ID Wisconsin Motor Vehicle Registration VI School registration record WLCM or SCHL, as appropriate Any other reliable document that verifies Wisconsin residency WMSC, or as appropriate U.S. Citizenship (verify citizenship only once) Certified copy of Birth Certificate (must be marked “For Administrative Use”) Baptismal Certificate or other religious record that lists a U.S. place of birth Hospital Birth Record or other medical birth record that lists a U.S. place of birth Native American ID Card or other tribal membership documentation issued by a Federally recognized Tribe Certificate of Naturalization (should be marked “For Administrative Use”) Certificate of Citizenship (should be marked “For Administrative Use”) U.S. Passport Enhanced Driver's License Citizenship documents issued by the U.S. Department of State to U.S. citizens born abroad Final adoption decree that lists a U.S. place of birth U.S. Citizen ID Card or Northern Mariana Card ID DX (DATA EXCHANGE) code when entered by CARES in the US Citizenship Verification field. **CARES birth query (Wisconsin births only) **SAVE database MB (MEDICAID BIRTH CLAIM) code when entered by an IM Worker in the US Citizenship Verification or US Citizenship MA Verification field. If the code is entered only in the US Citizenship MA Verification field, the FEP will need to enter the code in the US Citizenship Verification field. NX (CONTINUOUSLY ELIGIBLE NEWBORN) code when entered by CARES in the US Citizenship Verification field . NB (CONTINUOUSLY ELIGIBLE NEWBORN) code when entered by an IM Worker in the US Citizenship Verification or US Citizenship MA Verification field. If the code is entered only in the US Citizenship MA Verification field, the FEP will need to enter the code in the US Citizenship Verification field. DE (DATA EXCHANGE) code when entered by an IM Worker in the US Citizenship Verification or US Citizenship MA Verification field. If the code is entered only in the US Citizenship MA Verification field, the FEP will need to enter the code in the US Citizenship Verification field. Not applicable Qualifying Non-Citizen Status See 2.4.1 ID Marital Status (verify only if questionable) Certified copy of Marriage Certificate (must be marked “For Administrative Use”) Judgment of Divorce LEGAL Custody of Children (verify only if questionable) Court order LEGAL ** KIDS child support disbursement query Not applicable Cooperation with Jail Staff (verify for Huber Program participants only) Agency form; court order; city or county records; lawyer statement or record LEGAL Social Security Number (SSN) (verify only once) **Data Exchange verifying verbal statement of individual's SSN Note : This is the preferred form of verification for SSN. If the data exchange returns a "V-Verified" from the SSA Social Security Administration , there is no need to scan paper verification into ECF. Not applicable The following documents may be used as verification if the data exchange is unavailable or results in a discrepancy and must be scanned into ECF: Social Security Card Pay stub displaying the SSN W-2 Tax Form displaying the SSN Other reliable documents displaying both the name and SSN SSN S SN Application Date (Verify only if the individual does not have SSN) Form SS-5, Application for Social Security Number SSA document (e.g., receipt for SSN Application) Other written statement or agency form stating that the individual has applied for an SSN Oral statement from representatives of other state agencies, hospital staff, or other third parties verifying that a record exists of the individual's application for an SSN. For newborns only : Hospital discharge letter (must specifically reference the application for a SSN) SSN For exempt qualified non-citizens see 2.7.1 Not applicable Earned Income Dated check stubs for the past 30 days Letter from employer stating pay frequency, rate per hour, and average hours per pay period. Income tax return for the previous tax year EI Self-employment business tax records Self-Employment Income Report form (F-00107) SEI Any other document that verifies earned income SEI or EI as appropriate **CARES data exchange Not applicable Unearned Income Social Security Award Letter Unemployment Compensation Award Letter Divorce paperwork identifying a financial settlement Documentation of court awarded compensation Compensation Award Letter Veterans Administration Award Letter Any other document that verifies unearned income UI **CARES data exchange Not applicable Educational Aid Loans, scholarships, grants Financial Aid Award Letter Scholarship and Grant Award Letter School Records/Transcripts documenting aid received Loan Servicer Notices confirming disbursement of funds Summary of financial aid received from StudentAid.gov, educational institution, or the direct loan servicer Work study pay stub SCHL Financial Accounts * (Savings, Checking, Prepaid Debit Cards, Digital Financial Accounts, etc.) Current financial, bank, credit union, loan, prepaid debit card, and digital financial account (Chime, Venmo, Cash App, PayPal, Zelle, etc.) statement(s) *Note : Do not verify closed accounts or cards BNK In surance Policies Life insurance policy and the insurance company’s statement on the policy’s current cash value LIP Trust Funds Trust agreement Court order AST Oth er Savings or Investments Certificates of Deposit, Retirement Accounts (including IRA and KEOGH accounts), Stocks or Bonds Statement from stockbroker AST Copy of bonds SB Current bank, credit union, or savings and loan statement BNK Real Estate Deeds or titles Real estate receipts or tax records Statement of current value from local business AST Vehicles Cars, trucks, boats, campers, snowmobiles, and other motorized vehicles Car title or registration Written statement from car dealer Loan papers or sales receipt State Division of Motor Vehicle statement VI Pregnancy Medical statement from a doctor or other qualified medical provider (not allowed for At Risk Pregnancy). At Risk Pregnancy (ARP) Medical Information/Verification form (4070) form or a letter from a physician on the physician’s letterhead that contains all the information listed in 7.4.6.2 . See 4.4.6 S chool Enrollment Status Required for children subject to Learnfare (see 16.2.3 ) and for a Dependent 18-year-old A person who resides with a parent and who is 18, a full-time student at a secondary school or a vocational or technical equivalent, and who is reasonably expected to complete the program before attaining the age of 19. ) Report Card Statement from school or school district* Any other document that verifies school enrollment status* * Note : Verification for Dependent 18-year-olds must include expected graduation date. WLCM for Learnfare SCHL - for Dependent 18-year-olds Proof of a current and valid driver’s license Required for a JAL Job Access Loan for the purchase or repair of a vehicle State of Wisconsin Department of Transportation’s webpage , “Check driver license information” statement. See 17.2.1.3 VI Proof of motor vehicle liability insurance Required for a JAL for the purchase or repair of a vehicle Printed or electronic documentation showing proof of motor vehicle liability insurance. See 17.2.1.3 VI Proof of permission from a probation, parole or extended supervision agent to purchase a vehicle Required for a JAL for the purchase of a vehicle A note on Department of Corrections letterhead or an e-mail sent via the state e-mail system to the FEP Financial Employment Planner by a probation, parole, or extended supervision agent. See 17.2.1.3 VI
** Do not scan these items. Verification for these items is available via CARES queries and data exchanges.
Whenever possible, the FEP Financial and Employment Planner must attempt to verify eligibility information via CARES Client Assistance for Reemployment and Economic Support , data exchange, and ECF Electronic Case File . If that is not possible, the applicant or participant is responsible for obtaining verification of information that is necessary and appropriate in order for the W-2 Wisconsin Works agency to make a correct eligibility decision.
The applicant or participant has seven working days from the date the verification request is made to provide the needed verification. W-2 agencies must inform the applicant or participant in writing of the verification items required, including the due date.
The W-2 agency may extend the verification due date if:
Extenuating circumstances exist that make the verification requirements unduly burdensome; or
The verification submitted by the individual is questionable or contradictory.
If the individual is The verification due date may be extended An applicant Up to 30 days from the date the agency receives a signed Application Registration form. (See 1.4.2 and 1.4.4 ) A participant Up to 30 days from the date of the initial request for verification.
The W-2 agency must help the individual provide verification if the individual:
Has made a reasonable effort and cannot obtain the required verification;
Does not have the power to produce the verification; or
Requires assistance.
If the agency is unable to assist, the FEP must not deny an application or close a case based on the information that could not be obtained. The agency must use the available information to process the case and then reassess the case when the agency receives the requested information.
W-2 agencies have seven working days from the date they receive verification to process it.
If the applicant or participant is able to produce the information, but refuses or fails to do so, they are not eligible and the W-2 agency must deny the application or close the case.
Agencies must refer questionable verification or reporting supplied by applicants or participants for fraud investigation. (See 13.4.1 )
The following items must only be verified once per lifetime:
Identity;
Social Security Number;
Birth date; and
Citizenship.
To ensure these items are only verified once, the FEP Financial and Employment Planner must scan copies of the documents used to verify these items into ECF Electronic Case File in the appropriate folder based on the document type. See the ECF User Guide Document Lists and Codes for more information on document types.
Applicants do not need to resubmit verification for identity, SSN, birth date, or citizenship if verification of these items is stored in ECF. If an applicant has one of these items stored in ECF from a previous case, The FEP must:
View the verification documents stored in ECF from the previous case; and
Enter case comments documenting that these items were viewed in ECF and previously known to CWW CARES Worker Web .
Other eligibility criteria should be reviewed at every eligibility review and when new information is reported or received through a data exchange. (See 4.1.5 )
CWW CARES Worker Web exchanges data with federal and state databases as well as databases maintained by private agencies in order to verify information provided by applicants and participants. This CWW process is called data exchange, or DX Data Exchange , because it is a two-way flow of information in which a request is sent to another state or federal agency and the requested information is returned to CWW. Information exchanged through CWW DX includes:
Unemployment insurance benefits;
Earned income through wages;
SSN Social Security Numbers s;
SSI Supplemental Security Income payments;
Other SS Social Security income;
Incarceration status (see 11.7.1 ); and
Citizenship or Qualified Non-Citizen Status (see 2.4.1 ).
IEVS Income and Eligibility Verification System is a system that collects and exchanges income and resource data electronically between CWW CARES Worker Web and state and federal agencies.
The following are included in the IEVS data exchanges:
Unemployment insurance benefits;
Earned income through wages;
SSN Social Security Numbers s;
SSI Supplemental Security Income payments; and
Other SS Social Security income.
Discrepancies identified through the IEVS-related data exchanges must be reviewed by W-2 agency staff. (See 4.1.5.2 )
Under the UIB Unemployment Insurance Benefits data exchange process, UIB DX Data Exchange automatically enters UI Unemployment Insurance information received from state UI databases during intake, review, person add, and program add driver flows. The UIB DX requests UI information for all W-2 Group members over age 14 as long as there is a valid SSN (Verification Code V, C, or W) on the CWW Household Members page. If the DX returns UI income information, CWW automatically updates the Unearned Income Gatepost and the U nearned Income pages.
CWW also completes the UIB DX via a monthly batch process on the 2nd Saturday of the month and will automatically update the UI income for individuals who have had changes in their UI benefits. The monthly process also automatically end-dates UI benefits if no UI extension has been granted. Whenever UI income is updated via the monthly batch process, CWW enters a system-generated case comment.
There are limited situations in which CWW cannot automatically update the UI income information. In these situations, a discrepancy occurs. The FEP Financial and Employment Planner must resolve the discrepancy before running eligibility and confirming W-2. (See 4.1.5.2 )
The quarterly SWICA State Wage Information Collection Agency DX Data Exchange compares wage and income information provided by Wisconsin employers with information entered on the CWW CARES Worker Web Earned Income page. A discrepancy occurs if the monthly SWICA income plus other income budgeted for that month exceeds 115% of FPL for two consecutive months in a quarter. The FEP must update the earned income information on the Employment Queries page necessary to complete case processing before running eligibility and confirming W-2. (See 4.1.5.2 )
Because SWICA matches may not happen until participants have been open for several months, FEP Financial and Employment Planner s should use the CWW Employment Queries page when processing intakes, reviews, program adds, and person adds to determine if applicants and participants are correctly reporting income and employment.
The SOLQ-I State Online Query Internet Process DX Data Exchange is a web service that is initiated during intake, review, person add, and program add driver flows from the CWW CARES Worker Web General Case Information page. The SOLQ-I DX requests SSN Social Security Number , SS Social Security income, and SSI Supplemental Security Income income information from the Social Security Administration. The SOLQ-I requests information for all W-2 Group members who have a valid SSN (Verification Code V, C, or W) on the CWW Household Members page. If an individual’s SSN is verified and Social Security income or SSI income exists, CWW automatically updates the information on the CWW pages before the FEP gets to the page in the driver flow, unless there is a discrepancy.
Similar to the UIB data exchange process, if the SOLQ-I data exchange cannot update the SSN, Social Security, or SSI information, a discrepancy occurs. The FEP Financial and Employment Planner must resolve the discrepancy before running eligibility and confirming W-2. (See 4.1.5.2 ) If there is a discrepancy, the Benefits Received page displays a message notifying the FEP that SOLQ-I was either successful or unavailable.
Federal law requires FEP Financial and Employment Planner s to follow-up on all IEVS Income and Eligibility Verification System DX Data Exchange discrepancies identified during the DX process. FEPs must take action on IEVS DX discrepancies within 45 days for 80 percent of all discrepancies, including taking action to correct the case. The remaining 20 percent may exceed 45 days only if Third-Party Verification is outstanding. The FEP must take action on the remaining 20 percent no later than 90 days after the discrepancy was identified.
FEPs must take the following steps to process DX matches and follow-up on discrepancies:
Identify discrepancies. Once a discrepancy is set on a case, it displays in the information bar at the top of the page in CWW (next to Action Items and Documents).
The primary worker on the case will also see the discrepancy under the My Tasks section of the worker’s CARES Worker Web Home page. Because in mixed cases, CWW considers IM workers the primary workers and FEPs secondary workers, FEPs cannot see their discrepancies on their CARES Worker Web Home pages. CWW notifies secondary workers of discrepancies by sending an alert. FEPs can then see their discrepancies by:
Checking the discrepancies list on the participant’s Case Summary page;
Searching for discrepancies using the Caseload Management Search Criteria page; or
Using existing WebI reports to identify discrepancies.
Review the information returned via the DX and compare it to information entered in CWW .
Contact the participant or a third-party source to resolve the discrepancy and request verification, if necessary. The FEP must use the best available information to complete the data exchange process. The discrepancy must be resolved through the FEP’s action within 45 days of the match date, unless third-party collateral evidence is outstanding.
Update the appropriate CWW pages with the new information received. If the income was from employment, the FEP must also review and, if needed, update employment information on the WWP Wisconsin Work Programs Work History page. The FEP may also need to re-evaluate the individual’s W-2 placement based on newly verified employment information.
Run eligibility and confirm W-2 benefits. If possible, FEPs must resolve discrepancies before running eligibility and confirming benefits. Re-running eligibility may result in a case closure. If this is the case, the FEP must also determine if an overpayment occurred and, if it has, calculate the amount and establish a benefit recovery claim.
Update the status of the discrepancy. If the FEP is the secondary worker, the FEP must provide a written update to the discrepancy in case comments. If the FEP is the primary worker, the primary worker updates the status of the discrepancy by choosing one of the drop-down options.
Important Note: The secondary worker must not update the status of the discrepancy. If the secondary worker updates the status of the discrepancy, CWW will remove it from the information bar and from the primary worker’s My Task discrepancy count total. If this occurs, the primary worker may not ever know that the discrepancy existed. However, if the primary worker updates the status of the discrepancy before the secondary worker has an opportunity to follow-up on it, the alert will remain for the secondary worker as a reminder. For that reason, in cases with both a primary and a secondary worker, the secondary worker must provide updates to discrepancies in case comments.
The FEP should not verify information that has already been verified. (See 4.1.2 ) Information such as identity, SSN, birth date, or citizenship, must be verified only once per lifetime. (See 4.1.4 ) However, the FEP must verify employment and income at every eligibility review and when DX reports new information that changes frequently, such as earned and unearned income.
For more information on Data Exchange and IEVS, see Process Help 44 Data Exchange .
In addition to the Caseload Management Search Criteria page, FEP Financial and Employment Planner s can access the DX Data Exchange reports in WebI to view listings of all individuals who have outstanding data match discrepancies, and to monitor their progress in meeting the 45 and 90-day IEVS Income and Eligibility Verification System requirements for completing discrepancy reviews.
The following reports are in the Data Exchange folder in WebI Employment Programs, Report Monitoring subfolder.
DX Reports 1 and 2 Data exchange Report 1 provides a county summary. Report 2 provides a detailed report by county of all matches with incomplete dispositions/discrepancies due for 45 days or more.
DX Reports 3 and 4 Data exchange Report 3 provides a county summary. Report 4 provides a detailed report by county of the overdue dispositions/discrepancies completed during a specific month.
DX Reports 5 and 6 Data exchange Report 5 provides a W-2 agency summary. Report 6 provides a detailed report by agency of all matches that are due within 45 days and incomplete dispositions/discrepancies.
DX Report 7 Data exchange Report 7 provides a Worker ID summary and gives W-2 agency staff another tool to use to manage their dispositions/discrepancies.
DX Report 8 Data exchange Report 8 provides a statewide summary.
The applicant or participant has primary responsibility for obtaining verification. However, by signing the Wisconsin Works (W-2) and Related Programs Application form (2471) , the individual acknowledges that the W-2 Wisconsin Works agency may request information not considered confidential from any person it deems appropriate and necessary for the administration of W-2.
Cooperation of the third party is expected within seven working days of the agency’s request. The W-2 agency may extend the seven working day time limit if it is unduly burdensome. Wisconsin State statute does not provide for compensation for the third party.
Applicants and participants must not be penalized when a third party fails to cooperate with a verification request. The FEP Financial and Employment Planner must never delay eligibility determination and initial placement while waiting for information from a third party.
The placement decision must be made using the best available information, including consulting with appropriate agencies at the time of application. Eligibility must be reassessed when information from third-party sources is received.
During the application process, the FEP may refer the applicant for screenings or assessments, some of which require information from a third-party source. However, referrals for screenings and assessments are not eligibility requirements and are therefore not subject to verification time lines discussed here. (See 5.1.1.2 )
When requesting confidential information, the FEP must use the Authorization for Disclosure of Confidential Information form (10779) .
This form meets federal and state requirements for the confidential release of information from treatment providers, including:
AODA Alcohol and Other Drug Abuse treatment;
Mental health treatment;
Domestic violence counseling;
HIV/AIDS; and
Medical conditions.
Information concerning W-2 Wisconsin Works applicants and participants generally must not be disclosed for any reason except:
When it is necessary for the administration of the W-2 program; or
Under certain circumstances, when requested by law enforcement officers. (See 4.2.3 )
If the information requested is not directly related to program administration, it must not be provided.
To provide effective services to W-2 participants, it is often necessary to obtain highly sensitive, confidential information.
Information related to the following is considered confidential for purposes of the W-2 program:
Physical health, including HIV/AIDS;
Mental health;
Disabilities and impairments, including physical disabilities, learning disabilities, cognitive impairments, and developmental disabilities;
Alcohol and substance abuse; and
Domestic abuse.
Records related to confidential information may include but are not limited to:
Assessments, including vocational and functional evaluations;
Screening and test results;
Treatment notes;
Diagnoses; and
Services and accommodations.
See 4.4.2 for information on scanning confidential information into the Electronic Case File. See 4.4.6 for information on accessing and referencing confidential information about W-2 participants.
Confidential information is protected more heavily than general information about the W-2 participant. In general, the disclosure and use of confidential information between staff members should only occur when their assigned duties require that they have access to the information.
An individual or program in possession of confidential information (for example, a federally-assisted substance abuse program) may not release confidential information except as authorized by the individual. Anyone who receives confidential information may not again disclose it without the individual’s consent and cannot retain this information unless confidentiality can be maintained.
W-2 agencies may disclose confidential information in the following circumstances without a release of information:
To other staff within the W-2 agency when their assigned duties require they have access to the information;
To another W-2 agency if the individual changes agencies; and
To staff from the DCF Department of Children and Families , which has direct administrative control over the W-2 program.
EXAMPLE 1 : Juanita is a W-2 T participant. Her FEP referred her to a mental health specialist for a formal mental health assessment. Based on the results of the assessment and a diagnosis of depression and situational anxiety disorder, the FEP assigned Juanita to weekly mental health counseling appointments and limited hours at a work experience site. After six months, Juanita was ready to begin employment search. Juanita’s FEP shared with the employment readiness workshop facilitator Juanita’s mental health diagnosis, the necessary accommodations she would need to successfully participate in the job readiness workshop, and stressed that Juanita’s diagnosis and accommodations must be kept confidential. The sharing of this information was based on the workshop facilitator’s assigned duties requiring access to the information to be able to direct Juanita towards employment that would not cause anxiety as well as provide the accommodations Juanita needs in order to maintain employment.
EX AMPLE 2 : Roberta is a new W-2 T participant who has been diagnosed with post- traumatic stress disorder due to a traumatic event from her past. Roberta confided this in her FEP and shared some counseling records from her former doctor. Later that day, Roberta’s FEP shared with her co-worker the details of Roberta’s past and asked for advice on finding Roberta a new doctor. The sharing of Roberta’s past was not based on the co-worker’s assigned duties requiring access to the information because the FEP could have kept the details confidential while still seeking advice on referring Roberta to a local mental health professional.
If a law enforcement officer believes, on reasonable grounds, that a warrant has been issued and is outstanding for the arrest of a W-2 participant, the W-2 Wisconsin Works worker, at the request of the law enforcement office, may notify a law enforcement officer when the participant appears to obtain their W-2 payment.
The W-2 agency may release the current address of W-2 participants to a law enforcement officer who meets all of the following conditions:
The officer provides, in writing, the name of the recipient; and
The officer demonstrates, in writing, the following: The recipient Is a fugitive felon under 42 U.S.C. s. 608(a)(9) ; Is violating probation or parole imposed under state or federal law; or Has information that is necessary for the officer to conduct their official duties; The location or apprehension of the participant is within the official duties of the officer; and The officer is making the request in the proper exercise of their duties.
The W-2 agency is not required to report an applicant or participant to police simply because a worker is aware that the individual has an outstanding warrant. If there is any concern that an applicant or participant may cause harm to themselves or others, whether there is a warrant involved, the agency should take the initiative to contact the police.
W-2 Wisconsin Works eligibility information requiring verification must be either “validated” or “documented.”
Validation for the purpose of verifying W-2 eligibility information, means placing original items of verification evidence (or a copy thereof) in the case file.
Validation may be done by:
Making a photocopy of an original document and then scanning it into ECF Electronic Case File ;
Using an IEVS Income and Eligibility Verification System match report;
Using a query response from SAVE S ystematic Alien Verification for Entitlements ; or
Using a CARES Client Assistance for Reemployment and Economic Support birth query result.
Photocopies of verification items should be marked with the:
Date the document was obtained; and
Initials of the staff person who obtained the document and scanned it into ECF. (See 4.4.2 )
If the validation occurred through a CARES DX Data Exchang e , the verification code will automatically populate in CARES.
When vali dating eligibility information, the worker is not required to enter case comments documenting how the eligibility criteria were verified.
Documentation for the purposes of verifying W-2 eligibility information means describing the relevant verification evidence that is either entered as a case comment in CWW or a case note scanned into ECF based on a conversation with the individual or an observation, inspection, conversation, or collateral contacts by the W-2 worker.
The worker must enter comments as a formal record of case action or eligibility-related information for an individual by the end of the working day following the day the action or contact with a participant occurred to ensure chronological documentation.
Vital records are maintained by the Wisconsin Department of Health Services and are official records of:
Births;
Deaths;
Marriages; and
Divorces.
These documents are referred to as:
Birth Certificates;
Death Certificates;
Marriage Certificates;
Divorce and Annulment Certificates; and
Any data related to the above documents, e.g., printed birth query information from CARES Client Assistance for Reemployment and Economic Support .
Agencies must refer questionable verification or reporting supplied by applicants or participants for fraud investigation. (See 13.4.1 )
To mark a vital record with “Administrative Use Only,” the FEP Financial and Employment Planner must:
Make a photocopy of the original document;
Stamp the photocopy with “Administrative Use Only”; and
Scan the stamped photocopy into ECF Electronic Case File .
Originals must not be stamped or scanned into ECF, but must be returned to the W-2 applicant.
Following this process will ensure compliance with Wis. Stat. s 69.30 (2) which requires that vital records be marked, “Administrative Use Only.”
Although Certificates of Naturalization and Certificates of Citizenship are not considered vital records, W-2 agencies must also use the vital records process for these documents.
Workers must record comments using CWW CARES Worker Web and WWP Wisconsin Work Programs by the end of the working day following the day the action or contact with a participant occurred to ensure chronological documentation.
When a FEP Financial and Employment Planner makes a change to a W-2 case that leaves eligibility unconfirmed for other programs, the FEP must notify the Income Maintenance (IM)/Child Care (CC) worker to confirm eligibility for the other programs. In addition to comments, whenever the FEP or IM/CC worker makes a change in a case, the worker must also notify the other worker via e-mail, fax, or phone contact to ensure timely processing of the W-2, CC, and IM cases.
There are two types of comment entries, case comments and PIN comments.
Case Comments
Case comments are entered into CWW and should be entered when the interaction is describing a case-level event that impacts eligibility issues, such as:
Case reviews;
Verification;
Adding or deleting household members, etc.
PIN Comments
PIN comments are entered in WWP and should be entered when the interaction is describing an individual level event, such as:
Good cause;
Informal assessment summary;
General notes recording individual contact as it relates to work program participation, etc.
PIN comments are required as a formal record of all Work Programs-related information for an individual.
W-2 agencies may not disclose confidential information in comments and must note that further details are in ECF and/or the WWP Participant Barrier page. Below are examples of appropriate language that can be used when cross-referencing this information:
“Participant has been referred for a formal assessment. See WWP Participant Barrier page for further details.”
“Participant is currently restricted per completed medical capacity form to no more than 30 minutes of continuous sitting or standing. ECF contains complete medical information and diagnosis provided by the doctor.”
See 4.2.2.1 for a listing of confidential information that must never be entered in comments.
Workers must record provided supportive services and supportive service payments through the required documentation on the Supportive Services page in WWP.
The Electronic Case File (ECF) is a paperless case file system that uses document imaging (scanning) to store case file materials in an electronic format.
To ensure the effectiveness of ECF Electronic Case File in maintaining consistent retention of and access to case file documentation, W-2 Wisconsin Works agencies must follow program policy with respect to the maintenance of case file information.
W-2 Wisconsin Works agencies are required to scan all paper documents except attendance documentation that contains confidential information into ECF and comply with the following scanning guidelines:
Ongoing Case Documentation : All ongoing case scanning must be completed within 30 calendar days of: The reported/required case action having been performed in CWW CARES Worker Web , or WWP Wisconsin Work Programs ; or Being received in the W-2 agency.
This includes the scanning of documents turned in at intake, review, and those dropped off or mailed into the agency.
Confidential Information : All confidential information except attendance documentation that contains confidential information must be scanned into ECF under the appropriate document codes. (See 4.4.6 )
Case Review Monitoring : Files requested for review by the DCF Department of Children and Families must be scanned into ECF, in their entirety, within 10 working days of receiving the request. This may include cases requested for monitoring purposes, ad hoc queries, or any other monitoring purpose.
Transfer Cases : When transferring a case, agencies must scan all relevant material prior to transferring the case.
If the agency is unable to meet these requirements, agency staff must notify the appropriate DCF regional staff.
The following table outlines the required W-2 agency record retention time frames based on record type:
Record Type Required Retention Time frame W-2, JAL Job Access Loan , and EA Emergency Assistance case-related paper documents not scanned into ECF Electronic Case File . Three years after a case closes. Audio tapes of Fact Finding Reviews. Three years after the case closes. Case-related paper documents if any litigation, claim, or audit involving the case is unresolved. Note : The terms “litigation,” “claim,” and “audit” include lawsuits, Fact Finding Reviews, Departmental Reviews, Intentional Program Violation claims, federal or state audits, Legislative Audit Bureau audits, etc. Through the duration of the investigation, and three years from the date the issue was resolved.
Agencies may destroy paper documents properly scanned and stored in ECF at any time.
However, it is recommended that agencies retain paper documents scanned into ECF for at least a week in the event of a scanner operator error. This includes copies of:
Birth certificates;
Social Security cards;
Marriage certificates, etc.
Agencies must return original documents to the owner. (See 4.4.1 )
W-2 agencies must not delete any document from ECF unless the document is scanned under the wrong case. In this situation, the agency must either re-index the document to the correct case or delete and re-scan the document. See ECF Handbook sections 1.4 and 5.1.3 for more information.
To minimize subjectivity between agency workers storing documents in ECF Electronic Case File , agencies should:
Use the documentation matrix found in the ECF User Guide Document Lists and Codes ; and
Develop additional internal guidelines on document storage as needed.
All supporting documents for applications must be stored in the appropriate category, if one exists.
If there is not an existing document type in which the document most appropriately belongs, the agency worker should consider the document as part of the application and include it with the application in Sub-folder Case Information under Document Type APP.
For applications that have supporting documentation, the agency worker should notate the top of each document prior to scanning into ECF referencing the application the type of supporting documentation.
EXAMPLE : A worker storing Job Access Loan applications should file positive or negative notices in the Sub-folder Correspondence under Document Type NOD and file rental agreements in the Sub-folder Expenses under Document Type SUE. When doing so, the worker should put a notation at the top of the document prior to scanning referencing “JAL verification.”
All confidential information, with the exception of the paper documents listed below, must be stored in ECF Electronic Case File . See 4.2.2.1 for information that is considered confidential for purposes of the W-2 program.
The following confidential paper documents must be stored in a sealed envelope in the paper file under lock and key:
Confidential documents retained in case of scanner operator error (see 4.4.3 );
Confidential paper copies of any document an agency determines must be kept long-term; and
Attendance documentation that contains confidential information.
Agencies must return original documents to the owner. (See 4.4.1 )
See the ECF User Guide Confidential & Restricted Documents appendix for more information on the different types of document security in ECF.
Confidential cases in CARES Worker Web (CWW) restrict access to the case and the information the case contains. When a case is confidential in CWW, the corresponding participant data in WWP Wisconsin Work Programs , CARES Work Programs screens, and ECF are also made confidential.
W-2 applicants and participants may request to have their cases made confidential at any time.
Additionally, the FEP Financial and Employment Planner must make an individual’s case confidential in CWW CARES Worker Web in the following situations:
When the individual requests the case be made confidential;
When the individual is enrolled in the Safe at Home program;
When the individual is a victim of or is under the threat of domestic violence or physical harm;
When the individual is an employee of a W-2 agency;
When the individual is included in another CWW case that is confidential; or
Any situation in which the FEP believes restricting access to an individual’s case information is necessary for the individual’s protection and well-being.
If the individual was included in another CWW case that closed within the last three years and was confidential at the time of closing, the FEP must discuss with the individual whether the W-2 case should be made confidential.
When making a case confidential in CWW:
If the Individual is The FEP must Already currently enrolled in both W-2 and another assistance program in CWW (i.e., FoodShare, BadgerCare, or Wisconsin Shares). Contact the appropriate agency as needed if the confidential status changes. Both assigned workers and their supervisors will have access to the case and its documents. Enrolled in CWW for another assistance program and the case is already confidential at the time of W-2 application. Contact the appropriate agency to gain access to the case. After the FEP obtains access to the case, the FEP must return the case to confidential status immediately. Only enrolled in W-2 in CWW and requests another assistance program when the case is already confidential. Work with the appropriate worker from the other assistance program to allow access to the confidential case. After the other worker obtains access to the case, the other worker must return the case to confidential status immediately.
Only the FEP Financial and Employment Planner assigned to the confidential case and the FEP’s assigned supervisor can access the:
Case in CWW CARES Worker Web ;
Corresponding participant data in WWP Wisconsin Work Programs ; and
Case’s documents in ECF.
If the participant is enrolled in another assistance program, the Income Maintenance (IM) worker assigned to the individual’s case and the IM worker’s immediate supervisor can also access information from the individual’s case.
Other staff within the W-2 Wisconsin Works agency can access information from a confidential case only when their duties require that they have access to the information. If such access is required, staff must work with the FEP assigned to the confidential case or the FEP’s supervisor to obtain the needed information.
W-2 Wisconsin Works Participants can relocate and have their W-2 case transferred to the agency serving their new geographical area.
The sending and receiving W-2 agencies must follow all guidance, procedures, and timelines outlined in the Bureau of Working Families (BWF) W-2 Program Case Transfer Process Guide .
It is the responsibility of both the sending and receiving W-2 agencies to work collaboratively and efficiently to ensure the transfer process does not negatively affect the participant.
The sending W-2 agency must initiate a transfer no later than 2 working days after they learn of a participant’s relocation and is responsible for notifying the participant of the transfer. The sending W-2 agency must also attempt to contact the participant using various means, including an in-person meeting, phone call, email, etc.
The W-2 agency must give participants who are experiencing homelessness or domestic violence the option to receive services from the new W-2 agency, or remain with the agency that is currently serving them.
The participant’s placement, Employability Plan, and all assigned activities will remain open during the transfer process and be transferred to the receiving agency.
The sending W-2 agency must provide good cause for all nonparticipation caused by the moving and transfer process and document the rationale in PIN comments. See 11.3.3 for relevant good cause reasons.
EX AMPLE : Maria is currently placed in a CSJ in Milwaukee. Her FEP learns that Maria will be moving to La Crosse. Maria’s work experience is on site in Milwaukee and she will not be able to participate or complete this activity during the moving and transfer process to her new agency in La Crosse. Maria’s FEP in Milwaukee must provide good cause for her nonparticipation until she is fully transferred to the new agency in La Crosse and her EP can be updated to reflect activities in her new area.
The receiving W-2 agency must meet with the participant within 10 working days from the date of transfer as reflected in the transaction list in WWP to conduct an Informal Assessment. The participant must remain in their existing W-2 placement and assigned activities until meeting with the new W-2 agency.
Once the new FEP completes an informal assessment, they can determine with the participant if any changes should be made to the participant's:
Placement;
Activities;
Supportive services;
Accommodations, etc.
All results must be documented in PIN comments and on the appropriate WWP Wisconsin Work Programs pages, and any necessary changes must be made on the new EP Employability Plan . For more information on transferring assessment information, see 4.6.2 .
CMF Case Management Follow-Up or CMF+ Case Management Follow-Up Plus placements can be transferred to the receiving agency like any other placement. If an individual enrolled in a CMF or CMF+ placement loses the employment that led to the CMF or CMF+ placement while enrolled in W-2, the individual may seek W-2 services in the county where the individual has relocated.
When processing a newly transferred case, the receiving W-2 agency must check the WWP Wisconsin Work Programs Participant Barriers page to see if any formal assessments were completed during a prior W-2 episode. If so, the W-2 agency must obtain copies of the following information from the previously assigned W-2 agency:
All formal assessments and treatment notes from the past 12 calendar months; and
Any additional information and assessments, regardless of age, that were used to determine how the participant was last served by the previously assigned W-2 agency.
If the information is The W-2 Agency Must Scanned into ECF Obtain the information from ECF. Not scanned into ECF Contact the previously assigned W-2 agency and request formal assessments and treatment notes from the prior W-2 agency.
The previously assigned W-2 agency is required to provide all copies of requested documentation to the requesting W-2 agency so that it is received within seven working days.
Copies of confidential documents cannot be faxed or emailed. The requested documentation must be:
Scanned into ECF using the WPM code;
Sent by US mail or other delivery services with tracking; or
Sent through a courier service.
A formal assessment from a transferred case may only satisfy the formal assessment requirement for a W-2 T W-2 Transition placement if the formal assessment for the stated barrier/disability was completed within the 12 months prior to the agency transfer.
If the formal assessment for the stated barrier/disability was not completed within the 12 months prior, the new W-2 agency will need to request that a new formal assessment be completed within 30 days of making a new W-2 T placement. (See 5.5.1.1 )
During the application process and prior to placing the individual in a W-2 Wisconsin Works placement, the W-2 agency must work with the applicant to:
Complete an informal assessment (see 5.2 );
Complete an Educational Needs Assessment Educational needs assessments determine if the individual needs, or would benefit from, education or training activities, including a course of study for the granting of a declaration of equivalency of high school graduation. In making this determination, the FEP must consider the following: • The information gathered on the applicant/participant’s current educational levels; • The level of education and training necessary to obtain full-time employment in the local labor market; and • The applicant/participant’s personal employment goals. (see 5.3 );
Start the process of career assessment (see 5.4 ); and
Obtain the results of any career assessments, vocational evaluation/assessments, or formal assessments, if available from prior W-2 episodes (see 4.6.2 ).
Using the assessment information gathered at application, the worker may require the applicant to participate in up-front job search activities as a condition of eligibility (see 2.9.2 ).
To make the initial W-2 placement and develop the EP Employability Plan , the FEP Financial and Employment Planner must use the best information available during the application timeframe using the:
Results of the informal assessment, educational needs assessment, and career assessment, if available;
Progress made during assignment to up-front job search activities, if assigned; and
Results of any other vocational evaluation/assessments or formal assessments, if available.
When an individual applies for W-2, the W-2 agency must:
Determine if the individual received W-2 in the past; and
Obtain prior assessment information.
If prior assessment information is current and relevant to the individual’s current situation, this information may be used to aid in decision-making for the initial placement and EP.
If the individual received W-2 in the past, the W-2 agency must check the WWP Wisconsin Work Programs Participant Barriers page to see if any formal assessments were completed previously. If so, the applicant’s W-2 agency must obtain all copies of:
Formal assessments;
Treatment notes; and
Any additional information from ECF Electronic Case File .
If the formal assessment is not available in ECF and the individual was previously assigned to a different agency, the current W-2 agency must contact the previously assigned agency. The previously assigned W-2 agency is required to provide all copies of requested documentation to the current W-2 agency so that it is received within seven working days. (See 4.6.2 )
The FEP should consider a formal assessment acceptable if completed within one year prior to W-2 T W-2 Transition placement.
Results from a prior formal assessment may only be used if the assessment:
Contains the necessary elements; and
Is relevant to the employment barrier in question.
If the prior formal assessment results have an expiration date that indicates the results are no longer valid or there is reason to believe the formal assessment information does not reflect the participant’s current circumstances, then a new formal assessment must be completed. (See 5.5.1.1 )
During the application process, the FEP may also refer the applicant for vocational evaluation/assessment Assessments which are conducted to help individuals living with a disability establish realistic vocational goals and a plan to achieve them. The vocational evaluation process is designed to assess the unique strengths, resources, and experiences of an individual in order to match that person’s abilities and preferences to appropriate work placements, jobs, or training programs. The process is interactive; the intent is for staff to learn about the participant and the participant to learn about themselves and/or formal assessment of employment barriers. (See 5.5.1 ) However, completing referrals for vocational evaluation/assessments or formal assessments are not eligibility requirements.
The FEP must never delay eligibility determination and initial placement because of a pending assessment.
The placement decision must be made using the best available information during the application timeframe. (See 1.4.4 ) The W-2 placement may be adjusted later, if needed, when additional assessment information is received.
To gather assessment results, W-2 agencies are encouraged to consult with other employment and training resources, and accept previous assessments done by other agencies if appropriate.
Prior to making a change in W-2 Wisconsin Works placement, the W-2 agency must work with the participant to:
Complete and submit the WWP Wisconsin Work Programs Informal Assessment Driver Flow (see 5.2 ); and
Complete an educational needs assessment (see 5.3 ).
The following assessments are considered an ongoing activity, are part of general W-2 case management, and can be completed throughout ongoing case management as a participant's needs change:
Educational Needs Assessment Educational needs assessments determine if the individual needs, or would benefit from, education or training activities, including a course of study for the granting of a declaration of equivalency of high school graduation. In making this determination, the FEP must consider the following: • The information gathered on the applicant/participant’s current educational levels; • The level of education and training necessary to obtain full-time employment in the local labor market; and • The applicant/participant’s personal employment goals. : Standardized educational needs assessment tools, such as TABE Test of Adult Basic Education or BEST Basic English Skills Test , should be used to determine a participant’s educational levels. (See 5.3.1 )
Career Assessment : The Career Assessment page in WWP is a stand-alone page that is designed to identify a participant's work styles, skills, and interests. Completing the Career Assessment page will ensure that workers have sufficient detail to develop EPs and assign meaningful activities.
Job Readiness Assessment : The Job Readiness page in WWP is a stand-alone page with questions that are designed to guide conversation to complete a thorough job readiness assessment. Completing the Job Readiness page will ensure workers have sufficient detail on work preferences, history, applications, interviews, and contacts to develop EPs and assign meaningful activities.
WWP Informal Assessment : The FEP may also choose to complete or edit the WWP Informal Assessment when there is reason to believe that reviewing the WWP Informal Assessment questions or specific pages may help initiate conversation about a potential barrier that is affecting the participant’s ability to work or participate in assigned activities.
Additional Approaches to Informal Assessment : The W-2 agency may also use alternative approaches to supplement the information gathered through the WWP Informal Assessment Driver Flow. (See 5.2.1 )
Under W-2 Wisconsin Works , assessment is the process of gathering information to develop an Employability Plan (EP) customized for the participant that will result in either a:
Successful employment outcome to start the individual on a career path; or, if appropriate,
Path to eligibility for SSI Supplemental Security Income , SSDI Social Security Disability Insurance , or both.
Certain types of assessments are required for all W-2 applicants and participants, including:
Informal Assessment (see 5.2 ); and
Educational Needs Assessment (see 5.3 ).
The information gathered through these required assessments help the FEP in identifying whether additional Formal Assessments (see 5.5) are needed to develop the participant’s EP Employability Plan .
The assessment process is conducted in collaboration with the applicant or participant. The FEP must:
Discuss the results of each assessment with the participant; and
Work together with the participant when deciding which W-2 placement and activities are assigned as part of the EP.
Informal assessment is an ongoing case management practice, which starts during the W-2 Wisconsin Works application period and continues until the individual no longer receives W-2 services.
A comprehensive informal assessment via the WWP Wisconsin Work Programs Informal Assessment Driver Flow must be completed and submitted prior to initial W-2 placement and at each placement change.
The purpose of the informal assessment process under W-2 is to help the FEP better understand the goals and needs of the individual and their family to determine the:
Individual's ability to become employed;
Services and activities necessary for the individual to secure and maintain stable employment;
Appropriate W-2 placement of a participant;
Existence of potential disabilities or other specific limitations;
Need for further career assessment and planning;
Need for vocational evaluation/assessment; and
Need for a formal assessment of any disabilities or other employment barriers by a qualified assessing agency or individual.
Multiple approaches to informal assessment can be used, based on individual needs. Additional approaches to conducting informal assessment may include:
Automated screening and assessment tools available within the W-2 agency;
Information gathered through case management meetings;
Worksite performance evaluations;
Goal setting exercises/tools (e.g., where do you want to be in six months? Two years?, etc.); and
Experience with following through on job search and other assigned activities.
The WWP Wisconsin Work Programs Informal Assessment Driver Flow covers the following assessment categories related to an individual’s ability to become employed and remain employed:
Language(s);
Work History;
Participation in other Work Programs;
Education History;
Post-Secondary Education;
Military Service;
Housing;
Transportation;
Legal Issues;
Participant Barriers;
Child and Youth Supports; and
Family Barriers.
The WWP Informal Assessment Driver Flow also includes a Non-Custodial Parents page that provides an opportunity for applicants and participants who are noncustodial parents (NCPs) to discuss their role as a parent, and share basic information about the custodial parent and their child(ren) . In addition, the NCP Referral page is intended to help the W-2 Wisconsin Works worker determine if the agency could offer services to help the NCP of the individual's child(ren).
While moving through the WWP Informal Assessment Driver Flow, the W-2 worker must gather information about the individual's:
Personal strengths;
Work styles;
Interests: and
Skills that may help the individual secure employment or that may be further developed through activities assigned in the EP employability plan .
The W-2 worker must work with the individual to identify resources to address any unmet needs identified during the informal assessment process.
In addition to the information gathered through completion of the WWP Informal Assessment Driver Flow, the following inventory must be covered as part of the informal assessment A process to gather information about an individual and his or her family to determine the: •Individual's ability to become employed and remain employed; •Services and activities necessary for the individual to become employed and remain employed; •Appropriate placement of a participant on the W-2 employment ladder; •Need for further career assessment and planning; •Need for vocational evaluation; and •Need for a formal assessment of any disabilities or other employment barriers by a qualified assessing agency or individual. process and reviewed with each W-2 Wisconsin Works applicant or participant at application and as a part of ongoing case management.
Personal strengths, interests, and goals;
Job skills (including transferable skills);
Job readiness (including work preferences, history, applications, interviews, and contacts);
Recent job search efforts;
Results from the Career Assessment A broad spectrum of assessment tools that W-2 agencies, applicants, and participants use to obtain greater awareness about how an individual’s work styles, skills, and interests can be used to define a career path, assign meaningful activities, highlight strengths, identify training needs, and match the individual to employment opportunities that evaluate work styles, skills, and interests;
Current neighborhood environment and schools;
Household budgeting/money management strategies;
Access to social supports (e.g., family members, church, friends);
Other needs or barriers identified by the participant that impede their ability to participate in W-2 activities or find and retain a job.
Informal assessment inventory items are not eligibility requirements. Eligibility determination and initial placement must not be delayed due to a pending assessment.
The placement decision must be made using the best available information during the application timeframe. (See 1.4.4 )
The following table outlines the timeline and requirements for an applicant or participant that does not have the Job Readiness or Career Assessment page completed in WWP.
W-2 Status Assessment Type not Completed Scheduling and Completion Requirements New or re-applying to W-2 Job Readiness Assessment Must be scheduled within 30 days of an application and must be completed within 30 days of placement. Career Assessment Must be scheduled within 30 days of an application and should be completed within 30 days of placement. Current participant Job Readiness Assessment Must be scheduled within 30 days of an EP review and must be completed before the next EP review. Career Assessment Must be scheduled within 30 days of an EP review and should be completed before the next EP review.
Informal assessment must also include observations by the worker about the individual’s ability to complete assigned activities and/or perform job search.
When an applicant or participant is having difficulty completing assigned activities, this may be an indication of underlying barriers to employment and should result in further conversations with the individual about the appropriateness of the activities being assigned and the need for additional supportive services.
The WWP Wisconsin Work Programs Informal Assessment Driver Flow is intended to provide a framework to guide the interactive conversation needed to complete a comprehensive Informal Assessment A process to gather information about an individual and his or her family to determine the: •Individual's ability to become employed and remain employed; •Services and activities necessary for the individual to become employed and remain employed; •Appropriate placement of a participant on the W-2 employment ladder; •Need for further career assessment and planning; •Need for vocational evaluation; and •Need for a formal assessment of any disabilities or other employment barriers by a qualified assessing agency or individual. .
The W-2 Wisconsin Works worker is required to ask all questions that appear in the WWP Informal Assessment Driver Flow, including additional questions that appear based on the answers provided. The W-2 worker must also ask follow-up questions and engage the applicant or participant in further conversation beyond the prescribed questions to obtain information needed to identify potential barriers to employability.
This process is intended to ensure that the W-2 worker has sufficient detail on the W-2 applicant or participant’s skills, abilities, interests, and goals to inform Case Management The family-centered and goal-oriented process for assessing the needs of a W-2 group member and his or her family for employment, training and supportive services and assisting the W-2 group member in obtaining the services needed to achieve self-sufficiency. decision-making.
The WWP Informal Assessment Driver Flow includes a Participant Barriers page with questions to collect information about the applicant or participant’s health and personal life that may affect the individual’s ability to obtain and maintain employment. The WWP Informal Assessment - Participant Barriers page consists of five sections:
Physical Health;
Mental Health;
Alcohol and Other Drug Abuse (AODA);
Cognitive and Learning Needs; and
Domestic Abuse Screen.
The FEP Financial and Employment Planner must use the responses to the WWP Informal Assessment Participant Barriers questions provided to determine whether the individual could benefit from a Formal Assessment The process of establishing: •The extent and severity of any disabilities or other conditions (e.g., domestic violence, learning needs, need to care for disabled child) that may interfere with normal functioning in an employment setting or with a persons’ ability to meet W-2 program requirements; • The effect of a disability or other potential barrier on the person’s capacity to obtain and maintain unsubsidized employment, participate in employment-related activities (e.g., employment training or education) or otherwise meet W-2 program requirements; •The need for supportive services, accommodations, auxiliary aids or communication assistance; •The conditions under which the person is capable of employment or employment related activities; •The need to make reasonable modifications to policies, practices and procedures when necessary to ensure equal opportunity for people with disabilities; and •The appropriateness of specific assignments in the W-2 program. by a qualified professional or assessing agency. (See 5.5.2 )
The responses also provide basic information to inform case management decision-making until the formal assessment information is received.
When administering the Participant Barriers questions as part of the WWP Informal Assessment, the W-2 worker must explain to the applicant or participant the:
Purpose of the Participant Barriers questions; and
Type of follow-up services that may result from providing answers to the questions.
The W-2 worker should explain the Participant Barriers questions using positive language and emphasize how the applicant or participant may benefit from answering the questions.
The W-2 worker must ask each of the Participant Barriers questions; however, the applicant or participant may decline to answer the questions on this page without risk of sanction or case closure. If the applicant or participant declines to answer a Participant Barriers question, the W-2 worker must indicate this in WWP by checking the corresponding refused box and move on to the next question.
If the applicant or participant indicates that any of the issues identified on the P articipant Barriers page may impact their ability to participate in W-2, the FEP must document the:
Barrier in WWP and refer the individual for formal assessment; and
Formal assessment referral date on the corresponding WWP Barrier Details page.
If the individual declines the offer for formal assessment, the FEP must indicate that the referral was declined on the corresponding WWP Barrier Details page.
Due to the potential for safety risks, there are several exceptions to the instructions for the Participant Barriers questions and formal assessment referral specific to the Domestic Abuse Screen questions. The FEP must follow all instructions for administering the Domestic Abuse Screen in Section 5.6.1 .
The WWP Informal Assessment Driver Flow is required to be completed and submitted prior to initial W-2 placement and at each placement change. The WWP Informal Assessment Driver Flow must always reflect the most recent and up-to-date information the W-2 worker has about the participant and their family.
The FEP must revisit the informal assessment inventory as needed and edit the appropriate WWP Informal Assessment pages to document any reported changes as part of the ongoing case management process.
The FEP must also complete and submit the WWP Informal Assessment to aid in identifying potential barriers to gaining or maintaining employment or additional service needs when:
The individual requests to have the WWP Informal Assessment questions reviewed; and
The FEP is considering denying an initial extension for a 24-month placement time limit or the 48-month state lifetime limit and the WWP Informal Assessment has not been completed or updated within 12 calendar months prior to the participant’s 24th or 48th month in an ongoing case. (See 2.10.6.8 )
The FEP may also choose to complete the WWP Informal Assessment when there is reason to believe that reviewing the WWP Informal Assessment questions may help initiate conversation about a potential barrier that is affecting the participant’s ability to work or participate in assigned activities. (See 11.1 )
If the W-2 group is a W-2 Two-Parent Household A W-2 two-parent household is a W-2 Group where both adults: are custodial parents who have a child in common, reside in the same household with their child(ren), meet all W-2 eligibility criteria, are not disabled adults; and are not caring for a severely disabled child in the W-2 Group. , the WWP Informal Assessment must be completed with each parent separately, unless both parents request the WWP Informal Assessment be completed with the other parent present. (See 14.2.1 )
An individual must never be asked to complete the Domestic Abuse Screen while their partner or any other individual is present. (See 5.6.1 )
The WWP Informal Assessment Driver Flow touches on sensitive topics individuals may not feel comfortable discussing in front of their children.
When completing the WWP Informal Assessment, the W-2 agency must inform the individual of available child care options that may be used while completing the driver flow.
If requested, the W-2 agency should assist with connecting the participant to these child care options before completing the informal assessment questions.
The WWP Informal Assessment Driver Flow also includes Notes and Details fields for the W-2 worker to document additional information pertinent to the case management process.
The W-2 worker must never enter confidential information in the WWP Notes and Details fields, with the exception of the Participant Barriers and Family Barriers pages.
The Participant Barriers and Family Barriers pages prompt workers to ask questions about conditions that are considered confidential for purposes of the W-2 program and have security features to restrict access to these pages.
See 4.2.2.1 for a listing of confidential information that must never be entered on WWP pages without the additional security protections.
The educational needs assessment is used to determine if the W-2 applicant or participant needs, or would benefit from, education and training activities including:
A course of study meeting the high school graduation equivalency standards established under Wis. Stat. s. 115.29 (4);
Technical college courses;
Educational courses that provide an employment skill;
English as a second language (ESL) courses;
Adult basic education courses, including but not limited to: literacy skills, remedial math, or reading courses; or
Employer−sponsored training.
The W-2 Wisconsin Works agency is required to conduct an educational needs assessment with all new W-2 applicants and must reassess the participant for education and training needs before making a change in W-2 placement Within the W-2 program, an individual may be placed in up to one of fourteen W-2 placement types, all of which are identified by a CARES W-2 placement code (in parentheses): At Risk Pregnancy (ARP); Custodial Parent of an Infant (CMC); Case Management Denied (CMD); Case Management Follow-up (CMF); Case Management Follow-up Plus (CMF+); Case Management Job-Ready (CMJ); Case Management Minor Parent (CMM); Case Management Noncustodial Parent (CMN); Case Management Pregnant Women (CMP); Case Management Underemployed (CMU); Community Service Job (CSJ); Custodial Parent Trial Employment Match Program (TMP); Noncustodial Parent Trial Employment Match Program (TNP); Stipends for Noncustodial Parents (TSP); and W-2 Transition (W-2 T) . The assessment must:
Identify the applicant or participant’s current educational levels.
Agencies must use a standardized educational assessment tool to determine educational levels if the FEP determines an educational needs assessment is needed. TABE Test of Adult Basic Education , BEST Basic English Skills Test , and TABE/CLAS-E Tests of Adult Basic Education/Complete Language Assessment System-English are standardized educational assessment tools supported in WWP Wisconsin Work Programs .
The FEP must never delay eligibility determination and placement because completion of a standardized educational needs assessment tool is pending. If necessary to ensure timely placement, the FEP must use the best information available from the WWP Education History and Post-Secondary Education pages to fulfill the educational needs assessment requirement at application and inform the initial placement decision and EP.
In some cases, the self-reported information gathered through the WWP Informal Assessment Driver Flow may not be enough to determine current educational levels. When completion of a standardized educational needs assessment tool is necessary to determine or confirm an individual’s current educational levels, the tool must be scheduled and documented in WWP within 30 days of placement. See 6.4 for information on assignment of activities in WWP.
For an individual who has demonstrated reading and math skills through attainment of post-secondary education, a standardized educational assessment tool is not necessary.
Postsecondary education includes completion of any coursework or education beyond high school such as a:
Continuing education certificate;
Associate degree; or
Baccalaureate degree.
If a standardized assessment tool, such as TABE or BEST, has been completed within the prior six months, the agency may use the results of that assessment to determine the individual's current educational level.
Determine the individual's education and training needs.
In making this determination, the FEP Financial and Employment Planner must consider the following:
The information gathered about the individual's current educational levels. The FEP must document this information: On the appropriate WWP Wisconsin Work Programs Informal Assessment pages (Education History, Post-Secondary Education); On the WWP Test Scores Application; and In PIN comments.
The level of education and training necessary to obtain full-time employment in the local labor market. The Department of Workforce Development maintains a website with Wisconsin labor market information . From this website you can link to many useful resources.
See 8.4.1 for a list of education and training resources that can help provide information on in-demand occupations in Wisconsin, required training and experience, and available training and education program.
The individual’s program employment goals.
Program employment goals are shorter-term employment goals that can be achieved through participation in the W-2 program and are part of the EP. (See 6.1.1 )
If the FEP determines that the individual is eligible for W-2 and needs or would benefit from education or training activities, including a course of study meeting the high school graduation equivalency standards established under Wis. Stat. s. 115.29 (4), the education and training activities must be included in the individual’s EP. See 8.3 for additional information on education and training activities.
E XAMPLE : Holly is found nonfinancially and financially eligible for W-2. During the WWP Informal Assessment, Holly explained that she has not completed high school. Holly also tells the FEP she has had several brief jobs as a short-order cook and her long-term employment goal is to become a manager of a restaurant. The FEP determines that a CSJ Community Service Job placement would be best for Holly. Holly's initial EP includes activity hours for completing a TABE testing. After completing the first week, she is assigned to 30 hours per week at a work experience site that combines food preparation experience with culinary skills training, and eight hours per week of tutoring to prepare her for her GED General Education Diploma .
If the applicant or participant refuses to complete an educational needs assessment, such as the TABE Test of Adult Basic Education , and there is no other information available as to the individual’s current math and reading comprehension level, the W-2 agency may proceed to work with the individual as though there are no literacy or numeracy barriers.
Career assessment is a broad spectrum of assessment tools that W-2 agencies can use to help individuals learn more about their work styles, skills, and interests.
The W-2 agency must offer career assessments to all applicants and participants. However, career assessments are not required to be completed as a condition of eligibility for the W-2 program.
An applicant or participant may decline completing a career assessment for any reason.
Career assessment results can be used to:
Define a career path;
Assign meaningful activities;
Highlight strengths;
Identify training needs; and
Match the individual to employment opportunities.
More than one tool may be required to capture the three required elements:
Work styles represent personality and temperament factors that influence how someone works, such as preferences for working with others or independently. Work style-focused career assessments can demonstrate the individual’s attitudes and job readiness.
Skills represent a person’s competency to perform tasks which can improve with training and experience (e.g., computer programming). Skills-focused career assessments can include knowledge, aptitude, and ability. Skills can relate to a particular occupation, as typically listed in a job announcement to describe the tasks of a position.
Interests represent activities individuals like or dislike doing. Interest-focused career assessments help individuals identify work-related interests and find the types of careers that match.
Do not use educational needs assessment tools in place of career assessment tools. Educational needs assessment tools should be used in tandem with career assessment tools to identify the education and training needed to allow individuals to obtain employment that fits their work styles, skills, and interests.
The results of both assessments complement each other and inform the EP development and assignment of meaningful activities. (See 5.1.2 )
Initial Placement
FEPs must use informal assessment information when determining the initial placement for W-2 applicants. (See 7.1 )
FEPs are required to develop career goals with all W-2 participants using the information available at initial placement.
If an applicant is not ready to identify a specific career field when the EP is initially developed, the focus of the program employment goal may be broadened to a field of interest or an industry sector. (See 6.1.1 )
Because career assessment is not an eligibility requirement, the FEP must never delay eligibility determination and initial placement pending completion of a career assessment tool. The placement decision must be made using the best available information during the application timeframe. (See 1.4.4 ) The EP and W-2 placement may be adjusted later, if needed, when the career assessment results are received.
Timely Career Assessment
Career assessment must be offered to all applicants and assigned as an activity on the initial EP.
If an applicant is new to W-2 or is re-applying and does not have a career assessment documented in WWP Wisconsin Work Programs , a career assessment must be scheduled within 30 days of application and should be completed within 30 days of placement.
If an applicant has completed a career assessment that identifies work styles, skills, and interests, and chooses to remain on the career path indicated by that assessment, or is already working in a career field available in the local labor market, another career assessment does not need to be done.
Using Career Assessments to Inform Case Management
Career assessments and career exploration tools are used to help identify sectors, career pathways, training needs, and employment goals that match the career assessment results.
Career assessment tools can be administered throughout ongoing case management as an individual’s skills, goals, and work readiness may change.
As an EP is developed, it is important to consider how the program employment goals fit into the applicant’s or participant’s long-term career plan. The EP should identify any goals that are part of the individual’s long-term career plan. (See 6.1.1 )
If a participant does not have a career assessment documented in WWP Wisconsin Work Programs , the career assessment must be scheduled within 30 days of an EP review and should be completed before the next EP review.
To document the career assessment in WWP, the FEP must:
Assign Career Assessment as an activity on the EP using one of the following activity codes. (See 6.4.1 )
Activity Code Assignment Scenario UC – Upfront Career Planning For applicants who receive up-front career planning services geared toward assessment of their career interests and guidance in the career planning process. This activity must be ended at time of W-2 placement. CE – Career Planning & Counseling For participants who receive career planning and counseling services geared towards assessment of their career interests and guidance in the career planning process. OC – Occupational Testing For participants engaged in occupational testing related to employment. For example, some employers may require a typing test for a clerical position.
Post career assessment results on the Career Assessment page in WWP, including related occupations and how the career assessment results are being applied to the EP and activities. The FEP must discuss career assessment results with the individual and give them the opportunity to provide input on their W-2 placement and the activities that are assigned as part of the EP.
Scan assessment results into the participant’s Electronic Case File (ECF) using code WVAS.
If the applicant or participant declines to complete a career assessment, the worker must document that in PIN Comments.
A formal assessment is the process of establishing the:
Extent and severity of any disabilities or other conditions (e.g., domestic violence, learning needs, need to care for disabled child) that may interfere with normal functioning in an employment setting or with an individual's ability to meet W-2 Wisconsin Works program requirements;
Effect of a disability or other potential Barrier Something that acts to hinder or restrict employment opportunities. on the Individual's capacity to obtain and maintain Unsubsidized Employment Employment for which a W-2 agency provides no subsidy to the employer, including self-employment and entrepreneurship. There are three placement types under this definition: Case Management Follow-up (CMF), Case Management Follow-up Plus (CMF+), and Case Management Underemployed (CMU) , participate in employment-related activities (e.g., work training activities or education), or otherwise meet W-2 program requirements;
Need for supportive services, accommodations, auxiliary aids, or communication assistance;
Conditions under which the person is capable of employment or employment related activities;
Need to make reasonable modifications to policies, practices, and procedures when necessary to ensure equal opportunity for people with disabilities; and
Appropriateness of specific assignments in the W-2 program.
The formal assessment process may include gathering information about the participant from one or more qualified assessment agencies or individuals.
A FEP can determine the need for a formal assessment at any point; however, a formal assessment must be offered within 30 calendar days of any of the following situations:
An individual presents medical or other information, including their own statement that indicates they may have a disability or other barrier to participation in the W-2 program or employment; or
A W-2 agency staff or contractor observe behavior that indicates the need for a formal assessment.
The FEP must offer a referral for a formal assessment in any of the following situations:
A participant is placed in a W-2 T W-2 Transition position. Participants placed in W-2 T must have a formal assessment scheduled and documented on the EP within 30 calendar days of placement into W-2 T; and
The results of the WWP Wisconsin Work Programs Informal Assessment indicates a need for further evaluation for identification of a disability or other barrier to participation in the W-2 program or employment.
Note : When a participant is referred for a formal assessment based on the information discussed during the WWP Informal Assessment, any relevant information must be shared with the assessing agency if the participant agrees to sign a release of information.
When offering a formal assessment, the FEP must:
Document the formal assessment referral date on the WWP Participant Barrier Details or in the Family Barriers page;
Open a FA -- Formal Assessment Pending status for participants who agree to a formal assessment (see 6.4.1 ); and
Have a formal assessment activity scheduled and documented on the EP within 30 calendar days of the referral date indicated on the corresponding WWP Participant Barrier Details or Family Barriers page.
The FEP can document the results on the Participant Barriers Details page without having to add an activity on the EP when the individual:
Has an acceptable previously completed formal assessment; or
Obtains a formal assessment without informing the FEP that they scheduled the appointment.
FEPs should consider a formal assessment acceptable if completed within one year prior to the WWP Informal Assessment or W-2 T placement. It may be necessary for the W-2 agency to follow-up with the agency or individual who completed the assessment to interpret the assessment results and determine if any new treatment is being explored.
If the prior formal assessment results have an expiration date that indicates the results are no longer valid or there is reason to believe the formal assessment information does not reflect the participant’s current circumstances, then a new formal assessment must be completed.
Results from a prior formal assessment may only be used if the assessment:
Contains the necessary elements (see 5.5.3 ); and
Is relevant to the employment barrier in question.
For example, if a formal assessment completed eight months ago evaluated the need for AODA services, but the potential employment barrier indicated in the WWP Informal Assessment relates to learning needs, then a new formal assessment must be completed.
The FEP must use the W-2 Formal Assessment Agreement (2565) to help explain the purpose of the formal assessment and the type of follow-up services and activities an individual may receive by completing it.
The FEP should strongly emphasize how the applicant or participant can benefit from completing the formal assessment process. The FEP must explain that assessment results will enable the individual and their FEP to make informed decisions about:
Their W-2 placement;
Their employment goals and the activities that will help reach those goals;
Their ability to engage in training and education; and
Any special services and work site accommodations they may need.
The applicant or participant must indicate at the bottom of the agreement their decision to complete or decline a formal assessment.
When a formal assessment is pending, the FEP must use the best information available to initially place an individual in an employment position.
Participating in a formal assessment may be counted as participation in an employment position. The FEP must document all formal assessment information in WWP utilizing the:
WWP Participant Barriers and Family Barriers pages;
Formal Assessment Status; and
Employability Plan (EP), including PIN comments, as appropriate.
Within 30 days after receiving the results of the formal assessment, the FEP must:
Make necessary adjustments to the participant’s placement; and
Revise the EP Employability Plan based on the formal assessment.
The services and accommodations that are recommended in the formal assessment must be incorporated into the participant’s EP. This may include:
Obtaining needed medical treatment or counseling;
Receiving needed services from other providers in the community;
Ensuring participants have the necessary services, reasonable modifications and accommodations to successfully engage in assigned W-2 activities; and
Working with employers to put needed accommodations into place for participants making the transition to unsubsidized employment.
As part of the process of revising the EP, the FEP must:
Provide the participant with a written description of any needed services, activities, and reasonable modifications or accommodations using the form, Services and Accommodations To Help You Do Your W-2 Activities (2564) .
If the FEP does not incorporate all of the recommended accommodations or modifications into the participant’s EP, the FEP must document on the corresponding WWP Participant Barrier page the reason(s) the recommendation(s) were not incorporated. Any placement change based on a formal assessment must also be discussed with the participant and the participant’s EP must be updated accordingly.
Advise the W-2 education, training, or work site providers of any needed reasonable modifications or accommodations to the W-2 education, training, or worksite.
The W-2 agency must monitor the participant’s W-2 education, training, or work site to ensure that previously specified services, modifications, or accommodations identified in the EP are provided.
A formal assessment must be completed by one or more qualified assessing agencies or individuals.
A professional qualified to perform a formal assessment may include a:
Medical or mental health professional;
Social worker;
Psychologist;
Neuro-psychologist;
Division of Vocational Rehabilitation counselor; or
Similar qualified assessing agency or individual.
To be considered a qualified assessing professional, the agency or individual must demonstrate:
A competency or successful completion of training in the appropriate field and be certified by an appropriate accreditation organization; and
An understanding of the objectives of the assessment based on W-2 referral information, the initial interview, and stated purpose of the evaluation.
The qualified assessing agency must provide an individualized written assessment that enables the FEP Financial and Employment Planner to adapt W-2 Wisconsin Works activities to accommodate the needs of the participant. The assessment must include, at a minimum, the following elements:
Personal conditions/diagnosis that impact ability to function in activities of daily living and the ability to perform work;
Functional abilities;
Functional limitations related to employment and employability, and implications of those limitations on finding and maintaining employment;
General aptitude/cognitive level (applicable for formal assessments related to learning needs and traumatic brain injury);
Areas of deficit;
Range of recommended reasonable modifications and accommodations /assistive technology for the participant’s EP Employability Plan (i.e., both work training under W-2 and in unsubsidized employment);
The ability to engage in training and education;
Recommended reassessment date; and
Summary of findings, including rationale for any disability determinations/diagnosis, prognosis, and recommendations for additional services, as appropriate.
The FEP must offer to assist the participant in selecting the appropriate assessing agency or individual.
Participants identified as being at-risk for two or more disabilities or conditions may need to be referred for multiple assessments.
Participants whose WWP Informal Assessment results indicate the potential for a particular disability or condition must be referred to an appropriate provider for formal assessment. Once completed, all formal assessment information must be documented on the WWP Barrier Details page .
The process for gathering formal assessment information will vary depending on the medical condition or employment barrier being addressed:
Medical condition or employment barrier type Process for gathering formal assessment information Learning or cognitive disability The case worker may need to specify in writing to the assessing agency what type of information is needed. This may include: A specific diagnosis; Test findings that document both the nature and severity of the disability; Any limitations to learning or other major life activities resulting from the disability and the degree to which it impacts the individual in the context of learning; The impact the diagnosed learning or cognitive disability has on a specific major life activity; or Specific recommendations for accommodations as well as an explanation as to why each accommodation is recommended. Mental health condition or AODA Alcohol and Other Drug Abuse Assessment information may be gathered using the Mental Health Report form (126 ) . If the assessment information is collected through other methods such as a written evaluation developed by the assessing agency, it is important that the document covers the same content as the Mental Health Report to ensure that the caseworker is receiving adequate information to make case management decisions with the participant. Other types of medical conditions Assessment information may be gathered using the Medical Examination & Capacity form (2012) . Conditions that can be appropriately documented with the Medical Examination & Capacity form include, but are not limited to: Short-term medical conditions and injuries that may require surgery, medical treatment, or physical rehabilitation; Pregnancy; Long-term medical conditions such as multiple sclerosis, fibromyalgia, or arthritis; and When a participant presents themselves as unable to participate due to a medical problem(s) but is unable or unwilling to articulate the medical condition. Barrier related to the care for another household member The Need to Care for Disabled Family Member form (10786 ) must be used to gather the needed information for a formal assessment. (See 7.4.2 ) Although the information gathered with this form does not contain all of the required necessary elements of a formal assessment, it will serve as documentation of the need for the individual to be the sole provider of care when the individual is placed in a W-2 T W-2 Transition and assigned to care for another member of the W-2 Group An adult custodial parent, all dependent children with respect to whom the individual is a legal custodial parent and all minor children with respect to whom the adult individual’s dependent child is a custodial parent. W-2 Group includes any non-marital co-parent or any spouse of the individual who resides in the same household as the individual and any minor children with respect to whom the spouse or non-marital co-parent is a custodial parent. W-2 Group does not include any person who is receiving cash benefits under a county relief block grant program. This is also referred to as the W-2 Assistance Group (W-2 AG) who is ill or incapacitated.
FEPs should record family barriers, including caretaking responsibilities, on the Family Barriers page in the WWP Wisconsin Work Programs Informal Assessment and document non-confidential information in PIN comments.
When a participant has both a mental health condition and another type of medical condition and both conditions are potential barriers to employment that require formal assessment, the agency may need to request that the Mental Health Report (126) and the Medical Examination & Capacity form (2012) are both completed by the appropriate service providers.
When obtaining formal assessment information for a participant with a medical or mental health condition, the W-2 Wisconsin Works agency should first consult with any providers treating the participant for the condition.
If documentation provided does not contain information needed to determine an appropriate placement or necessary accommodations for the participant, the W-2 agency may refer the participant to another service provider for an independent assessment. (See 5.5.3 )
If assessment information is gathered from multiple sources, and the information about the medical condition or the recommended services or accommodations needed conflicts, the agency should use the information from the provider who has provided an independent assessment.
If a participant has multiple service providers for different medical conditions and they provide different opinions about the accommodations needed, the FEP Financial and Employment Planner must assign activities and provide needed accommodations based on both assessments.
The W-2 agency is responsible for paying for the participant’s needed assessment costs when not covered by a third-party source, such as Medicaid.
Under the ADA Americans with Disabilities Act of 1990 , an individual cannot be required to disclose a disability or be required to participate in a separate program for individuals with a disability. W-2 Wisconsin Works agencies must comply with this federal law when assigning activities to W-2 participants.
A participant must be given the opportunity to disclose a disability or other barrier Something that acts to hinder or restrict employment opportunities. to participate in the W-2 program or employment before payment reductions are imposed.(See 11.1 and 11.2.2.1 )
The following W-2 policies provide these assurances to participants:
W-2 payment reduction cannot be imposed on a participant for declining to complete a formal assessment.
A participant placed in a W-2 T or CSJ who has agreed to and is referred for a formal assessment may not receive a payment reduction for any assigned activity until: The formal assessment results are received by the W-2 agency and the formal assessment activity has been ended on the EP; or The W-2 agency has determined that the participant will not comply with the formal assessment referral (see 5.5.8.2 ) and the status and/or activity has been ended.
After the formal assessment activity has been completed on the EP and the FEP Financial and Employment Planner , in consultation with the participant, has made necessary adjustments to the participant’s EP Employability Plan , the individual may receive a payment reduction for failing to participate in assigned W-2 activities without good cause. This may include an activity recommended by the qualified assessing agency such as mental health counseling or physical therapy.
The participant’s self-report of a barrier, or a service provider’s statement as to a participant's the inability to participate which does not meet the definition of a formal assessment, is not sufficient by itself to confirm the existence of a barrier.
However, this information must be considered as part of the process of assessing for barriers to participation in W-2 Wisconsin Works or employment. The agency must use this information in conjunction with a formal assessment and other substantiating information (e.g., behavioral cues, low TABE Test of Adult Basic Education score, pattern of nonparticipation without good cause) to confirm the existence of a barrier.
EXAMPLE : Jean submits an application for W-2. During the initial informal assessment meeting, Jean explains that she cannot engage in any type of W-2 activities because she has severe back pain. The FEP explains to Jean that a formal assessment is needed in order to fully understand how Jean’s medical condition affects her ability to participate in W-2.
Together, the FEP and Jean review the W-2 Formal Assessment Agreement and Jean indicates at the bottom of the agreement that she will obtain a formal assessment. The FEP gives Jean the Medical Examination & Capacity form (2012) to bring to her physician and follows up with a phone call to Jean’s physician to explain what the form is and why a full formal assessment is needed.
Meanwhile, the FEP has all of the needed documentation and verification to determine eligibility for W-2 and places Jean in a W-2 T W-2 Transition while waiting for the results of the formal assessment.
If the participant declines a formal assessment and the participant’s barrier is not yet confirmed, the W-2 agency should proceed to work with the individual as though they do not have a barrier to participation in the W-2 program or employment.
If the participant declines a formal assessment, the FEP must continue to informally assess and revisit the benefits of completing an assessment at each review of the participant’s EP Employability Plan .
E XAMPLE : Naomi is applying for W-2. While completing the initial informal assessment, she tells her FEP that she has chronic migraine headaches and she will have to miss her work activities whenever the headaches flair up. The FEP explains to Naomi that a formal assessment completed by her physician will help determine what services and accommodations will help Naomi with W-2 participation.
Together, the FEP and Naomi review the W-2 Formal Assessment Agreement. After reviewing the agreement, Naomi states that she does not want to obtain a formal assessment and she indicates on the agreement that she is declining to complete a formal assessment. As a result, the FEP has no substantiating information about Naomi’s migraines to determine the extent to which Naomi’s medical condition will impact her ability to participate and no information regarding the types of services and accommodations Naomi needs.
Without additional information, the FEP must proceed to work with Naomi as though she does not have a barrier to participation in the W-2 program or employment.
The FEP should continue to watch Naomi’s case closely for a pattern of nonparticipation without good cause and re-offer a formal assessment when appropriate.
Completion of a formal assessment for W-2 T participants is necessary to make the determination that the individual is not ready for unsubsidized employment and unable to successfully participate in one of the other W-2 employment positions. (See 7.4.2 )
FEPs must offer assistance in obtaining the formal assessment throughout the entire process. The FEP must:
Refer participants to the appropriate assessing agency(s);
Request a formal assessment;
Attend or reschedule an appointment with the assessing agency if an individual has difficulty doing so; or
Obtain a formal assessment from the assessing agency if an individual has difficulty doing so.
FEPs must document in PIN comments any assistance offered or provided in obtaining the formal assessment.
If the individual is making attempts to complete the assessment and has been unsuccessful due to reasons outside of their control, they are cooperating with the assessment referral process and FEPs should continue to offer assistance as needed.
If the W-2 agency has determined that the participant is not complying with the formal assessment referral, the W-2 agency should work with the individual as though they do not have a barrier to participation in the W-2 program or employment and determine an alternate placement.
The Domestic Abuse Screen section of the WWP Wisconsin Work Programs Participant Barriers page helps the W-2 Wisconsin Works worker and Applicant An individual who applies for any service of the W 2 and Related Programs including support services. or Participant An individual who participates in any component of W-2. determine if referrals for a domestic abuse assessment and services are needed. The W-2 agency must also provide space for an individual to voluntarily and confidentially disclose if they are or have been a victim of domestic abuse or are at risk of further domestic abuse.
The W-2 worker must only ask the Domestic Abuse Screen questions if it is safe to do so. An applicant or participant must never be asked to complete the Domestic Abuse Screen while their partner is present, or if there are any other individuals present, including children. In addition, if an applicant or participant voluntarily discloses that they are or have been a victim of domestic abuse or are at further risk of domestic abuse, they are not required to be screened.
If the W-2 worker determines that it is safe to ask the Domestic Abuse Screen questions, the W-2 worker must read aloud the initial statement and each screening question exactly as it is written in WWP.
The applicant or participant may decline to answer any or all of the Domestic Abuse Screen questions without risk of sanction or case closure.
If the applicant or participant declines to answer a screening question, the W-2 worker must indicate the refusal in WWP. The applicant or participant may also decline to complete the remaining questions at any time during the screening. If this happens, the W-2 worker must leave the remaining questions blank.
The applicant or participant may request to revisit the screening questions at any time. The W-2 agency may also administer the Domestic Abuse Screen at any time that the W-2 worker has reason to believe that the participant may need domestic abuse services.
One or more “yes” answers in response to the Domestic Abuse Screen questions may indicate the need to refer the applicant or participant to local domestic abuse and/or sexual assault services for safety planning, counseling, or housing needs. (See 5.6.2 )
A referral to a local domestic abuse and/or sexual assault agency may be made as a result the Domestic Abuse Screen or as a result of the W-2 Wisconsin Works worker’s informal observations and discussions with the participant. (See 5.6.1 )
If a FEP Financial and Employment Planner or other W-2 agency employee identifies a participant, or a participant self-identifies, as a past or present victim of sexual assault or domestic abuse or as being at risk of domestic abuse, the FEP or other W-2 agency employee must provide information on community-based sexual assault and domestic abuse services, including:
Shelter and other programs for battered individuals;
Sexual assault provider services;
Medical services;
Sexual assault nurse examiner services;
Domestic abuse and sexual assault hotlines;
Legal and medical counseling and advocacy;
Mental health care;
Counseling; and
Support groups.
The FEP must discuss these services with the participant and offer a resource list in writing for them to take home.
If a participant would like a referral to counseling or to a supportive service provider, the FEP or other W-2 agency employee must provide one to an appropriate local agency.
The participant may not be penalized for declining or opting out of the referral.
The FEP must make the individual's case confidential in CWW when the individual is a victim of or is under the threat of domestic violence or other physical harm. (See 4.5.2 )
When developing or modifying the EP Employability Plan , the FEP Financial and Employment Planner must take into consideration the results of the Domestic Abuse Screen (see 5.6.1 ) and any follow-up assessment information to ensure the participant can safely engage in assigned W-2 Wisconsin Works activities without risk of violence from a partner.
The FEP should take into consideration for each activity:
Time of day;
Location;
On-site supervision, etc.
The Mental Health Report (126) and the Medical Examination & Capacity form (2012 ) may be used as a communication tool between SSA Social Security Administration and the W-2 Wisconsin Works agency on SSI Supplemental Security Income or SSDI Social Security Disability Insurance applications.
The forms can be shared with SSA at any point in the application or appeal process as long as the FEP Financial and Employment Planner obtains a written release of information from the participant.
The participant can complete a release of information through either:
A form from the W-2 agency; or
Handwritten note that grants permission for the FEP to contact SSA.
A release of information:
Gives the FEP permission to obtain information from SSA.
Does not give the FEP authority to automatically get appointment letters or decision notices regarding a W-2 participant’s case.
If information contained on either the Mental Health Report (126) or the Medical Examination & Capacity (2012) forms conflicts with SSA’s decision, the FEP may need to follow up with both SSA and the provider to obtain the correct information. Conflicting decisions can be detrimental to participants if, for example, they are completely restricted from activity by the provider and deemed able to work by the SSA.
For more information on assisting a participant with the SSI application process, see 9.5.1 .
The EP Employability Plan consists of four parts:
Goals (see 6.1.1.1) ;
Employments (see 6.1.1.2 );
Activities (see 6.1.1.3 ); and
Supportive Services (see 6.1.1.4 ).
This section of the EP lists goals developed collaboratively between the FEP Financial and Employment Planner and the applicant or participant using assessment results. For each major goal added to the EP, additional smaller steps are added to document specific action steps to reach the major goal.
The four types of goals available on the EP include:
Primary and Secondary Employment Goals:
There are shorter term employment goals that can be achieved through participation in the W-2 program which should be based on the following:
Based on Considerations The applicant’s or participant’s strengths, skills, work styles, interests, and needs. Consideration should be given to the individual’s prior work experience, prior education and training, professional goals, and assessments. What can be realistically planned for. Consideration must be given to all types of activities that may enable the applicant or participant to achieve their goal, including, but not limited to: Job search/job readiness activities; Work experience; Educational activities; and Job skills training and technical college participation. (See W-2 Manual Appendix - Activity Codes) Industry and employment opportunities in the local labor market. The FEP must review relevant labor market data to determine if employment goals align with the local labor market. Wisconsin’s WisConomy and the Job Centers of Wisconsin are excellent resources for labor market information. The Job Centers of Wisconsin Skill Explorer may be used to align participants' skills, interests, and needs with potential occupations. Length of time remaining in the W-2 program. Immediate engagement in meaningful activities positions participants to achieve the best outcomes possible within the time limits of the W-2 program. If the applicant or participant is nearing a time limit, types of activities must reflect an increased focus on transitioning from the W-2 program.
If the applicant or participant is not ready to identify a specific occupation when the goals are initially developed, the focus of the goal may be broadened to a field of interest or an industry sector. Career assessments and career exploration tools should be used to help identify sectors, career pathways, training needs, and family-sustaining employment goals that may match the results of the assessed work styles, skills, and interests.
Other Program Goals:
These are concrete short-term goals or outcomes the applicant or participant must achieve through W-2 participation on the way to reaching their employment goal. This may involve completing education or training courses or acquiring work experience in their field of interest. It may also involve overcoming a barrier to employment through assigned activities such as physical rehabilitation, treatment or counseling.
Long-Term Career Goals:
These goals are part of the individual's longer-term career plan. As the EP is developed, it is important to consider how the program employment goals and Other Program Goals fit into the applicant’s or participant’s longer-term career plan. Many industries have career pathways that enable employees to start in lower-skilled jobs and progress into increasingly higher paying jobs through training (e.g., Certified Nursing Assistant to Registered Nurse).
Personal Goals
Personal goals are additional goals not required for W-2 program participation. They are goals set by the individual that will strengthen the family and empower the individual to achieve their employment goals. Examples of personal goals include:
Addressing child and family relationship problems;
Involvement in support groups;
Moving to a safer neighborhood;
Attending individual or family counseling; and
Purchasing a home.
EXAMPLE : After discussing Neema’s career aspirations and previous experiences, Neema and her FEP identified a primary goal of becoming a mechanic because of Neema’s passion for cars and desire to keep moving during the day. To reach this goal, they decided on a secondary goal to obtain an automative technician certification through a community college course in Neema’s local area. Neema expressed a desire to work on communication in her family and to save for a larger apartment so they added personal goals of budgeting classes and family counseling to Neema’s EP.
This section of the EP lists the applicant or participant’s current employment(s) added from the Work History page in WWP, including average weekly hours. Average weekly hours and an individual’s work schedule must be considered when scheduling other activities to include in the EP.
For Federal Work Participation, these hours count as "Core."
The applicant’s or participant’s program activity plan portion of the EP includes the specific program activities the individual engages in to achieve their primary employment goal. The full list of activities that may be assigned under W-2 can be found in the W-2 Manual Appendix - Activity Codes .
The activity portion of the EP, must include the following detail for each assigned activity:
The activity to be completed;
An activity description to ensure that the applicant or participant fully understands what the activity involves;
The provider of service and activity location;
The activity schedule(s), including a planned begin and end date, the specific days of the week, and the specific number of hours on each day that the activity is assigned; and
Any additional remarks to assist the applicant or participant.
The W-2 agency is expected to provide supportive services to the applicant or participant throughout their participation in the W-2 program to help them complete the activities included in the EP.
Examples of supportive services include, but are not limited to:
Onsite child care;
Education/training funding;
Transportation funding;
Work-related clothing;
Work-related equipment;
Gift cards; etc.
Within 30 days after receiving the results of a formal assessment, the FEP Financial and Employment Planner must:
Make any necessary adjustments to the participant’s placement; and
Revise the EP Employability Plan based on the formal assessment.
The participant’s EP must be modified to include the services and accommodations recommended in the formal assessment to help the participant succeed in a work setting. (See 5.5.1.2 )
An Employability Plan (EP) is a written agreement developed collaboratively between the FEP Financial and Employment Planner and the applicant or participant. During the W-2 Wisconsin Works application period, if the applicant is assigned up-front job search, an RS Resource Specialist may write the initial EP.
The EP is a written document that outlines how an applicant or participant will achieve a specific employment goal or, if appropriate, obtain SSI Supplemental Security Income and/or SSDI Social Security Disability Insurance benefits.
The EP details how the individual will participate in the W-2 program to achieve their goals and how the W-2 agency will assist them.
The agency worker must use the information gathered through the assessment process (See 5.1.1 and 5.1.2 ) to develop the EP around the applicant’s or participant’s:
Strengths, interests, aptitudes, and needs;
Prior education and work history;
Strategies to overcome barriers to employment identified through informal and formal assessment;
Assignment of work and training activities to achieve the employment goal; and
Length of time remaining in the W-2 program. (See 6.1.1 )
Each time an EP is developed or changed, The FEP must:
Fill out the EP page in WWP Wisconsin Work Programs ;
Give the applicant or participant an opportunity to sign the EP; and
Give the applicant or participant a copy of the completed EP.
If the applicant or participant refuses to sign the EP, the agreement is still considered binding because the individual committed themselves to W-2 participation when they signed the W-2 Participation Agreement .
When to develop an EP
The EP must be developed with all:
Applicants assigned to Up-Front Job Search (see 2.9.2 ); and
Participants who are assigned to any of the following: A TEMP Trial Employment Match Program , TSP Stipends for Noncustodial Parents , CSJ Community Service Job , or W-2 T W-2 Transition placement; A CMU Case Management Underemployed , CMF Case Management Follow-up , CMF+ Case Management Follow-Up Plus , CMD Case Management Denied , CMJ Case Management Job Ready , or CMN Case Management Noncustodial Parent placement; A CMC Custodial Parent of an Infant , CMP Case Management Pregnant Women , ARP At Risk Pregnancy , or CMM Case Management Minor Parent placement only in circumstances where the participant has volunteered to participate in activities as part of the W-2 program; and A second parent in a two-parent household who participates in W-2 activities. (See Chapter 14 )
The EP must be developed before placing a W-2 participant into an employment position or case management placement.
See 16.3.4 for information on when to develop Learnfare Case Management plans.
Before placing a W-2 participant in an employment position or case management placement (see 6.1 ), an EP must be developed collaboratively during a meeting between the FEP and the participant. (See 1.4.2.4 )
When the meeting occurs via phone or video call, the FEP must send a signed copy of the final EP to the participant.
When appropriate, the applicant’s or participant’s family members may also provide input. In a two-parent household, a meeting with each parent must be conducted to assess total family strengths and determine which parent is more appropriate for W-2 placement. (See Chapter 14 )
The EP must be developed for a duration of no more than six months. The EP may be updated during that timeframe to reflect any changes in assignment of activities; however, under no circumstances can the FEP change the activities in the EP without first discussing the change(s) with the participant.
If the agency has made repeated and varied attempts but is unable to connect with a participant transitioning from a paid placement to a CMF Case Management Follow-Up or CMF+ Case Management Follow-Up Plus , the agency may change the placement to CMF or CMF+ prior to the EP appointment. (See 7.2.3.5.3 )
When this occurs, the agency must send an updated EP to ensure that the individual has in their possession an EP that aligns with the changes in activities. The EP end date must be 30 days after the date the CMF or CMF+ placement started on the new EP. This will give the participant the option to complete an EP appointment within 30 days or allow W-2 to close for noncooperation with program requirements.
An EP Employability Plan review must occur at a minimum once every six months and be scheduled to occur before the date the EP ends. EP reviews may occur more frequently as needed, particularly if the participant is nearing a time limit.
The purpose of an EP review is to revisit a participant’s goals and assigned activities, and determine if adjustments are needed to help move the participant towards achieving their employment goals.
The EP review must be completed during a meeting (see 1.4.2.4 ) between the FEP and the participant to ensure the EP is collaboratively created. This meeting also ensures that the participant has buy-in to achieving their goals and understands how the FEP and agency will support them.
When an EP review is conducted by phone, a copy of the EP must be mailed to the participant for their signature and returned to the agency. The worker must document in PIN comments how the EP was distributed and the date it was distributed.
If an EP review does not occur before the date the EP is set to expire because the participant missed an EP review appointment without good cause, the W-2 agency must follow the process outlined in 11.5.2 to close the case for noncooperation with program requirements.
W-2 agencies are required to work with local Job Centers to jointly serve persons under the Job Center network delivery model. Working cooperatively with local partner agencies on EP development reduces duplication of effort across work programs and maximizes the resources available to the applicant or participant.
When developing the EP Employability Plan , the FEP Financial and Employment Planner and applicant or participant should incorporate input from other programs the individual is connected with, including but not limited to:
Workforce Innovation and Opportunity Act (WIOA) program;
Division of Vocational Rehabilitation (DVR);
Wisconsin Technical College System (WTCS);
Refugee Assistance Employment and Training Program; and
Other mental health, child welfare safety services, housing, domestic violence, and AODA Alcohol and Other Drug Abuse programs.
Agency workers working with participants interested in exploring other job center programs such as Job Service/Labor Exchange Services, WIOA, and DVR, should reach out to their local job center partners to discuss dual enrollment opportunities for the participant. Any activities included in the W-2 applicant’s or participant’s EP must conform with W-2 policy.
The FEP should consult with other Job Center agencies as appropriate when developing the W-2 EP. However, W-2 agency staff must ensure that a W-2 EP is attached to any jointly developed EP since this is the primary EP document for W-2 applicants or participants.
EXAMPLE : Monica is working with a domestic violence victim program. Her advocate there is helping her find housing. Monica also attends weekly group counseling sessions and brings her daughter to individual counseling sessions every other week. Monica has signed the Authorization for Disclosure of Confidential Information form (10779) to allow her FEP to consult with her DV advocate and counseling professionals as needed. In developing her EP, Monica’s FEP incorporates her housing search and domestic violence activities and reaches out to Monica’s DV advocate and learns that Monica needs a new phone. The FEP provides Monica with a new phone and covers the first month’s phone bill through supportive services.
W-2 participants with a disability may receive employment planning consultation from a DVR counselor without being enrolled in the DVR program. For these W-2 participants, DVR may provide technical assistance in the development of the W-2 employability plan using the recommendations from a disability or vocational assessment. This technical assistance may include:
Recommending work or training activities to help move the participant towards employment in the local labor market; or
Identifying specific disability accommodations or assistive technology to make work or training accessible to a participant.
For W-2 participants enrolled in both W-2 and DVR programs, the W-2 case manager and the DVR counselor should coordinate the W-2 Employability Plan and the DVR Individual Plan for Employment (IPE). (See W-2 Manual Appendix - W-2/DVR Technical Assistance Guide )
Workers must use the following guidance to determine when travel time should be included as part of the assignment of hours.
When two or more activities are assigned for the same day, the travel time (if any) between the two activities may be counted toward hours of participation. Travel time to the first activity and the time spent returning home after the last activity cannot be counted towards hours of participation.
When Employment Search (ES) is assigned, the travel time between interviews may be counted toward hours of participation. Travel time to the first job interview and the time spent returning home after the last one cannot be counted.
The Federal TANF Regulations require states to have work verification procedures for all individuals receiving cash assistance through the TANF program. These procedures apply to all individuals in a:
CSJ Community Service Job or W-2 T W-2 Transition placement;
CMC Custodial Parent of an Infant or ARP At Risk Pregnancy placement who are voluntarily participating in activities; and
CMF+ Case Management Follow-Up Plus placement who are working in unsubsidized employment and must meet federal work participation requirements to be eligible for supplemental payment.
The TANF Regulations are explicit in requiring that all hours of work participation be supervised, documented and verified. (See W-2 Manual Appendix - TANF Work Participation Requirements )
The participant’s work schedule may fluctuate due to the need to make up work hours missed earlier in the week.
The following table outlines how make-up hours should be recorded:
If the participant makes up missed hours: The FEP must: In the same week they were scheduled (Sunday – Saturday) Record the hours in WWP Wisconsin Work Programs under Make-Up hours. Outside the week they were scheduled or not at all Calculate all remaining missed hours as nonparticipation or apply the good cause policy when appropriate. (See 11.2.1 and 11.3.2 )
While not part of the EP Employability Plan , Participation Statuses represent factors that may impact an individual’s EP activity assignments, and must be taken into consideration when developing the EP.
Participation statuses do not have scheduled hours associated with them and do not require participation tracking.
The following are available statuses to report for W-2 Wisconsin Works participants:
Status Report Status When CD – Caring for Disabled Child (Valid for W-2) An individual is providing care to a dependent child with a disability or incapacitation. Documentation of the need for the participant to be the sole provider of care must be provided. See 7.4.2.1 for acceptable forms of documentation. Reporting this status will exclude the participant from Federal Work Participation calculations. CF– Caring for Other Family Member (Valid for W-2) An individual is providing care to an adult W-2 Group member with a disability or incapacitation. Documentation of the need for the participant to be the sole provider of care must be provided. See 7.4.2.1 for acceptable forms of documentation. Reporting this status will exclude the participant from Federal Work Participation calculations. EC – Child Care for Employment Skills Training (Valid for W-2 with a two-year maximum) A W-2 participant is receiving FEP Financial and Employment Planner -authorized child care to enable the participant to engage in voluntary educational and training activities. EI – Employer Intervention Services* (Valid for W-2 and Learnfare) Services are directed at the employer to facilitate the resolution of job retention barriers faced by the participant. These services may include: Enhancing communication channels between the employer and participant; Employer counseling; Providing acceptable worksite accommodations; and Other on-site interventions with the employer. FA – Formal Assessment Pending An individual placed in a W-2 T or CSJ Community Service Job has agreed to and is referred for a formal assessment but has not yet completed the assessment. Participants cannot receive a payment reduction for nonparticipation recorded for assigned activities on days with this status open. (See 5.5.7 ) SD–SS(D)I Advocacy/Application The W-2 participant is in the process of applying for SSI Supplemental Security Income or SSDI Social Security Disability Insurance and the W-2 agency or another provider is providing related services. Examples include meeting with an SSI advocate or attorney, working with the FEP on filling out the SSI forms, attending hearings, etc.
* Note : This status is used to record employer intervention services provided by the W-2 agency. To record employment retention activities required by the participant, use the Job Retention Services (JR) activity code on the individual’s EP.
When determining the initial placement for W-2 Wisconsin Works applicants, FEP Financial and Employment Planner s must use all information gathered from the:
Informal assessment (see 5.2 );
Educational Needs Assessment Educational needs assessments determine if the individual needs, or would benefit from, education or training activities, including a course of study for the granting of a declaration of equivalency of high school graduation. In making this determination, the FEP must consider the following: • The information gathered on the applicant/participant’s current educational levels; • The level of education and training necessary to obtain full-time employment in the local labor market; and • The applicant/participant’s personal employment goals. (see 5.3 );
Any Career Assessment A broad spectrum of assessment tools that W-2 agencies, applicants, and participants use to obtain greater awareness about how an individual’s work styles, skills, and interests can be used to define a career path, assign meaningful activities, highlight strengths, identify training needs, and match the individual to employment opportunities results that identify work styles, skills, and interests (see 5.4 );
Progress made in up-front job search, if assigned (see 2.9.2 ); and
Results of any other Vocational Evaluation/Assessment Assessments which are conducted to help individuals living with a disability establish realistic vocational goals and a plan to achieve them. The vocational evaluation process is designed to assess the unique strengths, resources, and experiences of an individual in order to match that person’s abilities and preferences to appropriate work placements, jobs, or training programs. The process is interactive; the intent is for staff to learn about the participant and the participant to learn about themselves or formal assessments (see 5.1.1 ).
When making initial placements, FEPs must also:
Discuss and review all factors informing placement decision with the applicant;
Never delay placement because a formal assessment is pending (see 5.1.1.2 ); and
Document the reasons for the placement decision in PIN comments.
FEPs must provide ongoing case management including periodic reassessment of an individual’s current placement as circumstances change.
Participants must be placed at the highest level of participation possible.
This chapter outlines the W-2 program placements and their eligibility criteria, participation requirements, time limits, and W-2 services available.
Some placements are specifically for applicants and others are specifically for ongoing participants. The table below provides a brief description of the W-2 placement types.
Placement Types Description TEMP Trial Employment Match Program , CSJ Community Service Job , Prorated CSJ Community Service Job , W-2 T W-2 Transition Placements that provide work experience and training for individuals who have barriers to unsubsidized employment. CMC Custodial Parent of an Infant , ARP At Risk Pregnancy , CMP Case Management Pregnant Women , CMM Case Management Minor Parents Case management placements that acknowledge life circumstances (caring for a newborn, pregnancy, minor parents, etc.) and provide relevant employment supports and W-2 services. CMU Case Management Underemployed , CMF Case Management Follow-Up , CMF+ Case Management Follow-Up Plus , CMJ Case Management Job Ready , CMD Case Management Denied Case management placements related to unsubsidized employment, including follow-up and post-employment services for participants transitioning out of a paid placement. CMN Case Management Noncustodial Parent , TSP Stipends for Noncustodial Parents Noncustodial parent-specific placements.
The W-2 Wisconsin Works program is designed to help individuals prepare for and achieve unsubsidized employment. Ideally, all W-2 participants end up in a placement related to unsubsidized employment.
The following case management placements are related to unsubsidized employment:
CMU Case Management Underemployed – For individuals who are employed when they apply for W-2 (see 7.2.2 );
CMF Case Management Follow-Up or CMF+ Case Management Follow-Up Plus – For participants who obtain unsubsidized employment while in a W-2 placement or through up-front job search (see 7.2.3 ); and
CMJ Case Management Job Ready – For individuals who are unemployed but are ready for unsubsidized employment (see 7.2.4 ).
Participants in these placements receive case management services but do not receive a monthly W-2 cash payment, with the exception of the CMF+ supplemental payment.
Time in a case management placement does not count toward the:
60-month federal TANF Temporary Assistance for Needy Families lifetime limit; or
48-month state lifetime limit.
Participants in a CMU, CMF, CMF+, or CMJ placement are required to cooperate with child support as a condition of eligibility. (See 15.3.1 ) However, they are not required to assign a portion of the child support payments to the state. (See 15.1.1 )
The CMU Case Management Underemployed placement is for applicants entering the W-2 Wisconsin Works program who are working full-time or who are working part-time and have no barriers to full-time employment.
The purpose of the CMU placement is to provide support that helps participants maintain employment and pursue career advancement. This includes applicants with farming and self-employment income, provided they meet other placement criteria.
Participants may continue in CMU provided they:
Continue working;
Have no barriers to full-time employment; and
Meet all financial and nonfinancial eligibility requirements.
FEP Financial and Employment Planner s must not assign a CMU placement to applicants who are marginally employed, for example, working only a few hours per week or inconsistently. Depending on the individual’s specific circumstances, the agency may place a marginally employed applicant in a W-2 T W-2 Transition , CSJ Community Service Job , or pro-rated CSJ placement.
CMU is not for ongoing W-2 participants who find employment. W-2 participants who become employed while already enrolled in W-2 should be placed in CMF Case Management Follow-Up or CMF+ Case Management Follow-Up Plus . (See 7.2.3 )
A participant in the CMD Case Management Denied placement who finds unsubsidized employment may be placed in the CMU placement. FEPs should document this in PIN comments.
The purpose of the case management follow-up service placements, CMF Case Management Follow-Up and CMF+ Case Management Follow-Up Plus , is to support participants to stay employed and advance in their career after they find unsubsidized employment.
W-2 agencies must provide up to 12 consecutive months of follow-up services to individuals who find employment while in W-2. W-2 case management follow-up services can be provided without an additional financial eligibility test. (See 7.2.3.4 )
The following table outlines eligibility for the case management follow-up service placements based on an individual’s W-2 placement and employment status.
Placement W-2 Applicants W-2 Participants CMF (Case Management Follow-Up) Yes – if the applicant finds unsubsidized employment through up-front job search. Yes – if the participant finds unsubsidized employment while in one of the following placements: TEMP (TMP and TNP); CSJ; W-2 T; CMC; or CMJ. CMF+ (Case Management Follow-Up Plus) No Yes – if the participant meets minimum work hours and finds unsubsidized employment while in one of the following placements: TMP; CSJ; or W-2 T.
CARES Client Assistance for Reemployment and Economic Support will close CMF Case Management Follow-Up or CMF+ Case Management Follow-Up Plus cases at the end of 12 months. If a CMF or CMF+ placement lasts less than 12 months, the FEP must document the reason(s) in PIN comments.
If a participant wishes to receive case management follow-up services beyond the 12 consecutive months allowable in a CMF and CMF+ placement, the FEP may change the participant’s placement to CMU Case Management Underemployed if the participant meets financial and nonfinancial eligibility requirements.
Individuals are eligible for CMF services if they gained unsubsidized employment while:
Placed in one of the following paid W-2 placements— TEMP (TMP and TNP), CSJ, W-2 T, or CMC;
Placed in a CMJ Case Management Job Ready placement; or
An applicant in an up-front job search.
When a participant reports starting a new job, the FEP should use the participant’s verbal statement to:
Update the placement to CMF;
Revise the EP Employability Plan ; and
Assign appropriate case management activities.
While waiting for verification, the FEP must collect the following employment details from the participant:
Employer name and address;
Expected start date;
Hourly wage;
Expected weekly hours; and
Any additional relevant employment information.
All verified and unverified information must be recorded on the WWP Wisconsin Work Programs Work History page and the CWW CARES Worker Web Employment page. Once verification for unverified employment information is received, the FEP must update both systems to reflect the verified employment.
See the following table for placement guidance based on employment hours and barriers.
Scenario Typically Appropriate Placement Participant is working 30 hours or more per week in unsubsidized employment. CMF Participant is working in unsubsidized employment and meets the minimum work hours for their family type. CMF+ (see 7.2.3.5.2 ) Participant is working less than 30 hours per week in unsubsidized employment and has barriers to increasing their work hours. Prorated CSJ (see 7.4.1.5 )
EXAMPLE : Christina and her husband Jordan receive Wisconsin Shares. Christina is in a CSJ placement and Jordan is attending classes to complete his general education diploma. Christina has a history of employment; however, she has been out of the workforce in the last year due to pregnancy complications. Christina has a high school diploma and valid driver’s license with access to a vehicle. Christina is interested in nursing and the FEP refers Christina for CNA job skills training. Christina successfully obtains her CNA license and secures a position as a CNA working 35 hours per week at $15 per hour. The FEP completes an informal assessment and determines that a CMF placement works for Christina. Christina is not eligible for the CMF+ placement because working 35 hours per week does not meet the minimum work hours of 55 hours per week for her family type.
The W-2 agency must offer case management follow-up services for up to 12 consecutive months. During the 12-month period, the FEP must:
Provide individualized services to support job retention and career advancement; and
Maintain regular contact with the participant, in their preferred format, at least once each month.
Activities provided through case management services may include:
Job Retention Services (JR);
Literacy Skills (LS);
Vocational Literacy Skills (VL);
Vocational Adult Basic Education (VA);
English as a Second Language (EL);
Vocational English as a Second Language (VE);
Adult Basic Education (BE);
General Educational Development (GE); and
High School Equivalency Diploma (HE).
If a CMF or CMF+ participant loses their job or experiences a reduction in work hours, the FEP must reassess the individual’s circumstances to determine whether additional barriers exist.
FEPs should use the following table when determining the best placement for a CMF or CMF+ participant who experiences a job loss or reduction in hours.
A CMF or CMF+ Participant Additional Barriers are Identified Appropriate Placement* Is ready to obtain additional employment. No CMJ (See 7.2.4 ) Has a reduction in work hours that results in the individual being unable to meet the minimum work hours for the family type. No CMF Has a reduction in work hours that results in less than 30 hours per week. Yes – Assign activities specifically designed to help the participant increase their work hours or obtain full-time employment. Prorated CSJ (See 7.4.1.4 ) Loses their job. Yes – Offer a formal assessment and provide appropriate services based on the participant’s needs. TEMP, CSJ, or W-2 T
*These are typically appropriate placements. FEPs must discuss placement determinations with the participant and consider their individual needs and employment goals.
Note : In order for a participant to move from a CMF or CMF+ placement to a TEMP, CSJ, prorated CSJ, W-2 T, or CMJ placement, the participant must meet all financial and nonfinancial eligibility requirements.
EXAMPLE 1 : Barbara is in a CMF placement and has been working full-time for 90 days as a cashier. Barbara informs her FEP that her work hours have been reduced to part-time. The FEP verifies that Barbara’s hours have been reduced to part-time due to the end of the holiday season. The FEP meets with Barbara, completes an informal assessment, and determines that she meets nonfinancial and financial eligibility to move from a CMF placement to a prorated CSJ placement. Barbara enjoys working with customers and would like to work as a receptionist. The FEP places Barbara in a 1/2 CSJ placement and assigns activities that will help her find other full-time employment, including a workshop on data entry. The FEP arranges for Barbara to attend the on-site computer lab on her off hours to work on her typing skills. The FEP provides Barbara with information on an upcoming job fair hiring for various entry-level positions and contacts Barbara every other week to discuss her progress.
EXAMPLE 2 : Monique is in a CMF placement and began a new job as a CNA. Monique was placed on second shift and is scheduled to work every other weekend. After 30 days, Monique contacts her FEP and explains that her hours have reduced from 40 hours per week to 24 hours per week. The FEP schedules Monique for an appointment and requests that she bring her paystubs. Monique attends her appointment and submits paystubs showing an average of 25 hours worked per week. They discuss the situation and Monique explains that she requested not to be scheduled in the weekend rotation. After completing an informal assessment, the FEP determines that Monique has no new barriers to increasing her work hours and the CMF placement is still the best fit for Monique’s circumstances.
Participants may transition from a paid placement to CMF or CMF+ if they find unsubsidized employment and continue to meet all nonfinancial eligibility requirements. A financial eligibility test is not necessary when determining CMF and CMF+ eligibility.
EX AMPLE 1 : Caitlyn has one child and was in a CSJ placement for four months before starting a new job that pays $10 an hour for 40 hours per week. Based on her W-2 Group size and income level, Caitlyn continues to meet all of the nonfinancial eligibility requirements (see 2.2.1 ) and is therefore eligible for case management follow-up services. At her EP appointment, the FEP verifies Caitlyn’s employment and wages and changes her placement to CMF.
E XAMPLE 2 : Ben has custody of his two minor children, has been working as a mechanic for six months, and is in a CMF placement. During Ben’s six-month eligibility review conducted over the phone, Ben tells the FEP that his former spouse regained custody of both children last month. Because Ben no longer meets the W-2 nonfinancial eligibility requirements, Ben’s FEP ends Ben’s CMF placement, closes his W-2 case, disenrolls him from WWP Work Programs, and enters in PIN comments the reason why Ben’s CMF placement is less than 12 months.
The CMF+ placement is for participants who:
Find employment while in one of the following W-2 employment positions: TMP, CSJ, or W-2 T; and
Meet the minimum work requirements. (See 7.2.3.5.2 )
Participants who were previously in CMC, CMJ, or CMU and find employment are not eligible for CMF+, but may be eligible for CMF.
Participants who are in CMF and increase their work hours to meet the minimum work requirements may be eligible for CMF+ if their placement preceding CMF is a TMP, CSJ, or W-2 T.
A participant placed in CMF+ receives follow-up services and a monthly $50 supplemental payment. (See 7.2.3.5.1 )
Supplemental payments are provided as a monthly payment to W-2 participants who are working in unsubsidized employment for a minimum number of work hours and are in a CMF+ placement. (See 7.2.3.5.2 )
A participant must be in the CMF+ placement for one full W-2 participation period from the 16th of a month to the 15th of the next month in order to be eligible for a monthly supplemental payment. A participant in CMF+ may receive up to 12 supplemental payments.
The supplemental payment is a $50 monthly payment, and it is not prorated when a placement change occurs in the middle of a W-2 participation period. Similarly, a supplemental payment must not be deducted for:
Recoupments;
Hourly sanctions;
Learnfare sanctions; or
Drug Felon sanctions.
After one full participation period in CMF+, CARES will generate a $50 supplemental payment in the form of a paper check or by EFT following the W-2 payment cycles. (See 10.2.1 )
Like W-2 payments, a participant may request that the W-2 agency hold supplemental payments. (See 10.3.1 ) In addition, the W-2 agency may intercept a supplemental payment in emergency situations. (See Chapter 2 of the Payment Issuance Guide )
The CMF+ placement is for W-2 participants who are working in unsubsidized employment and meet the following minimum work requirements based on their family type:
Family Type Minimum Work Requirement Single-parent family with a child under the age of 6 At least 20 hours per week of unsubsidized employment. Single-parent family whose youngest child is age 6 or older At least 30 hours per week of unsubsidized employment. Two-parent family not receiving federally-funded child care At least 35 combined hours per week of unsubsidized employment. Two-parent family receiving federally-funded child care At least 55 combined hours per week of unsubsidized employment.
Participants working less than 30 hours per week in unsubsidized employment may be eligible for a prorated CSJ (see 7.4.1.5 ), CMF, or CMF+. In determining the most appropriate placement, the FEP must assess the participant’s:
Work hours;
Abilities to increase their work hours; and
Family type.
For initial verification, the FEP must follow the procedures outlined in 7.2.3.1 for documenting and verifying employment.
The FEP must not change a participant’s placement to CMF+ until verifying hours of unsubsidized employment. However, the FEP may change the placement to CMF until verification is received. When verification is received, the FEP must update employment information and reassess the participant for CMF+. (See 7.2.3.5.2 )
The FEP must meet with CMF+ participants to conduct a W-2 eligibility review at least once every six months and collect at least two consecutive weeks of pay stubs. (See 1.4.2.4 )
Months of participation in CMF+ count towards the 12-consecutive month participation limit for case management follow-up services. (See 7.2.3 ) Each time a participant is placed in CMF or CMF+, the 12-consecutive-month participation limit resets to zero. Uninterrupted months of participation in CMF and CMF+ are counted towards the 12-consecutive-month participation limit for follow-up services.
The CMF and CMF+ participation limit is not to be confused with state and federal time limits for assistance. (See 7.2.3.5.5 )
EXAMPLE 1 : Raleigh and Jules have two children, ages 2 and 3. Raleigh is in a TMP placement and was hired on permanently by their employer, working 40 hours per week. Jules stays home with the children and the family does not receive Wisconsin Shares. After verifying employment and eligibility, the FEP places Raleigh in a CMF+ placement because they are working above the minimum work hours for their family type. Raleigh is eligible for up to 12 consecutive months of CMF+ services because this is the start of a new participation in CMF+.
EXAMPLE 2 : Amara is a single parent in a W-2 T placement and has a 10-year-old child. Amara gets a job working 25 hours per week that can accommodate her physical therapy sessions from a recent knee injury. Amara and her FEP do not identify any barriers to increasing her work hours and her employer wants to provide full-time work after she completes physical therapy. Because Amara does not want to use up her W-2 time limit and participate in W-2 activities, Amara’s FEP places her in a CMF placement.
Amara is not eligible for a CMF+ because she does not meet the minimum work hours for her family type and does not have any barriers to increasing her work hours to be eligible for a prorated CSJ.
After three months, Amara reports that she completed physical therapy and is working 32 hours per week. The FEP places Amara in CMF+ because she now meets the required work hours for her family type. Amara is only eligible for up to nine more months of CMF+ services because her participation in CMF and CMF+ was uninterrupted.
EXAMPLE 3 : Mako is a single parent in a CSJ placement and has two children, ages 4 and 6. After a few weeks, Mako gets a job working 30 hours per week. The FEP places Mako in CMF+ because she is working the minimum work hours for her family type. After two months, Mako reports that she lost her job because her employer went out of business. The FEP places Mako in CSJ. After three months, Mako gets a new job working 40 hours per week. The FEP places Mako back in CMF+. Mako is eligible for up to 12 consecutive months of CMF and CMF+ services because the participation limit reset to zero when her prior CMF+ placement was interrupted.
Receipt of a supplemental payment does not count towards the state 48-month lifetime limit (see 2.10.2 ) or the federal 60-month lifetime limit (see 2.10.9 ).
Participants in the CMF+ placement are exempt from the requirement to assign child support payments to the state as a condition of eligibility (see 15.1.1 ); however, all parents in the W-2 Group must cooperate with child support in order to be eligible for CMF+ (see 15.3.1 ).
The Case Management for Job-Ready Individuals (CMJ) placement is for unemployed individuals who are job-ready and able to obtain and keep unsubsidized employment. The goal of the CMJ placement is to quickly connect job-ready individuals to employment.
CMJ is only appropriate for W-2 Wisconsin Works applicants, and in limited situations, participants moving from the following placements:
Case management follow-up (CMF);
Case management follow-up plus (CMF+);
Case management underemployed (CMU); and
Custodial Parent of an Infant (CMC).
Before assigning a CMJ placement to a W-2 applicant, the FEP Financial and Employment Planner must conduct an informal assessment and educational needs assessment. (See 5.1 - 5.3 )
In most instances, potential CMJ participants may be assigned to up-front job search activities. (See 2.9.2 ) Applicants who participate in these activities in a good faith effort to obtain employment and are assessed as job-ready are appropriate for a CMJ.
In certain cases, an applicant may be appropriate for CMJ without having completed up-front job search. For example, the applicant may have experienced a short-term barrier such as lack of child care or housing instability that was resolved but not within the 12 days prior to placement. These individuals may not have been assigned up-front job search, but still may be appropriate for the CMJ placement.
Conversely, not all applicants assigned to up-front job search are appropriate for a CMJ. For example, the W-2 agency may learn that the applicant has significant barriers that make it difficult for the applicant to obtain employment within the next 30 days or no jobs are available that align with their skills and experience. These individuals must be placed in a W-2 paid placement.
CMJ is generally only available to W-2 applicants. However, in limited situations, participants in certain placements may move into CMJ if they meet CMJ eligibility criteria. (See 7.2.4.3 ) The table below outlines CMJ eligibility based on prior placement.
W-2 Placement Eligible to move into a CMJ Community Service Job (CSJ, CSJ 1/3, CSJ 1/2, CSJ 2/3) No W-2 Transitions (W-2 T) No Custodial Parent Trial Employment Match Program (TMP) Noncustodial Parent Trial Employment Match Program (TNP) No Custodial Parent of an Infant (CMC) Sometimes The CMC participant may be considered for a CMJ placement if they were not in an ARP, CSJ (including partial CSJ), or W-2 T placement prior to going into CMC. At-Risk Pregnancy (ARP) No Case Management Follow-up (CMF) Case Management Follow-up Plus (CMF+) Case Management Underemployed (CMU) Yes Individuals in a CMF, CMF+, or a CMU may be considered for a CMJ placement. However, moving from CMU, CMF+, or CMF to CMJ is only appropriate for individuals who are able to find and keep full-time employment. Case Management Minor Parents (CMM) Sometimes The minor parent may be considered for a CMJ placement if the minor parent turns 18, has a high school diploma or equivalent, and a work history. Case Management Pregnant Woman (CMP) No Case Management Noncustodial Parents (CMN) Stipends for Noncustodial Parents (TSP) Sometimes The NCP Noncustodial Parent may be considered for a CMJ if they become a custodial parent. Case Management Denied (CMD) Sometimes The CMD participant may be considered for a CMJ if the extension denial reason was that the local labor market has jobs the participant could have gotten. (See 2.10.6.3)
To be placed in a CMJ position, an individual must meet all the following:
Be willing to work (all W-2 applicants are presumed willing to work);
Have a recent or steady employment history; and
Not have barriers to work that cannot be addressed within 30 days through W-2 services.
When considering recent or steady employment, the FEP must consider the types of work performed, duration of any job, and reasons for leaving the job. If the applicant’s employment history is consistent with some long-term employment, a CMJ placement is appropriate.
The FEP must conduct an informal assessment to determine whether barriers to maintaining employment can be addressed with W-2 services and resolved within 30 days.
See Chapter 9 for more information on barriers that the W-2 agency can address through W-2 services.
Individuals who have more significant barriers, such as family crises, legal issues, housing instability, or serious physical or mental impairments, that cannot be resolved within 30 days are not appropriate for CMJ.
If the FEP identifies barriers that can be addressed through W-2 services so that the individual is ready for immediate employment, the barriers and the services to address those barriers must be documented on the appropriate WWP Wisconsin Work Programs pages.
EXAMPLE 1 : Maria applied for W-2 and met with the Resource Specialist. She did not have child care available when she applied, so she was not assigned up-front activities. When Maria later met with her FEP, she reported that she now had certified child care for her two children, ages 3 and 4. Maria’s informal assessment indicates that she has a high school diploma, no reported barriers to employment, and recent work history that has prepared her for entry-level jobs in the local labor market. Based on the results of the informal assessment, Maria’s FEP determines that Maria is job-ready and appropriate for a CMJ placement.
EXAMPLE 2 : Hussein applied for W-2 and completed an informal assessment with his FEP. The assessment showed that Hussein has a high school diploma, a welding certificate from a local technical college, and five years of experience working at a machine company. However, Hussein has been unemployed for the past year after a work related injury to both knees. Although his employer-covered physical therapy treatment has ended, Hussein reports ongoing knee pain and is unsure if he can return to physically demanding work. Based on the results of the informal assessment and the concerns about his physical limitations, the FEP places Hussein in a W-2 Transition (W-2 T) placement and refers him for a vocational assessment to help determine next steps. His FEP also reaches out to the DVR worker who they have referred people to previously, to understand how DVR can support Hussein.
Participants in a CMJ placement must be assigned intentional, individualized activities designed to support their workforce participation.
The agency must employ an intensive case management strategy to coach CMJ participants through the job search process and help resolve any short-term barriers that may arise.
The activities assigned to CMJ participants are similar to those assigned during up-front job search. Because these participants are expected to obtain full-time employment, FEPs must assign no fewer than 30 hours per week of appropriate activities and may assign up to 40 hours. Job Search activities include:
Employment search (ES);
Career planning and counseling (CE);
Job readiness/motivation (MO); and
Life skills (LF).
A CMJ participant may be assigned to education and training activities if further educational attainment would increase employment prospects. Education and training activities include:
Adult Basic Education (BE);
English as a Second Language (EL);
General Educational Development (GED);
High School Equivalency Diploma (HE);
Literacy Skills (LS);
Job Skills Training (JS); and
Regular School (RS).
The W-2 agency shares an equal responsibility with the participant for finding employment. FEPs must schedule weekly contact with CMJ participants and provide an array of structured employment services and individualized case management, including:
Providing participants with information about specific job openings in the local labor market that match the individual’s skills and career assessment results;
Creating and updating the participant's Employability Plan (EP) with appropriate activities based on feedback obtained from the participant and from employers who did not offer the participant an interview or a job;
Offering career assessment services, providing guidance in career decision making, and identifying jobs that match the participant’s skills, interests, and abilities;
Monitoring a participant’s job search efforts to review specific jobs the participant has applied for and interviews outcomes to discuss with the participant why they did not receive an offer and help them adjust accordingly;
Discussing any nonparticipation with the participant and the reasons for the nonparticipation. FEPs must exercise due diligence in determining whether previously identified or unidentified barriers (such as personal and family challenges) are the underlying cause of the nonparticipation. The FEP must quickly re-engage CMJ participants in job search activities and place in a paid position CMJ participants who are found to have more severe barriers;
Connecting the CMJ participant with W-2 agency staff and community partners who assist in developing job leads and employer contacts; and
Discussing with the participant any barriers that may be preventing the participant from obtaining employment, including necessary supports, such as housing, transportation, and child care.
Participants with barriers that cannot be addressed with W-2 services within a 30-day timeframe must be placed in a paid W-2 employment position while these barriers are addressed. If barriers are discovered after the FEP has placed the participant in a CMJ, the FEP must not wait for the 30-day review period to move a CMJ participant to a paid W-2 employment position. (See 7.2.4.2 )
W-2 agencies must pay for supportive services that are needed for participation in the W-2 program (work uniforms, transportation, etc.). Additionally, participants in a CMJ:
Are eligible for Wisconsin Shares child care while in the placement;
May apply for a Job Access Loan to meet immediate employment needs to get or keep a job (see 17.2.1 ); and
Must have a Supportive Service Plan that is developed during a meeting between the case manager and the participant. (See 9.2 )
CMJ participants are not eligible for family stabilization payments.
W-2 agency staff who assist with developing job leads must actively work with local area employers to:
Solicit job openings;
Market participants to employers with jobs that match the participant's skills, abilities, and interests;
Set up job interviews;
Provide bilingual support for job contacts and interviews for individuals who are fluent in another language and are learning English; and
Follow up with employers to determine why a referred participant was not offered an interview or a job.
The FEP must review the appropriateness of the CMJ placement every 30 days to determine whether to:
Keep the individual in the CMJ placement;
Move the individual to a paid placement; or
End the CMJ placement.
If a CMJ participant has made a good faith effort to find employment but remains unemployed, the FEP must move the participant to a paid W-2 placement.
If the participant has not demonstrated a good faith effort to find employment, does not have any barriers to work, and the agency has provided appropriate case management services, the FEP may:
Keep the participant in a CMJ placement for another 30-day period; or
End the CMJ placement, depending upon the circumstances of the case. (See 7.2.4.8 )
The FEP may also keep a participant in a CMJ placement for another 30-day period if requested by the participant.
The following must be considered when making a placement determination during the CMJ 30-day reassessment:
Was the participant given multiple, specific job leads in the local labor market that matched their skills, abilities, and interests?
Did the participant get any job offers in the local labor market compatible with the participant’s skills, abilities, and interests?
Did the participant refuse or fail to apply for any jobs in the local labor market compatible with their skills, abilities, and interests?
What were the reasons the participant did not get a job or apply for one?
Were other W-2 participants with similar skills, abilities, and interests able to secure jobs in the local labor market?
Did the participant have previously identified barriers that were addressed with W-2 services? If so, were the services effective? Did the participant have previously unidentified barriers preventing them from obtaining unsubsidized employment?
The FEP does not have to wait for the 30-day review period to move a CMJ participant to a paid W-2 employment position. The FEP must discuss with the participant, on a weekly basis, any barriers that may be preventing the participant from obtaining employment. (See 9.1)
The FEP must document the results of the 30-day review, including the reasons for the placement decision, in PIN comments.
When a CMJ participant obtains unsubsidized employment, the FEP must offer employment retention and advancement services through a Case Management Follow-up (CMF) placement.
CMJ participants must meet all financial and nonfinancial eligibility requirements. However, participants in a CMF placement are only required to meet nonfinancial eligibility requirements.
The FEP must address any noncooperation with ongoing job search activities at the participant’s weekly meetings. (See 11.1 )
If a CMJ participant fails to cooperate with W-2 program requirements without good cause, the FEP must close the case. (See 11.5.1 )
At the 30-day reassessment, if the participant has not received a job offer, and the W-2 agency has provided appropriate case management and job development services, the FEP must determine whether:
The CMJ participant is likely to obtain employment if they receive additional job search assistance by remaining in the CMJ placement for another 30-day period; or
The CMJ participant has not cooperated with ongoing job search activities and the FEP must close the case.
If an individual placed in a CMD Case Management Denied , CMU Case Management Underemployed , CMF Case Management Follow-Up , CMF+ Case Management Follow-Up Plus , or CMJ Case Management Job-Ready declines case management services or does not participate without good cause, the FEP Financial and Employment Planner must:
Terminate eligibility for the placement; and
Document the refusal in PIN comments.
CWW CARES Worker Web will issue a W-2 Wisconsin Works denial notice.
There is no hourly payment reduction for noncooperation in CMD, CMU, CMF, CMF+, or CMJ placements. However, the FEP may close a CMD or CMJ placement if an individual:
Does not cooperate with job search requirements;
Misses an EP Employability Plan review appointment without good cause (see 11.5.1 ); or
Loses contact with the FEP.
The FEP should close a CMF, CMF+, or CMU placement if:
A participant fails to attend an EP or eligibility review appointment without good cause; or
The FEP has made repeated and varied attempts but is unable to connect with a participant.
Eligibility reviews must be conducted at least once every six months to maintain nonfinancial eligibility.
The Trial Employment Match Program ( TEMP Trial Employment Match Program ) placement is a W-2 Wisconsin Works employment position that provides subsidized work for applicants or ongoing W-2 participants. An individual working in a TEMP job earns at least minimum wage, and the W-2 agency subsidizes all or a portion of the hourly wages paid to the individual by the employer.
A TEMP job can last for a maximum of six months with an opportunity for a three-month extension. (See 7.3.5.1.2 )
A custodial parent may participate in more than one TEMP job but may not exceed a total of 24 months of participation in the TEMP placement. (See 7.3.6 )
A noncustodial parent meeting eligibility for W-2 case management services (see 7.5.1 ) may participate in only one TEMP job, provided that the NCP Noncustodial Parent has not exceeded the 24-month TEMP time limit. (See 7.3.6 )
There are two TEMP Trial Employment Match Program placement types, depending on an individual’s parental status:
Custodial Parent TEMP ( TMP Custodial Parent TEMP ); or
Noncustodial Parent TEMP ( TNP Noncustodial Parent TEMP ).
Individuals appropriate for a TEMP placement may:
Require a flexible schedule or other reasonable accommodations;
Have basic skills and/or education;
Not have skills that are marketable in the current labor market;
Be nearing a time limit; or
Have barriers preventing them from entering the labor market, such as; Little or no employment history; No recent employment history; or A history of failed employment.
The W-2 Wisconsin Works agency must utilize informal assessment results to identify W-2 participants who are capable of working and may be appropriate for TEMP. (See 5.2 for more information on informal assessments)
There are two service delivery models in TEMP Trial Employment Match Program :
Matching model; and
Sector model.
The matching model matches individuals to available subsidized jobs that require a specific set of skills, abilities, and aptitudes.
The matching model places individuals into subsidized jobs that align with their skills, abilities, and aptitudes. This model relies on:
A comprehensive assessment of the individual’s skills, abilities, and aptitudes; and
A review of the subsidized job requirements to ensure an appropriate match.
The sector model provides sector-specific training that prepares individuals for subsidized jobs in those sectors. The sector or sectors available depend on the partnerships with subsidized employers and training providers developed by the W-2 agency.
The W-2 Wisconsin Works agency is responsible for recruitment of potential subsidized employers for TEMP and must continue to provide TEMP participants services throughout the duration of the TEMP Trial Employment Match Program placement as described under the W-2 agency’s implementation plan.
For every TEMP placement, the W-2 agency must:
Pay a wage subsidy that is no more than the state or federal minimum wage ($7.25) for each hour worked, up to a maximum of 40 hours per week. The W-2 agency may negotiate with an employer to pay a wage subsidy that is less than $7.25 per hour, if the employer is willing to accept a wage subsidy less than $7.25 per hour.
Only pay a wage subsidy to an employer for a period when wages are paid to a TEMP employee.
For every TEMP placement, The W-2 agency must:
Complete the Wisconsin Works Trial Employment Match Program – Employer Agreement form (5088) with the employer; and
Scan the completed agreement into ECF Electronic Case File .
The W-2 agency and employer must also complete the Wisconsin Works (W-2) Work Training Site Agreement form (10792 ) for every training provider or employer at which a W-2 participant has been placed. (See 9.2.1 )
The W-2 agency must collect and verify timesheets for all hours worked by a TEMP employee prior to making payments to an employer.
The W-2 agency must:
Manually issue monthly payments to cover wage subsidies paid to TEMP employers for each TEMP participant employee; and
Accurately record the hourly subsidy for each TEMP participant employee using the WWP Wage History page.
A TEMP Trial Employment Match Program employer must:
Pay TEMP employees the same hourly wage paid to the employer’s entry-level employees who perform similar duties or the state or federal minimum hourly wage, whichever is higher; and
Provide TEMP participant employees with benefits comparable to those provided to regular employees in similar positions.
When an employer pays a wage (“Employee Wage”) that is higher than the negotiated wage subsidy (“Wage Subsidy”), the employer must pay the difference.
The portion of the employee’s wage that the employer is responsible for (“Employer Supplement”) is calculated using the following formula:
Employee Wage - Wage Subsidy = Employer Supplement
EXAMPLE: A TEMP employer pays a TEMP employee $8.50 per hour. The W-2 agency and employer negotiate a wage subsidy of $4.50 per hour. Because the employee wage is higher than the subsidy, the employer supplement is $4.00 per hour ($8.50 - $4.50 = $4.00).
A TEMP employer must invoice the W-2 Wisconsin Works agency monthly for the wage subsidy payment. The invoice must include the following for each TEMP employee:
Month of employment;
Actual wages paid monthly; and
Number of hours worked in the month.
A TEMP employer must agree to make a good faith effort to retain the participant as a permanent unsubsidized employee after the wage subsidy ends.
If a TEMP employer does not retain a participant as a permanent unsubsidized employee, the employer must do either or both of the following:
Serve as an employment reference for the participant; or
Provide a written performance evaluation of the participant, including recommendations for improvement.
Employers who routinely fail to offer unsubsidized jobs to successful TEMP participants should not receive future contracts.
The TMP Custodial Parent Trial Employment Match Program or TNP Noncustodial Parent Trial Employment Match Program placement must begin effective the first date of employment in a TEMP job. This will ensure there is no break in payments for participants previously in a paid W-2 Wisconsin Works placement.
TEMP Trial Employment Match Program jobs are generally 40 hours per week. However, an individual may, when needed, be placed in a TEMP job that is less than 40 hours per week. For example, an individual requests to work only 30 hours per week to accommodate their night school schedule.
Required work hours for a TEMP job must be:
Agreed upon by the participant, TEMP employer, and the W-2 agency; and
Documented in the Employer Agreement. (See 7.3.3.2 )
The W-2 agency must provide case management services to help individuals succeed in a TEMP job. This includes, but is not limited to:
Frequent follow-up with the employer and TEMP employee, including employer site visits;
Conflict mediation between employers and TEMP employees;
Identification and facilitation of referrals for work supports, such as transportation and child care, to support job retention; and
Ensuring individuals have information about work-related benefits, including the Earned Income Tax Credit (EITC), Transitional FoodShare, BadgerCare, Wisconsin Shares, and other available resources.
The W-2 agency must end a TMP or TNP placement on the participant’s last date of employment in a TEMP job.
NCP Noncustodial Parent s in the TNP placement are not eligible for multiple TEMP jobs. (See 7.3.5.1.1 )
The W-2 agency must conduct a thorough assessment of available TEMP jobs and individuals eligible for a TEMP placement to make appropriate matches. However, there may be instances where there is a mismatch of an individual’s skills with an employer’s expectations.
If the individual remains eligible and appropriate for TEMP, the individual may continue with a different employer. When this occurs, the W-2 agency must make every effort to ensure that there is no break in employment. If the W-2 agency is unable to immediately place the individual with a different employer, the W-2 agency must:
End the placement with the last date of employment; and
Reassess the individual for the most appropriate placement.
To be eligible for a three-month placement extension, the TEMP participant’s employer must request an extension based on the participant’s need to further develop or strengthen specific workplace competencies identified in their Employability Plan.
The W-2 agency should determine extensions to the wage subsidy, taking the agency’s budget into consideration.
All subsidy extensions must be justified by a need for continuing skill development balanced with the likelihood that the extension will result in permanent employment.
Individuals who move between TMP and TNP placements during one TEMP job may continue with and complete that TEMP job for the duration of the agreement. (See 7.3.3.2 )
W-2 Wisconsin Works participation in TEMP Trial Employment Match Program is limited to 24 cumulative months. (See 2.10.3 ) TMP Custodial Parent Trial Employment Match Program and TNP Noncustodial Parent Trial Employment Match Program placements count toward one 24-month TEMP eligibility time limit.
Time spent in TEMP counts toward the state 48-month lifetime limit. (See 2.10.2 )
Months accumulated in TEMP follow the individual regardless of changes in W-2 Group status.
History : Release 25-04 .
The Community Service Job (CSJ) placement is for applicants and ongoing W-2 Wisconsin Works participants who are not yet ready for unsubsidized employment.
The goal of the CSJ Community Service Job placement is to help participants build essential work habits and soft skills such as punctuality, reliability, and professionalism that support long-term employment success. CSJ work sites are expected to mirror regular employment settings as closely as possible, while allowing for job coaching and mentoring as needed.
Participants may take part in more than one CSJ placement, but the total participation time cannot exceed 24 months. (See 2.10.3 ) A full-time CSJ participant receives a monthly payment of $653.
Individuals placed in a CSJ may have:
Limited or no prior work experience;
A work history that includes frequent job changes, voluntary quits, or terminations;
Personal or health-related barriers, including physical or mental health conditions that limit regular employment; or
Family-related challenges such as domestic violence, temporary illness or incapacity, or other family crises.
EXAMPLE 1 : Jane has two children under the age of 5, has a very limited work history, and is one course short of her high school diploma. After applying for W-2, Jane explains that she is interested in becoming a child care provider but is worried that her limited experience and lack of high school diploma will prevent her from getting a job. The RS assigned Jane to up-front job search activities, and the job developer connected Jane to local child care employers who had openings. However, Jane was not hired due to her lack of experience and education. Jane’s FEP places her in a CSJ and assigns 10 hours per week of education to complete her high school diploma and 30 hours of work experience at a local daycare site.
EXAMPLE 2 : Jennifer has a high school diploma and completed a clerical training course but has no full-time work experience. Her son, Jason, age 7, has been recently diagnosed with severe behavioral issues and is in the process of being stabilized on medication. Jennifer applies for W-2 and wants to work somewhere she can use her clerical skills but needs flexibility to respond to her son’s needs as Jason’s school has Jennifer take him out of class weekly for behavioral issues. To do this, Jennifer’s FEP works with Jason’s school to set up a CSJ worksite in the front office, allowing Jennifer to gain clerical experience while remaining accessible for Jason when needed. Once Jason's medication stabilizes his behavior and Jennifer has the necessary clerical experience, the FEP will focus on moving Jennifer into unsubsidized employment.
The W-2 agency must issue a monthly payment of $653 to the CSJ participant if all participation requirements are met. The monthly payment of $653 must not be prorated or otherwise reduced if the assigned hours are less than 40 hours per week. Payments will be reduced by $5.00 for each hour that the participant fails to participate without good cause. (See 11.3.1 )
CSJ participants are generally expected to complete 40 hours of activities per week but can be assigned fewer hours depending on the participant’s circumstances. Of these 40 hours, up to 10 hours per week can be in education and training activities. (See 8.2.2.2 )
Education and training activities may include:
Aggregated education hours to allow a participant to complete a program within one year (see 8.2.2.3 );
Full-time participation in a technical college education program (see 8.2.2.5 ); or
Enrollment in a high school or high school equivalent course if the participant is 18 or 19 years old without a high school diploma or equivalent (see 8.2.2.1 ).
CSJ work training hours countable toward the maximum 40 hours of activity as approved by the FEP may include:
Work experience (WE);
Training activities at the CSJ work training site;
Job search activities (ES);
Vocational rehabilitation (VA, VE, VL); and
Meetings with professionals, including child support agency staff, social workers, health care professionals, or other meetings necessary to prepare a participant for employment (activity codes may vary).
CSJ work site employers may be public, private non-profit, or private for-profit. Each CSJ placement may be scheduled for up to six months with an opportunity for a three-month extension.
CSJ placements may be developed with a variety of employers, including, but not limited to:
Municipal or other local government agencies, including: Housing authorities; School districts; Local government agencies; Parks and recreation; and Sanitation departments.
Community-based organizations, including: Community non-profits; Religious organizations; Hospitals; and Schools.
Contract organizations, including: Private non-profits; W-2 agencies; Specialized for-profits such as industrial laundry; Packaging and distribution; Recycling recovery; and Maintenance.
The prorated CSJ placement is for W-2 applicants and participants who are working in unsubsidized employment for less than 30 hours per week and have limitations to increasing their work hours or obtaining additional job(s).
Hours of activities and payments are prorated to one of the following three levels based on the participant’s total weekly hours of unsubsidized work:
Prorated level Unsubsidized work hours per week Max CSJ activity hours per week Max education and training hours per week Monthly payment 1/3 CSJ 20-29 Up to 20 Up to 10 $218 1/2 CSJ 15-19 Up to 25 Up to 10 $327 2/3 CSJ 10-14 Up to 30 Up to 10 $435
The total combined number of hours of assigned activities and unsubsidized employment must not exceed 40 hours per week for individuals placed in a prorated CSJ.
Participants working up to nine hours per week in an unsubsidized job or a non-W-2 funded subsidized job may be granted a full CSJ payment. Participants working 30 hours or more per week in an unsubsidized job or a non-W-2 funded subsidized job are not eligible for a prorated CSJ.
Activities assigned to prorated CSJ participants must be specifically designed to assist the participants with overcoming their employment limitations within a reasonable time period. For information on combining prorated CSJs with aggregated education and training policy, see 8.2.2.4 .
A prorated CSJ placement may be appropriate for individuals with limitations or barriers to full-time employment, including, but not limited to:
Barriers to increased unsubsidized employment opportunities that cannot be addressed through supportive services;
Skills that do not align with the current job market;
Sporadic or limited work history;
No high school diploma or equivalent; or
A work history that includes frequent job changes, voluntary quits, or terminations.
E XAMPLE 1 : Brenda completed a specialized manufacturing training program, but shortly after, both local manufacturing plants near Brenda announced large layoffs. Without a high school diploma and unable to secure a manufacturing job, Brenda finds a job at a local restaurant working 23 hours per week and applies for W-2. After a thorough assessment and an unsuccessful job search, Brenda’s FEP places her in a 1/3 CSJ placement and assigns 10 hours of GED coursework and seven hours of job search per week. Her 1/3 CSJ payment, based on less than 10 hours of work activity per week, is $218.
EX AMPLE 2 : Maria is a single mom with two teenagers. She works 20 hours per week at an insurance company but has a physical disability that prevents her from increasing her work hours. Maria applies for W-2 and after providing verification of her physical disability from her doctor, Maria is placed in a prorated CSJ position. Maria's FEP reviews the medical documentation and together they create an Employability Plan focusing on moving Maria towards employment that utilizes her abilities. Maria makes a career goal of becoming a technical writer. Maria is assigned to participate in an online college-level writing workshop for four hours per week. In addition, Maria is referred to the agency's disability advocate to assist her in initiating an application for SSI. With her current hours of unsubsidized employment at 20 hours per week and less than 10 hours of assigned work activity per week, Maria will receive a 1/3 CSJ payment of $218 per month.
CSJ participants eligible for a prorated CSJ payment are expected to participate up to 40 hours per week in a combination of:
Unsubsidized employment;
Work training activities; and
Education or training.
In some cases, the combination of CSJ activities and employment may be less than 40 hours per week, such as when the participant's limitations are severe.
If a participant has severe limitations, the FEP must coordinate with the participant’s medical professional or assessing agency to determine appropriate CSJ activities that the participant can reasonably perform and that will meet allowable work training hours. FEP should also connect the participant with DVR for additional resources and support. (See 7.4.1.2 ) Assigned CSJ activities must not interfere with unsubsidized work hours.
All prorated CSJ payments, initial or ongoing, follow standard W-2 payment policies and are subject to the current W-2 payment reduction procedures. (See Chapters 10 and 11 )
There is no separate prorated CSJ 24-month time limit. The standard 24-month CSJ time limit applies to both full and prorated placements. (See 2.10.3 )
CSJ participants who, for medical reasons determined by a qualified assessing agency or professional, are out of the home or are unable to care for their children for periods of less than 60 days may remain in a CSJ placement.
During this period, the participation requirement is to cooperate with the prescribed treatment plan.
In most cases, the Physical Rehabilitation (PR) activity code should be used during this time frame.
The W-2 agency is responsible for identifying, developing, and managing CSJ positions that prepare CSJ participants for unsubsidized employment. The agency may contract for all or part of the operations.
CSJ positions must:
Replicate actual conditions of work;
Have responsibilities and expectations similar to unsubsidized employees, when feasible;
Serve a useful public purpose or be a project where the costs are partially or wholly offset by the revenue generated; and
Have a work training site supervisor. The work training site supervisor must provide a structured work environment and be willing to supervise, mentor, and coach CSJ participants to succeed in the workplace. See the TANF Work Participation Requirements appendix for more information on requirements for supervising W-2 activities.
If the W-2 agency partners with a for-profit organization to develop a CSJ worksite, the organization must agree to use the revenue or profit generated by CSJ participants’ activities to offset CSJ costs by providing on-the-job training that is valuable to the participant or by reimbursing a portion of the W-2 agency’s CSJ administrative costs.
Management of CSJ positions include:
Securing new work training sites;
Maintaining relationships with existing providers;
Creating CSJ placements within the W-2 agency;
Ensuring enough CSJ positions are available;
Providing special or additional on-site supervision of CSJ participants when necessary;
Providing or arranging for reasonable accommodations and supportive services, including translators;
Acting as a liaison between work training providers and CSJ participants;
Maintaining and updating an inventory of CSJ placements;
Providing worker’s compensation coverage for all participants, unless provided by the worksite; and
Requiring all work training sites to complete the Wisconsin Works (W-2) Work Training Site Agreement form (10792)
The CSJ work training provider must keep hourly time records and report nonparticipation to the FEP if it occurs. See the TANF Work Participation Requirements appendix for guidelines on documenting and verifying W-2 activities.
The U.S. Department of Labor requires that all federal employment laws apply to individuals in welfare-based employment and training participants, even if the participant is not an “employee” in other contexts.
To ensure CSJ activities qualify as training and not employment for the purpose of wage withholding requirements, including Federal Insurance Contributions Act (FICA), the Earned Income Tax Credit (EITC), and unemployment compensation taxes, the W-2 agency must confirm:
The training is similar to that provided in a vocational school;
The training is for the benefit of the CSJ participant;
Participants do not displace regular employees;
Employers do not receive an immediate benefit from the participant’s training;
Participants are not entitled to a job after the training is completed; and
Employers and the participant understand that the participant is not paid.
The W-2 agency must use its best efforts to ensure that CSJ activities comply with the criteria listed above.
If a CSJ placement is determined to be employment under federal law, the State of Wisconsin, not the W-2 agency, is considered the employer for wage and tax purposes.
The W-2 Transition (W-2 T) employment position is for individuals who are not ready for unsubsidized employment and cannot successfully participate in one of the other W-2 Wisconsin Works employment positions for reasons such as an individual’s incapacitation or the need to remain in the home to care for another W-2 Group member who is incapacitated or disabled.
Participants placed in a W-2 T W-2 Transition must have a formal assessment, as described below, scheduled and documented in WWP Wisconsin Work Programs within 30 calendar days of the W-2 T placement. (See 5.5.1 )
The FEP Financial and Employment Planner must not assume that a participant with a disability is unable to participate in unsubsidized employment or other W-2 paid employment positions.
The FEP may place a participant in a W-2 T when the participant cannot perform a CSJ Community Service Job , as determined by the W-2 agency, for reasons which may include:
Participant Disability or Incapacitation
An independent assessment by a medical professional or other similar qualified source must verify that the participant is, or is expected to be, incapacitated for a period of at least 60 days. Examples of incapacitation that would warrant an assessment may include:
Physical limitations;
Mental health limitations;
Cognitive limitations;
Learning disabilities;
Victim of domestic violence; and
Substance use disorder.
See 5.5.4 for how and what information must be gathered through a formal assessment.
Caring for an Incapacitated W-2 Group Member
The participant is needed in the home to care for a member of the W-2 Group who is ill or incapacitated. The following steps must be taken to determine the need for a W-2 adult to remain in the home to care for a family member:
Verify, through third-party sources, the incapacity or disability of the affected family member and the appropriateness of day care or child care outside of the home using the Need to Care for Disabled Family Member form (10786) or an agency-developed form that, at a minimum, has the same elements. Acceptable third-party sources include:
Medical professionals:
Social Security Administration;
Family Support program;
Birth to Three Early Intervention program;
Children and Youth with Special Health Care Needs program;
Exceptional Educational Needs program;
Supportive adult programs under the 51.42 service board; and
Independent Living Centers for a physical disability or mental health issues.
Determine whether day care or child care outside the home is available for the disabled/ or incapacitated family member so that the participant can engage in work training activities outside the home.
When a reasonable accommodation cannot be made or the care is not available, lack of adequate day care or child care is a good cause reason for not participating in W-2 requirements outside the home. Written documentation from one or more local day care or child care providers is sufficient verification that appropriate care is not available.
EX AMPLE 1 : Briella, a single parent with two children, worked as a waitress until her rheumatoid arthritis became so severe that she had to quit her job. Briella applied for W-2 and was placed in a W-2 T position and referred for a vocational assessment.
The results of the assessment showed that with accommodations and rehabilitation, Briella will be able to perform a sedentary job.
Briella and her FEP revised her Employability Plan, emphasizing activities that will allow her to work towards a job in customer service. Her participation requirement is 27 hours per week in a physical rehabilitation program, which involves physical therapy and independent mobility, plus three hours of work training.
After completing three months of rehabilitation, Briella is moved to a CSJ, where she is able to participate a full 40 hours per week in a combination of work training and education activities. Five months after her CSJ placement, Briella secures employment taking calls at a credit union in the customer service department.
E XAMPLE 2 : Anita applies for W-2. Her daughter Kathy, age 8, can no longer be exposed to other children in a school or day care setting due to an advanced autoimmune disease and an extremely fragile immune system. The FEP places Anita in a W-2 T employment position and opens the "CD-Caring for Disabled Child" participation status to care for her child with a disability. Anita tells her FEP that her mother stays with Kathy for two hours per week so she can attend grief mental health counseling sessions, which is added to her EP.
An in-depth formal assessment will determine:
The appropriate level of W-2 participation;
An individual’s ability to engage in specific work and training activities; and
The need for supportive services, accommodations, auxiliary aids, or communication assistance. (See 5.5.1 )
Attendance and cooperation with an in-depth assessment may satisfy participation requirements pending the results of the formal assessment. A W-2 payment reduction cannot be imposed on a participant for declining to complete a formal assessment. (See 5.5.7 )
Based on the results of the assessment, the participant may be assigned up to 40 hours per week in activities, which may include:
Work training;
Other W-2 T activities; and
Education and training.
The following two tables provide a non-exhaustive list of examples of work training and other activities for W-2 T participants and the corresponding activity codes and statuses the FEP may assign.
See 8.2.2 for information on education and training activities that may be assigned to W-2 T participants.
W-2 T Work Training Activity Examples Assignable activities may include Community rehabilitation program that provides directly or facilitates the provision of vocational rehabilitation to individuals with disabilities to help them maximize opportunities for employment. Services may include vocational assessment, job readiness training, job placement, and on-the-job support targeted at individuals with disabilities. Disability and Learning Assessment (AD); Career Planning & Counseling (CE); Employment Search (ES); Mentor/Coach (MN); Job Readiness/Motivation (MO); Occupational Testing (OC); On-The-Job Training (OJT); Paid Work Experience in the public sector, not funded by TANF (SW); and Work Experience (WE). Volunteer activity. Work Experience (WE). Activities similar to a CSJ but with more supervision. (See 7.4.1 ) Technical College Activities (TC); Work Experience (WE); Job search activities (ES); and Vocational rehabilitation (VA, VE, VL).
Other W-2 T Activity Examples Assignable Activities may include AODA detoxification, assessment, and treatment. AODA Counseling (CA); AODA Assessment (AA); and Personal Development (PD). Activities that provide support for children with special needs. Family Member Treatment/Counseling (FC). Activities related to obtaining shelter or retaining safety in a domestic abuse situation, or other activities needed to stabilize a family. Domestic Violence Assessment and Supportive Services (AV); and Personal Development (PD). Caring for a family member with an incapacity of such severity that without home care, the incapacitated member’s health and well-being would be significantly affected, as determined by the W-2 agency. Caring for Other Family Member (CF); and Caring for Disabled Child (CD).* Court-ordered activities. Court-Related/Legal Appointments (LA). Counseling or physical rehabilitation activities. Physician’s Assessment (AL); Ongoing Medical/Personal Care (MP); and Physical Rehabilitation (PR). Mental health activities, as prescribed by an appropriate health care professional. Mental Health Assessment (AM); and Mental Health Counseling (CM).
*See 6.4.1 for more information on participation statuses.
A W-2 applicant or participant who is marginally employed, for example, working only a few hours per week or inconsistently, in an unsubsidized job may also be placed in a W-2 T placement when the participant has long-term, severe barriers to:
Increasing the hours in their existing unsubsidized job; or
Obtaining additional unsubsidized employment.
In these instances, the FEP must schedule flexible activities around the unsubsidized employment and assign W-2 T activities specifically designed to assist the individual in overcoming these severe barriers while maintaining flexibility and sensitivity.
EXAMPLE : Sue’s son Jason, age 8, has a diagnosed brain disorder. Jason is able to attend school but is often sent home due to behavioral issues. Appropriate child care is often not available during these periods. Sue is marginally employed working approximately 10 hours per week at her local pharmacy, which provides a flexible work schedule. This situation is not likely to change for some time. Sue’s FEP places her in a W-2 T position since she will not be able to move to full-time employment in a short period of time. The FEP includes her 10 hours of marginal unsubsidized employment on her EP and assigns an additional two hours per week in a life skills motivational course. The FEP also opens the "CF-Caring for Other Family Member" participation status to care for her disabled child.
The W-2 agency is responsible for the development and management of work training sites that prepare W-2 T participants for unsubsidized employment. The agency must act as a liaison between providers and W-2 T participants when necessary and must ensure all work training sites:
Accommodate participants with barriers to employment;
Offer part-time and flexible schedules to meet the individual needs of W-2 T participants;
Provide comprehensive supervision of participants (see the TANF Work Participation Requirements appendix for more information on requirements for supervising W-2 activities); and
Provide supportive services, accommodations, auxiliary aids, or communication assistance when needed.
The W-2 agency must provide worker’s compensation coverage for participants when not provided by the W-2 work training provider.
All W-2 T work training providers must:
Complete the Wisconsin Works (W-2) Work Training Site Agreement form (10792) ; and
Comply with all provider assurances outlined in the agreement.
W-2 T participants are required to provide verification for hours of participation in all assigned activities, including education and training. See the TANF Work Participation Requirements appendix for verification and documentation guidelines.
The W-2 agency must issue a monthly payment of $608 to the W-2 T participant if all participation requirements are met. The monthly payment of $608 must not be prorated or otherwise reduced if the hours assigned are less than 40 hours per week. Payments will be reduced by $5.00 for each hour that the participant fails without good cause to participate. (See 11.3.1 )
The CMC Custodial Parent of an Infant placement is for eligible parents with newborns to help the parents provide care for their child(ren) during the early months of a child's life and successfully adjust to the challenges of being a parent.
A custodial parent of an infant 8 weeks old or younger who meets W-2 financial and nonfinancial eligibility may receive a monthly CMC payment of $673 and not be required to participate in W-2 activities, unless they volunteer to do so.
The eight-week CMC placement allows parents time to physically recover from childbirth, care for their newborn, secure childcare, and prepare for a return to the workforce.
W-2 agencies should encourage CMC participants to take advantage of employment-related services offered within the W-2 program during the eight-week CMC period.
To qualify for a CMC placement, the custodial parent With respect to a dependent child, a parent (see definition of parent) who resides with that child and, if there has been a determination of legal custody with respect to the dependent child, has legal custody of that child must meet all W-2 financial and nonfinancial eligibility requirements (see Chapters 2 and 3 ), and:
Have a child 8 weeks old or less; and
No other adult member in the W-2 Group An adult custodial parent, all dependent children with respect to whom the individual is a legal custodial parent and all minor children with respect to whom the adult individual’s dependent child is a custodial parent. W-2 Group includes any non-marital co-parent or any spouse of the individual who resides in the same household as the individual and any minor children with respect to whom the spouse or non-marital co-parent is a custodial parent. W-2 Group does not include any person who is receiving cash benefits under a county relief block grant program. This is also referred to as the W-2 Assistance Group (W-2 AG) is participating or eligible to participate in a W-2 employment position or is working in an unsubsidized job.
If another adult in the W-2 Group is working in unsubsidized employment or is eligible for W-2 participation, regardless of the W-2 Group’s income, the family is not eligible for CMC. Even if the income of the other adult results in the family's income being at or below 115% of the federal poverty level, the family is still ineligible for a CMC payment.
If the family's income is at or below 115%, the other adult must be considered for placement in a W-2 employment position. In this situation, this family would be considered a two-parent family and be treated accordingly. (See Chapter 14 )
EXAMPLE 1 : Diane gives birth to Marina and applies for CMC Custodial Parent of an Infant . Diane reports that Marina’s father lives with them and works part-time hauling lumber. Since he is a non-marital co-parent living in the home and is employed in unsubsidized work, the family is not eligible for CMC. The FEP Financial and Employment Planner must offer the family other employment services, if otherwise eligible, such as case management services in the CMU Case Management Underemployed placement.
EXAMPLE 2 : Dorothy applies for a CMC and has a 3-week-old baby. During intake, Dorothy explains that she is married to John, who is not the baby’s biological father but lives with her and works in unsubsidized employment. Although the family income is below 115% of the Federal Poverty Level, they are ineligible for CMC due to John’s unsubsidized employment. The FEP should explore other appropriate services and W-2 placements with Dorothy.
EXAMPLE 3 : Mia has a baby while employed full-time. Her husband Jeff, the baby’s biological father, has not worked in a year to stay home and care for their 3-year-old son. Because Jeff lives in the home and is eligible for W-2 employment services, the family is not eligible for a CMC. Based on Jeff’s work history, the FEP determines that Jeff is appropriate for a CSJ Community Service Job placement. Jeff agrees to be the placed parent as Mia plans to stay home with their son and newborn.
EXAMPLE 4 : Sonia has a 5-week-old baby. Sonia’s husband Victor is the biological father of the baby. Victor has been receiving SSDI Social Security Disability Insurance since 2000 when he was injured in a car accident. Although Victor is included in the W-2 Group, he is not working, and he would not be eligible to participate in a W-2 employment position. The family is eligible for CMC.
In situations where the CMC participant is not married, the FEP must inform the participant that they and the baby’s biological father will have the ability to sign the Voluntary Paternity Acknowledgment (PATH) form at the hospital to establish legal paternity. The FEP must explain that both parents must sign the form in the presence of a notary and that most hospitals have notaries on staff. The participant must also be informed that the PATH form requires a filing fee. If the participant cannot afford the fee, the hospital may be able to provide assistance.
If the participant is uncertain about the identity of the father, the FEP should explain the option of genetic testing.
FEPs must emphasize the importance of establishing legal paternity at the time of the child’s birth.
Benefits of establishing paternity include:
Both parents are legally and financially responsible for their child;
It supports a child’s right to know both parents;
The child may be eligible for coverage under the father’s health insurance; and
The child may gain access to benefits such as: Social Security and veterans’ benefits; Family medical history; and Tribal affiliation or enrollment.
If the FEP does not have the opportunity to discuss paternity acknowledgement until after the participant leaves the hospital, the FEP must still review the benefits of establishing paternity with the participant and inform the participant that the PATH form is also available through the local child support agency (CSA) or county Register of Deeds office.
The FEP must also explain how establishing paternity may affect CMC eligibility. If the alleged father lives in the home and paternity is established while the CMC payment is ongoing, the family becomes ineligible for CMC if the father is either:
Working in unsubsidized employment; or
Not working but is eligible to participate in a W-2 employment position.
In certain situations, the FEP must contact the local CSA and request that paternity establishment for a specific CMC case be prioritized. These situations include:
When both parents refuse to sign the PATH form;
When the PATH form is signed and then later rescinded due to concerns about losing the CMC payment; or
When paternity acknowledgement is not appropriate, e.g., there is more than one potential father living in the home.
If an individual meets the eligibility criteria, the FEP must place the participant in the CMC placement. Once the parent has been determined eligible for the CMC payment, the FEP may encourage the participant to volunteer for appropriate services such as:
Parenting and family relationship classes;
Family planning services;
Budgeting and financial literacy classes;
Household management and family nutrition classes; and
Job search, once appropriate.
These services are not mandatory activities and cannot be used as a basis for eligibility determination while the participant is in the CMC placement.
The CMC placement begin date is either the birth date of the child or the date of application, whichever is later. An applicant has seven days to provide appropriate verification. If the applicant provides verification within that timeframe, the placement must begin as of the date of application but no earlier than the date of birth. The agency may extend the verification period up to 30 days and still backdate the placement back to the date of the application. (See 4.1.3 )
The W-2 agency must have verification of a baby’s birth and application for an SSN prior to placing a participant into the CMC placement. Medical verification requiring the individual to be in the home for eight weeks is not necessary. (See 4.1.2 and 2.2.1. #14)
EXAMPLE 1 : Mary’s baby is born April 14. On April 21, she applies for a CMC placement. At the time of her April 23 intake appointment, Mary does not have verification of her baby’s birth or SSN application. Mary’s FEP instructs her to bring in verification no later than April 30. Mary brings in her verification on April 25 and is placed in CMC effective April 21, the date of application.
EXAMPLE 2 : Jontae applies for a CMC placement on May 5 because her baby is due on May 10. At her intake appointment on May 8, the FEP asks Jontae to bring in verification of the baby’s birth and SSN application as soon as possible. Jontae has her baby on May 11 and submits the required verification to the FEP on May 15. Jontae is placed in CMC effective May 11, the date of the baby’s birth.
Ongoing participants have 10 days to report a change in circumstances. (See 2.8.1) If the change (the birth of the baby) is reported within this timeframe, the payment should begin as of the date of the child’s birth. If it is reported outside of 10 days, the FEP determines whether the payment begins as of the date of the child’s birth or when the parent verified the birth and SSN application date. The FEP should consider whether circumstances prevented the parent from reporting the child’s birth within 10 days.
Individuals placed in CMC will receive a monthly payment of $673.
Whether a participant’s time in a CMC placement counts against the 24-month placement time limit, 48-month state lifetime limit, or 60-month federal lifetime limit depends on the participant’s W-2 placement history and the timing of the child’s birth.
The FEP must explain the impact reaching a time limit will have on the family’s eligibility for future W-2 benefits. If a CMC participant reaches the 48-month state lifetime limit while in the CMC placement, they are automatically eligible for a time limit extension.
See 2.10.8 for more information on W-2 time limits for CMC placements.
The CMC placement must end eight calendar weeks (7 days x 8 weeks = 56 days) after the child is born. CMC cannot extend beyond the date the child turns 8 weeks of age, regardless of the date the CMC placement begins.
A CARES Client Assistance for Reemployment and Economic Support alert is generated to remind the FEP to change the CMC placement on the appropriate day.
As the CMC placement end date approaches, the FEP must discuss next steps with the CMC participant, including employment goals and supportive service needs once the CMC placement ends.
If the CMC participant is going to continue in a different W-2 placement, the FEP must enter the new placement on the 57th day which will end CMC placement on the 56th day.
If the CMC participant is not going to continue in a different W-2 placement, the FEP must end date the W-2 episode on the 56th day which will also end the placement on the 56th day.
EXAMPLE 1 : Miguel is placed in a CMC on March 6, after the birth of his child, for whom he has sole custody. Two weeks before his 56th day in the placement, the FEP meets with Miguel to discuss Miguel’s options once his CMC placement ends. During this meeting, Miguel confirms that he will be returning to his prior job by relying on the child care services the FEP helped him secure and does not want any W-2 follow-up services. Based on this information, the FEP will end-date Miguel’s CMC placement effective April 30, which is the 56th day.
E XAMPLE 2 : Bobbi gave birth to a baby and is placed in CMC on March 6. Two weeks before the 56th day in the placement, the FEP meets with Bobbi to discuss plans for when her CMC placement ends. Bobbi explains that she originally planned to go back to work but has been very depressed and anxious and does not feel like she can handle getting a job as she had hoped. Based on an informal assessment, the FEP determines that Bobbi is in need of a formal assessment and possible mental health services depending upon the outcome of the assessment. For that reason, the FEP will place Bobbi in a W-2 T effective May 1, which will correctly end date the CMC placement on April 30 (the 56th day).
The At Risk Pregnancy (ARP) placement is for pregnant individual in their third trimester who have a medically verified at risk pregnancy. Participants in this placement receive a monthly payment of $673 and are not subject to the requirements of W-2 Wisconsin Works employment positions, such as Employability Plans (EPs), sanctions for nonparticipation, etc.
Pregnant teens younger than 18 years are not eligible for an ARP At Risk Pregnancy placement.
A pregnant woman who meets all of the following requirements must be placed in an ARP placement:
Meets all W-2 financial and nonfinancial eligibility requirements, except the woman is not a Custodial Parent (CP) With respect to a dependent child, a parent (see definition of parent) who resides with that child and, if there has been a determination of legal custody with respect to the dependent child, has legal custody of that child of a dependent child who resides in the woman’s home;
Is unmarried;
Is in the third trimester of pregnancy, defined as the 12 weeks before the medically verified estimated delivery date (see 7.4.6.2 );
Has a medically verified at-risk pregnancy; and
Is unable to work as a result of the at-risk pregnancy, as verified by a qualified physician.
ARP applicants are not required to have made a good faith effort to obtain employment and have not refused any bona fide offer of employment, including a job quit, within 180 calendar days immediately preceding application. (See 2.2.1 , #8)
EXAMPLE : Sophia is seven months pregnant with her first child and is not married. Sophia’s doctor recently put her on bed rest for the remainder of her pregnancy due to a pregnancy related medical condition. While on bed rest, Sophia applies for W-2 through ACCESS. A FEP then contacted Sophia by phone and went to Sophia’s home to complete her W-2 application. After determining Sophia as a good candidate for a W-2 ARP placement, Sophia’s FEP gave her an ARP Medical Information/Verification form to give to her doctor with the following information already filled out:
The W-2 agency’s name, address, phone, and email; and
Sophia’s name and birthdate.
Based on the remaining information in the form, completed by Sophia’s doctor, and the information Sophia already had provided to the W-2 agency, the FEP placed Sophia in an ARP placement.
The required medical information/verification for ARP must be provided through either:
The At Risk Pregnancy (ARP) Medical Information/Verification form (4070) ; or
A letter from the physician on the physician’s letterhead that includes all of the medical information listed below.
ARP medical information must include all of the following:
Participant’s full name;
Participant’s date of birth;
Participant’s estimated due date, provided by the participant’s physician;
Physician’s confirmation that the participant has an at-risk pregnancy;
Physician’s statement of the reason the participant’s pregnancy is an at-risk pregnancy;
Physician’s statement that the participant is unable to work due to the at-risk pregnancy;
Start date for the participant being unable to work due to the at-risk pregnancy;
Any other comments by the physician;
Physician’s specialty which must be General Medicine, Family Medicine or Obstetrics;
Physician’s National Provider Identifier (NPI);
Physician’s signature and printed name;
Date of the physician’s signature (must be no earlier than 30 days prior to the participant’s third trimester start date); and
Physician’s contact information.
Note : The W-2 agency may verify an NPI using the NPI Registry.
The physician-provided medical information/verification must be based on the physician’s medical examination of the participant.
The physician’s signed statement on either the ARP Medical Information/Verification form (4070) or on the physician’s letter must be completed no earlier than 30 days prior to the beginning of the participant’s third trimester of pregnancy. Medical information/verification completed earlier must be resubmitted and updated by the physician within the required time frame.
The W-2 agency must date stamp the ARP Medical Information/Verification form (4070) or the physician’s letter with the date the agency received the document.
EXAMPLE : Christa is pregnant with her first child and is currently on bed rest because her pregnancy is high risk. Christa applies for W-2 while still in her first trimester and is placed in a CMP placement. Christa’s medical condition could change between her first trimester and her third trimester when she may become eligible for an ARP placement. Therefore, Christa will need updated medical information/verification no earlier than 30 days prior to the beginning of her third trimester of pregnancy to be eligible for the ARP placement.
The start date for an ARP placement must be the latest of the following three dates:
Date of W-2 eligibility;
Start date of the third trimester, defined as 12 weeks before the medically verified estimated due date; or
Date specified by the physician in the ARP medical information/verification as the date the participant is no longer able to work due to the at-risk pregnancy.
Participants in an ARP placement are not required to cooperate with child support or assign their rights to child support payments. ARP placements do not count towards the 60-month federal lifetime limit because ARP payments are considered short term assistance under TANF Temporary Assistance for Needy Families regulations.
If an ARP participant transitions to another placement, child support requirements applicable to the new placement must be followed.
The W-2 agency must contact ARP participants at least once a month either in-person or by phone, depending on the needs of the ARP participant, to discuss the participant’s needs.
During these discussions, the W-2 agency must:
Identify any emerging needs; and
Provide W-2 services or make referrals to appropriate community resources.
For example, if an ARP participant expresses concerns related to their health, the FEP may refer them to visiting nurse services or prenatal care support programs.
The end date for an ARP placement is the earliest of the following dates:
The date the ARP participant transitions to a different W-2 placement, such as CMC, after the birth of the child;
Twenty days after the estimated due date, when CARES Client Assistance for Reemployment and Economic Support batch process ends the ARP placement; or
The date the participant no longer meets ARP eligibility criteria. (See 7.4.4.1 ) For example, the participant: Regained custody of their minor child; Got married; or Is no longer pregnant.
The purpose of the W-2 Wisconsin Works Case Management for Noncustodial Parents (CMN) and Stipends for Noncustodial Parents (TSP) placements is to provide case management and employment services to help NCP Noncustodial Parent s build economic stability and pay child support.
The following table outlines the differences between the CMN and TSP placements including eligibility, employment readiness, and participation requirements.
Case Management for Noncustodial Parents (CMN) Stipends for Noncustodial Parents (TSP) Purpose Provide case management services to noncustodial parents who meet W-2 eligibility requirements. Provide CMN case management services and stipends to eligible noncustodial parents not yet ready for a TEMP job or unsubsidized work. Placement Goal Help noncustodial parents find and maintain employment. Prepare noncustodial parents for unsubsidized work or a TEMP job. Eligibility Criteria Meet all eligibility criteria listed in 7.5.1.1 . Must meet all CMN eligibility criteria listed in 7.5.1.1 and not be ready for a TEMP job or unsubsidized work due to limited skills or education. Key Activities Employment Search (ES) Job Retention (JR) Career Advancement (CR) Parenting Skills (PA) Education and training (GE, HE, JS, LS) At least 20 hours per week in approved education or training: HSED/GED prep; ABE; ESL; and Short-term job skills training. Payment Type No stipend or W-2 payment. Stipend of up to $200 per month for up to 16 weeks. Participation Requirements No minimum hours; tailored to participant needs. Minimum of 20 hours per week in eligible education or training programs.
A noncustodial parent may be eligible for W-2 services through a CMN Case Management Noncustodial Parent or TSP Stipends for Noncustodial Parents placement when all of the following apply:
The custodial parent is:
Participating in a TMP Custodial Parent Trial Employment Match Program , CSJ Community Service Job , W-2 T W-2 Transition , or CMJ Case Management Job Ready placement;
Receiving a payment in an ARP At Risk Pregnancy or CMC Custodial Parent of an Infant placement; or
Receiving Wisconsin Shares child care assistance.
Agencies may disclose information to the noncustodial parent about the custodial parent's participation status in W-2 or child care (i.e., not participating in a qualifying program or placement) to explain why the noncustodial parent is not eligible for W-2.
If the FEP receives information indicating that the custodial parent may no longer be enrolled in W-2 or receiving child care, the FEP Financial and Employment Planner must reverify eligibility. At a minimum, this information must be verified again at the NCP’s six month eligibility review.
The noncustodial parent is subject to a child support order;
The noncustodial parent meets all other financial and nonfinancial eligibility criteria except that the individual is an noncustodial parent (see Chapters 2 and 3 ); and
The noncustodial parent meets all eligibility criteria defined in DCF 105 including drug screening and subsequent referral to testing or treatment as indicated.
EXAMPLE : Norman is the noncustodial parent of his 9-year-old son, Thomas. Thomas lives with his mother, Mary, who is in a CSJ placement. Norman has a child support order that requires him to pay monthly court-ordered support for Thomas. Because Norman is cooperating with the CSA Child Support Agency and meets all other W-2 financial and nonfinancial requirements, with the exception of being a custodial parent, he would be eligible for W-2 services for noncustodial parents.
7.5.1.2 W-2 Case Management Services for Noncustodial Parents ( CMN )
The W-2 agency may provide the following case management services to individuals in a CMN Case Management Noncustodial Parent placement:
Employment Search (ES);
Job Retention Services (JR);
Career Advancement Services (CR);
Education and Training activities, including; Job Skills Training (JS); General Educational Development (GE); High School Equivalency Diploma (HE); Life Skills (LS); Parenting Skills (PA);
Other case management activities (See the Activity Codes Appendix for a full list).
The Stipends for Noncustodial Parents (TSP) placement is available to eligible noncustodial parents who:
Are not ready for a TEMP Trial Employment Match Program job (see 7.3 ) or unsubsidized employment due to lack of work skills or education; or
Could benefit from a monetary stipend for participation in W-2 activities that will prepare them for a TEMP job or unsubsidized employment.
To be eligible to receive a stipend, a noncustodial parent in the TSP placement must participate in a minimum of 20 hours per week of education and training activities that prepare them for employment, such as:
A course of study meeting the high school graduation equivalency standards established under Wis. Stat. s. 115.29(4);
English as a second language courses;
Adult basic education courses, including, but not limited to, literacy skills, remedial math, or reading courses; and
Short-term job skills training for career-focused training programs such as vocational training classes and pre-vocational or bridge training focused on specific industry sectors.
The W-2 agency may prescribe additional requirements that an NCP must achieve in order to receive a stipend.
The W-2 agency may issue a stipend payment to a noncustodial parent at any point or frequency during the TSP placement based on the current needs of the individual while they are preparing for employment. However, stipend payments must not be based on hours of participation in W-2 activities.
A noncustodial parent may receive stipend payments for a maximum of 16 weeks in a rolling 12-month period. The total stipend payment amount may not exceed $200 per month and should help the noncustodial parent with meeting the costs associated with engaging in W-2 education and training activities.
Stipend payments should not be considered a substitute for other supportive services available to noncustodial parents. W-2 agencies must offer to develop a Supportive Service Plan (see 9.2.1 ) with the noncustodial parent and work with them to address any barriers to participating in W-2 activities identified in the process.
Note : Stipend payments qualify as Non-Recurrent, Short-term Benefit under the TANF definition of assistance and do not fall under the category of “cash assistance.” NCPs receiving stipends are not subject to the state 48-month lifetime limit.
Placement in TSP on any day of the standard workweek, i.e., Sunday to Saturday, will count as one week. To maximize participation, agencies should place NCPs in a TSP on a Monday or closest day to the start of the week when possible.
W-2 agencies must help NCPs in the TSP placement move to a TEMP job or unsubsidized job as quickly as possible. The stipend ends when the noncustodial parent starts unsubsidized work or enters a TEMP job in a TNP Noncustodial Parent Trial Employment Match Program placement. (See 7.3.1 )
The W-2 agency must develop a standard operating procedure (SOP) for issuing stipends and submit it for approval by the regional DCF contractor staff.
The W-2 agency must:
Manually issue stipend payments to eligible noncustodial parents; and
Document each payment in PIN comments.
The Children First program provides employment and training services and support to help eligible noncustodial parents increase their involvement in the lives of their child(ren).
Eligibility for Children First is not tied to W-2 eligibility. A noncustodial parent may receive both Children First and W-2 services at the same time.
For more information about the Children First program participation and services, see the DCF Children First webpage .
The Case Management for Minor Parents (CMM) placement is for individuals who are custodial Minor Parent A custodial parent under the age of 18. For Learnfare, a minor parent is either a custodial or a noncustodial parent under the age of 18. s. A custodial minor parent is eligible for W-2 Wisconsin Works regardless of the minor parent’s living arrangement and financial or nonfinancial eligibility status.
FEP Financial and Employment Planners s should provide individuals in the CMM Case Management Minor Parents placement with information and referrals regarding:
Available child care assistance;
Employment and financial planning;
Family planning services;
Community resources: and
Eligibility for BadgerCare Plus, FoodShare, and other food and nutrition programs.
W-2 agencies should encourage minor parents to apply for child care assistance through the Wisconsin Shares program online or at their local Income Maintenance agency .
When appropriate, a referral for the minor parent must be made to the county or tribal social/human services agency or another appropriate community-based organization for assistance in finding an adult-supervised supportive living arrangement.
EXAMPLE: K errie and Anthony, both age 17, live with their daughter, Olivia, and Kerrie's mother, Sandra. Sandra's income provides the household's only income and exceeds W-2 financial eligibility requirements. Kerrie and Anthony still qualify for the CMM Case Management Minor Parents placement solely based on their status as minor parents, regardless of their living arrangement or W-2 financial and nonfinancial eligibility status.
The Case Management for Pregnant Women (CMP) placement is for pregnant women who do not have custody of any children. CMP allows participants to receive case management services during pregnancy, even if they are not a custodial parent.
To be eligible for a CMP Case Management Pregnant Women placement, the individual must:
Have a medically verified pregnancy; and
Meet all the financial and nonfinancial eligibility criteria (see Chapters 2 and 3 ), with the exception of being a custodial parent of a dependent child.
The W-2 agency may provide the following services to individuals in a CMP placement:
Employment Search (ES);
Child Care Related Activities (CC); and
Other Case Management activities (See the Activity Codes Appendix for a full list).
Once the child is born, the participant may be eligible for the CMC Custodial Parent of an Infant placement.
If the participant has a medically verified at-risk pregnancy and also meets the ARP At Risk Pregnancy eligibility criteria, they may be eligible for case management services through a paid ARP placement. (See 7.4.4.1 )
EXAMPLE: Shawna is five months pregnant and does not have custody of any children. Shawna meets all W-2 Wisconsin Works financial and nonfinancial eligibility requirements with the exception of being a custodial parent of a dependent child and has a medically verified pregnancy. Shawna meets all of the eligibility requirements for a CMP placement.
The CMD Case Management Denied placement is for individuals who have reached their 24-month placement time limit or 48-month state lifetime limit and are no longer eligible for a paid placement. When a participant is denied or declines an extension, the FEP Financial and Employment Planner must offer the CMD placement.
To be eligible for the CMD placement, the participant must meet W-2 Wisconsin Works financial and nonfinancial eligibility criteria (see 2.2.1 ), with the exception of exceeding the 24-month placement time limit or 48-month state lifetime limit.
The goal of the CMD placement is to:
Match the individual to employment;
Connect the individual and their family to resources and services; and
Reassess, on a monthly basis, whether the individual is eligible for an extension.
E XAMPLE: Karl has been a CSJ Community Service Job participant for 18 months and assigned the following activities:
Life Skills;
Job Readiness/Motivation;
Mental Health Counseling for his daughter Kassandra;
Work Experience; and
Employment Search.
After missing multiple activities without good cause, Karl’s FEP referred him for a formal assessment with a mental health provider. However, Karl did not follow through with the referral. As Karl approached his 24th month, Karl’s FEP attempted to reach him by phone and mail a number of times to discuss an extension, but Karl never responded. In Karl’s 22nd month, Karl contacted his worker and told them that he was having a hard time. Karl’s FEP recognized that Karl may be suffering from depression and that without additional support to help Karl participate, that they would have to deny eligibility for another time limit extension.
Karl’s FEP gave him a three-month extension and, in addition to Work Experience and Employment Search, scheduled a new referral for a formal assessment with a mental health provider that provides virtual appointments so Karl would not have to leave his house.
Karl participated sporadically in the assigned activities but never followed through on the second formal assessment referral. The FEP denied eligibility for a subsequent time limit extension due to Karl’s nonparticipation and placed Karl in a CMD to try and assist Karl in finding employment.
Services provided to a CMD participant will depend largely on the:
Reason the extension was denied or declined by the participant; and
Placement the participant was in when they declined or were denied an extension.
Participants who are denied an extension due to nonparticipation may be assigned activities similar to activities assigned while in the subsidized employment position.
FEPs must meet with CMD participants:
Weekly, to help the participant find employment and connect them with needed resources; and
Every 30 days to review the CMD placement. (See 1.4.2.4 )
During the 30-day review, the FEP must reassess the case. If the participant has consistently participated, the FEP must reassess for potential barriers to employment and determine whether an extension is appropriate.
A participant in the CMD placement who finds unsubsidized employment may be placed in the CMU placement. FEPs should document this in PIN comments.
CWW Field Rule Exception W-2 Wisconsin Works Episode Begin Date For initial placements, the W-2 Episode Begin Date The date an individual is determined eligible for W-2 and is placed in an initial W-2 Placement can be backdated 10 calendar days or back to the W-2 Eligibility Begin Date The date an individual applies for W-2, also known as the W-2 Program Filing Date , whichever date is later (i.e., the more recent date). The W-2 Placement Begin Date The date an individual is placed in a W-2 Placement for an initial W-2 placement must be the same as the W-2 Episode Begin Date. CMC Custodial Parent of an Infant : For an initial CMC placement, the W-2 Episode Begin Date can be backdated up to the Eligibility Begin Date or up to the child's date of birth, whichever date is later (i.e., the more recent date). W-2 Episode Begin Date must be after the W-2 Episode End Date The date an individual is no longer receiving W-2 services of the previous W-2 episode. It cannot be prior to the W-2 Eligibility Begin Date. None W-2 Episode End Date The W-2 Episode End Date cannot be backdated prior to the start of the W-2 participation period when entered after the W-2 Pulldown cycle. (See 10.2.1 ) Also, it cannot be prior to the W-2 Episode Begin Date. None W-2 Placement Begin Date Initial The Placement Begin Date for all initial W-2 placements in a W-2 episode can be backdated to the W-2 Eligibility Begin Date or backdated up to 10 calendar days, whichever date is later (i.e., the more recent date). CMC: For initial CMC placements, the Placement Begin Date can be backdated either to the W-2 Eligibility Begin Date or the baby’s date of birth, whichever date is later (i.e., the more recent date). Subsequent The Placement Begin Date for all subsequent W-2 placements in a W-2 episode can be backdated up to 10 calendar days prior to the current date. CMC: For subsequent CMC placements, the Placement Begin Date can be backdated to the date of the baby’s date of birth. W-2 Placement End Date No backdating rule – this date is auto-populated by CWW. No exception – worker may not enter data.
CWW Field Rule Exception W-2 Wisconsin Works Episode Begin Date A W-2 Episode Begin Date The date an individual is determined eligible for W-2 and is placed in an initial W-2 Placement cannot be a future date. None W-2 Episode End Date A W-2 Episode End Date The date an individual is no longer receiving W-2 services can be a future date for any W-2 placement up to the last day of the last month eligibility is open. For W-2 cases that close with a W-2 Work Program End Reason, the Episode End Date must be the current date. W-2 Placement Begin Date Initial A Placement Begin Date The date an individual is placed in a W-2 Placement cannot be a future date for an initial W-2 placement within a W-2 episode. None Subsequent The Placement Begin Date for all subsequent W-2 placements in a W-2 episode can be a future date of up to 10 calendar days within the same W-2 Target Type. (See Operations Memo 11-67 ) CMC Custodial Parent of an Infant : The Placement Begin Date for a CMC cannot be a future date. W-2 Placement End Date No future-dating rule – this date is auto-populated by CWW. No exception – worker may not enter data.
W-2 Wisconsin Works emphasizes that education and training are pathways to meaningful employment. Education and training activities help provide tangible employment skills and can be combined with work or work training activities to help participants gain the skills necessary for career advancement.
To ensure all W-2 participants, including those placed in case management positions, may participate in education and training activities. W-2 agencies must:
Establish a referral relationship with other employment and training programs to provide participants with varied education and training opportunities; and
Encourage employers to make training sites available on the business site for participants.
The FEP Financial and Employment Planner should encourage participants interested in education and training to define their long-term career goals and help them identify the relevant education and training necessary to create an actionable path to career success.
The FEP should reference the resources outlined in section 8.4.1 when working with an individual interested in education and training.
The W-2 Wisconsin Works agency is required to conduct an educational needs assessment with all new W-2 applicants and before making a change in W-2 placement. (See 5.3.1 )
If a participant is placed in CMF Case Management Follow-Up , CMF+ Case Management Follow-Up Plus , or CMU Case Management Underemployed , the education and training case management services may include:
Employment skills training;
English as a second language classes;
A course of study meeting the high school graduation equivalency standards established under Wis. Stat. s. 115.29(4); or
Other remedial education courses (e.g., adult basic education, literacy services).
The W-2 Wisconsin Works agency must include an education and training activity in the participant’s EP Employability Plan and pay for the education services if:
The W-2 agency determines that the appropriate placement for an individual is CMF, CMF+, or CMU; and
The individual needs and wishes to pursue basic education.
Participants assigned to a CSJ Community Service Job or W-2 T W-2 Transition placement may be assigned education and training activities through any of the following means:
Allowable Activities Eligible Placements Relevant Section An education and training activities assignment for up to: 10 hours per week for individuals placed in a CSJ; and 12 hours per week for individuals placed in a W-2 T. CSJ and W-2 T 8.2.2.2 An aggregated education and training program that enables an individual to participate in an education and training program that requires more than 10 or 12 hours of participation per week. CSJ and W-2 T 8.2.2.3 A full-time technical college education program. CSJ and W-2 T 8.2.2.5 Enrollment in high school or a course of study meeting the high school graduation equivalency standards established under Wis. Stat. s. 115.29(4). 18- or 19-year-old CSJ participants 8.2.2.1
Participants who are interested in education and training activities not covered in W-2 Wisconsin Works policy should be advised on their options, which may include:
Pursuing an education or training program in addition to meeting their W-2 participation requirement through other assigned activities. While not a viable option for everyone, some participants may be able to manage both participation in required W-2 activities up to 40 hours per week plus education and training that is not part of assigned W-2 activities. Any employment search activities assigned by the W-2 agency should target employment that aligns with the training the participant is enrolled in.
Ending their participation in the W-2 program and applying for and using financial aid and other work supports (FoodShare, child care, etc.) to complete the training program. Individuals who wish to pursue education and training outside the scope of the W-2 program should be referred to a career counselor at the nearest Wisconsin Technical College to explore their options.
The W-2 agency should encourage individuals who choose to pursue training outside of W-2 to discuss child care options with their local Income Maintenance agency , as child care eligibility may be affected if the participant is not employed at least five hours per week.
18- or 19-year-old CSJ participants without a high school diploma or equivalent can fulfill, in whole or in part, the required hours of participation in a CSJ by:
Attending high school; or
Enrolling in a course of study meeting the high school graduation equivalency standards established under Wis. Stat. s. 115.29(4).
The W-2 agency must monitor each participant’s progress towards achieving a high school diploma or equivalent.
During the summer months, the agency must:
Assist participants in finding summer employment; or
Assign appropriate employment-related activities if summer employment is not obtained.
18- or 19-year-old CSJ participants who choose not to obtain a high school diploma or equivalent should be assigned to other work training and education and training activities as appropriate.
The FEP may assign education and training activities for the following:
10 hours per week for individuals placed in a CSJ; and
12 hours per week for individuals placed in a W-2 T.
Hours spent in the classroom, doing lab work or study time, must be included as part of the assigned education and training activities.
The following types of activities are allowable under the education and training hours for CSJ and W-2 T participants.
W-2 Education
A course of study meeting the high school graduation equivalency standards established under Wis. Stat. s. 115.29(4).
English as a Second Language.
Adult Basic Education courses.
W-2 agencies may coordinate with the Wisconsin Technical College System , the University of Wisconsin System, or other educational programs to provide a variety of Adult Basic Education opportunities including literacy skills and remedial math courses.
The W-2 activity codes associated with these education activities include:
Adult Basic Education (BE);
English as a Second Language (EL);
General Educational Development (GED);
High School Equivalency Diploma (HE);
Literacy Skills (LS); and
Regular School (RS).
The following activities may be assigned under these activities and tracked for attendance purposes:
Class time;
Supervised study time;
Up to one hour of unsupervised study time for each hour of class time.
A statement from the educational program indicating the amount of study time required must be used to determine the appropriate assignment of hours. This statement can come in the form of, but is not limited to:
A syllabus;
Course description; or
Note from the educational program.
EX AMPLE : Kalid is in a CSJ placement and is enrolled in an adult basic education course at the local technical college where the instructor recommends up to three hours of study time per hour of class time.
Kalid’s FEP assigns three hours of unsupervised study time to match Kalid’s three hours of in class time.
Because Kalid is in a CSJ placement, he can spend up to four hours in supervised study time for a total of 10 hours per week of education and training activities.
For more information on W-2 activities, see Activity Codes Appendix .
W-2 Training
Technical college courses and other educational courses that provide an occupational skill.
Employer-sponsored training.
W-2 agencies can coordinate with technical colleges to offer certified (or diploma/degree) training programs, and work directly with employers to develop on-site training opportunities.
These training courses must be tied directly to occupations for which there are job openings in the community. Examples may include:
Basic welding;
Data entry;
Certified nursing assistants;
Utility installation;
Administrative professional (e.g., administrative assistant, office manager, billing personnel etc.);
Food preparation/culinary arts;
Electronic assembly;
Child care;
Press production;
Construction;
Entrepreneurial/small business; and
Hospitality training.
The W-2 activity code associated with these training activities is Job Skills Training (JS).
The following activities may be assigned under Job Skills Training (JS) and tracked for attendance purposes:
Class time;
Supervised study time;
Up to one hour of unsupervised study time for each hour of class time.
A statement from the educational program indicating the amount of study time required must be used to determine the appropriate assignment of hours.
If these activities are not available through the Job Center or other community resources, W-2 agencies must take responsibility for funding these services if assigned as a required activity, with the exception of a full-time technical college program. (See 8.2.2.5 )
CSJ or W-2 T participants who want to enroll in a short-term intensive training program that requires more than 10 or 12 hours of participation per week, may use more than 10 or 12 hours per week of education and training activities so long as they do not exceed 516 hours total within a one-year period. This is called the aggregation policy.
The aggregation policy can be used for education and training programs that:
A W-2 T and CSJ participant can complete within a one-year period; and
Do not exceed 516 hours of required participation in education and training activity per year.
In addition to the education and training activities, the FEP Financial and Employment Planner must assign work training activities each week, not to exceed a total of 40 hours of participation per week.
When the aggregation policy is used, The FEP must document in PIN comments the:
Amount of aggregated education and training hours;
Occupational skills to be gained; and
Expected number of weeks needed to complete the training.
Wisconsin’s Technical College system offers many one- and two- semester certificate programs accessible to W-2 participants under the aggregated education and training policy.
EXAMPLE: Jennifer is a W-2 participant placed in a CSJ. Jennifer decides she wants to enroll in a short-term intensive training program and enrolls at her local technical college in a 16-week certificate program.
Lecture time and lab work requires her to attend school 20 hours per week. In addition, her instructor provides a written statement estimating that Jennifer will need to spend 10 hours per week studying.
Using the aggregation policy, the FEP assigns her to participate in a total of 40 hours per week:
30 hours per week in the program; and
10 hours per week of work training activities.
Jennifer’s total aggregated education and training time over this 16-week timeframe is 480 hours (30 hours per week x 16 weeks), keeping her within the aggregation policy’s one-year completion period and the 516-hour yearly limit.
If the FEP is unsuccessful in connecting Jennifer to unsubsidized employment after she completes her short-term intensive training program, her hours of participation in education and training activities are limited to the following:
For the remainder of the year, beginning with the date of her assignment to the education and training program, Jennifer cannot be assigned to more than 36 hours of education and training (516 – 480 = 36).
One year following the date of her assignment to the education and training program, if Jennifer is still in a CSJ placement, 10 hours per week of education and training activity may be assigned.
A prorated CSJ placement is appropriate for individuals who are:
Working in an unsubsidized job less than 30 hours per week; and
Identified, through an informal assessment, to have barriers that prevent them from obtaining an additional unsubsidized job or from increasing the number of hours in their current job.
See 7.4.1 for additional characteristics of an employed individual who may be appropriate for a prorated CSJ.
In some cases, these individuals may benefit from an intensive short-term training program using the aggregated education and training policy. (See 8.2.2.3 )
When combining the prorated CSJ policy and the aggregated education and training policy, the total hours of participation, including unsubsidized employment, must not exceed 40 hours per week.
EXAMPLE : Laura works 15 hours per week at a local restaurant. The FEP discusses Laura’s employability options and determines that she would benefit from additional training to expand her options for full-time employment. The FEP assigns her to a half-time CSJ.
A prorated CSJ would normally require Laura to participate 11 to 15 hours in work training and up to 10 hours of education and training per week. But Laura would like to participate in a certificate program on Medical Billing offered through the local technical college. The 16-week certificate program requires Laura to be in the classroom 14 hours per week. In addition, her instructor provides a written statement estimating that Laura will need to spend an additional six hours per week studying.
Laura’s total aggregated education and training hours over the 16-week timeframe is 320 hours (20 hours per week x 16 weeks) of education and training.
In addition to her training activity, the FEP assigns Laura to 5 hours per week of work experience at a site specifically related to the training. Laura is participating a total of 40 hours (15 hours in unsubsidized employment, 20 hours in education and training and 5 hours in work experience). Laura meets the requirements of the prorated CSJ policy while also benefiting from the aggregated education and training policy.
An individual placed in a CSJ or W-2 T may participate in a full-time technical college education program:
For the duration of the program but for no longer than two years, as long as the agency has determined that the program will likely lead to employment; and
As part of their CSJ or W-2 T placement if the participant meets all three of the following requirements: Is enrolled full-time and regularly attends all classes (up to 15 hours per week) in a program offered through the Wisconsin Technical College System that requires between one and two years of class--time to complete; Maintains a minimum grade point average of 2.0 (or the equivalent, as determined by the technical college); and Is employed or engages in work activities under a CSJ or W-2 T for 25 hours per week in addition to class time. The 25 hours must include the study time required for the program as well as other work activities that relate to the training the participant is engaged in that will improve the likelihood of obtaining employment once the training is completed. This may include activities such as: Work study or internships; Career planning or counseling; and Job shadowing and work experience activities related to the training program.
An agency must consult with its Community Steering Committee and local technical college board to determine if a technical college education program will likely lead to employment. Agencies are encouraged to detail their own internal policies governing how appropriate programs will be identified and how FEPs will make a determination for placement in a technical college education program. In all circumstances, the decision should be documented in PIN comments.
Including the technical college program on the EP does not obligate the W-2 agency to pay for the program out of its W-2 budget. If the participant has not identified available funding for the program, the agency may require the participant to do so. The agency must assist the participant if they apply for financial aid.
The W-2 activity codes associated with full-time Technical College are:
Technical College (TC)
Technical College Study Time (TT)
Education and training resources are available through multiple state, federal, and non-profit programs and providers. Agencies should be familiar with and reference the resources listed below when working with an individual interested in training and education.
The following list of education and training resources in not exhaustive. Agencies should work with local employers, community partners, agencies, programs etc. to provide education and training resources to best fit the needs and goals of each W-2 participants and applicant.
The Department of Workforce Development provides Wisconsin labor market information and resources including on-the-job training opportunities, apprenticeships, and education and training programs for job seekers across Wisconsin.
Education and Training Resource Provides Directory of Workforce Services A list of Workforce Innovation and Opportunity Act (WIOA) partner employment training and education services available in each county. Wisconsin's Eligible Training Programs List (ETPL) A list of education and training programs for WIOA program participants that can be funded by WIOA. Additionally, Trade Adjustment Assistance (TAA) program participants are also encouraged to use the ETPL when selecting TAA-funded training. Workforce Development Areas (WDA) WDAs are the subdivisions of the state for local planning and administration of employment and training programs. The eleven WDAs are used for delivery of Workforce Innovation and Opportunity Act (WIOA), Job Center development and administration, and regional planning of employment and training efforts. The boundaries of the WDAs, which follow county lines and may include more than one technical college district, were drawn in recognition of, and to enhance, positive relationships between counties and local employment and training service providers. WDAs were created in 1998. A Workforce Development Board (WDB) has responsibility for the WIOA program and other workforce development programs within their WDA. Labor market information Wisconsin labor market information, including the occupations in demand for each region and county in the state. DWD SkillExplorer Information on jobs that share similar skills, including: Typical education level required for entry; Required training; and Current openings searchable by location.
The Wisconsin Technical College System (WTCS) offers associate degrees, technical diplomas, short-term certificate options and partners with Wisconsin employers to provide customized instruction and technical assistance to increase the economic vitality of students, employers, and communities throughout Wisconsin.
Education and Training Resources Provides Wisconsin Technical College System Find Your Program A list of WTCS programs by college, program type, delivery method, duration, etc. Wisconsin Technical College System Affordable Education Webpage Information on affordable education options and financial aid including grants, scholarships and loans.
The US Department of Labor Occupational Information Network (O*NET) and CareerOneStop use federal and state level data to provide a variety of tools and resources geared toward helping individuals learn about short-term training programs for in-demand careers near them and the required education, training, and competencies needed for each occupation.
Education and Training Resources Provides CareerOneStop A wide range of free online tools and resources to help individuals: Explore career options; Find training and education; Search for a job; and Find local help and services. Occupational Information Network (O*NET) Career Seach and My Next Move websites. Information on job requirements and worker competencies for employment sectors and occupations.
The goal of W-2 Wisconsin Works work training experience is to help TEMP Trial Employment Match Program , CSJ Community Service Job , and W-2 T W-2 Transition participants find sustainable, family-supporting employment.
This section outlines the required guidelines for a W-2 agency and W-2 work training provider/employer participating in a W-2 work training provider site agreement.
Work training providers and employers can include:
Government;
Public or private non-profit organizations; or
Private for-profit organizations.
W-2 work training providers and employers should provide the following:
Willingness to interview more than one individual for every available position;
The same flexibility in work rules as an employee who is not enrolled in W-2 would receive; and
Sensitivity to work and family issues (i.e., single-parent households, disability-related issues, child care needs).
The W-2 agency and each W-2 work training provider/employer must follow the guidelines listed below and outlined in the Wisconsin Works (W-2) Work Training Site Agreement (10792) .
The W-2 agency must have a signed copy of the Wisconsin Works (W-2) Work Training Site Agreement (10792) on record for any work training provider/employer where a W-2 participant has been placed.
Comply with all federal, state, and local laws, ordinances, and regulations affecting W-2 participants including the: Family Medical Leave Act; Americans with Disabilities Act; and Civil Rights Act of 1964 prohibiting discrimination of any employee or trainee based on race, color, sex, age, sexual orientation, handicap, political affiliation, or national origin.
Provide supervision, structure, performance appraisals, training, materials, and tools normally provided an employee who is not enrolled in W-2.
Provide a safe and healthy work environment in compliance with federal, state, and local health and safety standards.
Develop and provide written expectations for all training positions to be filled by W-2 participants. These may include: Workplace rules such as: Dress codes; Attendance policies; Health and safety standards; Use of company property; and Appropriate workplace behaviors. Information on the training position such as: Training position titles; Work training schedules; Task descriptions; and Skills and abilities necessary for success in that position.
Collect and verify accurate time and attendance records.
Immediately notify the W-2 agency of participant injury, tardiness or absence not authorized by the work training provider, problems detrimental to continued success on the work training site, or transfer/termination from the work training site.
Notify the W-2 agency of any work training site requirements such as tuberculosis testing, driver's license, background checks, physical examinations, etc.
Timely notify the W-2 agency of any changes, such as collective bargaining, at the work training site which might impact a W-2 participant or necessitate a reevaluation of this work training site agreement.
Allow appropriate on-site access to W-2 participants by designated W-2 agency personnel as well as access to any participant records.
Agree to follow the provisions of the Wisconsin Works Employee Displacement Grievance Policy (DCF-P-DWSW13121) .
Not ask or require a W-2 participant to function in any task or activity which promotes or discourages religious, union, or political activity.
Provide work opportunities for W-2 participants suitable to their strengths and ability.
Agree not to disclose information concerning the W-2 participant for any purpose not connected with program administration.
Agree not to provide false information for purposes of securing or ensuring issuance of a W-2 payment.
W-2 Wisconsin Works work training providers/employers must inform their employees not enrolled in W-2 of the right to file a grievance and of the procedure for doing so.
Appropriate notification methods are provided in the Wisconsin Works W-2 Employee Displacement Grievance Policy (13121-P) . Work training providers/employers must inform the W-2 agency of the notification method being used.
An employee of a W-2 work-training provider/employer, who is not enrolled in W-2, may file a complaint with the local JCCC Job Center Complaint Coordinator if they believe:
They or another employee was unlawfully terminated to create a vacancy for a person in a W-2 employment position (i.e., TEMP Trial Employment Match Program , CSJ Community Service Job , or W-2 T W-2 Transition placement); or
A person in a W-2 employment position has been unlawfully placed in a vacancy created by a labor dispute.
Complaints of displacement must follow the procedure outlined in the Wisconsin Works W-2 Employee Displacement Grievance Policy (13121-P) .
W-2 Wisconsin Works work training providers/employers that engage in any of the prohibited displacement practices outlined in the Wisconsin Works Employee Displacement Grievance Policy (13121-P), are subject to the following penalties:
Termination of all existing W-2 work training site agreements after ensuring appropriate reassignment for any W-2 participants assigned to the provider/employer.
Termination of grants from DFES or its contractors and disqualification from future grants.
Disqualification from future W-2 work training site agreements with DFES or DFES contractors.
History : Release 24-13 .
W-2 workers are responsible for supporting participants and their families throughout their involvement in the W-2 program. It is essential workers understand that each W-2 group is unique and their circumstances and needs may change throughout their participation in W-2.
Individuals participating in W-2 face a variety of barriers that may impact program participation, including, but not limited to:
Finding safe, affordable, and reliable childcare;
Physical and mental health challenges;
Transportation;
Housing instability;
Family crisis;
Domestic violence, etc.
This chapter includes resources agency workers can use to support participants and their families, including supportive services plans, family stabilization payments, and transportation assistance.
The goal of a Supportive Service Plan is to ensure participants and their families have the resources they need to address family and work-related needs.
The Supportive Service Plan must include:
Information necessary to connect applicants and participants with supportive services available both within the agency and in the community.
Proactive strategies for addressing family and work needs before these situations result in a family crisis and/or loss of employment.
The W-2 Wisconsin Works agency must offer to develop a Supportive Service Plan with:
Applicants who withdraw their W-2 applications prior to W-2 placement. In this circumstance, the Supportive Service Plan would generally be developed between the Resource Specialist and the applicant.
Participants who are approved or denied a time limit extension.
Participants who are placed in a case management placement, including: CMF Case Management Follow-Up , CMF+ Case Management Follow-Up Plus , CMU Case Management Underemployed , CMD Case Management Denied , CMJ Case Management Job Ready , CMN Case Management Noncustodial Parent , CMM Case Management Minor Parent , CMP Case Management Pregnant Women , and TSP Stipends for Noncustodial Parents .
The Supportive Service Plan must be developed during a meeting (see 1.4.2.4 ) between the case manager and the applicant or participant using either:
The automated W-2 Supportive Service Plan in WWP; or
The W -2 Supportive Service Plan form (12956) .
The automated plan cannot be accessed until after an applicant has been referred to WWP Wisconsin Work Programs . When developing a Supportive Service Plan with an applicant who withdraws their W-2 application prior to placement and no referral to WWP was made, the worker must use the W-2 Supportive Service Plan form (12956) .
When the W-2 Supportive Service Plan form (12956) is used, and the case has been established in CWW CARES Worker Web , the worker must:
Document in PIN comments when the form was printed and given to the individual; and
Scan the form into ECF Electronic Case File .
An applicant or participant may choose not to develop a Supportive Service Plan. If this occurs, the refusal should be documented in PIN comments.
Because circumstances vary greatly from one family to another, it is essential for agency workers to develop Supportive Service Plans that reflect the unique needs of each family. Areas of need that should be addressed include, but are not limited to :
Emergency needs;
Housing;
Access to economic supports;
Household budgeting/money management;
Education and training (participant and other family members);
Legal assistance;
Employment support (i.e. work connection and retention services);
Child care (for job search and work);
Transportation;
Work equipment (e.g., uniform, work shoes or boots, safety equipment);
Personal and family health care; and
Other needs identified by the participant.
The Supportive Service Plan must include, at a minimum, the following elements for each identified need:
A short-term plan of action to help the participant address emergency or short-term needs;
A long-term plan of action that includes incremental steps to help the participant address long- term goals such as completing an education or training program or securing permanent housing;
Resource and referral information for any known government and community resources that may help to address the need, including an explanation of the purpose of each resource and how it addresses or relates to the identified need; and
W-2 Wisconsin Works agency contact information.
Workers must never enter confidential information in the W-2 Supportive Service Plan in WWP Wisconsin Work Programs . See 4.2.2.1 for a list of confidential information that must never be entered on WWP pages without the additional security protections.
EXAMPLE : Susan is in a CSJ placement. Susan has never had a driver’s license and rode the bus to her work site and back. However, her new job requires a much longer bus ride making it difficult for her to return home from work before her children arrive home from school. During her Supportive Service Plan meeting, Susan shared that she is considering quitting her job because of the long commute.
Together, the FEP and Susan updated her Supportive Service Plan. Her new short-term plan of action is to locate an after-school program for her children to attend so Susan will not have to quit her job. Her new long-term plan of action is to get her driver’s license and purchase a car.
The FEP identified five community resources that Susan may benefit from, including:
A referral to Wisconsin Shares to help cover child care costs;
A community driver's education program;
Two different after school programs near Susan's home; and
A community bank that offers low-interest car loans to income-eligible individuals.
Family stabilization payments are payments designed to meet participants’ needs at the beginning of a W-2 Wisconsin Works episode and qualify as a Non-Recurrent, Short-term Benefit under the TANF Temporary Assistance for Needy Families definition of assistance.
These payments are an important piece of providing a whole family approach to meeting participants’ needs.
Participants are not required to repay family stabilization payments.
There is no limit on the family stabilization payment amount and the W-2 agency should support the full need amount when possible.
However, payments more than $3,000 must have Contract Administration Section Manager approval. (See 19.3.3 )
Payment Eligibility
To be eligible, participants must be:
In a CSJ Community Service Job , CMC Custodial Parent of an Infant , W-2 T W-2 Transition , ARP At Risk Pregnancy , or TEMP Trial Employment Match Program placement;
In the period prior to their first scheduled W-2 Wisconsin Works payment; and
Experiencing a need.
W-2 agencies must determine eligibility during the initial informal assessment. When possible, payments should be used in conjunction with other supports available to participants, including the Emergency Assistance program, but it is not required.
Family stabilization payments do not use a month of TANF Temporary Assistance for Needy Families assistance and do not count as an additional W-2 benefit.
Participants can receive no more than four family stabilization payments within 12 months. Participants can only receive one family stabilization payment per W-2 episode.
Payment Uses
Family Stabilization payments may be used for needs, including, but not limited to :
Housing;
Food;
Work-related expenses;
Insurance;
Toiletries/household items/diapers;
Phone payments;
School supplies;
Short-term child care;
Legal fees, etc.
W-2 agencies must use the Family Stabilization Payment Request form (5751) to track issuance of these payments; no other application form can be used. The Family Stabilization Payment Request form must be completed by the participant.
W-2 agencies must scan the completed form into ECF Electronic Case File under the APP scan code following disbursement of the funding. Additionally, for payments requiring Contract Administration Section Manager approval, the approval must be scanned into ECF with the Family Stabilization Payment Request form.
Workers must document in PIN comments when a participant requests a family stabilization payment and if the payment was approved or denied. Family stabilization payments are not tracked through the CARES Client Assistance for Reemployment and Economic Support system.
Workers must document family stabilization payments on the Supportive Services page in WWP Wisconsin Work Programs . (See 4.3.4 )
The W-2 agency may issue the payment to:
The participant; or
A third party by participant request.
Workers must offer the participant a choice in how this payment is issued, either to the participant or to a third party. Workers must document in PIN comments the details of the participant's preferred method of payment.
EXAMPLE : Stan receives a family stabilization payment at placement before his first initial W-2 payment. Stan participates in the W-2 program for six months and exits. Stan applies and is approved to enter the W-2 program again. He is in need of a mobile phone and money for phone payments. He is approved for a family stabilization payment for this, as it is before his initial W-2 payment and is his second family stabilization payment within 12 months.
The W-2 Wisconsin Works agency must provide transportation assistance services to applicants and participants when it is necessary to ensure participation in W-2 activities.
Transportation services provided may vary by agency, based on the options in the area that are both available and reasonable. W-2 agencies must work together with applicants and participants to determine the types of transportation options that are reasonable to each individual’s needs. A reasonable transportation option must meet all of the following criteria:
The transportation option is safe;
All out-of-pocket transportation costs are reasonable with respect to the individual's income;
The one-way travel time between home, childcare, and work or activities is reasonable, as determined by the FEP and participant on a case-by-case basis; and
All relevant factors have been considered, (e.g., whether the option that is the most convenient and reliable also meets the other criteria).
All W-2 Wisconsin Works applicants and participants, regardless of W-2 placement, are eligible for transportation assistance, so long as the transportation is necessary for W-2 activities and childcare.
W-2 status Eligible for transportation assistance only if the transportation is necessary for: Applicant Up-front job search and childcare. Participant W-2 activities and childcare.
Individuals in need of transportation assistance who are not in a W-2 placement or not assigned to up-front job search (e.g., persons receiving assistance through the EA Emergency Assistance Program) must apply for W-2 and be placed in a W-2 case management position or assigned up-front job search to receive transportation assistance.
W-2 agencies must provide public transportation resources whenever the services are available and will reasonably meet the individual's needs. In determining the best transportation alternative, the FEP must consider the reasonability criteria listed in 9.4.1 .
If public transportation is not available or reasonable, the W-2 agency may provide private or personal transportation resources, including, but not limited to:
Gas cards;
Private van services; or
A referral to the W-2 Job Access Loan program. (See 17.1 )
If public transportation is not an option, the W-2 agency must take whatever reasonable measures are necessary to overcome transportation barriers.
A W-2 Wisconsin Works applicant or participant who receives transportation assistance is subject to all TANF Temporary Assistance for Needy Families requirements pertaining to the 60-month federal lifetime limit and other nonfinancial requirements. (See 2.2.1 )
However, transportation assistance will not use a month toward the 60-month federal lifetime limit and 48-month state lifetime limit for:
W-2 participants in CSJ Community Service Job , pro-rated CSJ, W-2 T W-2 Transition , and some CM C Custodial Parent of an Infant placements (see 2.10.8 ) as the participant will already be using a federal month due to the receipt of TANF cash assistance.
W-2 participants in an unpaid, case management only, placement if any of the following apply: They are employed for at least one hour per month; They are engaged in job search/readiness activities requiring child care; The transportation is not provided for longer than four months; or The transportation services are provided via a group transportation or transportation capacity building project (e.g., someone who rides a TANF funded expanded bus route is not receiving assistance because the service does not have a direct monetary value to the individual family).
When transportation assistance will use a federal and state month of assistance, the FEP Financial and Employment Planner must explain the potential impact and help the applicant or participant weigh the cost of using months of lifetime eligibility against the benefit of the service before assistance is given.
Workers must document all provided transportation service assistance on the Supportive Services page in WWP Wisconsin Work Programs . (See 4.3.4 )
Two goals of Wisconsin Works (W-2) are:
To prepare parents to secure and maintain stable employment; and
To help parents achieve economic stability.
For this reason, W-2 agencies provide case management and employment services to eligible Noncustodial Parents (NCPs).
W-2 offers eligible NCPs Noncustodial Parents a variety of employment services and programs including access to case management services, job search assistance, and subsidized employment through the Trial Employment Match Program (TEMP). (See 7.5.1 )
Eligible NCPs may also qualify for:
Educational services;
Stipends for work preparation; and
Job Access Loans (JAL) to help pay for work equipment, car repairs, and other job-related expenses.
These services and programs help NCPs to gain employment skills, access educational opportunities, and sustain their involvement in the workforce. When NCPs Noncustodial Parents succeed, custodial parents and their children benefit.
The following table includes a list of potential benefits related to assisting NCPs.
Group Potential Benefits Noncustodial Parents Higher wages and rates of employment; Ability to provide for their children; and Greater engagement with their children. Custodial Parents Greater financial and parental engagement from the NCP; and Greater ability to secure childcare and healthcare. Children Increased involvement with NCP; Greater academic success; Improved behavior and mental health; and Higher earning and rates of employment later in life.
Many NCPs face complex challenges. NCPs may need assistance beyond what can be offered by W-2 to maintain employment and support their families.
Along with local resources, W-2 agency workers should be familiar with additional free or low cost services available to NCPs. Some examples of such programs are listed below.
Resource Description 211 Wisconsin Provides support and resources for a variety of complex issues. Trained specialists are available 24 hours a day to assist Wisconsinites with mental health, substance abuse, food security, utilities, and housing issues. 211 Wisconsin can refer callers to the thousands of local programs and services available. FindTreatment.gov Is a service provided by the Federal Substance Abuse and Mental Health Services Administration to assist people in finding treatment facilities in their area. Substance abuse, mental health, health care, buprenorphine, and opioid facilities are available. Job Center of Wisconsin Connects job seekers with a diverse range of employers from across the state. LIFT Wisconsin Provides free legal assistance to people attempting to change child support orders, remove criminal records, remove eviction records, answer debt claims, and reinstate driver’s licenses. Wisconsin Association of Free & Charitable Clinics Provides primary care, dental care, and pharmaceuticals to uninsured and economically disadvantaged people. Wisconsin Office of Rural Prosperity Offers a resource directory that helps rural Wisconsinites access broadband internet, health services, housing, food, transportation, and more.
The W-2 Wisconsin Works agency is responsible for identifying participants who may be eligible, or who express an interest in applying for SSI Supplemental Security Income / SSDI Social Security Disability Insurance through screening, formal assessment, and consultation with other providers of disability-related services. When the participant and agency agree that the participant’s situation is appropriate for SSI/SSDI advocacy, the agency is responsible for assisting with the SSI/SSDI application and appeals process to the extent needed by each participant. Participants who are receiving SSI/SSDI advocacy should be placed in the appropriate placement using the same criteria used to determine placements for other participants. (See 7.1 )
A Disability Starter Kit is available on the Social Security Administration (SSA) website and provides additional information and documents to assist individuals with an online application or to prepare for a disability interview. Kits are available for adults and for children under age 18.
The W-2 agency must maintain staff with a working knowledge of the SSA guidelines used to determine SSI/SSDI eligibility including, but not limited to, the forms needed to apply and the methods used by the SSA when determining eligibility.
An SSI/SSDI application is submitted to the SSA Social Security Administration . To determine whether an individual is disabled according to Social Security regulations, the SSA examines:
The severity of an individual’s impairment(s);
Current age;
Education; and
Work history.
During the SSI/SSDI application process, the local SSA office is responsible for verifying non-medical eligibility requirements (financial and non-financial), which may include age, employment, marital status, or Social Security coverage information. Once verified, the SSA office sends the case to the Disability Determination Bureau (DDB) for evaluation of the disability.
It may take several months for SSA to process a submitted application. During this time, the W-2 agency should maintain contact with the SSA to ensure they have all the necessary information, the application is being processed correctly, and any issues are being resolved in a timely manner.
In some cases, an SSI application may be denied. If this happens, it is essential to support the participant through the appeals process.
The application process includes provisions for an applicant to appeal an SSI/SSDI eligibility decision. There are four levels to the application and appeal process:
Initial application;
Request for Reconsideration;
Request for Hearing with SSA Office of Hearing and Appeals ; and
Appeals Council Review.
The W-2 agency must review, monitor, and document the progress of the SSI/SSDI application and the progress with the assigned activities in CARES and WWP. The FEP should review existing case comments and activity progress every 60 days.
SSI/SSDI advocacy must be provided directly by the W-2 agency, through subcontract, or through a referral to an SSI/SSDI advocate.
An SSI/SSDI advocate provides specific services to facilitate the approval of a W-2 participant’s application for SSI/SSDI or appeal of an SSA decision. The roles and responsibilities of the advocate are the same whether a W-2 agency provides for advocacy through its own in-house staff or through an outside resource. A W-2 participant should receive SSI/SSDI advocacy services throughout the SSI application process including the initial application, reconsideration, or appeal.
In general, a qualified SSI/SSDI advocate must have the program background and knowledge necessary to successfully assist W-2 participants with the SSI/SSDI application process. In particular, an advocate should have the following background and knowledge:
Experience working in an SSI/SSDI advocacy role;
General knowledge of W-2 policy and procedures;
Knowledge of the SSI/SSDI application and appeal processes; and
A legal or medical background, or experience in the field of disabilities.
The SSI/SSDI advocate plays a vital role in a participant’s application process. An SSI/SSDI advocate shall gather the necessary information to build a strong medical narrative to accompany the participant’s SSI/SSDI application. Advocates must also gather information about the participant’s ability and capacity to work.
Ways in which this information can be collected include:
Formal and informal assessments;
Case management relationship; and
Through the participant’s experience participating (or failing to participate) in assigned activities and/or work experience.
The services outlined below may be provided at any point during all phases of the SSI/SSDI application or appeal process:
Review medical documentation and build a medical narrative.
Assist in supplying initial and subsequent documents, including non-medical documentation.
Coordinate with the case manager or an appropriate service provider to schedule additional evaluations that may build the medical narrative and support the disability claim.
Communicate information to and facilitate contacts among involved parties.
Attend phone calls, meetings, hearings, and appointments with the participant as needed or requested.
Present the facts in a participant’s case that favor a decision of disability.
Ensure all relevant documentation is available to the DDB Disability Determination Bureau .
Assist the participant in complying with the SSI/SSDI claim requirements.
Act as a liaison among SSA, DDB, and medical professionals.
Coordinate with the W-2 agency and the FEP to establish a referral process and an ongoing communication network, to include SSI/SSDI related activities on the Employability Plan and to provide supportive services such as transportation and childcare for SSI/SSDI related activities.
The SSI/SSDI advocate should maintain regular contact with the SSA, DDB, and W-2 participant throughout the application and appeal process.
If a participant wants more involvement from the SSI/SSDI advocate, they may appoint the advocate to be an authorized representative. The authorized representative may do all of the activities listed in 9.6.1.3 , and:
Review the applicant’s file at the local SSA office.
Get information from SSA about the claim, including notices and letters, just as the applicant does.
Represent the applicant at informal or formal hearings.
Provide SSA with evidence for the applicant, and/or help with the appeals process.
The SSA website provides authorized representatives with information and the necessary forms needed to effectively assist individuals with their SSA application or appeal.
No W-2 agency, W-2 agency staff member, or W-2 agency subcontractor may charge the participant a fee for providing authorized representative services.
To share necessary information with the other providers working with the participant, including SSA and DDB, an advocate must have a participant signed Authorization for Disclosure of Confidential Information form (10779) .
Individuals that are not an authorized representative but want to receive information from SSA or DDB about the participant during the application or appeals process, must send a participant signed SSA Consent for Release of Information form (SSA-3288) to SSA or DDB.
To determine the monthly SSI/SSDI payment, SSA divides the amount of the W-2 payment by the number of individuals in the W-2 Group and uses the resulting dollar amount to determine the SSI applicant’s share of the W-2 payment. The SSI applicant’s share of the W-2 payments is then used in the budget to determine the SSI/SSDI payment. This calculation is used whether the SSI/SSDI applicant is the W-2 participant, or another W-2 Group member.
If the SSI/SSDI applicant is also the W-2 participant, SSA will use a portion of the W-2 payments to determine the monthly SSI/SSDI benefit amount until the participant is no longer receiving W-2 payments. Generally, the SSI/SSDI applicant will be eligible for monthly SSI/SSDI benefits back to the month of application.
The case manager may begin to develop a written Transition Plan with the participant early in the SSI Supplemental Security Income advocacy process using the automated SSI/ SSDI Social Security Disability Insurance Transition Plan.
The Transition Plan must be developed during a meeting between the FEP Financial and Employment Planner and the participant. Once there is a formal decision handed down from the Social Security Administration (SSA) regarding eligibility for SSI/SSDI, the Transition Plan should be finalized with the participant. The final Transition Plan should be issued to the participant no sooner than 90 days prior to W-2 Wisconsin Works eligibility ending and reviewed regularly with the participant up until W-2 eligibility ends. The FEP must document in PIN comments when the final plan was printed and given to the participant.
Circumstances will vary greatly from one family to another, which will require case managers to be resourceful as they work through the plan with the participant. Areas of need that should be addressed include:
Emergency needs;
Housing needs;
Household budgeting and/or money management needs;
Access to economic supports;
Education and training needs for the participant and other family members;
Legal assistance needs;
Employment support needs with particular emphasis on work connection resources targeted at individuals with disabilities;
Child care needs for job search and work;
Transportation needs;
Personal and family health care needs; and
Other needs identified by the participant.
The Transition Plan must include, at a minimum, the following elements for each need that is identified:
A plan of action . A short-term plan of action should help the participant address an emergency or short-term needs. A long-term plan of action includes the steps necessary to carry out a goal towards self-sufficiency, such as completing an education or training program or securing permanent housing.
Resource and referral information for any known government and community resources that may help to address a participant's need. The Transition Plan should explain the purpose of each resource and how it addresses or relates to the participant’s identified need(s).
A W-2 worker must never enter confidential information in the SSI/SSDI Transition Plan in WWP. See 4.2.2.1 for a listing of confidential information that must never be entered on WWP pages without the additional security protections.
Important Topics to Cover in the SSI/SSDI Transition Plan
Benefits and supportive services targeted at individuals with disabilities, including recipients of SSI/SSDI. Examples include:
Ticket to Work :
The Ticket to Work and Self-Sufficiency Program is an employment program for individuals with disabilities who are interested in going to work. The Ticket to Work Program is designed to remove many of the barriers that influence people’s decisions about working because of the concerns over losing health care coverage. The goal of the Ticket to Work Program is to increase opportunities and choices for SSDI to obtain employment, vocational rehabilitation, and other support services from public and private providers, employers, and other organizations. To access a list of Ticket to Work providers in Wisconsin, see the SSA Ticket to Work webpage .
Division of Vocational Rehabilitation (DVR ): Provides employment services and counseling to people with disabilities; Provides or arranges for services to enable an individual to go to work; and Provides training and technical assistance to employers regarding disability employment issues.
A person is presumed eligible for DVR services if they are receiving SSDI or SSI and want to work. DVR service locations, see the DVR services for job seekers webpage .
Independent Living Centers (ILC):
Wisconsin ILCs are community based, consumer directed, nonprofit organizations. ILCs are nonresidential organizations serving persons of any age with any disabilities in all 72 Wisconsin counties. Unique in the world of human services, ILCs are governed and operated by a board and staff composed of a majority of people with disabilities. At a minimum, all ILCs funded through a contract with a designated state entity are required to provide these core services:
Peer Support – staff and trained volunteers provide support, encouragement, and guidance for individuals with disabilities;
Information and Referrals – one-stop shopping for information related to disability or services for individuals with disabilities, families, employers, and the community;
Independent Living Skills Training – assessment and training for people with disabilities in areas such as money management, housekeeping, communication, self-advocacy, prevocational skills and socialization; and
Individual and Systems Advocacy – consistent with the philosophy of independent living, individuals with disabilities are empowered to advocate for themselves. In addition, ILCs can engage in activities designed to create positive change in local, state, and federal systems affecting individuals with disabilities.
Services that facilitate the transition from nursing homes and other institutions to the community, provide assistance to those at risk of entering institutions, and facilitate transition of youth to postsecondary life.
For more information about these centers and where they are located, see the DHS Independent Living Center webpage .
Application Information for Caretaker Supplement (CTS):
Wisconsin’s CTS is a cash benefit available to parents who are eligible for SSI payments. Individuals can apply for CTS over the phone, by mail, or at a local agency. Applications can also be submitted in ACCESS when applying for health care or Foodshare benefits. More information on what CTS is, benefit amounts, and how to apply, see the DHS Caretaker Supplement Benefit webpage .
Aging and Disability Resource Centers (ADRCs):
ADRCs are service centers that provide a place for the public to get accurate, unbiased information on all aspects of life related to aging or living with a disability. These centers are friendly, welcoming places that anyone can contact to receive information and assistance regarding not only the public benefits that may be available, but all of the programs and services available throughout the area.
Individuals, concerned families or friends, or professionals working with issues related to aging, physical disabilities, developmental disabilities, mental health issues, or substance use disorders can receive information specifically tailored to each person's situation. ADRC services can be provided at a center, via telephone, or through a home visit, whichever is more convenient to the individual seeking help. For more information on what services are provided and ADRC locations, see the DHS Aging and Disability Resource Centers webpage .
Government-funded economic supports, including but not limited to: CTS; FoodShare; BadgerCare Plus – for dependent children of the SSI/SSDI recipient; Child Support; Wisconsin Shares Child Care Subsidy Program – for individuals who plan to work in unsubsidized employment or attend job skills training while employed; and Wisconsin Home Energy Assistance Program (WHEAP).
Community-based supportive services that may address unmet needs and prevent crisis situations from arising. Examples include: Subsidized housing programs; Household budgeting/money management services; Transportation services; Legal assistance services; Mental health and AODA Alcohol and Other Drug Abuse services; Domestic violence services; Adult literacy services; and Other services, including volunteer organizations.
W-2 Wisconsin Works participants in the following W-2 placement types receive payments:
Placement Type Monthly Payment Full CSJ Community Service Job $653 1/3 CSJ: for up to 10 hours of work training and up to 10 hours of education and training per week. $218 1/2 CSJ: for 11 to 15 hours of work training and up to 10 hours of education and training per week. $327 2/3 CSJ: for 16 to 20 hours of work training and up to 10 hours of education and training per week. $435 W-2 T W-2 Transition $608 CMC Custodial Parent of an Infant $673 ARP At Risk Pregnancy $673
In order to understand how W-2 Wisconsin Works payments are issued, it is important to first understand the payment cycles and the W-2 participation period.
There are two payment cycles that generate W-2 payments.
W-2 Pulldown Payment Cycle ( W2P W-2 Pulldown Payment Cycle ): This W-2 payment cycle occurs about five days prior to the end of the month with participants receiving their checks by the last day of the month.
W-2 Delayed Payment Cycle ( W2L W-2 Delayed Payment Cycle ): This W-2 payment cycle occurs around the 7th of the month with participants receiving their checks by the 10th of the month.
These payment cycles run on different days of each month. Specific monthly dates can be viewed:
On the TBIC Benefit Issuance Control Table located in CWW CARES Worker Web using the Ref Table Search under Reference Tools; or
By viewing the W-2 Benefit Issuance Schedule tab located on the BWF Work Programs Help Desk Home Page .
The timing of the payment depends on whether the individual receiving the check is:
A new participant (having just applied and been found eligible); or
An ongoing participant.
If the individual is a new participant, the payment is issued based on which day during the W-2 participation period the person was placed in a W-2 employment position. The W-2 participation period is from the 16th of a month to the 15th of the next month.
W-2 payments include all reductions for missed hours of assigned activities and other penalties imposed during the participation period. (See 11.2.1 )
History : Release 26-03 ; Release 24-13 ; Release 20-03 .
When a new participant starts a W-2 Wisconsin Works job, the timing and amount of their first payments depend on their placement date.
If the placement date falls on or between the 1st and the 15th of the month : The participant will receive a prorated payment for that month, issued in the monthly W2P W-2 Pulldown Payment Cycle . Starting the following month, the participant will receive their full monthly payments issued in W2P for each full participation period.
If the placement date falls on or between the 16th and the last day of the month : Their first payment will be prorated and split into two parts: The first partial payment will be issued in the monthly W2L W-2 Delayed Payment Cycle payment, covering participation from the placement begin date to the end of that month. The second partial payment will be issued in the W2P payment, covering participation from the 1st to the 15th of the next month. After these initial payments, the participant will receive their full monthly payments issued in W2P for each full participation period.
EXAMPLE 1: Placement between the 1st and the 15th of the Month
EXAMPLE 2 : Placement between the 16th and the End of the Month
Once W-2 Wisconsin Works is open and ongoing, subsequent monthly payments are issued in W2P W-2 Pulldown Payment Cycle at the end of the month in which the participation period ends.
As with unsubsidized employment, a final payment is issued for the current participation period when an individual leaves a W-2 Wisconsin Works employment position. Participants who become ineligible for W-2 will receive a prorated final payment for the percentage of the participation period they were in the placement on the W-2 Placement page in CWW CARES Worker Web .
EXAMPLE 1: Mary reports on May 19 that she moved to Minnesota. Mary is no longer eligible for W-2 services. Mary's W-2 placement end date is May 18. Mary will receive her final payment at the end of June for three days of participation (May 16, 17, and 18).
EXAMPLE 2: John is in a CSJ and reports on June 1 that he found unsubsidized employment and will begin his new position on June 27. The FEP Financial and Employment Planner informs him that he may continue to participate in the CSJ until his employment begins and informs the CSJ work training provider that John will be leaving the position. The FEP verifies John’s employment with his new employer and verifies that John will begin on June 27. Any hours missed without good cause up until June 26 will be deducted from the final payment.
When a W-2 Wisconsin Works participant moves between W-2 placements, their payments may or may not be prorated depending on the W-2 placement types.
When a participant moves from The payment is A W-2 T into a CSJ placement during a participation period Not prorated A CSJ, W-2 T, or CMC into an unpaid placement during a participation period Prorated An unpaid placement into a paid placement Based on when the new W-2 Placement Begin Date falls A CMF+ placement into a paid placement during a participation period Not prorated
When a participant moves between a W-2 T W-2 Transition and a CSJ Community Service Job placement during a participation period, the payment is not prorated. The participant receives the payment of the last assigned W-2 Paid Employment Position A Community Service Job or W-2 Transition placement for that participation period.
The participant uses a month of assistance based on the last W-2 Employment Position Community Service Job, Trial Employment Match Program, and W-2 Transition in a calendar month, not the participation period. (See 2.10.3 and 2.10.9 )
EXAMPLE : Jennifer is in a W-2 T placement. On August 9, her FEP Financial and Employment Planner places her in a CSJ. Her payment for participation from July 16 through August 15 is at the CSJ amount. Jennifer will use a month toward her W-2 T 24-month placement time limit for the month of July, and a month toward her CSJ 24-month placement time limit for August, as long as she is not moved to a W-2 T before the end of the calendar month.
When a participant in a CSJ, W-2 T, or CMC Custodial Parent of an Infant moves to an unpaid placement, the participant will receive a final prorated payment for the time that they were actually in the paid placement during the participation period.
EXAMPLE 1 : Rhonda is in a CSJ. On May 18, her FEP places her in a CMF. Her payment for CSJ participation on May 16 and 17 will be a prorated.
When moving from an unpaid placement to a paid placement, the participant will be paid similar to a new participant. (See 10.2.1 )
EXAMPLE 2 : Layla is placed in a CMU Case Management Underemployed placement in July. In August, Layla loses her job and on August 18, the FEP changes her placement to CSJ based on a reassessment. A prorated initial payment for the participation period 8/18 – 8/31 is issued on or about September 7, during W2L W-2 Delayed Payment Cycle . Layla’s next payment is also a prorated payment issued at the end of September for the participation period 9/1 – 9/15. Regular ongoing payments starting with the participation period 9/16 – 10/15 begin at the end of October during W2P W-2 Pulldown Payment Cycle .
When moving from a CMF+ placement to a paid placement during a participation period, the supplemental payment is not prorated. The participant will not receive a final supplemental payment unless the participant was in the CMF+ placement for one full W-2 participation period. (See 7.2.3.5.1 )
EXAMPLE : On July 8, Uma moves to a CMF+ placement. On October 10, her FEP places her in a W-2 T placement. Uma will not receive a final supplement payment for the period September 16 to October 15 because she was not in the CMF+ placement for the full participation period. However, Uma will receive a W-2 T payment for the period of October 10 to October 15.
There are two different types of auxiliary payments:
Automated auxiliary payments are system-calculated and automatically issued in WWP. These payments are issued when a worker takes an action following either the Delayed Cycle or the W-2 Pulldown Cycle (see 10.2.1 ) that causes a recalculation for the payment amount owed.
Actions that can result in an automated auxiliary payment include:
Backdating a paid placement after the Delayed Cycle into a previous month;
Backdating a paid placement into a prior participation period; or
Changing participation data after the W-2 Pulldown Cycle such as adding Good Cause for hours of nonparticipation.
Manual auxiliary payments can be created in WWP for cases where an auxiliary will not be calculated automatically, such as auxiliaries that must be issued as a result of a Fact Finding Review.
For lost, stolen, or destroyed W-2 or vendor checks, refer to the Appendix -- Payment Issuance Guide.
There is a two-party W-2 auxiliary payment approval process. W-2 agencies are responsible for keeping their list of designated approval workers current in Wisconsin Work Programs (WWP) The web based computer program used in Wisconsin for the W-2, TMJ/TJ, and Children First programs. Used for the W-2 program’s informal assessments, formal assessments, accommodations, and time limit tracking. .
WWP W-2 Auxiliary Payment Approval
Each W-2 agency must have at least two WWP identified W-2 Auxiliary Approvers. The agency must complete the form Wisconsin Works Program (WWP) User Access Request form (5212) in order to add or delete an agency worker as a W-2 Auxiliary Payment Approver in WWP. Current W-2 Auxiliary Approvers for each agency are listed in WWP under Worker Tools.
At a minimum, W-2 agencies must perform a monthly review of W-2 auxiliary payment monitoring reports available in WebI Web Intelligence . The data in these reports is updated by the second Monday of every month. The agency must investigate questionable payments or payment discrepancies identified on the reports. Some examples of questionable payments or discrepancies include multiple payments to a case for the same benefit month by one or more workers, or check amounts for a particular month issued to a case that exceed the monthly W-2 maximum payment level of $608, $653, or $673, depending on the W-2 placement.
If an agency identifies a questionable payment or a payment discrepancy, the W-2 agency must contact the appropriate case worker(s) to confirm that the discrepancy is not an improper or illegal payment.
If an improper payment has been made, the W-2 agency must take appropriate action to recover the payment. If applicable, fraud prevention actions will be implemented in accordance with W-2 contract and state fraud program requirements. Regional DFES Division of Family and Economic Security staff identifying any major discrepancies on the reports will contact the W-2 agency to ensure that the agency is investigating the discrepancies and gather the agency’s feedback on their findings. Regional staff also determine whether appropriate corrective action has been taken (e.g. benefit recovery, fraud referral, etc.)
W-2 agencies should provide money management and banking information to W-2 Wisconsin Works participants and encourage participants to use EFT Electronic Funds Transfer of W-2 payments into a financial institution rather than receiving a check by mail to help:
Make payments more secure and timely;
Participants avoid expensive check cashing fees;
Decrease staff time dealing with phone calls, documentation, and affidavit forms associated with lost, stolen, or destroyed checks; and
Promote work readiness as many employers require paychecks be issued electronically.
Many financial institutions offer a no-fee, no-minimum-balance checking or savings account with EFT accounts.
Some participants may decline the EFT option because they are chronically overdrawn, owe fees from a negative account balance, or distrust financial institutions due to a negative interaction. The FEP should discuss various options with the participant, such as opening a limited account with a debit card only option that does not allow expenditures in excess of available funds.
Participants with credit problems may still have access to a checking or savings account through smaller community banks and credit unions as their lending policies are often more flexible.
Participants who have "non-fraudulent" activities reported on their ChexSystems report and have been denied access to a checking account in the past may benefit from participation in money management classes or a program designed to help repair their standing with banks. Agencies should assist participants in connecting with these community resources.
Some participants may choose to have their W-2 payment EFT deposited to a prepaid debit card. FEP Financial and Employment Planner s should explain that, in addition to the monthly fee, prepaid debit cards have many hidden or hard to find fees, including:
Initiation or activation fees;
Point of sale transaction fees;
Cash withdrawal fees;
Balance inquiry fees;
Customer service fees;
Bill payment fees;
Monthly fees;
Inactivity fees;
Paper statement fees;
Fees to add or “load” funds, etc.
If the participant chooses EFT, the FEP must alert the participant to the potential for possible fees charged by the financial institution. All prepaid debit cards must be included when counting assets for determining financial eligibility.
If a participant chooses to use EFT, and later requests to have the W-2 payment “held,” the FEP must end the EFT so that WWP Wisconsin Work Programs will issue the participant’s W-2 payment by check and the FEP can then put a hold on the check.
EXAMPLE : Mercedes tells her FEP that she plans to get a prepaid debit card so she can have electronic deposit of her W-2 payments because she has poor credit. Her FEP explains the fees prepaid credit cards come with and suggests that Mercedes open a checking account with a local credit union instead. Mercedes agrees and her FEP connects her with a local credit union that has a second chance checking account program, and helps Mercedes enroll in a money management workshop.
Wage Garnishment
Some participants may have a garnishment order for unpaid debts or child support. Per Wis. Stat. s. 49.96, W-2 payments cannot be garnished; however, financial institutions must honor court-ordered garnishment actions.
The FEP must provide this information to W-2 participants who choose EFT for their W-2 payments and should advise the participant to seek legal assistance if a financial institution garnishes their W-2 payments.
When reductions are applied to the W-2 Wisconsin Works payment, participants receive a Wisconsin Works Payment Statement (BIL1) prior to payment issuance, indicating:
The gross payment amount;
Any reductions due to missed hours;
Learnfare reductions;
Drug felon penalties;
Recoupments; and
The net payment.
If mismanagement of funds is a threat to the health and safety of a child in the W-2 Wisconsin Works group as determined by the FEP Financial and Employment Planner , all or part of the CSJ Community Service Job or W-2 T W-2 Transition payment may be a:
Protective payment;
Vendor Payment Payment made on behalf of the household by a third party to another source ; or
Combination of a direct payment, protective payment, and/or vendor payment.
The agency must investigate reports of mismanagement before initiating protective or vendor payments.
The W-2 agency must document in the case record the:
Reason for the authorization of protective or vendor payments;
Name of the eligible participant;
Name of the protective or vendor payee; and
Amount and form of payment authorized.
Participants may voluntarily choose to receive all or part of the CSJ or W-2 T payment as a protective payment or vendor payment, without being subject to an investigation by a FEP into the participant’s use of funds.
CSJ Community Service Job , W-2 T W-2 Transition , or CMF+ Case Management Follow-up Plus payments must be made payable as appropriate to the:
Participant;
Spouse of the participant (the spouse must be living in the home unless designated as protective payee or appointed by a court to be legal representative); or
Guardian or conservator of the W-2 participant.
W-2 workers are responsible for supporting participants through their involvement in the W-2 program. It is essential workers understand that a participant’s needs and availability may be subject to change due to the barriers they face.
Individuals participating in W-2 Wisconsin Works face a variety of barriers that may impact program participation, including, but not limited to:
Finding safe, affordable, and reliable childcare;
Physical and mental health challenges;
Transportation;
Housing instability;
Family crisis; and
Domestic violence.
Participants who experience difficulty participating in assigned activities, have a payment reduction, or have a pattern of absence may need more individualized support.
A pattern of nonparticipation without good cause is one reason the FEP Financial and Employment Planner may consider completing the WWP Wisconsin Work Programs Informal Assessment, as it can help guide the conversation about potential barriers and service needs. (See 5.2.3 )
FEPs should collaborate with participants to:
Identify the root cause of barriers;
Provide personalized support; and
Help participants anticipate and address barriers before they disrupt participation in assigned activities.
CSJ Community Service Job and W-2 T W-2 Transition participants must participate in all assigned work training activities or education and training activities outlined in their EP Employability Plan .
Payments for CSJ and W-2 T participants who do not participate in assigned activities are reduced by $5.00 per hour for hours missed without good cause. (See 11.3.1 )
Agencies must encourage participants to inform their FEP Financial and Employment Planner prior to the activity start time, if they know in advance that they will be unable to participate in an assigned activity. However, a participant must not be penalized if they do not inform their FEP prior to the activity time.
A participant has seven working days after an absence from a W-2 assigned activity to notify their worker of the reason for the absence.
The FEP must then use the good cause criteria to determine whether the absence meets any of the W-2 good cause reasons. (See 11.3.2 )
Participants placed in CMC Custodial Parent of an Infant and ARP At Risk Pregnancy placements are not subject to W-2 hourly payment reductions, do not have participation requirements, and cannot be subject to a payment reduction.
In order to ensure a participant’s W-2 Wisconsin Works payment is accurate, the FEP Financial and Employment Planner must record all participation data in the W-2 Participation Calendar in WWP Wisconsin Work Programs .
When entering participation hours, the FEP must enter:
Hours participated based on the scheduled hours of each activity. Hours participated must be documented for each day and activity separately, and do not include make-up hours or hours where good cause was granted.
Hours participated that are scheduled on one day but are made up during a different day within the same week. (See 6.3.3 )
The participant's reason for nonparticipation, if provided, and whether good cause is granted. If good cause is granted, the number of hours approved for each activity are entered on each day separately. (See 11.3.3 ).
EXAMPLE 1 : Michelle is scheduled for Work Experience on Monday from 10 am to 12 pm but is unable to go. She calls her FEP and explains her situation. The FEP determines, using the good cause criteria, that her reason for missing the scheduled activity meets the good cause policy. The FEP enters 0 hours participated for WE on Monday. WWP calculates 2 hours of nonparticipation. The FEP then enters 2 hours of Good Cause.
EXAMPLE 2 : Tamara is scheduled for a one-hour ESL class on Tuesday evening but is unable to attend. Instead, she attends the same class later in the week on Thursday. For Tuesday, the FEP enters 0 hours participated for ESL and 1 hour of make-up hours with Thursday's date.
11.2.2.1 Calculating Monthly W-2 Payments with Payment Reductions
Monthly W-2 payments that include a payment reduction must be calculated using the following rules:
Payment reductions for missed hours are deducted from the payment for the participation period during which hours were missed.
In order to affect the next payment, the final date that participation data can be entered into WWP Wisconsin Work Programs is the date the W-2 Pulldown payment cycle is scheduled. If there are changes to participation data after W-2 Pulldown, WWP will calculate to determine if an auxiliary payment or overpayment is necessary.
A payment reduction cannot be imposed on a participant for failing to complete a formal assessment (e.g., educational needs assessment such as TABE, or a career assessment).
A payment reduction is not imposed for nonparticipation in any activities that are scheduled on a date that a formal assessment activity is open on the Employability Plan or the Formal Assessment Pending status is open. A payment reduction cannot be imposed until: The formal assessment has been completed; The assessment activity has been ended on the EP Employability Plan ; and The FEP, in consultation with the participant, has made the necessary adjustments to the participant’s EP.
Payment reductions are specific to a W-2 Group and, therefore, do not follow a participant.
Even if a participant moves out of the W-2 Group, any payment reduction for missed hours or penalties associated with that individual during the current participation period are deducted from the next W-2 payment issued to that W-2 Group.
Recovery of overpayments continues to follow an individual from W-2 Group to W-2 Group.
For additional information on entering nonparticipation, see W-2 Manual Appendix – TANF Work Participation Requirements .
CSJ Community Service Job and W-2 T W-2 Transition participants must participate in all assigned work training activities or education and training activities outlined in the EP Employability Plan .
When a participant is unable to attend an assigned activity, good cause can be used to excuse the absence and prevent a sanction for nonparticipation or noncooperation.
To be eligible for good cause for a missed assigned activity, the participant must notify and provide an explanation to their FEP Financial and Employment Planner of the reason within seven working days following the absence.
The FEP must then use the good cause criteria (See 11.3.2 ) to determine whether a participant absence qualifies as good cause.
The following table provides a brief overview of key good cause terms and definitions. For more detailed information, see the relevant W-2 manual section column in the table.
Good Cause Definition and Terms Explanation Relevant Manual Section Participant’s responsibility to notify When a participant misses an assigned W-2 activity, the participant must notify and provide an explanation to their FEP of the reason within seven working days following the absence to prevent a payment reduction. 11.2.1 When to use the good cause criteria Anytime a FEP is working with a participant with a missed assigned activity, the FEP must: Consider any hardships the participant may face that make completing activities or notifying the agency of missed activities more difficult, e.g., phone availability, reliable transportation, etc.; and Make a good cause determination using the following criteria; The participant’s explanation or written verification of the absence; and Allowable good cause reasons. 11.3.2 11.3.3 When to verify good cause with written verification The FEP must only request written verification of good cause when: A pattern of absences exists; and The FEP does not believe that a reasonable explanation has been given for the absences or the FEP believes that the participant is misusing the good cause policy. 11.3.4 Definition of a pattern of absences A pattern of absences is defined as absences that: Extend beyond three consecutive working days; or Are more than five working days in a rolling 30 calendar day period. 11.3.4.1
FEP Financial and Employment Planner s are responsible for determining if a W-2 Wisconsin Works participant has good cause for not participating in W-2 assigned activities. When determining good cause, FEPs must consider hardships participants may face that make completing activities or notifying the agency of missed activities more difficult, e.g., phone availability, reliable transportation, etc.
To make a good cause decision, FEPs must use the following criteria:
The participant’s explanation or written verification of the absence; and
The allowable good cause reasons. (See 11.3.3 )
FEPs must use the good cause criteria to determine whether a W-2 participant has good cause for not participating in a W-2 assigned activity and must enter in WWP Wisconsin Work Programs :
The hours participated;
The participant's reason for the nonparticipation;
Whether there is good cause for the nonparticipation; and
The reasons for approving or denying good cause documented using the Good Cause Determination Comment Type.
When there is good cause for nonparticipation, the FEP must:
Select the worker reason for approving along with the number of good cause hours approved; and
Document the rationale in PIN comments.
When the FEP determines that the participant’s explanation does not meet an allowable good cause reason, the FEP must:
Select the worker reason for denying good cause; and
Reference the number of hours, dates, and activities missed in PIN comments.
The good cause reasons for failing to comply with the W-2 Wisconsin Works assigned activities are:
Any required court appearance including a required court appearance for a victim of domestic abuse.
Inability to obtain child care that is necessary for the W-2 participant to participate or accept employment, but is unavailable and the W-2 agency was unable to provide or refer for alternate child care arrangements.
Lack of transportation with no reasonable alternative, as determined by the FEP Financial and Employment Planner . In determining the reasonableness of transportation alternatives, FEPs should consider factors such as the length of commute, participant safety, cost of transportation in relationship to income, and any other relevant factors.
Participant or W-2 Group member’s illness, injury, or disability or incapacity. It is expected that a participant will need to remain home occasionally to care for an ill child who has to miss school or daycare or a participant will need to miss an assigned activity due to an unexpected illness or a documented chronic illness, e.g., chronic asthma, panic attacks, disabled child, child with behavioral problems, etc.
Accommodations identified in a formal assessment are not available to complete the assigned activity.
Conflict with another assigned W-2 activity or job search attempts.
Inclement weather that impedes transportation or travel or is unhealthy to be out in (e.g., air quality advisories).
School emergency.
Domestic violence issues as defined in Wisconsin Administrative Rule DCF 101.15(3) .
Death in immediate family. (See 11.3.3.2 )
Observance of a religious holiday.
Routine medical or school appointments, which cannot be scheduled at times other than during assigned activities.
Child’s school holiday with the exception of summer break.
Any day that the worksite or training site is closed due to a site-specific holiday, e.g., days closed surrounding Christmas, closure the day after Thanksgiving, etc.
Other circumstances beyond the control of the participant, but only as determined by the FEP.
A single parent placed in a W-2 Employment Position Community Service Job, Trial Employment Match Program, and W-2 Transition cannot be sanctioned for nonparticipation in any W-2 activities during a period of time when they are unable to obtain child care for a child under the age of 13.
If child care is only available to the participant during specific hours of the day or days of the week, the W-2 agency must make every effort to assign work activities during those hours.
A participant who needs to secure child care arrangements in order to participate in W-2 activities should be assigned the task of securing child care as part of their participation requirements on their Employability Plan (EP).
The W-2 activity code associated with this activity is Child Care Related Activities (CC). See W-2 Activity Code Appendix .
The participant should initially be assigned the CC activity for no less than five working days and no more than ten working days to communicate the importance of obtaining child care. If the participant is not successful in obtaining needed child care by the end date of the CC activity, the worker must review the individual’s circumstances to determine if the participant has demonstrated an inability to obtain child care. (See 11.3.3.1.2 )
If the participant has demonstrated an inability to obtain child care, the worker must grant good cause for all nonparticipation, until:
Child care is obtained; or
The participant no longer demonstrates an inability to obtain child care.
Until child care is obtained (whether good cause is being granted or not):
The CC activity must remain assigned on the EP Employability Plan ;
The worker must continue regular check-ins; and
The participant must continue to pursue any possible available child care leads.
EXAMPLE : Jackie applied for W-2 and was placed in a CSJ Community Service Job . Her FEP Financial and Employment Planner develops the EP with Jackie and assigns Child Care Related Activities (CC) as well as 10 hours per week of GED classes and 10 hours of structured job search.
Jackie’s FEP gives her five working days to find child care and connects Jackie to the local Child Care Resource and Referral Network (CCRR) A network of Child Care and Referral agencies which can assist parents in locating a child care provider and discuss what to look for when selecting a provider, i.e. smoke alarms, emergency exits, etc. For a list of local CCRR agencies, contact the CCRR Network at (920) 734-1739. .
After five working days, Jackie meets with her FEP to discuss her progress and explains that she has not secured child care and did not follow up with the referrals she received from CCRR.
Jackie’s FEP calls the CCRR with Jackie and verifies that child care slots are still available in a licensed child care facility, within a reasonable distance from Jackie’s home, and that there is no documentation that the facility would be harmful to the health or safety of her children.
The FEP informs Jackie that because she cannot demonstrate an inability to obtain child care, she is no longer eligible for good cause due to lack of child care and that any future missed activities will result in a payment reduction for the hours missed.
The FEP encourages Jackie to secure child care as quickly as possible so that she can participate in these assigned activities.
In order to determine if child care is available, a W-2 worker must discuss child care with each participant at the time of the initial assessment and during the review of the W-2 Participation Agreement.
To help the participant locate a child care provider, a W-2 worker must:
Explain to the participant their responsibility to obtain any needed child care for the hours of participation in W-2.
Determine if informal child care, or formal child care within a reasonable distance from the participant’s home, is available. Informal child care arrangements may be discussed, but a participant cannot be required to use an informal child care arrangement. If another parent is in the home, able, and available to care for the child, child care is not needed.
Provide information to the applicant or participant about eligibility for W-2 child care assistance and the requirement for the provider to, at a minimum, be provisionally certified to qualify for assistance. (See Child Care Policy Manual )
If the participant does not currently have child care available, refer the individual to the local Child Care Resource and Referral Network (CCRR), which is available to help all parents locate safe and affordable child care throughout the state, and other child care resources in the community. If the referrals do not result in the participant locating child care, the W-2 agency may require the individual to demonstrate an inability to obtain child care. (See 11.3.3.1.2 )
If available, offer the use of the W-2 agency on-site child care to the parent until an ongoing child care arrangement is found. A W-2 on-site child care provider must be regulated in order for the parent to leave the premises.
Discuss the availability of backup child care arrangements to help the participant plan ahead for emergency situations when their regular provider is unable to care for the child(ren) or when their child is sick and cannot attend their regular child care program.
An inability to obtain child care must be based on the following reasons:
Child Care Type Reason Formal Child Care: Provided by a certified or licensed child care facility. Child care is not available in a reasonable distance*. Child care facilities in the area do not have space available for the child. Certified or licensed child care facilities, including a W-2 agency with certified or licensed on-site child care, must not be considered available if there is documentation that the facility would be harmful to the health or safety of the child. Informal Child Care : An arrangement where the child care provider is not licensed or certified. Child care by a relative or under other arrangements is unavailable or unsuitable. Any W-2 participant can use informal child care, but a participant cannot be required to use informal child care. (See Child Care Policy Manual, Chapter 1 )
The FEP will work with the participant to determine what a reasonable distance is on a case-by-case level. The FEP must document the decision that is made and reason(s) in PIN comments.
If the participant is unable to demonstrate an inability to obtain child care, they may face payment reductions for nonparticipation.
An inability to obtain appropriate child care may be indicative of a shortage of child care providers in the community (including sick child care, evening and weekend care, culturally competent child care, and care for disabled children) and W-2 agency management should be alerted.
A participant may be granted up to three working days of good cause if there is a death of an immediate family member. FEPs may grant good cause for up to seven working days if travel for funeral services is required or to accommodate cultural tradition.
Immediate family is defined as the participant’s:
Spouse;
Non-marital co-parents;
Parents, step-parents, and foster parents;
Children, step-children, and foster children;
Grandparents;
Grandchildren;
Siblings and their spouses;
Aunts or uncles;
Sons-in-law and daughters-in-law;
Cousins;
Nieces and nephews of the participant or their spouse or non-marital co-parent; and
Other relatives of the participant or their spouse or non-marital co-parent if these other relatives reside in the same household as the participant.
A FEP Financial and Employment Planner must request written verification of good cause before accepting a good cause reason for a participant’s absence from required activities if both of the following apply:
A pattern of absences exists; and
The FEP does not believe that a reasonable explanation has been given for the absences or the FEP believes that the participant is misusing the good cause policy.
See 11.3.4.1 for a definition of pattern of absences.
A FEP must not request written verification of good cause when:
A pattern of absences does not exist; or
A pattern of absences exists and the FEP believes there is a reasonable explanation given for the absences, or the FEP does not believe that the participant is misusing the good cause policy.
A “pattern of absences” is defined as absences that:
Extend beyond three consecutive working days; or
Are more than five working days in a rolling 30-day period.
An absence means being absent from any one activity.
For example, if a participant is assigned to work experience and adult basic education on the same day and misses just one of those activities, this is considered an absence.
However, when absences are for the same reason, (e.g., car accident, child has flu, etc.), this may be considered a reasonable explanation and no written verification is required.
If good cause is accepted for any of the absences, the good cause absences may still be considered as part of a pattern.
The FEP must determine whether there is a reasonable explanation on a case-by-case basis using their knowledge, experience, and familiarity with the case and must document the decision-making factors in PIN comments.
EXAMPLE 1: Iris missed three consecutive working days of her assigned activities and calls in on the fourth day to explain that her children have had a bad flu. Although the absences constitute a pattern, her FEP has no reason to believe that Iris is misusing the good cause policy. In this scenario, the FEP would not require written documentation of good cause for the missed activities.
EXAMPLE 2: Allie missed five working days in a rolling 30-day period due to school appointments. She brought in written verification for two of the five days indicating that her child is undergoing an evaluation for a possible learning disorder. Allie calls to explain that she will miss the next two days for jury duty. Because Allie missed five days, even with the two days she was granted good cause, this constitutes a pattern. Allie’s FEP has reason to believe that Allie may be misusing the good cause policy due to her history of absences. In this case, her FEP may require written documentation verifying good cause.
EXAMPLE 3 : Joey misses two consecutive days of activities because of an illness. These are the first two absences Joey has had in several months. Because this does not constitute a pattern, the FEP may not require written documentation verifying good cause.
W-2 Wisconsin Works policy requires FEP Financial and Employment Planner s to conduct ongoing informal assessments, which includes the need to work together with participants to identify any underlying causes of nonparticipation and provide individualized support to help them overcome barriers to participating in W-2 activities. (See 11.1 )
In addition to working with participants to identify and address barriers to participation, if a participant’s payment is going to be reduced by 20% or more due to nonparticipation, the W-2 agency must:
Provide written notice to the W-2 participant of the proposed 20% or more payment reduction, including the reasons for the proposed payment reduction; and
Allow the participant seven working days to rectify the discrepancy and prevent the proposed W-2 payment reduction.
To rectify means that the participant is given one last opportunity to present good cause for nonparticipation or to present late documentation of completed assigned activities.
CWW CARES Worker Web automatically generates the Notice of Potential W-2 Payment Reduction (letter NWSN) either at the:
Beginning of the month (W-2 delayed payment); or
End of the month (W-2 pulldown) when final W-2 monthly payment amounts are determined.
CWW populates the letter with information entered by the FEP in participation tracking in WWP Wisconsin Work Programs , including:
Missed activities;
Hours missed; and
Dates the activities were missed.
The letter informs the participant to contact the worker as soon as they receive the letter to explain why the activities were missed.
If the participant claims good cause, the FEP must use the good cause criteria (See 11.3.2) to determine:
If the absence meets any of the W-2 good cause reasons; and
If written verification of good cause (called “proof of good cause” in the letter) is required. (See 11.3.4 )
If the participant submits late documentation of completed assigned activities, the documentation must be for the dates the activity was assigned on the Employability Plan.
If written verification of good cause is required, the participant has seven working days to provide written verification of good cause. The next working day after the mailing date of the letter is day one. See table for example scenario.
Event Date Mailing date of the Notice of Potential W-2 Payment Reduction Letter Tuesday, March 19, 2024 Final date written verification can be submitted Thursday, March 28, 2024
The NWSN Notice of Potential W-2 Payment Reduction letter includes the date by which written verification must be provided, if required. (See 11.3.4 )
The date provided on NWSN is the final date any verification can be received. The verification due date cannot be extended from seven working days to 30 days.
A FEP Financial and Employment Planner must close a case when a participant fails to cooperate with specific W-2 Wisconsin Works program requirements without good cause.
W-2 participants must cooperate with the following requirements:
Complete unsubsidized employment search as assigned on the EP Employability Plan while in a W-2 employment position. (See 2.9.1 )
Apply for and accept other available public assistance or resources as determined by the FEP. The FEP may require this of the participant prior to being determined eligible for W-2 services or during W-2 program participation. (See 2.6.1 )
Complete an EP review appointment prior to the date the EP expires.
Note : If the participant has good cause for missing the appointment, the case cannot be closed.
Stay in contact with the FEP at least once every 30 consecutive calendar days. Prior to closing the case, the FEP must make repeated and varied attempts to contact the participant. “Repeated” attempts means the FEP or another W-2 agency representative must, at a minimum, make weekly attempts. “Varied” attempts means a combination of attempts to contact, such as worksite visits, home visits, phone calls, letters, e-mail, etc.
See 15.3.1 for policies regarding noncooperation with paternity establishment and child support enforcement services.
The date of noncooperation is the date, determined by the W-2 agency, on which the participant was expected to cooperate with the requirements of the W-2 program.
EXAMPLE 1: A participant’s EP review is scheduled for March 17 and the participant did not show for the appointment. Without good cause, the date of noncooperation is March 17.
EXAMPLE 2: The last date of contact the W-2 agency had with a participant was July 1. The FEP is unable to contact the participant after 30 calendar days of repeated and varied contact attempts. The date of noncooperation is July 31.
Prior to closing a participant’s case for noncooperation, The FEP Financial and Employment Planner must complete the following steps:
Assess for any potential underlying barriers;
Send the W-2 participant a Notice of Noncooperation with W-2 Requirements ( CWW CARES Worker Web letter NWNC) indicating the potential case closure and reason(s) for the closure; and
Provide the participant seven working days to rectify the Notice of Noncooperation with W-2 Requirements (NWNC) letter. Day one is the first working day after the mailing date of the NWNC Notice of Noncooperation with W-2 Requirements .
Although a payment reduction is not necessary prior to all case closures, e.g., failing to verify information, it is required prior to closing a case for noncooperation with job search.
W-2 informal assessment policy requires FEPs to conduct ongoing informal assessments, which includes the need to work together with participants to identify any underlying causes of nonparticipation and provide individualized support to help them overcome barriers to participating in W-2 activities. (See 11.1 )
Before closing a case for noncooperation, the FEP must complete and document completion of, in WWP Wisconsin Work Programs through detailed PIN comments and on WWP pages where appropriate, the following three steps:
Work together with participants to identify any underlying causes of nonparticipation, including unidentified barriers or other good cause reasons for failing to cooperate. (See 11.1 )
Provide individualized support to help address the barriers that may have caused the noncooperation.
Record all participation data in the W-2 Participation Calendar in WWP prior to determining ineligibility and completing case closure.
The FEP must issue the Notice of Noncooperation with W-2 Requirements (CWW letter NWNC) to provide a final opportunity for the participant to present good cause for noncooperation.
The FEP must manually issue the NWNC letter via CWW prior to generating a Notice of Eligibility, and indicate on the NWNC letter the:
Correct noncooperation reason; and
Date of noncooperation (See 11.5.1.1 ).
The NWNC letter informs the participant to contact the worker as soon as they receive it to explain why the noncooperation occurred.
The FEP must generate the case closure for CARES to issue the appropriate Notice of Eligibility if:
The participant does not comply with what is requested within the seven-working day-timeframe in the NWNC letter, or
The FEP determines, using the good cause criteria, that good cause does not exist for the noncooperation.
The FEP must not end the participant’s W-2 placement until the last day of the seven-working-day timeframe, even if the FEP determines prior to the last day of the seven-day timeframe that good cause does not exist.
The Notice of Eligibility contains information on filing a Fact Finding Review if the participant does not agree with the decision.
In addition to exploring potential barriers, if a participant’s case is going to close for noncooperation, the W-2 agency must:
Provide written notice to the W-2 participant of the proposed case closure, including the reason for the case closure; and
Allow the participant seven working days to rectify the discrepancy and prevent the proposed W-2 payment reduction.
Rectifying means that the participant is given one last opportunity to present good cause for failing to cooperate or to present late documentation of completed assigned activities.
If the participant claims good cause, the FEP must use the good cause criteria (See 11.3.2 ) to determine if:
The absence meets any of the W-2 good cause reasons; and
Written verification of good cause (called “proof of good cause” in the letter) is required. (See 11.3.4 )
If the participant submits late documentation of completed assigned activities, the documentation must be for the dates the activity was assigned on the Employability Plan.
If written verification of good cause is required, the participant has seven working days to provide written verification of good cause. The next working day after the mailing date of the letter is day one. See table for example scenario.
Event Date Mailing date of the Notice of Noncooperation with W-2 Requirements Letter Friday, April 12, 2024 Final date written verification can be submitted Tuesday, April 23, 2024
Noncooperation with W-2 Requirements (NWNC) letter includes the date by which written verification needs to be provided, if required. (See 11.3.4 )
The date provided on NWNC is the final date any verification can be received. The verification due date cannot be extended from seven working days to 30 days.
If a participant reapplies after their case closed due to noncooperation, and presents written verification of good cause, the agency must not apply the nonfinancial eligibility policy regarding cooperating with the W-2 agency within 180 days of application. (See 2.2.1)
In the case of a missed EP Employability Plan review appointment, the participant has seven working days from the date of the CWW CARES Worker Web letter NWNC Notice of Noncooperation with W-2 Requirements to make the appointment. It is assumed in this scenario that the participant missed an EP review appointment that was scheduled prior to the EP expiration.
The NWNC letter:
Instructs the participant to contact the worker to reschedule the EP; and
Explains that if the participant does not appear for the rescheduled appointment, the case will close unless good cause for the missed appointment exists.
If the participant calls, the W-2 agency must reschedule the EP review appointment; regardless of whether the participant has good cause for missing the first EP review appointment.
If the participant does not appear for a rescheduled EP review appointment, the FEP must not end the participant’s W-2 placement until the last day of the seven-working-day timeframe or the date the EP expires, whichever is later.
EXAMPLE 1: Jace did not verify his assets during an eligibility review. Before initiating a case closure, Jace’s FEP took steps to explore with Jace any potential barriers that may be interfering with his ability to cooperate. The FEP then generated the Notice of Noncooperation with W-2 Requirements, which gave Jace seven working days to submit verification and specified the due date. After seven working days, Jace’s FEP did not hear from Jace and initiated the case closure. The Notice of Eligibility was sent to Jace notifying him of the impending case closure and the right to a Fact Finding Review.
EXAMPLE 2 : Gwen’s EP was set to expire on December 16. Gwen missed an EP review appointment without good cause on December 2. Prior to initiating the case closure, Gwen’s FEP first took the steps to explore potential barriers that may be interfering with her ability to cooperate.
Participant’s Action FEP's Action Gwen did not provide good cause within the required seven-day time frame. Gwen’s FEP then generated the Notice of Noncooperation with W-2 Requirements (NWNC), which encouraged Gwen to contact her worker by December 14 (last day of the seven-working-day timeframe) for a final EP review appointment. Gwen did not contact the agency after receiving the letter and her FEP was not able to establish contact with her. Gwen’s FEP did not hear from Gwen and initiated the case closure. The FEP ended the placement as of December 16 because the EP expiration date was later than the last day of the seven-working-day timeframe. The Notice of Eligibility was sent notifying Gwen of the impending case closure and the right to a Fact Finding Review.
EXAMPLE 3 : Gabriel in enrolled in an CSJ Community Service Job and has an ongoing pattern of failing to complete a job search without good cause. Despite the resulting payment reductions and the FEPs efforts to help them identify potential barriers, Gabriel continues to not participate with job search requirements.
Participant’s Action FEP's Action Gabriel did not provide good cause within the required seven-day time frame. The FEP generates the Notice of Noncooperation with W-2 Requirements, which encourages Gabriel to contact their worker. Gabriel calls their worker to explain they were diagnosed with ulcers which caused them to miss assigned job search activities and provides the appropriate medical documentation supporting the diagnosis. The worker accepts good cause and does not close the case for nonparticipation. The worker then updates Gabriel’s assigned activities and the EP to reflect the ongoing medical attention needed to help them recover.
The purpose of the refusal to participate policy is to require a standard of conduct from program participants to prepare them for Unsubsidized Employment in the general economy through participation in employment positions in the W-2 program.
The refusal to participate policy applies to the W-2 Employment Position Community Service Job, Trial Employment Match Program, and W-2 Transition s, which include:
TEMP Trial Employment Match Program ;
CSJ Community Service Job ; and
W-2 T W-2 Transition .
The W-2 Group is ineligible to participate in the W-2 program for 90 calendar days if the FEP Financial and Employment Planner determines that:
A participant in a TEMP, CSJ, or W-2 T placement demonstrates a refusal to participate without good cause; or
A second parent in the participant’s W-2 Group who is subject to the work requirement under the two-parent policy (See 14.3 ) demonstrates a refusal to participate without good cause.
The FEP must close a case when:
A TEMP, CSJ, or W-2 T participant demonstrates a refusal to participate in the W-2 program without good cause; or
A second parent in the participant’s W-2 Group who is subject to the work requirement under the two-parent policy (See 14.3 ) demonstrates a refusal to participate without good cause.
A participant demonstrates a refusal to participate when the individual:
Is terminated from employment for misconduct or engages in misconduct on the premises of an employer . ‘Misconduct’ means an act by the individual that shows an intentional and substantial disregard of the employer’s interests or of the individual’s job duties and obligations. It does not mean an act of an isolated instance of carelessness and ordinary negligence or good faith errors in judgment. ‘Misconduct’ includes: A violation by an individual of an employer’s reasonable written policies concerning the use of alcohol or controlled substances. Theft of an employer’s property or services with intent to deprive the employer of the property or services permanently, theft of currency of any value, felonious conduct connected with an individual’s employment with an employer, or intentional or negligent conduct by an individual that causes substantial damage to an employer’s property. Conviction of an individual of a crime that was committed on or off duty, if the individual is unable to perform the duties that the individual performs for an employer due to the conviction. One or more threats or acts of harassment, assault, or other physical violence by an individual at an employment site. Use of profane or abusive language directed towards staff or others at an employment site
Fails to appear or appears more than 15 minutes after the scheduled start time of an interview with a prospective employer, a job fair, or a meeting with a prospective employer that was arranged by the W-2 agency. Failure to appear or appearing more than 15 minutes late does not include instances where there was a mistake, inadvertence, misunderstanding on the part of the individual, or other good cause.
Leaves an interview or a meeting with a prospective employer prior to the conclusion of the interview or meeting.
Appears for an interview with a prospective employer wearing inappropriate attire or exhibiting inappropriate grooming after receiving written or oral directions or training on appropriate attire and grooming. “Attire” means clothing and excludes jewelry and accessories. Examples of inappropriate attire include clothing with profane language, offensive references to a specific gender, ethnic, racial or religious group, vulgar messages, and references to alcohol and controlled substances. “Grooming” means unclean, unkempt, or inappropriate dress or grooming which adversely affects proper performance of duties or the image of the employer
Fails to complete a job application required by a prospective employer. A job application is “complete” when an individual submits the job application required by the prospective employer using the method specified by that employer. Failing to complete a job application does not include instances where there was a mistake, inadvertence, or misunderstanding on the part of the individual.
Communicates to a prospective employer an unreasonable requirement for salary, hours of employment, or working conditions that disqualifies the individual from employment with that employer.
Provides incorrect or incomplete information regarding employment qualifications in an interview or job application that disqualifies the individual from employment with the prospective employer after receiving written or oral directions or training from the W-2 agency regarding interviewing and filling out employment applications. Examples of employment qualifications include criminal convictions; work history; educational attainment; credentials and certificates; driving record or possession of a valid driver’s license; and salary history and expectations. Providing incorrect or incomplete information regarding employment qualifications does not include instances where there was a mistake, inadvertence, or misunderstanding on the part of the individual.
Quits appropriate employment or refuses a bona fide offer of appropriate employment. “Appropriate” means consistent with an individual’s employability plan.
Fails to participate in assigned activities and W-2 payments are reduced by 20% or more for two consecutive participation periods, or for three non-consecutive participation periods in a rolling six-month period.
Refuses or fails to follow a verbal or written direction from W-2 agency staff or staff at an employment site. Refusing or failing to follow a verbal or written direction does not include instances where there was a mistake, inadvertence, or misunderstanding on the part of the individual.
Uses vulgar or profane language or engages in abusive behavior directed towards staff or others in the W-2 agency or employment site.
Violates written work rules developed by the employer, if the work rules were provided to the individual and there is a signed acknowledgement of receipt of the work rules in the individual’s case record. Examples of work rules are dress codes, attendance policies, health and safety standards, use of company property, and appropriate workplace behaviors. A violation of written work rules does not include instances where there was a mistake, inadvertence, or misunderstanding on the part of the individual
The date of refusal to participate is the date that the participant demonstrated the refusal to participate.
EXAMPLE 1 : The W-2 agency arranges an interview for a participant with an employer on March 18, and the participant was a no-call, no-show to the interview. On March 22, the FEP learns that the participant did not show for the interview. The date of refusal to participate is March 18.
EXAMPLE 2 : A participant fails to participate in assigned activities and their May and June W-2 payments are reduced by 20% or more for two consecutive months as a result. At W-2 Pulldown, CWW issues letter Notice of Potential W-2 Payment Reduction (NWSN) to the participant with a good cause due date of June 6. The participant does not submit good cause by June 6. The date of refusal to participate is June 6, the final date that any good cause can be received for the 20% or more payment reduction.
Prior to closing a case for refusal to participate, the FEP Financial and Employment Planner must explore potential Barriers that may be interfering with a participant’s ability to participate in W-2 and take steps to address those barriers. (See 11.1 )
W-2 Participants are required to participate in all assigned activities in their W-2 Employability Plan (EP) and cooperate with W-2 program requirements.
When a participant does not comply with assigned activities or does not cooperate with specific program requirements, W-2 nonparticipation and noncooperation policies require the FEP to work with the participant to:
Identify potential barriers related to their missed activities (see 11.1 ):
Identify needed accommodations or modifications that will help them to participate; and
Provide services and supports needed for them to participate in appropriately assigned activities and to develop the skills and resources they need to manage issues that arise so they do not continue to miss activities without good cause (see 11.3.1 and 11.5.2.1 ).
The refusal to participate policy does not replace nonparticipation and noncooperation policies (see 11.4 and 11.5 ); however, the FEP must still follow the same policies and procedures for initiating action to uncover barriers and take steps to address the barriers that may have caused the refusal to participate.
The W-2 Notice of Refusal to Participate (W2RP) letter is generated via a nightly batch process and mailed to the participant.
The W2RP W-2 Notice of Refusal to Participate letter is intended to give the participant one last opportunity to present good cause for refusing to participate and encourages the participant to contact the worker as soon as they receive it to explain why the refusal to participate occurred.
In addition to exploring potential barriers, if a participant’s case is going to close due to a refusal to participate, the W-2 agency must:
Provide written notice to the W-2 participant of the proposed case closure and the reason for the case closure; and
Allow the participant seven working days to rectify the discrepancy and avoid the proposed case closure.
The FEP must create a record of all refusal to participate occurrences in CWW CARES Worker Web , including:
The individual who demonstrates the refusal to participate,
The date of occurrence, and
The reason(s) for the refusal to participate.
The participant has seven working days to provide good cause.
The due date for submitting good cause for refusing to participate cannot be extended from seven working days to 30 days. The seventh working day is the final date any good cause can be received. See table for example scenario.
Event Date Mailing date of the W-2 Notice of Refusal to Participate Letter Tuesday, March 19, 2024 Final date written verification can be submitted. Thursday, March 28, 2024
If the participant provides a valid good cause reason by the good cause due date:
The FEP must delete the refusal to participate record in CWW so W-2 eligibility is not impacted.
If the participant does not provide good cause by the due date, or the FEP determines that good cause does not exist:
The FEP must run eligibility to generate the case closure. CARES will issue the appropriate Notice of Eligibility after eligibility is run.
(See Operations Memo 18-13 for instructions on entering a W-2 Refusal to Participate record in CWW)
The penalty for refusing to participate in W-2 Wisconsin Works is ineligibility to participate in W-2 for three months. Three months means 90 calendar days.
The period of ineligibility begins the calendar day after the seven-working-day timeframe to rectify a refusal to participate. The following table provides an example timeline.
Event Date The last day of the seven working day timeframe for a participant to rectify a refusal to participate. Friday, November 16, 2024 If a participant does not rectify the refusal to participate, the period of ineligibility begins the following calendar day. Saturday, November 17, 2024 The period of ineligibility ends the 90th calendar day. Wednesday, February 13, 2025 The participant may reapply for W-2 and be eligible for W-2 services beginning the calendar day after the 90-day ineligibility period. Thursday, February 14, 2025
After the 90-day penalty period, the individual may reapply for W-2 services. Eligibility for W-2 is not automatically reinstated.
For applicants applying after the conclusion of a penalty period, the W-2 agency must not apply the nonfinancial eligibility requirements that the applicant:
Made a good faith effort to obtain employment and not refused any bona fide offer of employment within 180 calendar days immediately preceding application; and (See 2.2.1 , #8)
Cooperated with the W-2 agency’s assistance with finding employment if the current application is within 180 calendar days of a previous application. (See 2.2.1 , #9)
There is no limit to the number of penalties that a participant may receive for refusing to participate in W-2.
The W-2 agency may impose subsequent refusal to participate penalties after the individual has completed the 90-day penalty period, re-enrolled in the W-2 program, and then refused to participate again.
In a W-2 Two-Parent Household A W-2 two-parent household is a W-2 Group where both adults: are custodial parents who have a child in common, reside in the same household with their child(ren), meet all W-2 eligibility criteria, are not disabled adults; and are not caring for a severely disabled child in the W-2 Group. , the second parent in the W-2 Group An adult custodial parent, all dependent children with respect to whom the individual is a legal custodial parent and all minor children with respect to whom the adult individual’s dependent child is a custodial parent. W-2 Group includes any non-marital co-parent or any spouse of the individual who resides in the same household as the individual and any minor children with respect to whom the spouse or non-marital co-parent is a custodial parent. W-2 Group does not include any person who is receiving cash benefits under a county relief block grant program. This is also referred to as the W-2 Assistance Group (W-2 AG) who is required to participate in W-2 activities because the family is receiving federally funded childcare subject to the work requirement under the two-parent policy (See 14.3 ) may be ineligible to participate in W-2 if they refuse to participate.
Both the parent in a W-2 employment position ( TEMP Trial Employment Match Program , CSJ Community Service Job , or W-2 T W-2 Transition ) and the second parent in a two-parent household may each be ineligible to participate in W-2. Therefore, refusal to participate penalties imposed on each parent must be tracked independently of each other.
When either parent refuses to participate, both parents in the W-2 Group are ineligible to participate in W-2. If the parent who is under penalty moves out of the two-parent household and leaves the W-2 Group, the other parent may be eligible to reapply for W-2 services as a single-parent household.
EXAMPLE: Sharon is a CSJ participant. Her partner John works part-time at the mall and is assigned to four hours per week of employment search so he can find full-time work.
The two-parent household is receiving federally funded childcare and is subject to the work requirement under the two-parent policy (See 14.3 ). John was terminated from his employment for misconduct.
The FEP Financial and Employment Planner reviews the case and determines that John is refusing to participate. Therefore, both John and Sharon are not eligible to participate in W-2 for 90 days.
If John were to move out of the two-parent household and leave the W-2 Group, Sharon may reapply and be found eligible for W-2. However, John remains ineligible for 90 days regardless of leaving the W-2 Group because John refused to participate.
If John moves into a new two-parent household and enters a new W-2 Group with an adult in a W-2 employment position, the new W-2 Group would be ineligible to participate in W-2 for the remainder of John’s 90-day penalty period.
W-2 Wisconsin Works participants whose incarceration renders them temporarily unable to participate in assigned activities or retain care and control of their children will remain eligible for W-2 payments for up to 30 calendar days, provided they remain otherwise financially and nonfinancially eligible.
The 30-day timeframe allows for short-term incarceration without having to disrupt a participant’s activities, payments, and child care by disenrolling and then re-enrolling them in W-2.
Incarcerated W-2 participants who are unable to participate in work activities or retain care and control of their child(ren) for more than 30 consecutive calendar days are not eligible for W-2 payments.
For More Information on the Following Review Process Help Incarceration and Huber Program participation Process Help 3 Ongoing Case Maintenance Department of Corrections Record Query Process Help 44 Data Exchange Collecting absent parent information Process Help 65 Absent Parent
The daily Prisoner Match Data DX Data Exchange provides information from SSA Social Security Administration for all individuals included in the W-2 Group An adult custodial parent, all dependent children with respect to whom the individual is a legal custodial parent and all minor children with respect to whom the adult individual’s dependent child is a custodial parent. W-2 Group includes any non-marital co-parent or any spouse of the individual who resides in the same household as the individual and any minor children with respect to whom the spouse or non-marital co-parent is a custodial parent. W-2 Group does not include any person who is receiving cash benefits under a county relief block grant program. This is also referred to as the W-2 Assistance Group (W-2 AG) who are between 18 and 65 years old, as long as there is a valid SSN Social Security Number (Verification code V, C, or W) on the CWW CARES Worker Web Household Members page during:
Intake;
Review;
Person adds; and
Program adds.
CWW sends the request for prisoner match data via the SOLQ-I DX from the CWW General Case Information page. (See 4.1.5.3 )
Three days after CWW runs the data exchange, CWW will set discrepancies and alerts for individuals who have been incarcerated for more than 30 days and have no release date. The results of the data exchange match information appear on CWW Prisoner Response Details page.
When a discrepancy is set, the FEP Financial and Employment Planner must verify match results through a secondary source and update the case, if necessary.
Secondary verification can be done through:
Contacting the individual;
Phone calls or faxes to the facility; or
Online resources (see table).
Online Verification Resources State of Wisconsin Offender Locator For matches within the State of Wisconsin, FEPs can verify the information through the Offender Locator website . This website provides records of incarcerated offenders through the Wisconsin Department of Corrections (DOC). FEPs can also access this site through VINELink. The database only includes adults who are incarcerated in the Wisconsin prison system. It is a good practice to include aliases in your search. VINELink For data exchange results inside or outside the State of Wisconsin, agencies can verify incarceration matches through VINELink , the online version of Victim Information and Notification Everyday (VINE). Federal Prisoner Information For federal prisoner matches, FEPs can verify the accuracy at the Federal Bureau of Prison Find an Inmate website . If the online queries do not result in verification of incarceration information for individuals in county jails, workers should continue to use resources at the local agency level such as faxes, phone calls, and contact with the individual to verify the incarceration information.
Although incarcerated W-2 Wisconsin Works participants may remain eligible to receive W-2 payments, incarceration is generally not considered good cause for not participating in required work activities.
Hours of work activities missed because of incarceration will result in payment reductions just like any other hours missed without good cause, unless the W-2 agency:
Finds extenuating circumstances relating to the incarceration; or
Determines that the incarceration resulted from a situation beyond the participant’s control.
The FEP Financial and Employment Planner must determine good cause for missed activities due to incarceration on a case-by-case basis and document the reason in PIN comments.
EXAMPLE 1 : Amy was arrested for an Operating While Intoxicated (OWI) conviction. As a result, Amy served 20 days in jail. Amy’s W-2 payment was reduced based on the days she was unable to participate.
EXAMLE 2 : K en was arrested on suspicion of drug possession. After the preliminary hearing, the charges were dropped and he was released. Ken served 14 days while waiting for his hearing. Ken submitted a statement from the court to the FEP. The FEP gave him good cause for the hours because the charges were dropped.
A judge may order an incarcerated W-2 Wisconsin Works participant into the Huber Program, allowing for limited release for:
Work;
School;
Job search;
Treatment; and
Performance of child care responsibilities.
An incarcerated W-2 participant’s EP Employability Plan should be adjusted and modified as needed to reflect the court-specified terms of the participant’s Huber Program release to support continued W-2 participation, provided the participant maintains care, custody, and control of their child(ren).
EXAMPLE : Elizabeth, a W-2 participant, is court ordered into the Huber Program for three months. The judge indicated Elizabeth would be released during the day to care for her children and participate in specified work program activities. Elizabeth’s mother is available to stay with the children at night.
Elizabeth called her FEP Financial and Employment Planner and explained the changes in her family’s situation. The FEP altered the EP to reflect the changes in circumstances. Elizabeth’s updated EP includes:
GED classes for four hours a week at the Job Center; and
Clerical work site activities at the Job Center for eight hours a week where she can use the onsite child care.
A W-2 participant released under the Huber Program must cooperate with jail staff and rules in order to remain eligible for W-2 services. The W-2 worker must verify cooperation with jail staff every 30 days while the W-2 participant is in the Huber Program.
Huber Program participants are ineligible for Wisconsin Shares. W-2 agencies must work with W-2 participants in the Huber Program to establish appropriate child care when necessary.
For W-2 Wisconsin Works purposes, the definition of a drug felon is an adult (over 18) who is convicted of a felony, which occurred within the last five years in state or federal court, involving the possession, use, or distribution of a controlled substance.
As a condition of continuing eligibility, a CSJ Community Service Job or W-2 T W-2 Transition participant must report if they are convicted of a drug-related felony.
If the W-2 agency learns by another means that the participant received a drug felony conviction, and that the participant did not report the conviction, the participant may be ineligible for W-2.
Participants that report receiving a drug felony conviction must submit to a test for use of a controlled substance. The cost of drug testing must be paid for by the local agency.
Drug tests taken from another credible source may be used if taken within the last 30 days. Examples of credible sources include, but are not limited to:
Probation officers;
Employers; and
FEP Financial and Employment Planner s.
Only CSJ and W-2 T participants are subject to drug felon penalties.
There are three common scenarios for W-2 Wisconsin Works applicants or participants who meet the W-2 definition of a drug felon:
Scenario Eligibility Status The individual refuses to take a drug test. Ineligible for W-2 The individual agrees to a drug test and the test result is positive. Eligible for a reduced W-2 payment The individual agrees to a drug test and the test result is negative. Eligible for a full W-2 payment
If an applicant has agreed to a drug test, they are considered eligible for a full W-2 Wisconsin Works payment while the worker is waiting for the test results. If the test result is positive, then the next possible payment month is sanctioned.
The pre-sanction payment is to be reduced by not more than 15% for no fewer than 12 months, or for the participant’s remaining period of participation in a CSJ Community Service Job or W-2 T W-2 Transition , if less than 12 months. Within these parameters, the sanction period and amount are set at the discretion of the worker.
The number of months of the sanction period will be consecutive calendar months that continue irrespective of whether an individual:
Moves between placements;
Moves on and off W-2; or
Receives a payment.
If a Participant Moves Sanction Period Between a CSJ and W-2 T placement The sanction period does not stop or start over with a different placement. From a CSJ or W-2 T into a CMC Custodial Parent of an Infant placement The payment reduction would stop during the CMC placement period, but months would continue to be counted towards the sanction period. W-2 payment reduction resumes at the end of the CMC placement if the 12-month sanction period did not expire while the participant was in the CMC placement.
EXAMPLE 1 : Scott applies for W-2 and reports a drug felony conviction he received three years ago. As he is being placed in a W-2 T, he is required to take a drug test to meet conditions of eligibility. Scott agrees to take the drug test and the results are positive. The worker applies a 10% reduction for 12 months to Scott’s W-2 payment starting in the next possible payment month.
EXAMPLE 2 : Janet applies for W-2 and reports a drug felony conviction she received six years ago. Janet is not required to take a drug test or subject to a drug felon payment reduction since the conviction did not occur within five years of the W-2 application date.
EXAMPLE 3 :
Scenario Timeline Sanction Holly applied for W-2 and receives a drug felon sanction in January. Holly’s 12 months sanction period begins. She moves into a CMC placement in April. During the CMC placement, Holly receives a full W-2 payment, but the months still count toward the 12-month sanction period. Holly moves back into a CSJ placement in June. Holly’s payment reduction resumes. Holly continues in her CSJ placement through the end of the year. Holly’s sanction period will end in December if the results of Holly’s drug test are negative.
The participant is required to take another drug test at the end of the 12-month sanction period to determine whether they are eligible for a full W-2 Wisconsin Works payment.
The following table outlines the required W-2 Payment based on the drug test results.
Drug Test Result Resulting Sanction Negative The W-2 agency shall discontinue the drug felon payment reduction. Positive The pre-sanction payment will continue to be reduced by no more than 15% for no fewer than 12 months, or for the participant’s remaining period of participation in a CSJ Community Service Job or W-2 T W-2 Transition , if less than 12 months.
All subsequent payment reductions and drug test results will be treated in the same manner.
The W-2 agency may require an individual who has a positive drug test to participate in a drug abuse evaluation, assessment, and treatment program to meet their CSJ or W-2 T participation requirements.
There are two levels of review under the W-2 Wisconsin Works dispute resolution process:
Fact Finding Review; and
Departmental Review.
The purpose of the Fact Finding Review is to resolve disputes for applicants and participants who disagree with a W-2 agency’s decision. This includes decisions regarding all W-2 services including Learnfare and Job Access Loans.
A Departmental Review may be requested if an individual or the W-2 agency disagrees with a Fact Finding decision.
Individuals who disagree with an agency’s decision regarding benefits for the following programs must file a separate request for a Fair Hearing with the Department of Administration, Division of Hearings and Appeals:
Medicaid;
BadgerCare Plus;
Child Care;
FoodShare; or
Refugee Cash and Medical Assistance.
Participants must follow the Fair Hearing time frame which is detailed on decision notices.
See EA Manual Chapter 6 for more information on the dispute resolution process for Emergency Assistance.
All JAL Job Access Loan applicants and W-2 Wisconsin Works applicants and participants have the right to request a Fact Finding Review. The Fact Finding Review is completed by the W-2 agency’s Fact Finder as the first level of the dispute resolution if an applicant or participant believes a part of their application or placement was mishandled. See 12.2.3 for the list of reasons that qualify for a Fact Finding Review.
An applicant or participant who requests a Fact Finding Review should be encouraged to use the Request for Wisconsin Works (W-2) Fact Finding Review form (10783) .
However, the Petitioner An individual requesting a Fact Finding or Departmental review. may use other documentation containing the same information found in the form. A W-2 agency must also accept phone requests for Fact Finding Reviews and must document the phone request using the Request for Wisconsin Works (W-2) Fact Finding Review form (10783) .
The agency decision stands until it is overturned by a Fact Finding Review or a Departmental Review. However, a Learnfare Fact Finding Review request made within 10 calendar days after the date of the Learnfare Financial Penalty Notification, may overturn a Fact Finding Review or Departmental Review.
Fact Finding Review requests must be made within 45 calendar days from whichever date is later:
Mailing date of the Notice of Eligibility for W-2 services and JAL Job Access Loan s; or
Effective date of the decision announced in the notice.
If the 45th day falls on a weekend or holiday, the calculated date will be the next working day. If the request is received within the 45-day timeframe, the W-2 agency must schedule a Fact Finding Review.
If the request for a Fact Finding Review is received beyond the 45-day timeframe, the W-2 agency must provide the petitioner with a completed Fact Finding Review Denial Notice (2686) .
A request for a Learnfare Fact Finding Review must be made within 45 calendar days from whichever date is later:
Mailing date of the Learnfare Financial Penalty Notification stating the student is not in compliance with Learnfare requirements; or
Effective date of the decision announced in the notice.
However, a Learnfare financial penalty will not be imposed if the participant or family requests a Fact Finding Review within 10 calendar days after the date of the Learnfare Financial Penalty Notification. In this situation, a Learnfare financial penalty will not be imposed until after the Fact Finding decision is issued and is favorable to the agency, unless the participant withdraws the request in writing or abandons the request.
A W-2 applicant or participant may request a Fact Finding Review if they believe:
The denial of an application for W-2 was incorrect;
The application was not acted upon within 12 working days;
The W-2 placement was inappropriate;
The placement begin date was wrong;
The W-2 payment was incorrectly ended, reduced, or subject to an overpayment;
The extension to a W-2 24-month placement time limit or 48-month state lifetime limit was incorrectly denied;
The denial of a good cause request for noncooperation with child support was incorrect;
The agency’s determination of an IPV Intentional Program Violation was incorrect;
The W-2 case was incorrectly closed; or
A Learnfare financial penalty was incorrectly imposed.
A JAL Job Access Loan applicant may request a Fact Finding Review if they believe:
The denial of an application for a JAL was incorrect;
A JAL application was not acted upon within 12 Working Day Any day of the week except Saturday, Sunday, and CARES holidays. s; or
The agency’s determination of a JAL IPV was incorrect.
If an applicant or participant requests a Fact Finding Review for a complaint not related to any of the above reasons, the W-2 agency must provide the Petitioner An individual requesting a Fact Finding or Departmental review. with a completed Fact Finding Review Denial Notice (2686).
Each W-2 Wisconsin Works agency must have at least one individual assigned to conduct Fact Finding Reviews. The Fact Finder must:
Be an individual other than the one who took action on the case;
Be neutral and provide an objective Review and decision regarding the dispute; and
Have a full and complete understanding of all impacted programs.
The Fact Finder will create an environment that is mutually respectful for all involved in the Fact Finding. If the Fact Finder has given a good faith effort in running an equitable Review for participants and staff, but cannot continue due to an individual’s behavior, they may adjourn or exclude participation to complete the review.
W-2 agencies may choose to establish a process with another W-2 agency to assist in providing thorough and objective Fact Finding Reviews.
The Fact Finding Review is an informal process to resolve disputes. It permits the Petitioner An individual requesting a Fact Finding or Departmental review. and W-2 agency to present information regarding the action or inaction in dispute.
When a W-2 agency receives a request for a Fact Finding Review, The agency must:
Date stamp the request for the Fact Finding Review on the date the request was received;
Notify the petitioner via the Fact Finding Review Appointment Notice (10782) of the time, place, and date of the scheduled Fact Finding Review appointment within three working days after the date the request for Review is received by the agency;
Hold the Review within eight working days of receiving the request; and
Reschedule the Fact Finding Review If any party requests that the Fact Finding Review be rescheduled and has a reasonable reason for the request*.
*The Fact Finder is responsible for determining the reasonableness of the request to reschedule.
A recording of the Fact Finding Review is recommended. All participants must be informed of the recording.
The W-2 agency may contact the Petitioner at any time up to the date of the scheduled Fact Finding Review to discuss the disputed issue and offer a resolution. If the petitioner does not agree with the agency’s proposed resolution, the Fact Finding Review must be held.
If the petitioner agrees to the agency’s proposed resolution, the agency must complete the Fact Finding Review Voluntary Withdrawal form (11155) . A completed form must:
Be signed by the petitioner; and
Include any actions agreed upon by both the petitioner and the W-2 agency.
If either party fails to take action by the agreed upon due date, the form is void and a Fact Finding Review must be scheduled within eight working days to address the petitioner’s complaint.
When possible, the W-2 Wisconsin Works agency worker who made the decision being disputed should attend the Fact Finding Review to present the facts regarding the decision. If that worker is unable to attend the Fact Finding Review, another staff person must be present and prepared to represent the agency’s actions.
The Petitioner An individual requesting a Fact Finding or Departmental review. or their representative must also attend the Review. The petitioner may have a representative present to assist in contesting the agency’s decision. The process must provide flexibility in scheduling and location for the W-2 participant. If any party is not able to attend in person, teleconferencing must be offered.
The petitioner or their representative may request to view and copy any records pertaining to the decision. If the cost of copying the records is more than $30, repayment may be sought. (This is assuming a $.10 charge per page, which would allow up to 300 pages of copies before requiring payment.)
If the petitioner or their representative fails to attend the Fact Finding Review without good cause, the request for Review is considered abandoned. (See 11.3.1 for more information on good cause.)
The FEP Financial and Employment Planner or W-2 Wisconsin Works worker must be prepared to introduce as evidence any testimony, exhibits, and material from the case record or other sources pertinent to the disputed issue. Additionally, the FEP or W-2 worker must:
Review the facts of the case and be familiar with the case as a whole. If more than one issue is disputed, the FEP or W-2 worker must be familiar with the policies that relate to all issues being raised.
Ensure the case record is complete, meaning all necessary documents are present, appropriate, complete, and in chronological order. Appropriate documents include: W-2 activity assignment notifications; Signed W-2 Participation Agreements; Employability Plans; and Any correspondence that supports the actions of the W-2 worker.
Thoroughly document, for presentation at the Review, events pertaining to the issue with the date, place, and identity of any person involved, including documentation of conversations, such as: Dates of phone calls; Name of the individual taking the phone call; Dates of letters, etc.
Identify and present W-2 Manual citations and Operations Memos related to the issue(s).
Once the FEP Financial and Employment Planner or other W-2 Wisconsin Works agency representative has presented documentation to support the agency's action, the Fact Finder must give the Petitioner An individual requesting a Fact Finding or Departmental review. or their representative an opportunity to present their information.
If credibility is an issue, the Fact Finder must determine which party was most credible based on testimony and evidence presented during the Fact Finding Review.
At the conclusion of the Fact Finding Review, the Fact Finder must ask all parties to sign the Documents Submitted at Fact Finding Review form (370) . This form is used to list all evidence/documentation submitted and to capture the signature of each person attending the Fact Finding Review, swearing to the accuracy of their individual testimony.
If the Fact Finder determines that additional documentation may exist that will support statements made during the Review, the Fact Finder may hold the record open for a specified number of days to allow for submission of additional documentation. However, no new information may be submitted by the agency unless the petitioner is offered an opportunity to rebut the new information.
The Fact Finder must issue a decision within five working days after the Review date, unless the Fact Finder has granted the Petitioner An individual requesting a Fact Finding or Departmental review. a request to submit additional evidence. In these cases, the Fact Finder may extend the decision date as appropriate.
The Fact Finder must weigh all factors when making the final decision and must document the final decision on the Fact Finding Review Summary and Decision form (10784) , or its equivalent.
On the same day the Fact Finder reaches a final decision, the Fact Finder must:
Mail a copy of the decision by first-class mail to the last known address of the petitioner; and
Ensure that the date of the final decision is the same as the mailing date, taking into consideration postal holidays.
The decision notice must:
Include the final decision as well as the appropriate remedy;
Cite the source of the decision; and
Provide information regarding the individual’s right to appeal the Fact Finding decision by requesting a Departmental Review.
The Fact Finder must deny a request for a Fact Finding Review or refuse to grant relief if the petitioner does any of the following:
Withdraws the request in writing; or
Abandons the request.
Abandonment occurs if neither the petitioner nor their representative appear at the scheduled Review without good cause. (See 11.3.1 for more information on good cause.) The petitioner has seven working days from the date of the scheduled Fact Finding Review appointment to provide good cause.
W-2 Wisconsin Works agencies are bound by the Fact Finding decision for a particular case. W-2 agencies must comply with the Fact Finding decision within 10 calendar days after the decision date.
If a W-2 agency is unable to comply with a Fact Finding decision for any reason, the W-2 agency must contact the Petitioner An individual requesting a Fact Finding or Departmental review. and its Regional Administrator/Coordinator on or before the 10th calendar day after the decision date and explain why the decision cannot be carried out timely.
The following table outlines the required action based on the Fact Finding final decision.
If the final decision overturns the agency’s The agency must Denial of an applicant’s paid W-2 employment position Place the individual in a paid employment position that is appropriate for the individual. An individual is eligible for a payment for the employment position beginning on the date the individual begins participation in a paid placement. No retroactive cash payment for the period prior to participation shall be issued. Denial of an ARP At Risk Pregnancy placement Place the individual in the ARP placement effective the date of the application or the date that all the ARP financial and nonfinancial requirements have been met, whichever was later, and issue a retroactive payment. (See Operations Memo 09-77 ) Denial of a CMC Custodial Parent of an Infant placement Place the individual in the CMC placement effective the date of the baby’s birth or the date of the application, whichever was later, and issue a retroactive cash payment. End date of a CMC placement Correct the end date and issue a retroactive payment. Calculation, reduction, or termination of a W-2 payment Restore the W-2 payment to the appropriate level retroactive to the date on which the payment was incorrectly calculated, reduced, or terminated. Denial of a Job Access Loan (JAL) due to an error in financial or nonfinancial eligibility determination Re-examine the JAL eligibility based on the new information.
The Fact Finder must create and maintain a complete Fact Finding file. The file must provide a complete and thorough record of the Review and must include:
Request for Wisconsin Works (W-2) Fact Finding Review (10783) or its equivalent;
Fact Finding Review Appointment Notice (10782) ;
Fact Finding Review Voluntary Withdrawal (11155) , if relevant;
Fact Finding Review Summary and Decision (10784) , or its equivalent;
Documents Submitted at Fact Finding (370) ;
Any recordings of the Fact Finding Review; and
Any additional information or evidence presented by the W-2 agency, the Petitioner An individual requesting a Fact Finding or Departmental review. , or the petitioner’s representative.
All Fact Finding Review documentation, including any additional information or evidence presented by the W-2 agency, the petitioner, or the petitioner’s representative, must be scanned into the petitioner’s Electronic Case Record.
The petitioner, or petitioner’s representative, has the right to obtain copies of any part of the Fact Finding file, including the recording. The agency is responsible for providing any requested documentation. If the cost of providing the requested documentation is more than $30, repayment may be sought. (See 12.2.6 )
W-2 Wisconsin Works agencies are required to enter Fact Finding information into the Fact Finding application in WWP Wisconsin Work Programs by the 10th day of each month for the prior month. This includes the:
Fact Finding request date;
Review date;
Reason for the Fact Finding request;
Pre-Fact Finding resolutions;
Fact Finding attendance; and
Results of Fact Finding Reviews.
The Fact Finding Review process is governed by a series of required timelines that must be adhered to.
Below is a summary of the timeframes that must be followed by the applicant, participant, W-2 Wisconsin Works agency, and Fact Finder throughout the Fact Finding process:
Review Process Action Maximum Timeframe* See Section Fact Finding Request: An applicant or participant that disagrees with a decision impacting their case must request a Fact Finding Review. 45 calendar days from the effective decision date, or from the mailing date of the notice, whichever is later. 12.2.2 Scheduling the Fact Finding Review Appointment: The W-2 agency must schedule and notify the petitioner of their Fact Finding Appointment. Three working days from the date after the request for a Fact Finding was received by the agency. 12.2.5 Pre-Fact Finding Review Resolutions: The agency may contact the petitioner to discuss the disputed issue and offer a resolution. Any time up to the scheduled Fact Finding Review appointment date. 12.2.5.1 Fact Finding Review Appointment Date: The timeframe the Fact Finding Review must take place. Eight working days from the date the Fact Finding request was received by the agency. 12.2.5 Fact Finding Decision: The Fact Finding decision must be given. Five working days from the date after the Fact Finding Review took place. 12.2.9 Mailing the Fact Finding Decision: The Fact Finding Review decision must be sent to the petitioner’s last known address by first-class mail. Same date as the Fact Finding decision is reached. 12.2.10 Entering Fact Finding Information into WWP: The agency worker must enter Fact Finding details into the Fact Finding application in WWP. By the 10th day of each month for the prior month. 12.2.12
*Maximum timeframes indicate the number of days in which the action must be taken.
If the Fact Finding Review is rescheduled (see 12.2.5 ), the deadlines for issuing the decision, mailing the decision, agency action, and WWP entry are adjusted accordingly.
If a Petitioner An individual requesting a Fact Finding or Departmental review. or the W-2 agency disagrees with the final Fact Finding decision, they may appeal the decision by requesting a Departmental Review.
The Department of Administration, Division of Hearings and Appeals (DHA) conducts the Departmental Review. The Review is limited to the record and the decision of the Fact Finder.
The request for a Departmental Review, of a W-2 Wisconsin Works decision including a Job Access Loan decision, must be received by DHA Division of Hearings and Appeals within 21 calendar days after the mailing date of the Fact Finding decision (the same date as the Fact Finding decision).
Upon receiving a request for a Departmental Review, DHA must:
Date-stamp the Departmental Review request upon receipt; and
Promptly notify the W-2 agency when the request is received.
The W-2 agency must submit the Fact Finding file to DHA Division of Hearings and Appeals within five working days after the DHA notification of receipt of the request.
DHA will fully review the W-2 agency’s Fact Finding decision by completing a desk review.
If, after reviewing the Fact Finding file, DHA determines that the file is inadequate, DHA may:
Return the file to the W-2 agency to provide additional information;
Hold a teleconference interview with the Petitioner and W-2 agency representative; or
Request written supplementation from the petitioner or W-2 agency representative.
If the petitioner is not available due to a good cause reason, DHA may grant an extension of the decision or a postponement of a phone conference.
DHA must complete its Review within 10 working days of the receipt of the Fact Finding file, unless DHA determines the file is inadequate.
If the W-2 agency has requested the Departmental Review, the W-2 agency must comply with the Fact Finder’s decision while waiting for DHA to issue its decision.
If the Petitioner withdraws the request for a Departmental Review in writing, the Department must deny the request or refuse to grant relief.
This section is unusually large; deeper subsections were cut off. Open a subsection via its designator link — for example (01-01-1-1-w-2-overview) — to read its full text.