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3.7.1 Time Limit Extension Decisions

Legal References:

The TANF time limit policy is divided in two separate sub-sections:

Section 3.7.1 Time Limit Extension Decisions describes how to make TANF/SFA time limit extension decisions. This section includes:

Section 3.7.2 Approved Time Limit Extensions describes how to maintain the case once a TANF time limit extension has been approved.

3.7.1.1 What is the time limit for TANF, SFA and GA‑S cash assistance?

Federal law states an adult in the assistance unit can receive 60 months of Temporary Assistance for Needy Families (TANF) or State Family Assistance (SFA) in their lifetime. It allows states to extend cash assistance for up to 20 percent of the WorkFirst caseload to adults who qualify for a TANF/SFA time limit hardship extension.

Effective November 1, 2011, state law applies the 60-month time limit to ineligible parents during months they receive TANF/SFA for their children. These will be TANF/SFA child only cases with an SSI, disqualified or undocumented parent.

Visit the EA-Z manual, TANF/SFA Time Limit Overview and Indian Country Disregard for more details about:

When or before an adult recipient or an ineligible parent has received 48 months of cash assistance the ACES Re-Certification letter (027-01) will include a prominent statement that there is a 60 month TANF/SFA time limit, list all adults in the household and the number of TANF/SFA months each adult has used.

As the adult in the assistance unit or ineligible parent approaches 60 months on TANF/SFA staff must determine whether he or she qualifies for a time limit hardship extension.

3.7.1.2 What is the difference between the adult recipient and ineligible parent time limit?

Currently, we close the case once an adult who is a recipient in the assistance unit has 60 countable TANF/SFA months unless the adult qualifies for a time limit extension. As of November 1, 2011 we will also count months a non-recipient parent receives TANF/SFA for his or her children only towards his or her 60 month limit.

With this change, we are creating some new definitions to help us track both time limits. ACES will use these definitions to track each adult’s 60-month limit, list each countable month as an ineligible parent or adult recipient month and indicate whether the case is closed or extended under the adult recipient or ineligible parent time limit.

We are now calling our current time limit the adult recipient time limit. Key definitions include:

Ineligible parent time limit rules are new and go into place November 1, 2011. Key definitions include:

Below are some examples of how the new ineligible parent time limits will work:

3.7.1.3 What happens when an adult recipient or inelgible parent reaches 56 months on TANF/SFA?

When an adult in the assistance unit or ineligible parent has received 56 months of cash assistance an indicator will appear on eJAS demographic screen and the Time Limit Extension tool in eJAS will become available.

Although the eJAS time limit tool is available when a adult recipient/ineligible parent reaches 56 months on TANF/SFA, the person will not appear on the CLMR until they have received 58 months of cash assistance

3.7.1.4 What happens when an adult recipient/ineligible parent reaches 58 months on TANF/SFA?

When an adult in the assistance unit or ineligible parent has received 58 months of cash assistance they will appear on the CLMR notifying the WFPS or WFSSS that the person is nearing the 60 month lifetime limit. For two parent families, each parent will appear separately on the CLMR as they reach 60 months.

The WFPS or WFSSS must determine if the adult recipient /ineligible parent qualifies for a time limit hardship extension by the end of month 58 whenever possible and no later than the last day of the person’s 60th month.

Mail an ACES Online 50-05, General Appointment Letter, or the eJAS appointment letter to the adult recipient/ineligible parent stating when he or she will reach 60 months on TANF/SFA using the following text:

“Once you reach 60 months on TANF/SFA, you will only qualify for TANF/SFA cash aid if you qualify for a time limit hardship extension. Our records show you have [number] months of TANF/SFA. I need to meet with you on [date /time] to determine if you will qualify for an extension and review your plans for supporting your family if your case is closed.

Please come to this appointment to make sure we know of any employment, family violence issues, child welfare actions and your (or a family members’) health problems. We may be able to use this information to approve an extension and can help you get any needed evidence”

Give the adult recipient /ineligible parent 10 calendar days so he or she can make arrangements to attend the appointment.

Adult recipients /ineligible parents can contact us in writing, by phone, by going to the appointment described in their time limit appointment letter or by asking for a different appointment time. If the person is in the office, the person can waive his or her appointment notice and the client time limit interview can be done immediately. Or, the person can waive the in-person appointment and opt to complete his or her interview over the phone.

Document when a person waives the 10-days and give or send the person another time limit appointment letter to reflect when the appointment actually occurred for his or her files.

3.7.1.5 What are the time limit extension categories?

Once any adult in the assistance unit or ineligible parent has received sixty months of cash assistance, the entire assistance unit becomes ineligible for TANF/SFA cash assistance, unless that adult/ineligible parent qualifies for a time limit hardship extension.

For two-parent families, an extension can only be approved for an adult who has received 60 months of TANF/SFA. If either adult has 60 months or more on TANF/SFA and qualifies for an extension, the entire family remains eligible.

A caretaker relative with 60 months or more of TANF/SFA, who is not the child’s parent, and does not live with the parents of the child, may choose to receive a grant for the child only as allowed under WAC 388-408-0025(2)(c). If so, and there is no longer a 60+ month adult in the assistance unit, the family will remain eligible for TANF/SFA cash aid. The ineligible parent time limit doesn’t apply since there is no parent in the home.

An adult in the assistance unit or an ineligible parent that has received 60 months of cash assistance may qualify for a time limit extension #4 through #11 on the Time Limit Hardship Extension chart when the adult is:

Time limit extensions are based on meeting the criteria for an extension, not on the types of eJAS component codes entered in eJAS. See the Time Limit Hardship Extensions chart for more details about the extension categories, criteria, required documentation, participation requirements and review cycle.

An adult recipient/ineligible parent may qualify for more than one type of extension.

If an adult recipient/ineligible parent no longer meets the time limit extension criteria or TANF/SFA eligibility criteria during the hardship time limit extension, the family’s cash assistance will end.

3.7.1.6 How do I determine whether an ineligible parent qualifies for a disability time limit extension?

You can’t use WorkFirst support services to pay for an undocumented or fraud-disqualified parent’s medical evidence, even when we need it to determine their child’s eligibility. We also can’t use WorkFirst funds to purchase medical evidence for an undocumented or fraud-disqualified disabled child or adult relative.

However, WorkFirst Social Service Specialists are able to access general funds state in ICMS to purchase medical evidence for undocumented or fraud-disqualified individuals. As with any client, we don’t require ineligible parents to pay the cost, but don’t purchase more evidence than we need to establish time limit extension eligibility. For example, the parent may be able to access free clinics, or, if the parent is already seeing a doctor, we can likely purchase a report instead of a full medical exam.

Use the Missing Verification for Interview (0023-01) pend letter to request medical evidence, using the same timeframes we use for all other time limit cases and the following text:

“You must provide documentation of your [or your child or adult relative’s] mental, physical, emotional or cognitive impairment and your ability to engage in work from one of the primary or secondary medical professionals described in WAC 388-449-0010.

Medical documentation must include:

Once you receive the requested medical evidence, social service specialists sign in to Barcode to access the ICMS subsystem and use the 06030 ineligible parent medical evidence code to pay for medical evidence. The system uses the same medical evidence fee schedule that is used for ABD. See the Social Services Manual – Medical Evidence Requirements and Fee Schedule section and the Ineligible Parent Medical Evidence Desk Aid for more information on how to process these payments.

3.7.1.7 Who qualifies for the family violence time limit extension?

If an adult recipient/ineligible parent has received 60 months of cash assistance and declares family violence issues, you need to do three things to approve this type of extension:

Use the same verification requirements that you use for the Division of Child Support (DCS) Good Cause process to document the family violence. Verification may include one of the following:

Document family violence information in the family violence note type in eJAS (but not on any eJAS time limit denial letter) to protect the safety of individual(s). Offer a referral to the on-site or community based domestic violence advocate (or pro bono services, as available, for ineligible parents).

Although we are following the same requirements as DCS Good Cause to document the person has a family violence issue, the person may pursue the time limit extension without filing a DCS Good Cause claim. However, encourage the person to also request DCS Good Cause if establishing and/or collecting cash and/or medical support may result in serious physical or emotional harm to the child or parent/caretaker

In addition to documenting the family violence, an adult recipient/ineligible parent must also follow a family violence service plan that has been developed by a person trained in family violence in order to address family violence issues during the time limit extension. The person does not need to be currently experiencing family violence to do a service plan and qualify for the family violence time limit extension. The person may be taking steps to recover from the impacts of family violence. For example, a parent and children may be in counseling or need to avoid some areas of town during activities such as job search.

Always offer an adult recipient a chance to get his or her family violence service plan done by a family violence advocate whenever possible. If this is not possible, or the person does not want this done by a family violence advocate, a WorkFirst Program Specialist (WFPS) or WorkFirst Social Service Specialist (WFSSS) who is trained in family violence can complete the plan. If the person wants a service plan from an advocate, a WFPS/WFSSS trained in family violence can do a temporary service plan that only requires a completed service plan from the advocate within 30 days (or, with supervisory approval, within 90 days). The family violence service plan must be listed separately, as the adult recipient’s family violence service plan, in the IRP as participating in a family violence service plan is a condition of remaining eligible for a family violence time limit extension.

Create a reasonable, safe and doable plan for ineligible parents, drawing on locally available resources. See Ineligible Parents' Family Violence Plans for more information. Document the ineligible parents' family violence plan in eJAS family violence case notes.

See the Social Services manual, Good Cause chapter, and the WorkFirst Handbook, Section 6.5, Family Violence, for more information about DCS Good Cause verification requirements and family violence.

3.7.1.8 How do I know if an adult recipient/ineligible parent qualifies for a child in dependency time limit extension?

We want to support WorkFirst and ineligible parents as they work through potential custody issues with Children’s Administration (CA) or a tribal child welfare agency or court. Working collaboratively with CA helps address the needs of the family accessing services from both the child welfare system and the WorkFirst program. CA involvement provides the opportunity to make sure that WorkFirst requirements do not interfere with the actions parents are taking to keep their family together.

When determining eligibility for a time limit decision, contact CA staff to determine if the family has an open child welfare case. If it appears that there may be an open tribal child welfare case, you cannot initially approve the extension and must send the parent’s name and eJAS ID to WorkFirst program managers Kerry Judge-Kemp at judgeka@dshs.wa.gov with a cc to Stacey Bushaw at bushask@ dshs.wa.gov. Headquarters will track these cases and follow up on gathering additional information needed to determine whether the parent qualifies for the extension.

If CA is working with the family, follow up to see if there are any first-time court ordered dependency considerations or actions. That is, this is the first time any of the parent’s child(ren) have been involved in child dependency considerations or actions. If so, the parent qualifies for a child in dependency time limit extension through the date dependency is anticipated to be resolved or six months, whichever is less. This time period can cover any concurrent benefit and six-month follow up period while CA continues to work with the family. Please note voluntary placements or shelter care status doesn’t qualify for the extension.

Document in eJAS that you checked to see whether there was CA/tribal child welfare court ordered dependency considerations or actions and how you responded to any indications of dependency actions taken, including forwarding tribal child welfare cases to WorkFirst headquarters staff.

Families involved with CA or tribal child welfare may be required to do activities like counseling or treatment to help keep their families together. It’s critical to take these activities into consideration when developing the adult recipient’s IRP and add these activities as a WorkFirst participation requirement appropriately.

It is also helpful to involve CA or tribal child welfare in case staffings, assessments, and any intensive work with the family during a child dependency time limit extension. This ensures we are making joint plans that will meet the full spectrum of the family’s needs.

3.7.1.9 What is the time limit hardship extension process?

The WFPS or WFSSS must determine if the adult recipient /ineligible parent qualifies for a time limit hardship extension at the time limit client interview.  You cannot authorize WorkFirst support services for ineligible parents per WAC 388-310-0800(1)(a).

You must do a thorough case review to locate any evidence of potential eligibility for a time limit extension and respond to any evidence you find. When you review the case, identify:

At the time limit client interview, review the case and the results of your case review using the eJAS time limit tool to determine hardship extension eligibility and explain the process for obtaining medical or other needed evidence, as necessary. In addition, review the TANF time clock with the adult recipient/ineligible parent to confirm its accuracy.

It is also essential to discuss the person’s plan for supporting their family if TANF/SFA is terminated at the time limit client interview. Explain Transitional Food Assistance (TFA) and ongoing medical, WCCC, the benefits of applying for child support, the availability of community resources, and CEAP benefits that are available to households that are expected to close due to the 60 month lifetime limit.

If the adult recipient fails to attend the time limit client interview, do not pursue sanction. Determine if the adult recipient/ineligible parent is eligible for a time limit hardship extension based on the information in their case record.

Any time a case is reviewed via the eJAS time limit tool, and the person doesn’t qualify for an extension, a time limit extension denial letter will be generated in eJAS by the worker conducting the review. If we have any evidence related to a time limit extension, but the person meets any, or only some of the criteria needed to qualify, add the appropriate text to the time limit denial letter using the eJAS template text or as shown on the Time Limit Hardship Extensions chart describing the evidence we took into consideration in making our decision. However, we don not document a parent's history of family violence on the eJAS letter to preserve confidentiality.

We do not document a  person’s history of family violence on the eJAS letter to preserve confidentiality.  The eJAS time limit denial letter will be available for viewing and saved in the eJAS letter history. However, do not give or mail the eJAS time limit denial letter to the adult recipient /ineligible parent. You may tell the  person whether s/he appears to qualify for a time limit extension during the interview or if s/he calls and asks, but we cannot provide anything in writing. If translations are needed, eJAS will allow you to print the letter so you can get it translated, but again, do not mail the letter when the translations come back

When the adult recipient/ineligible parent qualifies for an extension, eJAS will automatically enter the time limit extension code(s) 4-11 in a real-time process when on the ACES TWEP screen. The longest extension will be used when the person qualifies for more than one type of time limit extension. For two parent families, when both have 60 months or more and one is approved for an extension and the other is denied, the approval will override the denial in ACES, the case will remain open and the family’s ACES notice will reflect the information for the approved parent.

The time limit decision must be entered into eJAS whenever possible in time to close the case after 60 months on TANF/SFA for those who don’t qualify for an extension so we don’t risk federal penalties. ACES will generate a 10-day notice in month 60 to close the case or extend TANF/SFA based on the time limit extension decision. See 3.7.1.11, how do I send the time limit decision notices to the parent, for additional processing instructions.

3.7.1.10 What happens when the adult recipient/ineligible parent doesn’t qualify for any time limit extensions?

When an adult recipient/ineligible parent doesn’t qualify for a time limit extension reassess the family’s plans post termination and ensure all needed services, like continuing WCCC, food and medical assistance, are provided.

Be sure to add explanatory text to the eJAS time limit decision letter when we have evidence related to a time limit extension, but the person doesn't meet any, or only meets some criteria needed to qualify as shown on the eJAS time limit denial letter template or the Time Limit Hardship Extensions chart.

If the person doesn't qualify for an extension, eJAS will pass this information to ACES on a real-time basis and enter the extension reason 13 on the ACES TWEP screen. Cases will only close once reason 13 has been entered into eJAS, populated on the ACES TWEP screen and the adult recipient/ineligible parent has reached 60 months.

ACES will generate a 10-day notice to close the case by end of the 60th month based on whether the person has reached the adult recipient or ineligible parent time limit and the hardship extension denial on the eJAS time limit tool. See 3.7.1.11, how do I send the time limit decision notices to the parent, for additional processing instructions.

3.7.1.11 How do I send the time limit decision notices to the adult recipient/ineligible parent?

No action is required for time limit approvals. ACES will generate and, as needed, translate the approval notice. There is also a fully automated process to send English denial notices that will print and mail out the ACES and eJAS time limit denial letters in one envelope

.

Translated time limit denial letters require the following action:

3.7.1.12 Can an adult recipient/ineligible parent who was denied a time limit extension request an Administrative Hearing and receive continued benefits?

If an adult recipient/ineligible parent has received 60 months of TANF/SFA and is terminated or denied cash assistance because they do not qualify for a time limit extension or they do not agree with the months used towards their 60 month lifetime limit, he or she has a right to an administrative hearing.

When a person is eligible for continued benefits per the EAZ manual, Fair Hearing- Pending Continued Benefits, the Administrative Hearing Coordinator who is handling the administrative hearing request must notify the WFPS/WFSSS so they can approve an administrative hearing (#12) time limit extension in the eJAS time limit tool. The start date in the tool is the first month the case will remain open pending an administrative hearing decision and the extension is approved in three-month increments. Once the extension is approved in eJAS, reinstate the case, ACES will keep the case open and send a notice.

When the decision is received the Administrative Hearing Coordinator (or appropriate staff member) must follow the decision process referenced in the EAZ Manual, Fair Hearing-The Decision, and follow the appropriate processes for restoring benefits or processing overpayments.

3.7.1.13 What happens when the adult recipient/ineligible parent offers more time limit extension evidence before we close their case?

Sometime a person’s circumstances may change or the person may be able to provide more evidence of time limit extension eligibility. For example, a medical condition may worsen, they may disclose family violence, they may increase their hours at work or child welfare may contact them about one of their children.

When a person who doesn’t qualify for a time limit extension contacts you offering more or new evidence before we close his or her case:

Once you receive the new evidence, use it to determine eligibility for a time limit hardship extension. If the person fails to provide the requested information by the date on the IRP or a Missing Verification for Interview (0023-01) pend letter, review the case and make the decision based on the information in the parent’s case record.

Use the eJAS time limit extension tool to document the decision and ,if you still cannot approve an extension, translate the eJAS time limit extension decision letter as needed, adding any needed details per the eJAS time limit denial letter template or the time limit hardship extension chart.

3.7.1.14 What if a person reapplies before their case is closed?

A person may choose to reapply before their case closes due to time limits. If so, WorkFirst staff can start to gather information needed for a TANF or, for adult recipients, Disability Lifeline eligibility determination immediately:

See the section below for instructions on processing the application once it is screened into ACES.

3.7.1.15 What happens when the parent states they qualify for a time limit extension after we close their case?

A person may reapply for cash assistance after being terminated due to time limits, including when they have new evidence or a change of circumstance (e.g., a new, serious medical condition) that may qualify them for a time limit extension.

Treat the application in the same manner as any other TANF application, with the following exceptions:

3.7.1.16 Time Limit Extension Decisions- Step-by-step guide
  1. The parent will receive a prominently displayed notice of the months of TANF receipt on his or her recertification notice as she or he approaches 48 months on TANF/SFA.
  2. Once the adult recipient/ineligible parent reaches 56 months on TANF, eJAS will indicate this on the eJAS demographic screen and the WFPS/WFSSS will have access to the eJAS time limit tool to process a decision.
  3. Once the adult recipient/ineligbile parent reaches 58 months on TANF/SFA, his or her name will appear on the CLMR to indicate a time limit extension decision must be made by the end of month 58 when possible, and no later than the end of month 60.
  4. The WFPS/WFSSS will send an ACES Online 50-05, General Appointment Letter or the eJAS appointment letter to the person and:
    1. Notify the person when he or she will reach 60 months and of the need for a time limit extension decision; and
    2. Give the person at least 10 days to come to the appointment. The person has the option to waive the appointment and complete the time limit interview sooner.
  5. At the time limit extension interview, the WFPS/WFSSS will:
    1. Explain the TANF/SFA time limit policy.
    2. Review the person’s TANF/SFA months for accuracy and only count adult recipient out of state or tribal TANF months.
    3. Discuss the available supports, such as transitional food or medical, for those who don’t qualify for a time limit extension and provide the person a list of community resources
    4. Use the Time Limit Hardship Extension Chart to determine whether the adult recipient/ineligible parent qualifies for one or more types of extensions.
    5. Use an IRP (or a Missing Verification for Interview pend letter (0023-01) for ineligible parents) to request any needed evidence for hardship determination but make the decision based on the evidence available at that time.
    6. Complete the eJAS time limit tool to document the interview and the time limit extension decision.
    7. If we have evidence related to a time limit extension, but the person doesn't qualify for a time limit extension, document the evidence we took into consideration in making our decision in the free form text box of the eJAS time limit tool using language from the eJAS time limit denial letter template or theTime Limit Hardship Extension chart.
    8. If the adult recipient/ineligible parent isn’t approved for an extension, save the letter. Or, for non-English letters, print, translate and hold (without imaging in DMS) the Time Limit Decision Letter . eJAS will enter the information on the ACES TWEP Screen and ACES will automatically create the 10-day notice to extend or close TANF/SFA when the person reaches 60 months.
    9. During month 60, ACES will send out extension approval and English extension denial letters. Staff will receive a Barcode tickle for extension denial letters needing translation:
      1. Send a copy of the translated eJAS denial letter for imaging
      2. Translate the ACES termination notice if it’s in a non-supported language
      3. Locally print and mail the translated ACES and eJAS letters to the client in one envelope
      4. Document the letters were mailed in the eJAS time limit note type and clear the Barcode tickle
  6. If the adult recipient/ineligible parent doesn’t show up for his or her time limit extension interview, the WFPS/WFSSS won’t pursue sanction, but will make the time limit extension eligibility decision based on the available information.
  7. If the person is terminated, files an administrative hearing and qualifies for continued benefits:
    1. The person processing the administrative request will notify the WFPS/WFSSS
    2. The WFSSS/WFPS will enter the administrative hearing with continued benefits into the eJAS time limit tool to continue cash aid.
    3. If the adult recipient/ineligible parent is upheld, process the ALJ approved extension into the eJAS time limit tool.
    4. If the department is upheld, closes the administrative extension and enters specialized text into the ACES termination notice.
  8. When the adult recipient/ineligible parent offers additional evidence before we close his or her case, the WFSSS/WFPS will:
    1. Document the client contact and type of new evidence in eJAS time limit note type.
    2. Use the IRP (or a Missing Verification for Interview (0023-01) pend letter for ineligible parents) to request additional information within 10 days, or no later than the last day of the person’s 60th month.
    3. Schedule an appointment if the person wishes to meet and discuss the updated information.
    4. Use the newly provided evidence to determine eligibility for a time limit hardship extension.
    5. Make the decision based on existing information in the case if the person fails to provide new evidence by the required date.
    6. Use the eJAS time limit tool to determine eligibility for a time limit extension and document the decision. If the extension is denied, print and translate the eJAS time limit decision letter, as needed (adding any needed details per the Time Limit Hardship Extension chart).
  9. When a former adult recipient/ineligible parent states she or he qualifies for a time limit extension after we close their case, she or he will need to reapply. The WFPS/WFSSS will use the normal application process with the following exceptions:
    1. Complete a family violence screening and the time limit interview along with the intake interview.
    2. Approve (if you have documentation) or deny the time limit extension in the eJAS tool and note any information needed to determine financial and time limit extension eligibility on the pend letter. Complete the CE for a former adult recipients if the person qualifies (or may qualify) for a time limit extension.
    3. Use Washington Apple Health (if available) or WorkFirst Support Services for a former adult recipients as described in WFHB 6.6.6 to pay for any needed medical evidence. See section 3.7.1.6 for ineligible parents.
    4. Once time limit evidence is received, use the eJAS time limit tool to determine eligibility for time limit extension.
    5. If the extension is denied, adds any explanatory text to to the ACES denial notice and does not generate an eJAS time limit denial letter.
    6. Follows the instructions in the Social Services Manual – Disability Lifeline – Pregnancy or Incapacity Determination to determine Disability Lifeline eligibility if the former adult recipient is pregnant or claims a mental or physical health issue prevents them from working.

Resources

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