3.3.2 Stacking Activities

Revised on: July 13, 2026

Legal References:

The 3.3 IRP and Stacking Activities section has two separate sub-sections:

  • Section 3.3.1 Individual Responsibility Plan.
  • Section 3.3.2 Stacking Activities. This section describes the stacking process including:
     
    • 3.3.2.1 What is stacking activities?
    • 3.3.2.2 What are countable core and non-core activities?
    • 3.3.2.3 Using the Pathway Development Tool recommendations to meet participation goals.
    • 3.3.2.4 How to build an Individual Responsibility Plan by stacking activities.
    • 3.3.2.5 How to deem.
    • 3.3.2.6 When to use the local minimum wage.
    • 3.3.2.7 How to Deem - Policy in Practice

 

3.3.2.1 What is stacking activities?

Stacking activities refers to building an Individual Responsibility Plan (IRP) that includes more than one WorkFirst activity. Multiple WorkFirst activities 'stack' together towards a plan, which in most circumstances meets minimum participation requirements for WorkFirst (and in many circumstances, TANF federal participation requirements). Though stacking goes beyond participation requirements, focusing on how WorkFirst can best support the needs of participants. Refer to WFHB 1.2.1 for more information on participation requirements.

 

3.3.2.2 What are countable core and non-core activities?

All WorkFirst activities are designed with a purpose - but not all count towards meeting TANF federal participation requirements. WorkFirst activities fall into one of these broad categories:

  • Fully countable core activities (paid and unpaid work).
  • Time-limited countable core activities (job search, life skills training, certain issue resolution activities [including some "X components], and vocational education).
  • Countable non-core activities (skills enhancement training, high school completion or high school equivalency for participants age 20 or older), which count once a participant has met their core activity requirements.
  • Exemptions and exceptions, which may count or qualify for TANF federal participation exemptions.
  • Stabilization services (uncountable ‘X’ components), that are temporarily needed to resolve a barrier.

The Core & Non-Core Activity Chart lists countable core and non-core activities.

The Stacking Activities Chart shows how WorkFirst activities count towards meeting TANF federal participation requirements, listing all exemptions, exceptions, stabilization (uncountable), and core activities. The chart gives an overall strategy for how core and non-core activities can be stacked to help the participant move towards stability and employment.

 

3.3.2.3 Using Pathway Development Tool recommendations to meet participation goals.

The comprehensive evaluation, and (if needed), assessment recommendations captured within the Pathway Development Tool (PDT) are designed to respond to participant needs. They support building IRPs that:

  • Address the participant’s primary needs.
  • Start with employment, job search, or unpaid work (like Community Works) as the participant's primary activity, when possible.
  • Make meaningful use of time-limited core activities. This can be done by including or focusing on:
    • Short-term, full-time issue resolution, when needed.
    • If job ready, enrolling participants in job search 4 weeks at a time with work experience activities interspersed between enrollments.
    • Starting vocational education once the participant is ready to engage full-time with it.
  • Focus on stabilizing the participant's situation if they are unable to initially participate in countable activities.
  • Offer participation exemptions, exceptions, and pathways (e.g., pregnancy to employment, high school completion, or high school equivalency for minors/dependent teens).
  • Uses continuous activity planning (see WFHB 3.2.1.5) to keep participants moving towards their goals whenever possible. This includes having current activities support the participant's next steps.

 

3.3.2.4 How to build an Individual Responsibility Plan by stacking activities.

An IRP is built based on the primary activity the participant needs to make progress in.

As a reminder, some individuals or households may meet their goals as well as WorkFirst (and federal) participation requirements by participating as follows:

  • 20 hours per week of core activities for participants in a single parent household, who are 20 years old and older and have a child under six years old.
  • 20 hours per week of high school completion or high school equivalency for teen participants age 18 and 19 if they don’t already have their high school diploma or high school equivalency. Hours are based on school requirements to progress towards graduation.
  • Participation in high school completion or high school equivalency per school requirements to progress towards graduation for pregnant and parenting minors age 17 and younger, unless they have a child under the age of 12 weeks old. Hours are based on school requirements to progress towards graduation.
  • 35 hours per week combined participation (30 hours core, 5 hours non-core activities) for two-parent households.

For these individuals and households this means how their plan is stacked could look different than others. Participants and households who fall into these groups can still add more core, non-core, and/or uncountable activities as needed to meet their needs and goals. For more information, refer to WFHB 1.2.2.

For all other individuals who are required to participate in WorkFirst activities may be stacked to build an IRP that both meets their needs and WorkFirst (as well as federal) participation requirements by:

  1. Starting with 20 hours per week of core activities.
     
    1. The participant can do more than one type of core activity to reach 20 hours per week. For example, add a few hours of an additional appropriate core activity to the participant's primary core activity to meet the 20-hour requirement.
    2. Working the FLSA maximum hours of WEX or community service meets the full core activity requirement. See WFHB 3.3.2.5.
    3. See WFHB 1.2.2 for information on adding an additional three hours (preferably core activity hours) in the participant’s IRP when possible.
  2. Adding 12-20 hours per week of countable activities:
     
    1. More hours of the main core activity.
    2. An appropriate additional core activity.
    3. Non-core activities (e.g. job skills training, basic education, high school completion, or high school equivalency).

Based on this approach the participant would end up with 32-40 hours total hours of scheduled activities participation each week.

Reminder: Participants who are exempt or have deferred participation may also have an IRP with required or voluntary activities depending on their given circumstances and program rules. These IRPs may not necessarily be stacked to meet WorkFirst (or federal) participation requirements depending on the given situation.
Example: Rebecca and her daughter, age 7, were just approved for TANF cash assistance. Rebecca reports no barriers, that she is working but that her hours were recently cut to 10 hours a week. Rebecca’s goal is to find a second job or a full-time job. Rebecca’s IRP is stacked with 10 hours a week of employment and 22 hours of job search, for a total of 32 hours of scheduled core activities.
Example: Naomi has a 10-year-old son. During her comprehensive evaluation she reports not having worked since her son was born. Her goal is to get her GED. After discussing options with WorkFirst staff, Naomi agrees to participate in Community Jobs to achieve additional work experience. Her IRP is initially stacked with 20 core activity hours per week for Community Jobs (CJ component with contractor code). In the eJAS referral to the contractor, WorkFirst staff add notes indicating that Naomi wants to work towards getting her GED as her other stacked activity for 12-20 hours a week.
Example: Jacques and Sarah are married with two children and receive TANF cash assistance. Jacques is working 25 hours per week and Sarah has been staying at home with the children. Both Sarah and Jacques want to participate in WorkFirst activities, with the goal of increasing the household’s income. Jacques' existing employment meets 25 hours of the household’s 30-hour core activity requirement. Jacques selects and agrees to the option of attending job skills training classes for 6 hours per week. Sarah agrees to go to job search for 32 hours per week. The household exceeds their minimum 35 hour per week participation requirements by doing 57 hours per week of core activity and 6 hours per week of countable non-core activity.

3.3.2.5 How do I deem?

The Fair Labor Standards Act (FLSA) has rules that apply to participants in community service and work experience (unpaid work activities), which are that:

  • Participants must have Labor and Industry Insurance coverage provided by the worksite or school.
  • Participants can't be required to work more hours than their cash grant plus food stamp benefits divided by the state or local minimum wage, whichever is higher, each month. This is called the "FLSA maximum hours".

Participants who work the FLSA maximum hours meet their full core activity requirement. Staff use the eJAS FLSA calculator tool to calculate the FLSA maximum hours based on the participant's cash grant and basic food benefits, divided by the state or local minimum wage. The result is the maximum FLSA hours for the month. The FLSA calculator tool automatically divides the monthly maximum FLSA hours by 4.33 and rounds down to determine how many hours the participant performs unpaid work, on average, each week. The FLSA maximum hours for the past, current and upcoming month are then displayed in eJAS within this Tool, and visible to contractors in the Component/Contractor/IRP Update screen via the Calculate FLSA link.

When a participant is first approved for TANF cash assistance and is entering a community service or work experience activity, WorkFirst staff use the eJAS FLSA calculator tool to determine the maximum number of participation hours for the current month. The cash and food benefit amounts and household size are entered into the Tool and once the information is saved, the Tool produces the FLSA maximum hours which WorkFirst staff share with community service and work experience providers. This information is also visible in eJAS to all contracted partners as soon as the calculation is saved.

Note, the eJAS FLSA calculator tool defaults to the Washington State minimum wage, so if a participant is subject to a higher local minimum wage the FLSA hours will need to be manually adjusted by WorkFirst staff. See WFHB 3.3.2.6 for more information about determining FLSA hours based on local minimum wages.

Example: Dorothy agrees to participate in Community Works and ESL classes and her FLSA maximum hours are 14 hours per week. Under FLSA we can only require Dorothy to do 14 hours per week of Community Works and that meets her 20-hour core activity requirement. Dorothy does an additional 12 hours per week of ESL classes to bring her up to 32 hours per week of countable participation. ESL providers may add 3 additional hours of ESL classes (instead of Community Works) per WFHB 1.2.3 to add additional hours without exceeding the FLSA maximum.

There are special rules for deeming with two-participant families. Most importantly, the FLSA maximum hours apply to the entire family, not to each participant. To be classified as a two-participant family under federal rules, neither participant can be:

  • An undocumented immigrant
  • Disabled (on SSI/SSA disability or with a ZD exemption), or
  • Caring for a disabled family member (with a ZB or ZC exemption)

Under WorkFirst, the goal is to have each participant to engage in 32-40 hours per week of activities unless one participant is opting out, or the participants are splitting the hours, per WFHB 1.2.4. CSD headquarters staff use federal rules to deem 30 hours of core activities if either participant works the family's FLSA maximum hours. When this is done, the whole family meets federal participation requirements if either participant does an additional 5 hours of another type of core or non-core activity.

Some families FLSA maximum hours exceed 20-30 hours per week. These additional hours are not deemed. In these cases WorkFirst staff may:

  • Credit excess hours towards the additional 12-20 hours of core/non-core activities, or,
  • Limit the community service/work experience to 20 hours per week so the participants can engage in other beneficial, countable activities.

See WFHB 1.2.3 for information on adding an additional three hours in the parent’s IRP when possible. As a reminder, unpaid work activities are not to exceed the FLSA maximum hours. Non-core activity hours can be substituted for core activity hours as needed to stay within the FLSA maximum.

 

3.3.2.6 When to use the local minimum wage.

The state or local minimum wage (whichever is higher) must be used when determining hours of participation in unpaid work experience and community service activities. Local ordinances are only in effect within the local government's boundaries and may only apply to some types of employment. For the purposes of FLSA deeming, DSHS is an employer. When a local minimum wage is higher than the state minimum wage, WorkFirst staff are responsible to calculate the adjusted FLSA hours using the local minimum wage in the eJAS FLSA calculator tool.

Note: When WorkFirst staff set up the unpaid work activity, they use the L&I Local Minimum Wage Rates website to determine whether local minimum wage applies.

 

3.3.2.7 How to Deem - Policy in Practice

  1. For unpaid work activities, WorkFirst staff and contractors determine if the local minimum wage rate applies using the L&I Local Minimum Wage Rates website.
  2. For newly approved WorkFirst applicants and re-applicants:
     
    1. When the state minimum wage applies, WorkFirst staff use the eJAS FLSA calculator tool on the Calculate FLSA screen to determine FLSA hours for the current month based on household size and the cash and food benefit amounts.
    2. When the local minimum wage rate applies, WorkFirst staff:
       
      1. Enter the number of TANF members in the Basic Food household, total members in the Basic Food household, monthly cash grant amount, and monthly Basic Food allotment into the corresponding fields of the eJAS FLSA calculator tool to determine the maximum FLSA hours using the local minimum wage.
      2. Notify the WorkFirst partner, as needed, of the adjusted hours.
      3. Documents local minimum wage data in ongoing eJAS notes:
         
        1. That local minimum wage applies,
        2. Local minimum wage rate, and
        3. FLSA hours.
      4. Updates the IRP, as needed.
  3. If there is a change in cash/food benefits during the participant’s unpaid work activity:
     
    1. WorkFirst staff get an eJAS Review FLSA hours notification via the CLMR, and:
       
      1. Check to see if this is a local minimum wage case, as the change in benefits may impact the maximum number of hours allowed for participation.
      2. For local minimum wage cases they:
         
        1. Enter the new minimum wage amount into the eJAS FLSA calculator tool.
        2. Document that local minimum wage applies, what the local minimum wage rate is, and the FLSA hours in ongoing eJAS notes.
        3. Modify the IRP as needed.
        4. Notify the WorkFirst partner, as needed.
  4. If the FLSA hours need to be split amongst household members, WorkFirst staff:
     
    1. Click on Split Hours to generate the FLSA hours for Parent 1 and Parent 2 (total monthly hours will be rounded down).
    2. Selects Parent 2 by name from the drop-down box on the Calculate FLSA for AU screen and enters the number of participation hours.

Resources

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