3.5.3 NCS Reapplications

Revised on: September 20, 2021

Note: If a participant re-applies, is determined financially eligible, and their case closed due to NCS Termination prior to July 1, 2021, TANF/SFA opens without any NCS penalty or cure requirement.

Legal References:

The Non-Compliance Sanction Policy section is divided in three separate sub-sections:

  • Section 3.5.1- Entering Non-Compliance Sanction (NCS) describes how to make the NCS decision.
  • Section 3.5.2 - Ending Non-Compliance Sanction (NCS) describes what happens when a participant stays in NCS.
  • Section 3.5.3 - NCS Reapplications describes how to process reapplications from NCS terminations. This section includes:
    • Can a participant reapply for TANF cash assistance after Non-Compliance Sanction (NCS) termination penalty?
    • Consolidated Emergency Assistance Program (CEAP) for NCS case closures.
    • What if a participant reapplies before their case is terminated in NCS?
    • How do I decide and track an applicant's participation requirements?
    • What if the applicant stops participating?
    • How is the NCS reapplication approved?
    • What if a participant's NCS reapplication is approved and they stop participating again?
    • NCS reapplication - step-by-step guide

3.5.3 NCS Reapplications Can a participant reapply for TANF cash assistance after Non-Compliance Sanction (NCS) termination penalty?

A participant may reapply for TANF cash assistance or State Family Assistance by filing a new application. Unless the participant is unable to participate, they must participate 4 weeks (28 days) in a row before they are approved for cash assistance. The participant receiving the NCS penalty may be eligible for CEAP while they meet the participation requirement (see Section Consolidated Emergency Assistance Program (CEAP) for non-compliance sanction case closures.

Participants closed for non-compliance sanction (NCS) may qualify for CEAP. They're eligible to apply for CEAP under the same rules as other applicants.

To determine eligibility and authorize benefits follow the CEAP eligibility and procedures described under WAC 388-436-0015. What if a participant reapplies before their case is terminated for NCS?

If TANF/SFA is closing after ten months of NCS reduction and an application is received before the NCS termination date:

  • Track the application in DMS, and
  • Attempt to contact the participant right away.
Note: Staff won't be able to input the application into ACES until the first of the following month.

After the participant completes an interview and staff determines financial eligibility, the WorkFirst Program Specialist (WFPS) or WorkFirst Social Service Specialist (WFSSS) determines if they're able to participate.

  • If the participant can't participate, lifts the sanction and restores full benefits the first of the following month or when all other financial eligibility criteria is met.
  • If the participant can participate, tracks 28 day NCS cure requirement. How are an applicant's participation requirements determined and tracked?

When a participant applies after the NCS termination, the intake worker:

  • Determines financial eligibility.
  • Pends application approval for WorkFirst participation.
  • Refers the case to WorkFirst staff to find out whether the participant must participate before they receive cash.

Once that decision is made, the ACES WorkFirst Participation - TANF Pending (85-06) letter is updated as needed. Once the participant is in pending status, they appear on the 'NCS Reapplicant report' on the Caseload Management Report. Only the participant who caused the termination appears on the report.

The participant must participate, if able, four weeks (28 consecutive days) in a row before they're eligible for cash benefits.

  • The 4-week participation requirement is waived, (and the SA or SN code removed) when the participant enters the third trimester of pregnancy if they:
    • Have completed a Pregnancy to Employment assessment and;
    • Don't have a mental health and/or chemical dependency treatment requirement.
  • The requirement is waived if their situation is now severe enough that they're exempt.
  • Notify the application intake worker if the participation requirement is lifted so they can update the pend letter or approve the application.

If the participant is able to participate, the WFPS/WFSSS:

  • Tracks the participation in eJAS.
  • Completes a re-engagement appointment.
  • Develops the IRP with the participant and authorizes necessary support services needed to participate, such as transportation.

If both participants in a 2-parent household refused to participate and caused their case to close, both participants need to meet the 28-day participation requirement. The application shouldn't be approved until both participants meet this requirement.

Day one of participation begins when the participant completes the Re-engagement appointment and their IRP. Excused absences count towards meeting the 28-day requirement. If TANF is closing at the end of the month due to NCS termination, participation in month 10 of NCS reduction should be credited towards meeting the 4-week participation requirement. WFPS/WFSSS must follow comprehensive evaluation and Pathway Development Tool (PDT) guidelines in WorkFirst Handbook 3.2.1 and every time a participant reapplies for benefits. 

After the comprehensive evaluation, any needed assessment, and Sanction Re-engagement interview is completed, the participant must be referred to other approved activities until the full 4 weeks (28 days) of participation is completed.

WorkFirst staff track when the four week participation requirement is met. TANF benefits start on the date the participant meets all other financial eligibility factors. What if the applicant stops participating?

When an applicant has stopped participating, deny the application if there wasn't a good reason for interrupting participation. The applicant can contact WorkFirst staff if they want a reconsideration of the denied application.

Good cause may be established if the participant is determined unable to perform the required WorkFirst activities or if significant barriers outside their control prevented participation as described under WAC 388-310-1600(3). Good cause that may be considered include:

  • An unmet need for Equal Access (EA) Accommodation Plan
  • Limited-English Proficiency (LEP) not addressed through interpreters or translations that result in the participant not understanding what is required
  • Emergent or severe medical condition (verified by a health care professional) of the participant or a family member in their care
  • Family Violence
  • Immediate legal concerns
  • Homelessness

Non-participation because of unexcused absences isn't considered a good cause unless there is a significant circumstance outside the participant's control (such as family violence or hospitalization). This circumstance must suggest a good reason why the applicant stopped participation.

If the WFPS/WFSSS determines good cause exists, the excused days will count towards the participant's cure period. For example, a participant stops participating on March 7th, which is the 6th day of the 28-day period. On March 12th, it is determined that good reason exists and the participant will start to participate again on March 15th. March 15th is now day 14 of participation of the 28-day period.

If the WFPS/WFSSS decides that no participation is required and the participant meets an exemption criteria, approve the application if otherwise determined financially eligible. How is the NCS reapplication approved?

When the applicant meets the participation requirement, remove the SA or SN code from eJAS and approve the application back to the date financial eligibility was met. What if a participant's reapplication is approved and they stop participating again?

Follow the  NCS process in section 3.5.1- Entering Non-Compliance Sanction (NCS); the participant has two months of NCS without reduction and ten months of NCS reduction to complete four consecutive weeks of participation or the case closes again for NCS. NCS Reapplication - Step-by-step guide

Applicants who closed due to the NCS Termination penalty must meet with WFPS/WFSSS to develop an IRP to complete a 4-week (28 days) WorkFirst participation requirement. Once the participant’s NCS reapplication is in pending status, they appear on the 'NCS Reapplicant report' on the Caseload Management Report. Only the participant who caused the NCS termination appear on the report.


  1. Determines if the participant is able to participate.
    1. If the participant can't participate, the WFPS pends the application for financial eligibility, or approves.
    2. If the participant reapplies before the NCS termination effective date and can't participate, lifts the NCS termination and reinstates the grant effective the first of the following month.
    3. If the participant can participate:
      1. Determines financial eligibility and confirms a WF Participation - TANF pending (85-06) letter has been provided
      2. Schedules/conducts an appointment
      3. Develops an IRP
      4. Approves needed supports
      5. Tracks participation in CLMR- NCS Reapplication report.
  2. Determines if there is good cause if the participant stops participating as required. If the participant:
    1. Is no longer able to participate, they will only need to meet financial eligibility criteria.
    2. Has good cause, they will pick up participation where it left off until the 28-day requirement is met.
    3. Doesn't have good cause, denies the NCS Reapplication.
Note: If the application is denied, review the case to see if the Basic Food Benefits should be penalized under the Basic Food Program rules for failure or refusal to comply with the Basic Food E&T requirements.​
  1. Removes the SA or SN code once all participation and financial eligibility criteria are met.

For further information about processing NCS reapplications or Basic Food Work Requirements see:


Related WorkFirst Handbook Sections

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