1.2 Required Participation

Created on: 
Oct 18 2017

Revised October 19, 2017

Legal References:

The Required Participation section includes:

  • 1.2.1 What is participation and how does it count?
  • 1.2.2 What are the WorkFirst participation requirements?
  • 1.2.3 What are the participation requirements for two-parent households?
  • 1.2.4 What is the participation requirement for single parents with a child under six?
  • 1.2.5 How do we determine the best employment pathway?
  • 1.2.6 When can someone participate in various WorkFirst activities?
  • 1.2.7 What does participation look like for families in crisis situations?
  • 1.2.8 What are contracted services?
  • 1.2.9 What if someone isn't exempt but can't participate in regular employment activities?
  • 1.2.10 What are the WorkFirst requirements for dependent teens and pregnant or parenting minors?
  • 1.2.11 Home schooling
  • 1.2.12 eJAS/ACES Codes
  • 1.2.13 Participation step-by-step guide

1.2.1 What is participation and how does it count?

Most participants are required to participate in work or work-related activities full-time, which is defined as "getting as close as possible to 40 hours per week," with a goal of at least 32 hours a week.  In order to develop a full-time Individual Responsibility Plan (IRP) we count the actual hours involved in an activity.  When working with the participant to develop the IRP, it is very important that we make every effort to reach 40 hours of activities per week.

Work with the participants who aren't in full-time (32-40 hours) activity(ies) to ensure that every hour of activity is properly recorded in the IRP, as close to 40 hours a week as possible, with a minimum of 32 hours.  See the 3.3, Individual Responsibility Plan, section for more information on Individual Responsibility Plans.

Federal rules reduce funding for states that fail to meet a federal work participation rate.  To meet the rate, states must have a percentage of participants in the required number of hours of countable activities each month.  The percentage is higher for two parent families.

To be a two-parent family, neither parent 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).

Federal rules define activities as "core" or "non-core".  As shown on the Core & Non-core Activity chart, some core activities only count for a limited amount of time.  This chapter outlines Washington’s WorkFirst participation requirements; however, a WorkFirst participant may be fully participating in WorkFirst activities and still not meet the federal work participation rate.

1.2.2 What are the WorkFirst participation requirements?

The chart below shows WorkFirst (WF) requirements for parents/caregivers who are able to participate and includes strengthened participation requirements. Most parents/caregivers  are still required to participate 32-40 hours per week with at least 20 of those hours in core activities.  Even though the participant has these requirements, it is also important to meet them where they are and engage them in WorkFirst activities that count and move them forward to self-sufficiency. 

Most participants must meet the requirements in row 1.  WorkFirst doesn't require the following to participate in core activities (rows 4 through 6 below):

  • One parent in a two-parent family when s/he meets the conditions in WFHB 1.2.3
  • Exempt participants in the Pregnancy to Employment Infant Exemption or Infant Exemption Extension (See WFHB 5.1.11)
  • Teen head of households (age 18 or 19 years of age) who don’t have a High School Diploma or GED
  • Minor parents who do not have a child under 12 weeks old

Strengthened participation is an additional three hours (preferably core activity hours) in the participant’s IRP to assist them in meeting the federal participation rate when participants may have unexcused absences or too many excused absences.

The strengthened participation requirements are shown in the chart below.

Who Core Activity Requirements  Core/Non-Core Activity Requirements   WF Participation Requirements   Strengthened Participation Requirements  
1.  Each participant    20 hrs/wk 12-20 hrs/wk 32-40 hrs/wk

35 hrs/wk (at least 20 hrs core)

2.  Recipient parents in a two-parent household who qualify for the two-parent options (see 1.2.3) 30 hr/wk 5 hrs/wk 35 hrs/wk

38 hrs/wk (at least 30 hrs core)

3.  Single parent/caregiver with a child under 6 20 hrs/wk None (additional hours are voluntary) 20 hrs/wk 23 hrs/wk (at least 20 hrs core)
4.  Participants claiming the  Infant Exemption or Infant Exemption Extension None None None (exempt) None
5. Teen head of households (age 18 or 19 years of age) that don’t have a High School Diploma or GED None

Participate in HS as per school requirements to progress towards graduation

Based on school requirement but can be a minimum of 1 hr/wk None

6. Unmarried pregnant or parenting minors  (age 17 and younger); except between infant’s birth and turning 12 weeks old

None Participate in HS as per school requirements to progress towards graduation Based on school requirement but can be a minimum of 1 hr/wk None

 

The following activities in most cases meet strengthened participation without adding additional hours (add additional hours when necessary):

  • Community Jobs and Career Jump
  • Work Study students as long as they meet the requirements in WFHB 8.1.10
  • Vocational Education

The following are important to remember when including strengthened participation in a participant’s IRP: 

  • A 38-hour per week full time job search is available when only one parent in a two-parent family is participating under the two-parent option.
  • Don’t exceed the FLSA maximum hours for Community Service or Community Works.  You can substitute non-core hours for core hours as needed to stay within the FLSA maximum.  See WFHB 3.3.2.5 for more information about deeming rules and the FLSA maximum.
  • 20 hours of unsubsidized employment (or 30 hours for a two-parent family) meets the core activity requirement.  For two-parent families or single parents with no children under six in this situation, consider adding non-core activities to meet the strengthened participation requirements.

Examples:

1.  Nancy is a single parent with no children under six in a full-time vocational education (VE) program.  The college she is attending has a 35 hour per week vocational education program in her field of study.  Her education plan shows 35 hrs/week in a VE.  She meets the 35 hrs/week strengthened participation requirements for a parent/caregiver. 

2.  Mary is a single parent with no children under six pursuing a specialized certificate program taking 15 credits including 15 hrs/week homework and 2 hrs/week lab time.  Her education plan shows VE 32 hours per week.  This is acceptable even though it doesn't meet the minimum 35 hrs/week strengthened participation requirement because adding hours in her case isn't possible.

3. Sharon is a single parent with ten-year-old child.  She works 5 hrs/week at an unsubsidized job and participates 12 hrs/week in a high school equivalency program.  Sharon agrees to participate in 18 hrs/week of job search to meet the strengthened participation core requirement of 23 hours per week. Her 5 PT, 18 JS, and 12 GE meet the 35 hrs/week strengthened participation requirements. 

a. Update:  Sharon loses her job and completes her high school equivalency.  Her WFPS increases her to 35 hrs/week full-time job search.  She meets the 35 hrs/week strengthened participation requirements for a parent/caregiver. 

b. Update: The father of Sharon’s child, Mark, returns to the home and they qualify for the two-parent participation options. Sharon and Mark decide that Sharon will continue participating and Mark will opt out of participation.  Her WFPS increases job search to 38 hrs/week.  Sharon and Mark meet the 38 hrs/week strengthened participation requirements for a two-parent household.

4.  Tom is a single parent raising a teen-age son participating in Community Works with a 25 hrs/week FLSA maximum.  His WFPS schedules him for 25 hrs/week Community Works and 10 hrs/week high school equivalency for a total of 35 hours per week participation.  Tom meets the 35 hrs/week strengthened participation requirements for a parent/caregiver.

a. Update:  Tom's FLSA maximum is 16 hrs/week.  Under deeming, this will meet his 20 hours of core activity, but we can't require any additional hours of Community Works.  Tom continues to participate in high school equivalency classes for 10 hours per week. To help Tom reach strengthened participation, Tom agrees to participate 3 hours/week in a Life Skills activity.  His 16 WC, 3 LS, and 10 GE meet the 35 hrs/week strengthened participation requirement.  

b. Update:  Tom’s FLSA maximum is still 16 hrs/week, but there is no Life Skills class or other core activity available that can be added to Community Works to bring his core activity up to 23 hours per week (16 hrs/week deems to 20 hrs/week). He has been doing 10 hrs/week of high school equivalency at the local community college.  College staff agreed to provide an additional 5 hrs/week by enrolling Tom in a study hall to meet the 35 hours/week strengthened participation requirements.

1.2.3 What are the participation requirements for two-parent households?

The participation standard for two-parent households is full-time (32-40 hours per week) for each parent.  However, under some circumstances, we can allow a household to choose a two-parent option.

Two-parent options are available to two-parent families who are:

  • In compliance with WorkFirst,
  • Appropriate for the option, and
  • Electing to choose that option after a discussion that includes both parents and the WFPS/WFSSS.  

Use these options when appropriate to assist two-parent families towards family stability and self-sufficiency.

In order to utilize the two-parent options, a conversation must occur with the family to determine whether this option is appropriate for their household and to determine if one parent may opt out of participation.  The conversation must focus on the whole family to determine the best participation option for the family to reach self-sufficiency. 

The two-parent options are only available when both parents are in full compliance with WorkFirst requirements.  Any time one or both of the parents utilizing the two-parent option falls out of compliance, the household will return to the full time participation standard for each individual.

Option One: Recipient two-parent families may choose to have one parent opt out of participation requirements to stay home and care for the children as long as:

  • Both parents are participating satisfactorily, meaning they have completed their Comprehensive Evaluation and any assessments needed.  If one or both parents are in WorkFirst sanction, the sanction(s) must be cured before the household can be offered the 2-parent participation option;
  • The parent opting to stay home is capable of caring for the child(ren);
  • The other parent agrees to  participate 35 hours per week (30 hours core and 5 hours core or non-core); and
  • Both parents engage in any needed chemical dependency or mental health treatment. 

If the WFPS or WFSSS and the TANF family determine that this option is appropriate, use the participating parent’s time spent in treatment to help meet the family’s work participation requirements.  If the participating parent stops participating as required without good cause, pursue sanction and send an appointment letter to the parent who was opting to stay home scheduling him or her for an appointment to develop an IRP.

Note: If there is a child under two years old and no mandatory participation is required, one parent can opt out of participation instead of using their infant exemption or infant exemption extension (IE or TE).  Parents must complete all requirements found in section 5.1 before considering the opt-out option.  This family would still be subject to all of the requirements under option one.

Option Two: Recipient two-parent families may choose to have both parents split participation requirements, as long as:

  • Both parents are participating satisfactorily, meaning they have completed their Comprehensive Evaluation and any assessments needed.  If one or both parents are in WorkFirst sanction, the sanction(s) must be cured before the household can be offered the 2-parent participation option;
  • They meet the core requirement of 30 hours per week, in addition to at least 5 hours of core or non-core; and
  • Both parents engage in any needed chemical dependency or mental health.

 

Note: If there is a child under two years old and no mandatory participation is required, neither parent would need to use the Infant Exemption or Infant Exemption Extension.  Parents must complete all requirements found in section 5.1 before considering the split participation option.  The family would still be subject to all of the requirements under option two above.

If one parent ceases to participate without good cause, pursue sanction and send an appointment letter to the other parent to come in for an appointment to build a full time IRP.

Examples:

Julie and Tom have two children ages 3 years old and 8 months old.  Julie and Tom choose full participation for Tom and Julie will stay home with the children.  Tom agrees to JS 35 hours per week.  This family meets participation requirements for a two-parent household. Even though they have a child that meets the IE criteria, Julie shouldn’t use IE months because Tom is fulfilling the two-parent participation requirement.  
Pam and Shawn have a 5-year-old child.  Pam and Shawn choose full participation for Shawn and Pam will stay home with the child.  Shawn agrees to CJ 20 hours per week and JT 15 hours per week.  This doesn’t meet the participation requirements for a two-parent household, as Shawn doesn’t have 30 hours of core activity participation.  Pam agrees to participate in Community Works (WC) 10 hours per week.  They now meet the participation requirements for a two-parent household.    

1.2.4 What is the participation requirement for single parents/caregivers with a child under 6?

For single parents/caregivers with a child under the age of six, the participation requirement is 20 hours per week in a core activity.  Parents/caregivers must participate satisfactorily and cure a sanction to avoid Non-Compliance Sanction termination. 

Parents/caregivers may voluntarily participate for more than 20 hours per week.  Parents/caregivers who wish to participate in Vocational Education activities must participate full time. 

1.2.5 How do we determine the best employment pathway?

Everyone has skills and abilities needed in today's workforce.  Weaving those skills and abilities with labor market realities and education levels is the cornerstone of the CE.  Its design is to help achieve better and quicker engagement in employment-related activities.

The CE is a key tool in leading participants directly to employment and job search continues to be the most appropriate pathway for the majority of participants.  For other participants, the CE will lead to employment through activities like education, Community Jobs or Career Jump.

The WorkFirst Program Specialist (WFPS) refers the participant to the appropriate employment pathway identified by the CE using the appropriate code(s).  The pathways include:

  • Job Search
  • Education & Training Activity
  • Unsubsidized Employment
  • LEP Pathway
  • Issue Resolution
  • Exempt
  • 3rd trimester of pregnancy Deferral
  • Infant Exemption

See section 3.2 and the "Comprehensive Evaluation Referral Criteria" document in the Resources section below for pathway details.

The information gained from the CE will also be available to the WorkFirst partners and the participant to ensure they engage in the employment pathway that will move them most effectively toward self-sufficiency.

If there is an indication or the participant discloses involvement with Children's Administration (CA) and/or the Department of Corrections (DOC) at any time, we must work collaboratively to address the needs of the family. 

Participants involved with CA and/or DOC may be required to do activities like counseling or treatment to help keep their families together.  It's critical to consider and include these activities, as appropriate, when developing the participant’s IRP.  We want to make sure that WorkFirst requirements don't interfere with the activities needed to comply with CA and/or DOC requirements and resolve their family issues and emergencies.

Participation Example #1 
After a newly approved WorkFirst participant completes the CE, s/he will start with full-time employment services (35 hrs/week) as their first activity. Employment Security staff define and direct full-time and part-time employment service activities and attendance. See 4.2 Job Preparation/Work Search section for more information on job search.
Participation Example #2
The WorkFirst participant is working 25 hrs/week at a local restaurant and is also in an approved educational component for 10 hrs/week.  Record the actual number of hours for each activity in the IRP and input the number of hours for each component on the component screen in eJAS, for a total of 35 hrs/week participation.
Participation Example #3
The WorkFirst parent is able to participate full time but is involved in the Department of Corrections (DOC) Community Parenting Alternative (CPA) programmer the Family & Offender Sentencing Alternative (FOSA) program.  The parent/caregiver is subject to electronic home monitoring and only allowed to leave the home to participate in required DOC activities, which include substance abuse treatment, parenting classes, and other activities agreed upon by the DOC Community Corrections Officer (CCO) and the WFPS/WFSSS. These could include, but are not limited to community jobs, education, and job search. The WFPS/WFSSS verifies these activities with the DOC Community Corrections Officer, records the actual number of hours for each activity in the IRP, and inputs the number of hours for each component on the component screen in eJAS.

1.2.6 When can someone participate in the various WorkFirst activities?

Unless the CE indicates otherwise, employment services are the first activity for almost everyone.  The CE is the key tool in leading participants to employment through job search, education, or other employment pathway activities like Community Jobs, Career Jump or Community Works approved by the WorkFirst Program Specialist (WFPS) or WorkFirst Social Service Specialist (WFSSS).

For participants who aren't successful in job related activities, it is important to determine what factors may be contributing to the lack of success.  The participant may have an undisclosed disability or deficit and you can't provide assistance without knowing what obstacles he or she is facing.  Inform the participant that you want to see him or her succeed and that support services are available for people needing special consideration.  Ask whether circumstances have changed and/or has the participant disclosed all information that may be affecting her/his success.

1.2.7 What does participation look like for families in crisis situations?

The WFPS considers and takes action for those participants in crisis/issue resolution situations that will count as full-time participation.  The WFPS can develop an IRP with the participant that specifically addresses the crisis issues.  When necessary, consult with expert personnel for assistance, including Social Service Specialists (SSS), tribal representatives, family violence specialists, and other WFPS or supervisors.  This should be done when assistance and expertise is needed to develop specific steps the person should take to mitigate her/his circumstances.

Living or working in an area impacted by a declared disaster may  affect a parent/caregivers’ ability to participate in WorkFirst activities.  Please see the Disaster Impact (DI) step by step for more information.

Both state and federal rules recognize that not all parents/caregivers are able to participate all the time. It is important that we stabilize families, resolve issues and provide participants with exemptions when that is the best plan for the family.

Deferrals and exemptions won’t necessarily make it harder to meet the federal rate.  As shown on the WorkFirst Stacking Strategy chart, some exempt participants qualify for federal exemptions, and participants in countable "X" codes may be able to add enough hours to meet federal participation requirements.

The WFPS directs a participant to the SSS after the CE via the Issue Resolution pathway for assessment and services when s/he has an urgent issue.  The SSS addresses the immediate need, determines appropriate participation activities, and outlines these activities in the IRP.

Be sure that the participant understands how and when to report progress or lack of progress in completing the steps outlined in the IRP.  The parent/caregiver meets required participation with completion of the activities outlined in the IRP until the SSS determines the issue is resolved or adds other activities to the IRP.

1.2.8 What are contracted services?

Refer participants to contractors to receive specific services and may include community or faith-based organizations, for profit providers, and others.  Contractors provide services that aren’t otherwise available through the partner agencies.  They address barriers or issues   to support  individuals in finding and keeping employment.  Notify contractors of any necessary accommodations.

WorkFirst has established strong certification standards for contractors and service providers.  Contractors and service provides must meet the standards to obtain WorkFirst certification, which occurs during the contracting process.  Contractors must meet the standards for reporting to the WFPS or WFSSS by providing monthly verification reports.  Contractors must report non-participation immediately.

1.2.9 What if someone isn't exempt but can't participate in regular employment service activities?

Division of Vocational Rehabilitation (DVR)

Some participants may need specialized services to participate and progress to self-sufficiency. For example, a person with a physical impairment that doesn’t  exempt them from participation, might best participate with Division of Vocational Rehabilitation (DVR) who can provide specific vocational services. Coordinate with the DVR counselor or other professionals when the participant is on a waiting list for services such as alcohol treatment or mental health counseling. In some cases, all a participant may do is complete necessary applications and prepare for another program, such as DVR or SSI. Through consultation with WorkFirst Social Service Specialists (WFSSS) and other professionals, determine the appropriate activities and level of participation while the participant is waiting for services such as chemical dependency treatment, parenting classes, counseling, adult education, and/or money management education. Participants who need DVR services may be able to work part-time in an entry-level job while waiting for the services that will help them obtain career employment.

Children’s Administration (CA)

Some participants working with Children’s Administration (CA) may not be able to participate in employment service activities while being required to attend court appointments, counseling or treatment. If at any time, there is an indication or the participant discloses involvement with CA at any time, it is critical to consider these activities when developing the participant's IRP.

Department of Corrections (DOC)

Some participants working with DOC in a sentencing alternative program may not initially be able to participate in employment service activities. An offender who is accepted into the “Family & Offender Sentencing Alternative (FOSA)” program will be under community custody supervision and those in the DOC “Community Parenting Alternative (CPA)” program will be subject to electronic home monitoring. Offenders in either program will report to a specialized DOC Community Corrections Officer (CCO) and can only leave the home to participate in required activities such as mental health or chemical dependency treatment, parenting classes, work, vocational education, life skills, or other similar productive activities that DOC allows. However, as the offender progresses through the phases of the program, additional activities may be included with approval from the CCO, such as community jobs, community service, or job search.

It is critical to collaborate and coordinate with DOC and consider these activities when developing the participants’ IRP. Please contact Jennie Fitzpatrick at fitzpjr@dshs.wa.gov or 360-725-4648 or Tom Berry at berrytj@dshs.wa.gov or 360-725-4617 if you have any questions.

1.2.10 What are the WorkFirst requirements for dependent teens and pregnant or parenting minors?

Dependent teens that are on an adult's WorkFirst cash assistance grant aren’t required to do an IRP or verify school attendance.

The following chart summarizes the CE, IRP, participation, and verification requirements for dependent teens/pregnant or parenting minors and teen head of households:

Age Dependent Teen Teen Head of Household
Federal Reporting Not included in the work participation rate. Included in the work participation rate.
17 and younger Parent’s responsibility to ensure the child is in school. No IRP required.

Participate in High School Completion or Equivalency courses as per school requirements to progress towards graduation is required unless parenting a child under the age of 12 weeks.

  • CE required
  • IRP required
  • Must verify actual hours of high school attendance monthly
18-19

Parent's responsibility to ensure the child is in school. No IRP required.

Note:  This category may include 20-year-old dependents receiving SFA.

Participate in High School Completion or Equivalency courses as per school requirements to progress towards graduation is required unless parenting a child under the age of 12 weeks.

  • CE required
  • IRP required
  • Must verify actual hours of high school attendance monthly

Note:  These participants may be eligible for the Infant Exemption or Infant Exemption Extension.

Upon Graduation N/A Same as adult parent/needy care relatives:
  • CE required
  • IRP required
  • Participate in required core and non-core activities as described in the participation requirements table in 1.2.2

There are no WorkFirst requirements for dependent teens that are in an adult's WorkFirst cash assistance grant. It is the participant's responsibility to ensure the child is in school. However, a Children’s Administration (CA) referral may be appropriate if a dependent teen isn’t in school.

Some pregnant or parenting minors must go to school and be in an approved living arrangement as a condition of TANF/SFA eligibility. See these sections of the EAZ Manual for more information:

1.2.11 Home Schooling

Unmarried pregnant or parenting minors and teen head of household families that are home schooled can meet the WorkFirst participation requirement for schooling upon approval by the household's local school district and meets the state law requirements. See RCW 28A.200 for more information.

When non-assistance unit caregiver reports they are providing, or intend to provide home-based instruction, they must submit a signed statement to the school district declaring their intent to home school. This is a yearly requirement. Once the participant files the document and provides a copy to the WFPS, then the home schooling can be added to the IRP.

Home schooling is WorkFirst participation for the minor parent or teen head of household only. A parent/caregiver providing the home schooling can’t satisfy WorkFirst participation requirements by providing the instruction.

1.2.12 eJAS/ACES codes

  • RO (referred to social service specialist)
  • HS (High School completion or High School equivalency for participants 19 years of age or younger)
  • BE (High School completion, including High School 21, for participants 20 years of age or older)
  • GE (High School equivalency for participants 20 years of age and older)

1.2.13 Participation - Step-by-Step Guide

Refer to the IRP section for a step-by-step guide to regular participation.  For all others, the WFPS or WFSSS looks at the age of all assistance unit members to determine participation.

 

Resources

Related WorkFirst Handbook Sections

Other Resources