3.2.2 Initial Comprehensive Evaluation

Legal References:

Note: The DSHS Annual and Returner Updates will not be available until August 22, 2014.

The Comprehensive Evaluation section is divided into three separate sub-sections:

Section 3.2.1– Comprehensive Evaluation describes the purpose and content of the CE and continuous activity planning.
Section 3.2.2 – Initial Comprehensive Evaluation describes how to create and complete an active CE. This section includes:
- 3.2.2.1 What is an active comprehensive evaluation?
- 3.2.2.2 When do I create an initial comprehensive evaluation?
- 3.2.2.3 What are the three parts of the comprehensive evaluation?
- 3.2.2.4 When do I do Part 4 (sanction reengagement) of the comprehensive evaluation?
- 3.2.2.5 When do I complete the initial comprehensive evaluation in-person?
- 3.2.2.6 When do I complete the initial comprehensive evaluation by telephone?
- 3.2.2.7 How do I schedule an in-person initial comprehensive evaluation?
- 3.2.2.8 How do I complete Part 1 of the comprehensive evaluation?
- 3.2.2.9 How do I pend after Part 1 of the comprehensive evaluation?
- 3.2.2.10 How do I complete the rest (Parts 2 and 3) of the initial comprehensive evaluation?
- 3.2.2.11 What are the requirements for pregnant dependent minors?
- 3.2.2.12 How do I complete the chemical dependency/mental health screening?
- 3.2.2.13 How do I complete the housing stability section in Part 2 of the CE?
- 3.2.2.14 Initial Comprehensive Evaluation - Step-by Step Guide
Section 3.2.3– Comprehensive Evaluation Updates describes how DSHS and WorkFirst partners update recipients’ and returners’ CEs.

3.2.2.1 What is an active comprehensive evaluation?

Our goal is to do a thorough initial comprehensive evaluation (CE) up-front when we approve TANF and then build on it as we hear back from partners and providers who have been working with the family. Once we have created the initial CE, we use CE updates, instead of a new CE, to track the family’s progress.

The initial CE stays active, open and updateable until the parent has been off TANF for 12 months. See the WorkFirst Comprehensive Evaluation Client Flow Chart for additional details about how we create the initial CE and keep it updated.

The active CE is a living document that shows, in one place, what has been going on with the parent and his or her children through their TANF stay. Key features of the initial CE include:

Allows applicants to complete the initial CE in stages, starting by screening for emergencies and then moving to finding out about the family and employability.
Uses trigger and follow up questions, as well as scripts and prompts, to help guide the conversation. When you get a prompt, you can ask the question, put the question in your own words, or the parent may provide the information before you ask the question. Just make sure that you cover these elements and document any that pertain to the parent in the CE.
Uses in-person interviews and specialized questions to promote an open-ended conversation that gathers more information about the family and adds a focus on strengths and supports.
Creates a follow up list as you complete the initial CE to ensure we address issues that came up during the interview.
Uses specialized sanction reengagement questions to start a sanction cure for recipients and for NCS re-applicants.
Imports ACES data for some questions, including the parent’s children (including SSI children) and relative children who are included in the assistance unit. Staff will confirm with the parent that this information is accurate and can change the imported information before they save/finish that part of the CE when needed.
Provides ‘declined’ buttons to indicate when a parent doesn’t want to answer a question. Also provides a ‘N/A’ button for some questions to indicate when it doesn’t apply to a family member, such as the question about a child’s pregnancy or family planning needs. This question may not be appropriate when all of the parent’s children are under the age of 12.

3.2.2.2 When do I create an initial comprehensive evaluation?

You do the initial CE at application for parents who are approved or likely to be approved for TANF. This CE will stay active until the parent has been off TANF for 12 months.

You can also create an active CE under two other circumstances:

You will create an active CE when the parent doesn’t have an active CE in eJAS. This will happen as we transition parents from the former, to the new, CE.
You can close an active CE at any time by opening a new active CE. However, if you do this, you will need to complete an entire new CE (Parts 1 through 3). Another alternative would be to keep the CE active and update it.

3.2.2.3 What are the three parts of the comprehensive evaluation?

The CE Redesign breaks the CE into three parts, so that staff can stop during the initial CE to address a crisis or significant barrier when needed and then finish the rest of the questions after the situation is stabilized.

Part 1 screens for emergencies
Part 2 covers family issues
Part 3 covers education and employment

Whether the parent does one part, or all three parts of the CE, the CE interview ends with an IRP and referral. You will need to save/finish Part 1 before you can save/finish Part 2, and save/finish Part 2 before you can save/finish Part 3.

3.2.2.4 When do I do Part 4 (sanction reengagement) of the comprehensive evaluation?

When a parent wants to cure sanction, instead of doing a new CE, the parent will complete the sanction re-engagement questions in Part 4 of the CE. These questions focus on why they got into sanction and how they will participate successfully in the future.

You will also complete these Part 4 sanction reengagement questions during the initial CE for NCS re-applications. These re-applicants will need to do Parts 1-3 of the CE because they are an applicant and Part 4 to start their sanction cure. Please note that it is NOT necessary to ask NCS re-applicants the screening question at the end of Part 4.

You can save/finish Part 4 at any time.

3.2.2.5 When do I complete the initial comprehensive evaluation in-person?

You will create the initial CE for an approved, or likely to be approved, TANF family, including both parents in a two-parent family. Whenever possible, a WorkFirst Program Specialist (WFPS) does the TANF financial intake.

If the parent is in the office, a same day, in-person CE can be done by the WFPS who did the financial intake, by another WFPS or by a WorkFirst Social Services Specialist, as appropriate. After completing Part 1, the parent also has the option to schedule an in-person CE within 10 days of their financial intake to complete the rest of his or her CE with the WorkFirst worker of record.

When the parent does their financial intake by phone, staff will normally arrange for an in-person CE with the parent’s WorkFirst worker of record. This makes it easier to conduct the interview in a private setting where staff will get visual cues as to what is going on with the client. An in-person exchange also promotes relationship-building that may produce a more effective IRP. Depending on who did the telephone red intake, the process will vary:

A WFPS will do Part 1 of the CE over the phone so we are aware of any emergencies that require immediate attention. The WFPS will use an ACES General Appointment Letter (50-05) or eJAS appointment letter allowing 10-day notice to complete an in-person CE with the worker of record unless exceptions apply.
A Financial Services Specialist (FSS) won’t do Part 1 of the CE. The FSS will set a tickler @WPS for a CE.

Whether a WFPS or FSS does the telephone red intake, the WorkFirst worker of record will then do an in-person CE to review Part 1 and complete Part 2 (and possibly Part 3).

3.2.2.6 When do I complete the initial comprehensive evaluation by phone?

An in-person CE is required for an approved or likely to be approved, adult. The intention is to do the CE in-person, when possible, because it promotes engagement and you will get a better understanding of what is going on with the parent and how they are reacting to the questions.

A WFPS or WFSSS may decide to waive the in-person CE under some circumstances. When this occurs, they must document why the in-person CE (which may include parts 1, 2, and/or 3 depending on the adult’s circumstances) when they determine it is not possible for the adult to come into the office. When this occurs, they must document why the in-person CE was waived in the eJAS CE note type and then may complete the CE by phone.

The in-person CE can be waived when the adult:

Is working
Has health issues
Has another reason why, in your judgment, it isn’t possible to complete the interview in person. For example, it may not be possible to do an in-person interview when the adult is experiencing family violence or when the adult lives in a remote area and there is no public transportation.

It is also acceptable to complete a pended Part 3 by phone if the adult has completed Part 2 of the CE in-person. The goal is to have face-to-face contact, when possible, as you complete the three parts of the initial CE for an approved or likely to be approved applicant, to enhance relationship building, case management, engagement and communication.

3.2.2.7 How do I schedule an in-person initial comprehensive evaluation?

If you cannot complete an in-person, same day CE for an approved, or likely to be approved, TANF parent, you will need to schedule an in-person appointment. Mail an ACES Online 50-05, General Appointment Letter, or the eJAS appointment letter to the parent stating an in-person CE/IRP is required within 10 days using the following text:

Your household is receiving, or is likely to receive, cash from the Temporary Assistance for Needy Families (TANF) program. You are required to participate in the WorkFirst program when you receive TANF benefits. The WorkFirst program is designed to assist you in obtaining employment in order for you and your family to become self-sufficient.

I have scheduled the above appointment to meet with you in-person to complete a WorkFirst Comprehensive Evaluation and an Individual Responsibility Plan (otherwise known as an IRP).

We will discuss any issues that you or your family may have that would need to be taken into consideration when deciding your WorkFirst participation.
We will work together to create an IRP that best fits your needs and the goals of the WorkFirst Program.
The IRP will clearly outline the activities we agreed you will participate in to become self-sufficient.
We will also discuss any needed support services that will enable you to follow your IRP.

It is very important that you attend this in-person meeting to complete your WorkFirst Comprehensive Evaluation and develop your Individual Responsibility Plan. If you are unable to keep this appointment, you will need to contact me prior to the appointment to reschedule your appointment to avoid possible sanction penalties.

There are many participation options with WorkFirst. I look forward to working with you and helping you develop a plan to become self-sufficient!

For telephone intakes, you can find out what time and date works best for the parent. Otherwise, make sure to take into account how long it will take for the parent to receive the appointment letter in the mail. That way, they will have sufficient time to make arrangements to attend the appointment.

3.2.2.8 How do I complete Part 1 of the comprehensive evaluation?

Part 1 of the CE is designed to screen for emergencies that require our immediate attention. The parent may need to resolve his or her crisis situation before they can focus on some of the other issues raised in the rest of the CE.

We allow parents with an emergency to come in later to complete the rest of the CE so we are asking the right questions at the right time. It is important to ask all of the questions in Part 1 before you pend Part 2 to make sure we make a plan to address all of the parent’s emergent/urgent issues up front. The goal is to get a good understanding of the parent’s situation to make a solid plan to address their crisis situation.

When the parent answers ‘yes’ to a Part 1 question, we get more information (by asking some of the Part 2 questions) and then document the issue and action plan in Part 1 . The parent may answer ‘yes’ to more than one question in Part 1. If the parent wants to pend Part 2, develop an IRP to address all of the identified urgent/emergent issues within 30 days, save/finish Part 1 and use the P2 eJAS component code to pend Part 2 of the CE for up to 30 days. Once you save/finish part 1, you will be able to go to the DSHS final decision and record the 30-day issue resolution IRP.

When the parent answers ‘no’ to all Part 1 questions, or there are no urgent/emergent issues, or the parent wants to continue, save/finish Part 1 and go on to Part 2.

3.2.2.9 How do I pend after completing Part 1 of the comprehensive evaluation?

As discussed above, staff may pend the comprehensive evaluation after completing Part 1 when the parent:

Did their red intake by phone and needs to come into the office to do the rest of their CE in-person within 10 days. Use an AP IRP, ACES General Appointment Letter (50-05), or the eJAS appointment letter allowing 10-day notice to require the in-person appointment.
Did their red intake in person, but would prefer to do the rest of their CE within 10 days. This may happen when it is late in the day by the time they finish their intake or when they want to come in without their children. Use an AP IRP, ACES General Appointment Letter (50-05), or the eJAS appointment letter allowing 10 day notice to require the in-person appointment.
Indicates they have an emergency (by answering yes to at least one of the questions in Part 1) and would like to take up to 30 days to address their emergency before they resume their CE. Save/finish the DSHS final decision and develop an IRP to address the urgent/emergent issue with the appropriate eJAS component code and use the P2 eJAS component code to track when Part 2 is due.

You may want to set up the follow up CE appointment at the same time you pend the CE. In addition, the P2 eJAS component code will pop up on the CLMR when Part 2 of the CE is due.

3.2.2.10 How do I complete the rest (Parts 2 and 3) of the initial comprehensive evaluation?

Part 2 is designed to learn more about the family and longer-term issues that may need to be addressed (such as an exemption or long-term deferral) before the parent can move into employment. Part 3 covers the parent’s employment and education history and plans.

You can pend completion of Part 3 of the CE until the DSHS Annual Update (for up to 12 months) to address serious health or family issues. Save/finish Part 2, complete and save/finish the appropriate DSHS final decision, use an IRP to address the issue and the P3 eJAS component code to track when the parent is expected to come back into the office to complete the rest of the CE. When you pend after Part 2 of the CE, reminders will pop up on the CLMR when Part 3 of the CE is due.

If there are no serious issues, or if the parent wants to continue, save/finish Part 2 and go on to Part 3. Complete and save/finish Part 3, complete and save/finish the DSHS final decision and end with an IRP and referrals to activities or needed services.

Once you have completed all three parts of the CE, you will not need to complete these sections again while the CE remains active. You will keep the CE up to date by using WorkFirst partner and annual CE updates described in section WFHB 3.2.3, Comprehensive Evaluation Updates. You can also go into the CE at any time to update it and complete a new DSHS final decision as appropriate.

The CE will remain active until the parent has been off TANF for 12 months unless you decide to close the active CE by doing another full CE before then. If a parent exits TANF and returns within 12 months, you will do a returner CE, as described in section WFHB 3.2.3, to review and update the active CE.

3.2.2.11 What are the requirements for pregnant dependent minors?

Staff should follow the policy for mandatory reporting of suspected child abuse, neglect or child rape in the EAZ Manual, Child Abuse and Neglect Reporting when a parent reports a minor, pregnant dependent child in the Child Education and Health Section (Part 2 of the CE). Under the mandatory reporting policy:

Staff will offer a referral to First Steps for the pregnant minor.
Staff shouldn’t report child rape to law enforcement unless we know the age of the father; staff are not required to ask the age of the father.
If the parent volunteers that information, and we become aware that it meets the criteria of child rape, a law enforcement referral is required.
Once the child is born, more information about the age and identity of the father may become available as part of the child support enforcement process.

3.2.2.12 How do I complete the chemical dependency/mental health screening?

The chemical dependency/mental health screening in Part 2 is the Global Appraisal of Individual Needs – Short Screener (GAIN-SS tool). GAIN-SS is used by other state agencies to screen for chemical dependency/mental health issues and the tool was specifically designed for use by staff who are not experts in these areas. The GAIN-SS isn’t intended to be an in-depth assessment that explores the history or severity of these conditions. Rather, it helps staff determine when a follow-up assessment would be helpful or needed.

When you administer the GAIN-SS tool, please read the introductory script and questions verbatim and make sure the parent understands the questions. We should also be sensitive to the parents’ need for privacy and conduct interviews behind closed doors whenever possible. Ask the questions as neutrally as possible in order to get the most honest responses. When the parent indicates they have been thinking about ending their life, an immediate intervention, such as a referral to a crisis line, is required.

You can refer the parent for a social services assessment if there are indications of possible chemical dependency or mental health issues, even when the parent answers no to all of the questions or declines to answer the questions. You can make referrals based on a parent’s behavioral responses to the questions or behavior overall. The parent’s yes or no responses to the questions are not intended to override your judgment or experience on when a social services referral would be helpful.

Also, it isn’t necessary to refer for a chemical dependency or mental health assessment if the parent is already in treatment, but you should consider making a social services specialist referral so they can explore the situation with the parent and get additional information that may help us develop a more effective IRP.

3.2.2.13 How do I complete the housing stability section in Part 2 of the comprehensive evaluation?

The housing stability section in Part 2 of the CE includes three questions to guide staff in making referrals to housing resources. Staff answer yes or no to all three questions. A yes response to either of the first two questions indicates that the parent is homeless or about to become homeless and meets the criteria for a referral. A yes response to the third question will ensure that a housing referral appears on the CE follow up list.

3.2.2.14 Initial Comprehensive Evaluation - Step-by Step Guide

The WFPS (or FSS when no WFPS is available) completes the red intake, followed by an in-person CE for approved or likely to be approved TANF applicants.
1. A WFPS/WFSSS completes the CE when the parent is in the office. Alternatively, the WFPS/WFSSS can use ACES General Appointment Letter (50-05) or the eJAS appointment letter to schedule an in-person CE appointment allowing 10-day notice.
2. For telephone red intakes (or for the second parent in a two parent family who is not in the office):
  1. The WFPS:
    1. Conducts a telephone CE if the parent is working, has health issues or it is not possible to do an in-person CE for another reason and documents the reason in eJAS CE case notes.
    2. If an in-person CE is required, conducts Part 1 of the CE via telephone to screen for emergencies.
    3. Schedules an in-person CE allowing 10-day notice with the worker of record to review Part 1 and do the rest of the CE, ACES General Appointment Letter (50-05), or the eJAS appointment letter.
  2. The FSS sets a tickler @WPS for a CE without completing Part 1 of the CE.
The WFPS/WFSSS completes the CE as follows:
1. Asks each question in Part 1 to screen for urgent/emergent issues.
  1. If there are urgent/emergent issues:
    1. Gathers more information by asking related questions in Part 2 and documents issue and plan in Part 1; and
    2. Can pend completion of Part 2 for up to 30 days while the parent addresses and urgent/emergent issue using an IRP to address the issue and the P2 eJAS component code to track when Part 2 is due;
    3. Saves/finishes Part 1. Once you save/finish Part 1 you will be able to complete and save/finish the DSHS final decision for the issue resolution IRP.
  2. If there are no urgent/emergent issues, or at the parent’s request, saves/finishes Part 1 and goes on to Part 2
2. Asks each question in Part 2 to learn more about the family and longer-term issues that may need to be addressed (such as an exemption or long-term deferral) before the parent can move into employment.
  1. If there are significant issues:
    1. Can pend completion of Part 3 until the DSHS Annual Update (for up to 12 months) completing and save/finishing the DSHS final decision and using an IRP to address the significant issue and the P3 eJAS component code to track when Part 3 is due; and
    2. Completes required actions on the follow-up list; and
    3. Saves/finishes Part 2.
  2. If there are no significant issues, or at the parent’s request, saves/finishes Part 2 and goes on to Part 3.
3. Completes and save/finishes Part 3 to identify employment and education history and plans, completes required actions on the follow-up list, completes and save/finishes the DSHS final decision and completes an IRP.
4. For NCS re-applicants, completes and save/finishes Part 4 and the DSHS final decision to start the sanction cure.
Uses the process in WFHB 3.2.3, Comprehensive Evaluation Updates, to keep the information in the active CE current.
The WFPS completes the full CE per above when the parent has no active CE in eJAS. They may also close an active CE and complete a new full CE as needed.

Economic Services Administration