8.1 Overview

Revised December 19, 2019

Legal References:

The Paid & Unpaid Employment - Overview section includes:

  • 8.1.1 What is employment?
  • 8.1.2 Where do hours of employment come from?
  • 8.1.3 Why are employment services important?
  • 8.1.4 How do I verify employment for job starts?
  • 8.1.5 What is acceptable verification of employment hours?
  • 8.1.6 How do we record hours for temporary employment?
  • 8.1.7 When must a participant take a job?
  • 8.1.8 What are employment principles?
  • 8.1.9 Will any job do?
  • 8.1.10 How do work-study hours count?
  • 8.1.11 What is AmeriCorps/VISTA employment?
  • 8.1.12 What is WIA paid work experience?
  • 8.1.13 Verifying job starts - Step-by-step guide

8.1.1 What is employment?

Employment, or work, means to engage in any legal, income generating activity which is taxable under the United States Tax Code or which would be taxable with or without a treaty between an Indian Nation and the United States. Work provides the best opportunity for families to raise their income and leave poverty.

Helping participants find permanent, unsubsidized employment to allow them to support their families - is the goal of the WorkFirst program as defined in WAC 388-310-0200.

8.1.2 Where do hours of employment come from?

Employment can be part-time (31 hours per week or less) or full-time (32 hours per week or more). It comes in a variety of forms, including:

  • A paid, unsubsidized job,
  • Subsidized employment (Community Jobs),
  • On-the-job training (that combines training with a job)
  • Self-employment,
  • College work study, and
  • Paid work experience, practicums or internships.

When a participant has 20 hours of unsubsidized employment (or 30 hours for a two-parent family) this will meet the core activity requirement.   For two-parent families or single parents with no children under six in this situation, consider adding core or non-core activities to meet the strengthened participation requirements. See WFHB 1.2.2 for additional information about stacking an additional three hours (preferably core activity hours) in the participant's IRP when possible.

Unlike every other type of countable WorkFirst activity, employment hours are counted and verified using the TANF prospective budgeting rules. This means we don't need to record actual hours of employment each month. We do, however, need to make sure we follow financial eligibility rules to:

  • Estimate the number of hours. For example, if a participant gets paid a twice a month and works 40 hours per week at $13.50 per hour, the calculation would be = $540 per week x 52 weeks per year = $28,080 ÷ 24 pay periods = $1,170 ÷ $13.50 = 86.66 hrs per pay period, rounded up to 87 hours. Staff would enter 87 hours per pay period into ACES 3G.
  • Verify employment when required. (See the Employment Hours Action Chart for additional details.) Employment hours must be verified:
    • At application.
    • When hours decrease causing an increase in benefits.
    • At the participant's TANF 6-month report.
    • When a participant gets a job. (Note: we don't need to verify other changes in an existing job during the certification period and except for the MCR.)

Staff request wage and hour verification during the normal course of business on all of these occasions, except for some job starts. See section 8.1.4 for the procedures we will use to verify employment hours when a participant starts a job. Rules for financial eligibility budgeting can be found in the EAZ Manual at WAC 388-450-0050.

Employment hours and income must be correctly entered onto the ACES 3G Earned Income Screen by WorkFirst or financial eligibility staff. Once employment hour data for the ongoing month is entered into ACES 3G:

  • The ACES 3G data will be used to report the participant's employment participation, including the Work Participation Rate (WPR), to the federal government.
  • ACES 3G calculates the average weekly hours of employment and display in eJAS so every WorkFirst partner knows how many employment hours we are reporting to the federal government.

8.1.3 Why are employment services important?

We use Career Scope services activities to connect participants to the labor market. We provide avenues for participants to move toward economic stability as soon as possible. The initial job, however, may be entry-level, temporary or part-time. This means it is important to connect participants with post-employment services options (reserved for those working 20 hours per week or more) to find or train for better jobs.

8.1.4 How do I verify employment for job starts?

There is one circumstance when we don't use TANF prospective budgeting rules. We need to verify employment hours for job starts before we can count them towards participation. Since TANF prospective budgeting rules do not require verification when a participant gets a job, WorkFirst staff will be responsible to verify employment hours for job starts.

Once a participant starts a new job, financial staff record wage and hour information, often based on the participant's statement, into ACES 3G. If the participant remains eligible for cash assistance WorkFirst staff will learn about changes in employment hours, including the start of a new job, via their Caseload Management Report Section #7 “Clients Where Employment Hours Have Changed”. Once WorkFirst staff learn of the change, we contact the participant to update their IRP.

As you change the IRP:

  • Determine if the participant has started a new job.
  • If so, check to see if the verification valid value on the ACES 3G Earned Income screen is CS or CE (Meaning staff used a client statement which is not federally countable); If yes:
    • Request verification of the participant's employment hours.
    • Start the sanction process if the participant refuses to bring in proof of employment hours.

Once we have verified the employment hours, the hours need to be entered into ACES 3G. Financial eligibility staff entering the employment hours into ACES 3G will adjust wages and hours, as needed, and update the verification valid value on the ACES 3G  Earned Income Screen to affect the ongoing benefit month.

To record  the historical employment hours, after employment is verified and the ongoing month is updated, the worker will go back into a minimum of 2 historical months (unless the employment start date was less than 2 months ago). The worker will update the historical ACES 3G Earned Income screens using:

  • The same budgeting method as the ongoing month
  • The same number of hours entered in the ongoing month
  • Income of $0.01 - Do not enter actual income for the historical months - it is critical that you must enter $0.01 to minimize overpayments. Ignore (IG) any BEGs created by entering historical information.
  • Appropriate valid value (ES, WS, CC or OT)

It is important to remember that historical hours can only be entered once verification of employment hours is received.

This process will allow the employment hours to count for WorkFirst participation in the historical months.

8.1.5 What is acceptable verification of employment hours?

Any source, including verbal, written, and email statements, can be used to verify employment hours as long as it meets the rules for evaluating verification in WAC 388-490-0005, which requires verification to:

  • Clearly relate to what the participant is trying to prove.
  • Be from a reliable source.
  • Be accurate, complete and consistent.

The Acceptable Forms of Verification Chart in the EAZ Manual has a suggested list of reliable sources of verification for income. We normally use a wage stub to verify employment. You can also use a written or verbal employer statement.

When you use a verbal employer statement, you must document in eJAS the participant's employment hour information, as well as the contact's name, title, phone number and the date of contact.

8.1.6 How do we record hours for temporary employment?

Temporary employment is a paid, unsubsidized job lasting 30 days or less. Examples include temporary employment agencies (such as Manpower, Labor Ready, etc) and casual labor (such as odd jobs for landlord, friends and relatives) or other employers offering temporary employment.

Temporary employment can be part-time (31 hours or less per week) or full-time (32 hours per week or more). In either case, there is an estimated employment end date of 30 days or less and the employer does not consider the participant a permanent full-time or part-time employee.

ESD releases participants from job search to engage in temporary employment. In the past these have been counted as excused absences. However, as long as we verify and document the temporary employment hours, we can count them as employment and use them to help the participant meet the work participation rate. Temporary employment hours for federal participation are recorded from the verified employment hours entered onto the ACES 3G Earned Income screen.

At the beginning of each month, the Employment Security Department (ESD) will send to DMS Temporary Employment Tracking Logs listing the verified temporary employment hours for each participant who reported temporary employment for the previous month.

DSHS staff will enter these verified temporary employment hours on the ACES 3G Earned Income screen for the historical month in which the employment occurred using the historical entry of hours method. Only enter income of $0.01 when entering historical employment hours and ignore any BEGs created by entering historical information.

For more information on the historical entry of employment hours, please refer to section 8.1.4.

For more information on ESD's temporary employment process, please refer to WFHB section 4.1.8 What is Temporary Employment and how is it recorded?

8.1.7 When must a participant take a job?

As shown in the chart below, these are some of the legal conditions under which a job is not appropriate, depending on whether the job is paid, unpaid, and/or subsidized.

A participant cannot be required to accept a job which ...
Is paid or unpaid and
  • Does not meet federal, state or tribal health and safety standards.
  • Is available because of a labor dispute.
  • Does not provide industrial insurance coverage (unless working for tribal government/ for-profit business).
  • Working hours/conditions interfere with religious beliefs/practices (and no reasonable accommodation made).
  • Unreasonable work demands or conditions (like not paid on schedule).
  • Displaces currently employed workers (results in another employee's job loss, reduced wages, reduced hours of employment or overtime or lost employment benefits).
Is paid and

Same as above, plus:

  • Pays less than the federal, state, local, or tribe minimum wage, whichever is higher.
  • Requires them to resign or refrain from joining a legitimate labor organization.
  • Does not provide unemployment compensation, unless they are:
    • Working for a tribal government or tribal for-profit business; or,
    • Treaty fishing rights related workers exempt under section 7873 of the Internal Revenue code.
  • Does not provide benefits equal to those provided to other workers employed in similar jobs.
Is On the Job Training (OJT) or subsidized and
  • The employer becomes involved in a strike, lockout or bona fide labor dispute.
  • The participant is used to displace another employee (and we stop paying the subsidy).

8.1.8 What are employment principles?

Whenever we think about WorkFirst, we need to keep the importance of work in mind.

Employment provides the best opportunity for families to raise their income and leave poverty.

Those who work always have more income than if they receive only a TANF cash grant.

Parents have the primary responsibility for supporting their children. Participant and the state share responsibility for helping families leave welfare. Participants are responsible for moving quickly into jobs. The state is responsible for helping participants find and keep a job, and for collecting child support.

Support is available to help participants become and stay employed, for example health care insurance and child care that participants can access and afford.

The partner agencies that share responsibility for WorkFirst will work with employers and other local partners to move families into self-supporting work.

Washington State welfare reform is based on a "work first" model, and on the conviction that everyone who can work should work, by immediately participating in Career Scope activities or employment. However, many of the families served through WorkFirst have barriers to employment and are best served through other referral pathways.

8.1.9 Will any job do?

Participants will often start with low-wage, temporary or part-time jobs and may continue to qualify for WorkFirst cash assistance. Others are in college work-study or in subsidized employment - jobs we know won't last. Any job is a start that can give participants the work history and references they need to obtain better employment. Still, there are things to keep in mind for participants who are employed, but in jobs that won't last long enough or pay well enough for a successful WorkFirst exit.

There are two basics to review with these participants while building their IRPs:

  • They may be required to participate for up to 40 hours per week, and
  • They have a choice of activities.

Individual circumstances will vary and affect participation options. A person in subsidized employment may be focusing on resolving issues as his or her additional activity, and moving to Career Scope activities as the situation improves. A person in college work study or who is limited-English proficient may be concentrating on their studies.

8.1.10 How do work study hours count?

Paid college work study is considered employment. The number of hours a participant is working in a federal or state work study count toward meeting the core activity requirement. Work study less than 19 hours per week must be stacked with other core activities (see stacking activities section).

The colleges are able to approve between 1 and 19 hours per week of work study. This will assist participants in meeting their core activity requirements. For example, a participant may be completing vocational education training that is 26 hours per week. The college can add 6 or more hours of work study to help the participant meet the goal of 32 - 40 hours per week of participation. The strengthened participation requirements in WFHB 1.2.3 don’t apply to work study students as long as they meet these requirements.

8.1.11 What is AmeriCorps/VISTA employment?

AmeriCorps national service programs, such as VISTA or AmeriCorps, provide a stipend living allowance to program participants (more commonly referred to as members). For the purposes of WorkFirst, the stipend is treated as salaried employment (not self-employment) and you code it as PT or FT depending on the number of hours the person works each week.

AmeriCorps/VISTA employment typically lasts for nine to 12 months, is normally full-time and result in educational award for teens or parents who successfully complete the program. Members will obtain marketable soft skills, job skills, a good source of income, and work experience. AmeriCorps and Vista programs can be an effective way for parents and teens to achieve self-sufficiency. See EAZ 388-450-0045 for information about how to budget AmeriCorps/VISTA earnings.

8.1.12 What is WIA paid work experience?

The Employment Security Department is authorizing paid work experience for participants in many areas of the state, funded by Title 1 of the Workforce Investment Act (WIA). Participants' WIA experience payments will affect both financial eligibility and WorkFirst participation.

WIA paid work experience is considered WIA on-the-job training for Basic Food purposes. It is coded on the ACES 3G Earned Income screen with employment code 'WJ'. For more information on budgeting WIA, please refer to the EAZ Manual under Income - Special Types, WAC 388-450-0045(1)(i) and (ii).

WIA paid work experience is considered employment for the purposes of the WorkFirst program. WorkFirst staff will code WIA paid work experience participation under the PT or FT eJAS component code. As employment, there is no FLSA maximum hours for WIA paid work experience and staff will not need to enter actual hours of participation each month.

8.1.13 Verifying Job Starts - Step-by-step guide

  1. When you learn of a change in employment hours:
    1. Require the participant to complete an IRP review and update.
    2. Determine whether the participant has started a new job. If not, the participant does not need to provide proof of employment hours.
    3. If the participant has started a new job, determine whether a CS or CE verification valid value was entered on the participant's ACES 3G Earned Income Screen. If not, the participant does not need to provide proof of employment hours.
    4. If the participant has started a new job and the CS or CE code was used, require the participant to provide proof of employment hours within 10 business days. Add to the participant's IRP "I agree to provide proof of the number of hours I work by [date]. "
    5. Start the sanction process if a participant refuses to provide proof of employment hours as required.
  2. If the WFPS or WFSSS uses a verbal employer statement as proof of employment hours, they must document in eJAS:
    1. The employment hour information.
    2. The name, title and phone number of the contact person.
    3. The date of the contact.
  3. The WFPS or financial eligibility staff updates the ACES 3G Earned Income Screen for the ongoing month and at least two historical months (unless the employment start date was less than 2 months ago) only once we have proof of employment hours, including:
    1. Adjusting wage information, as needed.
    2. Adjusting employment hours, as needed.
    3. Updating the verification valid value to document the type of proof that was obtained.


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