5.2 Limited English Proficiency (LEP) Pathway

Revised on: January 6, 2026

Legal References:

• RCW 74.08A.320
• WAC 388-310-0900
• WAC 388-271

The Limited English Proficiency Pathway section includes:

• 5.2.1 What is the LEP Pathway?
• 5.2.2 Who needs LEP Pathway services?
• 5.2.3 Who provides LEP Pathway services?
• 5.2.4 Who are Refugee Cash Assistance (RCA) recipients?
• 5.2.5 What are participation requirements for survivors of certain crimes and lawfully residing individuals?
• 5.2.6 What is the comprehensive evaluation and assessment process for LEP participants?
• 5.2.7 What are LEP Pathway participation activities?
• 5.2.8 Can LEP participants engage in non-LEP Pathway activities?
• 5.2.9 When should LEP participants be placed into a Community Service or Work Experience activity?
• 5.2.10 What Job Skills Training and Customized Job Skills Training are provided through the LEP Pathway?
• 5.2.11 When is it appropriate to code ESL as "JT" in eJAS?
• 5.2.12 How do LEP contractors capture WorkFirst participation?
• 5.2.13 LEP Pathway - Policy in Practice

5.2.1 What is the LEP Pathway?

The Limited English Proficiency (LEP) Pathway provides specialized culturally and linguistically appropriate services to WorkFirst participants with Limited English Proficiency. The goal of the LEP Pathway is to increase participants' employability and economic stability.

Key features of the Pathway are:

• Use of bilingual and culturally appropriate services.
• English as a Second Language (ESL) instruction  (also known as English Language Instruction or English Language Acquisition).
• Specialized employment services such as job readiness training, skills training and job placement assistance, and work experience. 

All WorkFirst participants, including LEP participants, are screened for Equal Access (EA) services and family violence needs to determine if additional referrals or accommodations are needed.

English as a Second Language (ESL) instruction:

All Community and Technical Colleges (CTCs) offer ESL classes for WorkFirst participants as part of the LEP Pathway. However, some colleges have more than one contract to support this activity - one through the State Board of Community and Technical Colleges (SBCTC) and one through the Office of Refugee and Immigration Assistance (ORIA), which is part of DSHS. Here are a few differences:

• ORIA CTC LEP contracts are only in specific areas. A list of ORIA contractors can be found here (note, all ORIA CTC contractor codes start with an 8 or 9). ORIA contracts with the CTCs offer break activities for participants but do not have funding to provide support services. Those would be done directly by local Community Services Office (CSO) WorkFirst staff.
• SBCTC CTC contracts are available with 33 Community and Technical Colleges in the state.  While these are not specific LEP Pathway contractors, all the CTC contractors provide ESL class support along with a variety of other activities (note, all the SBCTC CTC contractor codes start with an A or P). SBCTC contracts with the CTCs may not offer break activities, but most can provide support services issued directly by the CTC.

Specialized Employment Services

LEP Pathway contractors offer specialized employment services such as job readiness training, skills training and job placement assistance, work experience and subsidized employment options in specific areas in the state.   

• ORIA contracts with providers that offer activities like job search and work experience in specific areas of the state. A list of ORIA contractors can be found here and in the WorkFirst Partner Directory (only accessible to CSD staff).
• Commerce contracts with a small number of contractors that offer a more specialized LEP Pathway Community Jobs (subsidized employment) option.  LEP Community Jobs providers can be found in the WorkFirst Partner Directory (only accessible to CSD staff).

5.2.2 Who needs LEP Pathway services?

Any mandatory WorkFirst participant that has difficulty understanding or communicating in English is referred to the LEP Pathway. This includes:

• An individual who reports they have Limited English Proficiency.
• An LEP participant with ESL Level 1 through 6 who is identified by college staff or an ESL contractor as needing specialized assistance to participate.

When a WorkFirst participant reports that they have Limited English Proficiency, WorkFirst staff code the case with the Limited English Pathway (LP) indicator code.

5.2.3 Who provides LEP Pathway services?

LEP Pathway providers are contracted through the State Board of Community and Technical Colleges, Department of Commerce (see list of Commerce contractors) and DSHS Office of Refugee and Immigrant Assistance (see list of ORIA contractors) to provide ESL instruction and employment services to WorkFirst participants.

ORIA LEP Pathway contractors:

• Consult with the Case Manager to change/finalize the participant's IRP.
• Provide/arrange necessary and culturally appropriate WorkFirst employment services.
• Communicate the participant's employment status to the Case Manager at their local CSO, document scheduled attendance, actual participation hours and any other changes on a monthly basis in eJAS.
• ESL contractors:
  • Conduct/arrange CASAS test and/or ORIA approved assessment tools to determine a participant’s ESL proficiency level ( English language Competency Levels).
  • Document the ESL level and the date of the test in eJAS  on the ORIA LEP Pathway Plan screen.
  • If ESL instruction is needed, develop an Education plan in eJAS.
  • See additional information on Education and Training in WFHB Chapter 7. 
• Employment contractors:
  • Determine employability and develop an Employment Plan (EP) in eJAS.

CTC contractors:

• Conduct/arrange CASAS testing and other assessment tools to determine a participant’s ESL proficiency level (English language competency levels).
• Document the ESL level and the date of the test in eJAS Demographics Screen.
• Determine employability and look at Work Study options.
• If ESL instruction is needed, develop an Education plan in eJAS.
• Communicate the participant's employment status to the Case Manager at the local CSO, document scheduled attendance, actual participating hours and any other changes on a monthly basis in the eJAS.

For a complete list of ORIA contracted LEP Pathway contractors by region, and their current eJAS contractor codes, please see the LEP Pathway Contractor List. For a list of CJ contractors, see the CJ LEP Contractor List.

5.2.4 Who are RCA recipients and what are their participation requirements?

Refugee Cash Assistance (RCA) recipients are single or married individuals without dependents who can't be claimed as someone else’s dependent and are therefore not eligible for TANF.  They must meet program income and resource requirements, and their immigration status allows them to access this cash assistance. RCA recipients who aren't exempt are required to meet work and training (W&T) requirements and can be served through the ORIA contractors to meet these requirements. See CSD Procedure Providing Services for Refugee Cash Assistance Customers and EAZ Refugee Cash Assistance for additional information.   

5.2.5 What are participation requirements for survivors of certain crimes and lawfully residing individuals?

Survivors of certain crimes may be eligible for State Family Assistance (SFA), if they meet all other eligibility requirements except for immigration status. Survivors of certain crimes who qualify for SFA are required to engage in WorkFirst.

For more information on this population, please see WAC 388-424-0001 and EA-Z Manual: Citizen and Immigration Status Requirements Specific to Program – Benefits for Survivors of Certain Crimes.

All lawfully present non-qualified aliens, (also referred to as ‘lawfully residing individuals’), who qualify for SFA benefits, are subject to WorkFirst requirements. This population includes any noncitizen individuals who are residing in the U.S. because they have applied for adjustment of status and USCIS allows them to live in the U.S. lawfully while waiting for the results of their application.  

Examples of lawfully residing individuals may include:

• Applicants for asylum
• Individuals with Voluntary Departure granted

For more information, please see WAC 388-424-0001 and EA-Z Manual: Citizenship and Immigration Status Requirements for all Programs – Definitions.

Survivors of certain crimes and lawfully residing individuals most often do not have an employment authorization document (EAD). They aren’t referred to employment-specific services or job search activities. Instead, they’re:

• Excluded from work-specific participation requirements like job search or paid work
• Referred to LEP Pathway for ESL instruction, if their English skills are limited
• Referred for participation in appropriate activities and service that don’t require them to have a Social Security Number (SSN) or EAD. Examples of activities and service referral partners include, but aren’t limited to:
  
  • Basic education or high school equivalency completion
  • Family violence services
  • Emotional & mental health services – including counseling and support groups
  • Medical services
  • Community based organizations (CBOs)
  • Other appropriate ORIA providers
• Referred to legal services for assistance to adjust their immigration status (if desired by the participant)

Due to the unique circumstances of these populations, WorkFirst participation requirements are tailored to support the participant and their family. Actively take steps to refer and/or place participants into activities to help resolve or cope with their circumstances and create a safe environment for the family, as well as prepare for future employment if appropriate. WorkFirst participation exemptions are available to these populations, if they qualify (see WFHB 6.8).

Survivors of certain crimes and lawfully residing individuals without employment authorization are identified in eJAS using the PU (Lawfully Residing Individuals) indicator code (set at “0” hours), along with appropriate activity component, depending on assigned activities. PU is not an exemption code, it just indicates that these individuals do not have employment authorization to work in the U.S. and can’t participate in employment-specific and job search activities.

5.2.6 What is the comprehensive evaluation and assessment process for LEP participants?

LEP Participants are required to complete the comprehensive evaluation and assessments (as applicable) to all WorkFirst participants before being referred to the LEP pathway for bilingual and culturally appropriate services.

5.2.7 What are LEP Pathway participation activities?

The LEP Pathway offers several options for participants to enhance their skills and employability, including core and non-core activities. See WFHB 1.2 Required Participation for more information on federal core/non-core activity requirements.

Participants in the LEP pathway should be scheduled with activities as close to full time as is feasible. Full-time participation can be met with:

• Standalone core activities of Job Search (JS), Customized Job Skills Training (PE), Work Experience (WE) up to the monthly FLSA maximum, and Community Jobs (CJ).  
• With a combination of one or more core activities (at least 20 hours) noted above, stacked with non-core activities of ESL instruction or Job Skills Training (both JT).
• If the participant is in ESL instruction but is unable to participate at least 20 hours a week in a core activity due to other barriers or limited LEP core activities offered in their area, use (ES) to code the ESL activity.  LEP contractors track monthly ES participation hours in eJAS notes.

Participants must accept a job offer if, at any time during participation, a job becomes available and has been offered, unless there's a good reason to refuse the job (for definitions of "good reason" see WAC 388-310-1600). When a participant is able, but refuses without good cause to accept a job, a sanction penalty is imposed, following the Good Cause process.

Regular case staffing(s) are encouraged to review participation and progress. Anyone with an Equal Access (EA) plan may need more time in the component activity and fewer participation hours to accommodate their additional needs.

Participants who meet participation requirements are eligible for WorkFirst support services (see WAC 388-310-0800). Those who are working full-time and are still eligible for TANF cash assistance should be encouraged, but not required, to enroll in educational activities along with their employment.

5.2.8 Can LEP participants engage in non-LEP Pathway activities?

LEP Pathway provides specialized culturally and linguistically appropriate services to WorkFirst participants with Limited English Proficiency. However, WorkFirst LEP participants can engage in activities outside the LEP pathway if offered by the WorkFirst contractor or when the participant enters higher ESL levels.  For example, a community college might have WorkFirst Work Study available while the student is attending ESL classes, or the participant was approved to volunteer in their child’s elementary school.  WorkFirst staff  must follow the referral process as outlined in the appropriate WorkFirst chapter in those cases.

The following core activities are examples of activities that are not within the LEP Pathway but might be appropriate for LEP participants:

• Community Jobs - CJ 
• Community Works - WC
• Customized Job Skills Training – PE
• Life Skills Training - LS
• On-the-job Training - OT
• Vocational Education - VE
• High Wage High Demand Training - HW
• High School completion or High School equivalency (age 19 or younger) - HS
• Subsidized employment like Work Study PT
• Volunteer Services in child’s daycare or elementary school – VS

Non-core activities stacked with core activities are also great options when a participant needs additional education. These activities can include:

• High School completion (age 20 or older) - BE
• High School equivalency (age 20 or older) - GE

The non-LEP pathway contractor or agency must report these activities, and WorkFirst staff must review them.

5.2.9 When should LEP participants be placed into a Work Experience activity?

Community Service is a structured unpaid work activity in which LEP TANF participants work for the direct benefit of the community under the support of a public or non-profit organization. It's a core activity that counts towards the federal participation rate and is coded as XS on the eJAS component code screen.

Work Experience (WEX) is a structured unpaid work activity, which offers an opportunity for participants to practice or expand their work skills in a supportive and flexible work environment in a public or non-profit organization. It is a core activity and is coded as WE on the eJAS component code screen.

Participants may be determined to be best suited for WEX if they:

• Need time to acquire job skills needed for work and need minimal case management to be successful on the worksite.
• Have work experience but need additional experience to become competitive in the labor market.

Need an additional core activity to stack to meet full program participation.

5.2.10 What Job Skills Training and Customized Job Skills Training are provided through the LEP Pathway?

Job skills training is a short-term training and enhances participants’ employability by providing instructions and teaching specific skills that are marketable to employers. This service is a non-core activity that must be stacked with a 20 hour core activity to meet full participation. It is coded as JT on the eJAS component code screen.

Customized Job Skills Training (CJST), formerly known as pre-employment training, is an 8-22 week training program that is customized for specific employers or tied to a specific industry. CJSTs must include industry-specific training and be tied to jobs with good labor market demand. It's a time-limited core activity that counts towards full participation and is coded as PE on the eJAS component code screen.

5.2.11 When it is appropriate to code ESL as “JT” in eJAS?

ESL service is provided for participants with ESL levels 1-6 to assist in gaining language skills necessary to obtain and maintain employment. CASAS and ORIA-approved assessment tools are used to determine a participant’s ESL level and language skill gains.  When students finish level 6 via the LEP Pathway, they transition out of the LEP pathway but may continue with adult basic education (ABE) at the colleges if needed.  The contractor will communicate with the Case Manager when the participant completes level 5 and 6.

Based on placement determination from an approved assessment, the contractor will determine what activities are appropriate for the participant. Depending on the determined level of ESL needed, there are two general activities:

• Use the JT eJAS component code for ESL when stacked with 20 hours of core activities and indicate in the participant’s IR) that English language acquisition is a skill needed for employment.
• Use the ES eJAS component code for an ESL activity if they are participating in core activities for less than 20 hours a week.

5.2.12 How do LEP contractors capture WorkFirst participation?

Unsupervised homework hours for ESL instruction

Only classes with an expectation of homework equal to or greater than the scheduled class hours may be eligible for claiming unsupervised homework hours. One hour of unsupervised homework time for each hour of actual class time attended is allowed. If there is no homework expectation, we cannot claim homework hours.

CTC contractors:

Use the WorkFirst Calculator Tool to determine and document the total number of hours per week the participant is participating.  For more information on tracking education hours, see WFHB 7.1.3 and 7.1.4.  For more information on Basic Education see WFHB 7.3.3 and 7.3.4.

CBO contractors:

Use the Educational and Homework Requirements Worksheet (EHRW) to document scheduled class hours and the homework expectation for the class. CBO contractors must keep a copy of the EHRW form in the participant's case file. To claim homework hours, CBO contractors may double the participant's actual attendance hours to report via eJAS by the 10th of each month for the previous month.

In the event that the participant drops out or is referred back before completing their ESL class, one hour of homework time can be claimed for each actual class time hour attended by the participant if the homework expectation hours are equal to the scheduled class hours. This applies to CTCs and CBO contractors.

Absences

After two absences in a calendar month, the WorkFirst contractor must:

• Send an immediate notification to the Case Manager via eJAS eMessage  and explain if the absences is excused.
• Keep the activity open.
• Contact the participant and Case Manager to discuss next steps, including if it is appropriate to refer the participant back to the local CSO.

For more on how to treat excused and unexcused absences, please refer to section 3.7.1.5 and 7.1.6.

5.2.13 LEP Pathway - Policy in Practice (also see the LEP Pathway Flow Chart)

1. When TANF is approved or the family appears eligible for TANF, WorkFirst staff:
   
   1. Complete the comprehensive evaluation using the Pathway Development Tool (See section WFHB 3.2 - Comprehensive Evaluation for more information) and determine whether the participant needs an Equal Access (EA) plan.
   2. If the participant reports Limited English Proficiency is a barrier to employment, discuss the LEP Pathway and if participant chooses this option, add the LP indicator code.
   3. If the participant is reporting barriers to participation, create an IRP to address the barriers and determine if they can participate at least part time in LEP Pathway services.
   4. If the participant is able to participate in part or full time activities, refer the participant to the LEP Pathway contractor using the WorkFirst Partner Directory (only accessible to CSD staff):
      
      1. If the LEP participant is a returner, ask if they are already working with a contractor. If yes, generate a referral to that contractor to support their continued participation.
      2. For ESL instruction:
         
         1. Add the RA referral component with the contractor code for 7 days, creating an IRP using the RA template for ESL testing and completion of the education plan.
         2. Create an e-message referral to the contractor with the following information:
            • Participant's preferred language.
            • Description of expected specific activities (ESL testing, recommendations for the number of hours, if there is a core activity for at least 20 hours) in Comments section.
            • Signed Authorization for Release of Information on file.
         3. Print the IRP and complete any needed translation services.  Hand or mail the IRP to the participant and explain that it is their responsibility to contact the contractor within 7 days.
      3. For Employment Services:
         
         1. Add the RO referral component with the contractor code for 7 days, creating an IRP using the RO template for completion of the LEP Employment Plan.

2. Create an e-message referral to the contractor with the following information:
   1. Participant's primary language.
   2. Description of expected specific activities (job search or work experience and number of hours) in Comments section.
   3. Signed Authorization for Release of Information on file.
   4. Print the IRP and complete any needed translation services.  Hand or mail the IRP to the participant and explain that it is their responsibility to contact the contractor within 7 days.

2. The LEP Pathway contractor:
   
   1. Accepts the RA and/or RO component, entering the date of acceptance in eJAS.
   2. Makes all efforts to contact the participant as soon as possible to make an appointment.
   3. Reviews the referral and meets with the participant for a one-on-one interview.
   4. ESL contractors:
      
      1. Conduct/arrange for the CASAS and/or approved English language testing.
      2. Enter the ESL level and test date on the ORIA LEP Pathway Plan screen and in the Client Notes screen in eJAS.
   5. Reviews together with the participant their previous education, training, work history, skills and occupational goals to determine appropriate activities.
   6. Discusses WorkFirst participation requirements and develops a written plan in eJAS with the participant, making sure that the participant is a part of the decision-making process.  Plans created by the contractors include:
      
      1. Education Plan (including components).
      2. Employment (also known as ORIA LEP Pathway Plan – work).
      3. Individual Development Plan.
   7. Completes the eJAS Client Notes and e-messages the Case Manager information about the first meeting, recommended employment activities, and reasons why they may be beneficial.
   8. Updates the Employment Plan, Education Plans or Individual Development Plan in eJAS, including the activity components specifying hours and duration:
      • ES – ESL instruction only (not stacked with at least 20-hour core activity)
      • JT – ESL skills enhancement training when stacked with at least 20-hour core participation
      • WE - Work Experience
      • JS - Job Search
      • VE, PT, WC- Other non-LEP Pathway employment services deemed necessary (i.e. Vocational Education, Community Works, Work Study, etc.)
   9. Documents in eJAS the participant agreed to this plan.
   10. Rejects the RA or RO component by referring back the participant to the CSO within 7 days if no contact is made (face-to-face meeting with the participant) by the 7th day.
3. The Case Manager:
   
   1. Reviews the Employment and Education plans.
   2. Enters the activity components with scheduled hours of participation and duration indicated in the plan, along with the contractor code.
   3. Updates the IRP, including any translated pieces, and hands or mails to the participant documenting they agreed to this plan with the WorkFirst LEP contractor.
4. The LEP Pathway contractor:
   
   1. Works with the Case Manager to discuss and finalize the suggested activities.
   2. Modifies the Employment and Education Plan as needed.
   3. Enters the date the participant began participating in WorkFirst activities in Actual Start Date column of Contractor Caseload Screen.
   4. Documents participant's actual hours of participation by keeping daily attendance/timesheets. Documents excused absences in eJAS and states the reason for absence in eJAS Notes.

5. Reports actual participation hours monthly on the eJAS Contractor Caseload and Multiple Clients Monthly Participation screens by the 10th of the following month for the previous month's activities.

6. Reports in eJAS any identified issues. Attempts to resolve the issue with the participant and involves the Case Manager immediately when unable to resolve or if the issues are affecting the participant's ability to participate.
7. Sends immediate notification to the Case Manager within 1 business day after a participant has 2 excused or unexcused absences in a calendar month by using the "Immediate Notify" column in the Contractor Caseload screen, and keeps the activity open. Refer to WFHB 5.2.13- What steps do you take when a participant is absent? for more information.
8. Sends immediate notification to the Case Manager when a participant is unable to participate for the scheduled number of hours. Initiates conversation with Case Manager and participant about whether the activity is appropriate.
9. Contacts the participant and Case Manager to discuss next steps – see WFHB 3.2.1.5 and 3.2.1.6 for more information on the Continuous Activity Plan (CAP) staffing. 
10. Updates the ESL level in the ORIA LEP Pathway Plan in eJAS as the participant advances and communicates to the Case Manager when the Participant reaches a level 5 and 6.
11. Updates appropriate sections of eJAS.

5. The Case Manager:
   
   1. Continues to monitor the LEP Pathway case.
   2. Addresses any rejected referrals.
   3. When the contractor reports that the participant reaches an ESL level 5 or 6:
      
      1. Updates the ESL level on the participant’s eJAS demographic screen.
      2. Refers participants to Career Scope Services subsidized employment or Education and Training activities for additional services.
   4. Updates the IRP and eJAS with any activity changes as follows:
      
      1. Updates activity components and enters contractor's code in eJAS Active Components screen using the WorkFirst Partner Directory (only accessible to CSD staff), to give the contractor access to the case record.
      2. Updates or creates a new IRP, if necessary, and has the participant sign it.
      3. Documents scheduled WorkFirst activities in eJAS LEP notes.
   5. Notifies the contractor of changes in the participants' participation requirements so that Education/Employment Plan can be updated.
   6. Reviews the Contractors Caseload and Monthly Participation screens for monthly reporting.
   7. Updates the eJAS Employment screen as soon as possible with employment information received from contractor.
   8. Ensures the ACES Earned Income screen is updated.

For a summary of the LEP Pathway process, please see the WorkFirst LEP Pathway Program flow chart.

Resources

Related WorkFirst Handbook Sections

• 1.2 Required Participation
• 1.4 WorkFirst Orientation
• 2.2 Support Services
• 3.2.1 Comprehensive Evaluation
• 3.3.1 Individual Responsibility Plan
• 3.3.2 Stacking Activities
• 3.5.1 Entering Sanction
• 7.1 Education and Training Overview
• 7.2 Vocational Education
• 7.3 Basic Education, Skills Enhancement, High School/HSE
• 8.3 Community Jobs

Forms & Other Resources

• Capturing Homework Hours Chart
• Educational & Homework Requirements Worksheet (used by LEP Pathway contractors)
• LEP Pathway ESL Competency Levels
• WorkFirst LEP Pathway Program Flow Chart
• WorkFirst Calculator Tool (used by SBCTC staff)
• LEP Pathway Contractor List
• WorkFirst Partner Directory – only accessible to CSD staff