I.Purpose

To communicate policy changes around documentation requirements to establish WIA eligibility. In an effort to streamline the requirements for documenting eligibility, the existing guidance is being revised to align with U.S. Department of Labor (USDOL) Training and Employment Guidance Letter (TEGL) 28-11 allowing source documentation to be determined by the level of service.

II.Effective Date

Immediately

III.Background

WIA and 20 CFR Part 652 establish general and specific program eligibility criteria. In TEGL 28-11, USDOL established specific expectations for acceptable source documentation for WIA adult, dislocated worker, and youth participants.

As recipients of WIA Title IB Adult, Youth, and Dislocated Workers funds, the Ohio Department of Job and Family Services (ODJFS), Office of Workforce Development (OWD) and the local workforce investment areas are required to maintain and report accurate program and financial information. This policy lists the types of acceptable documentation to verify eligibility for the WIA adult, dislocated worker, and youth programs.

IV.Requirements

Local areas must verify (i.e. confirm) eligibility requirements through an examination of documents. Documentation requirements to support WIA adult and dislocated worker eligibility are tied to the level of services provided to the participant. While documentation is minimal for adults and dislocated workers who are enrolled in registered core services, the documentation requirements increase for participants to receive intensive services.

For WIA youth program participants, the eligibility documentation requirements do not vary between types of services.

See Attachment A for the specific types of source documents that may be used to verify participant eligibility for each level of service.

Electronic records: Documentation can be stored electronically; however, the document requirements remain unchanged and the documents must be available to monitors/auditors for monitoring purposes.

Types of source documentation

For documentation of eligibility for adult, dislocated worker and youth programs, there are multiple forms of acceptable source documentation. In many cases, a copy of a source document listed in Attachment A will be used to verify eligibility of a participant. Below are additional methods local areas may use if, according to Attachment A, the method is permissible for the particular eligibility criteria or data element being verified.

Telephone or Electronic Communication: In instances where telephone or electronic communication is acceptable and used by a local area, the case file must contain the name of the agency representative, the date of the conversation, and the result of the eligibility verification. Local areas should have standardized forms to document telephone communication. If a telephone communication is used to verify dislocation, the case file must contain the date and reason for termination, and a possible recall date if applicable. See Attachment B for a sample telephone verification form.

Self-Attestation: Self-attestation occurs when a participant states his or her status for a particular eligibility criteria and then signs and dates a form acknowledging this status. The key elements for self-attestation are:

a)The participant identifying his or her status for permitted eligibility criteria;

b)Signing and dating a form attesting to this self-identification.

The form and signature can be on paper or in the state management information system, with an online signature. Local areas should use a standardized form for self-attestation. See Attachments C and D for sample self-attestation forms.

Case Notes: Case notes refer to either paper or electronic statements by the case manager that identifies, at a minimum, the following:

a)A participant's status for a specific eligibility criteria;

b)The date on which the information was obtained;

c)The case manager who obtained the information.

Cross-Match: A cross-match requires WIA staff to acquire detailed supporting evidence for the eligibility criteria in another database (e.g. public assistance records). An indicator or presence of a Social Security Number in a non-WIA database is not sufficient evidence to document WIA eligibility. Detailed supporting evidence may include the date of eligibility determination, date of participation, and services rendered.

State Management Information System (MIS): State MIS refers to specific, detailed information that is stored in Ohio's Workforce Case Management System and supports eligibility criteria. An indicator such as a checkmark or date on a computer screen is not an acceptable source document.

Retention of records:

Per rule 5101:9-9-21 of the Ohio Administrative Code, ODJFS and local workforce investment areas are to retain records for a period of at least three (3) years after submittal of the final closeout expenditure report for that funding period.

V.Technical Assistance

For additional information, you may send your questions to the Office of Workforce Development: WIAQNA@JFS.OHIO.GOV.

VI.Reference

Workforce Investment Act of 1998, Pub. L. No. 105-220, 112 Stat. 936.

WIA Final Rules, 20 C.F.R. §§ 663.110, 663.115, 663.120, 663.220, 663.310, 664.200 (2000).

USDOL, Training and Employment Guidance Letter 22-04, Serving Military Service Members and Military Spouses under the Workforce Investment Act Dislocated Worker Formula Grant, March 22, 2006.

USDOL, Training and Employment Guidance Letter 28-11, Program Year 2011/Fiscal Year 2012 Performance Reporting and Data Validation Timelines, May 9, 2012.

O.A.C. § 5101:9-9-21

Attachment A, Allowable Source Documentation for WIA Program Eligibility

Attachment B, WIA Telephone Eligibility Verification (JFS 13188)

Attachment C, Self-Attestation (JFS 13186)

Attachment D, Citizenship Status / Authorization to Work Self-Attestation (JFS 13187)

Rescissions:

WIATL 27

Workforce Investment Guidance Letter 6-2000