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Wisconsin Department of Children and Families Wisconsin Works (W-2) Manual |
2.10.6.1 24-Month Time Limit Extension Criteria
2.10.6.2 State 48-Month Time Limit Extension Criteria
2.10.6.3 Local Labor Market Conditions Criteria
2.10.6.4 Valid Documentation for Family-Related Challenges Time Limit Extension
2.10.6.5 Processing Initial Time Limit Extensions
2.10.6.6 Processing Subsequent Time Limit Extensions
2.10.6.7 Reaching 24-Month and 48-Month Time Limits Concurrently
2.10.6.8 Time Limit Extension Decisions and Assessment
2.10.6.8.2 Case Management Practices and Time Limit Extension Approvals
There may be opportunities for time limit extensions of the 24-month placement time limits and 48-month state lifetime limits for TEMP, CSJ, W-2 T, and CMC participants. The W-2 agencies must work intensively with participants prior to and during time limit extension periods to help the participant overcome barriers or challenges.
For information on time limit extensions for CMC participants, see 2.10.8.4.
W-2 agencies have decision-making authority for all time limit extension approvals and denials.
For the purposes of this section:
"Reasonable unsubsidized employment opportunity" means a job the participant could get that pays at least minimum wage and conforms to all applicable federal and state laws.
Making “all appropriate efforts to find unsubsidized employment” means that the participant has participated in all assigned activities.
All time limit extension decisions must be made on a case-by-case basis.
The W-2 agency must use the placement extension criteria listed in the following table to determine whether a 24-month time limit extension is appropriate.
Placement |
Extension Criteria |
Additional Notes |
The Participant has:
|
Since subsidized employment positions in TEMP specifically target high-quality, high-wage opportunities, the likelihood of extending a TEMP placement is typically rare. | |
,CSJ |
The Participant has:
|
See 2.10.6.3 for documentation required to approve a 24-month placement time limit extension for local labor market conditions. |
The Participant has:
|
See 5.5 for more information on valid formal assessments. |
All time limit extension decisions must be made on a case-by-case basis.
To be eligible for a 48-month state lifetime limit extension, a participant must meet at least one of the following 48-month state lifetime limit extension criteria listed in the following table.
Extension Criteria |
Details |
Required Documentation |
| The participant has made appropriate efforts to find unsubsidized employment and has been unable to do so because the local labor market conditions preclude a reasonable unsubsidized employment opportunity for that participant. | In order to approve a time limit extension based on local labor market conditions, the agency must demonstrate or document any one of the following circumstances:
|
See 2.10.6.3 for required documentation. |
| The participant is unable to work because of a personal disability or incapacitation. | Examples include:
|
A valid formal assessment must have been completed to approve. |
| The participant is unable to work because they need to remain at home to care for a member of the W-2 Group. | The W-2 Group member in need of care must have an incapacity so severe that without in-home care provided by the W-2 participant, the health and well-being of the W-2 group member would be significantly affected. | A valid formal assessment must have been completed to approve. |
| The participant has significant limitations to employment. | Examples include: |
A valid formal assessment must have been completed to approve. |
| The participant has significant limitations to employment due to family-related challenges affecting a member of the W-2 Group. | Examples include:
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See 2.10.6.4 for required documentation. |
| The participant is unable to work to due to current participation in a substance abuse treatment program. | The program must be certified to provide treatment for substance abuse under ss. DHS 75.10 to 75.15 or psychosocial rehabilitation services as approved by the department. | Additional documentation is not required. |
| The participant’s W-2 group includes a member who has experienced domestic violence or extreme cruelty. | This includes, but is not limited to, the use or attempted use of:
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Additional documentation is not required. |
A W-2 agency may provide a 24-month placement time limit extension or a 48-month state lifetime limit extension on a case-by-case basis if the agency determines that a participant’s efforts to find unsubsidized employment have been unsuccessful due to the local labor market conditions.
Local Labor Market Time Limit Extension Approvals
In order to approve a time limit extension based on local labor market conditions, the agency must provide documentation or evidence supporting at least one of the following circumstances:
Specific examples show that other W-2 participants with comparable skills, or who are conducting job searches in similar geographic or occupational areas, are also unable to secure unsubsidized jobs.
Local job market decline in the participant’s field:
Published labor market data, or specific examples such as business closures or workforce reductions, demonstrate a local economic downturn or ongoing lack of available jobs in the labor market sectors that match the participant’s skills.
Published labor market data or specific examples, indicate a continued unavailability of jobs within reasonable participant travel time—defined as no more than 60 minutes travel time one-way, using available transportation, from the participant’s home to the employer, including travel time related to any necessary child care.
Documentation may include:
Case histories of other comparable participants (with any personally identifiable information removed);
Press coverage regarding the local job market or local business conditions;
Agency correspondence with historical or potential placement sites;
Current labor market data obtained from public or private sources; or
Products of current locally relevant labor market studies or research.
If the agency approves an extension based on local labor market conditions, FEPs should conduct assessments, including Career Assessments, with the participant and create an EP with assigned activities that focus on training to build skills valuable in the current local labor market.
In order to approve a 48-month state lifetime limit extension for a participant due to family-related challenges affecting the W-2 Group, the agency must have valid documentation.
Valid documentation of family-related challenges must reflect current circumstances. This includes:
Court, medical, criminal, child protective services, social services, psychological, school social worker, school guidance counselor, or law enforcement records regarding legal problems, family crisis, homelessness, children’s school or medical activities, or domestic abuse or physical or emotional harm to the parent or child;
Voluntary disclosure or identification from the Domestic Abuse Screener that the applicant or participant or group member is a survivor of domestic abuse or is at further risk of domestic abuse;
Written and signed statements from others with knowledge of the circumstances on which the family problems hardship claim is based, including, but not limited to, statements from public or private social services agencies providing services to the W-2 group, school counselors, domestic violence or homeless shelter service providers, attorneys, etc.;
Written statement by the applicant or participant; or
Any other supporting documentation, including formal assessments. (See 5.5 for more information on valid formal assessments.)
If the individual does not have a verified barrier, limitation, or family problem as required above or is not participating in all assigned activities, the FEP may deny a 48-month state lifetime limit extension.
2.10.6.5 Processing Initial Time Limit Extensions
The FEP must have a discussion with the participant about the possibility of a time limit extension no later than the month WWP displays:
18 months for the 24-month placement time limit; and
42 months for the 48-month state lifetime limit.
If a person applies for W-2 with more than 18 months on a 24-month placement time limit or 42 months on the 48-month state lifetime limit, the discussion must take place at application.
When determining eligibility for an initial time limit extension, the FEP must:
1. Complete the W-2 Agency Time Limit Extension Approval Record (5214) or the W-2 Agency Time Limit Extension Denial Record (5215) form that corresponds with the decision;
2. Provide the participant with a copy of the completed form; and
3. Scan the completed form into ECF.
The FEP must enter the time limit extension decision in the Time Limit Tracking module no later than the end of the month WWP displays:
20 months for the 24-month placement time limit; and
44 months for the 48-month state lifetime limit.
Note: This do no apply to applications received after WWP displays 20 months used for the 24-month placement time limit or 44 months used for the 48-month state lifetime limit.
Time limit extensions may be granted for six months from the first calendar day after the participant’s:
24th month for placement time limit extensions; and
48th month for state lifetime limit extensions.
If a participant is denied an extension or declines it, the FEP must continue to work with the participant during the period of time before their W-2 case closes to determine if circumstances have changed which would result in being granted a time limit extension.
2.10.6.6 Processing Subsequent Time Limit Extensions
After an initial 24-month placement time limit or 48-month state lifetime limit extension approval is granted, the W-2 agency can determine that a subsequent time limit extension period is necessary.
There is no limit to the number of subsequent time limit extensions a participant may receive.
The FEP must discuss the possibility of subsequent time limit extensions with the participant no later than the third month of the extension.
When determining eligibility for a subsequent time limit extension, the FEP must:
1. Complete the W-2 Agency Time Limit Extension Approval Record (5214) or the W-2 Agency Time Limit Extension Denial Record (5215) form that corresponds with the decision;
2. Provide the participant with a copy of the completed form;
3. Scan the completed form into ECF; and
4. Enter the extension decision into the Time Limit Tracking application no later than the month prior to the current time limit extension end month.
If the agency approves a subsequent extension, a participant’s activity assignment should reflect their assessment results, local labor market information, and anticipated time for the participant to be ready to work or referral to other programs.
2.10.6.7 Reaching 24-Month and 48-Month Time Limits Concurrently
The FEP must determine eligibility for a 48-month state lifetime limit extension rather than a 24-month placement time limit extension if a participant is going to reach either of the following within six months prior to reaching the 48-month state lifetime limit:
The FEP must then enter the 48-month state lifetime limit extension into the Time Limit Tracking application before the participant reaches the end of their 24th month or the end of a 24-month placement time limit extension.
| EXAMPLE: Mary will reach her 24th month in a CSJ on July 29. While reviewing Mary’s time limit history in preparation for a time limit discussion, her FEP sees that Mary will reach her 48th month of her state lifetime limit on October 31. Because Mary will reach 48 months three months after reaching her 24th month, the FEP determines eligibility for a 48-month state lifetime limit extension and enters the 48-month state lifetime limit extension approval by July 29. This extends both the 24-month placement time limit as well as the 48-month state lifetime limit. Any subsequent time limit extensions will be made to the 48-month state lifetime limit. |
2.10.6.8 Time Limit Extension Decisions and Assessment
The FEP must complete and submit the WWP Informal Assessment Driver Flow if:
1. An initial 24-month placement time limit or 48-month state lifetime limit extension is going to be denied; and
2. The WWP Informal Assessment driver flow has not been completed within 12 calendar months prior to the participant’s 24th or 48th month.
The FEP cannot deny a time limit extension until the WWP Informal Assessment Driver Flow is completed and submitted.
If the WWP Informal Assessment indicates the need for a formal assessment, a time limit extension cannot be denied until the formal assessment is complete.
When a participant is denied a time limit extension or the participant declines a time limit extension for either the 24-month placement time limit or 48-month state lifetime limit, the FEP must offer the CMD placement.
The CMD placement is a case management placement for individuals who have reached their time limit and are no longer eligible for a paid placement.
The goals of the CMD placement are to:
Help connect the individual to employment;
Connect the individual and family to services in the community; and
Reassess on a monthly basis whether the individual should receive a time limit extension.
To be eligible for the CMD placement, the participant must meet W-2 financial and nonfinancial eligibility criteria, with the exception of exceeding the 24-month placement time limit or 48-month state lifetime limit.
Services provided to a CMD participant will depend largely on the:
Reason for the time limit extension denial or the participant’s decision to decline the extension; and
Participant’s placement at the time of the extension denial or decline.
Participants who were denied a time limit extension due to nonparticipation should be reassessed to determine which activity assignments will best match the participant's needs and help the participant increase participation. These assignments may be similar to those assigned during their W-2 employment position placement.
FEPs must meet with CMD participants weekly.
Every 30 days, the FEP must meet with the participant (see 1.4.2.4) to review the CMD placement. During the meeting, the FEP must reassess the case to:
Determine whether the participant has consistently participated and reassess whether barriers to employment exist; and
Reconsider whether the individual is appropriate for a time limit extension.
The FEP must thoroughly document in PIN comments the details of the:
1. Weekly meetings;
2. 30-day reassessment process; and
3. Reason(s) the participant is going to remain in the CMD placement, if that is the FEP’s decision.
2.10.6.8.2 Case Management Practices and Time Limit Extension Approvals
When a participant is approved for a 24-month placement time limit or 48-month state lifetime limit extension, the FEP must continue to review the participant’s goals as part of ongoing case management and reinforce the objective of fulfilling employment goals within the time limits of the W-2 program. This includes:
Reviewing the EP with the participant frequently to ensure activities are making progress towards the participant’s goals;
Reviewing relevant labor market data to confirm that employment goals are in line with the job opportunities available in the local labor market;
Continuing to conduct informal assessment to determine whether potential barriers to employment exist and referring to formal assessment information as appropriate (see 5.2.1);
Reviewing whether accommodations would support the participant and if they have the tools and resources needed to succeed at activities (see 1.3.1.2); and
Reviewing the Supportive Service Plan to ensure the participant has access to benefits and services which will support them as they work towards their employment goals and provide a plan for addressing needs and ensuring success following exit from the program. (see 9.2.1)
History: Release 25-03; Release 22-05; Release 21-09; Release 20-03; Release 19-02; Release 17-02; Release 11-06.