7.4.1 Community Service Jobs (CSJ)

The Community Service Job (CSJ) placement is for applicants and ongoing W-2 participants who are not yet ready for unsubsidized employment.

The goal of the CSJ placement is to help participants build essential work habits and soft skills such as punctuality, reliability, and professionalism that support long-term employment success. CSJ work sites are expected to mirror regular employment settings as closely as possible, while allowing for job coaching and mentoring as needed.

Participants may take part in more than one CSJ placement, but the total participation time cannot exceed 24 months. (See 2.10.3) A full-time CSJ participant receives a monthly payment of $653.

7.4.1.1 General CSJ Participant Circumstances

· A work history that includes frequent job changes, voluntary quits, or terminations;

· Personal or health-related barriers, including physical or mental health conditions that limit regular employment; or

· Family-related challenges such as domestic violence, temporary illness or incapacity, or other family crises.

EXAMPLE 1: Jane has two children under the age of 5, has a very limited work history, and is one course short of her high school diploma. After applying for W-2, Jane explains that she is interested in becoming a child care provider but is worried that her limited experience and lack of high school diploma will prevent her from getting a job. The RS assigned Jane to up-front job search activities, and the job developer connected Jane to local child care employers who had openings. However, Jane was not hired due to her lack of experience and education. Jane’s FEP places her in a CSJ and assigns 10 hours per week of education to complete her high school diploma and 30 hours of work experience at a local daycare site.

EXAMPLE 2: Jennifer has a high school diploma and completed a clerical training course but has no full-time work experience. Her son, Jason, age 7, has been recently diagnosed with severe behavioral issues and is in the process of being stabilized on medication. Jennifer applies for W-2 and wants to work somewhere she can use her clerical skills but needs flexibility to respond to her son’s needs as Jason’s school has Jennifer take him out of class weekly for behavioral issues. To do this, Jennifer’s FEP works with Jason’s school to set up a CSJ worksite in the front office, allowing Jennifer to gain clerical experience while remaining accessible for Jason when needed. Once Jason's medication stabilizes his behavior and Jennifer has the necessary clerical experience, the FEP will focus on moving Jennifer into unsubsidized employment.

The W-2 agency must issue a monthly payment of $653 to the CSJ participant if all participation requirements are met. The monthly payment of $653 must not be prorated or otherwise reduced if the assigned hours are less than 40 hours per week. Payments will be reduced by $5.00 for each hour that the participant fails to participate without good cause. (See 11.3.1)

7.4.1.3 CSJ Participation Requirements

CSJ participants are generally expected to complete 40 hours of activities per week but can be assigned fewer hours depending on the participant’s circumstances. Of these 40 hours, up to 10 hours per week can be in education and training activities. (See 8.2.2.2)

· Aggregated education hours to allow a participant to complete a program within one year (see 8.2.2.3);

· Full-time participation in a technical college education program (see 8.2.2.5); or

· Enrollment in a high school or high school equivalent course if the participant is 18 or 19 years old without a high school diploma or equivalent (see 8.2.2.1).

CSJ work training hours countable toward the maximum 40 hours of activity as approved by the FEP may include:

· Meetings with professionals, including child support agency staff, social workers, health care professionals, or other meetings necessary to prepare a participant for employment (activity codes may vary).

7.4.1.4 Kinds of CSJ Work Site Placements

CSJ work site employers may be public, private non-profit, or private for-profit. Each CSJ placement may be scheduled for up to six months with an opportunity for a three-month extension.

CSJ placements may be developed with a variety of employers, including, but not limited to:

7.4.1.5 Prorated CSJs

The prorated CSJ placement is for W-2 applicants and participants who are working in unsubsidized employment for less than 30 hours per week and have limitations to increasing their work hours or obtaining additional job(s).

Hours of activities and payments are prorated to one of the following three levels based on the participant’s total weekly hours of unsubsidized work:

The total combined number of hours of assigned activities and unsubsidized employment must not exceed 40 hours per week for individuals placed in a prorated CSJ.

Participants working up to nine hours per week in an unsubsidized job or a non-W-2 funded subsidized job may be granted a full CSJ payment. Participants working 30 hours or more per week in an unsubsidized job or a non-W-2 funded subsidized job are not eligible for a prorated CSJ.

Activities assigned to prorated CSJ participants must be specifically designed to assist the participants with overcoming their employment limitations within a reasonable time period. For information on combining prorated CSJs with aggregated education and training policy, see 8.2.2.4.

7.4.1.5.1 General Prorated CSJ Participant Circumstances

A prorated CSJ placement may be appropriate for individuals with limitations or barriers to full-time employment, including, but not limited to:

· Barriers to increased unsubsidized employment opportunities that cannot be addressed through supportive services;

· A work history that includes frequent job changes, voluntary quits, or terminations.

EXAMPLE 1: Brenda completed a specialized manufacturing training program, but shortly after, both local manufacturing plants near Brenda announced large layoffs. Without a high school diploma and unable to secure a manufacturing job, Brenda finds a job at a local restaurant working 23 hours per week and applies for W-2. After a thorough assessment and an unsuccessful job search, Brenda’s FEP places her in a 1/3 CSJ placement and assigns 10 hours of GED coursework and seven hours of job search per week. Her 1/3 CSJ payment, based on less than 10 hours of work activity per week, is $218.

EXAMPLE 2: Maria is a single mom with two teenagers. She works 20 hours per week at an insurance company but has a physical disability that prevents her from increasing her work hours. Maria applies for W-2 and after providing verification of her physical disability from her doctor, Maria is placed in a prorated CSJ position. Maria's FEP reviews the medical documentation and together they create an Employability Plan focusing on moving Maria towards employment that utilizes her abilities. Maria makes a career goal of becoming a technical writer. Maria is assigned to participate in an online college-level writing workshop for four hours per week. In addition, Maria is referred to the agency's disability advocate to assist her in initiating an application for SSI. With her current hours of unsubsidized employment at 20 hours per week and less than 10 hours of assigned work activity per week, Maria will receive a 1/3 CSJ payment of $218 per month.

7.4.1.5.2 Prorated CSJ Participation Requirements

CSJ participants eligible for a prorated CSJ payment are expected to participate up to 40 hours per week in a combination of:

In some cases, the combination of CSJ activities and employment may be less than 40 hours per week, such as when the participant's limitations are severe.

If a participant has severe limitations, the FEP must coordinate with the participant’s medical professional or assessing agency to determine appropriate CSJ activities that the participant can reasonably perform and that will meet allowable work training hours. FEP should also connect the participant with DVR for additional resources and support. (See 7.4.1.2) Assigned CSJ activities must not interfere with unsubsidized work hours.

7.4.1.5.3 Prorated CSJ Payments

All prorated CSJ payments, initial or ongoing, follow standard W-2 payment policies and are subject to the current W-2 payment reduction procedures. (See Chapters 10 and 11)

There is no separate prorated CSJ 24-month time limit. The standard 24-month CSJ time limit applies to both full and prorated placements. (See 2.10.3)

7.4.1.6 CSJ Placements for Parents Temporarily Unable to Care for Their Children

CSJ participants who, for medical reasons determined by a qualified assessing agency or professional, are out of the home or are unable to care for their children for periods of less than 60 days may remain in a CSJ placement.

During this period, the participation requirement is to cooperate with the prescribed treatment plan.

In most cases, the Physical Rehabilitation (PR) activity code should be used during this time frame.

7.4.1.7 CSJ Administration

The W-2 agency is responsible for identifying, developing, and managing CSJ positions that prepare CSJ participants for unsubsidized employment. The agency may contract for all or part of the operations.

· Have responsibilities and expectations similar to unsubsidized employees, when feasible;

· Serve a useful public purpose or be a project where the costs are partially or wholly offset by the revenue generated; and

· The work training site supervisor must provide a structured work environment and be willing to supervise, mentor, and coach CSJ participants to succeed in the workplace. See the TANF Work Participation Requirements appendix for more information on requirements for supervising W-2 activities.

If the W-2 agency partners with a for-profit organization to develop a CSJ worksite, the organization must agree to use the revenue or profit generated by CSJ participants’ activities to offset CSJ costs by providing on-the-job training that is valuable to the participant or by reimbursing a portion of the W-2 agency’s CSJ administrative costs.

· Providing special or additional on-site supervision of CSJ participants when necessary;

· Providing or arranging for reasonable accommodations and supportive services, including translators;

· Providing worker’s compensation coverage for all participants, unless provided by the worksite; and

7.4.1.8 Attendance Records

The CSJ work training provider must keep hourly time records and report nonparticipation to the FEP if it occurs. See the TANF Work Participation Requirements appendix for guidelines on documenting and verifying W-2 activities.

7.4.1.9 CSJ Placements as Employment

The U.S. Department of Labor requires that all federal employment laws apply to individuals in welfare-based employment and training participants, even if the participant is not an “employee” in other contexts.

To ensure CSJ activities qualify as training and not employment for the purpose of wage withholding requirements, including Federal Insurance Contributions Act (FICA), the Earned Income Tax Credit (EITC), and unemployment compensation taxes, the W-2 agency must confirm:

4. Employers do not receive an immediate benefit from the participant’s training;

The W-2 agency must use its best efforts to ensure that CSJ activities comply with the criteria listed above.

If a CSJ placement is determined to be employment under federal law, the State of Wisconsin, not the W-2 agency, is considered the employer for wage and tax purposes.

Prorated level	Unsubsidized work hours per week	Max CSJ activity hours per week	Max education and training hours per week	Monthly payment
1/3 CSJ	20-29	Up to 20	Up to 10	$218
1/2 CSJ	15-19	Up to 25	Up to 10	$327
2/3 CSJ	10-14	Up to 30	Up to 10	$435

7.4.1 Community Service Job (CSJ)