Wisconsin Department of Children and Families
Wisconsin Works (W-2) Manual
22.214.171.124 General CSJ Participant Description Characteristics
126.96.36.199 CSJ Participation Requirements
188.8.131.52 Kinds of CSJ Work Site Placements
184.108.40.206 Prorated CSJs
220.127.116.11.1 General Prorated CSJ Participant Description Characteristics
18.104.22.168.2 Prorated CSJ Participation Requirements
22.214.171.124.3 Prorated CSJ Payments
126.96.36.199 CSJ Placements for Parents Temporarily Unable to Care for Their Children
188.8.131.52 CSJ Administration
184.108.40.206 Attendance Records
220.127.116.11 CSJ Placements as Employment
The CSJCommunity Service Job placement is for applicants and ongoing W-2Wisconsin Works participants who are not ready for unsubsidized employment. A CSJ placement provides the opportunity to practice work habits and skills that are necessary to succeed in any regular job environment, including punctuality, reliability, work social skills, and more. CSJ work site providers are expected to offer an environment which generally replicates regular employment, realizing that job coaching and mentoring may be needed to help the participant succeed. An individual is permitted to participate in more than one CSJ for a cumulative total of no more than 24 months. (See 2.10.3) A participant placed in a CSJ receives a monthly payment of $653 for full-time participation.
Persons placed in CSJs may have:
· Little or no work history;
· No evidence of reliable work habits;
· A work history with frequent voluntary quits or terminations;
· Physical or mental conditions or other personal limitations to regular employment; or
· Domestic violence, temporary illness or incapacity of self, family member, or other family crises.
CSJ participants are 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.
Education and training may be assigned:
· Up to 10 hours per week of allowable education and training (see 18.104.22.168);
· By aggregating education and training hours to enable a participant to engage in an education and training program that can be completed within a one year period (see 22.214.171.124);
· Through participation in a full-time technical college education program (see 126.96.36.199); or
· 18- or 19-year-olds who do not have a high school diploma or equivalent, can attend high school or enroll in a course of study meeting the standards either full or part-time (see 188.8.131.52).
CSJ work training hours countable toward the maximum 40 hours of activity as approved by the FEP may include:
· Work experience (WE);
· Training activities conducted at the CSJ work training site;
· Other assigned work training activities, such as;
o Job search activities (ES);
o Vocational rehabilitation (VA, VE, VL) and
o Meetings with child support agency staff, social workers, health care professionals or other meetings approved by the FEP and necessary to prepare a participant for employment (Activity Codes may vary.)
CSJ work sites may be with public, private non-profit and private for-profit employers. Each CSJ placement may be scheduled for up to six months with an opportunity for a three month extension. The following is a sample list of entities which may offer opportunities for CSJ work sites:
1. Municipal or other government - Jobs with easily expanded work crews.
· Example employers: housing authorities, school systems, parks and recreation, and sanitation departments
· Example job tasks: public housing painting and preparation, maintenance of parks or other facilities, city gardening, neighborhood watch patrol, clean up of city property or vacant lots, graffiti removal
2. Community-based organizations and government agencies - Participants proven to be reliable in the positions listed in the category above, but are still not ready for private employment, may be placed into these positions.
· Example employers: community non-profits, religious organizations, hospitals, schools, government agencies
· Example job tasks: health aide, clerical or administrative aide, child care aide, teacher's aide, personal assistant, driver, outreach worker in languages other than English, elder or youth services worker
3. Contract organizations - Private or public companies which bid for contracted services.
· Example employers: private non-profits, W-2 agencies, specialized for-profits such as industrial laundry, packaging and distribution, recycling recovery, cleaning and maintenance.
· Example job tasks: same as community-based organizations and other government.
Keep in mind that participants placed in positions may have to pass criminal back ground checks to work in certain facilities or positions.
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:
1/3 CSJ: Participants placed into 1/3 CSJs receive a payment of $218 for up to 20 hours of activity per week which may include a combination of work training and a maximum of 10 hours of education and training activities. (Participant working in unsubsidized employment 20 to 29 hours per week)
1/2 CSJ: Participants placed into 1/2 CSJs receive a payment of $327 for up to 25 hours of activity per week which may include a combination of work training and a maximum of 10 hours of education and training activities. (Participant working in unsubsidized employment 15 to 19 hours per week)
2/3 CSJ: Participants placed into 2/3 CSJs receive a payment of $435 for up to 30 hours of activity per week which may include a combination of work training and a maximum of 10 hours of education and training activities. (Participant working in unsubsidized employment 10 to 14 hours per week)
The total combined number of hours of activities and unsubsidized employment must not exceed 40 hours per week for anybody 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 the aggregated education and training policy with the prorated CSJ policy, see 184.108.40.206.
A prorated CSJ placement may be appropriate for individuals with limitations (or barriers) to full-time employment, such as:
· Barriers to increased unsubsidized employment opportunities which cannot be addressed through supportive services;
· A lack of skills to be competitive for available jobs;
· A sporadic work history;
· Little evidence of reliable work habits;
· No high school diploma, GED or HSED; and
· A work history with frequent voluntary quits or terminations.
CSJ participants eligible for a prorated CSJ payment are also expected to participate up to 40 hours per week in a combination of hours working in their jobs, work training activities and education and training activities. 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. When a participant's limitations are severe enough, the FEP should work closely with the assessing agency or medical professional to determine the types of activities the participant can reasonably perform. However, these activities must be allowable work training hours, such as vocational rehabilitation, meeting with social workers and health care professionals, etc. Participants must be assigned CSJ activities that do not interfere with the hours they are expected to work in their jobs.
Initial and ongoing payments are issued according to current W-2 payment policies and procedures. (See Chapter 10) Payment reductions are applied according to current W-2 payment reduction policies and procedures. (See Chapter 11) There is no separate prorated CSJ 24-month time limit. The CSJ 24-month time limit type will be affected regardless of whether the participant is in a prorated or a full CSJ. (See 7.4.1)
CSJ participants who, for medical reasons determined by a qualified assessing agency or individual, 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. The participation requirement will be to cooperate with the prescribed treatment plan. In most cases the Physical Rehabilitation (PR) activity code will be used during this time frame.
The W-2 agency is responsible for identifying, creating and managing CSJ positions that prepare CSJ participants for unsubsidized employment. The agency may contract for all or part of the operations.
1. CSJ positions must:
· Replicate actual conditions of work;
· Have responsibilities and expectations similar to unsubsidized employees to the extent feasible;
· Have a work training site supervisor. The work training site supervisor must provide a structured work environment to include close supervision and a willingness to 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, and
· Serve a useful public purpose or be a project of which the costs are partially or wholly offset by revenue generated from it.
If a W-2 agency develops a community service job worksite with a for-profit organization, there must be some agreement in place that the organization, using revenue or profit generated by the use of the CSJ participants, reimburses the agency for costs associated with the CSJ. This can include the organization using the profit to provide on-the-job training that is valuable to the participant or the organization may make a payment back to the W-2 agency to cover some of the administrative costs of the CSJ.
2. Management of CSJ positions include:
· Obtaining new work training sites;
· Maintaining relationships with existing providers;
· Creating CSJ placements within the W-2 agency;
· Ensuring that an adequate number of CSJs exist;
· Providing special or additional supervision of CSJ participants at the work training site when necessary;
· Providing or arranging for reasonable accommodations, translator or other supportive services;
· Acting as a liaison between work training providers and CSJ participants;
· Maintaining and updating an inventory of CSJ work training sites;
· Providing worker’s compensation coverage for all participants, except when the W-2 work training provider provides the coverage; and
· Requiring all work training sites complete the form Wisconsin Works (W-2) Work Training Site Agreement (10792).
The CSJ work training provider is responsible for keeping hourly time records and reporting nonparticipation to the FEP as it occurs. See the TANF Work Participation Requirements appendix for guidelines on documenting and verifying W-2 activities.
The W-2 agency will issue a monthly payment of $653 to the CSJ participant if all participation requirements are met. The monthly payment of $653 will 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.
The U.S. Department of Labor has stated that all federal employment laws apply to welfare employment and training participants, the coverage of this law is intended to be very broad and in some cases to cover a person who is not an “employee” in other contexts.
The W-2 Agency should conform to the standards described below for ensuring that a CSJ activity qualifies as “training” rather than “employment” for the purposes of wage withholding requirements (including FICA), the Earned Income Tax Credit (EITC), and unemployment compensation taxes.
· The training is similar to that given in a vocational school;
· The training is for the benefit of the trainees;
· Trainees do not displace regular employees;
· Employers derive no immediate advantage from the trainees’ activities;
· Trainees are not entitled to a job after the training is completed; and
· Employers and trainees understand that the trainee is not paid.
If there should be a finding that a particular CSJ activity is “employment” which results in liability for wage withholding or EITC payments under federal law, the individual is an employee of the state rather than the W-2 agency. It is the obligation of the W-2 agency, in following this policy, to use its best efforts to ensure that CSJ activities comply with the criteria listed above for “training.”
History: Release 22-09; Release 13-03; Release 12-05.