7.4.1 Community Service Jobs (CSJ)

The CSJ placement is for applicants and ongoing W-2 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.

7.4.1.1 General CSJ Participant Description Characteristics

· 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.

EXAMPLE 1: Jane has two children (ages 1 and 5) and a very limited work history. She worked a year and a half ago at a restaurant when she was forced to quit due to a difficult pregnancy. She has been off work since that time. She completed her 12th grade of school but did not receive her diploma because she failed to complete one class. She is eager to get back into the workforce, but she is worried that her limited experience and lack of high school diploma will prevent her from getting a job. She is interested in becoming a child care provider. Jane applied for W-2. The RSResource Specialist assigned Jane to up-front job search and the job developer connected Jane to local child care employers who had openings. Jane was not hired because of her lack of experience and no high school diploma. The FEPFinancial and Employment Planner places Jane in a CSJ. During her CSJ, Jane will be assigned to 10 hours per week of education in order to complete her high school course work and obtain her diploma. The FEP will also assign Jane to 30 hours of work experience at the Job Center day care site.

EXAMPLE 2: Jennifer applied for W-2. She is 24 years old, has a high school diploma, and she completed a clerical training course a year ago but has never had a full-time job. Her seven-year-old son Jason has severe behavioral problems and has recently been diagnosed with Attention Deficit Disorder (ADD). Jason's doctor is currently trying to get Jason's condition stabilized using medication. Jason goes to school for a full day, but about two to three times a month Jennifer is called to pick him up because of bad behavior. Jennifer wants to work and put her clerical skills to use, but doesn't see how she can until Jason's medication stabilizes his behavior. The FEP places Jennifer in a CSJ. The FEP designs a CSJ placement to allow Jennifer time to practice her clerical skills and provide flexibility for her to care for her son. In order to do this, the FEP sets up a CSJ worksite in the front office of Jason's school so that she is readily available if Jason begins to act out. The school is understanding of Jennifer's situation and allows her flexibility to care for her son whenever necessary. Once Jason's medication stabilizes his behavior and Jennifer has the necessary clerical experience, the FEP will focus on moving Jennifer to an unsubsidized job.

7.4.1.2 CSJ Participation Requirements

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.

· 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 8.3.2.3);

· Through participation in a full-time technical college education program (see 8.3.2.5); 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 8.3.2.1).

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

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.)

7.4.1.3 Kinds of CSJ Work Site Placements

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:

· 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.

7.4.1.4 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:

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 8.3.2.4.

7.4.1.4.1 General Prorated CSJ Participant Description Characteristics

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;

EXAMPLE 1: Brenda completed specialized manufacturing training. Shortly after completing her training, the two major manufacturing plants in Brenda’s area announced large lay-offs. There were no manufacturing jobs in town, but Brenda was able to secure a job at a local fast food restaurant working 23 hours per week. Unable to support her family with the income, Brenda applied for W-2. After a thorough assessment and an unsuccessful job search, the FEP determines that Brenda will not be able to increase her hours at work or obtain unsubsidized employment because the local job market for manufacturing workers is extremely limited. Also, Brenda lacks other skills that would allow her to compete for other available jobs in the local labor market. However, Brenda believes that she can compete for a full-time supervisor position at the fast food restaurant if she finishes her final GED courses. Brenda is assigned to GED courses in the evenings for 10 hours per week and to job search for 7 hours per week during the day. Her 1/3 CSJ payment, based on less than 10 hours of work activity per week, is $230.

EXAMPLE 2: Maria is a single mom with two teenagers. She works 20 hours per week as a program assistant for an insurance company. Maria has a physical disability which causes her severe pain and is preventing her from increasing her work hours. Maria is unable to support her family on her current income and applies for assistance from W-2. After receiving appropriate documentation from her doctor concerning her work limitations and abilities, 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 a college-based writing workshop over the internet for 4 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 $230 per month.

7.4.1.4.2 Prorated CSJ Participation Requirements

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.

7.4.1.4.3 Prorated CSJ Payments

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)

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

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.

7.4.1.6 CSJ Administration

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.

· 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.

· 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;

· Providing worker’s compensation coverage for all participants, except when the W-2 work training provider provides the coverage; and

7.4.1.7 Attendance Records

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.

7.4.1.8 CSJ Placements as Employment

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.

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.”

7.4.1 Community Service Job (CSJ)