7.4.2 W-2 Transition (W-2 T)

The W-2 Transition (W-2 T) employment position is for individuals who have been determined not ready for unsubsidized employment and unable to successfully participate in one of the other W-2 employment positions for reasons such as an individual’s incapacitation or the need to remain in the home to care for another W-2 group member who is incapacitated or disabled.

7.4.2.1 General W-2 T Participant Description Characteristics

Participants placed in a W-2 T must have a formal assessment, as described below, scheduled and documented in WWP within 30 calendar days of the W-2 T placement. (See 5.5.1) The FEP must not assume that participants who have a disability are unable to participate in an employment position other than W-2 T, including unsubsidized employment. The FEP may place a participant in a W-2 T when the participant is incapable of performing a CSJ, as determined by the W-2 agency, for reasons which may include:

1. The participant is determined, based on an independent assessment by a medical professional or similar qualified assessing agency or individual, to be or expected to be incapacitated for a period of at least 60 days. Examples of incapacitation that would warrant an assessment may include:

Section 5.5.4, Obtaining a Complete Assessment, describes the types of information that must be gathered through assessment and the methods for obtaining the information.

EXAMPLE 1: Ms. Anderson is a single parent with two children. She was a waitress until three months ago when her rheumatoid arthritis worsened to the level that she was no longer able to work. Ms. Anderson is placed in a W-2 T position and is referred for a vocational assessment. The results of the assessment show that with special sitting accommodations, rehabilitation and training, Ms. Anderson will be able to perform a sedentary job. Areas of employment recommended by the assessing agency include computer data entry, customer service, or telemarketing. Ms. Anderson and her FEP agree to revise her employability plan, emphasizing activities that will allow her to work towards a job in customer service. Her participation requirement is 27 hours per week in a physical rehabilitation program, which involves physical therapy and teaches independent mobility, plus three hours of work training. After completing three months of rehabilitation, Ms. Anderson is moved to a CSJ, where she is able to participate a full 40 hours per week in a combination of work training and education activities. Five months after placement in the CSJ, Ms. Anderson is successfully employed in a manufacturing company in their customer service department.

2. The participant is needed in the home to care for another member of the W-2 group who is ill or incapacitated. The following steps must be taken when determining the need for a W-2 adult to remain in the home to care for a family member:

a. Using the Need to Care for Disabled Family Member (10786) form (or an agency-developed form that, at a minimum, has the same elements), verify the incapacity/disability of the affected family member and the appropriateness of day/child care outside of the home through third party sources. The FEP may consider statements from sources such as medical professionals, the Social Security Administration, Family Support Program, Birth to Three Early Intervention Program, Program for Children with Special Health Care needs, and Exceptional Educational Needs Program. Supportive adult programs under the 51.42 service board or Independent Living Centers for a physical disability or mental health issues are other verification sources.

b. Determine whether day/child care outside the home is available for the disabled/incapacitated family member so that the participant can engage in work training activities outside the home. The Americans with Disabilities Act (ADA) requires that any day treatment or day care facility accommodate a child or elderly person and provide reasonable accommodations for individuals with disabilities. However, where a reasonable accommodation cannot be made or the care is not available, lack of adequate child care is a good cause reason for not participating in W-2 requirements outside the home. Written documentation from one or more local day/child care providers is sufficient verification that appropriate care is not available.

EXAMPLE 2: Ms. Johnson applies for W-2. Her daughter Kathy, age 8, is in an advanced stage of leukemia. Kathy has been hospitalized numerous times over the school year and has had extended absences from school. She has an extremely fragile immune system and can no longer be exposed to other children in a school or day care setting. The FEP places Ms. Johnson in a W-2 T employment position and opens the "CD-Caring for Disabled Child" participation status to care for her child with a disability. Ms. Johnson indicates to her FEP that her mother is available for two hours per week so she can also attend grief mental health counseling sessions, which is added to her EP.

7.4.2.2 W-2 T Participation Requirements

An in-depth formal assessment will determine the appropriate level of W-2 participation, the person’s ability to engage in specific work and training activities and the need for supportive services, accommodations, auxiliary aids or communication assistance. (See 5.5.1) Attendance and cooperation with an in-depth assessment may satisfy participation requirements pending the results of the formal assessment. A W-2 payment reduction cannot be imposed on a participant for declining to complete a formal assessment. (See 5.5.7)

Based on the results of the assessment the participant may be assigned up to 40 hours per week in activities which may include work training, other W-2 T activities and education and training.

W-2 T work training activities approved by the FEP may include activities such as a:

· Community rehabilitation program - a program that provides directly or facilitates the provision of vocational rehabilitation to individuals with disabilities and that enables an individual with a disability to maximize opportunities for employment. Services may include vocational assessment, job readiness training, job placement and on-the-job support targeted at individuals with disabilities. Assignable activities will vary depending on the focus of the program, but may include:

· AODA detoxification, assessment and treatment. Assignable activities may include AODA Counseling (CA) and AODA Assessment (AA) and Personal Development (PD);

· Mental health activities, as prescribed by an appropriate health care professional. Assignable activities may include Mental Health Assessment (AM) and Mental Health Counseling (CM);

· Counseling or physical rehabilitation activities. Assignable activities may include Physician’s Assessment (AL), Ongoing Medical/Personal Care (MP), Physical Rehabilitation (PR);

· Court ordered activities. Assignable activity is Court-Related/Legal Appointments (LA);

· Activities related to obtaining shelter or retaining safety in a domestic abuse situation or other activities needed to stabilize a family. Assignable activities may include Domestic Violence Assessment and Supportive Services (AV) and Personal Development (PD);

· Activities that will provide support for children with special needs. Assignable activity is Family Member Treatment/Counseling (FC); and

· Caring for a family member with an incapacity of such severity that without home care, the incapacitated member’s health and well-being would be significantly affected, as determined by the W-2 agency Reportable statuses are Caring for Other Family Member (CF) and Caring for Disabled Child (CD). (See 6.4.1)

· Through the assignment of up to 12 hours per week of allowable education and training (see 8.2.2.2);

· By aggregating education and training hours to enable a participant to engage in an education and training program that a participant can complete within a one year period with participation in up to 516 hours of education and training activity (see 8.2.2.3); or

· Through participation in a full-time technical college education program (see 8.2.2.5).

7.4.2.3 Marginally Employed W-2 T Participants

A W-2 applicant or participant who is marginally employed in an unsubsidized job only a few hours per week may also be placed in a W-2 T placement when the participant has long-term, severe barriers to increasing the hours in the existing unsubsidized job or obtaining additional unsubsidized employment. In these instances, the FEP must schedule flexible activities around the unsubsidized employment. W-2 T assigned activities must be specifically designed to assist the applicant or participant in overcoming these severe barriers while maintaining flexibility and sensitivity.

EXAMPLE: Ms. Smith’s son Jason, age 8, has been diagnosed with a brain disorder. Jason is able to attend school most of the time, however, the school often asks Sue to remove Jason when he is uncontrollable. Appropriate child care is often not available during these periods. Ms. Smith is marginally employed and works approximately 10 hours per week in a small town pharmacy. Her employer has been sensitive to Ms. Smith’s need for a flexible, part-time job. This situation is not likely to change for some time. Ms. Smith’s FEP places her in a W-2 T position since she will not be able to move to full-time employment in a short period of time. The FEP includes her marginal unsubsidized employment on her EP and assigns Ms. Smith to 2 hours per week in a life skills motivational course. The FEP also opens the "CF-Caring for Other Family Member" participation status to care for her disabled child.

7.4.2.4 W-2 T and Work Training

The W-2 agency is responsible for the creation and management of work training sites that prepare W-2 T participants for unsubsidized employment. The agency must act as a liaison between providers and W-2 T participants when necessary.

· Offer part-time and flexible schedules to meet the special needs of participants;

· Provide or arrange any needed supportive services, accommodations, auxiliary aids or communication assistance.

The W-2 Agency must provide worker’s compensation coverage for all participants, except when the W-2 work training provider provides the coverage.

7.4.2.5 W-2 T Time Records

The participant is required to provide verification for education and training hours as well as other hours in W-2 T activities. See the TANF Work Participation Requirements appendix for guidelines on documenting and verifying W-2 activities.

7.4.2.6 W-2 T Payments

The W-2 agency will issue a monthly payment of $608 to the W-2 T participant if all participation requirements are met. The monthly payment of $608 will not be prorated or otherwise reduced if the hours assigned are less than 40 hours per week. Payments will be reduced by $5.00 for each hour that the participant fails without good cause to participate.