11.2.4 When to Verify Good Cause

A FEP must request written verification of good cause if a pattern of absences exists, and the FEP does not believe that a reasonable explanation has been given for the absences or the FEP believes that the participant is misusing the good cause policy. (See 11.2.4.1 for a definition of pattern of absences.)

A FEP must not request written verification verifying good cause for a pattern of absences if the FEP believes that there is a reasonable explanation given for the absences and the FEP does not believe that the participant is misusing the good cause policy.

In addition, the FEP must not request written verification verifying good cause for absences that do not meet the definition of a pattern of absences. For example, W-2 participants will occasionally need to remain home to care for an ill child who has to miss school or daycare. Participants will also miss assigned activities due to their own unexpected illness. In addition to these types of situations, the FEP must not require written documentation verifying good cause if a participant misses assigned activities due to an already documented chronic illness, e.g., chronic asthma, panic attacks, etc., or known family circumstance, e.g., disabled child, child with behavioral problems, homelessness, domestic violence, etc.

11.2.4.1 Pattern of Absences

If a pattern of absences occur, the FEP may require written good cause verification. A “pattern of absences” are absences that extend beyond 3 consecutive working days or are more than 5 working days in a rolling 30 calendar day period. An absence means being absent from any one activity. For example, if a participant is assigned to work experience and adult basic education on the same day and misses just one of those activities, this is considered an absence. If good cause is accepted for any of the absences, the good cause absences may still be considered as a part of the pattern.

If the person misses beyond 3 consecutive working days or misses more than 5 working days in a rolling 30 calendar day period, but the absences are for the same reason, e.g., car accident, child has flu, etc., this may be considered a reasonable explanation for missing beyond 3 consecutive days and written verification is not necessary. The FEP determines whether there is a reasonable explanation on a case-by-case basis in which the FEP’s knowledge, experience, and familiarity with the case and the community are factors.

EXAMPLE 1: A participant misses 3 consecutive working days of her assigned activities and calls in on the fourth day because of the illness of her children and explains that one after the other of her four children were ill with a bad flu. Although the absences constitute a pattern, the FEP does not have reason to believe that the participant is misusing the good cause policy. In this scenario, the FEP would not require written documentation of good cause for the missed activities.

EXAMPLE 2: A participant misses her assigned morning activity 3 consecutive working days because she felt sick. She has no chronic health problems and does not offer an adequate explanation of what was wrong with her. On the fourth day, the participant again calls and says that she is feeling ill and cannot attend her activities. In this scenario, the FEP may require written documentation of good cause for the missed activities because the participant’s absences constitute a pattern and the FEP has reason to believe that the participant may be misusing the good cause policy.

EXAMPLE 3: A participant misses 5 working days in a 30 calendar day period because of school appointments. She brings in written verification for 2 of the days but not all 5 days indicating that her child is undergoing an evaluation for suspected learning problems. The participant calls and says that she will miss the next 2 days for the same reason. Because the participant has missed 5 days, even though 2 of the days she was granted good cause, this does constitute a pattern. The FEP has reason to believe that the participant may be misusing the good cause policy because the participant has a history of not attending activities. In this case, the FEP may require written documentation verifying good cause.

EXAMPLE 4: A participant misses 2 consecutive days of activities because she is ill. These 2 absences are the first absences the participant has had in several months. Because this does not constitute a pattern, whether or not the FEP believes the participant is misusing the good cause policy, the FEP may not require written documentation verifying the good cause.

11.2.4.2 Verifying Good Cause

If the FEP determines that written verification is necessary for a pattern of absences, the FEP must first check in the Electronic Case File (ECF) to ensure that written verification does not already exist. Examples of written documentation include a signed medical statement, an update to existing medical information from a licensed physician or some other qualified assessing agency, etc. If it does not, the participant must be informed in writing of the verification items required, including the due date. The FEP must give the participant 7 working days from the date the good cause request is made to provide the written documentation. The FEP must document in PIN comments using the Good Cause Determination Comment Type why the written documentation verifying good cause is required.

FEPs must not penalize participants when they attempt to obtain the written verification and other entities delay their ability to obtain the necessary documents. If the individual does not have the power to produce verification, or if circumstances exist that make the verification requirements unduly burdensome, the W-2 agency must assist the participant in obtaining the necessary documents and the FEP must extend the verification due date. The verification due date may be extended for up to 30 calendar days from the date the good cause verification request is made. In some instances, the W-2 agency may seek the verification directly. (See 4.1.3)

The verification due date cannot be extended from 7 to 30 days at the point when the participant receives CWW letter NWSN, which informs participants of a 20% payment reduction. In these circumstances, the nonparticipation has occurred, the participant has had the opportunity to request good cause (within 7 working days of the nonparticipation) and provide any necessary verification of that good cause (within 7 working days of the request for verification, unless extended to up to 30 calendar days). The NWSN letter is sent and it provides a final, but narrow opportunity for the participant to provide good cause for the past nonparticipation.