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Wisconsin Department of Children and Families Wisconsin Works (W-2) Manual |
18.2.6.1 RCA Eligibility Verification Requirements
18.2.6.1.2 Information Requiring Eligibility Verification
18.2.6.1.3 Requesting Verification from RCA Participants
18.2.6.1.4 Frequency of Verification
18.2.6.1.5 Income and Eligibility Verification System (IEVS) and Data Exchange (DX)
18.2.6.2 Requesting and Protecting RCA Participant Information
18.2.6.2.1 Requesting Information from Third Party Sources
18.2.6.2.2 Protecting RCA Participant Information
18.2.6.3 Documenting RCA Participant Information
18.2.6.3.1 Record of Verification
18.2.6.4 Storing RCA Participant Information
18.2.6.8 Requirements for RCA Notices
18.2.6.9 Payment Issuance and Reimbursement
18.2.6.10 RCA Overpayments and Underpayments
The W-2 agency must verify financial and nonfinancial information provided by the members of the RCA assistance group to determine whether the group qualifies for or remains eligible for RCA.
A list of eligibility criteria along with suggested sources of allowable verification can be found in section 4.1.2.
Whenever possible, the FEP should attempt to verify eligibility information via CARES, data exchange and ECF. If that is not possible, the applicant or participant is responsible for obtaining verification of information that is necessary and appropriate in order for the W-2 agency to make a correct eligibility determination. The applicant or participant has 7 working days from the date the verification request is made to provide the needed verification. The participant must be informed in writing of the verification items required, including the due date.
If extenuating circumstances exist that make the verification requirements unduly burdensome or the verification submitted by the individual is questionable or contradictory, the W-2 agency may extend the verification due date. For RCA applicants, the verification due date may be extended up to 30 days from the date the agency receives a signed Wisconsin Works (W-2) and Related Programs Registration (14880). (Keep in mind, though, that federal regulations require an RCA eligibility determination to be made within 30 days of the date of application). For RCA participants, the verification due date may be extended for up to 30 days from the date of the initial request for verification.
If the individual has made a reasonable effort and cannot obtain required verification, does not have the power to produce verification, or requires assistance to do so, the W-2 agency must assist the individual. If the agency is unable to assist, the FEP must not deny an application or close a case based on the information that could not be obtained. The agency must use the available information to process the case and then reassess the case when the requested information is received.
If the applicant is able to produce the information but refuses or fails to do so, he or she is not eligible and the case must be denied or closed.
Questionable verification or reporting supplied by applicants or participants must be referred for fraud investigation. (See 13.3.1)
There are a number of items that must only be verified once per lifetime, such as:
· Identity
· Social Security Number and
· Birth Date
To assure that these items are only verified once, the FEP must scan copies of the documents used to verify these items into ECF in the appropriate folder based upon the document type. Because RCA applicants may be applying for other public benefits such as FoodShare, the FEP should check ECF for necessary verification before requesting these from the RCA applicant.
Other eligibility criteria should be reviewed when new information is reported or received through a data exchange. (See 18.2.6.1.5)
See 4.1.5 for information on the systems used and required agency action.
While an applicant or participant has primary responsibility for obtaining verification, a W-2 agency has statutory authority [s. 49.143(5)] to request information from any person it deems appropriate and necessary for the administration of RCA. By signing the application, the individual acknowledges that the agency may request information from a third party unless the information is considered confidential.
Cooperation of the third party is expected within 7 working days of the agency’s request. The W-2 agency may extend the 7 working day time limit if it is unduly burdensome. The statute does not provide for compensation for the third party.
Applicants and participants must not be penalized when a third party fails to cooperate with a verification request. The FEP must not delay eligibility determination while waiting for information from a third party. Instead, the FEP must use the best available information, including consulting with appropriate agencies at the time of application.
Eligibility must be reassessed when information from third party sources is received.
During the application process, the FEP may refer the applicant for screenings or assessments, some of which require information from a third party source. However, referrals for screenings and assessments are not eligibility requirements and are therefore not subject to verification time lines discussed here.
When requesting confidential information, the FEP must use the Authorization for Disclosure of Confidential Information (10779). This form meets federal and state requirements for the confidential release of information from treatment providers, including Alcohol and Other Drug (AODA) treatment, mental health treatment, domestic violence counseling, HIV/AIDS, and medical conditions.
Follow the guidelines in section 4.2.2 regarding the safeguarding of RCA participants’ information.
As in the W-2 program, RCA eligibility information requiring verification must be either “validated” or “documented.” See 4.2.2 for guidelines on validation and documentation.
Workers processing RCA cases should follow the guidelines on case comment usage found in section 4.3.3.
The standards regarding storage of W-2 participants’ data also applies to RCA participants. See the following parts of the W-2 manual for more information:
· Electronic Case File (ECF) (See 4.4.1)
· Scanning Requirements (See 4.4.2)
· Record Retention Requirements (See 4.4.3)
· Access to ECF by an Authorized Representative (See 4.4.4)
· Scanning Consistency Within an Agency (See 4.4.5)
· Storing Confidential Information (See 4.4.6)
The W-2 agency is responsible for ensuring the integrity of the RCA program that it administers. As with the W-2 program, the W-2 agency must accomplish this responsibility by operating a fraud prevention program to identify and prevent errors/fraud at application, and investigating or referring possible fraud for investigation.
Fraud in the RCA program is defined as anyone who, with knowledge and purpose, makes false statements, suppresses facts, misrepresents circumstances, or fails to report a change in circumstance in order to obtain an RCA payment. An example of participant fraud is when an individual reports being unemployed during a period of time an employer reported earnings for that individual. However, it is important to keep in mind (especially for refugee populations) that a misstatement by an individual due to the individual’s misunderstanding on what constitutes income may not be considered fraud.
When investigating possible fraud, the agency must give the individual adequate notice and opportunity to respond to and, if necessary, appeal the allegation.
See also 13.2.1 for guidance on preventing fraud by using front-end verification and 13.3.1 for more information on fraud investigation.
The participant’s RCA change-reporting responsibilities are detailed in the “Responsibilities” section of the RCA Participation Agreement (15011), which the participant is required to sign. RCA participants are required to notify the W-2 agency of certain changes (including changes in income, assets and family structure) within 10 calendar days of their occurrence. Additionally, participants must inform the agency of any changes in their mailing address or phone number. The agency must respond to reports in a timely manner and keep case data up to date.
When a refugee reaches the twelve month time limit for RCA eligibility, review the case file to determine possible eligibility for W-2 due to changed circumstances.
Due to RCA’s short eligibility period there is no required review, but eligibility should be reviewed whenever a participant is scheduled for a regular review of any other benefits administered by the W-2 agency.
In order to comply with federal RCA policy regarding notices, refer to the following guidelines:
· The client must sign the RCA Participation Agreement (15011) which communicates RCA time limits, employment and training requirements, consequences of nonparticipation, and client rights.
· Use the RCA Eligibility Notice of Decision (13753) to inform an applicant that he or she is eligible for RCA.
· Use the RCA Ineligibility Notice of Decision (13758) to inform an applicant that he or she is ineligible for RCA.
· A notice of RCA termination must be provided at least 10 days prior to the termination date. Remember that a W-2 determination must be made when RCA is terminated due to time expiration (see 18.2.6.6).
· Use the RCA Sanctions Notice of Decision (13770) to inform a client that a sanction is being imposed on his or her RCA case.
· Use the RCA Work Programs Notice of Referral (13768) to inform clients of referrals to work programs.
· Use the Sample RCA Overpayment Notice (15725) to notify an RCA client of an overpayment and the RCA Repayment Agreement (15721) to record an RCA repayment agreement between the client and the agency.
The forms listed above are available in English and several refugee languages common in Wisconsin and can all be found on the DCF Forms webpage. If a form is not available in an appropriate language for a refugee client, another acceptable means of communication must be used, such as verbal translation into the refugee’s native language.
Since CARES is not programmed to support the RCA program, W-2 agencies must issue RCA payments manually. The initial RCA payment must be made within five days of the eligibility determination (see 18.2.2.5) and each payment thereafter must be made by the first of the month. Refer to 18.2.4.2 for guidance on pro-rating RCA payments.
W-2 agencies are reimbursed for the RCA payments and related administrative costs separate from their W-2 contract allocation. W-2 agencies must utilize the System for Payments and Reports of Contracts (SPARC) to submit RCA expenses to DCF. SPARC instructions, account information, and reports can be found on the SPARC webpage..
RCA clients can be placed into either subsidized employment (in accordance with the rules governing W-2 Trial Employment Match Program (TEMP)) (see 7.3.0), Community Service Jobs (CSJ) (see 7.4.1), or W-2 Transitions (W-2 T (see 7.4.2)) (see 18.2.2.4). RCA payment amounts are consistent with W-2 payment amounts for these placements (see 10.1)
W-2 agencies must maintain a procedure to ensure the recovery of overpayments and correction of underpayments for the RCA program.
History: Release 22-08; Release 14-03; Release 13-03.