Program Eligibility & Referral Process San Diego Workforce Partnership, Inc. Adult Programs Team, Special Projects 3910 University Avenue, Suite 400 San Diego, CA 92105-1326 Phone: (619) 228-2900 Fax: (619) 538-1423 www.workforce.org i
SAN DIEGO WORKFORCE PARTNERSHIP BREAKING BARRIERS SAN DIEGO PROGRAM Table of Contents I. Overview... 1 II. Program Eligibility... 1 1. Eligibility Criteria... 1 2. Random Assignment Intake Process and Requirement... 2 III. Referral Process... 2 1. CalWORKs Referral Process... 2 2. San Diego County Behavioral Health Services (BHS) Referral Process... 3 3. Department of Rehabilitation (DOR) Referral Process... 3 IV. Eligibility and Certification Process... 4 1. Local Flexibility... 4 2. Eligibility Certification and Registration... 4 3. Procedures for Exiting Ineligible Participants... 5 4. Eligibility Verification Assurances... 5 5. Verification Process... 5 6. Equal Opportunity (EO) and Non Discrimination Policy, Attachments I-1,2... 5 7. Universal Participant Authorization Form (UPAF), Attachment H... 6 8. BBSD Customer Complaint Procedures Notice... 6 V. Documentation Methodology... 6 1. Documentary Evidence... 6 2. Telephone Verification/Document Inspection Form... 7 3. Document Inspection Form... 8 4. Applicant Statement... 8 VI. General Eligibility Requirements... 9 1. Authorization to Work in the United States... 10 2. Selective Service Registration... 10 3. Internal Review Process... 10 4. Exited Clients... 11 VII. Attachments... 11 Attachment A - Acceptable Documentation Table(s) Attachment B - Eligibility Certification & Review Form Attachment C - Telephone Verification/Document Inspection Form Attachment D - I-9 List of Acceptable Documentation i
Attachment E - Applicant Statement Attachment F - Customer Complaint Procedures Notice Attachment G - Multimedia Publicity Privacy Release Attachment H - Universal Participant Agreement Form (UPAF) Attachment I-1 - EEO English Version Attachment I-2 EEO Spanish Version Attachment J - Breaking Barriers San Diego Referral Form Attachment K - Welfare to Work (WTW) Referral Form Attachment L - Random Assignment Manual Attachment M - BBSD Eligibility Checklist Attachment N - BBSD Checklist ii
I. Overview Breaking Barriers San Diego Program Program Eligibility and Referral Process Breaking Barriers San Diego (BBSD) is a regional strategy designed to advance the economic well- being of San Diego s California Work Opportunity and Responsibility to Kids (CalWORKs) recipients and other low income individuals that have a disability. BBSD will implement the Individual Placement and Support (IPS) model of supported employment model and evaluate the program design with an independent third-party evaluation. BBSD is funded by the Department of Labor (DOL), Workforce Innovation Fund (WIF). The evaluation study will utilize a randomized control trial to enroll eligible clients to evaluate the effectiveness of IPS supported employment services between a control group and an intervention group. Clients who agree to participate in the study will be randomly assigned to either the control group or program group. The control group are clients not receiving services from BBSD, and a program group are clients receiving BBSD services. Random assignment will be conducted through the America s Job Center of California (AJCC) network. The sections below will provide details concerning eligibility and the random assignment process. All data for program services must be entered into the Management Information System (MIS) within five (5) business days of the transaction date. II. Program Eligibility 1. Eligibility Criteria The eligibility criteria that must be verified for the BBSD program and study is as follows: 18 years or older; and Have a physical, developmental, or mental disability; and Unemployed; and Right to work in the United States; and Register for Selective Service, if applicable. 1
In addition to the eligibility criteria above, the following eligibility qualifications must be verified for the BBSD program and study: Veteran; or An individual that receives services as described below: o Receive public assistance through CalWORKs; or o Participate in services with the Department of Rehabilitation; or o Participate in county-funded mental health, or alcohol and drug related supports. 2. Random Assignment Intake Process and Requirement The intake process for random assignment includes completing the following: Group or individual orientation; Informed Consent Form; and Input of baseline, contact information, and health assessment into the MIS. Note: All steps must be completed prior to random assignment. Please reference the Random Assignment Manual, Attachment L for futher guidance. Clients randomly assigned to the program group shall have their MIS enrollment and health assessment date as the date of random assignment. SDWP recognizes the health assessment may be conducted prior to the date of random assignment. Note: Client s assigned to the program group cannot be co-enrolled in Workforce Innovation Opportunity Act (WIOA) Individualized Services; client s receiving WIOA Career Services are acceptable and not consider WIOA co-enrollment. Client s assigned to the control are eligible for both WIOA individualized and careers services. III. Referral Process 1. CalWORKs Referral Process A CalWORKs recipient who has been identified or self-identifies as having a physical, developmental or mental disability, including behavioral health, and meets all other eligibility criteria is deemed eligible for BBSD. Staff will obtain the following support documentation: A Welfare To Work (WTW) referral form 27-114, Attachment K, or recent Notice of Action (NOA) within six months of eligibility determination is acceptable documentation. 2
Documentation of barriers to employment or disability. Please see Attachment A (Acceptable Documentation Table). 2. San Diego County Behavioral Health Services (BHS) Referral Process A potential client receiving services from a San Diego County behavioral health program, including substance abuse or mental health services, and meets all other eligibility criteria is deemed eligible for BBSD. Staff will work with BHS program staff to receive a BBSD referral form or verify enrollment in behavioral health services if potential client is self-referred. For behavioral health clients who also receive CalWORKs, BBSD staff will obtain a WTW referral form 27-114 or recent NOA within six months of eligibility determination. Staff will work with both the BHS provider and WTW Employment Case Manager for participants enrolled in the program group and provide monthly progress updates and ongoing communication regarding participation in BBSD. For clients who are also identified as DOR consumers, staff will verify enrollment with the Vocational Rehabilitation Counselor. 3. Department of Rehabilitation (DOR) Referral Process A potential client receiving services from DOR and meets all other eligibility criteria is deemed eligible for BBSD. BBSD staff will verify that potential clients are not receiving employment services with a DOR vendor. Staff will work with DOR staff to receive a BBSD/DOR referral form, Attachment M or verify enrollment in DOR if potential client is self-referred. For DOR clients who receive CalWORKs, BBSD staff will obtain a WTW referral form 27-114 or recent NOA within six months of eligibility determination. For clients who are also identified as receiving BHS services, staff will verify enrollment with the BHS provider. Note: AJCC BBSD contractors have ten (10) days from receipt of a referral to accept or deny referrals. 3
IV. Eligibility and Certification Process 1. Local Flexibility The local eligibility determination policies, procedures, interpretations, guidance and definitions that have been developed by the SDWP for the BBSD are included in this guideline. These guidelines are subject to change if the DOL, SDWP, or its Boards subsequently revise the eligibility criteria. In this event, the changes will be communicated to BBSD contractors through an operations issuance. 2. Eligibility Certification and Registration The Eligibility Certification and Registration process begins with eligibility determination and certification and ends with enrollment into BBSD. Collection of information during the eligibility certification process may be accomplished through methods that include electronic data transfer, personal interview, or a potential client s application. Once eligibility certification is completed and the potential client is certified eligible for the program, then enrollment into the BBSD program is necessary. Only the clients randomly assigned to the program group will be eligible for IPS supported employment services provided by the BBSD program. Once a client is enrolled and randomly assigned into the BBSD program, he/she will be classified as a "client" and will count in the performance, evaluation, and common measures. Veterans are excluded from random assignment. The MIS is part of maintaining compliance with the eligibility certification process, and to guard against serving ineligible participants. Enrollment of ineligible participants in BBSD program may result in disallowed costs for the SDWP, the BBSD contractor(s), and may negatively affect performance standards. Prior to intake and eligibility, BBSD staff shall verify in the MIS that the participant has not been previously randomly assigned as part of the BBSD evaluation study. Any participant assigned to the control group is not eligible for services provided by BBSD for the duration of the program. 4
3. Procedures for Exiting Ineligible Participants BBSD staff are responsible for taking immediate action to exit participants who establish eligibility by providing false information or fabricated documentation, as well as any who are found ineligible during a subsequent monitoring review. If ineligibility is not the result of the potential client falsifying information, BBSD staff must assist the potential client in obtaining referrals to applicable services, or services provided through other community resources, and/or through referrals to other local providers, to reduce any negative effects of the exit from BBSD program services. A letter verifying the exit from the program must be sent to the participant, with a copy maintained in his/her file, and a notation of the details of the exit indicated in the MIS case notes. 4. Eligibility Verification Assurances During the eligibility certification process, BBSD staff must ensure that: Documentation is uniform and standard; and The documentation burden for the potential client is limited to the minimum necessary to adequately verify BBSD eligibility. 5. Verification Process During the information collection, the potential client must provide documentation to verify all information required for determining eligibility. See Attachment A, (Lists of Acceptable Documentation Table(s). The verification process is required to determine and record the validity of the eligibility information collected. 6. Equal Opportunity (EO) and Non Discrimination Policy, Attachments I-1,2 All potential clients who apply for the BBSD program must be provided with a notice that BBSD program may not discriminated against a member of any protected class. A copy of the BBSD Equal Opportunity is the Law notice is available as Attachment I-1, in English, and Attachment I-2, in Spanish. 5
7. Universal Participant Authorization Form (UPAF), Attachment H BBSD UPAF is provided as Attachment H. This form has been created to collect each client s signature, which is required on various forms, onto one main form. Initials and signatures on this form have been authorized to take the place of a client s signature on the following forms: Authorization of release of records from various agencies and organizations; Receipt of Equal Opportunity (EO) is the Law and EO is the Law Supplement Notices; and Receipt of Customer Complaint Procedures Notice. 8. BBSD Customer Complaint Procedures Notice All BBSD clients must be provided with the BBSD Customer Complaint Procedure Notice with instructions and timelines for filling a program or criminal complaint. V. Documentation Methodology In the context of establishing eligibility, verification means to confirm an eligibility requirement through examination of official documents (i.e., birth certificates), public assistance records, or speaking with official representatives of cognizant agencies. Documentation means to maintain on-file physical evidence, which is obtained during the verification process. Such evidence would be copies of documents, completed Telephone/Document Inspection forms, and/or signed Applicant Statement, as described below. The definitions of these three methods are as follows: 1. Documentary Evidence Documentary Evidence is official written evidence of the applicant s circumstances as issued by a governmental agency, social service organization, or business entity. Photocopies (unless expressly prohibited on the document) must be made of the documents submitted at the time of eligibility certification. These copies are maintained in the client s file for subsequent monitoring reviews and/or audits by local or federal monitors. 6
2. Telephone Verification/Document Inspection Form A (Telephone Verification/Document Inspection Form), Attachment C, may also be used to document any eligibility criteria, except right-to-work, and Selective Service registration. This form is acceptable to use and is equally as valid as direct documentary evidence. The Telephone Verification/Document Inspection Form serves a dual purpose: This form is used to verify eligibility information for documenting a disability through phone contact with a governmental agency, social service organization, or business entity. Information recorded on this form must include all the applicable information, to enable a monitor or auditor to adequately verify eligibility (i.e. items to be verified, date and time of verification, document name, contact name, telephone numbers, addresses, intake worker s signature and date, etc.). For this form to be used as acceptable documentation all applicable parts of the form must be completed. Examples of cognizant agencies that may assist in verifying eligibility information via telephone contact are: Local Schools; Social Security Administration; Veterans Administration; Medical and Health Facilities; Vocational Rehabilitation/DOR Facilities; Alcohol and Drug/Mental Health Facilities; Housing Authorities; Homeless Shelters; Judicial Agencies and Institutions; Employers; or Other state or local government agencies. 7
3. Document Inspection Form The Telephone Verification/Document Inspection Form may also be used in cases where documents may not be copied, and/or if intake is being conducted in the field and access to a copier is not available. All sections of the form must be completed if used as acceptable documentation. Note: The Telephone Verification/Documentation Inspection Form cannot be used for verification of right-to-work in the United States or Selective Service. When documentation of BBSD program eligibility criteria is accomplished by telephone or document inspection, the staff person verifying the information is required to use the standardized form included in this issuance, in order to establish uniformity for monitoring and auditing purposes. 4. Applicant Statement SDWP allows for the use of Applicant Statements, Attachment E, to document those items which, in some cases, are not verifiable, or which may cause undue hardship for individuals to obtain. An Applicant Statement is a self-attestation of the required eligibility information and may be used only after all reasonable attempts to secure official documentation have been made and failed. These attempts must be documented with a case note in the MIS. If all specifications for the use of the Applicant Statement noted in this section are not adhered to, the Applicant Statement is voided and the item(s) it is supposed to verify is not verified. This can result in disallowed cost and the the need to exit clients who are consequently not eligible. The Applicant Statement provided as Attachment E in this policy has a statement on the bottom, directing staff to explain attempts to obtain documentary evidence and the reason for failed attempts to get actual documents or telephone verification. These efforts must be documented in the MIS case notes or hard file if MIS is not available. Note: SDWP does not allow the use of the Applicant Statement to verify the following required information: Authorization to work in the United States; 8
Military Selective Service registration or exemption; Social Security Number (SSN); Age; Unemployment Insurance (UI) eligibility or exhaustion; Receipt of cash public assistance; Receipt or determination of eligibility for food stamps; Foster child verification (youth); Veteran and covered spouse status for veteran s priority; and Residency. When the Applicant Statement is used, case notes in the MIS must indicate what attempts have been made (and failed) to obtain documentary evidence. There must be a notation in the MIS case notes indicating what documentation staff attempted to get and an explanation of why the attempt(s) failed. The case note may explain that information was not readily available, or would cause a delay in providing services, or would cause undue hardship for the potential client to obtain, or documentation sources refused to provide the information, etc. SDWP s position on the use of Applicant Statements is to assist people who are low-income and may have difficulty finding and keeping self-sustaining employment. It is not the intention of this program to discourage participation by imposing difficult documentation and verification requirements. VI. General Eligibility Requirements In order to participate in the BBSD, clients must provide the following information: 1. A valid Social Security Number (SSN); 2. Proof of age; and 3. Selective Service Registration, if applicable. Official documents must be provided or obtained to verify the validity of these items. An Applicant Statement can be used to verify general eligibility requirements with the exception of 9
right- to- work, and Selective Service. Potential clients who self-attest eligibility requirements and complete the appropriate applicant statement can be enrolled into the program. Note: Social Security Number (SSN) Individuals who have no SSN or who refuse to provide it will not be eligible for the BBSD program. 1. Authorization to Work in the United States Participation in programs and activities assisted in whole or in part under BBSD program shall be open to citizens and nationals of the United States, lawfully admitted refugees and parolees, and other individuals authorized to work in the United States. Therefore, all persons applying for BBSD program eligibility must prove that they have the right- to- work in the United States (U.S.). The Form I-9 is provided as Attachment D. Please ensure that you are following the instructions from this version of the form in documenting right-to-work. A new Employer Handbook has also been issued by USCIS and can be accessed at: Download Form M-274, Handbook for Employers. A copy of the revised I-9 is also included in the Handbook. 2. Selective Service Registration BBSD contractors shall adhere to the Selective Service Registration requirements as outlined in the Workforce Service Directive (WSD1506) http://www.edd.ca.gov/jobs_and_training//pubs/wsd15-06.pdf 3. Internal Review Process The final step in the eligibility certification process is the second review, conducted by someone other than the person who initially deemed the client eligible, to ensure that eligibility was properly determined. The second review consists of a review of the documentation used to verify the required eligibility criteria to ensure it is correct and complete. Second review must be conducted with Attachment B, (Eligibility Certification & Review Form), and be completed within 5 days after random assignment. In the event a participant has been determined ineligible through the second review process, the BBSD Program Specialist and Manager of Special Projects must be notified immediately via email. 10
Once the 5 days after random assignment have expired, no further changes may be made to the information that was used to determine eligibility, unless the BBSD staff making the change indicates the reason for the change in the MIS case notes. Note: Please refer to Attachment N, BBSD Eligibility Checklist, as a tool to assist in determing if a potential client meets the eligibility threshold. 4. Exited Clients Once a client exits the BBSD program and chooses to re-engage in services, the original eligibility determination applies. VII. Attachments Attachment A- Lists of Acceptable Documentation Table(s) Attachment B- Eligibility Certification & Review Form Attachment C- Telephone Verification/Document Inspection Form Attachment D- I-9 Form Attachment E- Applicant Statement Attachment F- Customer Complaint Procedures Notice Attachment G- Multimedia Publicity Privacy Release Attachment H- Universal Participant Agreement Form (UPAF) Attachment I-1 EEO English Version Attachment I-2 EEO Spanish Version Attachment J-Breaking Barriers San Diegio Referral Form Attachment K- Welfare to Work (WTW) Referral Form Attachment L- Random Assignment Manual Attachment M- Breaking Barriers Department of Rehabilition Referral Form Attachment N- BBSD Eligibility Checklist 11