Upon review of the current WAC, copied in full below, the necessity of the SSN for service eligibility and financial aid eligibility was clear.
We will continue to ask questions of DSHS, but it would appear that the requirement of a SSN is more than an administrative function to process financial aid.
It would seem parents without an SSN would not be required to fulfill a work component, and therefore are also not eligible for tuition assistance as a TANF recipient.
We have continued to follow up with DSHS and have posed an inquiry regarding the ability to serve parents who have not yet been provided a social security number.
Previously, we had been advised there would be either a new SSN number provided (as in the case of relocated domestic violence victims) or one issued at the time services are rendered(in the case of human trafficking victims).
Here is what WAC 388-476-0005, which governs SSN requirements, says:
WAC 388-476-0005 Social Security number requirements.
(1) With certain exceptions, each person who applies for or receives cash, medical or food assistance benefits must provide to the department a Social Security number (SSN), or numbers if more than one has been issued.
(2) If the person is unable to provide the SSN, either because it is not known or has not been issued, the person must:
(a) Apply for the SSN;
(b) Provide proof that the SSN has been applied for; and
(c) Provide the SSN when it is received.
(3) Assistance will not be delayed, denied or terminated pending the issuance of an SSN by the Social Security Administration. However, a person who does not comply with these requirements is not eligible for assistance.
(4) For cash, medical, and food assistance benefits, a person cannot be disqualified from receiving benefits for refusing to apply for or supply an SSN based on religious grounds.
(5) For food assistance programs:
(a) A person can receive benefits for the month of application and the following month if the person attempted to apply for the SSN and made every effort to provide the needed information to the Social Security Administration.
(b) A newborn may receive benefits for up to six months from the date of birth if the household is unable to provide proof of application for an SSN at the time of birth.
(6) For medical programs, a newborn as described in WAC 388-505-0210(1) is eligible for categorically needy (CN) medical without meeting the SSN requirement until the baby's first birthday.
(7) There is no SSN requirement for the following programs:
(a) The consolidated emergency assistance program;
(b) The refugee cash and medical assistance program;
(c) The alien emergency medical program;
(d) The state-funded pregnant woman program; and
(e) Detoxification services.
Tuesday, August 31, 2010
College Success Foundation Scholarships
These scholarships can be used by WF and low-income students to continue their college educations beyond what WF can provide.
Help your students persist! Help them transition to the next step!
Here is the contact information for Teresa Kimball. She can help you get in touch with her counterpart at the Educational Service District nearest you. The application and more information about the program is below.
Theresa Kimball
College Bound Scholarship Counselor
ESD 113 (serving Thurston, Lewis, Mason, Pacific and Grays Harbor counties)
Email: tkimball@collegesuccessfoundation.org
Cell Phone: 360-701-9608
ESD address: 601 McPhee Road SW, Olympia WA 98502-5080
College Success Foundation
www.collegesuccessfoundation.org
In partnership with the Higher Education Coordinating Board (HECB)
www.hecb.wa.gov
College Bound Scholarship Program Q&A and Application
www.hecb.wa.gov/collegebound
Help your students persist! Help them transition to the next step!
Here is the contact information for Teresa Kimball. She can help you get in touch with her counterpart at the Educational Service District nearest you. The application and more information about the program is below.
Theresa Kimball
College Bound Scholarship Counselor
ESD 113 (serving Thurston, Lewis, Mason, Pacific and Grays Harbor counties)
Email: tkimball@collegesuccessfoundation.org
Cell Phone: 360-701-9608
ESD address: 601 McPhee Road SW, Olympia WA 98502-5080
College Success Foundation
www.collegesuccessfoundation.org
In partnership with the Higher Education Coordinating Board (HECB)
www.hecb.wa.gov
College Bound Scholarship Program Q&A and Application
www.hecb.wa.gov/collegebound
Financial Literacy: www.MyMoney.gov
Below is a link to a new website that can assist families with developing financial literacy.
Several years ago there was legislation requiring that the WorkFirst partnership create a list of all financial literacy training opportunities and that the resources be made available to distribute to families upon their request.
The enhanced comprehensive evaluation still includes a question asking if this is information a family may need to assist in stabilizing their circumstances.
This online resource can be shared with your partners to add to the local resource list or it can potentially be incorporated into our Life Skills classes. As this incorporates a more universal approach it could also be of benefit for Food Stamp recipients and/or the student body at large.
The Financial Literacy and Education Commission (FLEC) announced the launch of its redesigned financial literacy education website,
www.MyMoney.gov.
Several years ago there was legislation requiring that the WorkFirst partnership create a list of all financial literacy training opportunities and that the resources be made available to distribute to families upon their request.
The enhanced comprehensive evaluation still includes a question asking if this is information a family may need to assist in stabilizing their circumstances.
This online resource can be shared with your partners to add to the local resource list or it can potentially be incorporated into our Life Skills classes. As this incorporates a more universal approach it could also be of benefit for Food Stamp recipients and/or the student body at large.
The Financial Literacy and Education Commission (FLEC) announced the launch of its redesigned financial literacy education website,
www.MyMoney.gov.
Archiving Records: Does the State Board have a standard schedule for us to follow in terms of how many years of student files must be retained?
Guidance for WorkFirst records retention is included in the WorkFirst Delivery Agreement Plan Guidance document. Additional guidance may be found on the web(address noted within the plan guidance).
You should also check with your Registrar to identify appropriate college policy for relevant document retention.
Here is what the Plan Guidance says about record retention:
RECORDS RETENTION
Financial management systems shall reflect accurate, current, and complete disclosure of all cost expenses for WorkFirst activities.
Grant recipients are to maintain books and records, supported by source documentation, that sufficiently and properly reflect the source of funds and all costs expended for program purposes.
These records and financial statements are subject to inspection, review, reproduction, and/or audit by SBCTC or its designee for at least six years after the dispersal of funds, the termination or expiration of the contract, or the resolution of litigation or audits related to the program, whichever is latest.
Additional information on records retention may be found on the web:
http://www.sbctc.ctc.edu/docs/general_retention_schedule.pdf
You should also check with your Registrar to identify appropriate college policy for relevant document retention.
Here is what the Plan Guidance says about record retention:
RECORDS RETENTION
Financial management systems shall reflect accurate, current, and complete disclosure of all cost expenses for WorkFirst activities.
Grant recipients are to maintain books and records, supported by source documentation, that sufficiently and properly reflect the source of funds and all costs expended for program purposes.
These records and financial statements are subject to inspection, review, reproduction, and/or audit by SBCTC or its designee for at least six years after the dispersal of funds, the termination or expiration of the contract, or the resolution of litigation or audits related to the program, whichever is latest.
Additional information on records retention may be found on the web:
http://www.sbctc.ctc.edu/docs/general_retention_schedule.pdf
I am hoping to get approval to pay some WF-funded overtime. Is this possible? What are the necessary forms and/or next steps that need to be taken?
The answer depends, first, on whether you are a CTC or a non-profit:
CTCs: Please follow established campus policies regarding approval to use federal grant funds to pay overtime compensation.
Non-profits: Please follow the guidance provided in the Workfirst Delivery Agreement Plan Guidance.
Here is What the Plan Guidance says:
Overtime Compensation – Applicable only to non-profits
Premiums for overtime, extra-pay shifts, and multi-shift work are allowable only with the prior approval of the SBCTC except:
(a) when necessary to cope with emergencies;
(b) when employees are performing indirect functions, such as administration, maintenance, or accounting;
(c) in the performance of tests, laboratory procedures, or other similar operations which are continuous in nature and cannot reasonably be interrupted;
(d) when lower overall cost to the federal government will result.
Both types of organizations should make sure that the overtime compensation should be consistent with the Plan Guidance as a whole.
CTCs: Please follow established campus policies regarding approval to use federal grant funds to pay overtime compensation.
Non-profits: Please follow the guidance provided in the Workfirst Delivery Agreement Plan Guidance.
Here is What the Plan Guidance says:
Overtime Compensation – Applicable only to non-profits
Premiums for overtime, extra-pay shifts, and multi-shift work are allowable only with the prior approval of the SBCTC except:
(a) when necessary to cope with emergencies;
(b) when employees are performing indirect functions, such as administration, maintenance, or accounting;
(c) in the performance of tests, laboratory procedures, or other similar operations which are continuous in nature and cannot reasonably be interrupted;
(d) when lower overall cost to the federal government will result.
Both types of organizations should make sure that the overtime compensation should be consistent with the Plan Guidance as a whole.
Are there any restrictions or concerns regarding hiring an AmeriCorps volunteer with WF funds?
There is difficulty in alignment with AmeriCorps. While paying wages is not an issue for WorkFirst, paying the “match” that is required for AmeriCorps participants to work for us could be problematic, since using federal funds to pay a match to another federal program is prohibited.
If you have a source of state funds that could be used for the match, then it may be viable.
AmeriCorps members work 40-hour weeks. Be aware that they have a number of AmeriCorps program obligations such as service projects, attending AmeriCorps training conferences, and working on AmeriCorps performance objectives which may or may not be congruent with WF.
If you have a source of state funds that could be used for the match, then it may be viable.
AmeriCorps members work 40-hour weeks. Be aware that they have a number of AmeriCorps program obligations such as service projects, attending AmeriCorps training conferences, and working on AmeriCorps performance objectives which may or may not be congruent with WF.
Monday, August 30, 2010
Can we use WF Financial Aid for our $30 wait list fee if we have an RA (like we do for a Compass test voucher)?
We don’t address wait list fees specifically. But, we do identify that Tuition Assistance is paid once the student has been given an activity component in their IRP (NOT just a referral). Once they have an activity component in their IRP, you are able to pay tuition and fees, give COMPASS vouchers, etc.
You might make a local decision not to issue the component code until the student attends.
Otherwise, request the component and use the “actual start” date to trigger the onset of the component.
You might make a local decision not to issue the component code until the student attends.
Otherwise, request the component and use the “actual start” date to trigger the onset of the component.
Is there any rule that keeps us from buying a 3-year software license? It'll cost $5000, should I send in a request first?
There is no specific federal rule regarding software.
There are rules about necessary and reasonable, exclusivity (be made only available to WorkFirst if paid 100% from WorkFirst)and demonstrate that it’s addition would support expanding capacity.
Of course, all “other” appropriate fiscal rules apply.
And Yes, you should submit an request in advance of the software purchase.
There are rules about necessary and reasonable, exclusivity (be made only available to WorkFirst if paid 100% from WorkFirst)and demonstrate that it’s addition would support expanding capacity.
Of course, all “other” appropriate fiscal rules apply.
And Yes, you should submit an request in advance of the software purchase.
What are the eligibility requirements of WF Work Study?
WORK STUDY ELIGIBILITY
All WorkFirst Work Study must be awarded through the financial aid system. Work Study is subsidized paid employment not to exceed 19 hours per week, preferably in a job that enhances the student’s employability.
In order to be eligible, students must:
1. Enroll in classes, including Vocational, High Wage/High Demand, Customized Job Skills Training,I-BEST, Basic Education, or Skills Enhancement Training leading to either unsubsidized employment or entrance into education and training programs leading to work.
AND
2. Be a WorkFirst (TANF) recipient.
WorkFirst Work Study is limited to a total of four quarters.
All WorkFirst Work Study must be awarded through the financial aid system. Work Study is subsidized paid employment not to exceed 19 hours per week, preferably in a job that enhances the student’s employability.
In order to be eligible, students must:
1. Enroll in classes, including Vocational, High Wage/High Demand, Customized Job Skills Training,I-BEST, Basic Education, or Skills Enhancement Training leading to either unsubsidized employment or entrance into education and training programs leading to work.
AND
2. Be a WorkFirst (TANF) recipient.
WorkFirst Work Study is limited to a total of four quarters.
Are parents who already have a BA degree eligible for WorkFirst Financial Aid?
There is no barrier in policy that would prevent funding an existing TANF participant WorkFirst Financial Aid solely on the existence of a bachelors degree.
In fact, it’s recognized that the existing degree may be from an international source that would require retraining in order to be eligible for certification or employment or/or to allow for successful job search when previous degree content may be obsolete relative to current employment options.
However, while we are able to fund the participant, we must also consider leveraging other resources to support training completion. Typically WorkFirst Financial Aid is utilized as a resource to begin training, and participants are strongly encouraged to immediately apply for federal financial aid.
An existing bachelors degree could render an applicant ineligible for grants. So it is important to assist parents to either choose a program that can be completed in a relatively short period of time or help them to access a more permanent funding source that would limit the necessity to take on student loans which could result in excessive debt.
In fact, it’s recognized that the existing degree may be from an international source that would require retraining in order to be eligible for certification or employment or/or to allow for successful job search when previous degree content may be obsolete relative to current employment options.
However, while we are able to fund the participant, we must also consider leveraging other resources to support training completion. Typically WorkFirst Financial Aid is utilized as a resource to begin training, and participants are strongly encouraged to immediately apply for federal financial aid.
An existing bachelors degree could render an applicant ineligible for grants. So it is important to assist parents to either choose a program that can be completed in a relatively short period of time or help them to access a more permanent funding source that would limit the necessity to take on student loans which could result in excessive debt.
How many years back can a case manager go in determining if the parents have used up their 12 months of VE (vocational education)?
The relevant time frame does not go beyond the period of the onset of DRA (Deficit Reduction Act)as of October 1, 2008 since previous calculations were unreliable and CTCs did not have the ability to enter a RB (refer back) to indicate training had ceased.
Where can a former TANF parents find information on financial aid and college?
The Community and Technical college system has access to various resources to assist former TANF parents with the payment of tuition and other educational costs.
Two good places to start your search is the Check out a college and Federal Financial Aid application web site(s).
You may access them through http://checkoutacollege.com/ and www.fafsa.ed.gov
Two good places to start your search is the Check out a college and Federal Financial Aid application web site(s).
You may access them through http://checkoutacollege.com/ and www.fafsa.ed.gov
Since WF Work Study generates 19 hours, must we stack additional activities to get to 20 hours?
No. The 19 hours will be reported as 20 hours. You do not have to stack additional activities for the parent to earn the 1 hour. Here is the explanation of a DSHS staffer:
"Our systems will round up any 10th of an hour to the nearest whole hour, and this is acceptable to the feds. As long as the budgeting is being done correctly, and as long as this is only occurring for those in 19 hours of Work Study, then we do not have to stack additional activities as we are reporting out 20 hours."
"Our systems will round up any 10th of an hour to the nearest whole hour, and this is acceptable to the feds. As long as the budgeting is being done correctly, and as long as this is only occurring for those in 19 hours of Work Study, then we do not have to stack additional activities as we are reporting out 20 hours."
Gifting: Can I use WF funds to buy books or gift cards for WF students?
Question #1. During our full-time 6-week break workshops we are expecting students to spend time using their fall books to learn some study skills and get a head start.
Can we purchase any fall quarter books for them in August under these circumstances?
Answer #1: Yes. The books, however, belong to the college (and ultimately to the federal government, since you can’t use federal funds to "gift".
You can let the students use the books, but you need to collect them at the end of the 6-week period. You may let the students borrow them again for Fall Quarter, but again you must collect them at the end of the quarter.
There is a system group working who are creating common curricula that uses open source (i.e. free) materials from the web. They are starting with the 40 most often taken classes. Every instructor, of course, can decide to opt in or out.
Question #2. We have a participation incentives program here. We are awarding Fred Meyer gift cards to two of the students who have participated successfully and have turned in their attendance sheets on time each week based on a drawing of names each week.
Answer #2: No. You cannot use federal money for gifting. Rewards are great. Can you find a local benefactor who can fund the gift cards?
Can we purchase any fall quarter books for them in August under these circumstances?
Answer #1: Yes. The books, however, belong to the college (and ultimately to the federal government, since you can’t use federal funds to "gift".
You can let the students use the books, but you need to collect them at the end of the 6-week period. You may let the students borrow them again for Fall Quarter, but again you must collect them at the end of the quarter.
There is a system group working who are creating common curricula that uses open source (i.e. free) materials from the web. They are starting with the 40 most often taken classes. Every instructor, of course, can decide to opt in or out.
Question #2. We have a participation incentives program here. We are awarding Fred Meyer gift cards to two of the students who have participated successfully and have turned in their attendance sheets on time each week based on a drawing of names each week.
Answer #2: No. You cannot use federal money for gifting. Rewards are great. Can you find a local benefactor who can fund the gift cards?
Do criminal convictions disqualify WF parents from receiving financial aid?
In brief, it is only a federal or state drug conviction that can potentially disqualify an applicant. Attached is a clarification document identifying the type of criminal offense necessary to cause ineligibility and what process and methods can be employed to regain eligibility.
According to current policy convictions only count if they were for an offense that occurred during a period of enrollment for which the student was receiving Title IV aid—they do not count if the offense was not during such a period.
OR SALE OF DRUGS
A federal or state drug conviction can disqualify a student for FSA funds. The student self-certifies in applying for aid that he is eligible; you’re not required to confirm this unless you have conflicting information.
Convictions only count if they were for an offense that occurred during a period of enrollment for which the student was receiving Title IV aid—they do not count if the offense was not during such a period. Also, a conviction that was reversed, set aside, or removed from the student’s record does not count, nor does one received when she was a juvenile, unless she was tried as an adult.
The chart below illustrates the period of ineligibility for FSA funds, depending on whether the conviction was for sale or possession and whether the student had previous offenses. (A conviction for sale of drugs includes convictions for conspiring to sell drugs.)
If the student was convicted of both possessing and selling illegal drugs, and the periods of ineligibility are different, the student will be ineligible for the longer period.
Schools must provide each student who becomes ineligible for Title IV aid due to a drug conviction a clear and conspicuous written notice of his loss of eligibility and the methods whereby he can become eligible again.
A student regains eligibility the day after the period of ineligibility ends or when he successfully completes a qualified drug rehabilitation program or, effective beginning with the 2010–2011 award year, passes two unannounced drug tests given by such a program. Further drug convictions will make him ineligible again.
Students denied eligibility for an indefinite period can regain it after successfully completing a rehabilitation program (as described below), passing two unannounced drug tests from such a program, or if a conviction is reversed, set aside, or removed from the student’s record so that fewer than two convictions for sale or three convictions for possession remain on the record. In such cases, the nature and dates of the remaining convictions will determine when the student regains eligibility. It is the student’s responsibility to certify to you that she has successfully completed the rehabilitation program; as with the conviction question on the FAFSA, you are not required to confirm the reported information unless you have conflicting information.
When a student regains eligibility during the award year, you may award Pell, ACG, National SMART, TEACH, and Campus-based aid for the current payment period and Direct and FFEL loans for the period of enrollment.
Standards for a qualified drug rehabilitation program
A qualified drug rehabilitation program must include at least two unan¬nounced drug tests and must satisfy at least one of the following require¬ments:
• Be qualified to receive funds directly or indirectly from a federal, state, or local government program.
• Be qualified to receive payment directly or indirectly from a federally or state-licensed insurance company.
• Be administered or recognized by a federal, state, or local government agency or court.
• Be administered or recognized by a federally or state-licensed hospital, health clinic, or medical doctor.
If you are counseling a student who will need to enter such a program, be sure to advise the student of these requirements. If a student certifies that he has successfully completed a drug rehabilitation program, but you have reason to believe that the program does not meet the requirements, you must find out if it does before paying the student any FSA funds.
INCARCERATED STUDENTS
A student is considered to be incarcerated if she is serving a criminal sentence in a federal, state, or local penitentiary, prison, jail, reformatory, work farm, or similar correctional institution (whether it is operated by the government or a contractor). A student is not considered to be incarcerated if she is in a half-way house or home detention or is sentenced to serve only weekends.
Incarcerated students are not eligible for FSA loans but are eligible for FSEOGs and FWS. They are also eligible for Pell grants if not incarcerated in a federal or state penal institution. See Chapter 7 for more information on this and on sex offenders who were incarcerated but are now subject to an involuntary civil commitment.
You may accept the student’s written self-certification that he is no longer incarcerated.
Drug convictions
HEA Section 484(r)
34 CFR 668.40
Drug abuse hold
The Anti-Drug Abuse Act of 1988 in¬cludes provisions that authorize federal and state judges to deny certain federal benefits, including student aid, to per¬sons convicted of drug trafficking or possession. The CPS maintains a hold file of those who have received such a judgment, and it checks applicants against that file to determine if they should be denied aid. This is separate from the check for a drug conviction via question 23; confirmation of a student in the drug abuse hold file will produce a rejected application and a separate comment from those associated with responses to question 23. See the ISIR Guide for more information.
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