Program and Compliance Management

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Program and Compliance ManagementProgram and Compliance Management

Workshop: Workshop:

UNDERSTANDING PARTICIPATION CYCLESUNDERSTANDING PARTICIPATION CYCLES

V I R T U A L L V I R T U A L L YY

OutlineOutline

• A Basic Schematic

• ‘Participants’ and ‘Exiters’

• Services That Qualify

• Gaps in Service

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A Basic SchematicA Basic Schematic

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First Service (Participation Date)

Eligibility Determination

(as appropriate)

Services and Interventions

Various Start/End

Dates

Last Service (Exit Date)

Follow Up Activities (e.g., contacts) and Follow Up Services (required for youth

post exit)

The FlowThe Flow

AA

BB

CC

DD

EE

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First Service (Participation Date)

Eligibility Determination

(as appropriate)

Services and Interventions

Various Start/End Dates

Last Service (Exit Date)

Follow Up Activities (e.g., contacts) and

Follow Up Services (required for youth post exit)

Know Your Flow!Know Your Flow!

AA

BB

CC

DD

EE

1. What do we call individuals before they reach Point A? What do we call individuals between A & B?

2. What’s the maximum amount of time between A & B? Is there a State policy?

3. If a WIA participant received partner services prior to the first WIA-funded service, is the participation date based on the partner program or WIA? (Does the State utilize a “common participation date?”)

4. Etc.

Participants and ExitersParticipants and Exiters

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In the Opening Session we talked about a In the Opening Session we talked about a universal accountability framework. Where universal accountability framework. Where

does the federal “juice” come from for these does the federal “juice” come from for these two critical terms? What’s the primary source?two critical terms? What’s the primary source?

QUESTIONQUESTION

ParticipantParticipant

• An individual determined ________ to participate in the program who receives a ________ funded by the program in either a ________ ________ or remotely through electronic technologies

– Three components:

1. Determined ________ to participate2. Receives a funded _______3. In either a ________ ________ or through

electronic technologies

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ClarificationsClarifications

1. Individual determined ________ to participate– Depends on program/funding; doesn’t apply to

_______-______ (which is based on universal access)

2. Receives a _________– Not all _________ trigger participation and

inclusion in performance; it’s important to understand the distinction between those that do and those that don’t

3. In a __________ __________ or remotely– Adding remote access to the definition was a

major change in federal policy

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Participation DateParticipation Date

• Defined as date of ____ program-funded service

– Federal Policy – It’s possible to record an earlier date if services are being provided by another partner at the time of participation (if those services are “tracked”)

– What is your state’s policy? Do all staff have the same understanding? Is this part of regular staff training?

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ExiterExiter

• A participant who hasn’t received a service for ___ days and no _______ _______ are scheduled (program or partner-funded)

– Three components:

1. Hasn’t received a service

2. For at least ___ days

3. No _______ ________ scheduled

• Considered a “soft exit” approach

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ClarificationsClarifications

1. Individual hasn’t received a service– Could be program- or partner-funded depending

on policies/procedures (e.g., tracking)

2. In ___ days– Doesn’t include gaps in service which, by

definition, are at least ___ days

3. No _______ _______ scheduled– Some services can extend the exit date

– Does not include ___________ determination, follow-up services, or regular contact

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Exit DateExit Date

• Defined as date of _____ service

– Federal Policy – A _________ exit date is expected across the core workforce programs at a minimum (WIA, TAA, LX)

• Other terms related to exit include Exit Quarter and Exit Cohort

• Why is the Exit Date critical?

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Issues From Regional Issues From Regional Data Validation ReviewsData Validation Reviews

Staff unclear about services that trigger or commence participation

Service provision prior to formal participation

Exit dates not reflective of dates of _____ service

Gaps in Service spanning years

Case management used to extend exit date

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Issues From Regional Data Issues From Regional Data Validation Reviews (2)Validation Reviews (2)

Hard exits utilized (e.g., date of last contact, date of employment)

Services provided within ___ days

Lack of _________ exit date across core workforce programs

Exit dates not consistent with dates in MIS

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Qualifying ServicesQualifying Services

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Services as Triggers or Services as Triggers or ExtensionsExtensions

• Some services can commence or trigger participation

• Some services can extend the exit date

• State policy can/should clarify federal parameters

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Services That Commence Services That Commence ParticipationParticipation

• Self-service or self-directed job search and/or workforce information services (not applicable to WIA ______)

• Staff-assisted job search, job referral, career counseling, skills assessment, testing, job development (working with employer and job seeker), workshops, job clubs

• Comprehensive and specialized assessments, such as diagnostic testing and interviewing

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Services That Commence Services That Commence Participation (2)Participation (2)

• Individual or group counseling, career planning, development of individual employment plan

• Case management

• Short-term pre-vocational services

• Training services

• What’s the “typical” first service in your state (for A, DW, Y)? Does everyone have the same understanding?

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Services That Can Services That Can Extend ExitExtend Exit

• DOL funded One-Stop partner program services ‘____’ extend exit but services across the core workforce programs ‘_____’

– More services potentially means higher outcomes

– Requires ability to track participants until they exit all services (program and partner); tracking across the core workforce programs already required (e.g., common unique identifier)

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Services That Can Extend Services That Can Extend Exit (2)Exit (2)

• TRA and other needs-related payments tied to continuous participation

• What’s the “typical” last service in your state?

– Is it based on State guidance, local policy, local procedures?

– Does everyone have same understanding?

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Services That DO NOT Trigger Services That DO NOT Trigger Participation or Extend ExitParticipation or Extend Exit

• ________________ determination

• Case management of an _____________ nature (e.g., regular contact)

• Income maintenance or support payments (e.g., UI, TANF)

• Post-employment or Post-exit follow up services designed to ensure job retention, wage gains, and career progress

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Gaps in ServiceGaps in Service

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Gap in ServiceGap in Service

• QUESTION: What kind of exit does a QUESTION: What kind of exit does a gap in service prevent from taking gap in service prevent from taking place?place?

– After ____ days of no service, an exit will occur unless there is a gap in service

– Based on specific circumstances

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How do you “code” a gap in service in your state’s MIS?

Gap in Service (2)Gap in Service (2)

• Three allowable circumstances

1. Delay before beginning of training

2. Health/medical reason, family care

3. Temporary move from area

• No more than 180 days but a subsequent gap possible

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About Gaps in ServiceAbout Gaps in ServiceThings to Know!Things to Know!

• It is dependent on the participant’s intent to continue services

• Document rationale in participant case file, as well as beginning and expected end date

• A gap in service is optional

• It is not synonymous with hold forever or at least until we get them a job

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Sample Scenario:Sample Scenario:• Participant has a health issue that precludes further

participation for at least 90 days What do you do? – Does s/he intend to continue services?

• Based on the answer, a gap in service might be appropriate although an alternative is allowing exit to occur

– Exit based on “health/medical or family care” could be the basis for a performance exclusion

• Ultimately, utilizing a gap in service is a judgment judgment callcall; at a minimum, stay in periodic contact to ensure the situation has not changed

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Questions?Questions?

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