So you want to be a Hybrid?

How does the program look currently? SNAP E&T Program Mandatory Participation (STATE CHOICE) Level Sanctions EF-102 Referrals Work Registrants (Non-ABAWDs) Exemptions ABAWD Time-limits (3 months in a 36 month period) Work requirements ABAWD tickets ABAWD Disqualifications Ticket Reports WORKFARE Work at a public or private Non-Profit Work requirement determined by allocation/minimum wage Enhanced funding generated by starting employment within 30 days of last workfare activity.

WORKFARE SNAP E&T (MANDTORY) ABAWD PROGRAM

What are my choices for next fiscal year? Hybrid-Mandatory “ABAWDs Stay, Non-ABAWDs can volunteer” Mandatory “Business as usual” Hybrid-Voluntary “Nobody is required, but everybody is welcomed ”

What does it mean to be a Hybrid-Mandatory Program Every participant that isn’t exempt should received an EF-102 either in person or via mail. Non-ABAWDs are voluntary. ABAWDs are mandatory and subject to ABAWD disqualifications, tickets, and Level sanctions for missed appointments.

What does it mean to be a Hybrid-Voluntary Program Every participant that isn’t exempt should received an EF-102 either in person or via mail. Non-ABAWDs and ABAWDs are both voluntary. Level Sanctions are not entered in a Hybrid-Voluntary Program.

How are we honoring our ABAWD Pledge? By offering several qualifying components for ABAWD participants to meet the work requirement we honor our ABAWD pledge status. ABAWDs still receive tickets and ABAWD disqualifications in ANY PROGRAM option. Ticket reports are still worked and submitted to the state monthly

NEW IMPROVED EF-102 English as 2nd language Mandatory Voluntary

DATA ENTRY Upon receipt Each 102 should be entered in CBMS by EF State Per state reg. 4.310.9(B)(2) Enter required information from the work registration form into the Employment First automated system for each person referred from the local office to the Employment First; If a voluntary participant doesn’t attend orientation in a hybrid program the plan status of that case should be changed to “EF-Closed”.

DATA ENTRY CONTINUED Be sure to case comment that the participant didn’t attend orientation.

ABAWD DISQUALIFICATIONS VS. LEVEL SANCTIONS HOW CAN I TELL THE DIFFERENCE ? In the new hybrid Voluntary world Level sanction will not be entered for our Non-ABAWD population. In the Hybrid – ABAWD Mandatory World level sanctions will only be applied to ABAWD participants who miss appointments.

LEVEL SANCTIONS In all program models, level sanctions can only be complied if the sanction has been served. You can determine if a sanction is a level sanction by looking at the end date. If a sanction has an end date, it’s a level sanction and the client has to wait until after the end date or be come exempt to be eligible for benefits

FEDERAL FINDING Colorado was cited for not attempting to find good cause prior to entering a sanction. 273.7(4)(f)(i)- “As soon as the State agency learns of the individual's noncompliance it must determine whether good cause for the noncompliance exists, as discussed in paragraph (i) of this section. Within 10 days of establishing that the noncompliance was without good cause, the State agency must provide the individual with a notice of adverse action, as specified in §273.13. If the State agency offers a conciliation process as part of its E&T program, it must issue the notice of adverse action no later than the end of the conciliation period.

WHAT DOES THE FEDERAL FINDING MEAN TO ME? Prior to entering a non-compliance an attempt at good cause must be made. The State is currently exploring options to help with assessing for good cause. Examples of assessing for good cause include but are not limited to; calling, mailing a letter, emailing, and face to face assessment.

ABAWD DISQUALIFICATIONS ABAWD disqualifications should not be complied by FA techs for any reason. A participant must follow the regain process (8 hours of workfare or 80 hours of a qualifying activity over a 30 day period as defined in federal law and state rule) or become exempt to cure the disqualification.

ABAWD DISQUALIFICATIONS ABAWD disqualifications can be identified by not having an Effective End Date and the Type field indicating “ABAWD Third Ticket Sanction”. For no reason should an FA tech comply an ABAWD disqualification.

RECAP: When can I comply a Sanction/Disqualification? A level sanction can only be complied after it has been served even in counties where the participant is considered a voluntary EF participant. An ABAWD disqualification should never be complied by FA staff. An ABAWD disqualification can only be complied after a client has completed the state regain process (8 hours of Workfare or 80 hours of a qualifying activity in the last 30 days).

PARTICIPANTS TRANSFERRING COUNTIES If a participant transfers to a county where they are considered a volunteer or to a county that doesn’t have an EF program, but has served their sanction, then the sanction should be complied. If the participant is in the middle of the sanction period, the participant must serve the entire period before it can be complied regardless of the county’s operating status.

TICKET REPORTS 1st and 2nd ticket report runs monthly on the 7th for the previous month. 3rd ticket report runs on NOA each month. Each ticket should be checked for validity and the report should be sent back to the EF policy box on the state approved template. cdhs_ef_policy@state.co.us

2nd and 3rd ticket ABAWD participants ABAWD participants with 2nd and 3rd tickets need to meet the work requirement prior to NOA each month. (see attachment) 2nd and 3rd ticket ABAWDs can meet the work requirement after NOA but will already have a disqualification in place. To correct this the EF policy box should be contacted to remove the now invalid ticket (once hours are turned in) and have the disqualification closed. FA will then need to be contacted to run EDBC on the case to have benefits restored.

ABAWD TICKET REMOVAL Whenever an invalid ticket is discovered via ticket report or upon research, it should be removed as long as it’s in the current 36 month period. (Current period 10/1/2016-9/30/2019) Once an invalid ticket is found the state’s policy box should be contacted for it’s removal. cdhs_ef_policy@state.co.us In many cases, ticket removal will result in the ABAWD disqualification being removed.

ENHANCED FUNDING There is no change to the enhanced funding process. Volunteers into the EF program can still receive enhanced funding as long as they receive employment within 30 days of a workfare activity.

So, I like it… What do I need to do? Submit your county plan. Change your orientation to reflect the program’s new direction. Work on messaging . Use the updated EF-102 to refer ALL non-exempt participants.

Opportunities with Hybrid Program With sanctions going away, more focus can be placed on attempting to prevent ABAWD participants from gaining additional tickets. Participants on the ABAWD ticket report that are out of compliance should be invited to participate. Staff can dedicate more time to developing relationships with community partners and spend more time providing high quality assessments and career guidance to clients.

DECISIONS, DECISIONS If you decide to be a hybrid program please let your state rep know which hybrid option your county will be using for the next fiscal year.

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ANY QUESTIONS?