Improving Welfare Transition Program Performance through Properly Written IRPs and Correct Penalty Procedures Presented by Marilyn Sandoz Taylor, Lombardi, Hall & Wydra, P.A.

 Performance can be impacted by information documented on IRPs and sanction procedures ◦ IRPs must contain specific instructions for customers  Activity assignment – assigned hours, start date for activity  Responsibilities for submitting timesheets ◦ Sanctions must be timely  Participation and WTP Entered Employment Rates are impacted  Cases should not be in the denominator if requested prior to pull down  Cases remain in denominator for additional month when requested after pull down  Important to develop relationship with DCF contact to facilitate imposing sanctions in a timely manner

Well written IRPs:  Must advise customer of: ◦ What (s)he is assigned to do ◦ When (s)he is assigned to do it ◦ When participation documentation is due ◦ What is expected of her/him

 Initiated when a customer does not fulfill the actions specified on the IRP  Cannot be initiated if customer is not advised of specific responsibilities (via IRP or appointment letter)  Can impact performance when initiated improperly or untimely, or not followed up on in a timely manner

Example: The IRP in the case file was not signed by the customer. Issue: There was no documentation that the customer was advised of assignments specified on the IRP. Can the customer be held responsible for not doing something they did not agree to do and there is not an appointment letter in the file? In the WTP world…….NO Solution: IRPs must be signed by the customer and case manager.

Actual example from an IRP: “Complete 19hrs/wk of community service or work experience and 12 hours of Job skills Training at xxxxxxx, located at xxxxxx, beginning 09/06/2013 and submit signed time sheet by 5pm every other Friday beginning 1025/ /17/2014 to xxx-xxx-xxxx” Issue: What is the timeframe for the customer to complete the assigned 12 hours for the Job Skills Training activity? Per week? Per month? Solution: Ensure that the timeframe to complete assigned hours are documented. The step should specify that 12 hours per week were assigned for the Job Skills Training activity. Per the step noted, the customer could complete 12 hours in the Job Skills Training activity from “10 25/ /17/2014 “ and be in compliance. An inappropriate date was documented.

Actual example from an IRP:  “I will start my 30 hours of community service with the xxxxx starting on Monday, July 15, 2013 through January 15, 2014.”  “Failure Information: 10/28/2013: Failed to cmp 35 hours comm svc activity” Issue:  A pre-penalty was initiated for the customer failing to complete 35 hours per week in the Community Service activity – Per the signed IRP, the customer was assigned to complete 30 hours per week in the activity. Solution: Ensure that correct failure reasons are documented for pre-penalties

Actual example from an IRP: xxx is doing Job searching at xxx per 1140 hours monthly, 35 hours weekly, 5hrs daily. Activity began 07/29/13 to 08/23/13. xxx need to come on daily basis and complies work shop requirements.”  “Xxx needs to do the 160 hours at mo. and verifies if attendances are on file sent by Supervisor. Client needs to comply with the hours, daily and weekly basis. Time sheet attendance needs to be provided every Friday no later than 5PM by xxx” How many hours is the customer assigned to complete? How many hours can you hold the customer accountable for? Issue: Confusing and conflicting information is documented Solution: Ensure that steps are clearly written and do not contain conflicting information.

Steps to self-sufficiency do not clearly specify customer’s responsibilities Actual example from an IRP: ◦ “Complete 35 hrs/wk in JS. Document hours on a weekly basis on JS form completed and due to case manager every Monday for prior week” Issue: ◦ Starting when??????????? What is the date the customer was assigned to submit first timesheet? Solution: Steps should document the due date of the first timesheet Could the customer be held accountable for submitting timesheets the way the step to self-sufficiency was written? NO – the start date for the activity was not specified in the step and the due date for the first completed Job Search form was not documented

◦ Sanctions are improperly requested:  Incorrect failure dates are documented  Incorrect failure reasons are documented  Missing documentation supporting assignment  Customer’s responsibilities for submitting participation documentation are not specified on IRP’s ◦ Customers request hearings ◦ Participation “time” is lost ◦ Customers “win” hearings because of errors in the penalty process  The region’s performance/participation rate is negatively impacted

The WT Program Manager from Brevard Workforce will present the IRP they created that has helped in eliminating several IRP issues impacting performance The Quality Assurance Program Manager at Southwest Florida Workforce Development Board will present their sanction process that has helped in reducing issues with timeliness and correct sanction procedures