1. SCSEP: Another Look at Individual Durational Limit Policies
August 20, 2012 – 3pm ET

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7. Featured Speakers Presenter Moderator Joyce Welsh, MH West & Co.
Judith Gilbert, SCSEP Team Leader

8. Managing IDLs on grantee and sub- recipient level
Agenda
Ongoing requirements for individual participant durational limits (IDLs)
Common problem areas
FAQs
Managing IDLs on grantee and sub- recipient level
Specific requirements during the grantee transition period

9. IDLs: Statutorily Required Component of SCSEP
Effective as of July 1, 2007
Grantees MUST:
Develop IDL policy for DOL approval
Inform and train all sub-recipients in the policy
Monitor strict compliance with the policy
Sub-Recipients MUST:
Inform all participants at enrollment and whenever policy changes
Inform once again at 12 months out
Develop transition plan for participant’s final 12 months
Provide all exiting participants with 30 days’ written notice
Treat ALL participants equitably and consistently

10. DOL-Approved Policies
In PY 2010, every grantee formulated an IDL policy that was approved by DOL
Policies can be changed at any time by written request to DOL
Changes are effective ONLY after you receive a signed approval letter from DOL AND a 120-day period to inform all participants that your policy has changed

11. Three Possible Policies
No extensions: All participants exit the program at 48 months
Extensions for every waiver factor: Any participant who meets any of the 7 waiver factor receives an extension
Extensions for a sub-set of waiver factors OR extensions are one-time only
EXAMPLE: A participant who meets any 2 waiver factors
EXAMPLE: A participant who is (a) over 75 and (b) severely disabled
EXAMPLE: A participant may receive only one extension in their lifetime

12. If Extensions Are Part of Your Policy…
Your policy MUST be approved by DOL
EVERY participant reaching his/her durational limit that meets your policy criteria MUST be given an extension
Your policy must be implemented fairly and equitably

13. Best-Case Scenario Approach to Transition Planning
12 months out:
Inform participants in writing
Reassess all participants
Categorize by job potential
Update IEPs
Begin intensive job development
6 months out:
Reassess how many still have not found jobs
Update IEPs
Begin safety net planning
30 days before: send out termination letter

14. Prepare Participants for a Positive Exit
Review assessments and IEPs
Interview participants
Clarify participants’ goals and identify challenges to employment
Escalate IEPs of the most job-ready participants to include specialized training and OJE, as appropriate
Ensure marketable participants have resumes and prepare participants for interviews
For participants who are not job-ready, develop safety net planning to ensure quality of life without SCSEP wages

15. If You Have an Extension Policy…
The 7 waiver factors determine minimum eligibility for extensions
Must be updated in the program year in which the durational limit is reached in order to be used to request an extension
(Or in the prior quarter, where the durational limit is reached in the first quarter of a program year)

16. Common Problem Areas in Implementing IDL Policies

17. 1. No Policy Being Followed At All
Staff turnover at the grantee and/or sub-recipient level can cause incorrect practices to prevail
Lack of training or technical assistance can result in outdated or incorrect policies being followed
Lack of monitoring or follow-up can fail to catch potential problems in a timely manner
Put all policies and procedures in writing in a staff handbook; review annually to ensure sub- recipients have up-to-date information

18. 2. Policies Being Applied Inequitably
Protect your agency!
If IDL policies are not implemented fairly and correctly, it could result in legal action against your agency
If extensions are part of your policy, every participant with the approved waiver factor(s) MUST be granted an extension

19. 3. IDL Terminations Confused with IEP and Other Terminations
IDLs are one of 7 statutory reasons to terminate a participant
All terminations require 30 days’ written notice
Notice should include copy of grievance procedure
Make certain you are following the appropriate policy and specific procedures for IDL termination

20. 4. Participants Terminated at the Wrong Time
Some participants are being wrongly terminated for IDL at 27 months / after 48 months / etc.
Both are illegal (unless the grantee has approved extension policy)
Potential disallowed costs
Potential grievance or lawsuit
SPARQ rejects and locks records as a way to get your attention

21. 5. No Written Transition Planning in Participant Files
FPOs monitor for compliance with grantee IDL policy
Documentation that policy was explained and provided in writing at orientation and whenever policy changes
Written acknowledgement at 12 months out
12 month transition IEPs
6 month safety net planning
30 day IDL termination letter with copy of grievance procedure

22. Managing IDLs on the Grantee and Sub-Recipient Levels to Avoid These Problem Areas

23. If You Have an Individual Extension Policy…
Extensions to durational limits are dependent upon proper updating of information
You must run the Waiver of Durational Limit report to ensure that all participants scheduled to reach their durational limit within a year have updated waiver factors
Correct durational rejects as soon as they appear
Leave of absences must be reviewed (in the Approved Break Report) for accuracy and corrected as necessary

24. SPARQ Management Reports
Waiver of Durational Limit report – looking forward
Most useful for transition planning
Focuses on whichever durational limit date the participant is approaching (48 month, 60 month, etc.)
Shows the most recent waiver factor data to help you evaluate whether a participant qualifies for an extension

25. SPARQ Management Reports
Reached Durational Limit report – looking backwards
Provides a retrospective report on who received waivers and who didn’t
Not intended to be a planning tool!

26. Grantee Staff To-Dos
Review WDL reports on a quarterly basis (minimum!)
Flag potential and actual problem areas for follow-up with sub-recipients
Include review of IDL participant files while monitoring to ensure:
Adequate transition IEPs are being developed and followed
Required written notices have been provided
Provide staff training on your IDL policy and implementation strategies when turnover occurs

27. Sub-Recipient Staff To-Dos
Review SPARQ durational limit reports frequently
Use this for case management of transition planning steps
Transfer names from management report to the responsible case manager to begin the 12 month transition process
Ensure appropriate waiver factor documentation has been gathered and placed in the participant file
Make certain SPARQ data are up to date and accurate (approved breaks in participation, durational rejects, waiver factor annual updates, etc.)

28. Specific Requirements During the 2012 Grantee Transition Period*
*National competition transition process and equitable distribution changes due to new Census data

29. IDL Policies and Transfers
Exits before 10/1: Donor grantee applies its IDL policy
Exits between 10/1 and 10/31: Donor and recipient grantee work together on transition planning and notification.
Exits between 10/1 and 12/31: Apply the IDL policy most beneficial to the participant (see transfer list)
Exits after 12/31: Recipient grantee applies its IDL policy
Recipient grantees must honor the full length of extensions entered by the donor grantee before 10/1

30. Important Concepts for the Transition Period
Know the durational limit dates of all transferred participants
The transfer report flags participants with durational limit dates before 11/1 and before 12/31
Re-familiarize yourself with your approved IDL policy
If you are not sure, contact Irene Jefferson ASAP
Understand both donor and recipient IDL policies and their effective dates, so you can inform participants of their rights and likely duration
Even participants with remote durational limit dates are affected if the recipient grantee has a different IDL policy

31. Please enter your questions into the Chat Room!
Question and Answer Period
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32. Resources
Durational Limits: Transition Planning for SCSEP Participants
Handout: Volunteer organizations
Final Countdown to Durational Limit Exits
Handout: IEP checklist
Handout: Procedures for updating waiver factors
Waiver Factors for Durational Limits
SCSEP Durational Limits: What Do They Mean for Grantees and Participants?
Handout: An Overview of Durational Limits

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