State of Alabama Work Verification Plan FY2007

Alabama Department of Human Resources S. Gordon Persons Building 50 Ripley Street P.O. Box 304000 Montgomery, Alabama 36130-4000 (334)242-1773

Joel Sanders, Director Family Assistance Division

Contact: Debby Wood, Director Office of JOBS Program Operations (334) 242-8153 Debby.Wood@dhr.alabama.gov

September 29, 2006 Revised September 4, 2007

September 4, 2007 Sidonie Squier, Director Office of Family Assistance (OFA) Administration for Children and Families 370 L’Enfant Promenade, SW Washington DC 20447 ATTN: Jon M. Margolis

Dear Ms. Squire: Enclosed is the Work Verification Plan for FY2007 for Alabama. This plan is being submitted in accordance with the requirements of the Deficit Reduction Act of 2005 and 45 CFR 261.62(b). Revisions to the Work Verification Plan have been made to comply with the additional guidance supplied by your office in August 2007. An electronic copy of the plan has been sent to the OFA and to the Regional Office. I certify that the Alabama TANF Work Verification Plan dated September 4, 2007 includes all information required by the regulations at 45 CFR 261.62(B) and accurately reflects the provisions under which Alabama will be operating as of September 30, 2007. If further information is needed, please contact Mrs. Debby Wood at (334) 242-8153 or email her at Debby.Wood@dhr.alabama.gov.

Sincerely,

Joel Sanders, Director Family Assistance Division Enclosure cc: Mrs. Betty Ritchie TANF Program Specialist

Alabama Work Verification Plan September 4, 2007

Work Verification Plan for Alabama
Overview This guide was prepared by the Alabama Department of Human Resources (DHR) in accordance with the regulatory requirements of the interim final rule that the U.S. Department of Health and Human Service (HHS) published on June 29, 2006. Under the rule, each state must submit its Work Verification Plan to HHS for approval. We have included the information required by the interim final rule in this plan following the six sections: countable work activities; hours engaged in work; work-eligible individuals; internal controls; verification of other data used in calculating the work participation rates; and submittal procedures as described in the Work Verification Plan Guide and the Further Guidance on Work Verification Plans. The guides were used in conjunction with the appropriate preamble and regulatory text of the interim final rule to develop the Work Verification Plan for Alabama’s TANF Program. Alabama’s Work Verification Plan may require revision in future months as policy is refined and programming changes are made. We understand that all procedures and internal controls must be in place by October 1, 2007. In this plan we describe the program as it will be on September 30, 2007 but we also include information on intended program design changes that are planned. The State will amend its Work Verification Plan during the course of the fiscal year in accordance with the regulations at 45 CFR 261.63(c). Please note that the financial eligibility requirements of Alabama’s Temporary Assistance to Needy Families Program are administered through the Family Assistance (FA) Program and the work requirements through the JOBS Program and will be referred to as such throughout the plan. I. Countable Work Activities For each of the 12 work activities, we have addressed the four questions as outlined in the Work Verification Plan Guide. A. Unsubsidized Employment: Full- or part-time employment in the public or private sector that is not subsidized by TANF or other public programs. 1. Services/Programs. Employment activities include all activities performed by the client for which the client receives compensation in the form of wages that are not subsidized by TANF or other public or private programs. Employment may be full or part-time and may be selfemployment or non-self-employment. 2. Process for determining the number of hours to be counted. Alabama determines countable hours of participation using pay stubs,

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Alabama Work Verification Plan September 4, 2007 employer reports, or other employer-issued documents verifying the number of hours the individual has actually been paid. This includes hours for which the individual is paid but does not work, including paid leave and holidays. Since weekly hours to be counted must be based on hours for which it has been verified that the client was paid, the weekly paid hours will be verified as stated in “3” below after the client has actually received at least one representative week of pay. A representative week of pay is a week during which the client received pay for the number of hours for which the client states and the employer verifies are anticipated be paid each week. If the hours of pay vary from one week to another, at least two representative weeks of pay (showing the variation) will be verified and the average of the hours from the number of weeks verified will be used as the weekly hours. These average weekly hours will then be projected as stated in “4” below. Self-employment Hours: The number of hours counted will be determined by dividing the gross income (minus 40% for business expenses) by the federal minimum wage. The amount of gross income and business expenses will be determined using the same method used in the determination of eligibility for Family Assistance benefits. This calculation will determine the monthly number of hours. The monthly number of hours will then be divided by 4.33 to arrive at the average weekly number to be counted towards participation. 3. Verification/Documentation of Hours. Acceptable verification includes check stubs provided by the client and written statements completed and signed by the employer. The client may provide a written signed statement from the employer or the form DHR-FAD-1532 or other DHR program forms may be sent directly to the employer for completion, signature and return. A copy of written verification will be maintained in the case record and documented on the Paid Weekly Hours Computation Worksheet (Attachment G). If pay stubs or other employer produced documents cannot be obtained, the hours may be verified through a phone contact with the employer. The phone call will be documented in the case narrative and will include the date of the contact, the name and title of the person providing the verification, the number of verified hours, and the signature or initials of the person making the contact. Self-employment Hours: Business records showing gross income will be used as verification of gross income. Actual business expenses will not be verified. Instead, a standard 40% of the gross income will be deducted (from the gross income) for business expenses, as is used in determining eligibility for Family Assistance Program benefits.

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Alabama Work Verification Plan September 4, 2007 4. Projection of Hours: The number of hours will be projected using the method stated below for up to a six-month period based on verification from the employer or client as stated in “3” above. Alabama’s FA Program policy allows up to a six months disregard of earned income. Because the FA benefit amount is so low, in most instances, families will be ineligible for assistance after the six months earned income disregard period. Therefore the length of the projection period will coincide with the anticipated termination date of the FA up to a six-month period. The projected hours will be based on at least one representative week (as defined in “2” above) of verified paid hours. If hours vary each week, the projected hours will be based on an average of at least two representative weeks of verified paid hours. The average weekly hours projected will be calculated using the Paid Weekly Computation Worksheet (Attachment G). The verified hours for each representative week will be documented by the JOBS staff on the worksheet, totaled, and divided by the number of representative weeks that have been verified. Employment hours will be re-verified as stated above when the agency becomes aware of a change in the employment or during the last month of each projection period, whichever is earlier, for as long as the client is employed or receiving Family Assistance benefits. The process for reverifying the hours will begin in the month prior to the last month of the projection period (usually in the fifth month of the projection period) to allow sufficient time for receipt of the verification. The re-verified hours will then be calculated and projected for up to another six month period as stated above. B. Subsidized Private and Public Sector Employment: Subsidized Private or Public Sector employment may be full or part-time. 1. Services/Programs. Employment activities include all activities in the private or public sector for which the client receives compensation in the form of wages that are subsidized by public funds programs; i.e., governmental sources. Alabama DHR does not provide any subsidized private or public sector employment and is not aware of any other subsidized employment program serving DHR clients in the state other than college work study programs. Therefore, subsidized private and public sector employment in Alabama is restricted to the college work study programs that meet the guidelines. 2. Process for determining the number of hours to be counted. Alabama will count the actual number of hours reported by the educational institution or client’s pay stubs, or other documents verifying the number of hours the individual has actually been paid for work study.

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Alabama Work Verification Plan September 4, 2007 Since weekly hours to be counted must be based on hours for which it has been verified that the client was paid, the weekly paid hours will be verified as stated in “3” below after the client has actually received at least one representative week of pay. A representative week of pay is a week during which the client received pay for the number of hours for which the client states and the employer verifies are anticipated be paid each week. If the hours of pay vary from one week to another, at least two representative weeks of pay (showing the variation) will be verified and the average of the hours from the number of weeks verified will be used as the weekly hours. These weekly hours will then be projected as stated in “4” below. 3. Verification/Documentation of Hours. Acceptable verification includes check stubs provided by the client and written statements completed and signed by the employer. The client may provide a written statement from the employer or the form DHR-FAD-1532 or other DHR programs form may be sent directly to the employer for completion and return. A copy of written verification will be maintained in the case record and documented on the Paid Weekly Hours Computation Worksheet (Attachment G). If pay stubs or other employer produced documents cannot be obtained, the hours may be verified through a phone contact with the employer. The phone call will be documented in the case narrative and will include the date of the contact, the name and title of the person providing the verification, the number of verified hours, and the signature or initials of the person making the contact. 4. Projection of Hours: The number of hours will be projected using the method stated below for up to a six month period based on verification from the employer or client as stated in “3” above. Alabama’s FA Program policy allows up to a six months disregard of earned income. Because the FA benefit amount is so low, in most instances, families will be ineligible for assistance after the six months earn income disregard period. Therefore the length of the projection period will coincide with the anticipated termination date of the FA up to a six-month period. The projected hours will be based on at least one representative week (as defined in “2” above) of verified paid hours. If hours vary each week, the projected hours will be based on an average of at least two representative weeks of verified paid hours. The average weekly hours will be calculated using the Paid Weekly Computation Worksheet (Attachment G). The hours for each representative week will be documented by the JOBS staff on the worksheet, totaled, and divided by the number of representative weeks that have been verified. The results will be the number of weekly hours that will be projected and entered on the FACETS system. Employment hours will be re-verified as stated above when the agency

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Alabama Work Verification Plan September 4, 2007 becomes aware of a change in the employment or during the last month of each projection period, whichever is earlier, for as long as the client is employed or receiving Family Assistance benefits. The process for reverifying the hours will begin in the month prior to the last month of the projection period (usually in the fifth month of the projection period) to allow sufficient time for receipt of the verification. The re-verified hours will then be calculated and projected for up to another six month period as stated above. C. Work Experience: A work activity, performed in return for welfare that provides an individual with an opportunity to acquire the general skills, training, knowledge, and work habits necessary to obtain employment. 1. Services/Programs. The purpose of Alabama’s work experience program, which is called Community Employment or CEMP, is to improve the employability of those who cannot find unsubsidized employment. Placements are designed to help prepare the client to obtain unsubsidized employment by allowing him/her to develop a current work history and establish references for future employment seeking efforts as well as develop and improve marketable skills. Placements will be in both nonprofit and for-profit businesses. Placement in for-profit businesses will have shorter time frames (maximum of six weeks) than placements in non-profit businesses (maximum of six months). Before placement, each participant’s employment needs will be evaluated to determine the appropriate work site for that participant. The providers and the county DHR will sign an agreement which describes the responsibilities of both agencies, including the provider’s agreement to provide supervision, documentation, and verification of the client’s participation at the intervals requested by the county DHR, but no less frequent than every two weeks. The provider will document client participation hours for each day the client is scheduled to attend on the DHR Monthly Attendance/Progress Report. The sponsors will also evaluate each participant’s performance, send a written copy of the evaluation to DHR at mid-point of the assignment period and other intervals determined by DHR, and report any issues immediately. DHR will determine the number of participation hours for each client as stated in “2” below. 2. Process for determining the number of hours to be counted. Actual hours the client is engaged in CEMP activities will be documented by the CEMP provider on the Monthly Attendance/Progress Report (Attachment O) and sent to the JOBS staff every two weeks. The JOBS staff will use this information to calculate the average weekly hours to be counted as stated below.

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Alabama Work Verification Plan September 4, 2007 Alabama has requested and received approval to operate a mini-simplified food stamp program for TANF recipients. By using the amount of benefits to calculate the maximum number of required monthly hours the program will be in compliance with the Fair Labor Standards Act (FLSA). TANF assistance provided to work experience participants is not considered wages for Social Security, Federal income tax, or Earned Income Tax Credit purposes. Between the 1st and the 10th of the month following the month for which the hours will be counted, the JOBS staff will calculate the total number of hours using the Unpaid Hours Computation Worksheet (UHCW, Attachment H) based on the hours reported by the provider on the Monthly Attendance/Progress Report (Attachment O) and the JOBS staff’s determination of holidays and excused absence days. The UHCW is an Excel document designed to automatically calculate the total countable hours of participation based on the hours entered. The total hours will include actual hours of attendance, holiday hours, and up to two days per month and 10 days per 12-month period of excused absence hours. If there are more than two days of excused absence hours in any given month, only the hours from the two days with the highest number of excused absence hours will be counted. No more than 10 days of excused absence hours will be counted in any 12-month period. • The JOBS staff will determine the number of excused absence hours to be counted. When the client is absent for any reason, the provider will notify the JOBS staff immediately. The JOBS staff will contact the participant and determine if s/he had good cause for the absence. If so, the day on which the participant was absent will be documented as an excused absence day. If not, the day will be documented as an unexcused absence day. The maximum number of hours required will be calculated each month based on the actual amount of the client’s Family Assistance (FA) and food stamp benefits during the month for which the hours are reported. The actual amount of FA and Food Stamps benefits will be taken from the automated systems (FACETS and SCI-II, respectively) through which the benefits are issued and tracked. In addition to the UHCW Excel spreadsheet mentioned above, the State has developed an Excel spreadsheet, Community Employment (CEMP) Hours Calculation, which calculates the maximum number of monthly hours that may be required when the case manager enters the Family Assistance and Food Stamp benefits. See Attachment A. Partial hours in the totals are rounded down.

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Alabama Work Verification Plan September 4, 2007 • If the client participated for the maximum monthly required number of hours allowed under the FSLA as calculated using Attachment A and the total monthly hours when converted to average weekly hours (actual monthly hours divided by 4.33) do not equal to an average of 20 per week, the family will be deemed to have participated for an average weekly rate of 20 and reported according to federal reporting guidelines. If the client does not participate for the maximum monthly required number of hours or if the client participated for the required monthly number and the required monthly number results in a weekly average that is greater than 20, only the average weekly hours derived from the actual monthly hours will be reported, meaning no hours will be deemed or reported as such.

3. Verification/Documentation of Hours. Actual weekly hours will be tracked and documented by the provider on the DHR Monthly Attendance/Progress Report form (Attachment O) and submitted to the department every two weeks. The Monthly Attendance/Progress Report includes a list of the 10 holidays for which hours should be reported if the participant would have otherwise been scheduled to attend. The attendance form will be reviewed by JOBS staff upon receipt and any indication of a problem will be followed up on immediately. The form will be filed in the case record. 4. Method of Daily Supervision. Providers, as part of the approval process, must agree to provide daily supervision to the client. The provider agrees to notify the JOBS staff immediately if the client does not perform satisfactorily and/or fails to arrive at the work site at the agreed upon time. In addition the provider agrees to notify the JOBS staff at any point the provider becomes aware of barriers to employment such as problems with day care or the need for accommodations. The JOBS staff will work closely with the client and the work site supervisor to ensure that the placement is beneficial to the client and that all required work hours are performed satisfactorily. The provider will evaluate and document the client’s performance at the mid-point of the assignment period and send a copy of the evaluation to the JOBS staff. The JOBS staff will use the evaluation information to determine whether the placement will continue through the end of the assignment period. D. On-the-Job Training (OJT): Includes training that is given in the public or private sector to a paid employee while she or he is engaged in work and provides knowledge and skills necessary for full and adequate job performance. Employers are subsidized to offset the costs of training. 1. Services/Programs. OJT placements are available through the Alabama Department of Economic and Community Affairs (ADECA). See attachment N for program guidelines. While employed in an OJT position,

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Alabama Work Verification Plan September 4, 2007 the client will engage in productive work while receiving training in the knowledge and skills essential for adequate job performance. The client is compensated at a rate comparable to that of other employees performing the same or similar jobs, but at no less than minimum wage. At the end of OJT, the client should be retained as a regular employee. The additional on-site training in the skills and knowledge essential to job performance differentiates OJT placements from Subsidized Employment programs. In OJT the employee receives substantially more training and is not expected to perform immediately at the same level as other employees. In addition, the OJT provider is reimbursed for the costs of the extra training whereas with subsidized employment, the employer is reimbursed for the cost of the wages. 2. Process for determining the number of hours to be counted. Actual hours of the OJT will be documented and verified by the OJT provider or employer and reported to the Department on a written document. The process for determining the hours will be the same as the process described above for non-self-employment. 3. Verification/Documentation of Hours. Acceptable verification includes check stubs provided by the client and written statements completed and signed by the employer or OJT provider. The client may provide a written statement from the employer/OJT provider or the form DHR-FAD-1532 may be sent directly to the employer/OJT provider for completion and return. A copy of written verification will be maintained in the case record. If pay stubs or other employer/OJT provider produced documents cannot be obtained, the hours may be verified through a phone contact with the employer/OJT provider. The phone call will be documented in the case narrative and will include the date of the contact, the name and title of the person providing the verification, the number of verified hours, and the signature or initials of the person making the contact. 4. Projection of Hours. The number of hours will be projected using the method stated below for up to a six month period based on verification from the employer, client or OJT provider as stated in “3” above. The projected hours will be based on at least one representative week (as defined in “2” above) of verified OJT hours. If hours vary each week, the projected hours will be based on an average of at least two representative weeks of verified OJT hours. The average weekly hours will be calculated using the Paid Weekly Computation Worksheet (Attachment G). The hours for each representative week will be documented by the JOBS staff on the worksheet, totaled, and divided by the number of representative weeks. The results will be the number of weekly hours that will be projected.

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Alabama Work Verification Plan September 4, 2007 The hours will be re-verified as stated above when the agency becomes aware of a change in the OJT or in the month before the last month of each projection period, whichever is earlier, for as long as the client is in the OJT or receiving Family Assistance benefits. E. Job Search and Job Readiness Assistance. Help provided to clients in the areas of seeking or obtaining employment, preparation to seek or obtain employment. 1. Services/Programs. Job Readiness and Job Search Assistance include activities designed to assist participants in preparing and securing employment. Job readiness activities include classroom and one-on-one instructions on the following: • • • • • • • • • identifying and writing or orally expressing personal qualifications; Completing an employment application; Writing a resume Appropriate dress, hygiene and grooming; Effective interview behavior Expressing realistic expectations about salary and career development Appropriately responding to questions Following up after an interview Mental health and substance abuse counseling performed by a certified or licensed medical or mental health professional.

Job search activities includes structured job search supervised by a contracted provider or the DHR JOBS staff, including making contact with potential employers, whether by telephone, in person or via the Internet. The use of the Internet will allow the clients to learn about suitable job openings, applying for vacancies, and interview days of various agencies. Alabama has contracts with several service providers to provide combination Job Search and Job Readiness assistance as stated above for FA clients. In addition to the contracted programs, JOBS staff will also provide job readiness training and assistance with job search as described above. 2. Process for determining the number of hours to be counted. Actual hours the client is engaged in job readiness/job search activities will be documented by the job readiness/job search contractor or JOBS staff, as appropriate, on a daily basis. The limitation on four consecutive and six total weeks per fiscal year will be documented, tracked and enforced as stated in “3” below.

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Alabama Work Verification Plan September 4, 2007 For job readiness provided by a contractor, the contractor will maintain a daily attendance sheet of each participant’s hours of attendance, absences, and holidays. The attendance sheets will be signed daily by the participant and the contractor. For job search, the contractor will maintain a daily log of the time frame and number of contacts made by each participant. The log will be signed by the contractor and the participant. The information from the attendance sheets and/or logs will be individually recorded for each client by the contractor on the DHR Monthly Attendance/Progress Report and sent to the JOBS staff every two weeks. Upon receipt of the report, the JOBS staff will review the information on the report to ensure the client has participated as agreed in her/his individual JOBS participation plan and to identify any problem areas that have not been previously addressed. Problem areas will be addressed according to program policy through contact with the client and/or provider. The report will be filed in the participant’s case record until all hours for the month have been documented and reported. The JOBS staff will determine the number of excused absence hours to be counted. When the client is absent for any reason, the contractor will notify the JOBS staff immediately. The JOBS staff will contact the participant and determine if s/he had good cause for the absence. If so, the day on which the participant was absent will be documented as an excused absence day. If not, the day will be documented as an unexcused absence day. Between the 1st and the 10th of the month following the month for which the hours will be counted, the JOBS staff will calculate the total number of hours using the Unpaid Hours Computation Worksheet (UHCW, Attachment H) based on the hours reported by the provider or JOBS staff on the Monthly Attendance/Progress Report (Attachment O) and the JOBS staff’s determination of excused absence days. The UHCW is an Excel document designed to automatically calculate the total countable hours of participation based on the hours entered. The total hours will be entered on the FACETS system and will include actual hours of attendance, holiday hours, and up to two days per month and 10 days per 12-month period of excused absence hours. If there are more than two days of excused absence hours during any given month, only the hours from the two days with the highest number of excused absence hours will be counted and entered on FACETS. No more than 10 days of excused absence hours will be counted in any 12-month period. 3. Verification/Documentation of Hours. In situations where the job readiness/job search assistance is conducted by a contract provider, the contract provider will be responsible for verifying, documenting and tracking client participation daily, including attendance, absences and holidays, and for submitting this information to JOBS staff. The contract

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Alabama Work Verification Plan September 4, 2007 provider will complete and submit a copy of the Monthly Attendance/Progress Report to the JOBS staff every two weeks. The provider will notify the JOBS staff immediately when the participant fails to attend or is late and the JOBS case manager follows up immediately. The JOBS staff is responsible for determining whether the participant’s absence met the excused absence policy, i.e., if the participant had a good cause reason for not attending as required. In situations where the JOBS staff provides job readiness/job search assistance, the staff is responsible for providing daily supervision and guidance to the clients as well as documenting, verifying and monitoring the job search efforts. For job readiness, the JOBS staff will maintain daily attendance sheets signed by the participant and the JOBS staff attesting to the number of hours of participation for each day. For job search activities, clients will be contacted by phone or in-person on a daily basis to review the previous day’s job search efforts with the client and provide guidance for the next day’s activities. Contacts with clients will be documented daily in the case record. Each client will keep a daily log of employer contacts, DHR-WR-1707, “Record of Participation and Expenses,” that is submitted to the JOBS staff at the end of each week. Staff must randomly contact sites listed on the DHR-WR-1707 by the client to verify that a contact was made, an application was submitted and/or an interview was conducted. The number of weeks in job readiness/job search activities will be tracked manually by the JOBS staff using the Tracking Form to ensure that no more than four consecutive weeks and a total of six weeks per fiscal year are reported as countable (Attachment J). If the client participates for any length of time on any day falling in a calendar week (Sunday through Saturday) in the month, the week will be considered one of the four and six total weeks and recorded on the form. After a client has participated for four consecutive weeks and/or six total weeks, the client will not be coded as participating in countable job readiness/job search activities for the rest of the fiscal year. If a client engages in job readiness/job search activities after four consecutive weeks (meaning for any hours in the fifth consecutive week) and/or the six total weeks during any fiscal year, the JOBS staff will use a different code, UJOB, to indicate that the activities are not to be counted or reported for federal reporting purposes. Accuracy of the information on the forms and the transfer of the information to the computer system is reviewed and monitored as stated in the Internal Controls section below. The tracking form will be maintained in the case record. The number of weeks of the activity will also be tracked on the Client Participation Summary (Attachment K). 4. Method of Daily Supervision. Contract providers are required to meet daily in person or by phone with all clients in their program to provide

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Alabama Work Verification Plan September 4, 2007 supervision and guidance. Providers will also ensure that clients participate fully as required and assist clients with any barriers that have arisen either in the job search or in their personal lives. The JOBS staff will provide supervision and guidance in the same manner to clients not referred to a contract provider. F. Community service programs. Alabama does not have community services programs that meet the federal definition and guidelines at this time, but we are researching the possibility of developing such programs for the future, and will revise the Work Verification Plan accordingly. G. Vocational educational training. (not to exceed 12 months with respect to any individual) means organized educational programs that are directly related to the preparation of individuals for employment in current or emerging occupations requiring training other than a baccalaureate or advanced degree. 1. Services/Programs. Vocational educational training is organized educational programs that are directly related to the preparation of individuals for employment in current or emerging occupations requiring training other that a baccalaureate or advanced degree. It is also competency-based applied learning that contributes to a client’s academic knowledge, higher-order reasoning and problem-solving skills, life skills, work attitudes, employability skills, and occupation-specific skills through organized educational programs of sequenced courses. These courses should provide individuals with technical skills and academic knowledge needed for success in current or emerging employment sectors. It also, includes any formal instruction in a skill or trade, traditionally referred to as job skills training, determined by the JOBS staff to be other than purely academic in nature that prepares the client for a vocation, for example, technical programs designed to prepare a client for a specific occupation, including, nursing, plumbing, electrical, auto mechanics, welding and barbering. The training is limited to education that leads to useful employment in a state recognized occupation. Training is available to clients through WIA, vocational/technical schools, and some colleges/universities. Training includes courses for any state licenses, certificates, and/or degrees other than a four-year bachelor’s in the programs listed on Attachment P. 2. Process for determining the number of hours to be counted. Actual hours spent in class as well as time spent performing a clinical and lab work required for nursing or other vocational programs is considered to be a part of the primary activity for which it is required and will be counted. Time spent in supervised study halls will also be counted, but unsupervised homework time will not. Hours will be documented by the

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Alabama Work Verification Plan September 4, 2007 provider and reported to JOBS staff every two weeks on the Monthly Attendance/Progress Report (Attachment O), other written document prepared by the provider or orally with the provider over the telephone. The JOBS staff will determine the number of excused absence hours to be counted. When the client is absent for any reason, the provider will notify the JOBS staff immediately. The JOBS staff will contact the participant and determine if s/he had good cause for the absence. If so, the day on which the participant was absent will be documented as an excused absence day. If not, the day will be documented as an unexcused absence day. Between the 1st and the 10th of the month following the month for which the hours will be counted, the JOBS staff will calculate the total number of hours using the Unpaid Hours Computation Worksheet (UHCW, Attachment H) based on the hours reported by the provider or JOBS staff on the Monthly Attendance/Progress Report (Attachment O) and the JOBS staff’s determination of excused absence days. The UHCW is an Excel document designed to automatically calculate the total countable hours of participation based on the hours entered. The total hours will include actual hours of attendance, holiday hours, and up to two days per month and 10 days per 12-month period of excused absence hours. If there are more than two days of excused absence hours in any given month, only the hours from the two days with the highest number of excused absence hours will be counted. No more than 10 days of excused absence hours will be counted in any 12-month period. The countable hours will be entered on the FACETS system. 3. Verification/Documentation of Hours. The provider or classroom instructor will document client participation daily and provide written or oral documentation to the JOBS staff on the Monthly Attendance/Progress Report (Attachment O), other written document prepared by the provider and signed by the provider/instructor and client or orally with the provider over the telephone every two weeks. The report includes actual hours of attendance, absences, and holidays as defined by DHR. JOBS staff will file the report or other document and record its’ receipt in the case record in both narrative form and on the Unpaid Weekly Hours Computation Worksheet (Attachment H). 4. Method of Daily Supervision. The vocational educational training provider or classroom instructor will provide daily supervision in a classroom or other training style setting. Documentation: 1. Describe how the State ensures participation in vocational educational

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Alabama Work Verification Plan September 4, 2007 training does not count beyond the statutory limitations limiting participation to 12 months lifetime per individual. JOBS staff will manually track the months the client has participated in vocational educational activities and document the months on the Tracking Form (Attachment J). The tracking form will be filed in the case record. When a client is assigned to this activity, staff will use Alabama’s automated system, FACETS, to set a worker alert to indicate when a client’s participation in vocational educational activities has been counted for 12 months based on the documentation in the case record. After the hours have been counted for 12 months, the staff will take action to remove the hours from FACETS so that they are not reported as countable hours after the 12th month. DHR is developing automation to track the number of months an individual has been counted as participating in vocational educational training. Plans include an on-line counter that will be updated each month that the activity is counted. The Alabama Work Verification Plan will be amended when this programming is complete. 2. Explain how the State will ensure that basic and remedial education and English as a Second Language (ESL), if such activities are counted, are of limited duration and a necessary or regular part of the vocational education training. JOBS staff will review the curriculum for any program that includes basic and remedial education and English as a Second Language and also confirm with the providers that the activities are of limited duration and are a necessary or regular part of the training program. The findings and the confirmation with the provider will be documented in the case record, and will include the name of the person contacted, the date of the contact, and the signature or initials of the person making the contact. H. Job skills training directly related to employment means training or education for job skills required by an employer to provide an individual with the ability to obtain employment or to advance or adapt to the changing demands of the workplace. 1. Services/Programs. Training or education required as a prerequisite for employment or to advance or adapt to changing demands of current employment. Such training and education will provided through educational and training organizations. This activity includes all activities described above as vocational education and any four-year bachelor’s or advanced degree programs at any State certified college or university.

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Alabama Work Verification Plan September 4, 2007 2. Process for determining the number of hours to be counted. Hours will be counted only if the client is participating in a core activity for 20 hours. Actual hours of attendance will be documented by the provider and reported to the JOBS staff every two weeks on the Monthly Attendance/Progress Report (Attachment O) or orally over the telephone. Absences will be reported immediately to the JOBS staff for a determination of whether the hours of absence will be excused. JOBS staff will contact the client to determine if the client has good cause for the absence. If so the absence will be documented as an excused absence day. If not, the absence will be documented as an unexcused absence day. The JOBS staff will determine the number of excused absence hours to be counted. When the client is absent for any reason, the provider will notify the JOBS staff immediately. The JOBS staff will contact the participant and determine if s/he had good cause for the absence. If so, the day on which the participant was absent will be documented as an excused absence day. If not, the day will be documented as an unexcused absence day. Between the 1st and the 10th of the month following the month for which the hours will be counted, the JOBS staff will calculate the total number of hours using the Unpaid Hours Computation Worksheet (UHCW, Attachment H) based on the hours reported by the provider or JOBS staff on the Monthly Attendance/Progress Report (Attachment O) and the JOBS staff’s determination of excused absence days. The UHCW is an Excel document designed to automatically calculate the total countable hours of participation based on the hours entered. The total hours will include actual hours of attendance, holiday hours, and up to two days per month and 10 days per 12-month period of excused absence hours. If there are more than two days of excused absence hours in any given month, only the hours from the two days with the highest number of excused absence hours will be counted. No more than 10 days of excused absence hours will be counted in any 12-month period. The countable hours will be entered on the FACETS system. 3. Verification/Documentation of Hours. Actual hours of participation will be documented by the training/educational institution and reported to the JOBS staff every two weeks on the Monthly Attendance/Progress Report (Attachment O), other written document prepared by the provider/instructor or orally with the provider over the telephone. JOBS staff will file a copy of the report or other document and record it’ receipt in the case record narrative and on the Unpaid Hours Computation Worksheet (Attachment H) as the information is received. 4. Method of Supervision. Supervision will be provided on a daily basis by instructors in classroom and other training setting as determined

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Alabama Work Verification Plan September 4, 2007 appropriate by the educational institution. J. Education directly related to employment, in the case of a recipient who has not received a high school diploma or a certificate of high school equivalency means education related to a specific occupation, job, or job offer. Education directly related to employment must be supervised on an ongoing basis no less frequently than daily. 1. Services/Programs. Includes adult basic education and ESL, and where required as a prerequisite for employment education leading to a GED or high school equivalency diploma in any educational program approved by the Alabama Department of Education. 2. Process for determining the number of hours to be counted. Hours will be counted only if the client is participating in a core activity for 20 hours. Actual hours of attendance will be documented by the provider and reported to the JOBS staff every two weeks on the Monthly Attendance/Progress Report (Attachment O) or a written document signed by the instructor or provided orally over the telephone. Absences will be reported immediately to the JOBS staff for a determination of whether the hours of absence will be excused. JOBS staff will contact the client to determine if the client has good cause for the absence. If so the absence will be documented as an excused absence day. If not, the absence will be documented as an unexcused absence day. Between the 1st and the 10th of the month following the month for which the hours will be counted, the JOBS staff will calculate the total number of hours using the Unpaid Hours Computation Worksheet (UHCW, Attachment H) based on the hours reported by the provider on the Monthly Attendance/Progress Report (Attachment O) and the JOBS staff’s determination of excused absence days. The UHCW is an Excel document designed to automatically calculate the total countable hours of participation based on the hours entered. The total hours will include actual hours of attendance, holiday hours, and up to two days per month and 10 days per 12-month period of excused absence hours. If there are more than two days of excused absence hours, only the hours from the two days with the highest number of excused absence hours will be counted. The countable hours will be entered on the FACETS system. 3. Verification/Documentation of Hours. Actual hours of participation and good and satisfactory progress will be documented by the educational institution and reported to the JOBS staff every two weeks. Hours of unsupervised study will not be reported or counted. JOBS staff will document reported hours in the case record narrative and on the Unpaid

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Alabama Work Verification Plan September 4, 2007 Weekly Hours Computation Worksheet as the information is received. 4. Method of Supervision. Supervision will be provided on a daily basis by instructors in classroom and other training setting as determined appropriate by the educational institution. K. Satisfactory attendance at secondary school or in a course of study leading to a certificate of general equivalence, in the case of a recipient who has not completed secondary school or received such a certificate means regular attendance, in accordance with the requirements of the secondary school or course of study, at a secondary school or in a course of study leading to a certificate of general equivalence, in the case of a recipient who has not completed secondary school or received such a certificate. 1. Services/Programs. Includes education leading to a GED or high school equivalency diploma in any secondary educational program approved by the Alabama Department of Education. 2. Process for determining the number of hours to be counted. All hours are counted as core for teen parents (under age 20). For all other clients, hours will be counted only if the client is participating in a core activity for 20 hours. Actual hours of attendance will be documented daily by the provider on attendance sheets or other school documents and reported to the JOBS staff every two weeks on the Monthly Attendance/Progress Report (Attachment O) or orally over the telephone. Absences will be reported immediately to the JOBS staff for a determination of whether the hours of absence will be excused. JOBS staff will contact the client to determine if the client has good cause for the absence. If so the absence will be documented as an excused absence day. If not, the absence will be documented as an unexcused absence day. Between the 1st and the 10th of the month following the month for which the hours will be counted, the JOBS staff will calculate the total number of hours using the Unpaid Hours Computation Worksheet (UHCW, Attachment H) based on the hours reported by the provider on the Monthly Attendance/Progress Report (Attachment O) and the JOBS staff’s determination of excused absence days. The UHCW is an Excel document designed to automatically calculate the total countable hours of participation based on the hours entered. The total hours will include actual hours of attendance, state-defined holiday hours, and up to two days per month and 10 days per 12-month period of excused absence hours. If there are more than two days of excused absence hours, only the hours from the two days with the highest number of excused absence hours will be counted. The countable hours

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Alabama Work Verification Plan September 4, 2007 will be entered on the FACETS system. 3. Verification/Documentation of Hours. Actual hours of participation and good and satisfactory progress will be documented by the educational institution and reported to the JOBS staff every two weeks. Hours of unsupervised study will not be reported or counted. JOBS staff will document reported hours in the case record narrative and on the Unpaid Weekly Hours Computation Worksheet as the information is received. 4. Method of Supervision. Supervision will be provided on a daily basis by instructors in classroom setting. L. Providing child care services to an individual who is participating in a community service program. This will not be a work activity in Alabama at this point. II. Hours Engaged in Work This section includes two topics: excused absences and FLSA deeming. Describe the State’s excused absence policies for unpaid work activities. This includes its policies for holidays as well as the ten additional excused absences that the State may count in a 12-month period. If the policies vary by work activity, the State should describe how they vary and for which activities. Alabama’s allowable holidays policy is as follows: The countable holidays are the same for all unpaid activities. The hours may be counted as actual hours only if the provider is closed to business or the provider allows the client the time off in observance of one of the holidays listed below and the holiday falls on a day the client would have otherwise been scheduled to attend the activity. Countable holidays are restricted to 10 days per fiscal year for observance of the following events: New Year’s Day; M.L. King/R.E. Lee Birthday; G. Washington/T. Jefferson Birthday; National Memorial Day, Independence Day; Labor Day; Columbus Day/Am. Indian Heritage Day; Veteran’s Day, Thanksgiving Day; and Christmas Day. These are nationally recognized holidays and must be observed on the same day(s) as observed nationally. For easy reference for the service provider, the holidays are listed on the Monthly Attendance/Progress Report (Attachment O), which is the document most service providers will use to report hours to the JOBS staff. Alabama’s excused absence policy is as follows:

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Alabama Work Verification Plan September 4, 2007 JOBS staff will determine excused absence days. Absences will be reported immediately to the JOBS staff for a determination of whether the hours of absence will be excused. JOBS staff will contact the client to determine if the client has good cause for the absence as stated in sections 705 and 710 of the JOBS Program Policy Manual. If so, the absence will be documented as an excused absence day. If not, the absence will be documented as an unexcused absence day. Since the maximum number of countable excused absences may not exceed 2 days per month and 10 days per 12-month period, any day that the participant is absence with good cause for any part of the day’s scheduled hours will be considered an excused absence day for the month. The first 12-month period for each client begins with the first month after September 30, 2006 in which any excused absence days are counted and ends in the twelfth month from that month. Each 12-month period thereafter begins with the first month after the previous 12-month period in which any excused absence days are counted and ends in the twelfth month from that month. The JOBS staff will document all excused absence days on the Unpaid Hours Computation Worksheet. The excused hours that will be counted each month will be the total hours of the two excused absence days that had the most excused absence hours. The JOBS staff will manually track the days each month by entering the number of excused absence days counted for each month of each 12-month period on the Tracking Form (Attachment J) and Client Participation Summary (Attachment K). The Tracking Form and summary will be maintained in the client’s case record to ensure that no more than ten days of excused absence hours will be counted in any 12-month period. Between the 1st and 10th of each month the reported hours, which includes hours attended and holiday hours) and excused absence hours (up to the maximum) for the previous month will be calculated by JOBS staff using the Unpaid Hours Computation Worksheet, an Excel spreadsheet that calculates hours (Attachment H), and the results entered on Alabama’s automated system (FACETS) as the weekly hours to be counted for the previous month. FLSA Deeming If the State wishes to use the “deeming” provision permitted at §§ 261.31 and 261.32 for work experience or community service programs, describe how the State determines the work hours requirement, including how the monthly TANF grant and food stamp allotment are combined and divided by the appropriate minimum wage to meet the “core” participation requirement. Include a statement certifying that the State has adopted a “mini” Simplified Food Stamp Program in order to count the value of food stamp benefits. DHR certifies that it has received approval from the Food and Nutrition Service to operate a mini-simplified food stamp work program for TANF recipients. The

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Alabama Work Verification Plan September 4, 2007 approval letter is on file in the department. As a result, Alabama has chosen to use the “deeming” provision permitted at §§ 261.31 and 261.32 for work experience programs which are called Community Employment or CEMP. The maximum number of hours a client will be required to participate in a Community Employment work experience placement will be calculated based on the amount of the client’s Family Assistance (FA) and food stamp benefits. Each month, the case manager will retrieve the previous month’s amount of FA benefits from the FACETS computer system and amount of Food Stamps benefits from the food stamp automated system, SCI-II, to determine the family’s food stamp benefit. The State has developed an Excel spreadsheet that calculates the number of monthly and average weekly hours when the case manager enters the Family Assistance and food stamp benefits. See Attachment A. If the food stamp household contains non-TANF recipients, the amount of food stamps to use in the calculation will be prorated based on the number of TANF members in the household. The worksheet calculates the prorated amount of food stamp benefits and adds it to the full FA benefit. The total of the two benefits will then be divided by the federal minimum wage since Alabama does not have its own minimum wage. The resulting figure will be divided by 4.33 to determine the maximum number of monthly and average weekly hours. Partial hours are rounded down. DHR policy requires that the JOBS staff secures verification of the actual number of hours participated and determine the number of excused and unexcused absence hours prior to entering the information on the automated data system. The number of actual hours the individual participates in CEMP is tracked daily by the CEMP provider and submitted to DHR every two weeks on the Monthly Attendance/Progress Report (Attachment D) or other comparable documentation submitted by the provider to DHR. Participation is monitored by the JOBS staff and absences are followed up on immediately to determine the number of excused or unexcused days for the month. At the end of the month the number of hours the individual participated during the month and the excused absence hours (as explained in C. 2 above) are used in determining the average weekly hours for the month. If the average weekly hours is below 20 for any month, the deemed hours will be the number of hours necessary to make the average equal 20, i.e., 20 minus the number of average weekly hours. If the average number of hours equal 20 or more, no hours will be deemed. The number of hours as well as the date the information was verified is entered on ZD23 on FACETS. In addition to the documentation on FACETS, the written documentation received from the CEMP provider is filed in the case record. Programming for the TANF Data report is being changed to add the difference between the actual hours and the deemed hours (20) to the Waiver fields per federal verbal instructions. III. Work-Eligible Individual

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Alabama Work Verification Plan September 4, 2007 Documentation: 1. Describe the state’s procedures for identifying all work-eligible individuals, as defined at 261.2. This should include the procedures needed to identify a non-recipient parent excluded from the definition of work-eligible individual. Alabama DHR has procedures in place to identify all parents who reside with a child receiving assistance and to determine whether each parent, whether recipient or non-recipient is a “work-eligible individual”. Included in the state definition of work eligible are all adults (or minor heads-of-household) who are included in the assistance grant as well as all non-recipient parents living with a child receiving assistance with the exception of those excluded individuals described below. Work eligible individuals and individuals who are excluded from the definition of work eligible are identified by the Public Assistance (PA) worker during the Family Assistance (FA) eligibility determination process and by the JOBS case manager during the JOBS work assessment process as described below. The information used in the identification processes is entered on the FACETS system through use of FA eligibility, relationship, hardship and work eligible codes and the dates of birth. The formula, which describes the combination of FACETS codes to be translated to DHHS/ACF codes, is programmed in the FACETS system and run in a batch process. Identification of Work Eligible Individuals: During the FA eligibility determination process, the eligibility staff gathers, documents and verifies the information necessary to identify work eligible individuals. The head of household (FA assistance unit) must provide certain information on all persons living in the home including each person’s relationship to her/him and to each child receiving assistance. The head of household must swear to the validity of all information provided and sign an affirmation that this information is accurate. See Attachment B. The required information also includes the following for all parents living in the home, regardless of whether the parent receives assistance: • • Identifying information (name, age, social security number, employment or other income information and address if known); and Whether the parent has been found guilty in court of a drug felony or is a convicted felon who is fleeing to avoid trial, arrest or jail. The responses are stored electronically on FACETS on screen, ZC92. See Attachment C. Whether the individual is caring for a disabled family member living in the home who is not in school full-time.

This information is documented on FACETS for the head of household, spouse of the head of household, each recipient, and each parent living in the

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Alabama Work Verification Plan September 4, 2007 home who has a child receiving assistance through the use of FA eligibility, relationship, and hardship codes and the date of birth of the individual. The relationship codes identify the head of household, spouse of the head of household, and each adult parent living in the home, and indicate whether each of these individuals is receiving assistance and/or has a mutual child receiving assistance with another individual living in the home. The definition for each code is displayed on help screens on FACETS for easy reference. See Attachment M. The FA eligibility code indicates whether the individual receives assistance, is an SSI recipient, ineligible alien, or convicted felon or other individual who must be excluded from receiving assistance according to federal guidelines. The hardship code is used to indicate that a parent is caring for a disabled family member living in the home who is not in school full-time. The date of birth is used to determine if the individual is an adult or minor. Additional Identification of Excluded Work Eligible Individuals: In addition to the identification of work eligible individuals as described above, Alabama has added a field on screen ZD21 for JOBS staff to confirm or otherwise indicate whether an individual is work eligible, excluded because the individual is a minor child or a minor parent who is not the head of the household or spouse of head of household, or excluded because s/he meets the federal definition of caring for a disabled family member. The work eligible codes are used in conjunction with the codes described above in various combinations to identify the following individuals who are excluded from the definition of work eligible individuals: • • • • An alien parent who is ineligible to receive assistance due to his or her immigration status. These individuals are identified by a special participation status code. SSI recipients. These individuals are identified by a special participation status code. Alabama has elected not to include these individuals as work eligible. A minor parent who is not the head (or spouse of a head) of household. These individuals are identified by their date of birth, relationship and work eligible codes. A parent providing care for a disabled family member living in the home who does not attend school on a full-time basis, provided that the need for such care is documented by use of the form DHR-PAD-1876 completed by a physician or licensed psychologist. Documentation must also be in the case record that the child is not attending school full-time.

The exclusion for an individual in a family receiving MOE-funded assistance under an approved Tribal TANF program, unless the State includes the Tribal family in calculating work participation rates, is not applicable to Alabama.

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Alabama Work Verification Plan September 4, 2007 The State should also describe its procedures for identifying a parent caring for a disabled family member, who may also be excluded from the definition of a workeligible individual. The procedures should define the terms “disabled,” “family member” and “attending school full-time.” This should include a means of ensuring that the need for care in the home is supported by medical documentation and describe the nature of the medical documentation used to make such determinations. If the State includes in this group parents caring for a family member with a temporary disability, the State must describe its procedures for determining when the family member is no longer disabled and ensuring that the parent is then identified as a work-eligible individual. Definitions Disabled – For the purpose of determining the work eligible status of a parent of a child receiving assistance, disabled is defined as “a physical, mental or emotional illness or impairment that substantially reduces the individual’s ability to care for himself. The condition must be supported by medical evidence and expected to last longer than 30 days. The disability must be severe enough to require the full-time presence of a caretaker. A physician or licensed psychologist must verify both the condition and the need for a fulltime caretaker. The documentation must also include a statement about the length of time the condition is expected to last. Family Member – A family member is a person living in the home who is related to the parent providing the care as follows: • • • • • • • • • • Parent, including natural or step-parent (but not the parent of a stepparent); Spouse; Mother-in-law, father-in-law; Child (natural, adoptive, or step), grandchild (including step or adoptive), great-grandchild, great-great grandchild, great-great-great grandchild; Sibling, (natural, step, or adoptive); Grandparent (natural, adoptive, or spouse of natural or adoptive), great, great-great, great-great-great; Aunt/uncle, great- and great-great aunt/uncle; Niece/nephew; First cousin or first cousin once removed (meaning the first cousin of the client’s parent or the child of the client’s first cousin; and The spouse of any relative listed above.

NOTE: Blood relationships are not severed by adoption. Also, an individual who has ever been related to the parent as an “in-law” or “step” within the degrees listed above is considered a family member. Full-time school attendance – is defined by the school or institution.

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Alabama Work Verification Plan September 4, 2007 Caretakers of individuals who are attending school part-time are not excluded from work participation requirements. 2. Verification procedures are in place for ensuring the accuracy in reporting of work-eligible individuals on the TANF Data Report including: • • The correct reporting of the Work Participation Status of all adult (or minor child head-of-household) family members, and The proper identification of TANF Families for inclusion in only the overall work participation rate or the overall and two-parent work participation rates, or exclusion from both the overall and two-parent work participation rates.

The verification procedures for ensuring the accuracy in reporting of work eligible individuals are as follows: The information described above that is used to determine whether an individual is work eligible is verified by the PA staff according to Family Assistance Program policy as stated in Chapter 23, Section 23005 through 23015. See Attachment F for acceptable verification sources. A copy of all relationship verification is maintained in the FA case record and the verification source codes and the dates the relationship was verified for the head of household and her/his spouse are entered on the system’s relationship screen. A combination of data fields is used by the workers and the FACETS system to indicate whether a family is included in the overall work participation rate, the overall and two parent work participation rate or excluded from both the overall and two-parent work participation rates. • Any case where there is at least one adult (including the spouse of the head of household, regardless of age, and a non-recipient parent of an child receiving assistance) or minor parent head of household of a child receiving assistance is included in the overall work participation rate unless that adult or minor parent head of household is not work eligible. Any case where the only adults (including the spouse of the head of household, regardless of age, and a non-recipient parent of an child receiving assistance) or minor parent head of household are excluded from the federal definition of work eligible will be considered a child only case and not included in either work rate. NOTE: Under Alabama’s FA policy, all parents and their spouses living in the home must be included in the grant, except those who are SSI recipients, ineligible aliens, or otherwise ineligible for TANF assistance according to federal TANF regulations. The only adults in the home who may be included in the grant are the parents of a child who is receiving

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Alabama Work Verification Plan September 4, 2007 assistance or the spouse of a parent of a child receiving assistance. Nonparent adult relatives may not be included in the grant. Furthermore, Alabama imposes full-family sanctions for all failure to cooperate with work and/or child support requirements; therefore, no individual is excluded from the grant due to a sanction. These individuals, unless they meet one of the exclusions described above, are considered as work eligible and included in the overall and two-parent work participation rate, if there are two natural or adoptive parents of a mutual child. Each month all pertinent data needed to identify work eligible status of each parent is extracted and saved for use in the TANF data report. This includes age, relationship of the adult to the child receiving assistance, whether included in the grant or not, work eligible status and adult/child status in the grant. 3. The state has policies and procedures in place to ensure that, for each work eligible individual, it accurately inputs data into the automated system, properly tracks the hours, and accurately reports countable hours to HHS. Policy addressing these issues is found in the Assistance Payments Manual (APM), the FACETS User’s Guide and the JOBS Program Policy Manual. Workers are instructed to refer to these manuals for proper coding of the data elements that determine work eligible status. Program supervisors are instructed to review the data elements used to determine accuracy as part of their record reviews. State office reviews also include a review of this information. Proper tracking and documentation of actual hours of either paid employment or component participation is required by agency policy and monitored as well. Specific information on how the state accurately reports the hours to HHS is included in Section V. The State has defined countable and non-countable activities in the JOBS Program Policy Manual based on Federal definitions. Each activity is entered on FACETS using a specific code. Since each activity has a separate code, only those activities that meet the federal work definitions are pulled for inclusion in the TANF Data Report. The weekly number of participation hours and the placement and termination date is tracked on FACETS. Workers use the Unpaid Hours Computation Worksheet, Attachment H, to determine the average actual weekly hours of participation, including holiday and excused absences during the month. Two other forms are used by the JOBS case managers to document client participation activity. The Tracking Form, Attachment J, is used to track the number of months of vocational education training, days of excused absences and the number of weeks of job readiness/job search to ensure that the federal limits are not exceeded and the Client Participation Summary, Attachment K, which is a comprehensive listing of all client activities for the year used for documenting client activities. All hours reported for any individual are for months in which the individual

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Alabama Work Verification Plan September 4, 2007 received assistance for the entire month. No hours will be reported for an individual who received a partial month’s benefit. The average weekly hours reported for any month will be calculated by totaling the number of actual hours of participation for the month and then dividing that total by 4.33. However, this calculation is not straightforward at this point because of existing system programming which automatically recalculates the average weekly hours entered by the JOBS staff under certain circumstances. The automated recalculation was put into place to ensure that the average weekly hours reported were representative of the client’s participation in each activity for the entire month, regardless of the date the client started and/or ended participation during the month. This programming is being changed to make the calculation straightforward. Until this programming change is completed, interim steps as described below are being taken to ensure that the final results of the existing automated recalculation is the total actual hours of participation divided by 4.33. It is important to note that during the interim, the average weekly hours entered and displayed on the FACETS screen ZD23 will be different from the average weekly hours that are actually reported. Interim steps: Currently, there is no field on FACETS for staff to indicate the total number of actual hours of participation in an activity for any given month. There is only a field to indicate the average weekly hours. Because the actual monthly hours cannot be entered on the system, the automated recalculation process calculates the actual monthly hours based on the average weekly hours and the start and end dates of the activity as entered by the JOBS staff. Step 1: The JOBS staff calculates the total number of actual hours for the entire month and the average weekly hours for the weeks of participation in each activity for each month using the Unpaid Hours Computation Worksheet. The average weekly hours for the time frame of participation are then entered on the system for each activity based on the start and/or end date of the activity as stated below. These hours are not the average weekly hours that are reported, except as specified in step 2 below. • If the client begins the activity during the first week (seven days) of the month, the total actual hours of participation for the entire month is divided by 4.33, and the results is entered on the system as the average weekly hours for the period of participation. If the client begins the activity any time after the first week of the month, the total actual hours of participation for the entire month is divided by the appropriate divisor from the chart below for calculating the average weekly hours for the period of participation during that month: Date of Month Started 1st – 7th Divisor 4.33

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Alabama Work Verification Plan September 4, 2007 8th – 14th 15th – 21st 22nd – end of month • 3.25 2.167 1.08

If the client ends the activity during the month, the following chart is used to determine the divisor for calculating the average weekly hours for the participation period for that month: Date of Month Ended 1st – 7th 8th – 14th 15th – 21st 22nd – end of month Divisor 1.08 2.167 3.25 4.33

If the client begins and ends the activity during the month, the first chart is used to determine the divisor for calculating the average weekly hours for that month’s period of participation.

Step 2: When the data for the TANF Data Report is captured for the extract, an automated program looks at the start and end date of the activity to determine if the average weekly hours should be re-calculated to indicate the average weekly hours for the entire month, rather than the date the client started and/or ended the activity. • If the date started is in a month prior to the month for which the hours are reported (report month) or is the 1st through the 7th of the report month and/or the date ended is the 22nd or thereafter in the report month, there is no automated recalculation. Instead, the average weekly hours entered by the JOBS staff are reported. If the date started and/or date ended is any other date of the report month, the average weekly hours are recalculated as stated in step 3 below.

Step 3: If necessary, the recalculation is done by multiplying the average weekly hours that the JOBS staff entered by the divisor the JOBS staff used to determine the weekly average. This recalculation results in the same number of total actual hours for the month that the JOBS staff verified and entered on the Unpaid Hours Computation Worksheet. The total of the actual monthly hours is then divided by 4.33 and the results are reported as the average weekly hours for the entire month. Each month, county supervisors and staff in the Family Assistance Division in the state office receive report PSWJR091, listing the SSNs of all adults receiving FA who are not open on the JOBS side of FACETS. Policy instructs county staff to review this report each month and reconcile the cases, either by opening the case on JOBS or correcting the referral status code on FA. Staff members are

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Alabama Work Verification Plan September 4, 2007 also instructed to review the PSWJB025 report (Attachment L) each month to look for inconsistent combination of codes involving JOBS Participation Status, age, component activity, and attendance. Report PSWRJ510/PSWRZ021, 2 Parent Adults Regular TANF Transmission, is used to review the data on 2 parent families for consistencies. Data Items included on the report are: • • • • • • • • • • • Adult Records which have a case # that matches a Family included on the report County (regular not FIPS) Report Year Report Month TANF Case # SSN DOB Relationship to HOH Work Participation Status Work Eligibility Indicator Type Family

Data Items which are being added to the report include: • Family Affiliation • Parent With Minor Child IV. Internal Controls Alabama has internal controls and processes in place to ensure a consistent measurement of work participation. Alabama agrees to maintain all information submitted to ACF. This information is available for use by ACF and other auditors in their review of the State’s work participation verification system. Documentation: 1. Describe the internal controls designed to ensure established work verification procedures are properly being employed. Such controls may include supervisory guidance, policy directives, and staff training plans, as well as quality assurance processes, such as monitoring procedures to ensure adherence to procedures by staff, providers and contractors. For example, to ensure the State is identifying all work-eligible individuals, a State may periodically check the disability status of a family member who is temporarily disabled, as the parent caring for the disabled family member would become a work-eligible individual once the family member is no longer disabled. Alabama has a multi-prong approach to ensuring that information is gathered, Page 28 of 39

Alabama Work Verification Plan September 4, 2007 entered and accurately kept. State office staff is responsible for developing and issuing all Family Assistance and JOBS policy and procedures for county staff. The policy governing the TANF program in Alabama is included in the Alabama Administrative Rules, the Assistance Payments Manual, the FACETS Users’ Guide and the JOBS Program Policy Manual. New policy, before it is incorporated into one of the manuals, may be distributed to county staff in administrative letters, policy memos or through the electronic newsletter. Policy specifically addresses how to document all actions related to work participation, exclusion from work participation requirements and participation hours. It also addresses proper coding of the fields mentioned in the section on Work Eligible Individuals above. All new eligibility and JOBS workers are provided state-level basic training after receiving preliminary training by county supervisory staff. Basic training for both eligibility and JOBS staff includes all facets of basic policy and procedures staff members need to do their job correctly. Training also includes hands-on training on the automation system. Emphasis is placed on entering the data timely and accurately. All new supervisors are trained by the appropriate consultant. In addition, regional meetings are held periodically with all staff, or at a minimum, all supervisors. Family Assistance staff provides other training and assistance upon request by the counties and when needed for corrective action. Monitoring of staff activities through case record review is an integral part of county worker supervision. Every month county supervisors are required to review 5 Family Assistance cases per eligibility worker and submit the findings to the state office (See Attachment D). Because of the number of items reviewed, JOBS supervisors are required to review 3 JOBS cases per month per case manager and submit the findings to the state office. See Attachment E. Detailed instructions are provided to staff that include how to pull the sample in order to ensure the validity of the sample. Data contained in the paper case record as well as on the FACETS computer system is reviewed for accuracy, timeliness and completeness. Particular attention is focused on those data elements affecting an individual’s employment and/or participation in work activities. Monitoring includes a review of the case for correct coding of one or two parent family status, disability status and supporting documentation, and verification of actual participation hours. State staff reviewers select a sample of the reviews completed by the county supervisors. Each county is reviewed each year and corrective action plans implemented as needed. The review documents and the data elements reviewed are included in attachments D and E. Findings from the monthly reviews and state-office re-reviews are used in the yearly evaluation of county directors. Information on the types of errors found during the review is incorporated into basic training and/or provided to counties through regional meetings or policy memos. This information is also shared with county directors and supervisors on a regular basis.

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Alabama Work Verification Plan September 4, 2007 The Unpaid Hours Computation Worksheet has been developed to assist workers with tracking participation hours. See Attachment H. This form is described earlier in the Work Verification Plan under the Verification/Documentation of Hours Section for each activity. Use of this form ensures that the case manager documents the participation hours accurately and completely and it also tracks the number of excused absence days for the month. Another form, the VOCT and JOBS/JOBR Tracking Form, has been developed to track the months of client participation in vocational education training and the weeks of client participation in job readiness/job search activities to ensure that the limits are not exceeded. See Attachment J. These forms are filed in the client’s case record. An additional form, Client Participation Summary, has been developed to show a summary of the client’s participation for each month during the fiscal year, including the average weekly component and employment hours, excused absence days, weeks counted in job search/job readiness activities, and whether the client is in vocational education training. See attachment K. These forms are used to ensure that the state accurately tracks the client’s participation and does not exceed federally mandated time limits. Employment information tracked on FACETS on screen ZD11 includes name and address of employer, date of employment, hourly wage, monthly income, number of hours per week worked, verification source and date and type job. Each type of employment, unsubsidized, subsidized private and public, OJT, work study and self-employment is identified by a separate code. If the number of actual paid hours is not verified at the time the employment data is entered, the worker is instructed to enter 99 hours. This flags the programmer not to count these hours in the TANF Data Report. As soon as the paid hours are verified the actual number of hours is entered. A worker alert is set to remind the worker to follow up with securing the employment verification. Counties are sent a report monthly that lists all employments over 60 hours per week. This serves as a reminder, in addition to the worker alert, that the paid hours need to be verified. Component information is tracked on FACETS on screen ZD23. In addition to the basic information on provider, date placed in component and number of hours, there are several fields that track attendance and progress of the participant in the component. Workers are instructed to update these fields each month after they have received the Monthly Attendance/ Progress Report from the provider and have verified the average weekly hours in the component. Report PSWJB025, sent to the counties each month, lists the most current component placements and closed components, up to five. Workers are instructed to use this list to monitor placements and attendance. Supervisors use this list to monitor worker activities. 2. Describe the internal controls to control for data errors, including transcription and coding errors, data omissions, computational errors, and compilation errors.

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Alabama Work Verification Plan September 4, 2007 For example, a State might automatically review the case record of each workeligible individual whose reported average weekly hours of participation are unusually high (e.g., 70 or more hours per week) by examining the documentation used to support those hours. Alabama has incorporated many checks and balances to control for data errors in addition to the record reviews. Assignment of a family as a two parent family is done automatically by FACETS using the data entered elsewhere on the system by the eligibility worker. This programming eliminates the chance for worker error. In addition, JOBS workers are automatically notified when the parent’s status changes from one to two-parent and vice-versa. This alerts the worker to assess the case for possible changes in participation requirements. Additional information is used to determine whether the individual’s work eligible status removes the individual from work participation calculations. FACETS system edits are used to prevent entry of incorrect data. FACETS is programmed to consider all parents as work eligible unless the worker enters information that would make the parent not work eligible. Other checks and balances are based on county supervisors reviewing the data monthly to look for specific types of errors. A major report used monthly by county supervisors and state office consultants is the PSWJR091 that identifies all recipients age 16 and up who are open for Family Assistance but who are not open for JOBS (work program). This allows staff to quickly identify cases that need to be opened and assessed. Each JOBS case manager gets a printout, PSWJB025, which lists all open JOBS cases each month. This report includes all work activities to which the individual has been assigned and is a good tool for workers and supervisors for monitoring client activity or lack of activity. Both the case manager and the supervisor are instructed to review this printout for inaccuracies in data, to determine overdue cases and to validate that all data on an individual is consistent and accurate. This report is also used to ensure that assessments, reassessments, and other follow-up actions are completed timely by comparing the current date to the participation (PART STAT) code, the date (STAT DATE) the client was placed in that status, and the date the next action is/was due. Other fields to be monitored include referral status (adult recipient, minor child head of household or spouse or minor child not head of household) and inclusion in a two parent household. Another report, PSWJR103 A and B, lists all clients with employment, component and/or combination employment and component hours in excess of 60 hours per week. Employees are instructed to reconcile this list monthly by reviewing each individual listing and making changes as appropriate. Several other reports, as discussed in other sections, are available to help with data accuracy as well. 3. Describe the checks used to isolate electronic systems and programming errors and the steps to ensure that all work participation report items are internally consistent. For example, a State might obtain the raw data (prior to input into an automated data processing system) for a sample of work-eligible

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Alabama Work Verification Plan September 4, 2007 individuals and determine manually the average weekly hours of participation for each work activity for a month and compare that result to what the State actually reported to HHS. Alabama has several reports that are produced monthly to help check for system errors. One such report is PSWJR103-A and B which identifies clients with excess employment, component and/or combination employment and component hours. Supervisors and case managers are instructed to review this report each month and clean-up discrepancies. This report goes to both the eligibility worker and the JOBS case manager, if different. In addition, as supervisors and state office staff review the paper case record they also compare the information in the case record with information recorded on the FACETS computer system. Supervisors also compare the FACETS information such as component hours with the original source document received from the component provider. All inconsistencies found must be corrected. Examples of data inconsistencies looked at and reconciled include: - comparison of # of adults in house with one or two-parent status - comparison of age of JOBS participant with work eligible status and referral category - comparison of relationship to Head of Household to all other adults in the case - Family affiliation code and number of parents in case - whether adult parent is participating in JOBS program - Employment hours are entered on FACETS but paid hours are not verified - Participation hours are assigned but client was never placed in work activity - client was non-compliant with JOBS but no sanction information has been entered by the eligibility worker. Alabama also has edits on FACETS that prohibit certain key fields such as the individual’s relationship to the head of household and FA participation status from being left blank. These are critical fields used in determining Family Affiliation, Work Eligible status, and Parent of Minor Child. Edits are also in place when collecting the data for the Federal TANF Data Report to identify error prone information. Additional information of these major edits is included in the section on Verification of Data Used in Calculating the Work Participation Rate. The state also uses the error reports sent by ACF to identify and fix reporting errors. State office staff receives a paper copy of the TANF report for one of the largest counties in the state. This report, PSWRZ034, includes all information on all data elements submitted to ACF. Another report, PS278SPFI, contains all of the data stored on the data extract used to complete the TANF Data Report. A sample of these cases is reviewed and the data from both reports is compared to the data on FACETS. In the past, based on a comparison of data on these reports, edits have been added to FACETS and/or to the TANF Data Report as appropriate to prevent data inconsistencies. Additional edits will be added if future evaluations indicate the need.

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Alabama Work Verification Plan September 4, 2007 4. Describe any sampling and estimation techniques employed in data validation. The Work Verification Plan should document the soundness of all statistical procedures utilized in the verification process. All estimation techniques must be reasonable and fully described in the plan. For estimates based on sampling or other statistical techniques, the plan must contain, as appropriate, the step-by-step computations of precision, affirming that the produced estimates are within statistically acceptable levels of reliability and validity. Alabama currently does not have any sampling and estimation techniques employed in data validation except for those mentioned above. However, the state is exploring several different ways to incorporate statistically valid sampling processes. Any new policy and procedures decided upon will be in place by September 30, 2007 and the Work Verification Plan will be amended if changes are made. V. Verification of Other Data Used in Calculating the Work Participation Rates Under the “complete and accurate” standard for data reporting, States should validate all data submitted in its TANF Data Report and, if applicable, the SSPMOE Data Report. In addition to the work activities, the following data elements are used in calculating the work participation rates: • Reporting Month • Stratum • Case Number • Disposition • Type of Family for Work Participation • Amount of Food Stamps Assistance • Receives Subsidized Child Care • Amounts of TANF (and SSP-MOE) Assistance • Family Affiliation Code • Non-custodial Parent Indicator • Date of Birth (Adult) • Relationship to Head-of-Household • Parent with Minor Child • Work-Eligible Individual Indicator • Date of Birth (Child) The Work Verification Plan should contain the procedures needed to establish that the State has the capacity to breakout TANF families with a work-eligible individual by the case characteristics that relate to the special rules and conditions of participation, such as receipt of child care, age of child, age of adult or teen parent, number of months under a sanction, adult or teen parent with satisfactory school attendance, and families with a disabled family member (adult Page 33 of 39

Alabama Work Verification Plan September 4, 2007 or child). Documentation: 1. For each of the above data elements, describe the State’s data validation procedures to ensure “complete and accurate” data reporting. Since the above list contains multiple data elements a variety of ways are used to ensure complete and accurate data reporting for the TANF Data Report. Alabama does not operate a SSP-MOE program currently. The state performs a series of case record reviews, as described above, to validate the accuracy of the data reported. This includes reviewing the original source document from the provider of the component, verification of wages and work hours by the employer and review of data element on FACETS. Additionally, data elements that constitute points of eligibility require verification codes to show the type of document/verification used to establish the point to be entered as well as the element itself. A guide to acceptable sources of verification is included in Attachment F for reference. Alabama’s TANF Data Reporting Document prepared by program and programming staff describes how specific FACETS data elements are used to complete the TANF Data Report submitted to ACF. Programming for the TANF Data Report is being changed to incorporate the changes covered by the Deficit Reduction Act. Specific information of each of the data elements is described below: Data Element Reporting Month Source Automatically Populated How Validated Review by state office programming staff prior to submission N/A Validated through the Social Security Administration as part of the Income and Eligibility Verification System (IEVS) match activities. Verification source and date are stored on FACETS. N/A Alabama does not sample. Case record reviews and monitoring by county supervisors and state office staff. Edits such as the following are in place to

Stratum Case Number

N/A FACETS – Case # is the Social Security Number of the grantee relative. There is also a system generated Internal ID assigned to each individual in case the SSN changes. N/A Populated based on relationship code, participation status and work eligible indicator

Disposition Type of Family for Work Participation

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Alabama Work Verification Plan September 4, 2007 prevent incorrect coding of data: • Edits only allow coding of two parent family on cases with two work eligible adults. • Edits prevent use of code “2” in cases where there is only one adult, recipient or nonrecipient parent. • Edits prevent use of code “3” in cases with a work eligible parent. • Edits prevent use of code “2” when one parent is disabled. • Based on relationship code, if individual is not a parent of minor child, edit prohibits person from being coded “1” or “2”. • Review of reports PSWRB515-3 and PSWRJ510/PSWRZ021 for inconsistent data elements A sample of cases is reviewed each month for accuracy as required by federal QC rules. A sample of subsidized child care cases are reviewed each month for compliance with policy as well as the correct calculation of benefit amount, parental fee and payment to provider. The Child Care Management Agency must correct the errors within 30 days. Case record reviews and monitoring by county supervisors and state office

Amount of Food Stamps Assistance

SCI-II (State Food Stamp Automated System

Receives Subsidized Child Care

Populated from an electronic transmission received from the Child Care Management Agency of all cases receiving subsidized child care during the report month.

Amounts of TANF (and SSP-MOE) Assistance

Populated from FACETS Payment History

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Alabama Work Verification Plan September 4, 2007 Family Affiliation Code Populated based on Relationship Code N/A staff. Record review and monitoring by supervisors and state office staff N/A

Non-custodial Parent Indicator Date of Birth (Adult)

Populated from FACETS from Official sources include birth certificate, RSDI records, DOB field and hospital birth records. See Attachment F for additional information on validation of this element. Relationship to HeadRelationship code on Case record reviews and of-Household FACETS monitoring by county supervisors and state office staff. Data in the following reports Parent with Minor Child Populated based on relationship code, # of adults, are reviewed by state office work eligible status and family staff for accuracy: 1. PSWRZO34-A affiliation 2. PSWRJ510/PSWRZ021 3. PS278SPFI Edits are in place to reject inconsistent code combinations such as a relationship code that indicates adult is grandparent of children in case and work eligible code that indicates adult is recipient in case subject to work requirements. Record review and Work-Eligible Codes “1” and “9” are Individual Indicator populated for adult recipients monitoring by supervisors from work eligible indicator on and state office staff ZD21. For non-recipient Data in the following reports parents, FA Participation are reviewed by state office Status is used to determine staff for accuracy: the correct code. If Family Affiliation is “3” indicating non- • PSWRZO34-A recipient, non-parent, the • PSWRJ510/PSWRZ021 appropriate code of “6”, “7”, or • PS278PFI “8” is entered based on FA Edits are in place to insure Participation Status. consistency in data used to determine this item: for nonrecipient parents report

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Alabama Work Verification Plan September 4, 2007 edits that if Family Affiliation is “3”, work eligible code must always be “6” or in the case of recipient parents, if Family Affiliation code is “1”, work eligible status must be “1” or “9”. Official sources include birth certificate and hospital birth records. See Attachment F for additional information on validation of this element.

Date of Birth (Child)

Populated from FACETS

2. Describe any procedures employed to eliminate data inconsistencies between two or more data elements. Several reports, as listed in the chart above, are used to identify discrepancies between two or more data elements. Data reports are looked at monthly to evaluate the accuracy of the data on the FACETS system and corrections are made as needed. Multiple edits are in place, such as the ones described above, to prevent inconsistent data from being reported. State office staff continuously reviews data to determine the need for additional programming edits. Efforts are made to avoid data inconsistencies by using as many cross-edits as possible such as the ones described above. The state has written policy and procedures effective October 1, 2006 on how to count and verify reported hours of work. In addition, new policy has been written on how to report and verify non-paid component hours. Internal controls are in place to ensure that data on each individual is reported accurately and timely. Alerts are set automatically by FACETS to notify workers of actions that need to be taken by a certain date. Most alerts can be cleared only by taking action on the system. These alerts are monitored by county supervisors and by state office staff. The alert list from the review month is pulled and used for determining the sample of cases to review. Work Participation Status 1. Describe the State’s procedures to ensure that a family is not disregarded from the work participation rate for more than 12 months per lifetime based on being a single custodial parent with a child less than one year of age. Description of procedure: When an individual is deferred from participation because of a child under the age of one, the JOBS worker enters this information on FACETS screen, ZD21. Alabama has added a new field to FACETS for tracking purposes. The new field records the number of months a single custodial parent with a child less than 12 months is deferred from participation in JOBS. When the number of months in

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Alabama Work Verification Plan September 4, 2007 this field is 13 and greater, the adult will not be reported as disregard WPS “1” on the TANF Data report. A sample of cases coded “1” in the TANF Data Report are compared to the data on FACETS. 2. Describe the State’s procedures to ensure that a family is not disregarded from the work participation rate for more than 3 months in any period of 12 consecutive months based on a work eligible individual’s refusal to participate in work. Alabama imposes a full family sanction for all families that fail to cooperate with work requirements. The state reduces benefits for 3 months for the first instance of non-compliance. Second and subsequent instances of noncompliance will result in immediate disqualification from receipt of TANF benefits. Because of this policy the maximum number of months that an individual’s benefits can be reduced is 3. The specific months a case is sanctioned are stored on FACETS. This data is used to determine whether the month should be disregarded as “under sanction” for the report month. A sample of cases reported as sanctioned in the TANF Data Report are reviewed each month and compared to the data on FACETS. 3. Describe the State’s procedures for ensuring a family deemed engaged in work based on 20 hours of participation in countable work activities meets the requirements of a single custodial parent or caretaker relative with a child under age six. The JOBS case manager is responsible for assigning each adult for the appropriate number of participation hours including the minimum participation requirement based on the age of the youngest child. This data element is included in the monthly record reviews performed by county supervisors and rereviews conducted by state office staff. In addition, prior to submitting the TANF Data Report, the child members of each case are reviewed to ensure that the youngest child is less than six. If a child under six is not found, this case is not coded “17” in field 49, Work Participation Status. Edits are in place to not allow use of this code for two parent families when both parents are work eligible. A sample of cases coded “17” on the TANF Data Report are reviewed each month and the data compared with the data on FACETS. VI. Submittal Procedures Alabama is submitting a TANF Work Verification Plan based on current policy and procedures. Our plan is designed to support the accurate and timely submission of TANF data to ACF. This is to certify that Alabama’s TANF Work Verification Plan dated September 4, 2007 includes all the information required by the regulations at 45 DFR 261.64 (b) and accurately reflects the provisions under which Alabama will be operating as of September 30, 2007. As policy changes, the Work Verification Plan will be amended and resubmitted. The Work Verification Plan is being submitted to the Office of Family Assistance (OFA) with

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Alabama Work Verification Plan September 4, 2007 a copy to the appropriate Regional Office of the Administration for Children and Families (ACF). The original is being sent to: Office of Family Assistance Administration for Children and Families 5th Floor East 370 L’Enfant Promenade, S.W. Washington, DC 20447 Attachments Attachment A: Attachment B: Attachment C: Attachment D: Attachment E: Attachment F: Attachment G: Attachment H: Attachment I: Attachment J: Attachment K: Attachment L: Attachment M: Attachment N: Attachment O: Attachment P:

Community Employment Hours Calculation Form Affirmation and Agreement Form Copy of FACETS screen ZC92 Family Assistance Program Case Review Checklist and Instructions JOBS Supervisory Case Review Checklist and Instructions Assistance Payments Manual, Chapter 23, Verification Paid Weekly Hours Computation Worksheet Unpaid Hours Computation Worksheet Copy of FACETS Screen ZD21. VOCT and JOBS/JOBR Tracking Form Client Participation Summary PSWJB025 Participation Report Relationship Codes Description of OJT Monthly Attendance/Progress Report Programs of Study

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