TANF/VIEW Non-Compliance and Sanctions BPRO 2017 Spring Conference Weathering the Storm TANF/VIEW Non-Compliance and Sanctions BPRO 2017 Spring Conference

Virginia Initiative for Employment not Welfare Program (VIEW) PARTICIPATION - As a condition of eligibility, each able-bodied adult and required assistance unit member for TANF and TANF-UP must participate, as required in VIEW, unless otherwise exempt. (901.1)

SANCTIONS - Participants who fail to participate in the VIEW Program will be sanctioned. (901.6) The sanction will be imposed by suspending the TANF payment for the period of time specified at 901.6F. For needy non-parent caretakers, the caretaker is to be removed from the grant, rather than suspending the payment. The ESW must advise the EW of the decision to sanction and the sanction count.

Case Closure Requested The EW is to sanction the participant unless otherwise advised by the VIEW worker. If the participant requests that the TANF case be closed following the referral of the case for sanctioning, the EW will enter the sanction in VaCMS prior to closing the case. (901.6D)

Some Exceptions To Imposing The sanction will NOT be imposed if: For the 1st sanction only, the client obtains and verifies full time employment before the effective date of the proposed sanction. This does not apply to 2nd and 3rd sanctions. The EW will delete the sanction information from VaCMS. The ESW will remove the sanction information from ESP.

Exempt of Disabled If the EW is aware that the participant might have been exempt during the required participation period, or was unable to participate for reasons of disability or language barrier, the EW must advise the ESW. The ESW is responsible for making the final decision as to whether to proceed with the sanction.

Some Exceptions To Imposing The sanction will NOT be imposed if: It can be established that the client actually became exempt during the time they were required to participate. Verification must be received before the date the sanction is imposed. The EW and ESW will remove sanction information from the non-compliance screens in VaCMS.

Actions Before Sanction Referral The ESW attempts to determine good cause. If no contact is made or no good cause exists, the ESW completes the VIEW Non- Compliance Checklist and the VIEW supervisor signs. THE ANPA is mailed, either by the EW or the ESW (this is the manual notice, not the VaCMS notice) Note: this is not the time for the client to complete the activity, agree to participate, etc. This is their final opportunity to provide a good cause reason for not participating.

Sanction Time Frames First sanction - the grant will be suspended for a minimum period of one month and will continue to be suspended until the client complies. Second sanction - the grant will be suspended for a minimum period of three consecutive months and will continue to be suspended until the client complies. Third and subsequent sanctions, the grant will be suspended for a minimum period of six consecutive months and will continue to be suspended until the client complies.

Reapplying While In A Sanction All TANF applications (including those in a sanction when the TANF case closed) must first pass the 185 % and SOA screening If the case passes the initial income screening and is, or later becomes employed, they will be allowed the VIEW income disregards.

Approved In A Sanction If they pass the income screening, the EW will explain why their case is being approved without benefits. (TANF approved, payment suspended). The EW will explain that their VIEW counter will start to tick again. The EW will advise them to meet with an ESW to discuss compliance.

Approved In A Sanction The payment cannot be issued until the fixed period has been served and the ESW has notified the EW of the date to lift the sanction. If the client becomes exempt during the sanction period, the EW must wait until the payment can be issued (compliance not required).

Lifting The Sanction The ESW will communicate to life the sanction once the minimum sanction period has passed and compliance has occurred. The EW will end the sanction on the Non-Compliance screen and will issue the benefits from the date the ESW indicates the client is in compliance. The ESW will provide a new APR date, and the EW will enter this date on the Program Request screen.

Reminders If the case is approved in a sanction, and the payment suspended, each of the month(s) of suspended payment, including a partial month, will count toward the fixed sanction period. These months, including partial months, will count on the VIEW counter. Suspended months, which are never subsequently issued, do not count on the 60 month clock.

Reminders If the date of compliance is after the fixed period has ended, the sanction will be lifted as of that date. The grant can be prorated, depending on the date of compliance. If a TANF case has been closed, for any reason, for at least 24 months, prior sanctions no longer count and a new VIEW clock starts. Don’t get “closed TANF” confused with “closed VIEW”. If a sanctioned individual becomes exempt during the fixed period, the minimum sanction period must be served before the payment can be issued (no compliance required).

Termination Due To No APR If the ESW informs the EW the case should be terminated due to the VIEW participant’s refusal to sign the APR or keep the initial assessment appointment, the entire case will be closed. If the participant subsequently reapplies, the client must sign the APR with either the EW or the ESW, as a condition of eligibility, prior to TANF approval. (If the TANF has been closed for at least 24 months, this is no longer a condition of eligibility).

Termination Due to NO APR If the EW has the client sign the APR, she will forward a copy of the APR to the ESW to be used in the VIEW file. Note: if the client subsequently fails to keep her initial assessment appointment with the ESW, this will cause the case to be sanctioned (not terminated) because she has already signed the APR. The client is NOT required to sign another APR with the ESW.

The Tide is High We will review a few non-compliance and sanction examples. Let’s see if together we can stay afloat.

Your participation is appreciated My contact information: Cassandra Elliston Program Consultant Sr. Piedmont Regional Office Cassandra.elliston@dss.virginia.gov 540-204-9645 Thank You