ID&R Center ID&R TRAINING FOR ALL RECRUITERS

Writing Effective Comments

Objectives Recruiters and coordinators will gain knowledge and skills in order to write clear, more concise, and “audit proof” comments to support eligibility determinations, Help recruiters understand special conditions on the ECOE, and when and how to document comments.

What are the characteristics of a well written comment? It clarifies and explains information that may not be understood by someone not familiar with the family/move. It is concise, but provides enough information to demonstrate eligibility. It doesn’t repeat information already on the COE (i.e., the worker was hired to collect and pack eggs).

Well written comments – (cont’d.) It doesn’t “bird-walk” – it doesn’t ramble or provide so much information (often not related to the move) that the reviewer ends up with more questions than answers. It doesn’t get personal (i.e., mother and father going through a bitter divorce, or father can’t keep a job, etc.). Can you think of others?

Tips or ideas for helping to write a good comment Pay careful attention to what the parent or guardian is telling you. If any of the information about the move, qualifying work, who joined, who preceded, etc. is complicated, TAKE NOTES!

More tips – cont’d Make up your own little “cheat sheet” to help you remember what questions to ask and record responses. Remember the who, what, where, when, and why. Ask for clarification; repeat back to the parent pertinent information or anything you don’t understand. Other ideas?

What are Special Conditions? Special conditions typically involve moves, work, family dynamics, or other circumstances that surround eligibility that a reviewer, independent reviewer, or auditor might question when trying to determine if the family qualified for the program. Anything related to Qualifying Move and Work (basically the eligibility data) that needs clarification, must be documented in the Comments section.

What is So “Special?” Federally Required Comments - As you know, OME requires states/recruiters to provide comments when: √ 2bi: children joined or preceded the worker √ 4c: children qualified “on intent” (qualifying work was sought but not obtained). √ 5: children qualified on personal subsistence √ 6a: worker’s statement (temporary work) √ 6b: employer’s statement (temporary work)

The information on the COE needs additional explanation to be clearly understood by an independent outside reviewer. Sometimes the facts listed on the COE may cause confusion. A COE where the latest move is not the qualifying move is one such situation. It may not be immediately clear why the “moved-to city” is different from the current city, or perhaps why the crop is inappropriate for the local area. Short comments such as “housing move” or the comment shown below are helpful to explain any apparent discrepancies. A non-qualifying latest move is merely one example of a set of facts on the COE that could confuse an independent reviewer.

Brief Scenario A recruiter meets a mother with two children in Houma, LA and learns they made a qualifying move from Lockport, LA to Buras, LA to pick oranges. When that season was over, the mother returned to Lockport to work delivering newspapers. The hours were difficult, and she learned of a better paying job as a store clerk near Houma and she moved the family there.

Comments Poor comment: “Moved to get better job.” The qualifying work was found on the move to Buras, and the most recent move was from Lockport to Houma, but this is not explained. An outside reviewer could wonder why in the Qualifying Move & Work Section, the “moved-to city” is Buras, and not understand that there was an intervening move to Lockport. Better comment: “Latest move from Lockport to Houma was for non-qualifying work.”

Where the worker moves well before the qualifying work is reasonably expected to be available (moves in advance of season). If the family moves well before the qualifying work is reasonably expected to be available, the recruiter must explain why the family deliberately arrived early. Assuming that the recruiter is convinced that the family moved to seek qualifying work due to economic necessity, acceptable reasons for arriving in advance of employment could include: needing to apply for a job early to guarantee employment, getting children started in school, and finding housing. Unacceptable reasons include: arriving in advance of the season so a spouse could begin or resume non-qualifying work, returning to obtain unemployment benefits, and moving specifically to seek non-qualifying work.

Brief Scenario A family moves to Tickfaw, LA so that the mother can obtain work picking peppers in the local area. Picking peppers begins in June, but the family arrives in late March so the mother can submit her job application to secure her position when the grower begins hiring.

Comments Poor comment: “Mother came to work to pick peppers.” The Qualifying Move & Work Section already describes that the worker is seeking work picking peppers. But why did the family move so much in advance of the season?” Better comment: “Employer requires job applications to be submitted in person at least two months in advance of employment.”

Questions?