SNAP Employment and Training Plan. Federal Fiscal Year 2018

Transcription

1 SNAP Employment and Training Plan Federal Fiscal Year 2018 Updated: 11/27/2017

2 Table of Contents A. Authorized Signatures... 3 B. Assurance Statements...4 C. State E&T Program, Operations and Policy... 5 I. Summary of SNAP E&T Program... 5 II. Program Changes... 7 III. Workforce Development System... 8 IV. Other Employment Programs V. Consultation with Tribal Organizations VI. State Options in E&T Participants VII. Screening Process VIII. Conciliation Process IX. Disqualification Policy X. Participant Reimbursement XI. Work-registration Data XII. Outcome Reporting Measures (This needs to be updated) D. Pledge to Serve All At-Risk ABAWDs I. Pledge to serve all At-Risk ABAWDs II. Size & Need of ABAWD Population III. Geographic Areas IV. Estimated Cost to Fulfill Need V. Description of State Agency Capacity VI. Management Controls VII. Description of Education, Training, and Workfare Components Offered E. E&T Component Detail Table 2: E&T Component Detail F. Estimated Participation Levels Table 3: Estimated Participation Levels G. Partnership/Contracts of 39

3 Table 4: Partnerships/Contracts H. Contractor Detail Addendum I. Operating Budget and Budget Narrative Table 5: State Operating Budget Table 6: County Budget Summaries (supplement to section I) County Activities (supplement to section I) J. Budget Narrative and Justification [Narrative in lieu of Table 6: Budget Narrative and Justification Table] Direct Costs Indirect Costs State In-Kind Contributions Participant Reimbursements State Agency Cost on Dependent Care 39 2 of 39

4 A. Authorized Signatures State: Colorado State Agency: Colorado Department of Human Services Federal FY: 2018 Primary Contacts: Name Title Phone Glenn Robinson Programs Manager Luis Gomez Chris Carman Employment and Training Manager Employment and Training Supervisor Certified By: Katie Griego, Director Date Certified By: State Agency Fiscal Reviewer Date 3 of 39

5 B. Assurance Statements Check box at right to indicate you have read and understand each statement. I. The State agency is accountable for the content of the State E&T plan and will provide oversight of any sub-grantees. II. The State agency is fiscally responsible for E&T activities funded under the plan and is liable for repayment of unallowable costs. III. State education costs will not be supplanted with Federal E&T funds. IV. Cash or in-kind donations from other non-federal sources have not been claimed or used as a match or reimbursement under any other Federal program. V. If in-kind goods and services are part of the budget; only public in-kind services are included. No private in-kind goods or services are claimed. VI. Documentation of State agency costs, payments, and donations for approved E&T activities are maintained by the State agency and available for USDA review and audit. VII. Contracts are procured through appropriate procedures governed by State procurement regulations. VIII. Program activities are conducted in compliance with all applicable Federal laws, rules, and regulations including Civil Rights and OMB regulations governing cost issues. IX. E&T education activities directly enhance the employability of the participants; there is a direct link between the education activities and job-readiness. X. Program activities and expenses are reasonable and necessary to accomplish the goals and objectives of SNAP E&T. XI. The E&T Program is implemented in a manner that is responsive to the special needs of American Indians on Reservations. State shall: consult on an ongoing basis about portions of State Plan which affect them; submit for comment all portions of the State Plan that affect the ITO; if appropriate and the extent practicable, include ITO suggestions in State plan. (For States with Indian Reservations only) By signing on the cover page of this document, the Director and financial representative certify the above assurances are met. 4 of 39

6 Acronyms: Food Assistance...FA Employment First...EF Notice of Action.. NOA Notice of Adverse Action.. NOAA Employment and Training...E&T County Financial Management System...CFMS Colorado Benefits Management System.....CBMS Able-Bodied Adults Without Dependents....ABAWD Colorado Department of Human Services...CDHS Supplemental Nutrition Assistance Program.SNAP C. State E&T Program, Operations and Policy [Narrative in lieu of Table 1: State E&T Program, Operations and Policy Overview] I. Summary of SNAP E&T Program The Colorado Department of Human Services (CDHS) mission statement is: Collaborating with our partners, our mission is to design and deliver high-quality human and health services that improve the safety, independence, and well-being of the people of Colorado. In Colorado, the Supplemental Nutritional Assistance Program, Employment & Training (SNAP E&T) program, as required by 7 CFR 273.7(f), and the Section 20 Optional Workfare program allowed under the provisions of 7 CFR 273.7(m), operate together as the Employment First (EF) program. EF has operated in the state since the program s inception in Employment First helps SNAP recipients in Colorado connect to resources, seek work and training, develop and enhance skills to obtain gainful employment. The EF program components, activities, and services provided include the following (the full descriptions are on pages 21-27: Workfare 30-Day Job Search Workfare Self-Initiated Workfare 5 of 39

7 Work Experience Job Retention English as a Second Language Vocational Rehabilitation Basic Skills/Adult Basic Education GED Preparation Post-Secondary Education Employability Services WIOA Activities Vocational Training Literacy Instruction Entrepreneurship Colorado is a state supervised, county-administered state with 64 counties. Federal regulations, state statute, and codified regulations provide the administrative code of operation for all human service programs in the state, including Employment First. County administration of human services programs, and the parameters of state-supervision and county-administration, is outlined in Colorado statute (C.R.S. Title 26). Regulations for the Employment First program are promulgated by the State Board of Human Services; additional guidance is provided through the dissemination of policy, training, and technical assistance. As defined in state regulations, county departments that do not have unemployment above 10% or an insufficient number of jobs (i.e. qualify for a federal waiver or are appropriate for an exemption due to economic circumstances) must operate SNAP E&T programming for work-registrants. Able-Bodied Adults without Dependents (ABAWDs) are included in the work registrant definition (Colorado Code of Regulations ). In FFY 2017, thirty-seven (37) counties operated an Employment First program; this included several counties that met the criteria to preclude them from program operation, but who voluntarily opted in. Colorado has made programmatic adjustments going into FFY 2018, which includes leveraging the states bank of 15% ABAWD exemptions to exempt whole counties from operation. This allows Colorado to navigate budgetary and economic factors while ensuring a high quality of service if provided to participants in operating counties. All counties with an EF program will operate as an ABAWD Pledge county. Counties that do not operate an EF program either qualify for a federal ABAWD waiver, or will have the ABAWDs residing in their county exempted using the state s 15% exemptions. CDHS will operate the EF program in thirty-eight (38) of sixty-four (64) Colorado counties in FFY of 39

8 Of the thirty-eight (38), one (1) county, Costilla meets criteria for a federal ABAWD waiver based on unemployment rate but is choosing to run the program. Additionally, Colorado set 15% exempt criteria that predicated any county with: under two hundred and fifty (250) ABAWDs; had a federal waived in a prior year; and is not one of the ten large counties would be offered 15% exempt status. Four (4) counties, Archuleta, Baca, La Plata, and Rio Grande met this state defined criteria but are choosing to operate. Twenty-three (23) counties, Alamosa, Bent, Cheyenne, Conejos, Crowley, Custer, Delta, Elbert, Gilpin, Gunnison, Hinsdale, Kiowa, Kit Carson, Lake, Las Animas, Lincoln, Mineral, Moffat, Montezuma, Ouray, Pitkin, Rio Blanco, and San Juan accepted the 15% exempt status. The remaining three (3) counties Fremont, Huerfano, and Saguache meet federal waiver criteria based on unemployment rate or designation as a labor surplus area as outlined in CFR (f). Each operating county is required to submit a plan for program operation to CDHS for review and approval on an annual basis; plans must adhere to all applicable rules and regulations, and within those parameters, may be locally tailored based upon local capacity, resources and community needs. As an ABAWD Pledge state, all EF counties operate as Pledge Programs. County departments may sub-contract portions of their EF program, but they retain all fiscal and oversight responsibilities regardless of contractual delegations. II. Program Changes As the economy continues to recover from the impacts of the 2008 recession, Colorado, like many states, has experienced a decline in the ability to meet ABAWD waiver criteria, due to improving unemployment rates statewide. The unemployment rate in Colorado is very low at 2.3%; however, this percentage rate does not speak to the number of jobs that offer livable wages. This places an increased emphasis on the SNAP EF program, and the critically important role it plays. Federal funding of this program has remained flat, while volume has increased substantially. In an effort to mitigate the effects of operating in more counties with no a relatively nominal change to the states work registrant and decreases to ABAWD funding for Colorado as more state pledge to provide opportunities for that population to meet the work requirement, Colorado has chosen to allow counties to designate if they will run mandatory or voluntary programs. Program Design CDHS gave counties operating an EF program a choice between operating a mandatory EF program to serve all SNAP recipients, including upholding the pledge to ABAWDs, or a voluntary EF program for non-abawds while maintaining the pledge to ABAWDs. Under the voluntary or hybrid program model, Counties have two options in serving ABAWDs, described below. 7 of 39

9 1. Mandatory Program (M): If a county is choosing to operate a M program, all program participants, including ABAWDs, will be sanctioned for any non-compliance in the EF program. 2. Hybrid-mandatory (HM): If a county is choosing to operate a HM program, only non- ABAWD work registrants may participate on a voluntary basis. ABAWDs in these counties will be mandatory EF participants and thus subject to EF and ABAWD sanctions for non-compliance. 3. Hybrid-voluntary (HV): If a county is choosing to operate a HV program, all participants, ABAWDs and non-abawds, are EF volunteers. However, ABAWDs will still be subject to sanctions if they do not meet the work requirements independently and/or through EF. Twenty-nine (29) counties elected to operate a mandatory EF program and nine (9) counties elected to operate a voluntary, hybrid EF program. (County designation is identified below in section III. Geographic Areas. ) Expansion CDHS is also exploring 3 rd Party Match opportunities with Metropolitan State University of Denver, Community College of Denver, Community College of Aurora, and Center for Employment Opportunities. These partnerships are still in the development stage. We should be able to provide more detail in the coming months. Early indicators show that through these third party partnerships we should see services provided to, in excess of, 1000 participants across the Denver Metro area including Denver, Arapahoe, Boulder, Adams, Broomfield, and Weld County. III. Workforce Development System The various state agencies in Colorado that support economic development, either through engagement with job-seekers, industry, or both, are all aligned under the Colorado Blueprint ( This guiding framework provides resources, direction, and integration across a spectrum of organizations, all unified in supporting six (6) core objectives: 1. Build a Business-Friendly Environment 2. Retain, Grow and Recruit Companies 3. Increase Access to Capital 4. Create & Market a Stronger Colorado Brand 5. Educate & Train the Workforce of the Future 6. Cultivate Innovation & Technology 8 of 39

10 EF services align with objective 5, Educate & Train the Workforce of the Future. EF recognizes that SNAP recipients are a vital component of the talent pipeline, and are critical in filling middle skills jobs in the marketplace. The EF program supports this goal through providing opportunities, and connecting program participants with education, training and credentialing opportunities. These educational opportunities equip participants with the credentials to access career pathways in the labor market. Colorado looks to become a national leader in the development of sector-based strategies, and prioritizes industry-led training and credentialing across our fourteen (14) key industries: Advanced Manufacturing Aerospace Bioscience Creative Industries Defense & Homeland Security Electronics Energy & Natural Resources Financial Services Food & Agriculture Health & Wellness Infrastructure Engineering Outdoor Recreation Technology & Information Tourism & Outdoor Recreation Transportation & Logistics EF participants are encouraged to engage with the workforce development system, and Colorado ensures that components associated with job search and training through WIOA count towards participation as allowable under federal regulations. In local areas where Employment First is imbedded in the American Job Center, Employment First customers benefit from an array of services available to them, including resume writing workshops, career development and job coaching, access to labor market information, adult education and vocational rehabilitation services, and much more. In areas where geography limits access to the full array of services, county human service departments and their local partner organizations fill the gaps, by leveraging community colleges and local chambers of commerce among others. This ensures alignment with emerging markets and sector-based training opportunities. The primary referral to workforce services is generated through the local Employment First office in areas where workforce services are provided. This referral typically happens at the initial program orientation, but may occur at any time during the life cycle of the individual s participation. Additionally, integration across data systems has allowed for 9 of 39

11 identification of SNAP recipients between workforce center providers and employment first providers. The state anticipates that as we begin tracking more closely the required data elements stipulated by FNS, more collaboration across systems will be informed. IV. Other Employment Programs Colorado s TANF program (Colorado Works) and the SNAP E&T program, EF, are overseen by the same Division within CDHS, and these programs share one manager and a supervisor. As such, SNAP E&T staff is cross-trained on TANF, and vice versa. This structure supports and reflects the structure at the operational level for counties, where public assistance work programs align administratively, to meet common goals and serve similar populations. While these programs are distinct in their funding, mandates, programmatic rules, and outcome requirements, Colorado has found a great deal of commonality, and in those common areas, leverages expertise in workforce development and employment opportunities across both program areas. Colorado does not utilize SNAP E&T funding on TANF programming, or vice versa, and staff must complete 100% time reporting across all programs in which they work. However, Colorado is one of few states with the ability to spend SNAP E&T funds on TANF purposes and populations, per CFR (d)(ii)(d)(1). At this time, however, Colorado does not use funds in this manner. At the participant level, individuals participating in Title IV-A programming are exempted from participation in EF (per federal regulations), but may choose to voluntarily participate if they so desire. V. Consultation with Tribal Organizations The State of Colorado Department of Human Services meets with Tribal Organizations to review our services and engagement with tribal leaders, at a minimum, annually. The Department s county liaisons and leadership coordinate these visits and facilitate ongoing technical assistance to maintain a strong relationship and ensure access of EF services is available to Tribal Organizations. Colorado is home to two federally recognized American Indian tribes, the Southern Ute and Ute Mountain Ute tribes, residing in the southwest corner of the state. These tribes are served in SNAP E&T through their local county human service departments, and local county plans detail the scope of services in those areas, taking into consideration the unique needs of tribal members of the community. Through the local county office, all available components are offered to members of the respective tribal communities. 10 of 39

12 VI. State Options in E&T Participants Colorado does not serve categorically eligible, zero benefit households; individuals in these households meet the standard Federal exemptions or the Colorado exemptions. SNAP applicants are referred to the EF Program during eligibility determination to ensure the State engages the ABAWD population as quickly as possible. Initial scheduling for orientation occurs within fourteen (14) days of the eligibility determination, though the average number of days is eight (8). This helps to ensure work-requirements are met by serving all work-registrants through one of the two EF models in Colorado mandatory or voluntary. VII. Screening Process Work-registrant status is determined by decision tables in the Colorado Benefits Management System (CBMS). Status determinations are based upon information entered by eligibility technicians for new and renewal SNAP applications. In counties that operate an EF program, the eligibility technician completes the enrollment form and provides the appointment letter for the referral to EF at the time of application. This would occur regardless of the EF program design for each county. The technician provides one copy of the appointment letter to the participant, retains one for the SNAP case file, and sends one to the Employment First program. FA and EF eligibility technicians determine federal exemptions from work registration based on the data entered into CBMS. Further, at eligibility each technician reviews and screens for applicable exemptions. Screening for all exemptions both federal and state occurs when the eligibility technician reviews exemption criteria with the applicant and provides the applicant with the program rights and responsibilities form (FS-62). This form can be used to guide both the technician and participant about any and all applicable exemptions from the Employment First Program. Individual exemptions from activities are determined by the Employment First program, after the referral has been completed to EF from FA. EF program staff is responsible for working with work-registrants, to ensure compliance with program requirements, or the identification of new exemptions as appropriate. VIII. Conciliation Process When a participant does not comply with mandated work requirements in a county operating a mandatory EF program, FA merit staff shall consider the facts and circumstances, including information submitted by the household member involved to determine whether good cause for the noncompliance exists. Note: This information is typically collected by EF staff and sent to FA for the good cause determination. FA staff will notify the participant about providing good cause reasoning. If good cause is determined, the non-compliance will be overruled, which must be completed within seven calendar days from the date of the noncompliance. If 11 of 39

13 good cause does not exist, FA will initiate the Notice of Adverse Action within five calendar days of determining noncompliance, advising the household member of the pertinent EF requirements and the consequences of failing to comply. The household member shall be informed of the actions necessary for compliance and the date by which compliance must be achieved to avoid disqualification. To avoid disqualification, the member must perform a verifiable act of compliance. Verbal commitment by the household member is not sufficient, unless the household member is prevented from complying by circumstances beyond the household member's control. EF advises the FA staff of noncompliance with work requirements and requests that the FA staff issue the Notice of Adverse Action (NOAA), the FA staff shall issue the NOAA to the individual no later than 10 calendar days from the notice from EF. Both the NOAA and the disqualification may be cancelled if EF verifies and notified FA that compliance was achieved before the NOAA was issued or before the period of adverse action expires. Please note: In some counties, EF and FA are the same merit staff personnel. IX. Disqualification Policy Any non-compliance information (regarding mandatory EF participation or an ABAWD not meeting the work requirement) is entered into CBMS within seven working days of each occurrence. Eligibility technicians are electronically notified of this information through an automated system alert. The FA staff notifies the participant via a Notice of Adverse Action (NOAA) of the pending action on their SNAP allotment due to non-compliance; the NOAA is automatically mailed to the participant and is available as an electronic file, accessible by both EF program and FA staff. After proper notification of non-compliance and NOAA, CBMS will process the disqualification through the batch process, which occurs on a daily schedule. In mandatory or for ABAWDs in a Hybrid-Mandatory county run program, the first time an individual refuses to comply with work registration or fails without good cause to comply with Employment First, the individual shall remain ineligible until the later of the date the individual becomes eligible by complying with requirement or the date that is one month, three months or six months based on the occurrence level of sanction after the date the individual became ineligible. Ineligibility shall continue either until the member complies with the requirement or becomes exempt (other than by Title IV-A/IV-F, CRSP registration or UCB application, or serves the disqualification period). Further, the participant needs to comply the sanction even after it is served as guided by the county policy outlining a verifiable act. The exception would be if the participant qualifies for expedited benefits after the served time period or meet exemption criteria. If an individual has served the disqualification, but the case has the certification expire during the disqualification period, the nonexempt individual will be eligible at the later of the date of the application or the date of compliance with EF if eligible for expedited benefits. 12 of 39

14 The disqualification period shall begin the month following the expiration of the notice of adverse action, unless a fair hearing is requested. The member may stop the disqualification if the member becomes exempt from these requirements during the disqualification period. The disqualified member shall continue to be disqualified for noncompliance but may resume participation after the disqualification period (if otherwise eligible) by becoming exempt from work registration or complying with the appropriate work requirement. A disqualified member will be added back into the household after the disqualification period is over if the individual has complied with EF or has become exempt. In a county operating a mandatory EF program, sanctioned individuals are removed from a case during their sanction period such that the rest of an eligible household may continue to receive SNAP benefits. When individuals complete the compliance process, it is entered into CBMS by EF staff and shared with FA staff. These regulations are outlined in the Code of Colorado Regulations (CCR), Food Assistance Program, Disqualification Period for Employment First. It should be noted that Colorado refers to EF sanctions as level sanctions and ABAWD disqualifications as ticket sanctions. A ticket is synonymous with a countable month against an ABAWD s 3 months in 36 months of benefits. Mandatory EF Program This is how CDHS has historically operated their EF program to date. Noncompliance in EF will result in an EF level sanction, regardless of a SNAP recipient s ABAWD status. Therefore, ABAWDs in one of these counties are subject to level sanctions for noncompliance and ticket sanctions from the EF program for the ABAWD time limit. Hybrid-Voluntary EF Program This is a new program design for CDHS. In this model, non-abawds will not be disqualified for failing to comply with EF if they reside in one of these voluntary counties; level sanctions will not be applied. ABAWDs in one of these counties are only subject to ticket sanctions (disqualifications) from the EF program based on ABAWD time limit. Level sanctions will not be applied to ABAWDs. However all participants will be referred to the program and encouraged to participate. ABAWDs will be provided information about how best to meet the work requirement to avoid loss of benefits. Hybrid-Mandatory EF Program This is also a new program design for CDHS. In this model, non-abawds will not be disqualified for failing to comply with EF if they reside in one of these voluntary counties; level sanctions will not be applied. ABAWDs in these counties are subject to ticket sanction as well as level sanctions. All participants will be referred to the program and encouraged to participate. 13 of 39

15 ABAWDs will be provided information about how best to meet the work requirement to avoid loss of benefits. ABAWD Sanctions (Disqualifications) ABAWD disqualification remains consistent between both a mandatory and a voluntary EF program. ABAWDs who have received two months of SNAP benefits without meeting a work requirement will receive a system-generated Notice of Adverse Action in the third month. If the work requirements are not met in the third countable month as an ABAWD, the case will be closed automatically by CBMS. If the ABAWD does meet the work requirement, with or without EF participation, by the end of the third month, benefits will be restored for the fourth month. Each month thereafter, this process is continued to ensure that the ABAWD meets the monthly work requirement, or benefits are suspended. SNAP benefits are ended during the current month if the work requirements are not met. If an ABAWD has been disqualified from three months of benefits without meeting the work requirement, the individual must complete 80 hours of an education or work component, or participate in Workfare for a prescribed number of hours within a 30-day time period, in order to regain benefits. X. Participant Reimbursement The Colorado General Assembly has appropriated $78,435 in state funds for participant reimbursements for the SFY 2018, beginning July 1, Funds are allocated to county human service departments and are available to participants in in all EF programs at the same rate within a county. Participant reimbursement is paid either with those state funds to the degree available, or through local county funds. These expenditures are reimbursed federally at 50%, up to the state s maximum award. Participants will be served to the greatest extent possible; if monthly expenses are anticipated to exceed the E&T program limits, participation requirements may be modified or an exemption applied to fit within available resources. For transportation, participants may receive bus tickets, passes, or gas vouchers in advance to cover the round-trip transit from their home to a location where their component is offered if available. Colorado may also provide transportation supports for job seeking activities as resources allow. Participants are reimbursed for allowable costs including work tools, boots or uniforms for work. Reimbursements may also include clothing for job interviews, school books, and course registration fees. Each county is able to identify what they will reimburse and to set their own caps, as funding is limited locally. Items eligible for reimbursement, and county maximums, are submitted through county plans, and approved by the State. Participant reimbursement funds are allocated to counties based upon the county s share of work-registrant caseload across all Employment First counties; expenditures are tracked at the 14 of 39

16 local and state levels against available allocations on a monthly basis. County expenditures are monitored through the County Financial Management System (CFMS), which is an Oracle platform for financial management of county programs. County expenditure data is invoiced monthly for all EF cost categories by the 5th business day of the month. The State reviews monthly charges, and direct adjustments as needed, prior to approving reimbursements. County management evaluations and oversight also include reviews of source documentation associated with supportive services, and the mechanisms for distribution to the participants. XI. Work-registration Data The initial count of work-registrants is provided by the Colorado Benefits Management System, (CBMS) through a work registration status assigned by decision tables for each Food Assistance applicant and recipient. CBMS takes an annual snapshot of names and social security numbers of all work-registrants in the system on October 1st, which is reported to FNS. Every subsequent month, CBMS takes a snapshot of work registration codes, social security numbers, and names on the last day of the month. All new work-registrants are tallied throughout the year; duplicated names or social security numbers will not be counted again. XII. Outcome Reporting Measures At this time, Colorado does not intend to pursue sampling, but will provide the universe of data across each variable requested. However, as system design changes are further developed, sampling may be reconsidered. To the degree available, Colorado will derive all data from our benefits management system administrative data tables. Tables have been updated to ensure alignment and ability to track outcome measures as new required tracking measures begins in January Other data, such as that requested for quarterly earnings post-exit, or completion of educational components may require manual data entry into our system; however, Colorado will extract from other source systems, and will merge with CBMS administrative records by a data analyst as available and necessary. See SNAP E&T Outcome Measures State Worksheet for more detail, attached as exhibit A. for additional information considering the data sources, methodology and information collected in this annual report. CDHS acknowledges that components containing 100 or more participants will be included in this annual report. 15 of 39

17 D. Pledge to Serve All At-Risk ABAWDs I. Pledge to serve all At-Risk ABAWDs Colorado will serve all At-Risk ABAWDs under its status as a Pledge State. In FFY 2018, Three (3) of 64 counties, Costilla, Huerfano, and Saguache, and three (3) cities Grand Junction, Longmont, and Northglenn qualify for an ABAWD waiver under the provisions of 7 CFR (f)(2). In counties that are waived or can be exempted underneath the State s 15% exemptions, operation of the EF program is voluntary, meaning an EF program is not expected to be operated in these areas of the state. In all other counties, program operation is mandatory. Each county that operates a program must meet the work requirement for ABAWDs, and a qualifying activity will be provided each month for all at-risk ABAWDs who report for services. On-site program reviews are done each year and CBMS reports allow continual state oversight of ABAWD services. Colorado operates a program intended to serve every eligible work-registrant, including ABAWDs. EF serves a diverse population of participants in a variety of activities. The system offers an array of resources to help the ABAWD population meet the participation requirements. Education and training components are available for those who benefit from these services. Colorado operates a workfare program, and through these opportunities, enables many ABAWDs to meet federal work requirements at a reduced number of hours. II. Size & Need of ABAWD Population Colorado serves in excess of thirty thousand (30k) SNAP E&T participants on an annual basis. Of this population almost half are ABAWDs and in FFY16 the state served slightly over fifteen thousand (15k) ABAWDs. Many ABAWDs in Colorado present with significant challenges in attaching to employment including, 1) lack of a high school diploma or its equivalent, 2) no significant/relevant work history, 3) felony convictions, 4) substance abuse, 5) mental and physical health problems, 6) housing problems, and 7) transportation problems. Among the ABAWD population, the following issues are proportionately higher: 1) recent incarceration, 2) lack of a permanent address and/or homelessness, and 3) health problems. Colorado has expanded the definition of physically or mentally unfit for work to specifically include chronic homelessness. This allows for increased exemptions of ABAWDs dealing with homelessness and further supports food security and reserves E&T resources for those who stand to benefit from them most. The expansion of Colorado s Medicaid eligibility through implementation of the Affordable Care Act mitigated some of the acute medical problems resulting from homelessness and substance 16 of 39

18 abuse, and provided much-needed resources to ensure medical care and treatment as warranted. Colorado regulations allow for individual use of 15% exemption slots based upon established criteria, at county determination. Situations which may justify an exemption include: lack of transportation, a pending legal action, non-english speaking, serious lack of job readiness/employability, job attached (60 day exemption), lives more than one hour away from the EF office, transitional living situation including domestic violence shelters, mental health concerns (documented), working part-time at maximum capacity, child care problems interfere with availability for work, already doing mandatory community service work for another agency, or sex offender restrictions. III. Geographic Areas Colorado will operate the EF program in the following thirty-eight (38) counties that will operate an EF program. Of these, twenty-nine (29) will operate a mandatory program. Mandatory programs are shaded below in green and include: Adams, Archuleta, Baca, Boulder, Broomfield, Chaffee, Clear Creek, Costilla, Dolores, Douglas, Eagle, Garfield, Jefferson, La Plata, Logan, Mesa, Montrose, Morgan, Otero, Park, Prowers, Rio Grande, Routt, San Miguel, Sedgwick, Summit, Teller, Washington, Weld and Yuma. Nine (9) counties will operate one of two types of hybrid voluntary program, described above in Section II, Program Changes. These counties are highlighted below in blue and include: Arapahoe (M), Denver (V), El Paso (V), Grand (M), Jackson (M), Larimer (V), Phillips (M) Pueblo (V), Routt(V). Twenty three (23) counties will be 15% exempt. These counties are highlighted in purple and include: Alamosa, Bent, Cheyenne, Conejos, Crowley, Custer, Delta, Elbert, Gilpin, Gunnison, Hinsdale, Kiowa, Kit Carson, Lake, Las Animas, Lincoln, Mineral, Moffat, Montezuma, Ouray, Pitkin, Rio Blanco, and San Juan County. Five (5) counties met ABAWD waiver criteria; however, two of these counties are choosing to operate the program, Costilla and Rio Grande. The remaining three (3) counties are highlighted in yellow and will not operate a program. These include: Fremont, Saguache, and Huerfano County. 17 of 39

19 IV. Estimated Cost to Fulfill Need Colorado s EF program is structured to ensure all ABAWDs are provided with an opportunity to meet the work requirements, primarily through engagement in a workfare component. However, additional resources made available through ABAWD Pledge Funds help support more robust and individualized programming for ABAWDs, including the provision of training for in-demand occupations (See section C, part III). The foundational element of workfare ensures Colorado is able to meet the Pledge; the program is then able to offer additional services as resources allow. This initial number only indicated the pledge funds received from FNS. The number has been recalculated to show the cost to serve ABAWDs across the state. Colorado estimates that approximately 50% of all participants are ABAWDs. The number reflects that approximately 25% of the states allocated 100% funds and 50% of all additional funds are used in the service of ABAWDs. CDHS s estimated cost to fulfill the ABAWD pledge is in or around $3,251, of 39

20 V. Description of State Agency Capacity As a county-administered state, human services are available in all 64 counties across Colorado, through at least one physical office. County-level administration allows for a high degree of community integration, and strategies tailored to local economies, capacity, and need. Colorado s counties are equipped to support at-risk ABAWDs in all counties making the ABAWD Pledge, through access to at least one qualifying component. To address the transitory nature of both the ABAWD and non-abawd work registrant population, the EF program starts participants in a program component within two weeks of being determined a mandatory participant. The two week time to engage in a component is close to the maximum time to engage and the average length of time to be in a component is eight (8) days. This ensures the State is engaging at risk ABAWDs as early as possible, and fulfills the pledge to serve at-risk ABAWDs, ideally mitigating the likelihood that they become at-risk. VI. Management Controls Colorado carefully tracks ABAWDs in all areas that do not meet federal waiver criteria or are not under a county-wide 15% exemption. As a county choice (voluntary or mandatory) state for all ABAWDS and all other work registrants, Colorado is able to identify and serve workregistrants immediately upon SNAP application. Through immediate referral to the EF program, the EF program is quickly identify and track ABAWDs statewide. CBMS has management controls built into the system to ensure county supervisors and the state offices are able to monitor and ensure individuals are being scheduled for activities to meet the work requirement. There are tracking indicators in CBMS to determine when a participants ABAWD status changes. This may be due to qualifying for a federal exemption, change in family make-up, or other factors. Every month, CBMS generates a list (by county) of ABAWDs who used 1, 2, or 3 of their countable months; the system also creates the disqualification for the month following the 3rd countable month. Ongoing monitoring of these reports is performed at both the county- and state-level. Additional monthly reports have been created to help identify and schedule ABAWDs for service as soon as possible. These reports include a list (by county) of households wherein the youngest member will be turning 18 the following month, potentially changing the status of household members from non-abawd to ABAWD. County offices are also provided a bimonthly report of individuals receiving Food Assistance who are identified as work-registered mandatory ABAWDs, but for whom a plan is not currently in place. This report facilitates proactive outreach by EF staff to those individuals with a current open E&T case, in order to 19 of 39

21 contact them to schedule an appointment. The following reports are available through CBMS for oversight and quality assurance related to ensuring service to ABAWDs: FNS-583 Quarterly Report: Quarterly and annual report that presents all data required for the federal 583 report EF Active Client List (bi-weekly): Report by county and case manager of all individuals receiving Food Assistance and having a mandatory work registrant code along with their status in the program (EF-102 Sent, EF-Deferred, EF- Exempt, EF-Sanction, No Plan Status, EF-Active). Monthly Activity Report: Provides information for total caseload, number of fulltime jobs, full-time average wage, number of part-time jobs, placement rate, number of sanctions, and numbers of individuals beginning components of Education/Training, Workfare 30-day Job Search, Workfare, Working Part-time, and Job Seeking Skills activities. All information is presented by county and statewide. ABAWD 1 st and 2 nd Ticket Report: Lists, by county, social security numbers of all ABAWDs who had a 1 st or 2 nd ABAWD month posted against them in the current month. ABAWD 3 rd Ticket Report: Lists, by county, social security numbers of all ABAWDs for whom a 3 rd month was posted against them in the current month. ABAWD Regain Report: Lists, by county, social security numbers of all ABAWDs who are in their three regain months. EF 15% Exempt and Deferred Status Report: Monthly Report, by County and Case manager, of individuals in the 15% Exempt or Deferred status (i.e. mandatory work registrants exempted from EF participation by the case manager). EF 18 Report: Monthly list by county of individuals turning 18-years-old in the month who became ABAWDs. EF Component Activity Report: Monthly report, by county and case manager, of individuals who started a component or reported hours in a component. EF Employment Report: Monthly list, by county and case manager, of individuals reporting employment. EF Monthly Caseload Report: Monthly Report of cases that started, closed, or recorded hours during the month, reported by county and case manager. EF Turning 6 Report: Monthly list, by county, of households with the youngest child turning 6-years-old. EF Workfare Report: Monthly list, by county and case manager, of individuals starting Workfare or reporting Workfare hours. 20 of 39

22 EF Exemption report: Details clients who have become exempt from the Employment First program for a given month. The report is broken by client, case manager, county, and exemption reason. VII. Description of Education, Training, and Workfare Components Offered a) Workfare 30-Day Job Search In the 30-day period commencing with referral to Employment First, individuals are required at a minimum to 1) attend an orientation/assessment meeting where they may also complete a workfare screening activity; 2) attend four to six hours of job search skills training; and 3) complete an 8 hour course of Soft Skills training. Additional requirements (e.g. job contacts) may be included depending on the individual s circumstances. After the 30 day period, participants are placed at a permanent workfare site. b) Workfare Participants are required to work a specific number of hours each month (not to exceed the household monthly food assistance allotment divided by the state minimum wage of $9.30/hour) at a public or private non-profit work site, not to exceed 30 hours per week. Individuals with significant barriers or other needs determined by their assessment may be referred to another program or component instead of being placed on a workfare site. Participants may also engage in self-initiated workfare in the event that a county does not have a partnership with a site that fits the interest, aptitude, or skills need of the participant. Self- Initiated sites follow the same requirements as all workfare sites. The sole distinction is that through self-initiated workfare, the participant voluntarily finds his/her own work assignment and arranges to have participation reported to the Employment First program. (For more about Colorado s workfare opportunities see the State s workfare plan.) d) Work Experience Work Experience is comparable to workfare; however, job experience may be provided in the private sector, in comparable working conditions as paid employees. Participation hours are determined by the food assistance allotment divided by the state minimum wage up, not to exceed 30 hours per week. e) Job Retention Job Retention provides supportive services for up to 90 days to participants who have secured employment. Participants can be reimbursed for expenditures directly related to maintaining employment. Typical job retention reimbursements include clothing, equipment or tools, relocation expenses, transportation and childcare. 21 of 39

23 f) All Other Components (Additional Options) A variety of additional components are available to ABAWDs to satisfy the work requirement. Federal law requires participation of at least 20 hours per week to meet the work requirement; nine of those hours may be comprised of job contacts when combined with other components. Additional components (excluding Workfare 30-Day Job Search) can be combined in order to meet the ABAWD work requirement, as follows: Job Search Training o Employability Services E&T Educational Activities o English as a Second Language o Literacy instruction o Basic Skills/Adult Basic Education o GED preparation o Post-Secondary Education Vocational Training Self-employment training o Entrepreneurship Vocational Rehabilitation E. E&T Component Detail Table 2: E&T Component Detail All E&T Components are available statewide, and services are not targeted to specific cohorts, but are based upon individual circumstances. Education costs are not charged to the E&T program; however, qualifying expenditures may be identified for 50% federal reimbursement. Work Components Workfare 30-Day Job Search Description Participants will attend an orientation which will include an assessment, and workfare screening activity, job seeking skills and soft skills instruction. The 30 days begin when the participant attends Orientation. The 30 days may overlap into two months but the participant must be assigned to a permanent Workfare activity by the end of 30 days or any other activity that best assists the participant to employment. This component will requires the participant to complete a minimum of 12 job contacts that can be completed in one month or be split over a two month time period. 22 of 39

24 Workfare 30-Day Job Search Target audience (e.g., homeless, reentry population, ABAWDS) All participants are offered this component unless otherwise deemed not job ready Anticipated monthly participants (unduplicated count) Anticipated monthly cost* Provider(s) 2,214 $458,298 In-house Reporting measure(s) if > 100 participants per year % of participants to gain employment Workfare Description Specified number of hours worked at a private non-profit or public organization. Any participant assigned to workfare, whether an ABAWD or not, may be required to work up to the number of hours equal to their SNAP allotment divided by minimum wage. The worksite must be at a non-profit or public worksite. Target audience (e.g., homeless, reentry population, ABAWDS) Participants including ABAWDs, Non-ABAWDs or other who are assessed to need current employment or industry skills building to improve employment prospects A participant may not be mandated to participate in both workfare and another activity. However, participants who are enrolled in Workfare may volunteer to participate in another activity at the same time. Anticipated monthly participants (unduplicated count) Anticipated monthly cost* 380 $78,660 Provider(s) Public or private nonprofit organization Reporting measure(s) if > 100 participants per year % of participants to gain employment Work Experience Description This component is available to participants to gain employment experience in the private sector. The benefit will provide actual work experience/training expanding the reach for more placement opportunities for participants and to build marketable skill sets. This support helps participants gain and maintain regular full time employment. Participant are not required to work more hours monthly than the total obtained by dividing the household s monthly food stamp allotment by the higher of the applicable Federal or State minimum wage, up to 30 hours weekly and will not exceed 120 hours per month. Work experience assignments may not replace the employment of a regularly 23 of 39

25 Work Experience Target audience (e.g., homeless, reentry population, ABAWDS) Participants including ABAWDs, Non-ABAWDs or other who are assessed to need current employment or industry skills building to improve and sustain employment prospects. employed individual, and they must provide the same benefits and working conditions provided to regularly employed individuals performing comparable work for comparable hours. Anticipated monthly participants (unduplicated count) Anticipated monthly cost* 83 $17,181 Provider(s) For-profit organization Reporting measure(s) if > 100 participants per year >100 Self-Employment training (Entrepreneurship) Description Target audience (e.g., homeless, reentry population, ABAWDS) Self-employment instruction for participants who are interested in taking classes to learn how to start their own business. Classroom attendance is required as well as completion of all homework assignments and attendance at any individual appointments. Anticipated monthly participants (unduplicated count) Anticipated monthly cost* All categorically eligible participants 1 $207 Provider(s) Workforce Development Reporting measure(s) if > 100 participants per year <100 Non-Education, Non-Work Components Job Retention Description Supportive services up to 90 days post-employment Target audience (e.g., homeless, reentry population, ABAWDS) Anticipated monthly participants (unduplicated count) Anticipated monthly cost* Provider(s) Reporting measure(s) if > 100 participants per year 24 of 39