Policy Directive                                                             Issuance Number: TEA PD 01-02

Transitional Employment Assistance Manual      Issuance Date: 02-26-01

From: Ruth Whitney, Director                                       Expiration Date: Until Superseded

Subj: TEA Two-Parent Work Activity Participation Requirement

For federal fiscal year 1999, Arkansas failed to meet the two-parent work activity participation rate. Applying our caseload reduction credit to the two-parent 90% rate reduced our target for two-parent families to 61%. However, our actual reported two-parent rate for FFY 1999 was 10.5%.

An analysis of the two parent families that are currently receiving TEA assistance was conducted as a part of the development of the corrective compliance plan for FFY 1999. The analysis revealed that there was very little change from the information that was obtained for the corrective compliance plan for FFY 1998.

When Arkansas failed to meet the two-parent work activity participation rate in FFY 1998, TEA Policy Directive 99-15 was issued on November 20, 1999 to provide guidance on the work activity participation requirements for two-parent families. However, there continues to be some misinterpretations or misapplications of policy. Therefore for further clarification, we are providing a review of that policy directive and providing clarification of additional issues.

Only families that meet the "two-parent family" definition below are subject to the two-parent participation requirement:

• Two natural or adoptive adult* parents are included as eligible unit members; and

• The two parents have at least one child in common included as an eligible member; and

• Neither parent meets the definition of disabled, which is:

A parent who receives SSI or SSA disability benefits; or

A parent who has been found to have a disability too severe to be accepted for services by Arkansas Rehabilitative Services (ARS)

*If both parents are minors and one is a head of household minor parent, the family is subject to the two-parent participation requirement.

Temporary Deferrals Due to Medical Incapacity

• A temporarily deferred parent does not meet the definition of disabled.

• A parent who alleges a long-term disability and who has been referred to ARS for a disability assessment and the results of the assessment are pending will be temporarily deferred.

• A parent who has provided medical documentation verifying a short-term illness or incapacity that prevents the parent from engaging in work activities will be temporarily deferred.

NOTE: A two-parent family that includes a parent who is temporarily deferred due to medical incapacity is still subject to the two-parent participation requirement.

The Number of Participation Hours Required

• 35 hours per week - Applies to families in which both parents are included in the TEA cash assistance unit, have a child in common and neither parent meets the state's definition of disabled.

• 55 hours per week - Applies only to those families that are subject to the two parent participation requirement and are receiving federally funded child care. Federally funded child care is child care that is paid for with TEA funds or by the Head Start program.

• 30 hours per week - Applies to families in which one of the two parents in the home meets the definition of a disabled parent. (Single parent requirement)

Most families subject to the two-parent participation requirement will be required to participate for 35 hours per week. The hours may be shared between the two parents to meet the required total number of hours per week.

• The participation requirement does not change when one of the parents is granted a temporary deferral. The family must still meet the required number of participation hours (35 or 55, whichever is applicable).

• If the non-deferred parent is not participating 35 hours per week when the deferral is granted, an employment plan update should be conducted and the hours of participation for the non-deferred parent increased to 35 hours per week in order for the family to meet the two-parent participation requirement.

Example: Both parents in a two-parent unit that is subject to the two-parent participation requirement are each participating 20 hours per week in work activities. Mom is pregnant and is granted a deferral in the third trimester of her pregnancy. Since dad is only participating 20 hours per week when mom is deferred, an employment plan update must be completed for dad and his hours increased to 35 hours per week in order for the family to continue to meet their participation requirement.

NOTE: The non-deferred parent cannot be required to participate for more than 40 hours per week.

There has been much confusion expressed regarding two parents and education activities. The following describes how each of the education and training activities apply to two-parent families that are subject to the two-parent participation requirement.

• GED:

• Included as a work activity? Yes.

• Counts in participation rate calculation? Yes, IF one or both of the parents also participate for a total of at least 30 hours per week in one or more of the following work activities: Subsidized Employment, Work Experience, Community Service, OJT, Assisted Job Search, and Vocational Education Training. If the family is subject to participate 55 hours, the parents must participate for a total of 50 hours in one or more of the activities listed above.

• Limit of 15 hours in an additional work activity? No.

• Vocational Education Training:

• Included as a work activity? Yes.

• Counts in participation rate calculation? Yes, for up to 12 months. This includes college courses that meet the vocational educational criteria as listed in TEA 3252.2

• Limit of 15 hours in an additional work activity? No.

The Other Post Secondary Education work activity does not count for participation rate calculation purposes for the two-parent family. It is, however, an allowable work activity. Therefore, the adult in a two-parent family who chooses to engage in other post secondary education and training should never be encouraged to drop out. These parents have some options for meeting their participation requirement, such as the non-student parent participating in a countable activity for the required number of hours, or both parents participating in countable activities for a total of the required number of hours. Also, the student parent who is in an internship or clinical placement should be assigned and counted as participating in Work Experience.

All staff responsible for working with two parent families should review the information provided in this directive and in PD 99-15. By reviewing and ensuring that the policy and procedures are correctly applied, the two-parent participation rate is expected to increase. Since the single parent participation rate is 30 hours per week it is not unrealistic to expect two parent families to meet their participation requirement.

Inquiries to:  Lorie Williams, 682-8256

  Renee Green, 682-8266

  Gerry Reed, 682-8253