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HomeMy WebLinkAboutbocc.res.011.2017 RESOLUTION OF THE BOARD OF COUNTY COMMISSIONERS ("BOCC") OF PITKIN COUNTY, COLORADO, REPEAL AND REPLACE THE COLORADO WORKS (TEMPORARY AID TO NEEDY FAMILIES) POLICIES RESOLUTION NO. OI( -2017 RECITALS: 1. Pursuant to Section 2.8.4 (Actions)of the Pitkin County Home Rule Charter ("HRC"), all matters not required to be acted upon by ordinance or formal resolution may be acted upon by informal resolution. 2. TANF/Colorado Works Temporary Aid to Needy Families(known in Colorado as Colorado Works) is designed to provide assistance to needy families with or expecting children and to provide parents with job preparation,work and support services to enable them to leave public assistance programs and become self- sufficient. 3. Pitkin County is required to establish operational policies that guide the appropriate distribution of TANF dollars. 4. These policies provide direction to Pitkin County Human Services staff,and their designees, on the distribution of these funds to qualified individuals and families in Pitkin County to strive to alleviate barriers to self-sufficiency. 5. In 2015, Colorado Department of Human Services required that existing TANF policies be updated to align with federal rules.To comply with these regulations Pitkin is required to repeal all previous TANF policies and replace them with eight mandatory policies including County Diversion, Dispute Resolution, Domestic Violence, Fraud and Quality Assurance,Hardship Extension, Nepotism-Conflict of Interest, Other Assistance and Supportive Services, and Workforce Requirements and Employment Outcomes. Copies of these updated policies are attached and incorporated by this reference. 6. The BOCC finds that it is in the hest interests of the citizens or Pitkin County to approve this Resolution. NOW, THEREFORE, BE IT RESOLVED by the Board of County Commissioners of Pitkin County, Colorado that it approves a Resolution to Repeal and Replace the Colorado Works-Temporary Aid to Needy Families Policies 16-1 (County Diversion), 16-2 (Dispute Resolution), 16-3 (Domestic Violence), 16-4 (Fraud and Quality Assurance), 16-5 (Hardship Extension), 16-6(Nepotism-Conflict of Interest), 16-7 (Other Assistance and Supportive Services), 16-8 (Workforce Requirements and Employment Outcomes)and authorizes the Chair to sign on behalf of the county. The Human Services Director shall be responsible to maintain adherence to these policies and to maintain these records as well as a written log of exceptions. INTRODUCED, READ AND ADOPTED ON THE 91 441 DAY OF Dili&r Y 2017. ATTEST: BOARD OF COUNTY COMMISSIONERS i 14211 4, :i Uu Leo By: _ ;' /4_. VIJUw Je, .ette ones S George Newman, Chai DU.uty County C i rk L Date: cs (Z. 1 APPROVED AS TO FORM: MANAGER APPROVAL _1 `\/ John Ely;Com. Attorney on Peacock, ounty Manager 1 ATTACHMENT B-TANF POLICIES 16-1 through 16-8 Ithuvm Services PFTKIN COUNTY CAPES POLICY TYPE: Human Services - POLICY TITLE: �'i Operating Colorado Works Diversion Program (State & County) POLICY CWP 16-1 TANF/Colorado Works EFFECTIVE DATE:12/30/2016 This policy (CWP-16-1) supersedes Pitkin County Health and Human Services CWP-1.3 County Diversion and CWP-1.17 State Diversion policies which will be terminated effective 12/30/ 2016. Reference Colorado Revised Statute 26-2-706.6 CDHS Volume 3.606.8 BACKGROUND A Colorado Works applicant or participant may receive a diversion payment to address a specificI,I crisis or episode of need. Such payments are not designed to meet participants' basic ongoing , needs. PURPOSE The purpose of this policy is to identify the eligibility and suitability criteria for diversion payments,outline programmatic components associated with such payments,and establish a period of ineligibility for receiving ongoing cash assistance,barring hardship,once diversion has been issued. Maximum dollar thresholds are also established in this policy. 1 CO ATTACHMENT B-TANF POLICIES 16-1 through 16-8 DEFINITION A diversion payment is a needs-based,cash or cash-equivalent payment designed to meet short-term needs. Payments are designed to address specific crisis situations or episodes of need and are not designed to meet basic needs ongoing. POLICY In Pitkin County,both state and county diversion are available. Prior to issuing a diversion payment, Pitkin County will determine that ongoing need is not anticipated. Pitkin County provides cash or cash-equivalent payments to eligible families based upon established need, in conjunction with the determination that need is not expected to be ongoing. Payments may not exceed$3,000 unless approved by the Pitkin County Economic Assistance Manager. In no case shall a payment exceed$5,000. Lifetime maximum per household for diversion grants shall not exceed five (5) grants. Income Elioibility To receive a state diversion payment,applicants must be found eligible for basic cash assistance(BCA)by Colorado Benefits Management System (CBMS).Those who are otherwise eligible for BCA but are over the income guidelines (needs standard) and whose income does not exceed 200%of the Federal Poverty Level (effective April 18 of each year) may be eligible for county diversion. Other Eligibility Criteria • The household is experiencing a short-term crisis or episode of need which has interfered with the family's usual ability to be economically self-sufficient or that hinders the family from moving immediately toward employment and economic self-sufficiency. o A short-term crisis or episode of need,four months or less in duration, may include time-limited family emergencies such as a death in the immediate family; illness in the immediate family,documented by a physician as requiring the care of the parent or caretaker; a family disaster such as a fire, flood or major crime victimization; eviction necessitating a search for housing; threat of gas/electricity shutdown, food shortages,family care needs,breakdown of primary transportation,short-term legal issues,or other situations which are determined by the County as meeting the definition of a time-limited family emergency beyond the family's control. o For families transitioning off of Basic Cash Assistance to meet non-recurrent needs in support of long-term self-sufficiency. • The participant must demonstrate the household is not in need of long term cash assistance as determined by: o Client statement, o Verification of employment and/or other income that will be sufficient to assure long-term self-sufficiency. Self-sufficiency will be determined by comparing total household monthly income to total household monthly 2 ATTACHMENT B-TANF POLICIES 16-1 through 16-8 expenses for shelter,food, transportation,medical needs and personal items as identified by the client, o Documenting a non-recurring need for a specific item or type of assistance as a means to attain or maintain long term self-sufficiency, and o Documenting that the diversion payment amount is sufficient to divert the family from assistance and assure long-term self-sufficiency. • Applications submitted by an employee of the Pitkin County Department of Human Services or Pitkin County will be processed according to Pitkin County Colorado Works Program Policy CW-22 Nepotism/Conflict of Interest. • Recipients of a diversion grant must agree to a 24-month period of Colorado Works ineligibility (both basic cash assistance and diversion),unless good cause is evidenced via extenuating circumstances. The Pitkin County Economic Assistance Manager and/or Human Services Director or their designee must approve any good cause exception to the 24 month period of ineligibility. o Good cause exceptions are: • Parent ability to work: Layoff due to a workforce reduction; or the parent/caretaker has a disability that interferes with work activity. Objective Criteria: Physician or mental health professional statement or receipt of SSI/OASDI. • Pregnancy: The single caretaker is pregnant. The good cause exception can be granted only within a period not to exceed 12 weeks which can extend from the ninth month of pregnancy through the 3" month of infant care. Objective Criteria: Verification of pregnancy status and request by the parent to provide care and bonding. • Disabled child needing care: The parent/caretaker is required in the home on a full-time basis to care for the disabled child. Objective Criteria: Physician statement or certification by a Community Centered Board. • Lack of child care: There is no available childcare while the parent participates in work activity. Objective Criteria: The Department verifies absence of relative,legally exempt or licensed childcare. • Lack of Transportation: There is no transportation to work activity. Objective Criteria: The Department will verify the absence of public transportation and the absence of private transportation that could be accessed by the participant. • Family trauma: Family disaster such as a fire,flood or major crime victimization,or eviction (through no fault of the family) necessitating a search for housing; death or incarceration of a parent,spouse or caretaker; death of a child or the need to provide care for a family member;or other situations which are determined by the Pitkin County Economic Assistance Manager and/or the Human Services Director or designee,as meeting the definition of a family disaster. Objective Criteria: Verification through independent sources of a family disaster; or,assessment and statement by a mental health professional with a plan for counseling that will enable the family to 3 J • ATtACHNIENT B-TANF POLICIES 16-1 through 16-8 restore family functions; or, a statement by a physician that the parent/caretaker is needed in the home to provide care for another family member. Allowable Use of Funds Diversion grant funds will be used for a specific item(s)or type of assistance where there is a demonstrated non-recurrent need as a means to attain or maintain long term self-sufficiency. A diversion grant may be used for,but is not limited to, the following types of short-term assistance: • Work-related expenses such as uniforms,dues, or supplies • Transportation assistance including car repair,car insurance,etc • Housing assistance • Training or education; or • For amelioration of any other identified barrier to employment or self-sufficiency. The amount of the diversion grant will be based on the assessed need of the participant rather than a fixed formula. Payment • Payments will be made through CBMS. • Payments will be provided to the participant directly on his/her EBT card or through a vendor payment,depending on circumstances. Conditions for utilizing vendor payments will be contained in the individualized plan. • A diversion payment may not be made in the same month that basic cash assistance is received. Additional Criteria • Diversion recipients must enter into an individualized plan that documents why s/he does not need ongoing assistance, specifies the need for and the specific type of non-recurring assistance to be provided,defines the terms and expectations of the grant,and specifies the possible impacts on other assistance including Medicaid, Food Stamps,and Child Care. • Individualized plans will be completed for all custodial parents or caretakers of eligible children who are recipients of diversion grants and will be developed in conjunction with the participant and other service providers. The expectations under the individualized plan will be in writing and will be acknowledged by '.. signature of all parties to the plan. The individualized plan will be effective upon review and approval by the Pitkin County Economic Assistance Manager or designee. • The decision to approve a County Diversion grant must be within budget allocations and as funding allows. • Applicants who misrepresent their need,income,resources and situation will be prosecuted for fraud. • Diversion payments are subject to recovery. Such recovery will be pursued according to program regulations. 4 ATTACHMENT B-TANF POLICIES 16-1 through 16-8 Adopted by the Pitkin County Board of County Commissioners on this_22_day of _February,2017. Signed by Nan Sundeen, Director Human Services Date � r George Newman, hair, I itki County Board of Commissioners Date Nothing in the Pitkin County Colorado Works Program shall be interpreted to create a legal entitlement in any participants to assistance or services provided pursuant to the Colorado Works program. 5 , • Ifttkan.Services PIMIN COLIN/N.CAA fill POLICY TYPE: Human Services - POLICY TITLE: Operating Dispute Resolution Policy POLICY CWP-16-2 EFFECTIVE DATE: I. TANF/Colorado Works 12/31/2016 REFERENCES C.R.S. 26-2-127 CDHS Volume 1609.7 BACKGROUND Pitkin County,prior to taking action to deny,terminate,recover, initiate vendor payments or modify financial assistance,public assistance, or basic cash assistance or services provided under the Colorado Works Program to an applicant or recipient, shall,at a minimum,provide the individual an opportunity for a county dispute resolution conference. PURPOSE To set forth a procedure for County Level dispute resolution that is a simple non-adversarial format for the informal resolution of disputes regarding adverse case actions. DEFINITIONS Dispute resolution conference is a meeting that is held between Pitkin County Economic Assistance staff and the client in a simple non-adversarial format for the informal resolution of disputes regarding adverse case actions. POLICY Pitkin County shall provide all Colorado Works applicants and recipients an opportunity for a county dispute resolution conference. • Participants may request a meeting with the Pitkin County Economic Assistance Manager or their designee to review the factors of their individual situation and the basis for the county decision regarding cash benefits, services or sanctions. Applicant/recipient must request a local conference within the prior notice period listed in the notice of action sent to applicant/recipient. • "Good Cause"exception for not requesting a conference within the prior notice period includes, but is not limited to: o death or incapacity of an applicant/recipient,or a member of his/her immediate family, or the representative; o any other health or medical condition of an emergency nature; or, o other circumstances beyond the control of the applicant/recipient, and which would prevent a reasonable person from making a timely request for a conference or postponement of a scheduled conference. • Noticing and conducting of the conference will occur based on program regulations found at Volume of Income Maintenance (9 CCR 2503-6) Volume III, 3.609. • At the conclusion of the conference,the Pitkin County Economic Assistance Manager or their designee shall have the agreement entered into by the parties reduced to writing. Such agreement shall be signed by the parties and/or their representatives and shall be binding upon the parties. A copy of the written decision shall immediately be provided to the applicant/recipient and/or his/her representative. If the conference is held by telephone,the agreement need only he signed by the person presiding. A copy of the agreement will be promptly mailed or delivered to the other party(s). In the event the dispute is not resolved, the person presiding shall prepare a written statement indicating that the dispute was not resolved. The statement shall explain the applicant or recipient's right to request a state level fair hearing before an Administrative Law Judge. Adopted by the Pitkin County Board of County Commissioners on this_22_day of February,2017.�p - 17 Nan Sundeen, Director, Human Services Date - 1��- George Newn 'n, Chair, 'itkiiyCounty Board of County Commissioners Date Hua Services POLICY TYPE: Human Services - POLICY TITLE: Operating Domestic Violence Policy POLICY CWP-16-3 EFFECTIVE DATE: TANF/Colorado Works 12/31/2016 This Colorado Works Domestic Violence Policy (CWP-16-5)supersedes Pitkin County Health and Human Services 1.5 Domestic Violence Policy which will be terminated effective 12/31/2016. BACKGROUND Domestic Violence issues may prevent an individual from engaging with the standard components of the Colorado Works Program. Pitkin County will conduct a screening and assessment and will provide specific information, materials,and services that support individuals involved in family(domestic) violence, as defined in Colorado Works program rule. PURPOSE To set forth the assistance,services and waivers available for participants of the Colorado Works program. DEFINITIONS Domestic violence is defined as a pattern of coercive control one individual inflicts upon another in the context of familial,household or intimate partner(current or former) relationships including marriage and dating. POLICY '.. The Pitkin County procedure allows applicants and participants to voluntarily and confidentially self-identify as victims of family (domestic)violence, by providing multiple,safe opportunities for participants and applicants to disclose this information, and using trained staff to conduct routine assessments.The county will provide a safe and secure environment for victims to disclose and discuss abuse. There arc two private interview rooms in the Economic Assistance work space to ensure a confidential and safe environment for the client to disclose. Self- disclosed information remains confidential, unless an immediate threat to safety or well-being is present. 1 Pitkin County provides referrals to appropriate domestic violence advocacy,counseling,and support services, to include local domestic violence agencies, law enforcement, and mental health providers. Brochures and other informational handouts regarding Domestic and Family Violence issues are distributed and available in English and Spanish to all Colorado Works applicants and participants. All Colorado Works applicants will be screened and identified using the state's domestic violence screening form by an FVO trained worker. Screening will occur during initial application, and be addressed again at assessment and during one-on-one case management,as warranted. Waiver Pitkin County will offer,through FVO trained workers,a good cause waiver that exempts program participants who have experienced or are experiencing family violence from Colorado Works work activities, and/or the 60-month TANF time limit,and/or the requisite engagement with child support services. Pitkin County will involve the participant in the invocation of any waiver; the participant may accept or refuse any waiver offered. Good cause is granted as follows: 1. Work activities/time clock: If a customer is identified as a survivor of domestic violence that interferes with the safety and/or ability to participate in the Colorado Works Program, counties must offer the customer a waiver. 2. Child Support Services: If a customer is identified as survivor of domestic violence and seeking child support services would potentially endanger or unfairly penalize her/his or her/his family if she/he participated in the program requirement,counties must offer a child support engagement waiver to the survivor or assist the survivor in submitting a Request for Good Cause Exemption from Referral to Child Support Program according to Colorado Department of Human Services program rule 3.604.2(0)(1). Individuals receiving a waiver will be referred immediately to the appropriate domestic violence advocacy and support services. Individuals will also be provided information about and, if requested,enrolled in the statewide Address Confidentiality Program (ACP).This referral and associated services will be captured in the individualized plan, and reassessed every six months. Waivers will be accompanied by documentation describing the following: I. Past,present and ongoing impact of family violence on the individual and family 2. Individual's available resources 3. Specific program/work components being engaged in as well as those waived 4. While maintaining safety of the individual as a priority,maximize opportunities to engage in education,training,work, and other activities leading to family financial security. Trainin z U Pitkin Economic Assistance Eligibility Specialists will be required to attend Family Violence Option (FVO)training once every five years. In addition, staff will meet with Domestic Violence trainers from local agencies(RESPONSE)two times a year for staff development training. Adopted by the Pitkin County Board of County Commissioners on this_22 day of February,2017. ` C .4 A OVA 0P1/\ 27 ( fnf V Nan Sundeen, Director, I luman`Services Da e n � l , , a,L George Newman, Chair, "itkin Coin Board of County Commissioners ' ate Nothing in the Pitkin County Colorado Works program shall be interpreted to create a legal entitlement in any participant to assistance or services provided pursuant to the Colorado Works program. a /7') „tomServices PITKIN COUNTY CAPES POLICY TYPE: Human Services- POLICY TITLE: Operating Fraud Prevention and Quality Assurance POLICY CWP 16-4 EFFECTIVE DATE: TANF/Colorado Works 12/30/2016 Reference CDHS Policy No. 1-2.7 Fraud Prevention Policy CRS 26-1-112; 26-1-118; 26-2-703 (17.5) CDHS Volume 3.609 CDFIS Fraud Prevention Manual Agency Letter TCW-07-0S-P BACKGROUND '.. County Departments of Human Services are required to establish policies that facilitate the development of systems that will aid in the prevention and detection of internal and external fraud and promote accurate and timely eligibility processing. PURPOSE To set forth Pitkin County's fraud prevention and qualify assurance policy in order to provide accountability for the use of public funds,assure the funds are used to meet the needs of program participants and program goals,and ensure program eligibility is correctly determined based on the administrative rules of the CDHS. This policy contains the standards and framework for the maintenance of program integrity that ensures program accuracy and prevents the misuse of benefits. This policy applies to any irregularity, or suspected irregularity, involving employees as well ari customers,contractors, vendors,consultants, stakeholders,and/or other outside agencies with a business relationship with the department. 01) DEFINITIONS Fraud means the deliberate and conscious violation of rules or law for personal economic gain, including making any falsified claim for payment or benefit issued by the county department on behalf of the State Department by the client or others or receiving financial benefit from the county department on behalf of the State Department by means of willful misrepresentation including intentional concealment of essential fact(s)pertinent to determining eligibility. POLICY Fraud Pitkin County will maintain the following controls for fraud prevention and detection: Internal • Risk assessment • Confidentiality guidelines&practices including an annual renewal of written confidentiality agreement • Client files and information stored in locked file rooms • Electronic client files and information protected by network access security • Declaration of conflict of interest procedures • Guidelines for handling& storage of case file for Pitkin County employee applicants for assistance programs • Separation of duty practices • Case file reviews • New hire and ongoing staff training • Monitoring of program reports for irregular case actions and/or benefits • External • Third party verification of eligibility factors • Maintaining client files, computer screens and information so that is not visible to the public • Monitoring of program reports for irregular case actions and/or benefits • Supervisory approval of all State and County Diversion payments. li Any Pitkin County employee who discovers or suspects fraudulent activity will refer the case and provide all pertinent information to the Economic Assistance Manager-Quality Assurance Unit(QA Unit) for fraud investigation. The QA Unit will complete the investigation and request a hearing to determine Intentional Program Violation(IPV),obtain a signed waiver of hearing or ,, refer the case to the District Attorney for prosecution if fraud is determined through the investigation. The QA Unit will establish benefit recovery claims when an overpayment is 17 discovered through the fraud investigation process. Any suspected fraud reported by the public will undergo the same investigation procedures by the QA Unit. The QA Unit maintains the Pitkin County Fraud hotline(970) 920-5244 and the "Report Welfare Fraud" link on the Pitkin County Website. Quality Assurance The Pitkin County Department of Human Services Quality Assurance Unit(QA)staff will conduct all county level case file reviews and facilitate all CDHS case file and program reviews for the Pitkin County Public Assistance programs. Tier II -Secondary Stage Supervisory Reviews will be completed by the QA on cases identified monthly for Pitkin Counties by the state comprised from a random sample of 5%of the work eligible TANF/Colorado Works caseload. Agency Letter TCW-07-05-P,dated November 14, 2007, County Work and Eligibility Verification Procedures for Colorado Works Cases details the guidelines and policy which is set forth under Colorado's most current approved Work Verification Plan. • A minimum of two (2)additional cases per quarter will be reviewed the Pitkin County caseload • QA will facilitate all state Colorado Works program audits and coordinate the responses to audit findings with the Economic Services Division. Adopted by the Pitkin County Board of County Commissioners on this_22_day of February,2017. \\01/4A_(,L� \�_ JV CiQl/\ - ft ` i N Sundeen, Director, I luman Services Date C el✓ 2AJC. qP L1I�7 George Newma 1) e Chair, 'tkin County Board of Commissioners CI 2c' rlit Rom Services PITKPN COUNTY CARES POLICY TYPE: Human Services POLICY TITLE: Hardship Extensions (60 Month)Policy POLICY CWP 16.5 EFFECTIVE DATE: TANF/Colorado Works 12/30/2016 Reference Colorado Revised Statute 26-2-716(5) CDHS Volume 3.606.6 !� BACKGROUND An assistance unit containing an individual who has received Federal TANF assistance in Colorado or another state(s) as an adult for sixty(60) cumulative months shall not be eligible for Federal TANF assistance unless granted an extension by the county department due to hardship or domestic violence.Assistance units that contain excluded members shall not be eligible for consideration of an extension. PURPOSE To outline the criteria by which Pitkin County will grant a hardship to an assistance unit containing an individual who has received Federal TANF assistance in Colorado or another state(s) as an adult for sixty (60) months, DEFINITIONS Hardship—Circumstance or condition that prevents a participant from securing or maintaining employment. POLICY All participants,with the exception of assistance units containing excluded members, may request an extension when a hardship exists,A participant's request for an extension can be made in person,by phone,or in writing. Extensions maybe granted for up to six months; additional extensions may be granted if circumstances warrant the extension and it is requested prior to the end of the current extension.If a participant fails to request an 01* extension on a timely basis,an extension may be granted if the participant demonstrates good cause as determined by Pitkin County Human Services. Pitkin County shall approve or deny hardship or domestic violence extensions pursuant to the criteria established by the State Board of Human Services and contained in CDHS Volume 3.606(D) and (F.). Those criteria are: • Inadequate,or unavailable: • Childcare • Housing •Transportation • Employment opportunities,including but not limited to; • When layoffs occur • Wages are below applicable federal or state minimum wage standards • Workers' Compensation protection does not exist • Lack of jobs due to high unemployment rates • Available jobs do not align with skills or career profiles,on a case-by- case basis • Disability of the caretaker relative,his/her spouse,the dependent child(ren) or immediate relative for whom the caretaker is the primary caregiver,pursuant to the definition of"persons with disabilities"adopted by the State and found at CDHS Volume 3.601; • Involvement in the judicial system because a member of the assistant unit has an existing case; • Family instability which may include a caretaker with proven inability to maintain stable employment or inability of the caretaker to care for the children in their own home or in the home of a relative;or, • Domestic Violence issues as defined at CDHS Volume 3.604.2(V)(1)(a) Pitkin County has not defined any additional reasons for granting hardship extensions. Eligibility Pitkin County shall notify all participants who are approaching the 60-month time limit on Federal TANF assistance. Pitkin County Human Services shall make all reasonable efforts to contact the participants by phone or in person to explain the extension process and accept a request for an extension. Pitkin County Human Services shall make a decision to grantor deny the extension within 30 days. The department will provide written notification to the participant of the decision for the extension request pursuant to Colorado Department of Human Services program rule 3.609.7. If the extension is denied the notice shall include the reason for the denial and explain the appeal process pursuant to Colorado Department of Human Services program rule 3.609.8. Additional criteria Pitkin County Human Services will work with participants to develop an individualized plan that will include participation activities along with county and community supports to address the causes of the extension.Additionally, the plan will include sanction procedures for failing to comply and appeal rights. Good Cause Good cause is considered to be a circumstance or circumstances beyond the participant's control. Good cause for non-compliance with the conditions of the hardship extension plan are the same as any other individualized plan developed and agreed upon,and include, but arc not limited to: a) Physical or mental disability or illness of the participant b) Illness of an individual in the participants care,documented by a physician as requiring the care of the parent or caretaker. c) A parent being called frequently to a child's school. d) Required/frequent court appearances of client or child in client's care. e) Temporary breakdown in transportation. f) Temporary breakdown in child care arrangements and/or unavailability of child care. g) Homelessness/eviction/housing crisis. h) Incarceration. i) Domestic Violence j) Jury Duty k) Death of an immediate family member I) Family disaster such as a fire, flood or major crime victimization m) Other situations which are reviewed by the Department Director as meeting the definition of a time-limited family emergency. County Provisions related to Native Americans/Alaskans Any month of receipt of assistance by an adult while living in Indian Country, or a Native Alaskan village where at least 50% of the adults were not employed will not be counted toward the 60 month lifetime limit. Up to 20%of the county caseload may be granted an extension beyond the 60-month lifetime limit due to hardship or domestic violence. Adopted by the Pitkin County Board of County Commissioners on this 22 day of February, 2017. J 7�C.3-S�o v\ 1 Ito- ( Nai ,undeen, Director, Human Services Date ARA V\ 7‘*.L 11 Georg Newman, Chair, Pitkin Cou ty Board of County Commissioners Date ,, ,s, __ t : i: ,.. is 0 1- arum Services PITKIN COUNTY CARES POLICY TYPE: Human Services - POLICY TITLE: Operating Nepotism/Conflict of Interest POLICY CWP 16.6 12/30/2016 TANF/Colorado Works This policy(CWP 17.7)Nepotism/Conflict of Interest policy supersedes Pitkin County Health and Human Services(CWP 1.7)Employees as Participants Policy which will be terminated effective 12/30/2016. Reference CDHS Volume 3.603.1 BACKGROUND Any individual may apply for assistance and participate in the Colorado Works program if eligible. PURPOSE The purpose of this policy is to identify the mechanisms by which Pitkin County Human Services prevents conflict of interest or appearance of a conflict of interest from occurring within the department. POLICY Applications submitted by an employee of Pitkin County will be processed in a fair and equitable manner and according to the same guidelines as all other applications. No applicant will be discriminated against based upon the applicant's race, creed, religion,political affiliation,sexual orientation, or station in life. In the event an applicant is a blood-relative,relative by marriage or adoption,former spouse or otherwise related to a Pitkin County employee or elected official,a close friend or any member of the department staff, or any other reasons exists which might create a potential conflict of interest,the Pitkin County staff member assigned to the case will immediately notify his/her supervisor. If the conflict of interest is associated to the supervisor's relationship with the applicant,the staff member will immediately notify the Economic Services Manager. 01- Pitkin County relies upon the discretion and sound judgment of employees to identify situations as described above,and to follow the appropriate protocol. In the event that a staff member, customer,or citizen at large identifies a conflict on behalf of another entity who has not disclosed the potential conflict, such instances will be documented and shared with the Pitkin County Economic Assistance Manager and/or the Director of Human Services. The supervisor or Manager reviews the nature of the potential conflict of interest and determines how the application will be processed,which may include, but is not limited to: • The supervisor processing the case and maintaining case assignment with review by the Manager prior to benefit issuance; • Forwarding the application to a neighboring county for processing; • Reassigning the case to another Pitkin County staff member within the Department; or • Permitting the original assigned county staff member to process the application through regular business process. OnRoing For Colorado Works customers who receive a benefit above and beyond basic cash assistance (e.g. supportive services, special needs payments,child care,monetary incentives,etc.)where a conflict of interest may exist, the Pitkin County Economic Assistance Manager and/or the Pitkin County Human Services Director will be notified for approval prior to issuance. Pitkin County makes every effort to ensure case managers are not asked to handle cases where a conflict of interest may be present, but recognizes that sometimes this cannot be avoided.In that circumstance,measures to ensure additional supervision will be made. !, If questions and/or concerns arise regarding the possibility of a conflict of interest during case management or at any time throughout the life of the case,the case manager will consult with the Manager immediately. The established guidelines as outlined in this policy will then be followed. Any employee who has reason to believe that another employee is providing a service to a Colorado Works participant that involves payment of govermnental funds to the employee or household member of the employee,that employee shall notify the Economic Assistance Manager immediately. In these instances, the county attorney may be consulted to ensure fidelity to the program is maintained; involvement of the county attorney will automatically result in notification to the state office as well. Case File Maintenance In all circumstances, these sensitive cases and associated records are kept confidential in a locked filing cabinet, separate from all other case files,and electronic files are password protected. Case management records and system case notes are only accessible to certain staff with a special security profile, authorized and granted by the system administrator, To assure compliance, Quality Assurance (QA) measures are implemented in Pitkin County to discourage and detect the occurrence of fraud, and include,but are not limited to the following: • Pitkin County maintains a separation of functions within the department that are reasonable and required in relation to Department business processes. • The designated worker assigned to the case reviews verifies all supporting documentation for information supplied by the applicant; and requests and verifies other pertinent information needed at intake and on an ongoing basis. Adopted by the Pitkin County Board of County Commissioners on this 22 day of February, 2017. Nan Sundeen,Director, Human Service Date George Newman, Chair,Pitkin .•unty Board of County Commissioners Mate Nothing in the Pitkin County Colorado Works program shall be interpreted to create a legal entitlement in any participant to assistance or services provided pursuant to the Colorado Works program. Cv �" ' .. RINK Services PITKIN COUNTY CAPES POLICY TYPE Hunan Services POLICY TITLE: Other Assistance and Supportive Services Policy POLICY CWP-16-7 EFFECTIVE DATE: TANF/Colorado Works 1W31/2016 Reference Colorado Revised Statute 26-2-706.6; 26-2-709; CDHS Volume 3.606.8;1609.961 BACKGROUND Pitkin County,along with our community partners,plays a key role in supporting economic well-being for low-income individuals and families in our community. Pitkin County '...... recognizes that employment is a key component of family stabilization and economic '.... stability and acknowledges that education and other work and family supports are crucial for attachment to employment that offers family-sustaining wages,and career advancement opportunities.. Because of this,Pitkin County provides broad assistance to eligible Colorado Works participants to help them establish economic security,enhance their quality of life, and promote employment goals. PURPOSE The purpose of this policy is to set forth the supports and services available through Pitkin County Iltunan Services.Access to these services is contingent upon individual and family needs and Colorado Works program engagement,within the limits of county resources. DEFINITIONS "Assessed need" is defined as any need of a family receiving basic cash assistance,beyond ordinary, routine living expenses. Th "Noncustodial parent" shall mean an individual who, at the time he or she requests and receives program services: I. is a parent of a minor child;and, 2. Is a resident of Colorado; and, 3. Does not live in the same household as the minor child. "Other assistance"shall mean assistance provided to a participant including, but not limited to, cash assistance in addition to the basic cash assistance grant. Such assistance shall be based upon a participant's assessed needs. "Supportive Services" shall mean a payment and/or a service based on an assessed need. An eligible participant/recipient may receive supportive services, including but not Iimited to: I. Supportive services such as child care and transportation provided to families who are employed or working toward self-sufficiency; or, 2. Other or additional supportive services the county department deems appropriate/ necessary; or, 3. Additional payments made to the assistance unit to benefit the child. POLICY Pitkin County provides one-time and ongoing Other Assistance and Supportive Services for participants of the Colorado Works program. This assistance is intended to promote sustainable employment and is determined by individual assessment with the guidelines provided below. Income Eligibility To receive other assistance or supportive services, participants must be eligible for basic cash assistance and meet all criteria for the Colorado Works program. Additional Eligibility Participants must meet criteria for non-financial eligibility for the Colorado Works program,with the exception of non-custodial parents,who are exempted from dependent- child requirements. One and two-parent,and child only case types are eligible for the supports defined by this policy,as family need and county resources allow.All additional supports and services must be consistent with participant's assessment,must be identified in the individualized plan and case documentation must be provided to substantiate need. Assessed needs include but are not limited to, the items listed below in all categories of other assistance and supportive services outlined in this policy.Other items may be identified on a case-by- case basis,at the discretion of Pitkin Comity. Pitkin County takes an individualized,strengths-based approach when assessing families for supports and services that they may be need in addition to their cash grant,and beyond standard program services. Pitkin County staff has the responsibility of linking participants to resources that will help support their long-term economic security,and ensuring they receive appropriate supports in a timely manner.This includes advocacy,counseling, prevention and intervention,and mediation services,when appropriate. Enhanced Family mut Emnloyment Supports Pitkin County may authorize one-time additional or supplementary payments to support employment and job training goals outlined in the individualized plan,which may include, but are not limited to, the following not more than once per calendar quarter: • Transportation expenses to participate in employment, training or job preparation • Employment required tools,equipment, or clothing • Glasses or other prosthetic devices necessary for employment and not covered under Medicaid or Vocational Rehabilitation services • Relocation assistance,consistent with a firm job offer that will result in self- sufficiency and termination of Colorado Works benefits. • Housing deposits • Utility deposits • Installation or activation of phone service • Emergency assistance: shelter,childcare,or food • Other work-related expenses specified in the individualized plan and approved by the county • Work supplies and equipment not covered by the Workforce Investment and Opportunity Act(WIOA) • Personal care items and services needed for participating in work-related activities • Other work-related expenses specified in the individualized plan • Incentive payments (not to exceed the equivalent of three months of RCA for each incentive), as outlined in the individualized plan and based on County policy which include educational incentives for high school graduation, GED attainment and post- secondary education. Participants may receive incentive payments for each level of education achieved. Payment Assistance may be provided either as a one-time assistance payment or on an on-going basis,both of which are intended to promote sustainable employment. Payments will be made to a participant's EBT card (via direct deposit) or as a direct vendor payment, depending on the nature of the approved expense. Other assistance may not exceed the following amounts: o One Time Additional Cash Assistance: the equivalent of no more than three months'basic cash assistance grant and may be issued no more than C once per calendar quarter; supports employment and job training goals outlined in the individualized plan;education incentives are included as one- time additional cash assistance. One time additional cash assistance payments will not exceed $3,000 per year. o Ongoing Additional Cash Assistance: the equivalent of no more than the monthly basic cash assistance grant which may be paid for no longer than 24 months; supports employment and job training goals outlined in the individualized plan. o Supportive Services: not intended to meet ongoing basic needs of food, shelter, clothing,utilities, household goods, personal care items, and general incidental expenses. There is no limit on the cash value of these services. The Pitkin County Department of Human Services Director and/or the Economic Assistance Manager or their designee has the discretion to override the amount of other assistance if a hardship exists.The Economic Assistance Manager,or designee, must document.such hardship in CBMS. The decision to approve a Supportive Services/Other Assistance grant must be within budget allocations and as funding allows. Such payments are subject to recovery and will be pursued according to program regulations. Additional Cash AssisUmca Pitkin County may authorize recurring payments designed to meet the basic ongoing needs of the persons in the assistance unit,as determined by a needs assessment and documented in the individualized plan. Basic ongoing needs shall consist of,but are not limited to: • Training expenses,work supplies and equipment not otherwise covered by WIOA; • Personal Care Items and services needed for entering work related activities; • Transportation expenses to participate in employment, training or job preparation activities; • Other work-related expenses specified in the individualized plan and approved by the Pitkin County Economic Assistance Manager. Pitkin County may allow payments for a special need to a parent or specified caretaker whose child(ren) is eligible and receiving Colorado Works cash assistance. Adopted by the Pitkin County Board of County Commissioners on this_22_clay of February,2017. 493-- pqp ^� V�(,'�'( 4„ . V L - ( - -) Nan Su ndeen, IDirecto•,Human Services Date r(12) ) AIWS2(C f/1 co n, Chair, I kin County George New otmty Board of Commissioners )ate Nothing in the Pitkin County Colorado Works program shall be Interpreted to create a legal entitlement in any participant to assistance or services provided pursuant to the Colorado Works program. • Ftpcuk Services PITKIN COUNTY CARES POLICY TYPE: Human Services - POLICY TITLE: Operating Workforce Requirements & Employment Outcomes POLICY CWP 16-S EFFECTIVE DATE: TANF/Colorado Works 1W30/2016 This policy (CWP-l6-3) supersedes Pitkin County Human Services Child Care Availability (CWP 1.2), Job Readiness/Work Activities (CWP- 1.19)and Segregated Funds(CWP-1.16) policies which will be terminated effective 12/30/2016. Reference Colorado Revised Statute 26-2-703(21); 26-2-711 (1)(b) and (5)(a)(b); 26-2-714(5.5) CDHS Volume 3.606.8;3.608.1;3.608.2; 3.608.3;3.608.4 BACKGROUND As a condition of continued eligibility,Colorado Works assistance units that contain an adult member who is receiving basic cash assistance shall have such adult member in a work activity. PURPOSE The purpose of this policy is to identify the mechanisms by which Pitkin County ensures participants are assessed and supported on their progression to economic well-being through Colorado Works,and what criteria the county has established for exemptions from or accommodations to standard program elements, including locally defined services offered through the Colorado Works program in Pitkin County. POLICY Adults and youth over 16 are determined at application to be either eligible or ineligible for assistance. Cases that are without eligible adults are considered to be"child only" and are not required to participate in employment activities.Adults who are considered work- 1 eligible are provided with individualized services and supports to promote their family's economic well-being. Assessment Pitkin County conducts assessments for all work-eligible members of the household within 30 days of application.These assessments consider education,employment,household circumstances impacting economic well-being,and other relevant factors to determine which services and supports available in the program are the best fit for the participant, and working together,an individualized plan is developed. Assessment tools are used to support the assessment interactions as needed,and documentation is retained and case noted. Z& Job Readiness Job readiness in Pitkin County is when an individual is able to participate in and benefit from a variety of employment and training services or activities to assist participants in identifying and reaching their goals. Pitkin County recognizes that even those adults who have been identified as'work-eligible" may need to pursue strategies other than employment in order to attain economic well- being.Similarly,some families may be experiencing a crisis that needs to be dealt with before employment can be pursued. Examples may include families who are living in a shelter or those addressing immediate safety issues. Pitkin County may determine which individuals in these circumstances are not ready to focus on employment based on the assessment.Pitkin County considers the presence of the circumstances below as indicators that an individual is not ready to focus on employment: • Resolving medical or mental health issues • Actively seeking SSI/SSDI • Pregnancy past the 7th month or within a six week postpartum period • Primary care for an infant younger than 12-weeks • Primary care for a disabled family member !i • No available child care(see Child Care Availability below) • Individuals who have been assessed with having other significant challenges to working that may include,but are not limited to: o Homelessness o Limited English Speaking o Essential Skills Lacking • Other family emergency or situation on case-by-case basis,approved by the Pitkin County Economic Assistance Manager and/or Human Services Director or designee Domestic Violence issues are addressed in the Pitkin County Colorado Works Program Policy CW-06 Domestic Violence. Pitkin County does not require participants to document or verify their involvement in activities that are not focused on employment unless questionable,and will work closely with participants to schedule regular check-ins to document progress. Individualized Plan Utilizing the assessment results, Pitkin County will collaborate with al] work-eligible participants to develop an individualized plan. Plan will be tailored to each participant's strengths, desires,and goals,in addition to proactively addressing challenges that may arise in the pursuit of economic security. Case managers must collaborate with work-eligible participants to develop an individualized plan within 30 calendar days of the completion of the assessment. Because the duties and responsibilities of both parties must be clearly outlined in the plan,the plans must be completed in their entirety,and agreed upon by both the participant and the county worker. Plans may draw upon the full array of work activity opportunities,and/or include Pitkin County-defined activities for those who are not ready to focus on employment,supportive services,and referrals,as warranted. Services for lob-Ready Individuals Employment-focused Services: Participants who are determined to be job ready through the assessment process are individually engaged to ensure the most appropriate services and supports are provided to meet their employment goal. Job ready participants who do not have educational or skills gaps that need to be addressed may benefit from one or more of the following activities: • Employment • Subsidized Employment • Work Experience/Internship • Community Service • Job Search • On-the-job training • Search for available Child Care Education-focused Services: Pitkin County recognizes that for some participants,lack of formal or sufficient education may preclude them from successfully attaching to or sustaining employment. Participants who are lacking necessary educational qualifications and/or skills are individually engaged to ensure the most appropriate services and supports are provided to meet his/her needs. Pitkin County provides participants with opportunities to enhance their education,often through referral to community-based and partner organizations that offer adult and basic skills classes,and GED preparation and testing. Pitkin County works individually with participants to determine the best combination of offerings to quickly advance their employment goal and maximize their time in the program. Participants who have identified educational or skills gaps may participate in any of the following activities: • Basic Education • Vocational Education • English as a Second Language • • Job Skills Training • Work Study • High School • GED Prep Services for job-ready individuals are always paired with individualized case management, coaching,supportive services,and referrals as needed. Participants in these activities will have child care provided through the Colorado Works program,or the Colorado Child Care Assistance Program. Participants in these activities will be asked to support their progress through provision of state-required documentation. - - Services for Individuals Not Ready to Focus on Emnl ovment Segregated Funds-"Non-TANF County MOE": Pitkin County may utilize Non-TANF MOE funding under the following circumstances identified through the standard assessment process and documented through the individualized plan: • Individuals with a pending application for Social Security disability benefits. The individual's application date for Social Security disability benefits cannot be more than twelve months older than the TANF application or redetermination date. • Individuals have a current behavioral or physical health issue, documented by a medical or mental health professional • Individuals who are seven months or more pregnant or within a six week postpartum period. • No available child care(see Child Care Availability below) • Individuals who have been assessed with having other significant challenges to working that may include,but are not limited to: o Homelessness o Limited English Speaking o Children Circumstances o Essential Skills Lacking o Primary care for an infant younger than 12-weeks o Primary care for a disabled family member • Other family emergency or situation on case-by-case basis, approved by the Pitkin County Human Services D Director and/or Economic Assistance Manager or their designee. Non-TANF eligibility is contingent upon the availability of County Non-TANF MOE funds. Eligibility for Non-TANF MOE funds will be re-evaluated every six months. Non-TANF County MOE funding will cease for a participant when one or more of the following occurs: • The participant(s) is assessed as job-ready • Time limited and/or long-term barriers as outlined above no longer exist • The household is no longer TANF eligible • The County has exhausted all Non-TANF county MOE funds. Child Care Availability: ZR Pitkin County defines available child care as child care that maintains the health and safety of the child while encouraging growth and development and shall meet the physical, mental,and emotional needs of the child. Child care may be provided either by a licensed or exempt child care provider. An unlicensed provider is found unsuitable by Pitkin County if an individual residing in the home in which care is being provided,or who has access to the home,has a record of child abuse or neglect,violent behavior,substance abuse or any activity that may endanger the health or welfare of the child. Pitkin County uses the"child care unavailable"activity code in CBMS when participants who are caring for a child(ren) have demonstrated inability to obtain available child care. These participants may not be sanctioned. In order to be considered "available,"care must be: • Within a Reasonable Distance.Child care within a reasonable distance is defined as within a 15 mile radius of the participant's home or prospective employment or between the location of home and prospective employment. • Safe Transportation Options. Child care that is safely accessible by public transportation if no other transportation options exist is defined as available for children age six and older with distance and conditions of walking from the bus stop to the childcare program that are considered safe by the Department. • Appropriate.Providers offering a safe and healthy environment for all children and specialized care for children with medical conditions or special needs. • Safe Care. Appropriate child care that the parent self-identifies as safe for their child. • During Work Activity Hours. Appropriate child care that is available during the participant's scheduled work activity hours. Child care unavailability must be documented in the case file except for circumstances in which Pitkin County exercises the Prudent Person Principle in instances where documentation is unavailable or when obtaining such would create undue hardship to the family.Reasons for and use of the Prudent Person Principle must be documented in CBMS case notes. Notification Adult participants who are exempted due to any of the above (or any other criteria) must he notified that even though they maybe exempted from work-related service requirements, they are accumulating TANF months that count toward their 60-month lifetime limit. Holidays and Absences To help prepare our participants for employment outside of the Colorado Works program both employment and educational activities are treated like work.The total number of excused absences will be limited to 80 hours per year and no more than 16 hours per month. Allowable excused absences may include, but are not limited to the following reasons: • Temporary Child Care disruption • Funeral Leave • Legal Obligation • Site closed due to weather or for child if attending school • Medical appointment for self or child • Substance abuse treatment/counseling appointment/probation appointment. • Hospitalization of self,child,or other immediate family member Pitkin County case manager may approve additional excused absences,with respect to cultural and religious reasons,on an individual or case-by-case basis. The Colorado Works Program recognizes ten (10) holidays: • New Years Day • President's Day • Memorial Day • Independence Day li • Labor Day • Veterans Day • Thanksgiving Day • The Friday following Thanksgiving Day • Christmas Eve Day • Christmas Day Good Cause: Work Reauirementc Pitkin County makes every reasonable effort to ensure individualized plans are appropriate,achievable,and the most likely strategy to support a participant's long-term economic well-being goals. Pitkin County recognizes that there may be instances where a participant is unable to comply with the plan's terms.Good cause in Pitkin County is defined as follows: unforeseen, unusual or unavoidable circumstances that would prevent most people from �.. being able to engage in their plan as expected. Pitkin County does not require documentation or verification for good cause unless questionable,but does require that notice be provided within 48 hours of disengagement in order to avoid sanction. Notification should explain the reason for disengagement and should demonstrate good cause. In general,the Prudent Person Principle is used to determine good cause.At minimum, good cause for the county not pursuing a sanction will include: • Breakdown in child care arrangements or a lack of available and appropriate child care • Remotely located without transportation and unable to relocate or a breakdown in transportation arrangements with no feasible alternative • School obligations that frequently necessitate a parent's or specified caretaker's attendance • Loss of housing,or a housing crisis that might result in homelessness or eviction, which prevents the individual from participating in the requirements of their individualized plan • Verifiable medical emergencies or crisis involving members of the family • Short term temporary relapse in a participant's certified drug/alcohol treatment program • Participant's incarceration of less than thirty clays • Death of an immediate family member or authorized representative • Other situations,as determined by the Pitkin County I Iuman Services Director and/or Economic Assistance Manager or designee Work Centered Support Mechanisms Staff will be trained on interviewing, case management skills, and development of individualized plans as well as community wide work support programs.Annual meetings between Pitkin Economic Assistance staff and the Workforce Center will strengthen referrals,understanding of services and direct linkages for clients. In the event that a participant does not provide good cause rationale,a participant may be sanctioned or a case closed for demonstrable evidence according to Colorado Code of Regulations (CDHS Volume 3) 3.608.4. NOTE: This Good Cause: Work Requirements section of this CW-12 Workforce Requirements and Employment Outcomes policy supersedes Colorado Works Program Policy CW-16 Sanctions approved by the Pitkin County Board of County Commissioners on February 15, 2011. Adopted by the Pitkin County Board of County Commissioners on this 22 day of February, 2017. Nan Sundeen, director, Human Services Date itih Ailke George New an,Chair, n County Board of County Convnissio ers / Date Nothing in the Pitkin County Colorado Works program shall be interpreted to create a legal entitlement in any participant to assistance or services provided pursuant to the Colorado Works program. 6z3