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WIOA Young Adult ProgramsChapter 04: Documentation of EligibilitySummary:Guidelines for documenting initial program eligibility for Youth and Young Adults under the Workforce Innovation and Opportunity Act (WIOA) Initial general eligibility determination is to be based on a review of an application form signed by the applicant and (ideally, but not required) parent/guardian. The information provided on the application form used to determine eligibility for services under the WIOA Young Adult Program must be comprehensive enough to meet appropriate eligibility requirements. Documentation provided by the applicant and/or parent/guardian may be subject to subsequent data validation. Alternately, many (but not all) eligibility information items can be self-attested to by the applicant. In the instance of self-attestation, the applicant will be required to sign a form that affirms the self-attested characteristics being used for eligibility purposes. The completed application and eligibility determination form generated from Workforce One signed by the participant, case manager and parent/guardian (optionally) is to be kept on file by the service provider.Relevant Laws, Rules or PoliciesWorkforce Innovation and Opportunity Act (Public Law 113-128) HYPERLINK "" WIOA Final Rule (Dated 08-19-2016)WIOA Final Rule: Unified and Combined State Plans, Performance Accountability, and the One-Stop System Joint Provisions (Dated 08-19-2016)U.S. Dept. of Labor Training and Employment Guidance Letter No. 11-11, Change 2 (Dated 5/16/2012)U.S. Dept. of Labor Training and Employment Guidance Letter No. 23-14 (Dated 3-26-15) U.S. Dept. of Labor Training and Employment Guidance Letter No. 8-15 (Dated 11-17-15)U.S. Dept. of Labor Training and Employment Guidance Letter No. 10-16 Change 1 (Dated 8-23-17)U.S. Dept. of Labor Training and Employment Guidance Letter No. 21-16 (Dated 3-2-17)U.S. Dept. of Labor Training and Employment Guidance Letter No. 7-18 (Dated 12-19-18)U.S. Dept. of Labor Training and Employment Guidance Letter No. 23-19, Change 1 (Dated 10-25-22)U.S. Dept. of Labor Training and Employment Guidance Letter No. 9-22 (Dated March 2, 2023) U.S. Dept. of Labor Training and Employment Guidance Letter No. 23-19, Change 2 (Dated 5-12-23)Effective Date07/01/2015Last Updated5/19/2023ContactKay TracyEmail: Kay.Tracy@state.mn.usPhone: 651-259-7555John OlsonEmail: John.R.Olson@state.mn.usPhone: 651.259.7547Larry EisenstadtEmail: Larry.Eisenstadt@state.mn.usPhone: 651.259.7538PolicyEligibility, Equity and Accessibility: Consistent with TEGL 23-19, Change 1 and TEGL 23-19, Change 2, program operators are encouraged to consider impacts on equity and accessibility when developing any local policies and procedures around source documentation. Imposing additional more restrictive documentation requirements can serve as a deterrent for some prospective youth applicants. Self-attestation is an important option for populations with barriers to obtaining eligibility and reporting documents (such as disconnected youth, American Indian and Alaska Native populations, individuals experiencing homelessness, justice involved individuals, refugees, disaster impacted individuals, and others) and help ensure such populations are able to equitably access services. As a best practice, once enrolled, programs should assist the participant in obtaining the required documents using supportive service funds as these documents are likely needed for employment and training related activities. About Self-Certification: In January, 2023 the U.S. Department of Labor clarified that ANY Youth applicant can sign their own application form without requiring a signature from a parent or guardian. Whenever possible, a parental signature is preferred if the parent is supportive of the youth’s goals and objectives, but it is not required. Casenotes should be made, as appropriate.DOL has also reaffirmed the ability of applicants to self-certify in most (but not all) youth eligibility factors. The following data items located on the application form used to determine eligibility require documentation that may be subject to data validation requirements:Proof of Identity is required for all participants. The documentation may be in the form of a driver’s license or state ID; a copy of a utility bill; government issued birth certificate, passport; Veteran’s DD-214; health insurance card; Social Security card; school ID or school records. Self-attestation is allowed as a last resort.Proof of Age is required for all youth participants. Acceptable documentation includes driver’s license or state ID; baptismal record; governmental issued birth certificate; a copy of an age certificate issued by local school officials, DD-214 Report of Transfer or Discharge Paper; Federal, state or local identification card; passport; hospital record of birth; Social Security Administration printout, public assistance/social service records; school records; work permits; cross match with the Department of Vital Statistics; family bible or tribal records. Documentation must have date of birth. Self-attestation is also allowed.Social Security numbers must be documented but the refusal of giving a Social Security number CANNOT be used to deny services to an otherwise eligible individual. Acceptable documentation includes: Social Security card (other than a card indicating “not valid for employment); W-2 form, IRS form letter 1722; pay stubs; Social Security benefit checks; DD-214 Report of Transfer or Discharge; Military ID; Other Federal or state ID with a Social Security number.Selective Service registration information and request for a Status Information Letter must be documented for all males born on or after January 1, 1960 who have reached their 18th birthday but who have not reached their 26th birthday. Documentation can be in the form of an Acknowledgement letter; a Selective Service registration card; a stamped post office receipt of mailing a registration; DD-214 Report of Transfer or Discharge; Selective Service Status Information Letter; Selective Service registration record (form 3A, Selective Service Verification form).If the participant has not registered for the Selective Service, a registration form should be filled out and mailed or completed online. If the young adult is unable to locate the required documentation, Selective Service status can be checked at Selective Service Systems > Registration > Check a Registration. A screen printout from the Selective Service Verification website also constitutes valid documentation (see Related Links).Please Note: Selective Service registration only applies to individuals born biologically as males. Persons born as males, but later identifying themselves as something other than male are still legally required to register for Selective Service. Conversely, a person born as a female, but now identifying as something else should not register for Selective Service. Additional information can be found at Selective Service status for persons registered as male is NOT subject to federal data validation requirements. However, state and/or local monitors will check (where applicable) to ensure any male over the age of 18 during participation is registered. U.S. Citizenship/Authorization to Work Status must be documented and retained in the participant’s file. U.S. Citizenship/Authorization to Work is required for WIOA eligibility. Citizenship documentation can consist of: original or certified copies of a birth certificate issued by a state, county, municipal authority or outlying United States possession; alien registration card indicating Right to Work (USCIS forms I-151, I-155, I-94, I-197, I-179); voter registration card; public assistance or SNAP records, naturalization certification; DD-214 Report of Transfer or Discharge (if place of birth is indicated); foreign passport stamped eligible to work in U.S.; hospital record of birth (if place of birth is indicated); Native American tribal documentation; U.S passport (expired or unexpired); or any one verification source from List A of the I-9 form OR any one verification source from List B AND any one verification source from List C of the I-9 form (see related links); Social Security card unless it is stamped “not valid for employment.”Serving Refugees: As defined in 20 CFR 683.285(a)(5): Participation in programs and activities or receiving funds under title I of WIOA must be available to citizens and nationals of the United States, lawfully admitted permanent resident aliens, refugees, asylees, and parolees, and other immigrants authorized by the Secretary of Homeland Security or the Secretary's designee to work in the United States (emphasis added).The Employment Authorization card would meet the requirement of being authorized to work in the United States. Of course, all other eligibility criteria would need to be met in order to enroll the individual. Individual Status/Family Size documentation is preferred IF eligibility is based on family income; otherwise self-certification is acceptable. Acceptable documentation includes: birth certificate; appropriate court decrees; landlord statements; leases; divorce decrees; marriage certificates; medical cards; recent tax returns; public assistance/social service agency records; public housing records; written statements from publicly supported 24 hour care facilities (e.g. hospitals, prisons). Self-certification is also allowed. Family of One documentation is preferred IF eligibility for services under WIOA Youth is based on an in-school applicant with a disability whose own income is at or below the poverty line, but is a member of a family whose household income exceeds income levels or eligibility. Individual/Family Income documentation is preferred IF eligibility is based on the earnings received. Acceptable documentation includes: pay stubs; alimony agreements; Veterans Administration award letters; bank statements; compensation award letters; court award letters; employer statements; family/business financial records; housing authority verifications; pension statements; quarterly estimated tax statements; Social Security Administration benefit statements; Unemployment Insurance documents; public assistance/SNAP records; or cross-match with refugee assistance records. Self-certification is also allowed.NOTE: For WIOA youth who are out-of-school at the time of enrollment, eligibility using “low income” applies only where the applicant is qualifying for eligibility solely on the basis of “needs additional assistance” OR is an “English Language Learner.” OSY applicants with one or more other barriers do NOT need to meet income eligibility requirements.Proof of Receipt of Public Assistance/SNAP documentation is required IF it is directly pertinent to eligibility; otherwise self-certification is acceptable if it is noted why source documentation is not available. Acceptable documentation includes: copy of public assistance check; public assistance records/printout; cross-match with public assistance database; copy of authorization to receive SNAP benefits; SNAP receipt; letter from SNAP agency; postmarked SNAP mailer with name and address; medical card showing cash grant status; refugee assistance records or public assistance case number obtained by eligibility determination staff from a call to the public assistance office. WDAs choosing to use individual/family income as a qualifying factor do NOT need to verify receipt of public assistance/SNAP.All required Workforce One eligibility/Demographic Characteristics should match the initial application form. However, ONLY those items necessary for eligibility determination may need to be verified/documented or self-certified. In determining which characteristics to verify, the WDA should use the documentation presented by the applicant.Specific eligibility documentation for WIOA youth program applicantsPlease note that WIOA data validation requirements may include a review of any of the items listed below. In addition, each item is relevant to eligibility at the time of enrollment—NOT the time of application.School Status at time of Enrollment (not Application): Acceptable documentation includes: school ID card; transcript, report card, attendance record; other student data or record; letter from school. Self-attestation is also permitted under WIOA Youth.A low-income individual: Acceptable documentation includes: “family of one” (indicated above); “individual/family income” (indicated above) or “free or reduced price lunch” (indicated below). Self-attestation is also permissible; case notes should reflect relevant circumstances.Basic skills deficient: Acceptable documentation includes: assessment test results; applicable records from educational institution (transcripts, academic assessments, other school documentation); case notes.IMPORTANT NOTE: Self-attestation for basic skills deficiency is NOT permitted in this instance, per DOL. Test results must be used for determination.An English Language Learner (ELL): Acceptable documentation includes: case notes; assessment test results; applicable records (transcripts, letters) from an educational institution; signed Individualized Service Strategy and/or application enrollment form. Self-attestation is also permitted.An offender: Acceptable documentation includes: case notes; court documents; letter of parole; letter from probation officer; documentation from the juvenile or adult criminal justice system; referral transmittal from a reintegration program/agency; signed Individualized Service Strategy and/or application or enrollment form. Self-attestation is also permitted.A homeless participant, homeless youth or runaway youth: Acceptable documentation includes: a signed intake application, documentation form a shelter or social services agency, needs assessment documentation, case notes, signed individual service strategy, documentation from a caseworker or support provider. Self-attestation is also permitted.Foster Child: This may include any youth who is 24 years of age or younger at the time of enrollment and is currently in the foster care system or has aged out of the foster care system. Acceptable documentation includes: written confirmation from a social services agency, case notes, a copy of transmittal/referral documentation from a foster care agency, needs assessment, signed intake or application form, a signed Individual Service Strategy. Self-attestation is also permitted.Pregnant or Parenting Youth: Acceptable documentation includes: case notes, needs assessment, Women, Infants and Children (WIC) eligibility verification, TANF/MFIP single-parent eligibility verification. Self-attestation is also permitted. Youth with a disability: Acceptable documentation includes: School Section 504 records provided by the student, assessment test results. Self-attestation is also permitted; however, the applicant can identify as having a disability but chooses not to self-identify any additional details regarding the disability.Youth Who Require Additional Assistance (5% Participant): TEGL 9-22 clarifies program operators should use this ONLY if there are no other barriers associated with the applicant. Conversely, if there are other barriers, the “Youth Who Require Additional Assistance” should NOT be used. This will assist in ensuring Minnesota does not exceed more than five percent of youth served using this “barrier of last resort.” Students eligible to receive (or receiving) free or reduced-price lunches may be used as a proxy for meeting low-income requirements under WIOA. While self-attestation is permissible, documentation or confirmation from the school district the applicant is attending is preferred.Related LinksSelective Service Systems > Registration > Check a Registration ................
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