1.2 Required Participation

Revised on: January 31, 2023

Legal References:

• RCW 74.08A.250

The Required Participation section includes:

• 1.2.1 What is participation and how does it count?
• 1.2.2 What are the WorkFirst participation requirements?
• 1.2.3 What are the participation requirements for two-parent households?
• 1.2.4 What is the participation requirement for single parents with a child under six?
• 1.2.5 How do we determine the best employment pathway?
• 1.2.6 When can someone participate in various WorkFirst activities?
• 1.2.7 What does participation look like for families in crisis situations?
• 1.2.8 What are contracted services?
• 1.2.9 What if a participant doesn't meet an exemption but can't participate in regular employment activities?
• 1.2.10 What are the WorkFirst requirements for dependent teens and pregnant or parenting minors?
• 1.2.11 Home schooling
• 1.2.12 eJAS/ACES Codes
• 1.2.13 Participation step-by-step guide

1.2.1 What is participation and how does it count?

Most participants are required to participate in work or work-related activities full-time, which is defined as "getting as close as possible to 40 hours per week," with a goal of at least 32 hours a week.  In order to develop a full-time Individual Responsibility Plan (IRP) we count the actual hours involved in an activity.  When working with the participant to develop the IRP, it is very important that we make every effort to reach 40 hours of activities per week.

Work with the participants who aren't in full-time (32-40 hours) activity(ies) to ensure that every hour of activity is properly recorded in the IRP, as close to 40 hours a week as possible, with a minimum of 32 hours.  See the 3.3, Individual Responsibility Plan, section for more information on Individual Responsibility Plans.

Federal rules reduce funding for states that fail to meet a federal work participation rate.  To meet the rate, states must have a percentage of participants in the required number of hours of countable activities each month.  The percentage is higher for two parent families.

To be a two-parent family, neither parent can be:

• An undocumented immigrant;
• Disabled (on SSI/SSA disability or with a ZD exemption); or
• Caring for a disabled family member (with a ZB or ZC exemption).

Federal rules define activities as "core" or "non-core".  As shown on the Core & Non-core Activity chart, some core activities only count for a limited amount of time.  This chapter outlines Washington’s WorkFirst participation requirements; however, a WorkFirst participant may be fully participating in WorkFirst activities and still not meet the federal work participation rate.

1.2.2 What are the WorkFirst participation requirements?

The chart below shows WorkFirst (WF) requirements for parents/caregivers who are able to participate and includes strengthened participation requirements. Most parents/caregivers are still required to participate 32-40 hours per week with at least 20 of those hours in core activities.  Even though the participant has these requirements, it is also important to meet them where they are and engage them in WorkFirst activities that count and move them forward to self-sufficiency. 

Most participants must meet the requirements in row 1.  WorkFirst doesn't require the following to participate in core activities (rows 4 through 6 below):

• One parent in a two-parent family when they meet the conditions in WFHB 1.2.3
• Exempt participants in the Pregnancy to Employment Infant or Toddler Exemption (See WFHB 5.1.11)
• Teen head of households (age 18 or 19 years of age) who don’t have a High School Diploma or GED
• Minor parents who do not have a child under 12 weeks old

Strengthened participation is an additional three hours (preferably core activity hours) in the participant’s IRP to assist them in meeting the federal participation rate when participants may have unexcused absences or too many excused absences.

The strengthened participation requirements are shown in the chart below or in the Participation Requirements Resource.

The following activities in most cases meet strengthened participation without adding additional hours (add additional hours when necessary):

• Community Jobs and Career Jump
• Work Study students as long as they meet the requirements in WFHB 8.1.10
• Vocational Education

The following are important to remember when including strengthened participation in a participant’s IRP: 

• A 38-hour per week full time job search is available when only one parent in a two-parent family is participating under the two-parent option.
• Don’t exceed the FLSA maximum hours for Community Service or Community Works.  You can substitute non-core hours for core hours as needed to stay within the FLSA maximum.  See WFHB 3.3.2.5 for more information about deeming rules and the FLSA maximum.
• 20 hours of unsubsidized employment (or 30 hours for a two-parent family) meets the core activity requirement.  For two-parent families or single parents with no children under six in this situation, consider adding non-core activities to meet the strengthened participation requirements.

Examples:

1.2.3 What are the participation requirements for two-parent households?

The participation standard for two-parent households is full-time (32-40 hours per week) for each parent.  However, under some circumstances, we can allow a household to choose a two-parent option.

Two-parent options are available to two-parent families who are:

• In compliance with WorkFirst,
• Appropriate for the option, and
• Electing to choose that option after a discussion that includes both parents and the WFPS/WFSSS.  

Use these options when appropriate to assist two-parent families towards family stability and self-sufficiency.

In order to utilize the two-parent options, a conversation must occur with the family to determine whether this option is appropriate for their household and to determine if one parent may opt out of participation.  The conversation must focus on the whole family to determine the best participation option for the family to reach self-sufficiency. 

The two-parent options are only available when both parents are in full compliance with WorkFirst requirements.  Any time one or both of the parents utilizing the two-parent option falls out of compliance, the household will return to the full time participation standard for each individual.

Option One

Recipient two-parent families may choose to have one parent opt out of participation requirements to stay home and care for the children as long as:

• Both parents are participating satisfactorily, meaning they have completed their comprehensive evaluation and any required assessments.  If one or both parents are in WorkFirst sanction, the sanction(s) must be cured before the household can be offered the 2-parent participation option;
• The parent opting to stay home is capable of caring for the child(ren);
• The other parent agrees to  participate 35 hours per week (30 hours core and 5 hours core or non-core); and
• Both parents engage in any needed chemical dependency or mental health treatment. 

If the WFPS or WFSSS and the TANF family determine that this option is appropriate, use the participating parent’s time spent in treatment to help meet the family’s work participation requirements.  If the participating parent stops participating as required without good cause, pursue sanction and send an appointment letter to the parent who was opting to stay home scheduling them for an appointment to develop an IRP.

Option Two

Recipient two-parent families may choose to have both parents split participation requirements, as long as:

• Both parents are participating satisfactorily, meaning they have completed their comprehensive evaluation and any assessments needed.  If one or both parents are in WorkFirst sanction, the sanction(s) must be cured before the household can be offered the 2-parent participation option;
• They meet the core requirement of 30 hours per week, in addition to at least 5 hours of core or non-core; and
• Both parents engage in any needed chemical dependency or mental health.

If one parent ceases to participate without good cause, pursue sanction and send an appointment letter to the other parent to come in for an appointment to build a full time IRP.

1.2.4 What is the participation requirement for single parents/caregivers with a child under 6?

For single participants with a child under the age of six, the participation requirement is 20 hours per week in a core activity.  Participants must participate satisfactorily and cure a sanction to avoid Non-Compliance Sanction termination. 

Single participants may voluntarily participate for more than 20 hours per week.  Single participants who wish to attend Vocational Education activities must participate full time. 

1.2.5 How do we determine the best engagement pathway?

Everyone has skills and abilities needed in today's workforce.  Weaving those skills and abilities with labor market realities and education levels is the cornerstone of WorkFirst. A comprehensive evaluation using the Pathway Development Tool (PDT) is key in leading participants to employment, through activities like job search, education, Community Jobs or Career Jump.

The WFPS/WFSSS refers the participant to the appropriate engagement pathway identified by the comprehensive evaluation or assessment using the appropriate code(s).  The pathways include:

• Career Scope (Job Search)
• Education & Training Activity
• Community Jobs
• Community Works Program
• Unsubsidized Employment
• Limited English Proficient (LEP) Pathway
• Issue Resolution
• Exempt
• 3rd trimester of pregnancy deferral

See WFHB 3.2 for engagement pathway details.

If there is an indication or the participant discloses involvement with Department of Children, Youth and Families (DCYF) and/or the Department of Corrections (DOC) at any time, we must work collaboratively to address the needs of the family. 

Participants involved with DCYF and/or DOC may be required to do activities like counseling or treatment to help keep their families together.  It's critical to consider and include these activities, as appropriate, when developing the participant’s IRP.  We want to make sure that WorkFirst requirements don't interfere with the activities needed to comply with DCYF and/or DOC requirements and resolve their family issues and emergencies.

1.2.6 When can someone participate in the various WorkFirst activities?

Unless the outcome of the comprehensive evaluation or assessment indicates otherwise, employment services are the first activity for most.  The PDT is the key tool in leading participants to employment through job search, education, or other engagement pathway activities like Community Jobs, Career Jump or Community Works approved by WorkFirst staff.

For participants who aren't successful in job related activities, it is important to determine what factors may be contributing to the lack of success.  The participant may have an undisclosed disability, barrier, or challenge and you can't provide assistance without knowing what obstacles they are facing.  Inform the participant that you want to see them succeed and that support services are available for people needing special consideration.  Ask whether circumstances have changed and/or has the participant disclosed all information that may be affecting their success.

1.2.7 What does participation look like for families in crisis situations?

The WFPS considers and takes action for those participants in crisis/issue resolution situations that count as full-time participation.  The WFPS can develop an IRP with the participant that specifically addresses the crisis issues.  When necessary, consult with expert personnel for assistance, including Social Service Specialists (SSS), tribal representatives, family violence specialists, and other WFPS or supervisors.  This should be done when assistance and expertise is needed to develop specific steps the person should take to mitigate her/his circumstances.

Living or working in an area impacted by a declared disaster may affect a parent/caregivers’ ability to participate in WorkFirst activities.  Please see the Disaster Impact (DI) step by step for more information.

Both state and federal rules recognize that not all parents/caregivers are able to participate all the time. It is important that we stabilize families, resolve issues and provide participants with exemptions when that is the best plan for the family.

Deferrals and exemptions won’t necessarily make it harder to meet the federal rate.  As shown on the WorkFirst Stacking Strategy chart, some exempt participants qualify for federal exemptions, and participants in countable "X" codes may be able to add enough hours to meet federal participation requirements.

The WFPS directs a participant to the WFSSS via the Issue Resolution pathway for assessment and services when s/he has an urgent issue.  The WFSSS addresses the immediate need, determines appropriate participation activities, and outlines these activities in the IRP.

Be sure that the participant understands how and when to report progress or lack of progress in completing the steps outlined in the IRP.  The participant meets required participation with completion of the activities outlined in the IRP until the SSS determines the issue is resolved or adds other activities to the IRP.

1.2.8 What are contracted services?

Refer participants to contractors to receive specific services and may include community or faith-based organizations, for profit providers, and others.  Contractors provide services that aren’t otherwise available through the partner agencies.  They address barriers or issues to support individuals in finding and keeping employment.  Notify contractors of any necessary accommodations.

WorkFirst has established strong certification standards for contractors and service providers.  Contractors and service provides must meet the standards to obtain WorkFirst certification, which occurs during the contracting process.  Contractors must meet the standards for reporting to the WFPS or WFSSS by providing monthly verification reports.  Contractors must report non-participation immediately.

1.2.9 What if a participant doesn't meet an exemption but can't participate in regular employment service activities?

Division of Vocational Rehabilitation (DVR)

Some participants may need specialized services to participate in required WorkFirst activities. If a participant is unable to engage in regular employment activities, they may be required to participate in an activity. Each participant's impairment needs to be assessed and evaluated by professionals who are knowledgeable of their medical needs, skills, and abilities, while exploring their desired employment outcomes. WorkFirst staff supports the participant with obtaining medical evidence, and a referral to the Division of Vocational Rehabilitation (DVR). DVR Counselors (VRC) provide specific vocational services. WorkFirst staff coordinates with the VRC or other professionals when the participant is referred for services (see WFHB section 6.6.8 DVR Referrals).

In some cases, the participant may be placed on a waiting list with DVR. If on the wait list, determine other potential activities the participant can engage in to prepare for participation in DVR work-related services, such as gathering medical evidence and following all required treatment. Potential activities that are appropriate for a participant waiting for DVR employment services and may be included in the participant's IRP:    

• Substance abuse treatment,
• Medical treatment,
• Mental health counseling,
• Parenting classes,
• Adult education,
• Life skills courses,
• Money management education,
• Work part-time in an entry-level job,
• Applying for SSI

Department of Children, Youth and Families (DCYF)

Some participants working with DCYF may not be able to participate in employment service activities while being required to attend court appointments, counseling or treatment. If at any time, there is an indication or the participant discloses involvement with DCYF at any time, it is critical to consider these activities when developing the participant's IRP.

Department of Corrections (DOC)

Some participants working with DOC in a sentencing alternative program may not initially be able to participate in employment service activities. An incarcerated individual who is accepted into the “Family & Offender Sentencing Alternative (FOSA)” program is still under community custody supervision and those in the DOC “Community Parenting Alternative (CPA)” program and subject to electronic home monitoring. Incarcerated individuals in either program report to a specialized DOC Community Corrections Officer (CCO) and can only leave the home to participate in required activities such as mental health or chemical dependency treatment, parenting classes, work, vocational education, life skills, or other similar productive activities that DOC allows. However, as the incarcerated individual progresses through the phases of the program, additional activities may be included with approval from the CCO, such as community jobs, community service, or job search.

It is critical to collaborate and coordinate with DOC and consider these activities when developing the participants’ IRP. Please contact Tarimah Williams if you have any questions.

1.2.10 What are the WorkFirst requirements for dependent teens and pregnant or parenting minors?

Dependent teens that are on an adult's WorkFirst cash assistance grant aren’t required to do an IRP or verify school attendance. The following chart summarizes WorkFirst requirements for dependent teens/pregnant or parenting minors and teen head of households:

There are no WorkFirst requirements for dependent teens that are in an adult's WorkFirst cash assistance grant. It is the participant's responsibility to ensure the child is in school. However, a DCYF referral may be appropriate if a dependent teen isn’t in school.

Some pregnant or parenting minors must go to school and be in an approved living arrangement as a condition of TANF/SFA eligibility. See these sections of the EAZ Manual for more information:

• Teen Parents
• Age Requirements

1.2.11 Home Schooling

Unmarried pregnant or parenting minors and teen head of household families that are home schooled can meet the WorkFirst participation requirement for schooling upon approval by the household's local school district and meets the state law requirements. See RCW 28A.200 for more information.

When non-assistance unit caregiver reports they are providing, or intend to provide home-based instruction, they must submit a signed statement to the school district declaring their intent to home school. This is a yearly requirement. Once the participant files the document and provides a copy to the WFPS, then the home schooling can be added to the IRP.

Home schooling is WorkFirst participation for the minor parent or teen head of household only. A parent/caregiver providing the home schooling can’t satisfy WorkFirst participation requirements by providing the instruction.

1.2.12 eJAS/ACES codes

• RO (referred to social service specialist)
• HS (High School completion or High School equivalency for participants 19 years of age or younger)
• BE (High School completion, including High School 21, for participants 20 years of age or older)
• GE (High School equivalency for participants 20 years of age and older)

Resources

Related WorkFirst Handbook Sections

• 3.2.1 Comprehensive Evaluation
• 3.3.1 Individual Responsibility Plan
• 3.5.1 Entering Non-Compliance Sanction (NCS)
• 5.1 Pregnancy to Employment Pathway
• 6.1 Resolving Issues - Overview
• 7.1 Education & Training - Overview

Other Resources

• Desk Aid - Alternatives to Total Confinement – Persons with Minor Children
• DSHS 14-427(X), Teen Parent Living Assessment
• Participation Requirements