8.1 Overview

Revised December March 14, 2025

Legal References:

The Paid & Unpaid Employment - Overview section includes:

  • 8.1.1 What is employment?
  • 8.1.2 Where do hours of employment come from?
  • 8.1.3 Why are employment services important?
  • 8.1.4 How do I verify employment for job starts?
  • 8.1.5 What is acceptable verification of employment hours?
  • 8.1.6 How do we record hours for temporary employment?
  • 8.1.7 When must a participant take a job?
  • 8.1.8 What are employment principles?
  • 8.1.9 Will any job do?
  • 8.1.10 How do work-study hours count?
  • 8.1.11 What is AmeriCorps/VISTA employment?
  • 8.1.12 What is WIA paid work experience?
  • 8.1.13 Verifying job starts -Policy in Practice

8.1.1 What is employment?

Employment, or work, means to engage in any legal, income generating activity which is taxable under the United States Tax Code or which would be taxable with or without a treaty between an Indian Nation and the United States. Work provides the best opportunity for families to raise their income and stabilize their family.  Helping participants find permanent, unsubsidized employment means additional income for families and is the goal of the WorkFirst program as defined in WAC 388-310-0200.

8.1.2 Where do hours of employment come from?

There are several different ways that WorkFirst staff may learn about new employment.  The participant may report the change verbally (during a conversation or a voicemail), or in writing (e.g. turning in a wage stub, employer statement, reporting it on a change of circumstance form or Eligibility Review) or Case Managers may learn of a new job through a WorkFirst partner in an eMessage.  In all cases, the income must be budgeted in ACES and staff must verify the hours.

Employment can be part-time (31 hours per week or less) or full-time (32 hours per week or more). It comes in a variety of forms, including:

  • A paid, unsubsidized job,
  • Subsidized employment (Community Jobs),
  • On-the-job training (that combines training with a job)
  • Self-employment,
  • College work study, and
  • Paid work experience, practicums or internships.

When a participant has 20 hours of unsubsidized employment (or 30 hours for a two-parent family) this will meet the core activity requirement.   For two-parent families or single parents with no children under six years old, discuss with them any benefit of adding additional  activities to meet the strengthened participation requirements. See WFHB 1.2.2 What are the WorkFirst participation requirements? for additional information about stacking an additional hours in the participant's Individual Responsibility Plan (IRP) when possible.

Unlike every other type of countable WorkFirst activity, employment hours are counted and verified using the TANF prospective budgeting rules and collected from ACES 3G. This means Case Managers don't need to request actual hours of employment each month, however, they must verify employment when required (see the Employment Hours Coding Desk Aid for additional details). 

To determine financial eligibility for TANF, CSD Eligibility staff request wage and hour verification at application, eligibility review, mid-certification review or when hours are decreasing (before increasing benefits).  Verification is not required for job starts, so CSD Eligibility staff can update the new reported income using just the client’s statement. See section 8.1.13 Verifying Job Starts - Policy in Practice explaining how employment hours must be verified when a participant starts a job. Rules for financial eligibility budgeting can be found in the EAZ Manual chapters Income – Effect of Income and Deductions on Eligibility and Benefit Level and Income Special Types.

 

Employment hours and income must be correctly entered onto the ACES 3G Earned Income Screen. Once employment hour data for the ongoing month is entered into ACES 3G and verified:

  • The ACES 3G data will be used to report the participant's employment participation, including for federal reporting.
  • ACES 3G calculates the average weekly hours of employment and display in eJAS, that way, all WorkFirst staff including  partners know how many employment hours are being reporting to the federal government.
     

8.1.3 Why are employment services important?

Career Scope service activities connect participants to the labor market. It provides avenues for participants to move toward economic stability as soon as possible. The initial job, however, may be entry-level, temporary or part-time. This means it is important to connect participants with post-employment services options (reserved for those working 20 hours per week or more) to find or train for better jobs.

8.1.4 How do I verify employment for job starts?

WorkFirst staff must verify employment hours for new jobs before the hours can count towards participation. As mentioned in 8.1.2 Where do Employment Hours Come From?, prospective budgeting rules don’t require verification when a participant gets a job. WorkFirst staff are responsible to verify employment hours.

If CSD eligibility staff first learn of a new job, they record wage and hour information, often based on the participant's statement, into ACES 3G. If the participant remains eligible for cash assistance, Case Managers will learn about changes in employment hours, including the start of a new job, via their Caseload Management Report (CLMR) Section #7 “Clients Where Employment Hours Have Changed”. Once WorkFirst staff learn of the change, they contact the participant to update their IRP and confirm that the employment hours have been verified - see more in section 8.1.13 Verifying Job Starts - Policy in Practice.

If the Case Manager determines the participant started a new job, it’s time to update the IRP:

  • Review the ACES 3G Earned Income screen to see if the valid value is Client Statement CS or Client Estimate CE (both meaning staff used a client statement which is not federally countable); If yes:
    • Request verification of the participant's employment hours in the IRP and give/mail the IRP to the participant.
    • Start the sanction process if the participant refuses to provide proof of employment hours.

Once employment hours have been verified, the coding in ACES 3G will need to be updated with the correct valid value and to adjust the hours if appropriate. CSD staff can find additional information in the CSD Procedure Manual – Communication to Financial from Social Services for additional information. CSD Eligibility staff entering the employment hours into ACES 3G will adjust wages and hours, as needed, and update the verification valid value on the ACES 3G Earned Income Screen to affect the ongoing benefit month.

Updating historic employment hours

To record  the historical employment hours, after employment is verified and the ongoing month is updated, the worker will go back into a minimum of 2 historical months (unless the employment start date was less than 2 months ago). The worker will update the historical ACES 3G Earned Income screens using:

  • The same budgeting method as the ongoing month
  • The same number of hours entered in the ongoing month
  • Income of $0.01 - Do not enter actual income for the historical months - it is critical that CSD Eligibility staff enter $0.01 to minimize overpayments. Ignore (IG) any BEGs created by entering historical information.
  • Appropriate valid value (Employer Statement ES, Wage Stub WS, Collateral Contact CC or Other OT)

This process allows the employment hours to count for WorkFirst participation in the historical months.

Reminder: Historical hours can only be entered once verification of employment hours are received.

8.1.5 What is acceptable verification of employment hours?

Any source, including verbal, written, and electronic statements, can be used to verify employment hours if it meets the rules for evaluating verification in WAC 388-490-0005, which requires verification to:

  • Clearly relate to what the participant is trying to prove.
  • Be from a reliable source.
  • Be accurate, complete and consistent.

The Acceptable Forms of Verification Chart in the EAZ Manual has a suggested list of reliable sources of verification for income. 

When using a verbal employer statement, WorkFirst staff must document in eJAS the participant's employment hour information, as well as the contact's name, title, phone number and the date of contact.

8.1.6 How do we record hours for temporary employment?

Temporary employment is a paid, unsubsidized job lasting 30 days or less. Examples include temporary employment agencies (such as Manpower, Labor Ready, etc) and casual labor (such as odd jobs for landlord, friends and relatives) or other employers offering temporary employment.

Temporary employment can be part-time (31 hours or less per week) or full-time (32 hours per week or more). In either case, there is an estimated employment end date of 30 days or less and the employer does not consider the participant a permanent full-time or part-time employee.

Employment Security Department (ESD) releases participants from job search to engage in temporary employment. In the past these have been counted as excused absences. However, as long as the temporary employment hours are verified and documented, they will count as employment. Temporary employment hours for federal reporting purposes are recorded from the verified employment hours entered onto the ACES 3G Earned Income screen.

At the beginning of each month, ESD will send to DMS Temporary Employment Tracking Logs listing the verified temporary employment hours for each participant who reported temporary employment for the previous month.

WorkFirst staff will enter these verified temporary employment hours on the ACES 3G Earned Income screen for the historical month in which the employment occurred using the historical entry of hours method. For more information on the historical entry of employment hours, please refer to WFHB section 8.1.4 How do I verify employment for job starts.

For more information on ESD's temporary employment process, please refer to WFHB section 4.1.8 What is Temporary Employment and how is it recorded?

8.1.7 When must a participant take a job?

As shown in the chart below, these are some of the legal conditions under which a job is not appropriate, depending on whether the job is paid, unpaid, and/or subsidized.

A participant cannot be required to accept a job which ...
Is paid or unpaid and
  • Does not meet federal, state or tribal health and safety standards.
  • Is available because of a labor dispute.
  • Does not provide industrial insurance coverage (unless working for tribal government/ for-profit business).
  • Working hours/conditions interfere with religious beliefs/practices (and no reasonable accommodation made).
  • Unreasonable work demands or conditions (like not paid on schedule).
  • Displaces currently employed workers (results in another employee's job loss, reduced wages, reduced hours of employment or overtime or lost employment benefits).
Is paid and

Same as above, plus:

  • Pays less than the federal, state, local, or tribe minimum wage, whichever is higher.
  • Requires them to resign or refrain from joining a legitimate labor organization.
  • Does not provide unemployment compensation, unless they are:
    • Working for a tribal government or tribal for-profit business; or,
    • Treaty fishing rights related workers exempt under section 7873 of the Internal Revenue code.
  • Does not provide benefits equal to those provided to other workers employed in similar jobs.
Is On the Job Training (OJT) or subsidized and
  • The employer becomes involved in a strike, lockout or bona fide labor dispute.
  • The participant is used to displace another employee (and DCYF stops paying the subsidy).

8.1.8 What are employment principles?

When thinking about WorkFirst, remember to keep the importance of work in mind.

Employment provides the best opportunity for families to raise their income and leave poverty.

Those who work always have more income than if they receive only a TANF cash grant.

Parents have the primary responsibility for supporting their children. Participant and the state share responsibility for helping families leave welfare. Participants are responsible for moving quickly into jobs. The state is responsible for helping participants find and keep a job, and for collecting child support.

Support is available to help participants become and stay employed, for example health care insurance and child care that participants can access and afford.

The contracted partner agencies that share responsibility for WorkFirst will work with employers and other local partners to move families into self-supporting work.

Washington State welfare reform is based on a "work first" model, and on the conviction that everyone who can work should work, by immediately participating in Career Scope activities or employment. However, many of the families served through WorkFirst have barriers to employment and are best served through other referral pathways.

8.1.9 Will any job do?

Participants will often start with low-wage, temporary or part-time jobs and may continue to qualify for WorkFirst cash assistance. Others are in college work-study or in subsidized employment - temporary jobs that won't last. Any job is a start that can give participants the work history and references they need to obtain better employment. Still, there are things to keep in mind for participants who are employed, but in jobs that won't last long enough or pay well enough for a successful WorkFirst exit.

There are two basics to review with these participants while building their IRPs:

  • They may be required to participate for up to 40 hours per week, and
  • They have a choice of activities.

Individual circumstances will vary and affect participation options. A person in subsidized employment may be focusing on resolving issues as his or her additional activity, and moving to Career Scope activities as the situation improves. A person in college work study or who is limited-English proficient may be concentrating on their studies.

8.1.10 How do work study hours count?

Paid college work study is considered employment. The number of hours a participant is working in a federal or state work study count toward meeting the core activity requirement. Work study less than 19 hours per week must be stacked with other core activities (see stacking activities section).

The colleges are able to approve between 1 and 19 hours per week of work study. This will assist participants in meeting their core activity requirements. For example, a participant may be completing vocational education training that is 26 hours per week. The college can add 6 or more hours of work study to help the participant meet the goal of 32 - 40 hours per week of participation. The strengthened participation requirements in WFHB 1.2.3 don’t apply to work study students as long as they meet these requirements.

8.1.11 What is AmeriCorps/VISTA employment?

AmeriCorps national service programs, such as VISTA or AmeriCorps, provide a stipend living allowance to program participants (more commonly referred to as members). For the purposes of WorkFirst, the stipend is treated as salaried employment (not self-employment) and you code it as PT or FT depending on the number of hours the person works each week.

AmeriCorps/VISTA employment typically lasts for nine to 12 months, is normally full-time and result in educational award for teens or parents who successfully complete the program. Members will obtain marketable soft skills, job skills, a good source of income, and work experience. AmeriCorps and Vista programs can be an effective way for parents and teens to achieve self-sufficiency. See EAZ 388-450-0045 for information about how to budget AmeriCorps/VISTA earnings.

8.1.12 What is WIOA paid work experience?

ESD may authorize paid work experience for participants in many areas of the state, funded by Title 1 of the Workforce Innovation and Opportunity Act (WIOA). Participants’ WIOA work experience payments will impact financial eligibility for CSD benefits and count for WorkFirst participation.

WIOA paid work experience is considered employment for the purposes of the WorkFirst program and therefore must also be added in ACES 3G. WorkFirst staff will code WIA paid work experience participation under the PT or FT eJAS component code. As employment, there is no FLSA maximum hours for WIA paid work experience and staff will not need to enter actual hours of participation each month.

8.1.13 Verifying Job Starts - Policy in Practice

  1. When a Case Manager learns of a change in employment they:
    1. Require the participant to complete an IRP, review and update.
    2. If the participant has started a new job, determine whether the income has been coded in ACES 3G Income Screen. 
    3. If the income is not entered into the ACES 3G Income Screen: 
      1. Follow steps in the CSD Procedure Manual – Communication to Financial from Social Services so the income can be coded, and,
      2. Require the participant to provide proof of employment hours within 10 business days. Add to the participant's IRP "I agree to provide proof of the number of hours I work by [date].", and hand to or mail to the participant.
    4. If the income is coded but the CS or CE valid value code was used, the new job hours have not been verified.  Require the participant to provide proof of employment hours within 10 business days. Add to the participant's IRP "I agree to provide proof of the number of hours I work by [date]. " and hand to or mail to the participant. 
    5. Start the sanction process if a participant refuses to provide proof of employment hours as required.
  2. Once the Case Manager verifies employment, they must:
    1. Document in eJAS how the hours were verified sending any employment documents to the ECR.  If an employer verifies the statement by phone, document:
      1. The employment hours information.
      2. How they verified the hours.
      3. The date of the contact.
    2. Make any needed updates to the employment components and update the IRP, adding any additional stacked activities, see WFHB 3.3.1 Individual Responsibility Plan and Stacking Activities. 
    3. Update the participant’s eJAS employment screen 
    4. Inform Case Planner to update ACES 3G. CSD staff can find additional information in the CSD Procedure Manual – Communication to Financial from Social Services for additional information.
  3. The WorkFirst staff updates ACES 3G Earned Income Screen for the ongoing month and all historical months based on employment start date once WorkFirst staff have proof of employment hours, including:
    1. Adjusting wage information, as needed.
    2. Adjusting employment hours, as needed.
    3. Updating the verification valid value to document the type of proof that was obtained.
       

Resources

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