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Local Operating Procedures
Building a Foundation
22
Developing Local Procedures
• What are the governing authorities for the Welfare Transition (WT) program ?
– Federal Law
• Code of Federal Register (CFR)
– State Law
• Florida Statutes (F.S.)
• Florida Administrative Code (FAC)
• State Plan
– State guidance
33
Federal Law
• Federal Law
– Provides general parameters and guidelines under which states must operate different programs
• For the WT program, it is 45 CFR
– It also provides the minimum requirements for program elements
44
State Law
• State Law
– Uses federal requirements to set more specific standards and guidelines
– It lays the foundation for program administration
– It can also be more restrictive than federal law
55
State Guidance
• State Guidance
– Uses State Law to provide more detailed direction and instruction relative to the program
– References both federal and state requirements
• Can be more restrictive than federal or State law
6
Local Operating Procedures
• We often use the analogy that work activities are like a house in the WT program:
– Core activities serve as the base of the house
• They can stand alone
• Don’t need help to hold them up
– Core plus serve as the roof of the house
• Need the base (core) activities to hold them up
• If work activities are the program’s house, the LOP is the foundation on which it is laid
7
Local Operating Procedures
1. Job Skills Training
2. Education Directly Related to Employment++
3. Satisfactory Attendance HS/GED++
1. Unsubsidized Employment
2. Subsidized Private Emp.
3. Subsidized Public Emp.
4. On-the-Job Training
5. Work Experience
6. Job Search/Job Readiness Assistance
7. Community Service
8. Vocational Education and Training
9. Providing Childcare
++Core for teen parents without a high school diploma/GED
Local Operating Procedures
88
Local Operating Procedures
• Think of your RWB as another layer of the governing process
– Will what works for one region work for all other regions?
– Will processes that work for a large city also work for a rural area?
– Are all participants and their situations the same?
9
Local Operating Procedures
• What issues might a rural area be dealing with that a big city may not encounter?
– Transportation
• No access to public transportation
• No access to taxis
• No access to shuttles
• No access to close neighbors with a vehicle
10
Local Operating Procedures
• Transportation
– Do all case managers know what’s allowed?
• Are transportation deferrals allowed in your region?
– If so, under what circumstances?
• Is there a limit on how long a participant can be deferred due to transportation issues?
– If so, what is that duration?
– What steps must the case manager take to try to eliminate the barrier?
1111
Local Operating Procedures
• Why do we need LOPs?
– They provide strict and specific program instruction
– They hold up the integrity of the region’s processes
– They are written instruction on how the region runs its programs
– They eliminate process confusion
1212
Local Operating Procedures
• Why do we need LOPs?
– They are written documentation in the event of
• A request for supervisory review of a case
• A fair hearing with Department of Children and Families
• A grievance
• A law suit
1313
Supervisory Review
– Participants may request a supervisory review of their case if
• They feel their case is not being handled appropriately
• They feel they were treated unfairly
• They feel that they were unjustly denied a service
1414
Fair Hearing
• A participant may request a fair hearing
– If they feel action was taken on their case inappropriately
• Sanction
• Termination of services due to a sanction
1515
Local Operating Procedures
• Grievance
– A participant may file a grievance if (s)he feels
• Discriminated against
– Race or Ethnicity
– Age
– gender
• Treated unfairly
• Is not satisfied with the results of a fair hearing
1616
Local Operating Procedures
• Where do we start?
– Look at the program from beginning to end
• From applicant to transitional
• What program processes need to have LOPs?
• For which program elements am I requiring every case manager to follow the same rules?
1717
Local Operating Procedures
• Work Registration
• Initial Assessment
• Individual Responsibility Plan (IRP)
• Work Activities
• Documenting Hours of Participation
• Support Services
• Good Cause
• Domestic Violence
1818
Local Operating Procedures
• Work Registration
– Design a customer flow process
• How do you want applicants to flow from the front-desk through work registration?
• Think of every possible scenario and how staff should help applicants
• While it may not be possible to plan for all scenarios, LOPs provide a reference and guidance for program processes
1919
Local Operating Procedures
• Work Registration
– Recommended elements for the LOP
• What must the applicant complete for the work registration process to be successfully completed?
– Orientation/Overview
– Workshops
– Applicant job search
– Job matching
– Up-Front Diversion Screening process for appropriate candidates
2020
Local Operating Procedures
– It should also include:
• The process for medically incapacitated individuals who cannot complete work registration
• When to provide support services to individuals who need services to complete work registration
2121
Local Operating Procedures
• Initial Assessment
– Your initial assessment LOP should identify:
• The initial assessment tool program staff use
• How the tool assesses
– Work history
– Skills
– Employability
• This could be a locally developed form or a combination of forms and standardized tests like the TABE
2222
Local Operating Procedures
• Initial Assessment Tool
– How do you know when it was completed?
• Was it dated by the program participant?
– How do you know if it was reviewed?
• Was it dated by the program staff?
• Are any elements missing or left blank?
2323
Local Operating Procedures
• Initial Assessment
– The LOP should also include:
• When supplemental assessments may be needed
• Assessing for hidden disabilities
– Is this contracted out or a preliminary in-house assessment?
• Assessing for possible mental health and substance abuse issues
• Assessing for possible domestic violence and need for services
– Are these general questionnaires?
2424
Local Operating Procedures
• Individual Responsibility Plan (IRP)
– The LOP for IRPs could include:
• The process for developing the IRP
• When it must be completed
• How often the steps-to-sufficiency must be updated and signed
• The tool the RWB uses
• IRP Requirements
25
Local Operating Procedures
– When must staff initiate the IRP?
– Who is required to sign the IRP?
– What must be included on the IRP
• Employment goals
• Educational goals
• Needs and Barriers
• Steps to Self Sufficiency
25
2626
Local Operating Procedures
• Individual Responsibility Plan
– It should also include:
• How often the plan should be updated?
– Is the full plan updated or only the steps to self-sufficiency?
• Under what circumstances must the full plan be updated?
• Under what circumstances must the steps be updated?
– Provide examples and scenarios
– Provide a template to make it easier for staff to follow
2727
Local Operating Procedures
• Documentation
– Your documentation LOP should include:
• How often documentation must be collected
– Weekly, bi-weekly
• Who must sign documentation for
– On-site job search
– Work sites
– Education time sheets
2828
Local Operating Procedures
• Documentation
– It should also include:
• What information is required when a collateral contact is made
– What forms are acceptable for collateral contacts
• Data entry requirements
– Documentation must be received prior to entering data into the system
– Who is responsible for entering data in the system
– Deadline for entering data into the system once information has been received
2929
Local Operating Procedures
• Support Services
– Does your support services LOP include:
• Processes for providing services to
– Applicants
– Mandatory participants
– Transitional customers
• Is transportation provided based on
– Mileage and participation
– Participation only
3030
Local Operating Procedures
• Support Services
– It should also include:
• Processes for providing services to those completing alternative activities (non-traditional activities)
– Attending doctor’s appointments
– Physical therapy
– Counseling sessions
3131
Local Operating Procedures
• Good Cause
– Does your good cause LOP include:
• What is good cause for noncompliance
• When documentation must be provided to support good cause
• The appropriate use of excused absences based on good cause
• The appropriate steps to take with the customer if good cause does not exist
3232
Local Operating Procedures
• Domestic Violence
– Does your domestic violence LOP include:
• What staff must do if someone self-discloses
• Where to refer the participant if (s)he is requesting domestic violence services
– Is there a contracted entity in-house?
– Is it out in the community?
3333
Local Operating Procedures
• Domestic Violence
– Your domestic violence plan should also include:
• What should be included in the participant’s safety plan
• What steps must be taken to ensure confidentiality
• What must be included in the system
– To learn more about domestic violence requirements for Florida’s WT program, click here
3434
Local Operating Procedures
Questions?
Please contact the Welfare Transition Team
at 866-352-2345.
An equal opportunity employer/program. Auxiliary aids and services are available upon request to An equal opportunity employer/program. Auxiliary aids and services are available upon request to individuals with disabilities. All voice telephone numbers on this document may be reached by individuals with disabilities. All voice telephone numbers on this document may be reached by
persons using TTY/TDD equipment via Florida Relay Service at 711.persons using TTY/TDD equipment via Florida Relay Service at 711.