Data Validation
Documentation for
Enrollment
Quick Reference
Guide
Data Validation for Enrollment Quick Reference Guide 8/14/13
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This guide follows the data validation documentation requirements, input screen- by- input
screen, as an Age and Income Application (eForms OPS002 or OPS003) is processed during
an enrollment. This guide compares the eForms data validation drop down menus with the
data validation requirements of the U.S. Department of Labor’s, Division of Older Worker
Programs,
Senior Community Service Employment Program Data Validation Handbook
,
revision 6 (February 2013). References to the
SCSEP Data Collection Handbook
(Revision 6
April 2010) are included.
This guide is designed to assist all Experience Works staff in interpretation of data validation
documentation requirements for the purpose of enrolling new applicants into the Senior
Community Services Employment Program. This is a quick reference guide that specifically
lists acceptable forms of data validation. There may be instances where data validation
documentation not specifically referenced in this guide is presented as evidence to satisfy a
data validation requirement. If a document not specifically listed in this guide is presented,
contact your supervisor for a ruling on acceptance of the document(s) presented. Your
supervisor will contact the Director of Training and Quality Assurance for a final ruling.
This guide does not cover all of the documentation required for enrollment. The following
documents are also required in addition to the data validation documents covered in this quick
guide:
•
I-9 form: This form is located in the Experience Works Employee Intranet under
“Forms” => “Participant Intake”. Training for correct use of the I-9 form can be found in
the Experience Works on-line University,
Employment Eligibility Verification – Form I-9
tutorial.
•
Income eligibility: Training to correctly determine participant income eligibility is located
in the Experience Works on-line University,
Determining Income Eligibility
tutorial. The
correct determination of income is guided through the Income Worksheet wizard in
eForms OPS002 and OPS003.
•
Federal Income Tax Withholding Form W4: This form is located in the Experience
Works Intranet under “Forms”=> “Participant Intake”. Instructions for filling out the form
are included in the form.
•
Participant Orientation Record: This form is located in the Experience Works Employee
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Table of Contents
Source Documentation Descriptions………..
3
Residence Address………...
5
Is Applicant Homeless………..
6
Is Applicant at risk of Homelessness……….
7
Date of birth………
8
Disability……….
9
Does Participant Have Limited English Proficiency……….
11
Employment Status………...
12
Did Participant Fail to Find Employment after Using WIA Title 1 Services……….
14
Veteran Status………...
15
Number in Family………..
16
Income – Type of Documentations Used to Verify………..
18
Applicant Assessment – Most In Need
Low Literacy Skills……….
20
Severe Disability………
21
Is Participant Frail……….
22
Is Participant Old Enough For Social Security Title II Benefits But Does Not Have
Enough Wage Credits to Qualify……….. …….
23
Low Employment Prospects………
24
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Source Documentation Descriptions
The following describes acceptable data validation documentation in very broad terms. These
descriptions are subject to interpretation. When possible use the forms of data validation listed for each data element contained in the eForms drop down menus. This will facilitate processing of the
application and remove a potential source of confusion due to individual interpretation by Experience Works staff.
SOURCE DOCUMENTATION
There are four categories of source documentation requirements:
• Official Documents or Business Records • Confirmation of Signature and Dates • Detailed Case Notes
• Participant or Third-Party Signed Attestation
1. Official Documents or Business Records
Official Documents or Business Records include the following four subcategories:
Government records – includes Social Security Administration records; immigration records; driver’s license; federal, state, or local government identification card; Veteran’s Administration records; Department of Defense records.
Medical records – includes actual medical records; physician’s statement; psychologists’ diagnosis; rehabilitation evaluation; certification from a medical professional; disability records; worker’s compensation records; vocational rehabilitation letter.
Grantee, sub-grantee, or host-agency business records – a broad category of documents meant to include records created in the normal course of business. This subcategory would include, but is not limited to: time-sheets, payroll records, written communications (letters, memos, faxes, email) to an external entity (for example, a letter from sub-grantee to host agency or vice versa; an email from host agency to participant; or a fax from host-agency to sub-grantee).
Other official or third-party business records – a broad category of documents meant to provide flexibility for grantees to use documents received from external entities (e.g. bank statements, payroll records, letters from employers) not explicitly listed above, yet that could clearly establish the facts being considered. Such documents could be received from the external entity directly or delivered from the participant or a third party. These documents are prepared by a disinterested party, are generally used by the entity in the course of its business, and are presumed to be reliable. This category also includes religious records, such as baptismal certificates or other religious documents that provide evidentiary information, such as date of birth.
Examples of Official Documents or Business Records that are listed for the data elements in the Data Validation Handbook references below are meant to be illustrative. Validators should use the guidance above to determine whether particular sources meet the standards of proof. For example, if a document is not on the list, but the type of information contained in the unlisted document and the circumstances under which the document was prepared are the same as those which are present on the documents that are listed, then such a document may be acceptable. Note, however, that official documents and business records do not automatically constitute sufficient support for a data element; they must be relevant and must encompass the specific requirements of the element at issue.
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For example:• A disability sticker issued by the Department of Motor Vehicles (DMV) is an official
document, but it does not support a determination that a participant is disabled unless the state DMV uses the SCSEP definition of disability.
• You can use official documents to establish family size to the extent that the documents are
relevant. A determination of a state or federal agency to award benefits to a SCSEP applicant is unlikely to be relevant to the issue of family size for SCSEP eligibility purposes unless the other agency uses the same definition of family that SCSEP uses. In most cases, you are more likely to use the facts found by the other agency, e.g., that the applicant is married and lives with his or her spouse and no other persons, than the legal conclusion the agency drew, because most programs have their own definitions of family and includable income. Even when you can use the facts from another agency's determination, you may have to determine that those facts remain true at the time you make your eligibility determination.
Since copies of documentation are acceptable (except when there is reasonable doubt as to their authenticity), it does not matter whether the copies are produced mechanically or electronically.
Therefore, faxed or scanned documents are allowed. See note on electronic documentation at the end of this section on page 5 for more information.
2. Confirmation of Signature and Dates
Confirmation of Signature and Dates is the simplest form of support. Validators will simply confirm that the relevant signature exists on the application.
Signatures that are produced from electronic signature pads are acceptable as long as there is a clear policy governing their use. See note on electronic documentation at the end of this section for more information.
3. Detailed Case Notes
Detailed Case Notes consist of the case worker’s own documentation of his or her activities. Case notes can be based on information derived in person or by telephone. Every case note used to validate data must include the following three foundation elements along with the specific facts being
documented:
• Case notes must include the name of the person who is the source of the information, his or
her phone number, and the person’s organization and title or relationship to the participant, whichever is appropriate. Depending on the circumstances, this could be an individual associated with the grantee, the employer, the host agency, or some other party.
Case notes must include the name or initials of the person making the note and must contain all relevant dates:
• the date on which the event occurred, where applicable, • the date on which the information was obtained, and • the date on which it was recorded, if different.
Case notes can be stored in any format, including hand-written notes, standardized forms, or electronic records (see note on electronic documentation at the end of this section for more information). No particular format is required as long as the information listed above is present. The term “detailed” does not correlate to length or amount of information, but instead recognizes that the case notes need to provide sufficient information so that a reasonable person could make a determination as to specific events or decisions.
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4. Participant or Third-Party Signed AttestationParticipant or Third-Party Signed Attestation is used when information is obtained directly from the participant or, when appropriate, a knowledgeable third party. U. S. Department of Labor has provided a form that can be used for all items for which signed attestation is permitted. Please note that the applicant’s signature on the participation form does not constitute self-attestation. Signed attestation suffices ONLY IF there is no evidence in the case file that contradicts the statements made through attestation.
Important notes: Except where specifically stated, when more than one category of source documentation requirement is listed for a data element, grantees and sub-grantees only have to provide a source document from one category. In addition, grantees and sub-grantees do not have to provide all the specific documents listed under the official documents and business records category. Instead, grantees and sub-grantees should provide the documents necessary to establish that the program requirements for the data element have been met; in some cases, one document will suffice; in other cases, more than one document will be needed.
Although the Data Validation (DV) rules permit the use of multiple data sources, a grantee is free to set higher standards or to otherwise limit the sources that its sub-grantee may use to fewer than those permitted in the Handbook. A grantee may wish to limit documentation to the most reliable sources feasible in order to ensure consistency among all grantees or to simplify the process of documentation for sub-grantee staff. If the grantee does establish higher standards, it should follow the rules in the Handbook for determining which elements pass or fail the official validation. It will have to keep separate notes to record when a sub-grantee has not complied with the grantee’s standards.
Electronic documentation
When a grantee uses electronic forms and signatures, the grantee must have a policy that describes the process for entering the data and the required signatures. The policy must specifically detail how and where in the case file records a validator can determine that the electronic signatures and dates are valid. This information must be updated and provided to validators for each annual Data Validation cycle.
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Data Validation Handbook page 43
NOTE: Validation of this data element is a two-step process:
(1) Validate State of mailing address/State of residence if different from mailing address; and
(2) Validate consistency with program requirements, i.e., participant must have documentable proof of in-state residence, or there must exist a cross-border agreement between the participant’s state of residence and the state in which the grantee operates; or the participant must be homeless and this has been validated..
Both requirements must be met.
OFFICIAL DOCUMENTS AND BUSINESS RECORDS:
Official records that substantiate the participant’s state of residence, including but not limited to: Approved cross-border or multi-state agreements; driver’s license or State, Federal or Tribal ID Card; home utility bill or other billing statement providing documentation of residence or mailing address (if different than address on license or ID); document from a public or private institution (independent living housing, Community Based Residential Facility or Assisted Living) or housing authority; official
government mail dated within the last 30 days; bank statement; Social Security Statement; rental agreement; homeowners or rental insurance policy or statement; voter registration card.
Data Collection Handbook Participant Form page 5
• If the applicant does not have a residence, try to obtain an address at which the applicant can
receive mail. The mailing address fields will be used to mail letters and the customer service survey.
• Be sure to enter the complete address exactly as you want it to appear on the envelope.
“County” will not be used for mailing. If you know the last address you have for the participant is wrong and you are unable to obtain the correct address, delete the street number and street name only. Leave the last known data in the other address fields. This will prevent surveys being mailed to the participant.
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Data Validation Handbook page 43
OFFICIAL DOCUMENTS OR BUSINESS RECORDS:
Official records that establish that the regulatory definition as explained in the Data Collection Handbook has been met are acceptable, including but not limited to:
Letter or written statement from director of shelter or institution providing temporary living
accommodations; written statement from an individual providing temporary residence; statement from a Social Service agency; statement from a Veteran’s hospital/rehab center.
OR
DETAILED CASE NOTES:
In addition to the standard requirements for all case notes, must also detail:
(1) how the participant’s living condition meets the regulatory definition as explained in the Data Collection Handbook, and
(2) how that determination was made.
OR
SIGNED ATTESTATION:
Participant signed self-attestation is acceptable.
Signed attestation from a third-party who has knowledge of the participant’s living condition is acceptable.
Data Collection Handbook Participant Form page 5
• Homeless means (1) an individual who lacks a fixed, regular, and adequate nighttime residence;
and (2) an individual who has a primary nighttime residence that is: (A) a supervised publicly or privately operated shelter designed to provide temporary living accommodations (including welfare hotels, congregate shelters, and transitional housing for the mentally ill); (B) an
institution that provides a temporary residence for individuals intended to be institutionalized; or (C) a public or private place not designed for, or ordinarily used as, a regular sleeping
accommodation for human beings.
• The most-in-need measure will count participants who are homeless or at risk of homelessness.
Is Applicant At Risk of Homelessness
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OFFICIAL DOCUMENTS OR BUSINESS RECORDS:Records that establish the participant is “at risk” for homelessness, including but not limited to: Eviction notice, letter from official at homeless shelter.
OR
DETAILED CASE NOTES:
In addition to the standard requirements for all case notes, must also detail that the participant meets the definition of “at risk” for homelessness.
For example, rent/mortgage unpaid or overdue; often borrows to pay rent/mortgage; real estate taxes unpaid or overdue; temporarily sharing space with family or friend; involuntarily moved several times in last year; credit history or background disqualifies from most rental/lease agreements; cannot pay rent/mortgage most months; frequently has unpaid or overdue electric/gas/water bills; evicted from a residence in the last 12 months; lived in a shelter during the past 12 months.
OR
SIGNED ATTESTATION:
Participant signed self-attestation.
Or, signed attestation from a third-party who has knowledge of the participant’s living situation.
Data Collection Handbook Participant Form page 5
• Being at risk for homelessness is considered along with actual homelessness as a single priority
for service and a single factor for the most-in-need measure. An individual may be either at risk for homelessness or homeless, but not both at once.
• At risk for homelessness means an individual is likely to become homeless and the individual
lacks the resources and support networks needed to obtain housing. The risk must be real and imminent. In some sense, anyone living below the poverty level may be at risk of homelessness. This requires a more specific and identifiable risk than just low income.
Date of Birth
Data Validation Handbook page 44
OFFICIAL DOCUMENTS OR BUSINESS RECORDS:Data Validation for Enrollment Quick Reference Guide 8/14/13
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birth certificate; DD-214, Report of Separation; driver’s license; marriage license or divorce decree; Federal, state or local identification card; passport; hospital record of birth; public assistance/social service records; school records or ID card; work permit; cross match with Department of Vital Statistics; tribal records; Social Security award letter; baptismal record.Data Collection Handbook Participant Form page 8
Since age is a SCSEP eligibility requirement, this information is required for all applicants.
Disability
Data Validation Handbook page 50
OFFICIAL DOCUMENTS OR BUSINESS RECORDS:Documentation should be an official government record or other official record that indicates that (1) a medical professional made a determination of disability and
(2) describe how the determination of disability meets the SCSEP regulatory definition as explained in the Data Collection Handbook, including but not limited to:
Receipt of Social Security Disability Insurance (SSDI), other Social Security Administration records; school records; sheltered workshop certification; social service records or referrals; community-based aging and disability organizations; social service agency record or referral; independent Living Center statement; letter from Group Home administrator.
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Note: Not all official documents will suffice to establish disability. For example, a state disabled parking sticker is an official document, but it does not establish disability for SCSEP purposes unless the state employs the SCSEP definition and standard of disability.Alternatively, certification from a medical professional or medical record that establish specific facts that meet the regulatory definition as explained in the Data Collection Handbook are acceptable, including but not limited to:
Letter from Drug or Alcohol rehabilitation agency; medical records; physician’s statement; psychologist’s diagnosis; rehabilitation evaluation; disability records; Veteran’s medical records; vocational rehabilitation letter; worker’s compensation record.
Data Collection Handbook Participant Form pages 40 & 41
The regulations define “disability” as: a condition attributable to mental or physical impairment, or a combination of mental and physical impairments, that results in substantial functional limitations in one or more of the following areas of major life activity: (A) self-care; (B) receptive and expressive
language; (C) learning; (D) mobility; (E) self-direction; (F) capacity for independent living; (G) economic self-sufficiency; (H) cognitive functioning; and (I) emotional adjustment.
• Disability is validated only if the participant actually is impaired at the time of enrollment. We
do not count as disabled an individual who merely has a history of impairment or is regarded as being impaired. The individual must have the impairment currently.
• Applicants must be informed that this information is voluntary and that the refusal to provide
their disability status or to produce documentation will have no effect on any decision to provide services to them.
• Documentation is required if the applicant is claiming status as a family of one due to
disability.
• Data validation is also required if this element is used for the most-in need measure.
Because disability is an Equal Opportunity item, a participant may self-report and decline to provide documentation. In that case, you will indicate, self-report,” and you will not receive most-in-need credit.
• The data validation requirement in no way prevents grantees from recruiting or enrolling
disabled participants. Indeed, the Older Americans Act requires grantees to give disabled participants priority of service. You must still allow participants to self-attest to disability, and you may not require them to provide documentation. The validation requirement only means that you will not get credit for the most-in-need measure if you do not obtain documentation.
• For disability to count for the most-in-need measure or to establish status as a family of one,
there must be medical documentation that meets the regulatory definition. If there has not been an official documentation of disability , you may use a doctor’s statement that satisfies the criteria: 1) a mental or physical impairment (or combination of impairments); 2) that results in substantial functional limitations; 3) in one or more of the nine listed areas of major life activity
The doctor does not have to use the word “disability”, but the statement must cover all three aspects of the definition. Grantees are not allowed to use their own judgment about whether a medical impairment exists and whether it substantially limits functioning in one or more areas.
• Social Security Disability, where there are objective standards and a formal medical
determination, is sufficient to establish disability. A DMV disability card or parking sticker by itself would not qualify unless the standard that is applied to issue the card meets SCSEP standard. In many states, parking stickers for handicapped parking are provided for reasons that fall short of the regulatory definition of disability.
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Does Participant Have Limited English Proficiency
Data Validation Handbook page 48
• Documentation for this element must be dated as of the time of enrollment. If there is
documentation of limited English proficiency as of a later date, it may be used for waiver purposes but not for validating the priority of service.
Additional notes regarding disability:
• Due to varying levels (percent) of disability, veteran’s disability documentation by itself is not
sufficient to validate disability. Additional validation documentation will be required to substantiate the disability.
• The receipt of Social Security Disability Insurance (SSDI) satisfies the SCSEP requirement for
disability because of the standard applied by the Social Security Administration. However, the VA disability determination provides an individualized rating that does not on its face satisfy the SCSEP requirement. You will need to obtain a letter from the applicant's physician stating whether the applicant has "a condition attributable to mental or physical impairment, or a combination of mental and physical impairments, that result in substantial functional limitations in one or more" of the nine areas of major life activity specified in the definition.
• The letters DI after an individual's SSN indicate that the individual is receiving or has received
Social Security Disability Insurance. The DI indicator appears on the individual's Medicare card and on correspondence from the Social Security Administration. The problem is that the DI indicator remains after the individual has reached the age of normal retirement and the SSDI has converted to regular retirement benefits. At that point, the DI indicator is not reliable evidence of either disability or the receipt of SSDI.
o Given the ambiguity of the DI indicator for many SCSEP applicants and participants, the better approach is to have the individual obtain documentation of disability and SSDI by requesting a benefit verification letter from the Social Security Administration. This can be done by phone at the time of initial application or recertification.
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OFFICIAL DOCUMENTS OR BUSINESS RECORDS:Official records that establish limited English proficiency are acceptable, including but not limited to: Results of literacy testing or standardized test results.
OR
DETAILED CASE NOTES:
In addition to the standard requirements for all case notes, must also explain: (1) that the participant has limited English proficiency,
(2) how assessment was made, e.g., participant appeared with an interpreter or directly communicated to case worker that she doesn’t speak English, and
(3) the date that assessment was made.
OR
SIGNED ATTESTATION:
Participant signed self-attestation or signed third-party attestation
Data Collection Handbook Participant Form pages 36 & 37
• The applicant has Limited English Proficiency (LEP) if they cannot speak or read English well
enough to fully participate in all aspects of the program.
• There is no substantive change in the definition. An LEP individual is one who does not speak
English as his or her primary language and who has a limited ability to read, speak, write, or understand English. If you are in doubt, ask the participant.
• Sub-grantees should use this information to provide language assistance to the participant. It
may also be used to send the customer satisfaction survey in the participant’s primary language.
• This priority of service is counted in the most-in-need measure.
Employment Status
Data Validation Handbook page 46
NOTE: Validation of this data element is a two-step process:
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(2) validate consistency with program requirements, i.e., that the applicant was unemployed at the point of enrollment.
Both requirements must be met for a to validate Employment Status OFFICIAL DOCUMENTS OR BUSINESS RECORDS:
Government records or other official records are acceptable to establish no employment at time of application, including but not limited to:
Record indicating firm date of separation from military service, unemployment insurance documents, notice of termination from employer.
OR
DETAILED CASE NOTES:
In addition to the standard requirements for all case notes, must also detail no employment at time of application.
OR
SIGNED ATTESTATION:
Participant signed self-attestation or signed attestation from a third-party who has knowledge of the participant’s employment status prior to participation is acceptable to establish no employment at time of application.
Data Collection Handbook Participant Form pages 11 & 12
The applicant is considered employed at the time of participation if the individual on the date of participation is one who, on the date participation occurs:
• Did any work at all as a paid employee (except the individual is NOT considered employed if: a)
he/she has received a notice of termination of employment or the employer has issued a Worker Adjustment and Retraining Notification (WARN) or other notice that the facility or enterprise will close; or b) he/she is currently on active military duty and has been provided with a firm date of separation from military service);
• Did any work at all in his/her own business, profession, or farm;
• Worked 15 hours or more as un unpaid worker in an enterprise operated by a member of the
family; or
• Was not working, but has a job or business from which he/she was temporarily absent because
of illness, bad weather, vacation, labor-management dispute, or personal reasons, whether or not paid by the employer for time off, and whether or not seeking another job.
• If the participant is a person who, although employed, has received notice of termination of
employment.
If the individual does not meet the definitions listed above, i.e., was not employed on the date of participation. The point of determination is the date of assignment to community service.
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Did Participant Fail to Find Employment after Using WIA
Title 1 Services
Data Validation Handbook page 52
NOTES:(1) Participants receiving only core services may be included or excluded based on enrollment rules of WIA program in your area. It is essential that the one-stop office confirm whether the participant was officially enrolled in WIA.
(2) Validation of this data element is a two-step process:
(a) validate with the WIA provider that the participant was enrolled in WIA Title I (adult services), and (b) validate that the participant was not employed subsequent to the WIA enrollment.
Unless there is documentation of enrollment in WIA, this this cannot be validated. OFFICIAL DOCUMENTS OR BUSINESS RECORDS:
To establish WIA Title I enrollment, official government records are acceptable, such as:
WIA correspondence with participant, written crosscheck request, or other program related document.
OR
DETAILED CASE NOTES:
In addition to the standard requirements for all case notes, to establish WIA Title I enrollment, case notes must also detail:
(1) that a crosscheck against WIA enrollment data was made, and (2) how it was made (e.g., phone call).
OR
SIGNED ATTESTATION:
To establish no employment at time of application, participant signed self-attestation is acceptable.
NOTE: WIA enrollment cannot be confirmed by self-attestation. It must be documented by an official document or case notes
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Data Collection Handbook Participant Form page 29
• Validate if the participant was enrolled in WIA Title I (adult services) prior to enrolling in SCSEP
and was unable to obtain employment before enrolling in SCSEP. If the participant reports having used the One-Stop system, you must call the WIA provider to determine whether the participant was actually enrolled in WIA. Mere registration by or use of the One-Stop center does not constitute registration in WIA.
• This priority of service is counted in the most-in-need measure. Data validation is required for
this element. WIA enrollment may be documented by a case note regarding the call to the One-Stop center. You may accept signed self-attestation as to the lack of employment.
Veteran Status
Data Validation Handbook page 50
OFFICIAL DOCUMENTS OR BUSINESS RECORDS:Official government document that verifies veteran status, such as: Military discharge papers; DD-214; cross-match with Veteran’s Database.
Veterans who do not have a DD-214 can provide a copy of military identification or other formal documentation provided by the Department of Veterans Affairs.
OR
DETAILED CASE NOTES:
For veterans discharged prior to 1950, case notes are acceptable in all cases. In addition to the standard requirements for all case notes, must detail
(1) the veteran status of the participant, including the branch served in and the approximate dates of service, and
(2) how that determination was made.
OR
SIGNED ATTESTATION:
For veterans discharged prior to 1950, participant signed self-attestation is acceptable in all cases
Data Collection Handbook Participant Form pages 39 & 40
• a. Validate if the individual is a person who served in the active U.S. military, naval, or air
service and who was discharged or released from such service under conditions other than dishonorable. Active service includes full-time duty in the National Guard or a Reserve component, other than full-time duty for training purposes.
• b. Validate if the individual is the spouse of any of the following:
o any veteran who died of a service-connected disability
o any member of the Armed Forces serving on active duty who, at the time of application for the priority, is listed in one or more of the following categories and has been so listed
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for a total of more than 90 days: (i) missing in action; (ii) captured in line of duty by a hostile force; or (iii) forcibly detained or interned in line of duty by a foreign government or powero any veteran who has a total disability resulting from a service-connected disability, as evaluated by the Department of Veterans Affairs; or
o any veteran who died while a disability was in existence
• No validation is required if neither (a) nor (b) applies
• Documentation is required. Grantees must verify the status of an individual as a veteran or
eligible spouse at the time of eligibility determination and subsequent enrollment in SCSEP. Eligibility can be verified using a variety of official documents, including, but not limited to:
o a DD 214 (issued following separation from active duty);
o an official notice issued by the VA that establishes entitlement to a disability rating or award of compensation to a qualified dependent; or
o an official notice issued by a State veterans’ service agency that acknowledges veterans’ status or spousal rights.
• To mitigate the burden of establishing proof-of-covered-person status, grantees also may
establish other means for verifying status, such as electronic communication with official databases such as those maintained by State Veterans’ service agencies, or property tax exemption databases in states that grant exemptions to certain types of veterans or other covered persons
• See TEGL 10-9 and the accompanying guidance, SCSEP and Veteran’s Priority of Service for
complete information about the grantee’s obligation under the Job for Veteran’s Act
• This priority of service is counted in the most-in-need measure
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Data Validation Handbook page 45
OFFICIAL DOCUMENTS OR BUSINESS RECORDS:To establish the number in family at the time of application, official government records or other official records are acceptable, including:
A HUD form; a lease; beneficiary forms (to substantiate a spouse for a family size of 2)
To establish a family-of-one is due to disability, official government or other official records are acceptable, including but not limited to:
Receipt of Social Security Disability Insurance (SSDI), other Social Security Administration records; school records; sheltered workshop certification; social service records or referrals
Alternatively, certification from a medical professional or medical record that establish specific facts that meet the regulatory definition as explained in the DC Handbook are acceptable, including but not limited to:
Letter from Drug or Alcohol rehabilitation agency; medical records; physician’s statement; psychologist’s diagnosis; rehabilitation evaluation; disability records; Veteran’s medical records; vocational rehabilitation letter; worker’s compensation record; Assessment results; verification from an aging, information and referral assistance (I&A or I&R)/case management program; Aging and
Disability Resource Center (ADRC); Independent Living Center (ILC); certification from a medical professional.
NOTES:
(1) It is required that the record of documents must be jointly signed by applicant and grantee interviewer.
(2) A ‘Disability Identification Card’ issued by the State is only acceptable if there is documentation that the medical standards used to issue the card meet the regulatory definition as explained in the Data Collection Handbook.
OR
DETAILED CASE NOTES:
In addition to the standard requirements for all case notes, to establish the number in family at the time of application, case notes must also detail:
(1) the number in family as defined by TEGL 12-06, and
(2) the rationale for accepting information from that individual without a signature.
NOTE: Case notes are not acceptable for establishing family-of-one is due to disability
OR
SIGNED ATTESTATION:
To establish the number in family at the time of application, signed attestation from a third-party who has knowledge of the participant’s number in family and reflects the living situation at time of application.
NOTE: Participant signed self-attestation is prohibited.
Signed attestation from a third-party (as opposed to a medical professional) is not acceptable in establishing family-of-one is due to disability
Data Collection Handbook Participant Form page 9
• Enter the number of individuals in the applicant’s family. A “family” is defined as husband, wife,
and dependent children; parent or guardian and dependent children; or husband and wife. (If the applicant is claimed as a dependent on someone else’s tax return, you must use the broader Current Population Survey (CPS) definition of family. Count only current family
members living together. Do not include deceased spouses or separated spouses who are living separately. In addition, an applicant with a disability may, at the option of the applicant, be treated as a family of one for income eligibility determination purposes. Family-of-one status does not extend to other members of the applicant’s family.
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Income-Type of Documents Used to Verify
Data Validation Handbook page 47
NOTE:Validation of this data element is a two-step process:
(1) validate that total includable family income was correctly calculated; and
(2) validate consistency with program requirements which stipulate that in order for a participant to be eligible, his or her family income must be less than or equal to 125% of the federal poverty line for the appropriate family size.
Both requirements must be met.
OFFICIAL DOCUMENTS OR BUSINESS RECORDS: Validation requires that both:
(1) official documents and business records establish includable income, and (2) attestation establishes that no other includable income exists.
Government records or other official records that establish the amount of income for the 6-month or 12-month look-back period are acceptable, including but not limited to:
If you are determining a Family of One Due to Disability check to make sure that the data validation documents you are presenting are those specifically annotated (for family-of-one due to disability).
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Pay stubs; Social Security Award letters; earning statements from employers; pension statements; bank statements showing interest.NOTE:
(1) It is required that there be a record or listing of all documents used to establish income and that this record be signed by the applicant and the interviewer. If the record contains a statement that the documents listed are the only sources of income for the applicant, the record satisfies the requirement for certification that the applicant has no other sources of income.
(2) Income tax returns can often be a helpful part of the documentation but they will rarely be sufficient in themselves to establish the amount of income for the 6-month or 12-month look-back period because they cover a complete calendar year. Additional documentation will usually be required to establish includable income for the entire look-back period.
OR
DETAILED CASE NOTES: (For Claims of Zero Income Only)
Case notes based on information from a knowledgeable third-party are acceptable to (1) explain how participant supported self if zero income is claimed, or
(2) document that no other includable income exists.
In addition to the standard requirements for all case notes, those case notes must also: (1) confirm zero income and/or that no other family income exists,
(2) explain how participant supported self, and (3) detail how that confirmation was made.
OR
SIGNED ATTESTATION: (For Claims of Zero Income Only)
If zero income is claimed, participant signed self-attestation or signed third-party attestation that explains how participant supported self is required.
Beyond establishing total includable family income through official documents and business records, participant signed self-attestation is also required to document that no other includable family income exist
Data Collection Handbook Participant Form pages 12 & 13
• You use the 12-month period prior to application or the 6-month.
• Family income is used to establish eligibility. It includes the income of current family members
identified. You may use any income worksheet you wish for calculating income. The worksheet must be retained in the file for all applicants. You must also retain documentation of all income sources.
• There are no exceptions for validating income. You must calculate the family income for the
12-month period prior to application or the 6-12-month period and annualize it. If the applicant is ineligible because the income in both look-back periods is not truly typical, the applicant will have to wait until the atypical income drops out of the look-back period and reapply at that time.
Pay special attention to these requirements as they often omitted or overlooked as part of the data validation required documentation:
• It is required that there be a record or listing of all documents used to establish income and
that this record be signed by the applicant and the interviewer. If the record contains a statement that the documents listed are the only sources of income for the applicant, the record satisfies the requirement for certification that the applicant has no other sources of income.
• Participant signed self-attestation is also required to document that no other includable
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Applicant Assessment – Most In Need
Low Literacy Skills
Data Validation Handbook page 49
NOTE:• Documentation for this element must be dated as of the time of enrollment. If there is
documentation of low literary skills as of a later date, it may be used for waiver purposes but not for validating the priority of service.
OFFICIAL DOCUMENTS OR BUSINESS RECORDS:
Official records that establish low literacy skills are acceptable, including but not limited to: Literacy testing; standardized test results.
OR
DETAILED CASE NOTES:
In addition to the standard requirements for all case notes, must also explain: (1) that the participant has low literacy skills,
(2) how that assessment was made, and (3) the date that assessment was made.
OR
SIGNED ATTESTATION:
Participant signed self-attestation or signed third-party attestation
Data Collection Handbook Participant Form page 38
• Check “yes” if the participant calculates or solves problems, reads, writes, or speaks English at
or below the 8th grade level or is unable to compute or solve problems, read, write, or speak at a level necessary to function on the job, in the individual’s family, or in society.
• The field for low literacy skills does not apply to participants who are LEP.
• Asking the participant about literacy is likely to embarrass the participant and is unlikely to
produce accurate information. As part of the IEP, you may wish to test all participants who have less than some college education. Standard tests include Test of Adult Basic Education
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local One-Stop center can administer any of these tests for you. You should not design your own test.• This priority of service is counted in the most-in-need measure.
Severe Disability
Data Validation Handbook page 59
OFFICIAL DOCUMENTS OR BUSINESS RECORDS:When a medical certification or statement is used as support, related documentation should be an official government record or other official record that
(1) indicates that a medical professional made a determination of disability and
(2) describes how the disability meets the regulatory definition as explained in the Data Collection Handbook, including but is not limited to:
medical records; certification from a medical professional; physician’s statement; psychologist’s diagnosis; rehabilitation evaluation; disability records; Veteran’s medical records; vocational rehabilitation letter; worker’s compensation record.
When a specific medical certification or statement is not used as support, official government or other official records may still be used as long as they establish how the disability meets the regulatory definition as explained in the Data Collection Handbook, including but not limited to:
Social Security Administration records; school records; sheltered workshop certification; social service records or referrals; community-based aging and disability organizations; social service; agency record or referral; Independent Living Center statement; letter from group home administrator; referral from Vocational Rehabilitation
NOTES:
(1) Medical professional certifications or statements must not merely conclude that a severe disability exists. Rather, they must clearly establish specific facts that meet the regulatory definition as explained in the DC Handbook.
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Data Collection Handbook Participant Form page 66
Severe disability means a severe, chronic disability attributable to mental or physical impairment, or a combination of mental and physical impairments, that (A) is likely to continue indefinitely, and (B) results in substantial functional limitation in 3 or more of the following areas of major life activity: (i) self-care, (ii) receptive and expressive language, (iii) learning, (iv) mobility, (v) self-direction, (vi) capacity for independent living, (vii) economic self-sufficiency.
• Severe disability is to be recorded in addition to disability. Each is counted separately for the
most-in-need measure.
• Severe disability must be documented by a physician.
Is Participant Frail
Data Validation Handbook page 60
OFFICIAL DOCUMENTS OR BUSINESS RECORDS:When a qualified medical or professional certification or statement is used as support, related documentation should be an official government or other official record that
(1) indicates that a qualified professional made a determination of frailty and
(2) describes how the disability meets the regulatory definition as explained in the Data Collection Handbook, including but is not limited to:
medical records; certification from a qualified professional; physician’s statement; psychologist’s diagnosis; rehabilitation evaluation; disability records; Veteran’s medical records; vocational rehabilitation letter; worker’s compensation record.
When a specific professional certification or statement is not used as support, official
government or other official records may still be used as long as they establish how the frailty meets the regulatory definition as explained in the Data Collection Handbook, including but not limited to:
Social Security Administration records; school records; sheltered workshop certification; social service records; document from a rehabilitation agency/organization to include a recent evaluation; social
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service agency record or referral; community-based aging and disability organizations; Independent Living Center statement; letter from group home administrator.NOTE: Receipt of SSDI is NOT sufficient to document frailty.
Data Collection Handbook Participant Form page 67
• Frail means that an individual 55 years of age or older is determined to be functionally impaired
because the individual:
(A) (i) is unable to perform at least two activities of daily living without substantial human assistance, including verbal reminding, physical cueing, or supervision; or (ii) at the option of the grantee, is unable to perform at least three such activities without such assistance; or
(B) due to a cognitive or other mental impairment, requires substantial supervision because the individual behaves in a manner that poses a serious health or safety hazard to him- or herself or to another individual.
• Frailty must be documented by a qualified professional.
Is Participant Old Enough For Social Security Title II
Benefits But Does Not Have Enough Wage Credits to
Qualify
Data Validation Handbook page 63
OFFICIAL DOCUMENTS OR BUSINESS RECORDS:Official government document that establishes that the participant has not worked in the U.S. for 40 quarters, including but not limited to:
Social Security Administration documents (e.g. Social Security Statement) or immigration records that show that participant has not been in the U.S. for 40 quarters. If immigration records are used, the relevance to this element must be established.
Data Collection Handbook Participant Form page 67
An individual may qualify for SS retirement benefits at age 62. If an individual is 62 or over but does not have sufficient wage credits to qualify for retirement benefits, check “yes.” This factor applies only if the
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participant is not monetarily eligible for Social Security. If the participant qualifies but chooses to delay receipt to increase the amount of benefits, check “no.”Low Employment Prospects
Data Validation Handbook page 53
NOTE:The following barriers may already have been successfully validated:
• Homeless,
• Limited English proficiency, • Low literacy skills
• Disability
If any were successfully validated, the validator would be able to automatically check “yes” for this data element IF the case file establishes that one of these barriers was relied on to establish low
employment prospects.
For all other barriers that are relied upon for this element, any of the following sources may be used. Regardless of the source used, the documentation must explain how the barrier result in the
participant’s having low employment prospects. Not all possible barriers will meet this standard. At risk of homelessness by itself does not meet the definition of the kinds of barriers that count for this factor. However, the underlying facts may support another barrier.
OFFICIAL DOCUMENTS OR BUSINESS RECORDS:
Official government records, medical records, or other official records that establish one of more significant barrier to employment exist, including but not limited to:
Receipt of Social Security Disability Insurance (SSDI), other Social Security Administration records, school records, sheltered workshop certification, social service records or referrals; Letter from director of shelter or institution providing temporary living accommodations, results of literacy testing,
standardized test results; certification from a medical professional or actual medical records.
OR
DETAILED CASE NOTES:
In addition to the standard requirements for all case notes, must also detail: (1) participant has one or more significant barrier to employment;
(2) how the determination was made that the condition described in the official case notes or attestation form contributes to low employment ,
(3) the source of the information, (4) the contact at the source, and
(5) the date that information was obtained.
OR
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Participant self-attestation that establishes one or more significant barrier to employment exists is acceptable, except for disability, severe disability and frail, which require a higher level ofdocumentation. Information on the attestation form should include identification of the situation itself and specific information which explains why the attester’s situation can be considered a significant employment barrier.
Data Collection Handbook Participant Form pages 43 & 44
There is no definition for this particular barrier to employment. However, the general rules for low employment prospects apply.
• For social or economic isolation, the case note must contain sufficient facts to establish both
that the area in which the participant resides is socially or economically isolated and that employment opportunities are limited in that area. Isolation in a rural area should be relatively easy to document. Isolation in an urban area may turn on whether there is a social infrastructure in the area (civic organizations, churches, government offices, etc), whether there is
transportation, and whether there is normal commercial and economic activity (stores, businesses, or industry).
• The area in which the participant resides may depend upon the transportation options available
to the participant and normal commuting patterns. For a city with good public transportation, the area could be the city or even surrounding towns. For one with no or very poor transportation, the area might be much more limited. The unemployment rate for the area could be used to establish that employment opportunities are limited there compared to less isolated areas. If there is no official unemployment rate for the area, you will need to determine whether the number of non-profit, government, and private sector entities in the area is insufficient to provide jobs for all residents of the area who want employment.
• As with many of the barriers to employment, you will need to develop the facts as best you can
and use your judgment. As long as the case note contains the facts upon which you rely and you apply the correct factors, there should be no problem.
References
• Experience Work’s Employee Intranet, eForms OPS002
• U.S. Department of Labor, Division of Older Worker Programs, Senior Community
Service Employment Program (SCSEP) Data Validation Handbook (Revision 6, February 2013), Section IV.1 and IV.2 – SCSEP Data Validation Instructions
• U.S. Department of Labor, Division of Adult Services, SCSEP Data Collection
Handbook (Revision 6, 4/19/10), Participant Form Guide
