ACTION BULLETINS (PY 2005)

AB # 53 WIA SELF-SUFFICIENCY THRESHOLD

AB – #53
Effective Date: 07/01/2005


ACTION BULLETIN


TO: ONE STOP CAREER CENTER SITE MANAGERS

DATE: June 23, 2005

SUBJ: WIA SELF-SUFFICIENCY THRESHOLD
Alameda County Workforce Investment Area


Purpose of Bulletin

On May 12, 2005, the Alameda County Workforce Investment Board (WIB) approved a revised Self-sufficiency threshold of $24.10 per hour earned wages to apply in the determination of eligibility for Employed adult applicants requesting Intensive and/or Training services under Title IB of the Workforce Investment Act (WIA). This bulletin supercedes Action Bulletin #7 issued September 2000.

Citation

Workforce Investment Act (WIA) Section 134(d)(3)(a)(ii)
Congressional Federal Register 20 CFR Part 663.320

Background:

Per the Workforce Investment Act (WIA), the Local Workforce Investment Board (LWIB) is the designated body to set the self-sufficiency threshold, for EMPLOYED applicants, as one determination of eligibility for the provision of services under Title 1B of the Workforce Investment Act (WIA).

Since there are different local conditions that should be considered in this determination, the federal regulations provide maximum flexibility to states and local areas, requiring only that self-sufficiency means employment that pays at least the lower living standard income level (LLSIL). In June 2004, the LLSIL for a family of three equates to an hourly wage of $9.36.

ACWIB approached the determination from another perspective, using a maximum self-sufficiency hourly wage threshold. In September 2000, the Operations Committee of the LWIB adopted a self-sufficiency threshold of $21.94. Since then employed applicants whose hourly wage exceeded the threshold of $21.94 were not eligible for or in need of WIA funded services because they were, by definition, already earning a self-sufficiency wage.

By using a maximum threshold ACWIB providers can serve a greater number of employed applicants, either through standard enrollment in the One Stops, or through Employer customized training projects.

The majority of employed applicants come from employer customized training projects. Employees are incumbent workers requiring skills upgrade, career advancement, or layoff aversion. Sixty-eight (68) have been enrolled since 7-1-04, with an average hourly wage of $15.98. By setting a reasonable threshold, based on confirmed economic data, employers can include in a customized training project those working employees whose hourly rate of pay is at or below the threshold. This is good for the employer, the employee and the LWIA.
The self-sufficiency threshold is not intended to suggest to employers that they pay this wage to their employees. It’s use is to allow employers, whose workers make up to the threshold, the ability to take advantage of WIA funded services to improve the quality of life and career opportunities for their employees.

Incumbent workers, though not included in the performance measures for entered employment, wage gain/replacement, or retention are included in the entered employment with credential measure and are often very successful in assisting the LWIA in earning a positive attainment.

For employed applicants, age 18-65 years, coming through the One Stop Center system, the WIA employment and training programs mandate a universal access approach with tiered services requiring a determination of whether or not the customer is unable to obtain or retain employment at each tier before moving to the next tier. The system provides extensive Core services to WIA registrants. Employed applicants unable to obtain/retain employment leading to self-sufficiency, through Core services, will be those with one or more barriers to employment such as: poor work history; lack of education; basic skill deficient; and obsolete skills. Since 7-1-04 approximately 9% of the adult applicants are employed with an average hourly wage of $12.34.

The recommended $24.10 self-sufficiency threshold was determined by using a report called “The Bottom Line: Setting the Real Standard for Bay Area Working Families”.
Developed in 2003 by the United Way of the Bay Area in partnership with Dr. Diana Pearce of the Center for Women’s Welfare at the University of Washington, the National Economic Development and Law Center and Wider Opportunities for Women. The report focused on nine (9) counties in the San Francisco Bay Area. The report uses 2000 Census Data but excludes households and individuals who were elderly and/or disabled, as the Self-Sufficiency Standard measures income adequacy for “working age” families (18-65 years of age).

The report measures the ACTUAL cost of living on a countywide basis, including costs of transportation, taxes, childcare, housing, food and health care without benefit of public subsidies, such as public housing, Food Stamps, Medical or child care, or private/informal subsidies, such as free babysitting by a relative or friend, food provided by churches or local food banks, or shared housing. The report estimates the level of income necessary for a given family type – whether working or in transition to work – to be independent of welfare and/or other public and private subsidies.

The recommended Self-Sufficiency Standard of $24.10 for Alameda County (including the City of Oakland) is based on a family unit consisting of One Adult and Two Children (one infant, one school age). It equates to $4,242 a month, and $50,907 annually.

The report set self-sufficiency standards for various family configurations, but WIB staff felt the 3 member family configuration compared the best across standards. It is used by cities to set Living Wage standards for employer contractors, and by the Alameda County CalWORKs program when determining the wages required for eligibility for Targeted Assistance for Needy Families (TANF).

In the determination of eligibility for WIA services, a self-sufficiency threshold determination will not be made for adult customers who are:
1. Employed, but still receiving public assistance;
2. Not Employed; or
3. Disabled, whose income meets the Lower Living Standard Income Levels (LLSIL) but whose family income does not.

Therefore, both unemployed and under-employed customers with some or limited work experience can meet the self-sufficiency threshold for enrollment into WIA Intensive and/or Training services if such services are required to find self-sufficient employment.

Procedure

The WIA employment and training programs mandate a universal access one-stop system with a tiered approach to service delivery. When an employed registrant is unable to obtain or retain employment that leads to self-sufficiency through the Core (Self-Directed and/or Staff-Assisted) service levels and requires enrollment in the Intensive service level, documentation must be collected to prove the customer’s per hour earned wages, including regular overtime, is at or below $24.10 per hour prior to enrollment.

· Acceptable Documentation

Collection of one (1) of the following documents is required to establish that an employed low-income or dislocated worker registrant’s per hour earned wage, including regular overtime, is at or below the $24.10 self-sufficiency threshold on the date of enrollment into the Intensive service level.

1. A current pay stub showing per hour earned wages
2. A letter from employer substantiating per hour earn