ACTION BULLETINS (PY 2005)

AB - # 54 DETERMINATION OF DATE OF PROGRAM EXIT

AB - # 54
Effective Date: July 1, 2005


ACTION BULLETIN


TO: All Adult, Dislocated Worker and Youth Program Providers

DATE: July 18, 2005

SUBJECT: Determination of Date of Program Exit


PURPOSE OF BULLETIN
The purpose of this bulletin is to provide an updated policy and procedure for determining the Date of Program Exit from any Workforce Investment Act (WIA) Title I programs for Adults, Dislocated Workers or Youth.

BACKGROUND
On April 15, 2005, the Employment and Training Administration (ETA) issued Training and Employment Guidance Letter 28-04 regarding the new Common Measures Policy. Portions of the guidance letter outlined the definition of program exit.

The guidance letter defines the term program exit:

“A participant does not receive a service funded by the program operator or funded by a partner program for 90 consecutive calendar days and is not scheduled for future services.”

The guidance letter defines what is NOT a service:

“The term service does not include:
· A determination of eligibility to participate in the program,
· Self-directed job search that does not result in a referral to a job,
· Services and activities specifically provided as follow-up services or regular contact with the participant or employer for purposes of obtaining information regarding his/her employment status, educational progress, need for additional services, or income support payments.

Program operators that use services provided by partner programs to extend the point of exit must have the ability to track partner program services.”

The guidance letter explains the retroactive component to determining program exit date:

“If a participant has not received any services funded by a program operator or a partner program for 90 consecutive calendar days and has no planned gap in service, the date of exit is applied retroactively to the last day on which the participant received a service funded by the program operator or partner program. The phrase “and not scheduled for future services”: does not apply to participants who voluntarily withdraw or dropout of the program.

The guidance letter also outlines a planned gap in services documented in the Individual Employment Plan (IEP):

“Participants should not be considered exited if there is a planned gap in service of greater than 90 days in one of the following circumstances: (1) delay before the beginning of training, (2) health/medical condition or providing care for a family member with a health/medical condition, (3) temporary move from the area that prevents the individual from participating in services.”

This methodology for making a determination of date of program exit is very different from the current procedure of the Alameda County Workforce Investment Board (ACWIB) which uses the “end of the quarter” exit strategy outlined by the State of California Compliance Management Team, and requires that the date of program exit be within 90 days of the last day of service, not the last day of service. This procedure is rescinded as of 6-30-05.

ACTION
Effective July 1, 2005, once a participant:
(1) Has completed all services funded by the program operator or a partner program, the Date of Program Exit is the last day of service; OR
(2) Has not received a service funded by the program operator or a partner program for 90 consecutive calendar days, and (3) has no planned gap in service, and (4) is not scheduled for future services, the Date of Program Exit is applied retroactively to the last day on which the participant received a service funded by the program operator or partner agency.


INFORMATION & INQUIRIES
Linda Slater
MIS Administrator
(510) 259-3802
Lslater@acgov.org


Date of Program Exit
Tips and Processes


Date of Program Exit
The program operator must ensure that the Date of Program Exit is the last day on which the participant received a service funded by the program operator or partner agency. The MIS exit form will be the official document to report the exit. The determination of exit date is based on the IEP and case notes and will be audited for compliance.

Determination and Documentation of Services
The program operator must ensure that “at least” one documented service is provided to a participant every 90 days while the participant actively participates in the program, or the program operator must exit the participant from the program retroactively to the last day of service. Documentation of service will consist of notations in the IEP and case notes in the file.

The program operator must be aware that the following are NOT considered active services:
· A determination of eligibility to participate in the program,
· Self-directed job search that does not result in a referral to a job,
· Services and activities specifically provided as follow-up services or regular contact with the participant or employer for purposes of obtaining information regarding his/her employment status, educational progress, need for additional services, or income support payments.

Active services are Staff-Assisted Core, Intensive and/or Training that require significant staff assistance. Active services following Intensive and/or training include, but are not limited to:
· Assistance with job search & placement, including career counseling or resume preparation
· Assistance with counseling regarding the workplace, like career ladders or salary negotiation
· Assistance with job referrals/leads
· Assistance with additional learning resources, like ESL
· Assistance with job development, including interviewing skills
· In person closing the case interview regarding follow-up services, with participant signature

Active services may be provided in a variety of ways: in person, over the telephone, via email, or by mail. The key is to document provision of an active service requiring significant staff-assistance at least once every 90 days, then upon determination of exit go back retroactively to the last day of active service and use that date as the Date of Program Exit.


Maximizing Local Area Performance
In order to maximize local area performance outcomes, ACWIB continues to promote the “end of the quarter” exit strategy by encouraging program operator to provide a service to the participant near the end of the quarter determined for exit.

Auto Exits
An estimated date of activity completion/exit is provided by the program operator at time of enrollment into an activity and is subsequently tracked in the MIS Job Training Automation (JTA) system. The system automatically exits participants whose estimated date of activity completion/exit exceeds 90 days. Program operators must ensure that all MIS paperwork related to active services is up-to-date and accurate to avoid unnecessary auto-exits. The ACWIB MIS department will supply rosters on a regular basis to let program operators know when participants are approaching their 90-day limit.

Planned Gap in Service
When a program operator knows that there will be a “planned gap in services of more than 90 days” they will document by explaining in the IEP and the case notes. They will also submit an enrollment/registration form that: (1) closes out all open activities, (2) enrolls the participant in activity code 83 – Planned Break in Services until the participant returns to enrollment. At that time the planned break in services activity is closed and the active services are reopened.