8.3.4 - Version 1

8.3.4 Economic Self-Sufficiency

Effective date: July 1, 2017 - June 27, 2018

8.3.4.1 Background

One of WIOA's main purposes is to increase economic self-sufficiency (ESS) through workforce development activities.¹

The U.S. Department of Labor expects local workforce development areas to follow a process for determining ESS standards for Adult and Dislocated Worker Program participants.² The State has the discretion to develop and adopt a method for calculating ESS standards that addresses the income needs of households based on household size, ages of household members, and geographic location within the state.³ The DWD-DET, in turn, adopted a uniform approach for defining and determining ESS that is to be used statewide for Adult and Dislocated Worker Program participants.

8.3.4.2 Definition of Economic Self-Sufficiency

For purposes of the Adult and Dislocated Worker Programs, the DWD-DET defines "economic self-sufficiency" as the minimum amount of income required for a household⁴ to meet its most basic expenses, without public or private assistance. Under WIOA, this amount must always be equal to or greater than 100 percent of the Lower Living Standard Income Level (LLSIL), by family size.⁵

In this definition, "income" means income earned from employment and includes:⁶

Wages, salaries, tips, commissions and other taxable employee pay
Net earnings from self-employment
Note: For multi-member households, income earned by members below the age of 18 should not be included.

Earned income is NOT:

Interest or dividends
Retirement income
Social Security
Unemployment benefits
Alimony / spousal maintenance
Child support

8.3.4.3 Wisconsin's WIOA Title I ESS Standard

State Policy Criteria

To be considered economically self-sufficient, an Adult or Dislocated Worker Program participant must:

have individual income that meets or exceeds the ESS level for a single adult household;
AND
if part of a multi-member household, have household income that meets or exceeds the ESS level based on the household composition.

A Dislocated Worker Program participant must meet the above criteria and one of the following:

have individual income that meets or exceeds 80 percent of the dislocation wage;
OR
have individual income that meets or exceeds the 75th percentile of wages for all occupations in the county of residence.⁷

Method

The DWD-DET adopted a method for calculating economic self-sufficiency levels that uses credible federal and state datasets addressing typical costs for housing, transportation, food, health care, childcare, taxes, and other miscellaneous costs.⁸ This method produces the "ESS Standard," which is a statewide dataset that accounts for household composition (i.e. the number and ages of people in a household) and county of residence when determining the income needed to meet basic household costs. The DWD-DET will ensure that the ESS Standard is refreshed every three years to represent changes in costs of basic needs.

The ESS Calculator

The ESS Calculator is accessible in ASSET through the "Manage Planning Tools" menu item. To create a new ESS calculation click "Add Self-sufficiency" and complete the required fields. Career planners have 24 hours to make changes before the calculations are no longer editable. A training video is available for the ESS Calculator.

Career planners must use the DWD-DET's ESS Calculator to establish whether a program participant's ESS level. The career planner enters the participant's information into the calculator based on the field prompts. From there, the ESS Calculator provides the following output:

A matrix identifying:
- the target ESS level for each of the DWD-DET's policy criteria;
- the amount entered into the ESS Calculator for each of the DWD-DET's policy criteria; and
- whether the target ESS level for each of the DWD-DET policy criteria were met.
A determination of whether the participant is considered economically self-sufficient based on DWD-DET's policy criteria.

The participant is not required to provide documentation of household income used for the calculation. Self-reporting by the participant is an acceptable source of the information. Since the information provided may be used as a basis to approve or deny training services, the career planner must ensure that the self-reported information is documented in writing with a signed attestation by the participant that the information is true and correct. This may be accomplished by including the income and household composition information in the local workforce area's program intake form or having the participant sign a printout of the ESS Calculator's results.

8.3.4.4 Requirements for Applying the ESS Standard

There are two times when career planners are required to use the ESS Calculator — when enrolling a new participant and to justify placing a participant into training.

Career planners must perform an ESS calculation for all Adult and Dislocated Worker Program participants as part of program registration and enrollment. When creating a new ESS calculation in ASSET, select the checkbox "Status at Enrollment."

Note: Self-sufficiency is not part of the program eligibility criteria. Program enrollment cannot be denied to individuals who are considered economically self-sufficient, if they meet the program eligibility criteria.
A participant can only receive WIOA Title I funded training if s/he meets all requirements of Section 680.210 of the DOL WIOA Final Rule, which include:
- the individual is not considered economically self-sufficient and needs training to obtain economic self-sufficiency
  OR
- the individual is considered economically self-sufficient but is unlikely to remain so without training.⁹
When creating a new ESS calculation in ASSET, select the checkbox "Training."
- Note: There are a number of situations in which training services may be appropriate for participants who are self-sufficient at the time training services are provided. Examples include participants who:
  - will soon be laid off from employment;
  - are expecting a child;
  - have a spouse who will need to stop working (e.g., because of a serious illness or the need to care for an aging parent or a child with an illness/disability).
  The career planner must document in an ASSET case note the upcoming circumstances that justify the need for training. Self-reporting by the participant is an acceptable source of the information.

8.3.4.5 Other Ways to Use the ESS Standard

Career planners are not required to calculate and use ESS except upon enrollment of a participant or to justify training. However, they may wish to use it in a variety of other ways to increase the quality of services provided to program participants. Examples include:

identifying occupations that would likely result in economic self-sufficiency using county-level occupational wage data;
measuring progress for participants embarking on a career pathway; and
determining whether a participant has met the program goal of securing employment resulting in economic self-sufficiency.

¹ WIOA Sec. 2(6)
² TEGL 03-15, p. 6
³ WIOA Section 134 (a)(3)(A)(xii); 20 CFR § 682.210(p)
⁴ The DWD-DET does not define "household" for purposes of assessing economic self-sufficiency. Career planners are to determine what constitutes a household on a case by case basis, to best address financial responsibilities the participant may have for others (e.g., children and other family members who may not live with the participant full time).
⁵ 82 FR 23595
⁶ DWD-DET is adopting the "earned income" definition used by the IRS, https://www.irs.gov/credits-deductions/individuals/earned-income-tax-credit/earned-income
⁷ The 75^th percentile is calculated as part of the DWD-DET's Occupational Employment and Wage Estimates.
⁸ DWD-DET procured with the University of Washington an ESS standard for Wisconsin. More information about the University of Washington's work on this topic can be accessed at http://www.selfsufficiencystandard.org/node/3

⁹ 20 CFR 680.210