2. Employment & Training
3. Partners
4. WIOA Title I-A & I-B
5. Policy & Procedure Manual
6. Previous Policy - 8.3.4

8.3.4 Economic Self-Sufficiency

Effective date: October 24, 2019 - September 30, 2024

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 requires local workforce development areas to follow a process for determining ESS for Adult Program and Dislocated Worker Program participants.² Each state has the discretion to develop and adopt a method for calculating ESS that addresses the income needs of households based on household composition and geographic location within the state.³ Accordingly, DWD-DET adopted a standard for defining and determining ESS that is to be used statewide for the Adult Program and Dislocated Worker Program.

DWD-DET's standard takes into account the minimum amount of income required for a household⁴ to meet its basic expenses at a minimally adequate level, without public or private assistance. Under WIOA, this amount must always be equal to or greater than 100 percent of the most current Lower Living Standard Income Level (LLSIL),⁵ by household size.⁶

DWD-DET's ESS Standard for the Adult Program & the Dislocated Worker Program

Definition of Economic Self-Sufficiency

For the Adult Program, participants are considered economically self-sufficient if they:

• have individual income that meets or exceeds 125 percent of the ESS level for a single adult household in their county of residence;⁷
• have household income that meets or exceeds 125 percent of the ESS level for their household composition in their county of residence;⁸
• AND
• have household income that meets or exceeds the LLSIL for their household⁹ size.

For the Dislocated Worker Program, participants are considered economically self-sufficient if they meet all of the above criteria and one of the following:

• have an individual income that meets or exceeds 80 percent of their dislocation wage;¹⁰
• OR
• have an individual income that meets or exceeds the 75^th percentile of wages for all occupations in their county of residence.¹¹

The ESS Calculator

DWD-DET developed a calculator that career planners must use to establish whether individuals they serve are economically self-sufficient according to the ESS definition. The career planners' ESS calculator is accessible in the CEPT application, through the "Self-sufficiency" widget.

To perform a calculation, the career planner either enters an individual's current income and other information into the calculator based on the field prompts for the applicable program or can use information from a calculation that the participant completed in My JCW.

Note: When performing an ESS calculation for a participant whose income varies (e.g., from week to week or month to month), the career planner must average the participant's income for the period the career planner feels best captures the individual'''s current circumstances. Additionally, it is DWD-DET's intent that the ESS calculation determines if a participant is economically self-sufficient without having to work multiple jobs. If a participant holds more than one part- or full-time job, the career planner must only use the income from the individual's highest-paying job to perform the ESS calculation.

The calculator (1) generates results based on the criteria outlined in the definition of Economic Self-sufficiency and (2) provides a breakdown of monthly income, expenses and possible tax credits for the ESS level of a household with the same household composition and geographic location.

To create a new ESS calculation in CEPT, click "Add" and complete the required fields. Career planners have 24 hours to make changes to content in the fields before the calculation is no longer editable. To use information from a calculation that the participant completed in My JCW, open a shared calculation in CEPT and click "Accept." If a career planner determines that the calculation should not be accepted, click "Reject" and provide a reason for rejecting the calculation.

When a career planner creates an ESS calculation, a case note automatically populates in ASSET, so the career planner does not need to manually create an ASSET case note. Career planners are able to modify the title and body of the case note through the CEPT ESS calculator.

The individual is to self-report information for the ESS calculation and attest to the information's accuracy in one of the following ways:

• by accepting an ESS calculation that the career planner created in CEPT, through the individual's My JCW account;
• by sharing a calculation with the career planner that the individual completed in My JCW;
• OR
• by signing a printout of the ESS calculator's results after one is created in CEPT.

If a career planner needs to perform an ESS calculation for a participant who resides in a county bordering Wisconsin, the career planner must find the Wisconsin county most equivalent to the border county by using the ESS Guidance: Bordering Counties tool.¹² If the participant's state and county of residence do not appear in the dropdown list, email the participant's state and county of residence and DWD-DET will provide the most equivalent Wisconsin county to use for the participant's ESS calculation.

Requirements for Applying the ESS Standard

DWD-DET requires career planners to perform an ESS calculation in the CEPT "Self-sufficiency" widget after an individual has been found eligible for the Adult Program or the Dislocated Worker Program.¹³ The calculation must be completed within 30 days of the Actual Close Date of an Eligibility Determination service. This calculation is valid for the participant's entire period of participation.

Participants co-enrolled in the Adult Program and Dislocated Worker Program only need one ESS calculation; however, DWD-DET requires career planners to use the Dislocated Worker Program ESS criteria for co-enrolled individuals. If an Adult Program participant is subsequently co-enrolled in the Dislocated Worker Program, the career planner must perform a new ESS calculation in CEPT using the Dislocated Worker Program ESS criteria.

ESS and Training

Economic self-sufficiency is an important component of training eligibility determinations, although it is not the only criterion that must be considered when deciding if participants are eligible to receive WIOA Adult Program- or Dislocated Worker Program-funded training.

A participant may ultimately be determined eligible for program-funded training if s/he:

• is not considered economically self-sufficient and needs training to obtain economic self-sufficiency;
• OR
• is considered economically self-sufficient but is unlikely to remain so without training.¹⁴

Note: If a participant can obtain or retain economic self-sufficiency through career services only, training is not approvable.¹⁵

The career planner must use the results from the CEPT "Self-sufficiency" widget to determine whether the participant is considered economically self-sufficient for purposes of receiving program-funded training.

A participant who has been approved for training will not lose eligibility for training if s/he becomes economically self-sufficient later in his or her period of participation.

Participants Expected to Lose ESS

There are two instances when a career planner may approve program-funded training even though the participant is considered economically self-sufficient:

1. the participant is working but has received a notice of termination or layoff;
2. OR
2. the participant is expected to lose economic self-sufficiency within six months (e.g., expecting a child, spouse will need to stop working due to illness or to care for child or aging parent).¹⁶

For participants in one of these two situations, career planners must perform an initial ESS calculation with current information. To support program-funded training, the career planner must also perform another ESS calculation in CEPT that reflects the upcoming change(s) that will cause the participant to lose economic self-sufficiency and add a comment to the case note the CEPT system automatically generates to describe the anticipated change in circumstances. The participant could also begin the initial and/or subsequent calculation(s) through the Self-sufficiency Calculator in My JCW and share the calculation(s) with the career planner.

Reassessing ESS for Participants Whose Circumstances Have Changed

If a participant who was economically self-sufficient when the ESS calculation was initially performed has a change in income, household composition, or county of residence during the Title I program period of participation, the career planner or participant may perform a new ESS calculation. Subsequent calculations that demonstrate the loss of economic self-sufficiency may be used to support program-funded training and are valid for the remainder of the participant's Title I period of participation. If a new ESS calculation is performed to support program-funded training, the career planner must add a comment to the case note the CEPT system automatically generates. This comment must describe the change in the participant's circumstances that led to the new calculation being performed.

The career planner may wish to perform a new ESS calculation as an informational tool, even if a participant is not interested in training.

Other Ways to Use the ESS Standard

Career planners may wish to use ESS calculations in a variety of other ways to increase the quality of services provided under the Adult Program and Dislocated Worker Program. 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;
• determining whether a participant has met the program goal of securing employment resulting in economic self-sufficiency;
• and
• using the breakdown of typical basic monthly expenses from the ESS calculator results to assist an individual with budgeting.

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• ¹ WIOA Sec. 2(6)
• ² TEGL 03-15, p. 6
• ³ WIOA Sec. 134(a)(3)(A)(xii); 20 CFR § 682.210(p)
• ⁴ DWD-DET does not define "household" for purposes of assessing economic self-sufficiency. Career planners are to determine what constitutes an individual's household on a case by case basis, to best address financial responsibilities the individual may have for others (e.g., children and other family members who may not live with the participant full time).
• ⁵ 82 FR 23596
• ⁶LLSIL uses the term "family," however, for purposes of ESS determinations only, career planners are to use household size instead of the potentially stricter definition of "family." The foundation for DWD-DET's ESS standard is household composition, therefore, use of "family" may not allow for equal comparison between the various criteria used in its definition of economic self-sufficiency.
• ⁷ In 2016, DWD-DET contracted with the University of Washington to create an initial statewide data set and report to determine the income needed to cover an ordinary household's basic needs (aka its ESS level), taking into account household composition and county of residence. The data comes from federal and state sources. DWD-DET plans to update the data set approximately every three years to reflect changes in costs of basic needs. More information about the University of Washington's work on this topic can be accessed at http://www.selfsufficiencystandard.org/node/3.
• ⁸ See footnote 7.
• ⁹ See footnote 6.
• ¹⁰ DWD-DET uses 80 percent, consistent with the Trade Adjustment Assistance Program's definition for "suitable employment," at 20 CFR § 617.22(a)(1). The intent of this ESS criterion is to address dislocated workers who are accustomed to earning wages that exceed 125 percent of the ESS level.
• ¹¹ The 75^th percentile is calculated as part of DWD-DET's Occupational Employment and Wage Estimates. The intent of this ESS criterion is to address dislocated workers who are accustomed to earning wages that exceed 125 percent of the ESS level and who are overall high wage earners within their county of residence.
• ¹² DWD-DET will update the data set for the ESS Guidance: Bordering Counties tool approximately every three years to reflect changes in costs of living.
• ¹³ Self-sufficiency is determined after program eligibility; it is not part of the Adult Program or the Dislocated Worker Program eligibility criteria.
• ¹⁴ 20 CFR § 680.210 states that participants are eligible for program-funded training if, among other things, they are "unlikely or unable to obtain or retain employment that leads to wages comparable to or higher than wages from previous employment" without training. DWD-DET interprets this language as only applying to dislocated workers. DWD-DET's ESS definition addresses this language by allowing a higher level for economic self-sufficiency for dislocated workers.
• ¹⁵ 20 CFR § 680.210(a)(1)
• ¹⁶ DWD-DET has determined that six months is a reasonable amount of time to consider future changes that could cause a participant to lose self-sufficiency.