2. Employment & Training
3. Partners
4. WIOA Title I-A & I-B
5. Policy & Procedure Manual
6. Previous Policy 12.2

WIOA Title I-A & I-B Policy & Procedure Manual
Ch. 12) File Documentation

12.2 Requirements

Effective date: September 1, 2020 to September 30, 2020

Local WDBs must establish eligibility and verify other participant data through an examination of documents and/or other information. This can happen in a variety of ways:

12.2.1 Paper Documentation

Paper documentation consists of records, certificates, documents, identification cards, and other items, some of which may be photocopied and included in the participant's file. Source documents include documents issued by a governmental entity (e.g., driver's license, library card) and private documents (e.g., utility bills, paycheck stubs, or termination notices). Other evidence can be verified through completion of document/verbal verification forms, signed self-attestation/participant statements, and/or the local WIOA application form.

Written statements from governmental, educational, judicial, social services, or other appropriate sources may also be used to document certain eligibility criteria.

12.2.2 Verbal Verification

Career planners may document certain data elements through verbal contact with the same resources that could provide written statements. In documenting verbal contact, the following information must be included:

1. Date of contact;
2. Agency contacted, including address and phone number;
3. Person contacted;
4. All required information related to the data element, ensuring that the potential participant's name is noted; and
5. Signature of person making contact (career planner).

Verbal verifications may be made in-person, via telephone, or through other means of direct contact and must be documented in the participant's file using either the Verbal Verification Form attached to this policy or other means of documentation developed locally, that satisfy the requirements above.

12.2.3 Self-Attestation / Participant Statement

For much of the information collected during the registration process, the participant can self-attest to the data.

Self-attestation must be allowed for any and all data elements for which it is allowable; career planners must work with each individual to use the easiest means of documentation possible for that person. Local WDBs and/or service providers may not establish additional documentation requirements that could create artificial barriers to program participation for individuals with barriers to employment/education.

Key requirements for an acceptable self-attestation/participant statement¹ are:

1. the individual identifies their status for permitted elements; and
2. the individual signs and dates a written form attesting to this self-identification.

The form and signature can be the local WIOA application form, WIOA registration form (printed ASSET Manage Programs screens), or any other form/statement that satisfies the requirements above. Self-attestation/participant statements submitted through electronic means and containing electronic signatures are acceptable (e.g., emails, CEPT application, etc.)²

12.2.4 Automated System Support for Employment and Training (ASSET)

Content coming soon.

12.2.5 Case Notes

Case notes refer to either paper or online statements, primarily captured in ASSET Manage Customer Notes, made by the career planner that identify an individual's status for a specific data element, the date on which the information was obtained, and the career planner who obtained the information.³

NOTE: The requirement to utilize case notes to document an individual's status for a specific data element applies only when case notes are an allowable documentation methodology for a particular data element and are being used as the sole method for documenting that element.

Case notes should also be used as a means to document regular interactions with individuals including meetings, phone calls, emails, or other types of communication.

Case notes should tell the story, from beginning to end, of each individual's engagement with the WIOA Program.

Effective case notes are objective, detailed, accurate, and timely. DWD-DET defines the timely entry of case notes as occurring within 10 calendar days from the date of the interaction being documented.

12.2.6 Photocopying

Wisconsin State Statutes⁴ prohibit photocopying records of vital statistics and certain other official documents identified in the list below:

• State of Wisconsin issued Identification cards;
• Birth Certificates;
• Death Certificates;
• Marriage Documents (including declarations of domestic partnerships);
• Divorce/Annulment Certificates and related records (including terminations of domestic partnerships);
• Vehicle Titles; and
• Any documents specifically marked "Do Not Copy" or similar.

For these documents, a standardized Document Verification Form should be used to show that program staff verified a specific document. This form must record pertinent information to the data element being verified (e.g., date of birth), as well as the following:

• Identification/serial number of document(s);
• Issuing agency/state;
• Date of issue;
• Expiration date (if applicable); and
• Any other relevant information needed to identify the document, if necessary.

The Document Verification Form must be signed and dated by an authorized program staff member (career planner).

Documents used to verify eligibility that can be photocopied (e.g., Driver's License⁵and Social Security Card), may be photocopied and retained in the participant file. These photocopies must be marked "For Administrative Use Only." ⁶

12.2.7 Retention of CARES, Unemployment Insurance, IRIS, etc. Screens

CARES (TANF/W-2/FoodShare), Host on Demand/UIBNet (Unemployment Insurance), IRIS (Division of Vocational Rehabilitation), and other program participant tracking system screens that require authorized access through data sharing agreements must not be printed and placed in the participant's file. Placing these screen prints in the participant's file can result in unauthorized viewing of information protected through data sharing agreements. Pertinent data needed from these screens may be reported on either the Verbal Verification Form or Document Verification Form.

However, if an individual receives documentation directly from an agency documenting their eligibility for and/or receipt of benefits and shares this with their career planner for proof of eligibility or other required registration data, then this documentation may be placed in the participant's file since it is not protected through a data sharing agreement. (Example: Screens from the participant's My UI Portal may be printed and retained in the file, but screens from Host on Demand or UIBNet accessed by staff may not.)

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• ¹ TEGL 7-18, Attachment I; TEGL 23-19, Change 2, Attachment II
• ² TEGL 7-18, Attachment I; TEGL 23-19, Change 2, Attachment II
• ³ TEGL 23-19, Change 2, Attachment II
• ⁴ Wisconsin Statute § 69.30; Wisconsin Statute § 343.50(12)(e)
• ⁵ Wisconsin Statute § 102.205
• ⁶ Wisconsin Statute § 69.30