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

12.2 Requirements

Effective date: September 1, 2020

Revised date: October 1, 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)

Automated System Support for Employment and Training (ASSET) is the designated management information system (MIS) and official system of record for customer reporting and data collection for the WIOA Title I Adult Program, Dislocated Worker Program, and Youth Program. As detailed throughout this chapter, all information required for federal reporting purposes must be completely and accurately documented in ASSET.

For participants entering program participation on or after October 1, 2020, DWD-DET requires that, at minimum, documentation necessary for data validation3 be uploaded to ASSET for any data element that applies. This chapter details when documentation is required and what forms of documentation are allowable in each case.

At its discretion, DWD-DET may require local WDBs and/or their service providers to upload additional documents or participant records to ASSET (e.g., to satisfy additional federal or state monitoring needs, etc.).

Local WDBs and/or their service providers may choose to upload additional participant-specific documentation to ASSET at their discretion.

NOTE: Consistent with Chapter 5.7, documents uploaded to ASSET that include any medical or disability-related information about an individual, including information that could lead to the disclosure of a disability, must be marked "Confidential" using the functionality available in ASSET. Similarly, consistent with Chapter 1.6.2, to ensure the protection of participants' personally identifiable information (PII), the retention of PII should be limited as much possible (e.g., the social security number should be collected and retained only once and should be redacted from additional documentation whenever possible).

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.4

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 Statutes5 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 License6 and Social Security Card), may be photocopied and retained in the participant file. These photocopies must be marked "For Administrative Use Only."7

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.)

Eligibility Determination

Effective date: July 26, 2019

DWD-DET defines eligibility determination as applying the information collected during program registration to the eligibility criteria to see if the individual is eligible for the program.


Effective date: September 1, 2020

The process for collecting information to support a determination of eligibility. This information may be collected through methods that include electronic data transfer, personal interview, or an individual's application. (20 CFR § 680.110)

Personally Identifiable Information

Effective date: October 1, 2020

Personally Identifiable Information (PII) means information that can be used to distinguish or trace an individual's identity, either alone or when combined with other personal or identifying information that is linked or linkable to a specific individual.

2 CFR § 200.79