12.2 Requirements

12.2.2 Verbal Verification

Effective date: October 11, 2022

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 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.

• ¹ Per 20 CFR 680.110
• ² Per TEGL 23-19, Change 2, Attachment II, Data Element 900 Data Element Validation is required.
• ³ Per TEGL 23-19, Change 2, Attachment II, Data Element Validation is required for multiple elements
• ⁴ Per TEGL 23-19, Change 2, Attachment II, Data Element 901 Data Element Validation is required.
• ⁵ TEGL 7-18, Attachment I; TEGL 23-19, Change 2, Attachment II
• ⁶ Per TEGL 23-19, Change 2, Attachment II
• ⁷ Per OMB Control No. 1205-0521
• ⁸ Per TEGL 23-19, Change 1, Attachment II

12.2.3 Self-Attestation / Participant Statement

Effective date: October 1, 2020

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

• ¹ TEGL 23-19, Change 1, Attachment II
• ² TEGL 23-19, Change 1, Attachment II

12.2.4 Automated System Support for Employment and Training (ASSET)

Effective date: August 14, 2023

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 validation¹ be uploaded to ASSET for any data element that applies. Document uploads must occur within 30 days of the date the information is first obtained by the career planner, or the date the activity being validated is completed (e.g., credential is attained, text/exam results are available, etc.). This chapter details when documentation is required and what forms of documentation are allowable in each case. See also, Data Validation by Element.

NOTE: Career Planners must ensure documents uploaded to ASSET include the date the documents were received and/or an ASSET case note is entered to reflect the date the document was received. If career planners are having difficulty obtaining documents within 30 days of completion of the activity, they must case note the steps they have taken to obtain the information.

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).

• ¹ TEGL 23-19, Change 2, Attachment II

12.2.5 Case Notes

Effective date: August 14, 2023

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.¹

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.

• ¹ Per TEGL 23-19, Change 2, Attachment II

12.2.6 Photocopying

Effective date: August 14, 2023

Wisconsin State Statutes¹ 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).

Identification documents that can be photocopied (e.g., Driver's License² and Social Security Card), may be photocopied and retained in the participant file. However, it is not required to photocopy and retain such documents. Should the career planner opt to photocopy and retain such documents, the photocopies must be marked "For Administrative Use Only."³

• ¹ Wisconsin Statute § 69.30; Wisconsin Statute § 343.50(12)(e)
• ² Wisconsin Statute § 102.205
• ³ Wisconsin Statute § 69.30

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

Effective date: October 1, 2020

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.)

12.2.8 Signature Requirements

Effective date: July 1, 2022

DWD-DET does not require career planners to collect signatures from parents and/or legal guardians on any forms related to WIOA Title I Programs for applicants and/or participants under age 18.¹ Local WDBs and/or their services providers may not establish a requirement to collect signatures from parents and/or legal guardians and may not refuse service to youth on the basis of not obtaining such signature(s). A parent/guardian signature requirement could create an unintended barrier to accessing services for underrepresented populations of youth, thus limiting participation

Parent/legal guardian signatures are required for apprenticeship contracts and work permits for minors, except emancipated minors.² These are issued separately from WIOA Title I programs and are considered binding contracts.³ Parent or guardian signatures are also not required on Individual Service Strategies.⁴

• ¹ Email from DOL to DWD-DET, 12/15/2021, email from OLC to DWD-DET, 12/15/2021, and Email from OLC to DWD-DET, 2/23/2022
• ² Wis. Stat. § 48.375(2)(e)
• ³ Wis. Stat. § 106.01(1)
• ⁴ TEN 22-19 Attachment I, page 4