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

12.3 Adult Program File Documentation

Table of Contents

12.3.2 Priority of Service

Effective date: September 1, 2020

Priority of service must be assessed for each Adult Program applicant at the time of eligibility determination and may be updated during participation if a change in an individual's status allows them to receive a higher priority of service.¹ Individuals may fall into one of five Priority of Service categories.²

NOTE: Career planners must record each participant's Priority of Service Category in an ASSET case note.

Priority of Service Category	Acceptable Documentation
Category 1: Veterans and eligible spouses who are low-income or basic skills deficient3	Eligible Veteran Status4 Form DD-214 showing the military service member's discharge that is anything other than dishonorable Cross-match with Department of Defense records Cross-match with Veterans Service Database Letter from the Veterans Administration AND Appropriate documentation of low-income status5 or basic skills deficiency6 as outlined below.
Category 2: Individuals who are low-income and/or basic skills deficient but are not Veterans and eligible spouses	Documentation of low-income status or basic skills deficiency as outlined below
Category 3: Veterans and eligible spouses who are not low-income or basic skills deficient	Documentation of veteran status as outlined above, and no determination of low-income status or basic skills deficiency
Category 4: Anyone who does not belong to one of the groups above, but who belongs to a priority population established by DWD-DET or the local WDB.7	Documentation of state or locally established criterion. See local policy.
Category 5: Everyone else.	File contains no indication of veteran status, low-income status, or basic skills deficiency.

12.3.2.1 Income Status Documentation

For each Adult Program applicant, a determination of income status must be made.

Income status cannot be used as an eligibility criterion in the Adult Program but does impact an individual's priority of service category and is required for federal reporting⁸ purposes.

Family Size

Acceptable Documentation

Family size for determining low-income status9 Family size must be correctly determined and documented in order to correctly establish a low-income determination. NOTE: Information used to establish Family size is different from the information used to establish a household composition for the purposes of determining Economic Self-Sufficiency. NOTE: Family size is determined as of the date of eligibility determination. Family members who may have comprised part of the family during the past six months but no longer meet the definition of family should not be counted.

Self-attestation OR Local Income Determination Form - SAMPLE

Low-Income Criterion	Acceptable Documentation Documentation should be provided for each applicable includable income source received by the applicant and each Family member for the six-month period immediately preceding the eligibility determination date.
FoodShare (Supplemental Nutrition Assistance Program (SNAP))10	FoodShare/SNAP eligibility verification Copy of Authorization to Receive Foodshare/SNAP Receipt of FoodShare/SNAP purchase showing balance from point of sale and date of purchase Referral Transmittal from Foodshare/SNAP Cross-Match with Foodshare/SNAP Public Assistance Record Verbal Verification from appropriate Human Services agency Printout from www.access.wisconsin.gov showing benefits statement NOTE: The following are not acceptable forms of documentation: A copy of the participant's FoodShare/SNAP (Quest) card Screen prints from CARES
Temporary Assistance for Needy Families (TANF)11 / Wisconsin Works (W-2)	TANF/W-2 Eligibility Verification TANF/W-2 Period of Benefit Receipt Verification Referral Transmittal from TANF/W-2 Cross-Match with TANF/W-2 Public Assistance Records Verbal Verification from appropriate Human Services agency NOTE: It is not allowable to use screen prints from CARES to document TANF.
Supplemental Security Income (SSI) / Social Security Disability Insurance (SSDI)12	SSI/SSDI Receipt of Benefits Verification Referral Transmittal from Social Security Administration (SSA) SSI/SSDI Eligibility Verification Cross-Match with SSA Database Verbal Verification from Social Security Administration
Other Income-Based Public Assistance (Other Public Assistance Recipient)13	Copy of Authorization to Receive Cash Public Assistance Copy of Public Assistance Check Medical Card Showing Cash Grant Status Public Assistance Eligibility Verification Cross-Match with Refugee Assistance Records Cross-Match with Public Assistance Records Cross-Match with State MIS Database Verbal verification from appropriate social services agency NOTE: Career planners may not use screen prints from CARES to document public assistance.
Family Income at or Below the Current Federal Poverty Level (FPL) or 70 Percent of the Lower Living Standard Income Level (LLSIL)14 Family size must be accurately determined prior to making a Income Guidance for included and excluded income types and the time span for calculating income.	Self-attestation OR Award letter from Veterans Administration Bank statements Pay stubs Compensation award letter Court award letter Pension statement Employer statement/contact Family or business financial records Housing authority verification Quarterly estimated tax for self-employed persons Social Security benefits UI claim documents Copy of authorization to receive cash public assistance Copy of public assistance check Public assistance eligibility verification Cross-match with Refugee Assistance records Cross-match with public assistance records Cross-match with UI wage records Local Income Determination Form NOTE: The career planner must document the participant's income, even if the income was $0 for the past six months.
Homeless (Homeless participant, Homeless Children and Youths, or Runaway Youth at Program Entry)15	Self-attestation OR Signed WIOA intake application or registration form Written Statement or Referral Transmittal from a Shelter or Social Service Agency Needs Assessment Signed Individual Employment Plan A letter from caseworker or support provider Verbal or written verification from social service agency Case Notes
Receiving or Eligible to Receiving Free or Reduced-Price School Lunch16 NOTE: Applies only to the applicant, not other family members. NOTE: Does not apply where school districts do not use individual eligibility criteria, but instead have the Community Eligibility Provision (CEP) Healthy, Hunger-Free Kids Act of 2010.17	Self-attestation OR Documentation from school Documentation that individual is "eligible for" free lunch by having family income at or below 130 Percent of the FPL Documentation that individual is "eligible for" reduced-price meals by having family income at or below 185 Percent of the FPL
Individual with a disability18 whose own income does not exceed the higher of the Federal Poverty Level (FPL) or 70 Percent of the Lower Living Standard Income Level (LLSIL).	Self-attestation OR School 504 records provided by student Assessment test results NOTE: Case notes and other documentation related to this element must be maintained in compliance with Section 5.719 of this policy manual.

12.3.2.2 Basic Skills Deficient

All individuals applying for the Adult Program must be assessed for basic skills deficiency.²⁰ Consistent with the Basic Skills Deficient Guidance this assessment must be conducted using the Basic Skills Screening Tool (DETW-18156-E).

Basic skills deficiency cannot be used as an eligibility criterion in the Adult Program, but it:

1. impacts priority of service for individuals who are not low-income or public assistance recipients; and
2. is required for federal reporting purposes.²¹

Basic Skills Criterion	Acceptable Documentation
Basic Skills Deficient22	Basic Skills Screening Tool (DETW-18156-E) OR Assessment test results Applicable records from education institution (transcripts, academic assessments, or other school documentation) Case notes
English Language Learner23	Self-Attestation OR Basic Skills Screening Tool (DETW-18156-E) Assessment test results Applicable records from education institution (transcripts, or other school documentation) Signed WIOA intake application or registration form Signed Individual Employment Plan Case notes

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• ¹ See Section 8.3.2.
• ² See Section 8.3.2.
• ³ TEGL 10-09
• ⁴ Per TEGL 23-19, Attachment II, Data Element 301 Data Element Validation is required.
• ⁵ Per TEGL 23-19, Attachment II, Data Element 802 Data Element Validation is required.
• ⁶ Per TEGL 23-19, Attachment II, Data Element 804 Data Element Validation is required.
• ⁷ Any additional priority populations established by DWD-DET must be listed in the WIOA State Plan. TEGL 19-16, p. 9
• ⁸ OMB Control No. 1205-0521
• ⁹ This criterion is not included as its own Data Element in TEGL 23-19, Attachment II, but is included as part of the Data Element Definition for Data Element 802. WIOA Sec. 3(36)(A)(ii) states that an individual is "low-income" if they are in a family with total family income that does not exceed the higher of (I) the poverty line; or (II) 70 percent of the lower living standard income level. Family is defined at 20 § CFR 675.300.
• ¹⁰ Per TEGL 23-19, Attachment II, Data Element 603 Data Element Validation is required.
• ¹¹ Per TEGL 23-19, Attachment II, Data Element 600 Data Element Validation is required.
• ¹² Per TEGL 23-19, Attachment II, Data Element 602 Data Element Validation is required.
• ¹³ Per TEGL 23-19, Attachment II, Data Element 604 Data Element Validation is required.
• ¹⁴ This criterion is not included as its own Data Element in TEGL 23-19, Attachment II, but is included as part of the Data Element Definition for Data Element 802. WIOA Sec. 3(36)(A)(ii) states that an individual is "low-income" if they are in a family with total family income that does not exceed the higher of (I) the poverty line; or (II) 70 percent of the lower living standard income level. Family is defined at 20 § CFR 675.300.
• ¹⁵ Per TEGL 23-19, Attachment II, Data Element 800 Data Element Validation is required.
• ¹⁶ This criterion is not included as its own Data Element in TEGL 23-19, Attachment II, but is included as part of the Data Element Definition for Data Element 802. WIOA Sec. 3(36)(A)(ii) states that an individual is "low-income" if they receive or is eligible to receive a free or reduced price lunch under the Richard B. Russell National School Lunch Act (42 U.S.C 1751 et seq.).
• ¹⁷ TEGL 21-16, p.6
• ¹⁸ Per TEGL 23-19, Attachment II, Data Element 202 Data Element Validation is required.
• ¹⁹ 29 CFR § 38.41 requires that any medical or disability-related information about a particular individual, including information that could lead to the disclosure of a disability, must be collected on separate forms. All such information, whether in hard copy, electronic, or both, must be maintained in one or more separate files, apart from other information about the individual, and treated as confidential.
• ²⁰ WIOA Sec. 3(5)(B)
• ²¹ OMB Control No. 1205-0521
• ²² Per TEGL 23-19, Attachment II, Data Element 804 Data Element Validation is required.
• ²³ Per TEGL 23-19, Attachment II, Data Element 803 Data Element Validation is required.




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.



Wisconsin Works

Effective date: August 20, 2018

"Wisconsin Works" (W-2) is a limited-time program that provides temporary cash assistance and case management services to low-income parents and pregnant women who engage in work activities. https://dcf.wisconsin.gov/w2/parents/w2



Family (20 CFR § 675.300)

Effective date: October 1, 2017

"Family" means two or more persons related by blood, marriage, or decree of court, who are living in a single residence, and are included in one or more of the following categories:

• a married couple and dependent children;
• a parent or guardian and dependent children; or
• a married couple.

A "married couple" can either be a man and a woman or same-sex individuals. United States v. Windsor, 133 S.Ct.2675 (2013); 81 FR 56088



Supplemental Security Income

Effective date: August 20, 2018

"Supplemental Security Income" (SSI) is a federal income supplement program funded by general tax revenues (not Social Security taxes). It provides cash assistance to aged, blind, and disabled people who have little or no income so they can meet their basic needs for food, clothing, and shelter. https://www.ssa.gov/ssi/



Public Assistance

Effective date: August 20, 2018

Revised date: September 1, 2020

"Public Assistance" means federal, state, or local government cash payments where eligibility is determined by a needs or income test.

WIOA Sec. 3(50)

As WIOA does not define "cash payments," DWD-DET used definitions provided by the U.S. Census Bureau and the U.S. Citizenship and Immigration Services to define "cash payments" as cash or a cash equivalent, such as a debit card or check, that can be spent however the recipient choses, and is not restricted to a specific purpose like groceries or childcare.

U.S. Census Bureau (https://www2.census.gov/library/publications/ 2013/acs/acsbr11-12.pdf); U.S. Citizenship and Immigration Services (https://www.uscis.gov/policy-manual/volume-8-part-g-chapter-10)



English Language Learner

Effective date: August 20, 2018

English Language Learner means an individual who has limited ability in reading, writing, speaking, or comprehending the English language because English is not his or her native language OR he or she lives in a family or community environment where a language other than English is the dominant language.

WIOA Sec. 3(21); WIOA Sec. 203(7); TEGL 21-16, p. 3



Case Notes

Effective date: ______________, 2020

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.

TEGL 7-18, Attachment I, p. 2; TEGL 23-19, Attachment II, p. 1



Homeless

Effective date: August 20, 2018

"Homeless" means a person who lacks a fixed, regular, and adequate nighttime residence. This covers the following situations: (1) sharing the housing of other persons due to loss of housing, economic hardship, or similar; (2) living in a motel, hotel, trailer park or campground due to the lack of alternative adequate living accommodations; (3) living in an emergency or transitional shelter; (4) abandoned in a hospital; (5) awaiting foster care placement; (6) using a public or private place for nighttime residence that is not designed for or typically used by human beings for regular sleeping accommodations; (7) a child who has moved in the last 36 months either as a migratory agricultural worker or fisher or with a parent or spouse who is a migratory worker or fisher.

42 U.S.C. 14043e—2(6) ; 42 U.S.C. 11434a(2)



Household composition

Effective date: July 26, 2019

DWD-DET defines household composition as the number of individuals who are members of a household and their ages.



FoodShare Wisconsin

Effective date: August 20, 2018

"FoodShare Wisconsin" helps people with limited money buy food they need for good health. FoodShare recipients are people of all ages who work but have low incomes, are living on small or fixed incomes, or have no incomes because they have lost their job, are retired, or are disabled and not able to work. https://www.dhs.wisconsin.gov/foodshare/index.htm



Disability (WIOA Sec. 3(25))

Effective date: August 20, 2018

"Disability" means:

• a physical or mental impairment that substantially limits one or more major life activities such as caring for oneself, performing manual tasks, seeing, hearing, eating, sleeping, walking, standing, lifting, bending, speaking, breathing, learning, reading, concentrating, thinking, communicating, working, and the operation of major bodily functions
• a record of such impairment

OR

• is regarded as having such impairment (which means the individual can establish that s/he has been the subject of a discriminatory action under the American with Disabilities Act because of an actual or perceived impairment whether or not the impairment actually limits a major life activity).

WIOA Sec. 3(25); 42 U.S.C. 12102 (1)-(3)

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