Previous Policy - 12.5 Youth Program File Documentation

12.5.3 Income Status Determination

Effective date: September 1, 2020

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

In order to be eligible for the WIOA Youth Program:

Youth who are determined to be in school (ISY) must be determined to be low-income by satisfying at least one of the criteria in the table below.
Youth who are determined to be out of school (OSY) must be determined to be low-income by satisfying at least one of the criteria in the table below if they:
- are a recipient of a secondary school diploma or its recognized equivalent and are basic skills deficient, or an English Language Learner; or
- meet the local definition of "requires additional assistance;"
  AND
- have no other qualifying barrier to education/employment.

NOTE: For federal reporting purposes youth who are determined to be eligible as an OSY based on any other eligibility barrier must still have their income status assessed and documented as outlined below.

Family Size	Acceptable Documentation
Family size for determining low-income status¹ 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

Family Size

Acceptable Documentation

Family size for determining low-income status¹

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 Documentation² 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.
Family Income at or Below the Current Federal Poverty Guidelines or 70% of the Lower Living Standard Income Level (LLSIL) Guidelines Family size must be accurately determined prior to making a low-income determination. See 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)³	Self-attestation OR Signed WIOA intake application or registration form Written Statement or Referral Transmittal from a Shelter or Social Service Needs Assessment Signed Individual Service Strategy A letter from caseworker or support provider Verbal or written verification from social service agency Case Notes
FoodShare/ Supplemental Nutrition Assistance Program (SNAP)	FoodShare/SNAP eligibility verification Copy of Authorization to Receive Foodshare/SNAP Referral Transmittal from Foodshare/SNAP Cross-Match with Foodshare/SNAP Public Assistance Record Receipt of FoodShare/SNAP purchase showing balance from point of sale and date of purchase 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/SMAP (Quest) card Screen prints from CARES
Temporary Assistance for Needy Families (TANF) / 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/W-2.
Supplemental Security Income (SSI)/Social Security Disability Insurance (SSDI)	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)	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: It is not allowable to use screen prints from CARES to document public assistance.
Receiving or Eligible to Receiving Free or Reduced-Price School Lunch 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 2010.⁴ NOTE: Applies only to the applicant, not other family members, except in cases where an OSY is a parent living in the same household as a child who receives or is eligible to receive free or reduced-price lunch based on their income level.⁵	Self-attestation OR Documentation from school Documentation that individual is "eligible for" free lunch by having family income at or below 130% of the Federal Poverty Guidelines Documentation that individual is "eligible for" reduced-price meals by having family income at or below 185% of the Federal Poverty Guidelines
Foster Care (Foster Care Youth Status at Program Entry)⁶ (ISY/OSY)	Self-Attestation OR Written Confirmation from Social Services Agency Foster Care Agency Referral Transmittal Signed WIOA intake application or registration form Needs Assessment Signed Individual Service Strategy Verbal Verification from cognizant agency or official (school counselor, social worker, court, etc.)
Individual with a disability⁷ whose own income does not exceed the higher of the Federal Poverty Guidelines or 70% of the Lower Living Standard Income Level (LLSIL) Guidelines.	Self-attestation OR School 504 records provided by student test results NOTE: Case notes and other documentation related to this element must be maintained in compliance with Section 5.7 ⁸ of this policy manual.
High Poverty Area⁹ Youth living in high poverty areas automatically meet the low-income criterion.¹⁰	Residency Self-Attestation OR Driver's license Postmarked mail addressed to applicant Other documentation of residency AND Census Tract Screen print from US Census Bureau website showing participant's address and Census Tract number¹¹
Low-Income Exception (5% Maximum) (ISY/Some OSY)	Absence of low-income status AND Relevant documentation of barrier

¹ 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.
² Unless otherwise noted, information on documentation sources is from OMB Control No. 1205-0521 and TEGL 23-19, Attachment II. In the WIOA Youth program data element validation is required for Data Element 802 based on the definition of "low-income individual" at WIOA Sec. 3(36).
³ Per TEGL 23-19, Attachment II, Data Element 800 Data Element Validation is required.
⁴ TEGL 21-16, p. 6
⁵ TEGL 21-16, p. 6
⁶ Per TEGL 23-19, Attachment II, Data Element 704 Data Element Validation is required.
⁷ Per TEGL 23-19, Attachment II, Data Element 202 Data Element Validation is required.
⁸ 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.
⁹ TEGL 21-16
¹⁰ TEGL 21-16
¹¹ TEGL 21-16, Attachment 2, provides guidance for determining whether a geographic location is a high poverty area.