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

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:

  1. 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.
  2. 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.


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 Level (FPL) or 70% of the Lower Living Standard Income Level (LLSIL)

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 FPL
  • Documentation that individual is "eligible for" reduced-price meals by having family income at or below 185% of the FPL
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 Level (FPL) or 70% of the Lower Living Standard Income Level (LLSIL).
  • 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 5.78 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.


Eligibility determination

Effective date: July 26, 2019

Eligibility determination means applying the information collected during program registration to the eligibility criteria to see if the individual is eligible for the program.



High-Poverty Area

Effective date: August 20, 2018

"High-poverty area" means that one of the following has a poverty rate of at least 25 percent based on the American Community Survey 5-Year Data:

  • a county;
  • a Census tract;
  • a set of contiguous Census tracts;
  • an American Indian Reservation;
  • Oklahoma Tribal Statistical Area;
  • Alaska Native Village Statistical Area;
  • Alaska Native Regional Corporation Area;
  • Native Hawaiian Homeland Area; and
  • Other tribal land as defined by USDOL in guidance.

20 CFR § 681.260



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)



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/



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



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



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)



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



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.



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)