Preperation and Submission of Data Verification Procedures

Work Verification Plan Guide
Overview
This guide was prepared to help each State develop its Temporary Assistance for Needy Families
(TANF) Work Verification Plan in accordance with the regulatory requirements of the interim
final rule that the U.S. Department of Health and Human Service (HHS) published on June 29,
2006. Under the rule, a State must submit its Work Verification Plan to HHS for approval. The
guide provides key directions or questions to help States provide the information that must be
included in the plan. The guide is organized into six sections: countable work activities; hours
engaged in work; work-eligible individuals; internal controls; verification of other data used in
calculating the work participation rates; and submittal procedures. It provides separate directions
and questions for each section. The guide should be used in conjunction with the appropriate
preamble and regulatory text of the interim final rule and assumes an understanding of the rule.
Please refer to Attachment A for the text of 45 CFR 261.62, the regulatory section specifying
what a State must do to verify the accuracy of its work participation information, including the
required contents of the Work Verification Plan.
A State’s Work Verification Plan is a planning document that may be phased-in over a period of
time and may also require substantial revision in future months. (All procedures and internal
controls must be in place by October 1, 2007.) The State should describe the program it will
have in effect on October 1, 2006, but we also encourage the State to reflect its intended program
design based on the information available to it at the time of submission. If actual practice
differs from future intent, the State should explain where those differences appear. The State
may amend its Work Verification Plan at any time during the course of the fiscal year in
accordance with the regulations at 45 CFR 261.63(c).
I. Countable Work Activities
For each of the 12 work activities, address the four questions below in completing the Work
Verification Plan. Following those general questions, the guide gives the Federal regulatory
definition of each activity in italics, with bulleted key preamble requirements. After each
definition, the guide asks questions specific to that activity.
General Plan Documentation Guidance
For each activity:
1. Describe the services or programs the State includes under the activity. (Services and
programs must conform to the Federal definition of the activity.)
2. Describe how the State determines the number of countable hours of participation for the
activity. If the State uses different methods for different services or programs within the
activity, the State should describe each.

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3. Describe how the State verifies the actual hours of participation for the activity. Include the
procedures for obtaining and maintaining documentation of hours of participation.
4. Describe the methods of daily supervision for each unpaid work activity.
Plan Documentation Guidance Specific to Each Activity
Unsubsidized employment means full- or part-time employment in the public or private sector
that is not subsidized by TANF or any other public program.
• The determination of whether employment is subsidized, or not, depends on whether the
employer, rather than the recipient, receives a subsidy.
• Recipients whose employers claim a tax credit for hiring economically disadvantaged
workers are considered to be in unsubsidized employment.
Documentation:
1. For self-employment, describe how the State counts and verifies the hours of
participation. A State may not count more hours toward the participation rate for a selfemployed individual than the individual’s self-employment income (gross income less
business expenses) divided by the Federal minimum wage. The State may also describe
an alternative methodology to count and verify hours a client is engaged in selfemployment.
2. If the State intends to project forward hours of participation based on current,
documented, actual hours, explain how it will make this projection.
Subsidized private sector employment means employment in the private sector for which the
employer receives a subsidy from TANF or other public funds to offset some or all of the wages
and costs of employing a recipient.
Subsidized public sector employment means employment in the public sector for which the
employer receives a subsidy from TANF or other public funds to offset some or all of the wages
and costs of employing a recipient.
• Subsidized employment is distinguished from work experience, because the participant is
paid wages and receives the same benefits as an employee with no subsidy who performs
similar work.
• Subsidized employment does not include “on-the-job training” programs, where
employers are subsidized to offset the costs of training.
• The preamble outlines three subsidized employment models:
1. Work supplementation where TANF funds that would otherwise be paid as assistance
are paid to employer;
2. A third-party contractor, like a temporary staffing agency, serves as employer of
record and is paid a fee to cover salary, expenses and success in placing employees;
and
3. Supported work for individuals with disabilities in an integrated setting.
The State may also describe other “subsidized employment” models.

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Documentation:
1. If the State intends to project forward hours of participation based on current,
documented, actual hours, explain how it will make this projection.
Work experience (including work associated with the refurbishing of publicly assisted housing) if
sufficient private sector employment is not available means a work activity, performed in return
for welfare, that provides an individual with an opportunity to acquire the general skills,
training, knowledge, and work habits necessary to obtain employment. The purpose of work
experience is to improve the employability of those who cannot find unsubsidized employment.
This activity must be supervised by an employer, work site sponsor, or other responsible party on
an ongoing basis no less frequently than daily.
• An individual that is considered an “employee” under the Fair Labor Standards Act
(FLSA) must be compensated at the applicable minimum wage. In addition, the FLSA’s
overtime pay (for over 40 hours in a work week), child labor, and recordkeeping
requirements also apply. Questions about the applicability the FLSA should be directed
to the Department of Labor.
• TANF assistance provided to work experience participants is not considered wages for
Social Security, Federal income tax, or Earned Income Tax Credit purposes.
• A State may consider a participant to be an “employee” for purposes of workers’
compensation.
Documentation: None.
On-the-job training (OJT) means training in the public or private sector that is given to a paid
employee while he or she is engaged in productive work and that provides knowledge and skills
essential to the full and adequate performance of the job. On-the-job training must be
supervised by an employer, work site sponsor, or other responsible party on an ongoing basis no
less frequently than daily.
• States may subsidize the employer to offset training costs.
• Supported employment may be counted as OJT, if it includes significant on-site training
in the skills and knowledge essential to job performance.
Documentation:
1. Describe the nature of training provided by employers that distinguishes this from
subsidized employment.
2. If the State intends to project forward hours of participation based on current,
documented, actual hours, explain how it will make this projection.
Job search and job readiness assistance means the act of seeking or obtaining employment,
preparation to seek or obtain employment, including life skills training, and substance abuse
treatment, mental health treatment, or rehabilitation activities for those who are otherwise
employable. Such treatment or therapy must be determined to be necessary and certified by a

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qualified medical or mental health professional. Job search and job readiness assistance
activities must be supervised by the TANF agency or other responsible party on an ongoing basis
no less frequently than daily.
• “Job search” includes looking for suitable job openings, making contact with potential
employers, applying for vacancies, and interviewing for jobs.
• Job readiness assistance comprises two activities:
1. Preparing an individual to obtain employment, such as preparing a resume or job
application, interviewing skills, instruction in work place expectations, and life skills
training; and
2. Substance abuse treatment, mental health treatment, or rehabilitation activities for
those who are otherwise employable.
• A State may only count an individual’s actual hours of participation in treatment or
rehabilitation activities.
• If a portion of the treatment or rehabilitation activities meets a common-sense definition
of another work activity, then the hours associated with the work may count under the
appropriate allowable work category.
• For purposes of the six-week limitation (no more than four consecutive weeks), a week
consists of seven consecutive days.
• If substance abuse treatment, mental health treatment, or rehabilitation activities are
assigned a qualified medical or mental health professional must certify that such
treatment is necessary.
Documentation:
1. If the State intends to count as substance abuse treatment, mental health treatment and
rehabilitation activities, describe the criteria to determine whether recipients are
“otherwise employable” and establish the necessity of treatment or therapy. Describe the
certification requirements for qualified medical or mental health professionals used in
this process.
2. Describe how the State ensures that no more than six total weeks (four consecutive
weeks) of job search and job readiness assistance are reported in a fiscal year (or a total
of 12 weeks in States that meet the definition of a “needy State” for the Contingency
Fund).
Community service programs mean structured programs and embedded activities in which
TANF recipients perform work for the direct benefit of the community under the auspices of
public or nonprofit organizations. Community service programs must be limited to projects that
serve a useful community purpose in fields such as health, social service, environmental
protection, education, urban and rural redevelopment, welfare, recreation, public facilities,
public safety, and child care. Community service programs are designed to improve the
employability of recipients not otherwise able to obtain employment, and must be supervised on
an ongoing basis no less frequently than daily. A State agency shall take into account, to the
extent possible, the prior training, experience, and skills of a recipient in making appropriate
community service assignments.
• Family- and self-improvement activities that do not provide a direct benefit to the

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•
•
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community may not be counted as community service, including substance abuse
treatment, mental health and family violence counseling, life skills and parenting classes,
job readiness instruction and caring for a disabled household family member.
Community service programs may not include activities that meet the definition of
another allowable TANF work activity.
Programs must include structured activities that both provide a community service and
also improve the employability of participants.
Excluded activities include unstructured and unsupervised activities such as helping a
neighbor or friend, and foster parenting.
A participant that is considered an “employee” is subject to the Fair Labor Standards Act
(FLSA) requirements.

Documentation:
1. Describe how the types of community service positions that create an employer/employee
relationship and are subject to the FLSA minimum wage requirements will be
determined.
2. If the State permits self-initiated community service positions, describe how it determines
that the position provides a direct community service and improves the recipient’s
employability.
Vocational educational training (not to exceed 12 months with respect to any individual) means
organized educational programs that are directly related to the preparation of individuals for
employment in current or emerging occupations requiring training other than a baccalaureate
or advanced degree. Vocational educational training must be supervised on an ongoing basis no
less frequently than daily.
• Unsupervised homework time may not count; however structured and monitored study
sessions which can be documented may be counted.
• Vocational education must be provided by education or training organizations, such as
vocational-technical schools, community colleges, postsecondary institutions and
proprietary schools, etc.
Documentation:
1. Describe how the State ensures participation in vocational educational training does not
count beyond the statutory limitations limiting participation to 12 months lifetime per
individual.
2. Explain how the State will ensure that basic and remedial education and English as a
Second Language (ESL), if such activities are counted, are of limited duration and a
necessary or regular part of the vocational education training.
Job skills training directly related to employment means training or education for job skills
required by an employer to provide an individual with the ability to obtain employment or to
advance or adapt to the changing demands of the workplace. Job skills training directly related

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to employment must be supervised on an ongoing basis no less frequently than daily.
• May include both customized and general training to prepare an individual for
employment, including literacy and language instruction.
• Barrier removal activities, such as substance abuse counseling and treatment, may not be
included.
• Unsupervised homework time may not be counted.
Documentation: None.
Education directly related to employment, in the case of a recipient who has not received a high
school diploma or a certificate of high school equivalency means education related to a specific
occupation, job, or job offer. Education directly related to employment must be supervised on an
ongoing basis no less frequently than daily.
• May include adult basic education and ESL, and where required as a prerequisite for
employment education leading to a GED or high school equivalency diploma.
• Participants should make “good or satisfactory progress” such as performance,
attendance, and completion timeframes under the standards of the institution or program.
• Unsupervised homework time may not be counted.
Documentation:
1. Describe the State’s criteria for “good or satisfactory progress” and when and how it is
documented.
Satisfactory attendance at secondary school or in a course of study leading to a certificate of
general equivalence, in the case of a recipient who has not completed secondary school or
received such a certificate means regular attendance, in accordance with the requirements of the
secondary school or course of study, at a secondary school or in a course of study leading to a
certificate of general equivalence, in the case of a recipient who has not completed secondary
school or received such a certificate. This activity must be supervised on an ongoing basis no
less frequently than daily.
• Participants should make “good or satisfactory progress” such as performance,
attendance, and timeframes under the standards of the institution or program.
• May not include other related educational activities, such as adult basic education or
language instruction.
• Unsupervised homework time may not count.
Documentation:
1. Describe the State’s criteria for “good or satisfactory progress” and when and how it is
documented.
Providing child care services to an individual who is participating in a community service
program means providing child care to enable another TANF recipient to participate in a
community service program. This activity must be supervised on an ongoing basis no less
frequently than daily.

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Does not include providing child care to enable a TANF recipient to participate in any of
the other 11 allowable work activities.

Documentation: None.
II. Hours Engaged in Work
This section includes two topics: excused absences and FLSA deeming.
Excused Absences
Describe the State’s excused absence policies for unpaid work activities. This includes its
policies for holidays as well as the ten additional excused absences that the State may count in a
12-month period. If the policies vary by work activity, the State should describe how they vary
and for which activities.
FLSA Deeming
If the State wishes to use the “deeming” provision permitted at §§ 261.31 and 261.32 for work
experience or community service programs, describe how the State determines the work hours
requirement, including how the monthly TANF grant and food stamp allotment are combined
and divided by the appropriate minimum wage to meet the “core” participation requirement.
Include a statement certifying that the State has adopted a “mini” Simplified Food Stamp
Program in order to count the value of food stamp benefits. The Food and Nutrition Service has
indicated that a TANF work experience or community service program can serve as the Food
Stamp Workfare Program, which would otherwise be required before a State could combine the
food stamp allotment to calculate the hours required.
If State policies or procedures differ for work experience and community service programs on
FLSA deeming, the State should make those differences clear.
III. Work-Eligible Individual
The State must describe:
• procedures for identifying all work-eligible individuals;
• how the State ensures that, for each work-eligible individual, it
¾ accurately inputs data into the automated data processing system,
¾ properly tracks the hours, and
¾ accurately reports countable hours to HHS that do not include participation in an
activity that does not meet a Federal definition.
Work-eligible individual means an adult (or minor child head-of-household) receiving assistance
under TANF or a separate State program or a non-recipient parent living with a child receiving
such assistance (usually a child-only case) unless the parent is:
• A minor parent and not the head-of-household or spouse of the head-of-household;
• An alien who is ineligible to receive assistance due to his or her immigration status; or

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At State option, on a case-by-case basis, a recipient of Supplemental Security Income
(SSI) benefits.
The term also excludes:
• A parent providing care for a disabled family member living in the home who does not
attend school on a full-time basis, provided that the need for such care is supported by
medical documentation; and
• An individual in a family receiving MOE-funded assistance under an approved Tribal
TANF program, unless the State includes the Tribal family in calculating work
participation rates.
Documentation:
1. Describe the State’s procedures for identifying all work-eligible individuals, as defined at
§ 261.2. This should include the procedures needed to identify a non-recipient parent
excluded from the definition of work-eligible individual. These are:
• A minor parent who is not the head-of-household and not spouse of the head-ofhousehold;
• An alien who is ineligible to receive assistance due to his or her immigration status;
and
• At State option, on a case-by-case basis, a recipient of Supplemental Security
Income (SSI) benefits.
The State should also describe its procedures for identifying a parent caring for a
disabled family member, who may also be excluded from the definition of a workeligible individual. The procedures should define the terms “disabled,” “family
member” and “attending school full-time.” This should include a means of ensuring
that the need for care in the home is supported by medical documentation and describe
the nature of the medical documentation used to make such determinations. If the State
includes in this group parents caring for a family member with a temporary disability,
the State must describe its procedures for determining when the family member is no
longer disabled and ensuring that the parent is then identified as a work-eligible
individual.
2. Describe verification procedures for ensuring the accuracy in reporting of work-eligible
individuals on the TANF Data Report and the SSP-MOE Data Report, including:
• The correct reporting of the Work Participation Status of all adult (or minor child
head-of-household) family members, and
• The proper identification of TANF Families for inclusion in only the overall work
participation rate or the overall and two-parent work participation rates, or exclusion
from both the overall and two-parent work participation rates.
3. Describe the procedures that show how the State ensures that, for each work-eligible
individual, it accurately inputs data into the automated data processing system, properly
tracks the hours, and accurately reports countable hours to HHS that do not include
participation in an activity that does not meet a Federal definition.

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IV. Internal Controls
The State is required to describe internal controls that ensure a consistent measurement of the
work participation rates. The Work Verification Plan should contain a clause confirming that the
State will maintain all pertinent findings produced through its internal control processes and that
these finding will be available for use by ACF and other auditors in their review of the State’s
work participation verification system.
If the State is phasing in procedures or internal controls, describe the phase-in. All procedures
must be in place by September 30, 207.
Documentation:
1. Describe the internal controls designed to ensure established work verification procedures
are properly being employed. Such controls may include supervisory guidance, policy
directives, and staff training plans, as well as quality assurance processes, such as
monitoring procedures to ensure adherence to procedures by staff, providers and
contractors. For example, to ensure the State is identifying all work-eligible individuals,
a State may periodically check the disability status of a family member who is
temporarily disabled, as the parent caring for the disabled family member would become
a work-eligible individual once the family member is no longer disabled.
2. Describe the internal controls to control for data errors, including transcription and
coding errors, data omissions, computational errors, and compilation errors. For
example, a State might automatically review the case record of each work-eligible
individual whose reported average weekly hours of participation are unusually high (e.g.,
70 or more hours per week) by examining the documentation used to support those hours.
3. Describe the checks used to isolate electronic systems and programming errors and the
steps to ensure that all work participation report items are internally consistent. For
example, a State might obtain the raw data (prior to input into an automated data
processing system) for a sample of work-eligible individuals and determine manually the
average weekly hours of participation for each work activity for a month and compare
that result to what the Sate actually reported to HHS.
4. Describe any sampling and estimation techniques employed in data validation. The
Work Verification Plan should document the soundness of all statistical procedures
utilized in the verification process. All estimation techniques must be reasonable and
fully described in the plan. For estimates based on sampling or other statistical
techniques, the plan must contain, as appropriate, the step-by-step computations of
precision, affirming that the produced estimates are within statistically acceptable levels
of reliability and validity.
V. Verification of Other Data Used in Calculating the Work Participation Rates
Under the “complete and accurate” standard for data reporting, States should validate all data

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submitted in its TANF Data Report and, if applicable, the SSP-MOE Data Report. In addition to
the work activities, the following data elements are used in calculating the work participation
rates:
• Reporting Month
• Stratum
• Case Number
• Disposition
• Type of Family for Work Participation
• Amount of Food Stamps Assistance
• Receives Subsidized Child Care
• Amounts of TANF (and SSP-MOE) Assistance
• Family Affiliation Code
• Non-custodial Parent Indicator
• Date of Birth (Adult)
• Relationship to Head-of-Household
• Parent with Minor Child
• Work-Eligible Individual Indicator
• Date of Birth (Child)
The Work Verification Plan should contain the procedures needed to establish that the State has
the capacity to breakout TANF families with a work-eligible individual by the case
characteristics that relate to the special rules and conditions of participation, such as receipt of
child care, age of child, age of adult or teen parent, number of months under a sanction, adult or
teen parent with satisfactory school attendance, and families with a disabled family member
(adult or child).
Documentation:
1. For each of the above data elements, describe the State’s data validation procedures to
ensure “complete and accurate” data reporting.
2. Describe any procedures employed to eliminate data inconsistencies between two or
more data elements.
Work Participation Status
1. Describe the State’s procedures to ensure that a family is not disregarded from the work
participation rate for more than 12 months per lifetime based on being a single custodial
parent with a child less than one year of age.
2. Describe the State’s procedures to ensure that a family is not disregarded from the work
participation rate for more than three months in any period of 12 consecutive months
based on a work-eligible individual’s refusal to participate in work.
3. Describe the State’s procedures for ensuring a family deemed engaged in work based on
20 hours of participation in countable work activities meets the requirements of a single
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custodial parent or caretaker relative with a child under age six.
VI. Submittal Procedures
The State must submit its interim Work Verification Plan to HHS no later than September 30,
2006. Failure to submit the interim Work Verification Plan on time opens a State to a penalty of
five percent of the grant. We will review a State’s Work Verification Plan for completeness and
approve it if we believe that it will result in accurate reporting of work participation information.
If, after our review of the plan, we require changes or modifications to the plan, we will request
these changes in writing. (We anticipate the need for conference calls or technical assistance and
will arrange and discuss change requests with States.) A State must make the changes and
submit them within 60 days of receipt of our notice. While all necessary changes must be made
and the final plan approved by HHS by no later than September 30, 2007, States will need time
to implement their plan. Consequently, States should submit their original plan as soon as
possible and respond to required changes quickly.
The IV-A Administrator in the State should submit the Work Verification Plan to the Office of
Family Assistance (OFA), with a copy to the appropriate Regional Office of the Administration
for Children and Families (ACF). The original should be sent to:
Office of Family Assistance
Administration for Children and Families
5th Floor East
370 L’Enfant Promenade, SW.
Washington, DC 20447
A State may also submit the Work Verification Plan electronically (as an e-mail attachment) and
mail the original signature separately.
If you have any questions about this guide or developing your Work Verification Plan, please
contact Sean Hurley at (202) 401- 9297 shurley@acf.hhs.gov or Robert Shelbourne at (202) 4015150 rshelbourne@acf.hhs.gov.

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Attachment A
§ 261.62 What must a State do to verify the accuracy of its work participation information?
(a) To ensure accuracy in the reporting of work activities by work-eligible individuals on the
TANF Data Report and, if applicable, the SSP-MOE Data Report, each State must:
(1) Establish and employ procedures for determining whether its work activities may count
for participation rate purposes;
(2) Establish and employ procedures for determining how to count and verify reported hours
of work;
(3) Establish and employ procedures for identifying who is a work-eligible individual;
(4) Establish and employ internal controls to ensure compliance with the procedures; and
(5) Submit to the Secretary for approval the State’s Work Verification Plan in accordance
with paragraph (b) of this section.
(b) A State’s Work Verification Plan must include the following:
(1) For each countable work activity:
(i) A description demonstrating how the activity meets the relevant definition at § 261.2;
(ii) A description of how the State determines the number of countable hours of participation
for self-employed individuals; and
(iii) A description of the documentation it uses to monitor participation and ensure that the
actual hours of participation are reported;
(2) A description of the State’s procedures for identifying all work-eligible individuals, as
defined at § 261.2;
(3) A description of how the State ensures that, for each work-eligible individual, it:
(i) Accurately inputs data into the State’s automated data processing system;
(ii) Properly tracks the hours though the automated data processing system; and
(iii) Accurately reports the hours to the Department;
(4) A description of the procedures for ensuring it does not transmit to the Department a
work-eligible individual’s hours of participation in an activity that does not meet a Federal
definition of a countable work activity; and
(5) A description of the internal controls that the State has implemented to ensure a
consistent measurement of the work participation rates, including the quality assurance processes
and sampling specifications it uses to monitor adherence to the established work verification
procedures by State staff, local staff, and contractors.
(c) We will review a State’s Work Verification Plan for completeness and approve it if we
believe that it will result in accurate reporting of work participation information.

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