OLDER WORKER BULLETIN NO. 96-5

TO: ALL SENIOR COMMUNITY SERVICE EMPLOYMENT PROGRAM SPONSORS

SUBJECT: Minimum Eligibility Documentation Requirements

1. Purpose. To provide Senior Community Service Employment Program (SCSEP) sponsors with the minimum documentation requirements for eligibility determinations.

2. References. SCSEP regulations at 20 CFR 641.302(c) and 641.305(e)(1). For other information on eligibility determinations please refer to OW Bulletin 95-5 "Procedures for Computing Annual Family Income".

3. Background. The regulations which were published on May 17, 1995 for the SCSEP indicated that the Department of Labor would issue minimum requirements for: enrollee assessments 641.309(g); eligibility documentation 641.302(c); and Individual Development Plan (IDP) terminations 641.315. In July, a work group consisting of State and national SCSEP sponsors prepared draft standards for these regulatory related matters. These draft standards were circulated to SCSEP sponsors for comments. A number of sponsors provided comments which have been incorporated into our final issuances.

This bulletin is the second in a series of issuances which are intended to clarify the SCSEP regulation. Future issuances will provide guidance on IDP terminations and physical examinations.

4. Directive. SCSEP sponsors must adhere to the requirements stated in the attachment to this bulletin, "Eligibility - Documentation Requirements". Sponsors may institute more stringent documentation requirements than those contained herein, but this bulletin and the attachment provide the framework for enrollee/applicant documentation procedures. We expect that each eligibility determination will be made after a conscientious review of all available information and that appropriate documentation will be retained.

5. Inquires. Questions may be directed to your Federal Representative at (202) 219-5904.

JAMES H. NORRIS, Chief
Division of Older Worker Programs

PAUL A. MAYRAND, Director
Office of Special Targeted Programs

Attachment

SENIOR COMMUNITY SERVICE EMPLOYMENT PROGRAM

1. Format. A written or electronic format (form) will be created by each grantee that covers all eligibility documentation requirements.

2. Types of Determination. The format will provide for three types of eligibility determinations: initial enrollment, re-enrollment, and re-certification.

3. Content of Format. The format established by the grantee will address the three basic eligibility requirements of age, income and residency. The form will contain space and/or a series of common choices for attesting to the source of the eligibility information. For instance, the form may contain space or check off boxes to enter information from such sources as: a driver's license, an official photo ID, birth certificate, Social Security/Medicare card, and "Other" sources.

For the income requirement, the following categories will be included: calculation method used (6 or 12 months), amount of income (total family income), source of income (social security, wages, etc), and the organization providing the information (the Social Security Administration, XYZ Co., etc.) It is recommended that the form contain information on both "includable and excludable" income. (See OW Bulletin 95-5 for an explanation of "includable and excludable" income information.)

4. Certification. The grantee's format must include certification of the information and data by the intake interviewer with the date. In all cases, the grantee's format will be jointly signed or initialed by both the individual applicant/enrollee and the interviewer.

Note: A supervisory or secondary review may be conducted at the discretion of the grantee. If an enrollee is the interviewer, a second review by a staff person is required. This review is intended to find and correct incomplete or improperly calculated information.

5. Family Size. Where records are not available or do not exist to verify the existence or non-existence of the number of persons residing in the family, the interviewer must determine that all potential

information sources have been considered prior to acceptance of the individual's attestation of the number of family members.

Note: Potential sources of information include documents such as: court decrees, landlord statements, leases, marriage certificates, medical cards, the most recent tax return, social agency records, housing records, written statements from 24-hour care facilities or records of on site observations. In exceptional cases, attestations by individuals who can vouch for the number of persons in the family may be used.

6. Work Sheet for Income Eligibility. The development of an optional work sheet which will form the basis for completing the grantee format is encouraged. While it may not be part of the formal record and is not required, the work sheet may be used to establish or clarify the basis for the determination. For instance, the work sheets may include mathematical calculations or narrative explanations which do not fit on the intake form.

7. Telephone Verification. Documentation may be secured by phone as opposed to hard copy documents when the cooperating agency, employer or other organization agrees to supply such information. The interviewer may use a telephone verification work sheet that provides for pertinent information; i.e., item to be verified, name of contact, etc.

8. Exceptional Cases. In situations where no documentation can be secured from any source, an explanation of the rationale for the determination must be developed and retained.

9. Self-Certification. When the individual is the only source of information, (e.g. casual labor, where wage information is not available) the individual may attest to the accuracy of the information. Self-certification is to be used only in an emergency or on an exception basis.

Note: Sponsors may use signed self-certification statements which go beyond the minimum requirements mentioned above. These written statements should be designed to indicate clearly the importance of providing accurate information and the consequences of providing false information. In addition, the project staff should verbally explain this information to the applicant or enrollee.

10. Sources of Information. A single source of eligibility information may be used for documentation purposes if it provides all the necessary information.

11. Maintenance of Source Documents. When the interviewer sees a document which is used to support an applicant or enrollee's eligibility, the interviewer must note the facts on the appropriate form. Although, there is no Federal requirement to maintain originals or copies of the source information, sponsors are encouraged to do so, particularly with regard to income eligibility information. The telephone verification work sheets, which are mentioned in item 7 above, should be maintained.

JAMES H. NORRIS, Chief
Division of Older Worker Programs

PAUL A. MAYRAND, Director
Office of Special Targeted Programs