Attachment A


Questions and Answers Regarding the TANF Summer Youth Program


  1. Will there be TANF funds available for Summer Youth Employment and Training programs?
    Yes, $15 million in TANF Surplus funds have been made available to local workforce investment areas to run a Summer Youth Employment Program. The budget appropriation language for the TANF summer program allows local areas to provide services to needy families whose income does not exceed 200% of the federal poverty level.

  2. What are the start up and end dates for the program?
    The Summer Youth program is conducted during the summer vacation months. The funding for the Summer Youth program is available for expenditure from May 1, 2004 through September 30, 2004.

  3. How will funds be allocated to the local workforce investment areas?
    Funds will be distributed based on the WIA Youth Allocation Formula. Please see Attachment B for allocations by area.

  4. Who, at the local level, will be recipients of the funding?
    As established under the Workforce Investment Act, the chief elected official in a local area is the local grant recipient. The entity that has been designated as the fiscal agent for the WIA Youth funds will serve as the fiscal agent for the TANF Summer funds.

  5. How will local areas be able to draw down the TANF funds?
    Local Areas will continue to utilize the same cash draw down procedure currently used.

  6. Are there any cost limitations associated with the TANF Summer Youth Program Funds?
    Yes, not more than 15% of the funds made available may be used for program administration. Examples of administrative costs include: salaries and benefits of staff performing administration and coordination functions; preparation of program plan, budgets, and schedules; and monitoring of programs and projects.

  7. How are these funds intended to be used?
    These funds will be utilized in accordance with both the first and third stated purposes of the TANF Block Grant which are: to provide assistance to needy families; and to prevent and reduce the incidence of out of wedlock pregnancies by engaging youth in meaningful activities.

  8. When will local planning guidance be issued and when will local plans be due for this summer program?
    This will serve as the local planning guidance. No other planning requirements will be necessary.

  9. What specific activities can be funded under this program?
    Allowable activities under TANF are:

  10. How will local areas determine eligibility for the TANF Summer Youth Program?
    Locals can utilize the income up to 200% of the federal poverty level provision allowable under the TANF state plan. If the local area has a process in place for determining eligibility for this youth summer employment program, that process can be used instead of the TANF Youth Services Application/Certification forms. If such a process is not in place, eligibility will be determined using the TANF Youth Services Application/Certification. (The forms are attached to this technical advisory.) TANF prohibits the automatic eligibility of individuals based on JTPA definitions of family of one for individuals with disabilities and individuals in foster care. Notwithstanding the JTPA definitions, these individuals may be determined eligible in the TANF Summer Youth Program based on family income of up to 200% of the federal poverty level.

  11. Are individuals in foster care eligible for services based on their foster care status?
    These individuals are not considered categorically eligible for services under this funding stream. However, these individuals could be considered as household of one for eligibility purposes and, therefore, only the youth’s income would be reported for eligibility. It should also be noted that a foster child does not need a plan to return home to be eligible for services.

  12. Is there an age limitation for youth that can be served under the TANF program?
    Yes. Only TANF eligible youth under 21 may be served with TANF funding.

  13. Must participants of the TANF Summer Youth Program be eligible to receive TANF benefits/cash assistance?
    No. The appropriation language allows this funding to support not only those in receipt of benefits/cash assistance but also those eligible youths whose incomes are up to 200% of the federal poverty level.

  14. What are the eligibility criteria for TANF 200% Non-Assistance Programs?
    Participants must meet the all requirements outlined below.

  15. What are the 200% of Poverty Standards for PY 2003 that must be utilized in determining eligibility?

    Family SizeAnnual Income
    1$ 18,620
    2 $ 24,980
    3 $ 31,340
    4 $ 37,700
    5 $ 44,060
    6 $ 50,420
    7 $ 56,780
    8 $ 63,140

    PLEASE NOTE: For family units with more than eight members, add $6,360 for each additional family member.

    Please note: Poverty guidelines for program year 2004 must be utilized for the 2004 TANF Summer Youth Program. The attached Local Commissioners Memorandum titled TANF Services for Individuals and Families with Incomes up to 200% of the Federal Poverty Level, dated September 27, 2000 includes additional information concerning TANF services. Poverty Income Standards are also detailed in Technical Advisory #04-1 Poverty Guidelines for 2004.

  16. Is there any way that minors in independent living with no plan to return home can receive TANF services?
    Yes, this population may be eligible for services that would fall under the TANF purpose of preventing and reducing the incidence of “out of wedlock” pregnancies. All Department of Labor programs meet this purpose, allowing minors living on their own to qualify for services if they meet all other eligibility requirements.

  17. Are youth aged 18 (not in school), 19 and 20 eligible for TANF services if they do not reside in a household with a minor child?
    For Department of Labor programs, youth aged 18 (not in school), 19 and 20 may receive services without regard to a minor residing in the household. The youth must meet all other eligibility criteria.

  18. If a 18 year old (not in school), 19 or 20 year old applicant for TANF services lives with his or her parents and minor siblings, whose income is counted in the eligibility determination?
    The income of the 18 year old (not in school), 19 or 20 year old as well as the income of his or her parents and minor siblings is counted in the eligibility determination. If the total income exceeds 200% of the federal poverty level, the applicant is not eligible for services. Please note that the TANF Youth Services Application (Attachment H) has been revised to clarify that the earned income of those under 18 or 18 and attending high school should not be included in the calculation. The income of individuals (applicants) aged 18 who are not in school, 19 or 20 years old must be included.

  19. Is an individual with a disability whose own income meets the requirements of economically disadvantaged but who is a member of a family whose income do not meet such requirements eligible for services as a “family of one?"
    No.

  20. Can youth with alien status be served under this TANF Summer Youth Program?
    Certain aliens are not eligible to receive services supported by TANF funding. Therefore, procedures are to be implemented to check citizenship/immigration status. Desk and client aides are available as Attachment C of this Technical Advisory. Where appropriate, referrals of aliens can be made to other programs for youth employment assistance. WIA funds can be used to provide services to lawfully admitted permanent resident aliens, refugees, asylees, and parolees, as well as any other immigrant authorized by the Attorney General to work in the United States.

  21. What forms should be used for application and intake?
    If the local area has in place a process that accurately determines eligibility for this youth employment program, that process can be utilized in place of the TANF Youth Services Application (Attachment H). The attached TANF Youth Services Application form must be used to establish eligibility if a process is not in place to determine eligibility otherwise. If the local area elects not to use the TANF Services Certification forms, the attached citizen status form (see Attachment C) must be signed by the counselor or intake person and the applicant verifying the applicants citizen status. If participant attestation is used to determine income eligibility standards, parents will need to sign an income eligibility document. Please note that Attachment I may only be used if the youth is receiving one of the benefit programs (i.e. Family Assistance, Medical Assistance, etc.) and was born in the United States. If both of these requirements are not met, either the TANF Youth Services Application or the TANF Services Application/Certification form must be used.

  22. What is the fiscal reporting responsibility of the local area?
    Areas must be prepared to report expenditures on TANF allowable activities on a monthly basis. The attached forms 3184A – Standard State Agency Claim Form, Assistance and Administration Relating to TANF Summer Youth Employment Programs and 4727A – State Agency Report on TANF and TANF Maintenance-of-Effort Programs (Attachment D & E) must be utilized for this purpose. These reports are due on the 20th day of the month following the month of expenditure. Local fiscal agents must adhere to OMB Circular A-87 for allocating costs. Final fiscal reports showing all funds expended must be received by NYSDOL and the LWIA must have received cash to equal their reported expenditures by December 1, 2004. Unexpended funds will be deobligated at that time. Please note: TA #01-18.1 details the policy for timely and accurate submission of financial reports.

  23. When is the program report due and where should it be sent?
    Attachment J should be used to accommodate the submittal of program data. It should be completed to reflect total program data and submitted with the final Expenditure Report Form (3148A) and Report on TANF and TANF Maintenance of Effort Programs (DOL-4727A) by December 1, 2004, to:

    Robin Holmes
    NYS Department of Labor
    Workforce Development and Training
    State Office Building Campus
    Building 12, Room 425
    Albany, NY 12240

  24. What are the performance requirements?
    Each local area shall establish written program goals and objectives, such as:

    Monitoring for this program will include quality indicators for the established goals and objectives in addition to compliance. It is expected that local areas will provide innovative, performance driven programs to meet the needs of the targeted population and the employment needs of local businesses.

  25. Who will provide oversight for the program?
    The NYSDOL’s Workforce Development and Training Division will have oversight and monitoring responsibility. Therefore, your current State Representative will perform all program oversight reviews, and your Financial Oversight and Technical Assistance representative will advise you on fiscal matters.

  26. Can WIA and TANF Funds be blended for direct program costs?
    LWIAs must consider both the cost allocation and program/performance implications in blending the TANF funds with the WIA funds. If $1 of WIA money is spent on a youth, WIA performance must be reported. Direct program staff funded with both WIA and TANF will require all youth to be counted in WIA performance. However, you will be allowed to fund direct program costs exclusively to TANF funds even when the wage subsidies are paid by both TANF and WIA funding. The exception to this scenario is when the WIA enrollee is not TANF eligible such as, when they do not meet the alien or age requirements of TANF. Direct program costs would include staff time such as, for counselors, supervisors, case managers, etc. who will provide direct service to youth.

  27. Can wage subsidies be blended with both TANF and WIA funding?
    Yes. The LWIAs can choose which funding source will pay for the wage subsidies for the summer youth program. LWIAs can plan on using WIA funds to support only those summer youth that are WIA eligible and expected to continue in WIA year-round youth programming, and follow-up services or youth not eligible for TANF services, but WIA Eligible, and therefore, will be counted in the WIA performance outcomes/measures.

  28. Can a counselor provide job search counseling to 10 kids – 5 TANF programs and 5 WIA funded, and allocate those costs?
    According to OMB Circular A-87, this would be allowable. Performance outcomes would be for only those that have been enrolled in WIA.

  29. Can administrative costs be blended?
    Normal administrative costs must be cost allowed in conformity with OMB Circular A-87.

  30. Will local areas receive these funds next summer?
    These TANF summer funds are not meant as a permanent long-term solution to the changes in youth programming under WIA. Local areas should utilize the TANF funding as an opportunity to offer additional services that complement their year-round comprehensive program for youth.

  31. What is the Summer Youth Program 200% Provider Certification Agreement?
    The agreement outlines provisions of program implementation that the operator must concur with and implement. The form should be printed, signed and submitted by July 1, 2004. Send signed agreements to:

    Robin Holmes
    NYS Department of Labor
    Workforce Development and Training
    State Office Building Campus
    Building 12, Room 425
    Albany, NY 12240

  32. When a minor who is part of a public assistance household earns wages through a summer youth employment program do these wages impact the family’s eligibility?
    No, wages earned by a minor through a summer youth employment program are exempt and disregarded as income and resources in determining continued eligibility for public assistance.

  33. How can the receipt of HEAP be used to determine income eligibility?
    If the individual has received a HEAP benefit since the previous November 1, then they would be considered income eligible for 200% purposes.

  34. The TANF Services Certification form requires a signature in Section Four. Who may sign this application?
    The application must be signed for all minor youth. If the minor youth resides with a parent or caretaker, that individual should sign the application. If the youth applicant does not reside with a parent or caretaker/relative, the applicant must sign the application.