WorkFirst HandBook
Pathways to Employment
5.2 Limited English Proficiency (LEP) Pathway
The Limited English Proficiency Pathway section includes:
- 5.2.1 What is the LEP Pathway?
- 5.2.2 Who needs LEP Pathway services?
- 5.2.3 Who are RCA recipients and what are their participation requirements?
- 5.2.4 Who are PRUCOL and what are their participation requirements?
- 5.2.5 What is the CE process for LEP parents?
- 5.2.6 Can LEP Parents participate in non-LEP Pathway activities?
- 5.2.7 Who provides LEP pathway services?
- 5.2.8 What steps do you take when a parent is absent?
- 5.2.9 What are LEP Pathway participation activities?
- 5.2.10 Who provides LEP pathway services?
- 5.2.11 LEP Pathway – Step-by-step guide
5.2.1 What is the LEP Pathway?
The Limited English Proficiency (LEP) Pathway provides specialized culturally appropriate services to refugees and other WorkFirst parents with limited English proficiency. The goal of the LEP Pathway is to increase parents' employability and income.
Key features of the Pathway are:
- Use of bi-lingual and bi-cultural services.
- English as a Second Language (ESL) instruction which may be stacked with WorkFirst core activities.
- Specialized employment services such as job readiness training, skills training and job placement assistance.
All LEP parents must be screened for Necessary Supplemental Accommodations (NSA) services and family violence.
5.2.2 Who needs LEP Pathway services?
Anyone receiving cash assistance, who has difficulty understanding or communicating in English, should be referred to the LEP Pathway. This also includes:
- An LEP parent with ESL Level 5 or 6 who is identified by college staff or an employment counselor as needing specialized assistance to participate.
- Individuals receiving Refugee Cash Assistance (RCA) or Refugee Medical Assistance (RMA).
5.2.3 Who are RCA recipients and what are their participation requirements?
Refugee Cash Assistance (RCA) recipients are single individuals or childless couples who meet program income and resource requirements, and whose immigration status allows them to access cash assistance. See WAC 388-400-0030 , 388-466-0150 , 388-466-0005 .
Individuals receiving RCA can receive cash and medical benefits for ONLY 8 months and need immediate intensive job search and job placement assistance. RCA individuals:
- Are referred to LEP Pathway provider as soon as possible
- Are not required to have an Individual Responsibility Plan
- Must have an employability plan developed for them
- Must participate in job search activities
Work participation components for RCA recipients cannot currently be entered in eJAS. LEP Pathway service providers track their participation and progress monthly.
5.2.4 Who are PRUCOL and what are their participation requirements?
The acronym PRUCOL means Permanently Residing Under Color of Law. PRUCOL is not an alien status; it is a term used to define the eligibility of certain aliens for public benefits. PRUCOL includes any alien without official United States Citizenship and Immigration Services (CIS) status who is residing and intends to reside in the U.S. indefinitely and the CIS knows they are residing in the U.S. but does not take steps to enforce their departure. Examples of PRUCOL may include:
- Applicants for asylum.
- Suspension of deportation granted.
- Voluntary departure granted.
For additional information see WAC 388-424-0001 and Eligibility A-Z Manual, Citizenship and Alien Status .
Some parents in PRUCOL status do not have work authorization and should not be referred to an employment provider. They are:
- Excluded from work participation requirements.
- Exempt from CE after completion of foundation section.
- Referred to LEP Pathway for ESL instruction only if their English skills are limited.
- May be referred to legal services for assistance to adjust their immigration status.
- May be referred for participation in appropriate activities that do not require them to have Social Security Number (SSN) or work authorization (e.g. basic education, GED completion, and high school attendance) to prepare for job search and employment later when they receive their work authorization.
To identify PRUCOL cases in eJAS add a PU component code to eJAS component screen and refer to additional services as needed.
5.2.5 What is the CE process for LEP parents?
WorkFirst parents who are identified as LEP are exempt from CE process after completion of the CE foundation section and referred to the LEP Pathway for bi-lingual and bi-cultural services.
5.2.6 Can LEP Parents participate in non LEP Pathway activities?
WorkFirst LEP parents can be involved in activities outside the LEP pathway. The WFS/RSW shall follow the referral process as outlined in the appropriate WF chapter in those cases.
The following activities are examples:
- Community Jobs – CJ
- On-the-job Training – OT
- Vocational Education – VE
- Customized Job Skills Training – PE
- High Wage High Demand Training – HW
Non-core activities that are used to stack with core activities are also encouraged when ESL is not scheduled. These activities can include:
These activities would be reported by the non-LEP pathway contractor or agency and reviewed by the WFPS/RSW.
5.2.7 What are LEP Pathway participation activities?
Parents involved in the LEP pathway should:
- Start their pathway participation activities within 30 days after approval for WorkFirst/RCA assistance, if able.
- Have full-time (32-40 hours) participation in Job Search (JS), Vocational Education (VE), or up to the monthly FLSA maximum but not to exceed 20 hours of Work Experience (WE) or Community Service (XS) within 30 days of their referral to the LEP Pathway employment provider.
- ESL instruction may be stacked with other WorkFirst core activities.
- If at any time during participation, a job becomes available and has been offered to the parent, it is his/her responsibility to accept it, unless there is a good reason to refuse the job. For definitions of "good reason" see WAC 388-310-1600.
- When a person is able, but refuses without good cause to accept a job, a sanction penalty is imposed following the Good Cause process.
- Regular case staffing(s) are encouraged to review participation and progress.
- Anyone with a NSA plan may need more time in the component activity and fewer participation hours to accommodate their additional needs.
- Parents who meet participation requirements are eligible for WorkFirst support services . For more information, see WAC 388-310-0800 .
- Those who are working full time and are still on WorkFirst cash assistance should be encouraged, but not required, to enroll in educational activities along with their employment.
5.2.8 What steps do you take when a parent is absent?
Excused Absences
After two excused absences in a calendar month, the WorkFirst partner/provider will:
- Send an immediate notification to the case worker after 2 excused absences in a calendar month,
- Keep the activity open, and
- Contact the parent and case manager to discuss next steps, including if it is appropriate to refer the client back to DSHS.
Unexcused Absences
After two unexcused absences in a calendar month, the WorkFirst partner/provider will:
- Send an immediate notification to the case worker after 2 unexcused absences in a calendar month to initiate the sanction/good cause process ,
- Keep the activity open, and
- Contact the parent and case manager to discuss next steps, including if it is appropriate to refer the client back to DSHS.
For more on how to treat excused and unexcused absences, please refer to section 3.9.1.5.
5.2.9 When it is appropriate to code ESL as JT in eJAS?
- Use the JT eJAS component code for ESL that is stacked with core activities and indicate in the parent's employment plan that ESL is a skill needed for employment.
- ESL instruction may also be provided as a stand-alone activity until the parent's English proficiency is sufficient for them to participate in core activities. Use the ES eJAS component code for ESL that is not stacked with a core activity.
5.2.10 Who provides LEP pathway services?
The DSHS Refugee and Immigrant Assistance (RIA) Program contracts with LEP Pathway employment and ESL providers to offer direct services to LEP individuals or link those who are eligible with other services in the community.
Refugee & Immigrant Assistance (RIA), located in the ESA Office of the Assistant Secretary also provides and maintains:
- Collaboration with CSD, DSHS partner agencies, local community and government organizations to ensure that services to LEP parents are provided appropriately.
- LEP Pathway policies.
- Contracts with community agencies for employment services, ESL instruction, skills training, work experience, community service, and various social services.
- Training, program monitoring and review.
- Statistical reports and performance measures for the LEP Pathway.
LEP Pathway Providers are contracted through RIA to provide ESL instruction and employment services to LEP Pathway parents/recipients. They:
- Conduct/arrange a Comprehensive Adult Student Assessment System (CASAS) test and determine a person's ESL proficiency level ( ESL Chart ).
- Document the ESL Level and the date of the test in eJAS Demographics Screen.
- Arrange/provide ESL instruction.
- Determine employability and develop an Employment Plan with full-time (32-40 hours) participation.
- Arrange/provide necessary and culturally appropriate WorkFirst employment services.
- Consult with the DSHS WorkFirst Program Specialist (WFPS) and/or Refugee Social Worker (RSW) to change/finalize the parents' Individual Responsibility Plan (IRP)
- Communicate the parent's employment status to the Community Services Office (CSO), document scheduled attendance, actual participating hours and any other changes on a monthly basis in the eJAS.
For a complete list of contracted LEP Pathway providers by region, and their current eJAS contractor codes please see the Provider List .
5.2.11 LEP Pathway – Step-by-step guide
- After assistance is approved, the WFPS/RSW:
- Completes the foundation section of the eJAS comprehensive evaluation.
- Provides family planning and family violence information in the parent's primary language and makes necessary referrals.
- Refers the parent to Refugee Social Worker (RSW)/Social Worker (SW) for intensive services if there are barriers to participation or an emergent issues preventing the parent from completing the CE foundation. The RSW/SW will determine whether the parent needs NSA services.
- Refers the parent to the LEP Pathway contractor, if there are no barriers, for ESL level testing and creation of an Employment Plan:
- Enters LP Indicator and ES component with 0 participation hours for 10 business days. ES component is used to indicate a referral to the employment provider for ESL testing and creation of the employment plan.
- Enters the LEP Pathway contractor code to both the LP and ES components by clicking on the "Add a Contractor" link above the components. (For help with Contractor code click the question mark "?" or use the LEP Providers List.) The ES contractor code is opened to allow the provider electronic access to the case in eJAS, to enter the case notes, and bill RIA for provided services. The LP contractor code is opened to allow the WFPS/RSW to create the initial IRP.
- Creates an Individual Responsibility Plan (IRP) from the LP component for ESL testing and completion of Employment Plan with chosen contractor.
- Creates/completes a referral to the contractor with
- Contractor's agency name and code
- Contact person name and phone number
- Referral type – Participation
- Parent's primary language
- Description of expected specific activities (ESL testing, recommendations for Employment Plan) in Comments section
- Release of information on file, if necessary.
- E-messages the referral to the contractor,
- Prints the referral for the parent and explains that it is parent's responsibility to contact the contractor.
- If the LEP parent is a returner, asks if he/she is already working with a contractor. If yes, generates a referral to this contractor and continues working with the case as usual. When referring the participating parent to a different contractor, notif ies the previous contractor immediately.
- The LEP Pathway contractor
- Makes all efforts to contact the parent as soon as possible to make an appointment.
- Reviews the results of the CE foundation and meets with the parent for a face-to-face interview.
- Conducts/arranges for the CASAS language testing.
- Following local procedures enters the ESL level and CASAS test date on the Client Demographic Screen and in the Client Notes.
- If the ESL level is 1 through 4:
- Accepts the ES component by entering the date when the referral is accepted.
- Reviews together with the parent his/her previous education, training, work history, skills and occupational goals to determine appropriate activities.
- Discusses WorkFirst participation requirements with the parent and develops a written Employment Plan.
- Completes the eJAS Client Notes and e-messages to WFPS/RSW the Note with information about the first meeting, recommends employment activities, and explains why they may be beneficial. Indicates if any of the following activities are recommended:
- Vocational Education or Customized Job Skills Training
- Community Service
- Work Experience
- Community Jobs
- Job Search
- ESL instructions when combined with one of the activities above as a skill needed for employment
- Skills Enhancement training when meeting the 20 hour core participation
- Rejects the ES component within ten full business days if.
- No contact was made (face-to-face meeting with the parent) at the end of tenth full business days.
- Parent's ESL level is 5 or higher, and it is determined that the parent can benefit from mainstream Work First activities. Refer the parent back to CSO by an e-message. Once referred back to CSO, the provider is no longer responsible for this parent's participation.
- The WFPS/RSW
- Discusses the actual participation activities with LEP Pathway provider to reach an agreement;
- Extends the LP indicator code on the Active Component Screen for the duration of the LEP Pathway services in addition to actual activity components;
- Finalizes the IRP and enters the activity components with the actual hours of participation and the provider's 3 digit code;
- Uses the following eJAS component codes for ESL instructions:
- JT if the ESL will be stacked with a core activity
- ES if the ESL will be required as a stand-alone activity
- The LEP Pathway contractor:
- Works with WFPS/RSW to discuss and finalize the suggested activities following the local procedures. Makes sure that the parent is a part of the decision making process.
- Modifies the Employment Plan as needed and schedules the parent for full-time (32 to 40 hours a week) WorkFirst activities using the stacking activities.
- Enters the date the parent began participating in WF activities in Actual Start Date column of Contractor Caseload Screen.
- Documents parent's actual participating hours by keeping daily attendance/timesheets. Documents excused absences in eJAS and states the reason for absence in eJAS Notes. Although not specifically stated in WAC, cultural holidays may be considered an excused absence.
- Reports actual participation hours monthly on the eJAS Contractor Caseload and Multiple Clients Monthly Participation screens between the 1st and the 10th of the following month on the previous month's activities.
- Reports in eJAS any issues identified. Attempts to resolve the issue with the parent and involves the WFPS/RSW immediately when unable to resolve or if the issues are affecting the parent's ability to participate.
- Sends immediate notification to the caseworker within 1 business day once a parent has 2 excused or unexcused absences in a calendar month by using the “Immediate Notify” column in the Contractor Caseload screen, and keeps the activity open. Please refer to section 5.2.8– What steps do you take when a parent is absent?
- Contacts the parent and case manager to discuss next steps, including if it is appropriate to refer the client back to DSHS.
- Sends immediate notification to the caseworker when a parent is unable to participate for the scheduled number of hours. Initiates conversation with caseworker and parent about whether the activity is appropriate.
- Reports employment placement information including job title, employer name, address, contact person, phone, wage rate, average hours worked per week, medical benefits and employment start date on the eJAS Client Note screen and through an eMessage.
- Monitors employed parents for a minimum of 90 days following job placement.
- The WFPS/RSW:
- Continues to monitor the LEP Pathway case.
- Addresses any rejected referrals (ESL level 5 and 6):
- Explains to the parent mainstream WorkFirst participation requirements.
- Completes the comprehensive evaluation process through partner agencies.
- Documents in eJAS Client Notes reasons for an exception to policy if the mainstreamed LEP parent is identified by college staff/ESD as not proficient enough in English and referred back to CSO. Refers parent to LEP Pathway Provider for Employment Services.
- Updates the Individual Responsibility Plan (IRP) and eJAS with any activity changes as follows:
- Updates activity components and enter provider's 3 digit code (Providers List) in eJAS Active Components screen to give the provider access to the case record.
- Updates or creates a new IRP, if necessary, and has the parent sign it.
- Documents scheduled WorkFirst activities in eJAS LEP notes.
- Notifies the provider of changes in the parents' participation requirements so that Employment Plan can be updated.
- Reviews the Contractors Caseload and Monthly Participation screens for monthly reporting. If the provider is not reporting as required, contacts the RIA regional program manager who will work with the provider on any issues.
- Reviews the case every 90 days for participation and progress. The participating parent may be reassigned to a new provider if the WFPS/RSW believes progress will not be made with the current provider. Notifies the previous provider immediately about the change and indicates the reason for it.
- Notifies the LEP provider if the parent moves to different address outside of the CSO area or has been referred to a different contractor and indicates why.
- Updates the eJAS Employment screen as soon as possible with employment information received from provider.
- Ensures the ACES ERN screen is updated.
"PT" and “FT” components for LEP Pathway parents always need a 3 digit provider code to allow the provider an eJAS access to the case for additional monitoring and reporting. When closing Work First case, remember to leave the eJAS case open for another 4 months from the date of TANF closure.
Resources
Related WorkFirst Handbook Sections
- 1.2 Required Participation
- 1.4 First WorkFirst Engagement
- 2.2 Support Services
- 3.3.1 Individual Responsibility Plan
- 3.3.2 Stacking Activities
- 3.6.1 Sanctions
- 7.1 Education and Training Overview
- 7.2 Vocational Education
- 7.3 Basic Education, Skills Enhancement, High School/GED
- 8.3 Community Jobs