ADVISORY	:	TRAINING AND EMPLOYMENT GUIDANCE LETTER NO. 15-01
TO	:	STATE WELFARE-TO-WORK CONTACTS STATE WORKFORCE LIAISONS
FROM	:	EMILY STOVER DeROCCO Assistant Secretary
SUBJECT	:	Set of Revised Welfare-to-Work Questions and Answers

1. Purpose. To transmit a set of revised Welfare-to-Work (WtW) Questions and Answers (Qs & As) as official policy to the system; provide guidance and clarifying information to WtW grantees regarding the need for the revisions; describe how the Qs & As are organized and can be accessed electronically; and highlight those Qs & As of particular importance. 

2. Authorities and References.
   

   • Title IV-A and Title IV-D of the Social Security Act (SSA)

   • Personal Responsibility and Work Opportunity Reconciliation Act of 1996 (Pub. L. 104-193)

   • Balanced Budget Act of 1997 (Pub. L. 105-33) amending Title IV-A of the SSA

   • WtW Regulations, 20 CFR Part 645, Final/Interim Final Rule published at 66 Fed. Reg. 2690 (Jan. 11, 2001), effective date: April 13, 2001.

   • Department of Labor Appropriations Act, 2001 (Pub. L. 106-554)

   • Omnibus Consolidated and Emergency Supplemental Appropriations Act, 1999 (Pub. L. 105-277)

   • Title VIII of H.R. 3424, enacted as part of the Consolidated Appropriations Act of FY 2000 (Pub. L. 106-113), which contains the WtW and Child Support Amendments of 1999

   • Workforce Investment Act (WIA) of 1998 (Pub. L. 105-220)

   • WIA Regulations, 20 CFR 667.220 (published at 65 Fed. Reg. 49294 (Aug. 11, 2000))

3. Background. Throughout the start-up and implementation phases of the WtW program, a number of policy questions were raised by WtW formula and competitive grantees, as well as the system's Federal, State, regional, and local partners. Many of these questions and their answers were posted and maintained on the WtW website on an ongoing basis.
   
   The 1999 Amendments changed the WtW program significantly, primarily in the areas of eligibility, allowable activities, and reporting requirements. In order to reflect the changes brought about by the enactment of the 1999 Amendments, all the Qs & As on the WtW website were recently reviewed by an ETA team, and, where appropriate, revised both in content and format. In addition, new Qs & As were developed.
   
   NOTE: The attached revised Qs & As will be posted on the WtW website at http://wtw.doleta.gov on or about the same date as this Training and Employment Guidance Letter (TEGL) is published. At the website's homepage, click on “Policy” and click on "Questions and Answers" in order to access the Qs & As.

4. Information regarding how the Qs & As are organized. The revised Qs & As are formatted in much the same order as they were originally on the website. The subject areas are as follows:

   Section I	General Program (GP)
   Section II	Administration and Fiscal (AF) General Pertaining to Match (AFM) Pertaining to Reporting(AFR)
   Section III	Eligibility (E)
   Section IV	Allowable Activities (AA)
   Section V	Technical Assistance (TA)
   Section VI	WtW and WIA (W/W)

   This TEGL supercedes TEGL No. 5-98 and its attachments, and replaces, in its entirety, the array of questions and answers that, until now, were available and posted on the website. As a result of this revision process, readers will notice that a number of the original Qs & As have been consolidated or moved to other areas so that they are logically grouped with questions and answers of a related topic. Qs & As that continue to contain accurate, albeit outdated, information on the WtW program have been archived, but are available on the website. Finally, those Qs & As that contain information that is inaccurate in light of the 1999 Amendments have been removed from the website. A master index, which identifies the changes made to the original Qs & As, has been developed, and may be accessed by contacting your Grant Officer's Technical Representative (GOTR).   
   
   In addition to the Qs & As that address all of the sweeping changes brought about in the WtW program as a result of the 1999 Amendments, readers are encouraged to give particular attention to and review the following Qs & As that were newly developed or substantially revised and have significant impact on WtW policy. They are:
   
   

   Section II:	Revised 70% minimum/30% maximum expenditure requirement (AF1) Guidance for developing a termination policy (AFR 11)
   Section III:	Expanded definition of "TANF assistance" (E3) Providing WtW services to families sanctioned off TANF (E14) Documentation of eligibility for noncustodial parents (E20)
   Section IV:	Requirement that Local Boards provide certain services through contract or voucher (AA2) 50% hold-back requirement on unsubsidized job placement contracts (AA3) Use of WtW funds for capacity-building (AA6) Use of WtW funds to provide cash payments to participants (AA13) Continued prohibition on using WtW funds for direct cash incentives (AA14 and AA15) Use of WtW funds for transportation and related services (AA21) Use of WtW funds for outreach and recruitment (AA28) Serving youth with WtW funds (AA34)

   The WtW Qs & As will be updated on an ongoing basis. Most supplemental Qs & As added to the website subsequent to this posting will be transmitted via a TEGL and all will be individually annotated with the date of entry, to distinguish them from this attached set of revised Qs & As.

5. Action Requried.  Disseminate the attached Qs & As to appropriate individuals responsible for administering and operating the WtW program.

6. Inquiries. Inquiries on this policy guidance should be addressed to your Grant Officer's Technical Representative.

7. Attachments. Set of WtW Questions & Answers - Revised November 2001.