Welfare-to-Work (WTW) Plan Student Training and Education Program (STEP) Provisions

Effective January 1, 2021, Senate Bill (SB) 1232 provides program flexibility to CalWORKs WTW participants who are enrolled full-time or part-time at a publicly funded or non-profit (henceforth referred to as publicly funded) post-secondary institutions of higher education, such as community colleges, technical schools, 4-year colleges or universities, as well as adult education and adult schools. SB 1232 provisions also apply to online schools that meet the definition of a publicly funded post-secondary institution of higher education, even if the actual institution is located out-of-state.

Effective January 1, 2023, SB 768 made changes to the program established by SB 1232.  The program established by SB 1232 and impacted by the passage of SB 768 is now known as the Student Training and Education Program (STEP).   

Policy

SB 1232 allows participants to enroll in Adult Education, English as a Second Language (ESL),  High School Diploma (HSD), General Educational Development (GED), Associate’s, Bachelor’s, Master’s, Doctor of Philosophy (PhD), teaching credential, and undeclared major/certificate programs. The Associate Employment Counselor (AEC)/Employment Counselor (EC) is to follow current procedures for participants enrolled or enrolling in private for-profit post-secondary educational institutions (non-SB 1232), which include following existing criteria for Self-Initiated Program (SIP) and In-house Assessment processes.

Determining STEP Eligibility for Private Nonprofit Educational Institutions

Private-nonprofit educational institutions are eligible for STEP provisions.  A private/nonpublic postsecondary educational institution is a qualifying STEP school if it meets all of the following:

• It grants undergraduate degrees and/or graduate degrees.
• It is recognized as a nonprofit organization
  • The federal government defines nonprofit organizations, also referred to as a 501 (c)(3), as charitable organizations that serve “tax- exempt purposes.”  Confirmation of whether an educational institution is a 501 (c)(3) can be verified with the school or by searching the name of the institution using the  Internal Revenue Service (IRS) Federal Tax-Exempt Organization Search Tool.
     
• Is accredited by an agency recognized by the U.S. Department of Education.
  • The U.S. Department of Education Database of Accredited Postsecondary Institutions and Programs can be used to check the accreditation status of a postsecondary institution or program.

Identifying Eligible Adult Schools

Adult Education and Adult Schools administered by a community college and/or funded by the Adult Education Block Grant are considered publicly funded post-secondary educational institutions for STEP eligibility purposes.  Since they are not considered private schools, they do not need to meet the criteria listed in the section above, including being accredited.  If the AEC/EC is unsure of whether an adult school is STEP- eligible, they can refer to California Adult Education-Find a School , as it lists all STEP-eligible adult schools and providers in California.

Massive Open Online Courses (MOOCs)

MOOCs are online classes that are designed for unlimited participation, massive numbers of students, and free, open access via the internet.  A MOOC is often a third-party provider company hosting content from educational institutions, and the MOOC itself would not be considered a qualifying entity for STEP.  However, the educational institution providing the curriculum might be considered a qualifying entity for STEP.  The AEC/EC must determine whether the WTW participant is considered enrolled at a qualifying educational institution.  If the participant can provide proof of enrollment at a STEP-qualifying educational institution that has partnered with a MOOC to offer one or more online courses, they would qualify for STEP provisions.

 ExampleExampleCoursera is a for-profit company that is not a qualifying educaitonal institution.  However, Coursera often partners with STEP-eligible educational institutions to offer courses.  In some instances, individuals may take courses through Coursera which are offered by qualifying educational institutions, but the individual is not considered registered/enrolled at said institutions.  If the participant is solely registered/enrolled through Coursera (or another non-STEP-eligible provider) and is not considered enrolled at a qualifying educational institution, then they would not qualify for STEP.

National Educational Website

If the AEC/EC is unsure of whether a school is classified as a public or private/for-profit, the AEC/EC may navigate to the National Center for Education Statistics (NCES) website and enter the name of the school to determine the school classification.

Orientation & Appraisal

SB 768 establishes that a CalWORKs STEP participant must not be required to participate in Orientation & Appraisal and Online CalWORKs Appraisal Tool (OCAT) procedures more than once unless that participant has had a break of one year or more in receiving aid or supportive services.  To familiarize participants with the supportive services available to them and to help identify any potential barriers to participation, it is highly encouraged that STEP participants participate in Orientation & Appraisal by following existing Orientation & Appraisal/OCAT procedures.  

Noncompliance shall not be initiated for failure to attend Orientation & Appraisal for any STEP participant who has had a break of less than one year in receiving CalWORKs cash aid or supportive services and chooses not to attend Orientation & Appraisal.

STEP participants who are returning to CWES after 6 months but less than one year after a break in aid will automatically be included in the Cal-OAR denominator for the OCAT/Appraisal Completion Timeliness rate.  To ensure that these STEP participants will be successfully counted in the denominator and numerator of the measure, the AEC/EC will add an Appraisal activity in CalSAWS and select [Completed] in the Status field and select [Completed Satisfactory] in the Status Reason field without having to readminister it, if it was administered prior to the break in aid.

Assessment

STEP participants are not required to have their educational program approved by an Assessment Counselor. The assigned AEC/EC is to approve the field of study. In addition, the participants are not subject to approval of their educational program based on the list of approved majors nor are they subject to Assessment testing for the purpose of approving a program.

A participant’s choice of post-secondary education courses or fields of study in publicly funded, post-secondary educational institutions cannot be denied, including when the educational program is not expected to lead to employment. The AEC/EC may advise clients about the job potential of their chosen educational path, considering relevant factors including but not limited to, labor market conditions, High Paying In-Demand Careers (SCD 2621), the client’s individual work and educational history, and any criminal background that would impact employability.

Assessment will be conducted only to identify barriers to participation, such as domestic violence, substance abuse, mental health, and learning disability. Assessment can also be used to assist clients with career exploration, High Paying In-Demand Careers (SCD 2621), identifying bridging activities, or assisting a part-time student with identifying a concurrent activity. As an option, the Assessment can be done via phone or electronic means.

Note: Participants who intend to enroll in a community college or adult education program may be referred to an off-site assessment at the educational institution where they plan to enroll.  This will serve as a bridging activity that allows the participant to obtain assistance with enrolling in the classes needed to meet their educational goals.

Proof of Enrollment

Verification of enrollment is required prior to signing a WTW Plan and issuing transportation, diaper and supportive service payments. For STEP participants, a signed WTW Plan is not required to issue Advance Standard Payment (ASP) for required books and college supplies, as long as proof of enrollment is provided. Proof of enrollment includes a class schedule that shows the number of academic units or instructional hours. When the class schedule is not available, and there are other documents, such as a school-developed stage/mock plan, enrollment welcome letter, or email from the school indicating enrollment, the AEC/EC is to act upon the verification to calculate the correct ASP for books and supplies.

Other information such as a comprehensive conversation with the client can be documented to help the AEC/EC develop the WTW Plan, when no other information or documentation is available. As additional information becomes available, the WTW plan can be amended. No stage plan/mock plan is necessary when any proof of enrollment is provided to develop the WTW 2 with the required hours of participation.

The community college liaison will also provide an education plan, which is to be utilized by the EC to help develop the WTW Plan.

Note: The STEP policies take effect at the point that the client provides proof of enrollment in the publicly funded post-secondary educational institution.

WTW Plan

The duration of the WTW Plan will be developed in alignment with the duration of the Educational Plan. The WTW 2 will specify the number of required hours (20, 30, or 35), the number of units, class times, times for online courses (as applicable), and study time computation. The WTW Plan will also include in the Additional Comments section: “Follow the class schedule,” where applicable.

If an Educational Plan is not provided by the STEP educational institution, the WTW Plan should be created for a duration of no more than 12 months. 

WTW Plans can be provided and signed electronically. A new WTW Plan will be developed no later than 30 days prior to the beginning of the school term when:

• Signing an initial WTW Plan for an educational activity
• Change in status from full-time to part-time; from semester to quarter, or vice versa
• Changes in career goal or major.

Note: If a new WTW 2 is not provided to the client by 30 days before the start of the subsequent school term, the previous WTW 2 will remain in effect and the previous ASP for required books and college supplies will be used for the subsequent school term.

When a STEP participant’s CalWORKs hourly participation requirements change, the AEC/EC must engage the participant as soon as possible and adjust their WTW Plan, as necessary, to reflect any change in participation requirements.  

ExampleExampleA single parent with a child under six years old (20-hour weekly CalWORKs participation requirement) is attending six units for a total of 24 weekly STEP hours, including study time.  During the school term, the youngest child turns six, increasing the participant's weekly CalWORKs participation requirement to 30 hours per week.  In this example, the assigned AEC/EC should engage with the participant as soon as possible to determine how they will meet the new CalWORKs hourly participation requirements in addition to their STEP activity.  Once it is determined how the participant will meet the additional hours, the participant must sign a new WTW 2 form, which includes the new required hours (30) and the activity(ies) they will participate in to meet those requirements.

Homework Study Time

Homework study time under SB 1232 can be supervised or unsupervised and is deemed by adding three hours of study time for each class unit. The study time is to be embedded within the WTW 2 and in CalSAWS for the appropriate educational activity: Vocational Training. Verification of study time is not required. The study time can be more than 3 hours per unit, if the school prescribes it, such as for a student who has a learning disability. When the class unit is a unit fraction, round up to the nearest unit. Example: 0.5 unit is rounded up to 1.0 unit. Classes such as labs, guidance classes, or physical education classes are covered under all STEP provisions.

SB 768 establishes that a part-time STEP participant’s hourly participation may be calculated using either academic units or instructional hours interchangeably.  
When calculating a STEP participant’s participation hours, an instructional hour is defined to mean class time of 50 minutes.  
When classes are non-credit/non-units, three hours of study time for each instructional hour is allowed.

The number of units for noncredit courses cannot be used in the calculation of study time for online courses. To determine participation hours, the AEC/EC should review the same class that is offered in-person to determine the instructional hours. Once the instructional hours are known, the study time calculation can be computed.

Note:  Unsupervised study time is to continue to be used for only private, for-profit schools and is to be embedded within the appropriate activity on the WTW 2. Unsupervised study time cannot exceed one hour for each hour of class time.

Participation

A STEP participant who is enrolled full-time is deemed to be meeting participation requirements.

Students attending part-time may need to be assigned a concurrent activity if the class units and study time do not meet the minimum participation requirements. The client can propose a concurrent activity from the full array of WTW activities or be referred to in-house Assessment for assistance in identifying the concurrent activity.

SIP rules do not apply under STEP provisions. In a two-parent household, each parent can attend school and share the 35 total weekly participation hourly requirement.

Example: For an AU of 2. Parent 1 is enrolled in two non-credit/non-unit courses at DeAnza Community College. Each course is 3 hours in instructional time. Instructional time is 6 hours = (2 X 3). Study time is 18 hours = (6 X 3). Total participation is 24 hours = instructional time (6) + Study time (18). Parent 2 is enrolled at San Jose City College in one 3-unit class. Study time = 9 (3 X 3). Total participation is 12 hours = (3 + 9). The combined weekly participation hours for Parent 1 (24) + Parent 2 (12) = 36 hours.

Participation During School Breaks

School breaks are defined by the educational institution and include breaks both within and between terms.  For example, spring and Thanksgiving breaks typically occur within a given academic term, while winter and summer breaks typically occur between academic terms.  Transfer periods from one qualifying educational institution to another also qualifies as a school break if the transfer period falls between adjacent school-year terms for which enrollment and/or admission verification has been provided.

SB 768 establishes that STEP participants must not be required to participate in WTW activities during school breaks to satisfy the educational hours portion of their WTW hourly participation requirements; however, they should be encouraged to participate in voluntary WTW activities to maximize the benefit of CalWORKs programs and associated supportive services.

Part-time STEP participants who were assigned a non-STEP activity to fulfill their hourly participation requirements must continue participating in those activities during school breaks.  

STEP participants who choose to participate during school breaks must be treated like other voluntary participants in that they must be provided with all necessary supportive services to enable their participation and will not be subject to noncompliance and sanction for any failure to participate.  

To ensure that STEP participants who are not participating during school breaks, such as summer or winter breaks, are captured in the Cal-OAR Engagement Rate, the AEC/EC must enter one participation hour in the CalSAWS Vocational Training activity.  A Journal Entry must be added to the Journal Detail page in CalSAWS. 

If the AEC/EC has not received proof of enrollment by the start of the subsequent term, they must contact the STEP participant to confirm whether they intend to continue with their education activity or need to be assigned a new activity(ies). 

The participant has 30 days from the start of the subsequent term to submit verification.  If, by the 30th day after the start of the subsequent term, the participant has not provided proof of enrollment, or the AEC/EC has been unable to obtain the proof of enrollment from the CalWORKs Liaison at the school, then the AEC/EC may initiate noncompliance.

Establishing Academic Session Type for Adult Schools

To determine whether school enrollment is considered a semester or quarter term, the term is based on the duration of the academic session. A client enrolled in an adult program for 13 weeks or less is equivalent to a quarter term. Enrollment for any period exceeding 13 weeks is to be treated as a semester term.

For clients who enroll in an adult school mid-session, their quarter/semester determination and Advance Standard Payment(ASP) should be determined based on the number of weeks they are enrolled instead of the number of weeks of the full-term course.

Example: A client who enrolls in a 16-week adult school course during the fifth week of the session would be enrolled in the course for 12 weeks, thus they would be considered enrolled in a quarter system, and would be eligible for the appropriate quarter system ASP. If the client decides to enroll at the same adult school during the following session for a full 16-week educational session, they would be considered enrolled in a semester school system and eligible for the appropriate SB 1232 semester-based ASP.

Full-Time/Part-Time Enrollment Status

Adult school enrollment status is based on the number of instructional hours a client is enrolled per week. A participant who is enrolled in classes requiring 12 or more instructional hours per week is considered full-time. Enrollment in less than 12 instructional hours per week is considered part-time. A client who is enrolled in an academic session lasting less than 8 weeks is considered part-time, regardless of the number of instructional hours required for their classes.

To calculate instructional hours for clients enrolled in self-directed courses at adult schools, the AEC/EC will go based on the expected number of hours per week for the course as documented in the client’s course syllabus.

Reminder: An instructional hour is defined as class time of 50 minutes.  

Example: A STEP participant is taking two semester term courses at an adult school that does not use academic units and whose proof of enrollment does not indicate whether they are enrolled full- or part-time.
Course A meets for 50 minutes, three times a week.
50 minutes multiplied by 3 classes = 150 minutes of weekly class time.
150 minutes divided by 50 minutes (an instructional hour as defined) =
3 weekly instructional hours.
Course B meets for 80 minutes, twice a week.
80 minutes multiplied by 2 classes = 160 minutes of weekly class time.
160 minutes divided by 50 (an instructional hour) = 3.2 weekly instructional hours.
Therefore, the STEP participant in this example is enrolled in a total of 6.2 instructional hours (3 for Course A, plus 3.2 for Course B) this semester. This is less than a total of 12 weekly instructional hours and is considered part-time enrollment.

In instances where a STEP participant is enrolled in an adult school that allows them to determine their own schedule and there is no other way to confirm either full-or part-time enrollment, the AEC/EC must base the part-or full-time enrollment determination on the STEP participant’s signed Welfare-to-Work Plan Activity Assignment (WTW 2).  The AEC/EC should meet with the STEP participant, review relevant school information such as course catalog, syllabus and class schedule, and use that information to come to an agreement about the STEP participant’s estimated weekly participation hours.  The estimated weekly participation hours would be entered into the WTW 2 plan and used to determine whether the participant is attending full- or part-time.  

If the AEC/EC is unable to obtain a signed WTW 2 at least 10 days prior to the start of the adult school course(s), the county should issue the adult school STEP participant a part-time Advanced Standard Payment (ASP).  If the STEP participant subsequently signs a WTW 2 confirming full-time enrollment, the AEC/EC must issue a supplemental payment to equal a full-time ASP.  The supplemental payment, equaling the difference between the part-time and full-time ASP, must be issued within 10 days of the WTW 2 being signed.  

Supportive Services

STEP students are entitled to the full array of services including Ancillary, Transportation, Diaper, and Child Care supportive services.

Advance Standard Payments (ASPs) for Books and Supplies

WTW participants attending a publicly funded educational institution of higher education are to receive an ASP per term based on their enrollment status. The payment covers required books and college supplies and must be issued 10 calendar days prior to the beginning of each school term. Receipts/estimates are not required for the ASP.

The participant should have a signed WTW Plan on file, or proof of enrollment, with information to calculate correct payment based on school status of full-time/part-time and type of term (quarter/semester) to be advanced one of the following ASP amounts when:

• Enrolled full-time in a semester term: $500
• Enrolled full-time in a quarter term: $350
• Enrolled part-time in a semester term: $250
• Enrolled part-time in a quarter term: $175
• Enrolled in Winter Intersession term(s): $175
• Enrolled in Summer full session issue $350
• Enrolled in Summer condensed sessions issue $175 per condensed session.

If a student requires additional ancillary funds for required books and/or supplies, then receipts and estimates using the Ancillary Expenses Estimate, Request and Verification (SCD 1584) are required. Students can network with their community college liaison to better gauge the total cost of required books and college supplies.

Summer Session Advance Standard Payments (ASPs)

SB 768 codified that for the purpose of STEP, summer sessions must be counted as quarters.  STEP participants who are enrolled in summer sessions are eligible to receive an ASP based on their enrollment status during the summer session.

Clients enrolled in a summer session lasting the duration of the summer term as determined by the educational institution (typically around 12 weeks) are eligible for $350 for full-time enrollees and $175 for part-time enrollees regardless of whether the educational institution adheres to a semester or quarter system during the normal school year.

Clients enrolled in a condensed summer session (less than the full summer term offered at the educational institution) must be provided an ASP of $175 per condensed session, regardless of their full-time or part-time enrollment status. A client who is enrolled in two condensed summer sessions is to receive two payments of $175.

Winter Intersessions

Clients enrolled in winter intersessions are entitled to receive a $175 Advance Standard Payment (ASP) regardless of their full-time or part-time status and regardless of whether the school follows a semester or quarter system. Clients enrolled in winter intersessions are considered to be meeting their hourly WTW participation requirements.

Enrollment in Multiple STEP Eligible Institutions

WTW participants may be enrolled simultaneously in multiple STEP eligible institutions. In cases like this, the AEC/EC must calculate the total number of units and/or instructional hours across all STEP eligible institutions to determine the client’s enrollment status and the appropriate Advance Standard Payment (ASP) amount.

Participants determined to be enrolled in 12 or more units/instructional hours are considered full-time. Enrollment in less than a total of 12 units/instructional hours is considered part-time. If a participant is simultaneously enrolled in a quarter and semester-based STEP eligible institutions, the AEC/EC is to issue the appropriate semester-based ASP. The maximum ASP a STEP participant can receive for the duration of an academic session is $500 regardless of the number of academic units/ instructional hours they are enrolled in.

Issuing the Advanced Standard Payment (ASP)

AEC/EC Staff will advance the standard ASP for required books and supplies directly to the client using the DSRC 147628 listing. The listing will be generated once prior to the beginning of schools that operate under the semester system, and once for schools that operate under the quarter system. CWES staff is to follow the payment process below.

The assigned Management Analyst (MA):

• Receives and validates the DSR 147628 report
• Saves finalized reports in the Saved Drive.
• Updates the report as needed.

The AEC/EC:

• Retrieves listing and verifies the participating students are enrolled and eligible for payment.
• A minimum of 10-days prior to the new semester or quarter, creates a Need and Service Arrangement in CalSAWS. Selects Ancillary-Education for the Category and Advanced Standard Ancillary Payment for the Type payment drop-down menus and enters “SB 1232” in the Description field of the Need Detail page. On the Service Arrangement Detail page, in the Service Type Description field, enters “books and supplies for Fall part-time 2024"
• Enters a CalSAWS Journal Entry to include, “Ancillary for required books and educational supplies advanced per SB 1232 for Fall part-time semester 2024."  Ancillary for required books and educational supplies advanced per SB 1232 for Fall 2024 part-time semester. 

Note: AEC/EC does not need to wait for the DSR listing to be issued to make an educational ancillary payment. If the client is enrolled in an eligible STEP educational institution, the AEC/EC may issue the ASP at least 10 days prior to the start of the new quarter/semester.

Additional Payments

For additional amounts over the ASP, the assigned AEC/EC will create a Need and Service Arrangement in CalSAWS, and approve subsequent payment(s) within 20 calendar days of the client request(s) and the provision of receipts and/or SCD 1584. Verification of the actual costs associated with the initial ASP must be provided to the assigned AEC/EC prior to issuing the additional ancillary payment(s), in addition to providing the receipts for the additional payment.

The assigned AEC/EC will also issue the difference in the standard payment amount when the client’s enrollment status changes from part-time to full-time during the current term.

The AEC/EC is to review the CalSAWS Issuance History page and Journal Entries prior to issuing the payment to ensure the correct payment is made.

Note: Repayment of school loans and tuition are not allowed as an ancillary expense.

Late Payments

The student is eligible for the ancillary payment at any point in time during the quarter or semester. When the initial ASP for required books and supplies cannot be issued timely to the client, such as for students who enroll late or for students who did not provide proof of enrollment timely, the assigned AEC/EC will create a Need and Service Arrangement in CalSAWS, and approve the standard initial payment to the client. The payment will be made within 10 calendar days of proof of enrollment received.

The AEC/EC is to review the CalSAWS Issuance History page and Journal Entries prior to issuing the payment to ensure the correct payment is made.

Overpayments

Overpayments do not apply if the actual cost of required books/college supplies was less than the ASP, or if the student’s enrollment status subsequently changes to part-time during the term. As long as the student was eligible at the time of payment, there is no overpayment.

Overpayments exist if clients receive a payment for which they were not eligible. The assigned AEC/EC is to ensure that the educational activity in CalSAWS is in the correct status prior to the beginning of each school term. When a WTW participant is no longer attending school, ensure that the appropriate educational activity is in a closed status.

Satisfactory Progress

Satisfactory Progress measurement is determined by the schools, which is based on the ability of the student to enroll in the subsequent school term. A participant is satisfactorily participating if verification of enrollment is provided at initial enrollment or provided at the beginning of each subsequent school term. GPA does not apply for the purpose of measuring satisfactory progress for STEP students.

Once a student provides proof of enrollment in the publicly funded postsecondary educational institution, they are considered a STEP participant from that moment, through the term of enrollment, and through any immediately following school break.

Example: A STEP participant enrolled in a Spring semester that is immediately followed by a summer break is enrolled in STEP until after the start of the following Fall semester unless they inform, or the county becomes aware, that they have opted not to continue their STEP activity.

SB 1232 Informing Notice

The SB 1232 Informing Notice (SB 1232) provides information to WTW participants who are interested in postsecondary education and advanced standard payments for books and supplies at an approved school.  The AEC/EC can manually generate and issue the SB 1232 Informing Notice in the Template Repository Search page of CalSAWS.  The AEC/EC can determine when and which client should receive the notice, as not every client will require it.

SCD 1755A

As part of county policy, the Attendance Verification (SCD 1755A) is not required to be collected and/or requested monthly for STEP-eligible educational activities.  Instead, the AEC/EC will utilize the institution enrollment verification to project participation hours each month of an academic term.

Example: Student 1 is enrolled in three courses at Evergreen Valley College. Each course is 2 hours in instructional time. Instructional time is 6 hours = (3 X 2). Study time is 12 hours = (6 X 2). Total participation is 18 hours = instructional time (6) + study time (12). 

Note: The SCD 1755A should be requested if the participant is enrolled part-time and assigned a concurrent activity to fulfill their hourly participation requirement.  In this case, the AEC/EC will only verify the participation hours of the concurrent activity.

Noncompliance

Existing noncompliance procedures are to be followed; however, noncompliance shall not be initiated for a STEP participant who:

• Refrains from attending Orientation/Appraisal, and who has had a break of less than one year in receiving CalWORKs cash aid or supportive services.
• Fails to submit their Attendance Verification (SCD 1755A) for any STEP educational activity.

Curing Sanctions for STEP Participants

Clients enrolled full-time in STEP eligible educational institutions are considered to be meeting WTW participation requirements.  Receipt of proof of full-time enrollment and determination of STEP eligibility is considered the date on which the client successfully performed the sanction curing activity.  This may also be used as the date they indicated the desire to cure their sanction if not previously communicated.  The AEC/EC should include enrollment in a STEP-eligible educational institution as an appropriate activity to restore aid. 

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