Noncompliance - Compliance Plan
Correcting the Problem
A client must agree to enter into a compliance plan within the 20-day period, and complete the compliance plan as required when a determination of "No Good Cause” is made. The EC should document in the Journal Detail page in CalSAWS and have the client sign a "Welfare-to-Work Compliance Plan" (WTW 32).
The compliance plan will specify that the individual must complete the agreed upon activity(ies) which may include, but are not limited to:
- Attending orientation or appraisal activities.
- Signing a Welfare-to-Work Plan (WTW 1, WTW 2)
- Participating in a WTW Activity.
- Accepting a job offer or job referral.
- Participating as necessary to remedy termination of employment or reduction of earnings.
[Refer to "Noncompliance Process Guidance/Participant Does Not Have Good Cause and is Placed in a Compliance Plan" for additional information.]
“Welfare-to-Work Compliance Plan” (WTW 32)
The WTW 32 must be signed by the client when no good cause is determined, indicating that he or she agrees to complete the activities outlined in the compliance plan or a sanction will be imposed. The WTW 32 provides the following:
- Activity participation requirements
- Start and end dates of required participation to avoid a sanction
- Other rights and responsibilities pertaining to compliance
The nonparticipating individual may suggest alternative activities for consideration, if they do not agree with the county’s proposed plan. The EC may include some or all of the client’s suggestions in the compliance plan, as appropriate. This form is only used as part of the noncompliance process and DOES NOT take the place of the WTW 2. However, a new WTW 2 is needed if the client is assigned to a different activity.
Compliance Plan by Telephone
The county may develop a compliance plan with a client by telephone. If the individual agrees to a compliance plan (WTW 32) over the telephone, the EC must take the following steps:
- Develops and signs the compliance plan (WTW 32).
- Informs the client of his or her requirements (assigned activity, provider location, starting and ending date of participation, etc.).
- Forwards a copy to Imaging and documents in the Journal Detail page that the plan was completed over the telephone and mailed to the client.
- Mails two (2) copies of the plan to the client (one to sign and return and the other to keep for their records), including a self-addressed stamped envelope.
Note: The WTW 32 may be signed via DocuSign. The return date indicated on the WTW 32 must be at least ten (10) calendar days from the date the county sends U.S. mail or DocuSign of the WTW 32 to the client.
- Receives the signed WTW 32 from the client and forwards the signed WTW 32 to Imaging for scanning.
- Documents action taken in the Journal Detail page in CalSAWS.
If the client fails to sign and return the compliance plan, postmarked no later than the return date indicated on the WTW 32, or fails to participate as agreed to over the telephone as noted on the WTW 32, the compliance process failed and the client will be sanctioned.
Additional Information for Compliance Plan
If the client attends the meeting or calls the worker, as required, and the county requires additional information or time to review the good cause information, or the county is unable to propose a compliance plan during the 20-day period, the county will not impose a sanction until it concludes NO GOOD CAUSE exists and the recipient fails to agree to enter into a compliance plan.
A client contacts their EC within the 20-day period indicated in the "Sanction of Mandatory Participant Notice" (NA 840) and presents information regarding good cause that requires additional verification. The worker cannot impose a sanction pending the verification. The client turns in the verification within the time period indicated in writing by the worker, but by the time the worker receives and reviews it, it is beyond the 20-day period. The worker finds no good cause and advises the client that he or she must enter into a compliance plan to avoid a sanction. If the client agrees to enter into a compliance plan, a "Determination of Good Cause/No Good Cause" (NA 840A) is mailed stating that no good cause was found but because the client agreed to a compliance plan, her aid will not be reduced.
Compliance Period
A compliance plan requires program participation in a CWES activity for the duration of the activity or for 60 consecutive calendar days from the date the client begins the activity, whichever is sooner.
A recipient is assigned to a six-month community service program scheduled for December through May. During the first month he missed seven days and was found to have violated the program’s attendance requirements without good cause. After receiving the NA 840, the recipient contacts the county within the 20-day compliance period, and agrees to sign a compliance plan. The recipient signs the compliance plan on February 1 and the county reassigns him to the community service program to participate for 60 calendar days, from February 15 through April 17. After the recipient has successfully completed his assignment on April 17, he has met the 60-day compliance requirements, and the instance of noncompliance must not be counted.
Related Topics
Noncompliance Program Requirements
Noncompliance - Failure to Show to Appointment
Noncompliance - The Compliance Interview
Noncompliance - Establishing Good Cause/No Good Cause
Noncompliance - No Contact by the 20th Day
Noncompliance - Supervisor Review
Noncompliance - Successful Compliance Plan
Noncompliance - Unsuccessful Compliance Process
Noncompliance - Two-Parent Cases
Noncompliance - Financial Sanctions
Noncompliance - Implementing a Welfare-to-Work (WTW) Sanction
Noncompliance - Vendor Payment
Noncompliance - Curing a Sanction