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HomeMy WebLinkAboutC07-282 EC Health & Human Services_EC works program policiesEAGLE COUNTY HEALTH & HUMAN SERVICES EAGLE COUNTY WORKS PROGRAM POLICIES Adopted by the Eagle County Board of County Commissioners Nothing in the Eagle County WORKS program shall be interpreted to create a legal entitlement in any participant to assistance or services provided pursuant to the Colorado WORKS program or the Eagle County WORKS program. I. Application and Assessment Process A. Ability to apply Applicants shall have the option of applying for any and all programs offered by Eagle County Health & Human Services. Applicants will be advised of various program options, benefits, services, eligibility requirements and client responsibilities at time of application. Applications will be available in HHS offices during normal working hours and by mail. B. Action on Applications Applicants will receive an appointment to process their application within five working days. If an emergency housing, food, childcare or medical need exists, applicants will be seen the same working day. All applications will be processed within 45 days. C. Assessment Applicants for WORKS will complete an assessment of job readiness within 30 days of application. This assessment will include a structured interview with an HHS case manager; an overview of employment readiness through identification of job skills and education, child care options, transportation, housing and other work support factors; and completion of other additional assessments of job readiness as may be indicated by the structured interview and overview of employment readiness. D. Participant Responsibilities Participants in the WORKS program are required to > give truthful and accurate information and to provide information on the factors that determine eligibility as required by State and County Program Regulations. > cooperate with child support enforcement efforts. > have current immunizations for their children and provide written proof. > participate in the job readiness assessment process. > participate in development and signing of Individual Responsibility Contract. > cooperate with training, education or work requirements. > report and document compliance with their Individual Responsibility Contract. > provide timely return of their Monthly Status Report (7th or 8th of the month). > notify the agency in advance if they cannot keep appointments. > follow through with the IRC plan and referrals agreed upon. > request good cause exemptions in a timely fashion. > voice grievances in accordance with the County's dispute resolution process. EAGLE COUNTY WORKS PROGRAM POLICIES Page 2 E. Agency Responsibilities > to treat participants with dignity and respect. > to hold private and confidential all information regarding the participant's application, benefits, IRC and case records. > to inform participants of their rights and responsibilities. > to provide information on agency programs and benefits. > to accept applications for benefits or services. > to apply the rules of eligibility equally. > to act in a timely and courteous manner on a participant's request for services. > to engage the participant in the planning of services. > to inform participants about the services or care that they will be receiving; the staff involved; the frequency and length of service. > to allow participants to refuse services or treatment within the confines of law and inform participants of the consequences of their actions. > to provide translation services or services in the participant' s own language. (including language translator, sign language, visually impaired assists) > to notify participants of the reasons for agency decisions. > to provide information on other community service options. > to receive grievances and complaints about unsatisfactory treatment without reprisal; and to investigate those grievances or complaints > to allow participants to appeal the decisions of the Department regarding their application for or receipt of benefits and services II. Basic Cash Assistance Basic Cash Assistance will be provided in accordance with statewide eligibility criteria and the rules established by the State Board of Human Services. A. Optional payment methods: 1. Monthly cash assistance grants. Z Vendor payments. Vendor payments may be used for Statewide and County Diversion benefits; for lump sum payments; or, when the participant requests vendor payments. 3. Lump sum payments: Lump sum payments may be authorized when the participant is at imminent risk of homelessness or loss of employment and when (1) a lump sum payment can secure housing or employment without, (2) jeopardizing the participant's ability to participate in work-related activities, or (3) the participant's ability to meet other basic needs of their family. EAGLE COUNTY WORKS PROGRAM POLICIES Page 3 B. Conditions for Authorizing Vendor Payments: 1. Statewide and County Diversion: Based on the Individual Responsibility Contract between the participant and Eagle County as approved by the County Director/designee. Z Lump Sum payment. That portion of the lump sum payment required to secure housing or employment will be identified in the Individual Responsibility Contract between the participant and Eagle County as approved by the County Director/designee. 3. At Participant's Request. When the participant requests in writing that vendor payments be made. C. Hardship Extensions: An assistance unit containing an individual who has received Federal TANF assistance in Colorado or another state as an adult for sixty (60) or more cumulative months shall not be eligible for Colorado WORKS unless granted an extension by the county department due to hardship or domestic violence. Hardship extension will be accepted and processed pursuant to State regulations. Hardship is defined only as those criteria listed in State regulations. III. Individual Responsibility Contracts Individual Responsibility Contracts will be completed for all custodial parents of eligible children, persons over age 18, and for all persons under age 18 who have not completed high school and are not in school and who are recipients of basic cash assistance, state- wide diversion grants and county diversion grants. Individual Responsibility Contracts will be developed in conjunction with the participant and other service providers. The expectations under the IRC will be in writing and will be acknowledged by signature of all parties to the IRC. The IRC will be effective upon review and approval by the Director or designee. For basic case assistance cases, refusal to participate in training, education, or work as evidenced by an affirmative statement by the participant or demonstrable evidence, may result in denial or termination of the basic cash -assistance grant in its entirety as determined by the county for a minimum of one month. IV. Employment and Job Preparation Requirements All WORKS applicants, and custodial parents of eligible children, are expected to participate in work-related activities. Eagle County may exempt participants from sanction for non -participation in work related activities. This exemption does not stop the individual's federal requirement to enter a work related activity within 24 months. A. Fair and objective criteria for the determination of exception from work-related requirements: 1. Parent Ability to Work: The parent/caretaker has a disability that interferes with work activity. Objective Criteria: physician or mental health professional statement or receipt of SSI/OASDI. 2. Pregnancy: The single caretaker is pregnant - for a period not to exceed 12 weeks that can extend from the ninth month of pregnancy through the P month of infant care. Objective Criteria: verification of pregnancy status and request by the parent to provide care & bonding. EAGLE COUNTY WORKS PROGRAM POLICIES Page 4 3. Disabled Child Needing Care: The parent/caretaker is required in the home on a full-time basis. Objective Criteria: physician statement or certification by a Community Centered Board agency. 4. Lack of Child Care: There is no available childcare, as defined in Section XII, while the parent participates in work activity. Objective Criteria: The Department will verify the absence of relative, legally exempt or licensed childcare. 5. Transportation: There is no transportation to work activity. Objective Criteria: The Department will verify the absence of public transportation, the absence of private transportation that could be accessed by the participant. 6. Domestic Violence: Separation due to domestic violence or child abuse, or the parent/caretaker would be placed at imminent risk of domestic violence if they participated in a work related activity. Objective Criteria: The parent/caretaker makes such a request and there exists documentation of law enforcement reports and intervention to protect the parent/caretaker from domestic violence. 7. Family Trauma: Death of a child, parent, spouse or caretaker or the need to provide care for a family member. Objective Criteria: Assessment and statement by a mental health professional with a plan for counseling that will enable the family to restore family functioning or a statement by a physician that the parent/caretaker is needed in the home to provide care for another family member. B. Work-related activities The following activities are recognized by the county as meeting work related requirements: 1. Unsubsidized employment 2. Subsidized private sector employment 3. Subsidized public sector employment 4. Work Experience 5. On -the -Job Training - see B & C. 6. Job Search and Job Readiness Activities 7. Community Service Programs as available in the community. 8. Vocational educational training - not to exceed 12 months per individual. 9. Provision of child care services to a participant in a community service program. 10. Job Skills Training directly related to employment - employer specific. 11. Education directly related to employment in the case of a participant who has not received a high school diploma or certificate of high school equivalency. 12. Satisfactory attendance at secondary school, Adult Basic Education, English as a Second Language or in a course of study leading to a certificate of general equivalence, in the case of a participant who has not completed secondary school or received such a certificate. 13. Post second edocat on 14. Domestic violence, mental health or substance abuse treatment that is necessary in order to participate in other work-related activities. Special Note: Items 10-14 do not count for purposes of Federal work participation rate calculations. EAGLE COUNTY WORKS PROGRAM POLICIES Page 5 V. Other Assistance A. Cash Additional cash assistance may be provided to a WORKS client to support employment and job training goals outlined in the client's Individual Responsibility Contract. Additional cash assistance may be one-time or ongoing assistance. 1. One - time cash assistance: One time cash assistance may be equivalent to no more than three months basic cash assistance level. One time cash assistance may be authorized for the following: > employment required tools, equipment or clothing. > glasses or other prosthetic devices necessary for employment and not covered under Medicaid or Vocational Rehabilitation Services. > relocation assistance with a firm job offer that will result in self-sufficiency and termination of WORKS benefits. > housing or utility deposits or installation of phone service. > emergency assistance for shelter, childcare and food. 2. Ongoing additional cash assistance: Ongoing additional cash assistance may be equivalent to no more than the monthly basic cash assistance grant. Ongoing additional cash assistance above that of the basic cash assistance grant may be provided to assist with the following: - transportation expenses to participate in employment, training or job preparation. - training, work supplies and equipment not otherwise covered by WIA. - personal care items and services needed for entering work related activities. - other work-related expenses specified in the IRC and approved by the County. 4. Additional cash assistance for grandparent placement of children: Grandparents to the children who have been the subject of an open and active child welfare case that resulted in guardianship with the grandparents may receive ongoing cash assistance in an amount not to exceed the usual family foster care reimbursement of Eagle County. B. Other Services Eagle County HHS will connect WORKS participants with other community services which support self-sufficiency goals and will use WORKS funds to purchase these services through vendor payments when they are not available under Medicaid or in the community without additional cost to the family or the agency. Purchased Services may be provided in a total amount not to exceed the equivalent of six months basic cash assistance grant. EAGLE COUNTY WORKS PROGRAM POLICIES Page 6 These services will also be made available under the WORKS program to families that qualify for services under Title IVA-EA of the Social Security Act. That is, for families: > whose children are living at home or with relatives within the 5th degree, and > who are US citizens or documented residents, and > whose gross family income is less than $ 75,000/ year, and > who are experiencing an emergency that impacts their ability to care for their children. Purchased Services will parallel the Title IV -An Emergency Assistance and Familv Preservation guidelines and may include the following: Services to help families gain employment > Adult literacy and English as a Second language > Adult Basic Education or General Eauivalent Diploma > Pre-employment skills and Job coaching > Transportation or translation. Services to help families achieve independence > Legal services for domestic relations and landlord/tenant issues > Financial and household management services > Homemaker services for disabled adult caretakers or disabled children > Medical case management services > Child Support Enforcement services - custodial parent fee. Services to help strengthen family life > Parenting education and support and family mentoring > Family communication services > Substance Abuse treatment services > Domestic violence treatment Services to help youth achieve independence > Independent living services for youth between the ages of 16 and 18. > Day treatment services > Youth mentoring services > Youth sexual offender assessment and treatment Eagle County may also provide grants to community agencies for programs that promote two parent families, reduce teen pregnancy, stabilize family life and promote self- sufficiency in accordance with the goals of TANF. C. Time Limits for Other Assistance and Services 1. Cash Assistance One-time assistance - payments may be extended over a four-month period. On-going assistance - up to 24 months EAGLE COUNTY WORKS PROGRAM POLICIES Page 7 2. Purchased Services - throughout the time of WORKS eligibility and for six months after achieving self-sufficiency (termination of cash assistance payments). D. Restrictions on Other Assistance 1. Cash Assistance: Must be categorically eligible under the Colorado WORKS program. Additional or transitional needs must be documented and included in the Individual Responsibility Contract between the participant and Eagle County as reviewed and approved by the County. Services: Service needs for WORKS participants must be documented and included in the Individual Responsibility Contract between the participant and Eagle County and approved by the County Director or designee. Service needs for Title IVA-EA families must be documented in an application for services and approved by the County Director or designee. All services except for services related to training and employment will be available to client families on a VOLUNTARY basis. Eligibility and appropriateness for services will be determined by HHS in conjunction with service vendors. VI. Statewide Diversion A. Criteria for receipt of a statewide diversion grant 1. The family is NOT in need of long-term cash assistance as determined by: a. Client statement b. Verification of employment and other income that will be sufficient to assure long-term self-sufficiency. Determination of self-sufficiency will compare total monthly income to total monthly expenses for shelter, food, transportation, medical needs and personal items as identified by the client 2. The family, at time of application, meets the eligibility criteria for the Colorado WORKS program. 3r The amount of diversion payment, up to the equivalent of six month's basic cash assistance under WORKS, is sufficient to divert the family from assistance and assure long-term self-sufficiency or meets the immediate needs to stabilize tile'6mily blh B. Method of Payment Vendor payments or direct payments to participants will be utilized for statewide and county diversion grants. C. Limits on reapplication Applicants for Statewide Diversion grants will agree in writing to NOT apply for basic cash assistance or diversion grants for a period of 12 months. EAGLE COUNTY WORKS PROGRAM POLICIES Page 8 D. Good Cause: Families who have received an optional state diversion payment may apply for basic cash assistance or subsequent diversion payments prior to the end of the 12 -month exclusionary period for the good cause. (see Section VIII: sanctions & fraud) E. Services Eagle County HHS will make the following in-kind services available to recipients of statewide diversion grants: > Information and Referral services to other community agencies. > Case Management and Service Coordination VII. County Diversion Program A. Criteria for receipt of a county diversion grant 1. The family's income does not exceed 200% of the federal poverty level. 2. The family meets all criteria for eligibility under the Colorado WORKS BCA program except that the family's income exceeds the BCA eligibility level. 3. The family is NOT in need of long-term cash assistance as determined by: a. Client statement b. Verification of employment and other income that will be sufficient to assure long-term self-sufficiency. Determination of self-sufficiency will compare monthly income to monthly expenses for shelter, food, medical needs, transportation, and personal items as identified by the client. 4. The amount of diversion payment, up to the equivalent of six month's basic cash assistance under WORKS, is sufficient to divert the family from assistance and assure long-term self-sufficiency. Eagle County HHS will connect WORKS participants with other community services which support self-sufficiency goals and will use WORKS funds to purchase these services through vendor payments when they are not available under Medicaid or in the community without additional cost to the family or the agency. Purchased Services may be provided in a total amount not to exceed the equivalent of six months basic cash assistance grant. These services will also be made available under the WORKS program to families that qualify for services under Title IVA-EA of the Social Security Act. That is, for families: > whose children are living at home or with relatives within the 5th degree, and > who are US citizens or eligible qualified aliens, and > whose gross family income is less than $ 75,000/ year, and > who are experiencing an emergency that impacts their ability to care for their children. EAGLE COUNTY WORKS PROGRAM POLICIES Page 9 Purchased Services will parallel the Title IV -A Emergency Assistance and Family Preservation guidelines and may include the following: Services to help families gain employment > Adult literacy and English as a Second language > Adult Basic Education or General Equivalent Diploma > i ati.' station and er 7;Fost Second educaQatwtio and +nac�mn`csst > Pre-employment skills and Job coaching > Transportation or translation Services to help families achieve independence > Legal services for domestic relations and landlord/tenant issues > Financial and household management > Homemaker services for disabled adult caretakers or disabled children > Medical case management services > Child Support Enforcement services - custodial parent fee. Services to help strengthen family life > Parenting education and support and family mentoring > Family communication services > Substance Abuse treatment services > Domestic violence treatment Services to help youth achieve independence > Independent living services for youth between the ages of 16 and 18. > Day treatment services > Youth mentoring services > Youth sexual offender assessment and treatment. Eagle County may also provide grants to community agencies for programs that stabilize family life and promote self-sufficiency in accordance with the goals of TANF. B. Method of Payment Vendor payments and direct payments to participants may be utilized for county diversion grants. C. Limits on reapplication Applicants for County Diversion grants will agree in writing to NOT apply for basic cash assistance or diversion grants for a period of 12 months. D. Good Cause: Families who have received an optional county diversion payment may apply for basic cash assistance or subsequent diversion payments prior to the end of the 12 month exclusionary period for good cause. (See Section VIII: sanctions & fraud) EAGLE COUNTY WORKS PROGRAM POLICIES Page 10 E. Services Eagle County HHS will make the following in-kind services available to recipients of county diversion grants: Information and Referral services to other community agencies. Case management and service coordination. F. Community Resource Investment Assistance Eagle County will contract with community agencies to provide services that address one or more of the four federal TANF goals. The community resources in which Eagle County will invest include prevention, early intervention, and treatment services which assist youth and families in achieving economic self-sufficiency, stabilizing families to prevent family breakdown, prevention and reduction of out -of -wedlock pregnancies, and promotion of two parent families. For PRWORA Goals 1 & 2: Self-sufficiency and Family Stabilization Families maybe eligible for services: > whose children are living at home or with relatives within the 5th degree, and > who are US citizens or documented residents, and > whose gross family income is less than $ 75,000/ year, and > who are experiencing an Aemergency@ that impacts their ability to care for their children. For PWORA Goals 3 & 4: Reduction of out of wedlock pregnancy and Promotion of two parent families, there are no income eligibility or residency requirements. Contractors are responsible to obtain information from participants establishing participant eligibility. Contractors maintain eligibility documentation for audit. Eagle County reimburses contractors only for services to TANF eligible participants. Dispute resolution process: Participants are provided with a written notice of their potential benefits and right to appeal. The overall TANF dispute resolution process also applies to community investment grant services. VIII. Demonstrable Evidence, Sanctions and Fraud A. Basic Cash Assistance 1. Demonstrable Evidence The county may deny a case or terminate the entire basic cash assistance grant for a minimum of one month when the participant refuses or fails, without good cause, to participate in all training, education or work related activities as evidenced by an affirmative statement or demonstrable evidence. EAGLE COUNTY WORKS PROGRAM POLICIES Page 11 2. Sanctionable Items Sanctions will be imposed in accordance with State rules for sanctions and disqualifications. Sanctionable items include: > Refusal or failure to fully participate in one or more training, education or work related activities as outlined in the IRC- 3 tier sanction > Failure to cooperate with Child Support Enforcement - 3 tier sanction > Failure to secure immunizations for children - 3 -tier sanction. > Fraud - removal of caretaker from the grant for 12 -month period for the first offense, 24 months for the second offense and lifetime for the third offense. > Misrepresentation of information to receive assistance in two states or two counties at the same time - ineligible for a period of 10 years. An appointment for conciliation will be provided in the first month after a client has not met the cumulative hourly requirements of work activity or failed to complete a sanctionable item as outlined in their IRC. The conciliation appointment allows the client to explain the mitigating circumstances that interfered with compliance on items within the Individual Responsibility Contract. If the client fails to appear for the conciliation appointment and/or the department determines good cause does not exist, the 3 -tier sanction will be implemented. Notices of sanctions or termination of benefits will be provided certified return receipt requested mail. a. Three tier sanction for basic cash assistance First Sanction: 1 month or until cured Second sanction: 3 months or until cured Third sanction: 6 months or until cured 3. Reasons for good cause for not imposing sanctions or closing case for demonstrable evidence: > domestic violence > inability to obtain child care > incarceration. > jury duty. > time-limited family emergencies such as a death in the immediate family; illness in the immediate family, documented by a physician as requiring the care of the parent or caretaker; a family disaster such as a fire, flood or major crime victimization; eviction necessitating a search for housing; or other situations which are reviewed by the County Director as meeting the definition of a time-limited family emergency. 4. Process for establishing good cause: A participant may request conciliation or good cause exception from the imposition of sanctions or case closure for demonstrable evidence at the conciliation appointment. A request for conciliation is a request to explain the mitigating circumstances that interfered with compliance on items within the Individual Responsibility Contract. A request for good cause exception must be accompanied by written documentation of domestic violence, inability to obtain child care, incarceration; jury duty; or family emergency or signed releases for the agency to obtain such written documentation of good cause. EAGLE COUNTY WORKS PROGRAM POLICIES Page 12 Verification of a family emergency and review by the County Director will be accomplished within two working days of the request. During the period of the review, sanctions will not be imposed nor will case closure for demonstrable evidence occur. If the good cause determination is not approved, the participant will be notified in writing of imposition of sanctions or case closure for demonstrable evidence in accordance with the general procedures of the Colorado WORKS programa B. Other Assistance Case closure for demonstrable evidence and sanctions on other cash assistance and purchased services will be applied in the same proportions as case closure sanctions on the basic cash assistance grant. Reasons for good cause will be the same as in basic cash assistance. Client notice, decision making and review of decision will be conducted in the same manner as in basic cash assistance. C. Statewide Diversion Grants The Statewide Diversion program is a one-time authorized payment plan. Sanctions, other than the agreement to not reapply for 12 months, will not be imposed. Applicants who misrepresent their need, income, resources and situation will be prosecuted for fraud. Families who have received an optional state diversion payment may apply for basic cash assistance or subsequent diversion payments prior to the end of the 12 -month exclusionary period for the following good cause: Parent Ability to Work: Layoff due to reduction in force; or the parent/caretaker has a disability that interferes with work activity. Objective Criteria: physician or mental health professional statement or receipt of SSPOASDI. Pregnancy: The single caretaker is pregnant for a period not to exceed 12 weeks that can extend from the ninth month of pregnancy through the 3rd month of infant care. Objective Criteria: verification of pregnancy status and request by the parent to provide care & bonding. Disabled Child Needing Care: The parent/caretaker is required in the home on a full-time basis. Objective Criteria: physician statement or certification by a Community Centered Board. Lack of Child Care: There is no available childcare while the parent participates in work activity. Objective Criteria: The Department verifies absence of relative, legally exempt or licensed childcare. Transportation: There is no transportation to work activity. Objective Criteria: The Department will verify the absence of public transportation, the absence of private transportation that could be accessed by the participant. Domestic Violence: Separation due to domestic violence or child abuse; or, there is an imminent risk of domestic violence to the participant. Objective Criteria: The parent/caretaker makes such a request for exemption and there is documentation of law enforcement reports/intervention to protect the parent/caretaker from domestic violence. EAGLE COUNTY WORKS PROGRAM POLICIES Page 13 D. County Diversion Grants The County Diversion program is a one-time authorized service plan. Sanctions, other than the agreement to not reapply for 12 months, will not be imposed. Participants who misrepresent their need, income, resources and situation will be prosecuted for fraud. Families who have received an optional county diversion payment may apply for basic cash assistance or subsequent diversion payments prior to the end of the 12 -month exclusionary period for the following good cause: Parent Ability to Work: Layoff due to reduction in force; or the parent/caretaker has a disability that interferes with work activity. Objective Criteria: physician or mental health professional statement or receipt of SSI/OASDI. Pregnancy: when the single caretaker is pregnant for a period not to exceed 12 weeks that can extend from the ninth month of pregnancy through the P month of infant care. Objective Criteria: verification of pregnancy status and request by the parent to provide care & bonding. Disabled Child Needing Care: The parent/caretaker is required in the home on a full-time basis. Objective Criteria: physician statement or certification by a Community Centered Board. Lack of Child Care: There is no available childcare, as defined in Section XII, while the parent participates in work activity. Objective Criteria: The Department verifies absence of relative, legally exempt or licensed childcare. Transportation: There is no transportation to work activity. Family Trauma: Family disaster such as a fire, flood or major crime victimization, eviction, through no fault of the family, necessitating a search for housing, death or incarceration of a parent, spouse or caretaker, the death of a child, or the need to provide care for a family member, or other situations which are determined by the County Director as meeting the definition of a family disaster. Objective Criteria: Verification through independent sources of a family disaster; or, assessment and statement by a mental health professional with a plan for counseling that will enable the family to restore family functioning; or, a statement by a physician that the parent/caretaker is needed in the home to provide care for another family member. Domestic Violence: Separation due to domestic violence or child abuse; or, there is an imminent risk of domestic violence to the participant. Objective Criteria: The parent/caretaker makes a request for exemption and there is documentation of law enforcement reports/intervention to protect the parent/caretaker from domestic violence. IX. Dispute Resolution Participants may request a meeting with the County Director or her designee to review the factors of their individual situation and the basis for the county decision regarding cash benefits, services or sanctions. Meetings with the County Director or designee will occur within 5 working days. Benefits will continue during the period of County dispute resolution. Participants who disagree with the Director's review of their situation will be provided information on the their right to appeal the county's decision. Eagle County will not provide interim relief when a participant appeals an agency decision after the prior notice has expired. EAGLE COUNTY WORKS PROGRAM POLICIES Page 14 X. Segregated Funds The county will segregate TANF funds according to State rules and regulations XI. Eagle County HHS Employee as Applicant/Participant Applications submitted by an employee of HHS will be processed according to the same guidelines as all other applications. The Director will review any planned action regarding an applicant/participant who is an employee of HHS. XII. Child Care Availability Appropriate and affordable childcare arrangements are defined as unavailable or unsuitable when the following conditions exist: A. Formal Childcare Arrangements 1. There are no openings in licensed child care programs that accept Child Care Assistance Program (CCAP) families within a 15 mile radius of home or prospective employment — or between the location of home and prospective employment; or, 2. When only public transportation is available to transport children under the age of six and the distance and conditions of walking from the bus stop to the childcare program is considered dangerous by the Department. B. Informal Childcare Arrangements 1. For two-parent families when the non -working parent is physically, mentally or emotionally unable to care for their children as documented by a physician or mental health professional. 2. For all families, when the extended family member is physically, mentally or emotionally unable to care for their children as documented by a physician or mental health professional; or when the extended family member or legally exempt provider has been the subject of a founded child abuse or neglect report; or involved in situations of domestic violence; substance abuse; or criminal activity. XIII. Transitioning from Colorado WORKS to Low -Income Child Care Assistance Program Families who leave the Colorado WORKS program due to employment will be transitioned to the Low -Income Child Care Assistance Program. A. Low -Income Child Care Assistance Application Not Required For Transitioning Families 1. No Low -Income Child Care Assistance Application will be required of Colorado WORKS families leaving the Colorado WORKS program due to employment. 2. At the point of transition, the Colorado WORKS case manager will obtain a signed Client Responsibilities Agreement and Client Responsibilities Agreement Supplemental in order to share the required information between the Colorado WORKS program and the Child Care Assistance program staff. The original of these forms will be kept in the Low -Income Child Care Assistance case file with a copy in the Colorado WORKS case file. EAGLE COUNTY WORKS PROGRAM POLICIES Page 15 3. Information to be shared includes: > Household composition and verification > Activity information and verification > Any additional information related to low-income eligibility as outlined in Volume 3.900. B. Colorado WORKS Cases Which Will Not Be Transitioned to Low -Income Child Care Assistance Program 1. Circumstances Where No Transition from Colorado WORKS to Low -Income Child Care Assistance Program will occur: > The family leaves the Colorado WORKS program due to a program violation as determined in Section 3.621; > The family is participating in training activities which Eagle County does not include as an eligible activity for the Low -Income Child Care Assistance program; > Eagle County's Low -Income Child Care Assistance program's eligibility level is below that of the transitioning family; or > Eagle County's Low -Income Child Care Assistance program has a waiting list. 2. Noticing Requirements When No Transition Will Occur All Colorado WORKS participants who will not be transitioned due to the reasons listed in XIII (B) (1) will be noticed according to regulations outlined in Volume III, Section 3.830 and 3.924. C. Re -determinations for Transitioning Families 1. Families who transition from the Colorado WORKS program to the Low Income Child Care Assistance Program will be re -determined three (3) months after the Low Income case is established. 2. Subsequent re -determinations after the first determination will comply with low- income re -determination rules as outlined in Volume III, Section 3.906. XIV. Domestic Violence and the Family Violence Option A. Notice All applicants who are past or present victims of domestic violence or at risk of further domestic violence shall be provided notice of the possible waivers and applicable procedures available under the Colorado WORKS program. Staff shall be trained in the domestic violence option and utilize the state approved domestic violence packet to screen and identify victims of domestic violence. B. Referrals Referrals to any available counseling and supportive services shall be provided to past or present victims of domestic violence or those at risk of further violence. The County is not obligated to pay for any services to which the participant is referred. EAGLE COUNTY WORKS PROGRAM POLICIES Page 16 C. Good Cause 1. Upon a showing of good cause, waivers from any program requirements shall be provided in any instance that will make it more difficult for an applicant or participant to escape domestic violence or that would unfairly penalize such individuals who are or have been victimized by such violence or who are at risk of further violence. 2. Requests for waivers of work requirements shall be submitted by the County to the state department to determine whether good cause exists to grant good cause waivers. D. Voluntary and Confidential All procedures for identifying eligibility for referrals to supportive services and waivers, for applying for waivers, and the procedures by which an applicant or a participant who is denied a waiver may appeal such decision shall be voluntary and confidential. XV. Earned Income Tax Credit Assistance shall be provided to help participants apply for and receive the earned income tax credit. XVI. Individual Development Accounts Individual Development Accounts will be established for individuals upon request. Individual Development Accounts may be used to set aside funds for home purchase, business capitalization, or higher education in accordance with federal law. Adopted by the Eagle County Board of County Commissioners on this 20th day of November, 2001; Amended on April 15, 2003, April 13, 2004, April 26, 2005, June 19, 2007, and September 11, 2007. /--� Am M. Menconi, Chairman Eagle County Board of Commissioners Sara J. Fisher, ice- Chai an Peter F. Runyon, Commisa oner Colorado Works Program Plan September 11, 2007 EAGLE County Section 1 - Eligibility Criteria and Benefit Limits For each type of benefit or service that applies to your county (except for basic cash assistance), please list the maximum income levels for eligibility; the maximum payment amounts for each type of benefit or service; and any other criteria that apply for the receipt of each type of benefit or service. Please be as detailed as possible and attach additional U5 Ais'taUC same as for Basic Cash Assistance One-time CA: Not to exceed the equiv- alent of 3 mos BCA Ongoing CA: not to exceed 1 mos BCA Auto Purchase Plan: not exceeding six mos BCA Services: not to exceed equiv of 6 mos BCA One-time additional assistance — no more than one payment per calendar quarter Ongoing additional assistance — up to 24 months Services — throughout the time of WORKS eligibility and for six months after achieving self-sufficiency. Services and assistance must be specified in IRC. Services to parallel Title IV -A Emergency Assistance and Family Preservation Guidelines. Community Investment Resource contracts in accordance with 3.631. Services to a Non-custodial parent of a TANF child State'Diwersiow same as for Up to the equivalent Applicants agree in writing to not apply for BCA or Basic Cash of six months BCA diversion payments for a period of 12 months following Assistance diversion. Good cause provided for exception to the 12 month rule; ➢ parent ability to work " ➢ pregnancy ➢ disabled child needing care ➢ lack of child care ➢ transportation issues ➢ domestic violence risk ➢ family trauma Family stabilization state diversions may be used to meet immediate needs when the family requires in- depth assessment to determine if ongoing basic cash assistance is alipropriate. County Up to 200% of Up to the equivalent Non-custodial parent of TANF child may apply Diversion FPL (effective of six months BCA. Applicants agree in writing to not apply for BCA or April 1" of Payments may be diversion payments for a period of 12 months following each year) extended over a diversion. four-month period. Good cause provided for exception to the 12 month rule; ➢ parent ability to work ➢ pregnancy ➢ disabled child needing care ➢ lack of child care ➢ transportation issues ➢ domestic violence risk ➢ family trauma Section 2 - Description of Benefits Provided For each category of benefit or service that applies to your county (including basic cash assistance), please describe in as much detail as possible the benefits or services to be provided. Please provide examples as appropriate and attach additional pages as necessary. Also, please consider the following in your answers: • For basic cash assistance, whether or not you close cases for demonstrable evidence for failure to follow the terms of the Individual Responsibility Contract (IRC). If yes, what is your procedure? • For State Diversion, if you provide services in lieu of cash, describe the services provided and the circumstances under which you provide them. • For each type of benefit or service, include in your description whether or not you provide optional payment methods such as vendor payments, voucher payments and/or lump -sum payments, and under what conditions these optional payment methods will be used. • Include in your description the process used to determining eligibility and benefits for applicants and participants who are employees of your county department of social/human services. Basic; Cash Assistance" Monthly payments; lump sum payments in multiples of two to six month amounts. Lump sums provided to secure housing or employment may be made as vendor payment. Case closure for demonstrable evidence and sanctions provided for failure to comply with the terms of the IRC in accordance with state rules for sanctions and disqualifications. Demonstrable Evidence and Sanctionable items include: ➢ Refusal to complete an IRC — deny or discontinue for failure to complete a required IRC ➢ Refusal or failure to participate in all training, education or work related activities as outlined in the IRC — discontinue case for demonstrable evidence ➢ Refusal or failure to participate fully in one or more training, education or work related activities as outlined in the IRC — 3 tier sanction ➢ Failure to cooperate with Child Support Enforcement — 3 tier sanction ➢ Failure to secure immunizations for children — 3 tier sanction ➢ Fraud — removal of caretaker for the grant for a 12 month period for the first offense; 24 months for the second offense and lifetime for the third offense. ➢ Misrepresentation of information to receive assistance in two states or two counties at the same time — ineligible for a period of 10 years. Applications submitted by an employee of the Department will be processed according to the same guidelines as all other applications. The Director will review any planned action regarding an applicant/participant who is an employee of the Department. One time: ➢ employment transportation expenses ➢ employment required tools, equipment or clothing ➢ glasses or other prosthetic devices necessary for employment and not covered under Medicaid or Vocational Rehabilitation Services. ➢ Relocation assistance with a firm job offer that will result in self-sufficiency and termination of WORKS benefits. ➢ Housing or utility deposits or installation of phone service. ➢ Emergency assistance for shelter, childcare or food. Ongoing: ➢ transportation expenses to participate in employment, training or job preparation activities ➢ training expenses, work supplies and equipment not otherwise covered by WIA ➢ personal care items and services needed for entering work related activities ➢ other work-related expenses specified in the IRC and approved by the County Director. ➢ Vendor payments may be made at the request of the participant or the County. Kinship Placement of children: Non- parent caretakers within the 5's degree of relationship to the children who have been the subject of an open and active child welfare case that resulted in guardianship with the non -parent relative caretaker may receive ongoing cash assistance in an amount not to exceed the usual family foster care reimbursement of Eagle County. Services: Eagle County will connect WORKS participants with other community services, which support self-sufficiency goals and will use WORKS funds to purchase these services through vendor payments when they are not available under Medicaid or in the community without additional cost to the family or the agency. Purchased services are in addition to any basic cash assistance payment. Services will parallel the Title IV -A Emergency Assistance and Family Preservation guidelines. Services will also be made available under the WORKS program for families that qualify for services under Title IV -A EA of the Social Security Act. Services will include community resource investment contracts in accordance with 3.631. Applications submitted by an employee of the Department will be processed according to the same guidelines as all other applications. The Director will review any planned action regarding an applicant/participant who is an employee of the Department. Criteria: The family has experienced a short-term crisis beyond the family's control (three months or less in duration), which has interfered with the family's usual ability to be economically self-sufficient, and the family is not in need of long-term basic cash assistance. Time limited family emergencies may include a death in the immediate family; illness in the immediate family, documented by a physician as requiring the care of the parent or caretaker; a family disaster such as a fire, flood or major crime victimization; eviction necessitating a search for housing; or other situations which are determined by the County as meeting the definition of a time-limited family emergency beyond the family's control. ➢ The family is NOT in need of long-term cash assistance as determined by client statement, verification of employment and other income that will be sufficient to assure long-term self-sufficiency. Determination of self-sufficiency compares total monthly income to reasonable monthly expenses for shelter, food, transportation, medical needs and personal items. State diversion payments may be used to stabilize applicant families while in-depth assessment is completed to determine if ongoing basic cash assistance is appropriate and for families transitioning off Basic Cash Assistance. ➢ The family at time of application meets the eligibility criteria of the Colorado WORKS program Vendor payments and direct payments to clients will be used as appropriate. Applications submitted by an employee of the Department will be processed according to the same guidelines as all other applications. The Director will review any planned action regarding an applicant/participant who is an employee of the Department. Services: Eagle County will connect WORKS participants with other community services, which support self-sufficiency goals and will use WORKS funds to purchase these services through vendor payments when they are not available under Medicaid or in the community without additional cost to the family or the agency. Purchased services are in addition to any basic cash assistance payment. Services will parallel the Title IV -A Emergency Assistance and Family Preservation guidelines. Services will also be made available under the WORKS program for families that qualify for services under Title IV -A EA of the Social Security Act. Criteria: The family has experienced a short-term crisis beyond the family's control (three months or less in duration), which has interfered with the family's usual ability to be economically self-sufficient, and the family is not in need of long-term cash assistance. Time limited family emergencies may include a death in the immediate family; illness in the immediate family, documented by a physician as requiring the care of the parent or caretaker; a family disaster such as a fire, flood or major crime victimization; eviction necessitating a search for housing; or other situations which are determined by the County as meeting the definition of a time-limited family emergency beyond the family's control. ➢ The family is NOT in need of long-term cash assistance as determined by client statement, verification of employment and other income that will be sufficient to assure long-term self-sufficiency. Determination of self-sufficiency compares total monthly income to reasonable monthly expenses for shelter, food, transportation, medical needs and personal items. Diversion payments may be used for families transitioning off Basic Cash Assistance. ➢ maximum allowable income at the time of application: 200 % of FPL ➢ applicants meet all criteria for eligibility under the Colorado WORKS BCA program except that the family's income exceeds the BCA eligibility level. Vendor payments and direct payments to clients will be used as appropriate. Applications submitted by an employee of the Department will be processed according to the same guidelines as all other applications. The Director will review any planned action regarding an applicant/participant who is an employee of the Department. Services: Eagle County will connect WORKS participants with other community services, which support self-sufficiency goals and will use WORKS funds to purchase these services through vendor payments when they are not available under Medicaid or in the community without additional cost to the family or the agency. Purchased services are in addition to any basic cash assistance payment. Services will parallel the Title IV -A Emergency Assistance and Family Preservation guidelines. Services will also be made available under the WORKS program for families that qualify for services under Title IV -A EA of the Social Security Act. Services will include Community Resource Investment Contracts in accordance with 3.361. Per 26-2-716 (2.5) C.R.S., please attach all county policies related to basic cash, other assistance, state diversion and county diversion. Please use additional pages as necessary. .MnN Section 3 - Sanctions What is the minimum number of months for each sanction level? Sanction Levet Mhoma tnNumber: d M6nths, . li�' '. 1 XX 2 3 2 3 XX third 3 4 5 6 XX Please list the good cause reasons for which you do not impose sanctions, and describe your process for determining when to impose sanctions. Good cause for not imposing sanctions ➢ domestic violence inability to obtain child care ➢ incarceration Jury Duty Time limited family emergencies such as a death in the immediate family; illness in the immediate family, documented by a physician as requiring the care of the parent or caretaker; a family disaster such as a fire, flood or major crime victimization; eviction necessitating a search for housing; or other situations which are reviewed b the County Director as meeting the definition of a time-limited family emergency. Notice of impending sanction will be provided in the first month that client has not met cumulative hourly requirements of work activity. Clients will be given an opportunity to reach work activity goals or to contact the County to consider a revised work activity plan. If the client fails to contact the County for a revised plan or to achieve work activity goals in the second month, the 3 -tier sanction will be implemented. Notices of sanctions or termination of benefits will be provided certified mail return receipt requested. Process for establishing good cause: A participant may request conciliation or a good cause exception from the imposition of sanctions. Recipients must contact their worker within three business days of any emergency unless that individual is incapable of making such contact. A request for conciliation is a request to explain the mitigating circumstance that interfered with compliance on items within the Individual Responsibility Contract. A request for good cause exception must be accompanied by written documentation of domestic violence, inability to obtain child care, incarceration; jury duty; or family emergency or signed releases for the agency to obtain such written documentation of good cause. Verification of a family emergency and review by the County Director or designees will be accomplished within two working days of the request. During the period of the review, sanctions will not be imposed. If the good cause determination is not approved, the participant will be notified in writing of imposition of sanctions in accordance with the general procedures of the Colorado WORKS program Per 26-2-716 (2.5) C.R.S., please attach all county policies related to sanctions against basic cash assistance and other assistance. Please use additional pages as necessary. Section 4 - Job Readiness and Work Activities Please describe your county definition of job -ready. An individual is "job ready" when they possess the job skills and experience which meet the requirements of local employers for employment, when the jobs available are consistent with a long term goal for self-sufficiency, and when child care and transportation are available in the community to support an employment plan. If your county automatically exempts participants from work activities based on the age of their youngest child, what is the maximum age of the child (in months) that will result in the exemption. f 1 12 13 XX 14 15 16 17 18 19 110 111 The following 12 work activities may be used to meet work participation rates as established by the federal government, as well as satisfy the 24 -month requirement. Please indicate which ones your county uses. X Unsubsidized employment X Subsidized private sector employment X Subsidized public sector employment X Work experience X On -the -Job Training X Job Search/Job Readiness X Community Service Programs X Vocational Educational Training X Provision of Child Care for a Participant in a Community Service Program X Job Skills Training Directly Related to Employment X Education Directly Related to Employment X Satisfactory Attendance at Secondary School or GED If Community Service Programs is indicated above, please define the activities which will be included in your county's community service programs in addition to those listed in Volume III at 3.626.2 (G). Volunteer placement through the Eagle County Volunteer Program, through another governmental agency or not-for-profit service organization. In addition to those activities listed above, please describe what other work activities your county uses in order for individuals to meet the 24 month requirement. ➢ Domestic violence, mental health or substance abuse treatment that is necessary in order to participate in other work-related activities. ➢ Participation in Adult Basic Education or English as a second language studies. Per 26-2-716 (2.5) C.P.S., please attach all official written county policies related to work activities in your county. Please use additional pages as necessary. Section 5 - Child Care Availability Appropriate and affordable formal childcare arrangements are defined as unavailable when the following conditions exist: ➢ When there are no openings in licensed child care programs that accept Child Care Assistance Program (CCAP) families within a 15 mile radius of home or prospective employment — or between the location of home and prospective employment; or, ➢ When only public transportation is available to transport children under the age of six and the distance and conditions of walking from the bus stop to the childcare program is considered dangerous by the Department. Informal childcare by a relative or under other arrangements are defined as unavailable or unsuitable when the following conditions exist: ➢ in two parent families: the non -working parent is physically, mentally or emotionally unable to care for their children as documented by a physician or mental health professional. ➢ For all families, when the extended family member is physically, mentally or emotionally unable to care for their children as documented by a physician or mental health professional; or when the extended family member or legally exempt provider has been the subject of a founded child abuse or neglect report; or involved in situations of domestic violence; substance abuse; or criminal activity. What is the definition of a reasonable distance from an individual's home or work site for which appropriate childcare would be considered unavailable? 15 miles radius of home or prospective employment — or between the location of home and prospective employment. See above. Per 26-2-716 (2.5) C.R.S., please attach all official written county policies related to childcare availability in your county. Please use additional pages as necessary. Section 6 - Domestic Violence and the Family Violence Option Please answer the following questions about the Domestic Violence and the Family Violence Option. Please use additional pages as necessary. How will your county create an environment that ensures that victims of domestic violence are able to voluntarily disclose abuse in a confidential manner? Participants will receive services in a culturally and language appropriate and confidential manner. Interviews will be conducted in a private office. Interviews will be paced in a manner that develops rapport and trust. Staff are trained in the domestic violence option and utilize the state approved domestic violence packet to screen and identify victims of domestic violence. Personal safety will be explored with all applicants. How will your county assure that appropriate domestic violence services are available to participants of the Colorado Works Program? Staff are trained in the domestic violence option and utilize the state approved domestic violence packet. Information on domestic violence and local domestic violence services will be displayed in reception areas and interview rooms. Service coordination will occur with local domestic violence programs, law enforcement and mental health services. How will your county assure that appropriate referrals are made to appropriate domestic violence services for Colorado Works participants? Staff are trained in the domestic violence option and utilize the state approved domestic violence packet to refer the victims to appropriate counseling or other services. Additionally, the Department has developed written protocols with the local domestic violence agency. What procedures are in place to provide State approved domestic violence training to county staff and to any entity with which the county has a contract for service? How often is the training provided? How will your county verify that contractors receive domestic violence training? What qualifications and/or credentials are required for the individual(s) providing domestic violence training for your county? WORKS Staff attend state sponsored domestic violence training. Eagle County will utilize training provided by staff certified by the Colorado Department of Human Services or from community based domestic violence programs. How will your county assure domestic violence training is provided to county staff and contractors? (check one) X State provided training _X_ State approved training provided by our county _X Contract for training Will your county be implementing the Family Violence Option? Yes XX No Section 77 Earned Income Tax Credit Per Section 26-2-709 (2) (b) C.R.S., please describe how you help participants apply for and receive the federal earned income tax credit. Please use additional pages as necessary. Posters on the Earned Income Tax Credit are displayed in all offices. Participants are provided information and technical assistance in how to apply for the federal earned income tax credit. Section 8 - Individual Development Accounts Per Section 26-2-716 (2) (g) C.R.S., please describe how you make available opportunities for Individual Development Accounts (IDAs). Please use additional pages as necessary. Individual Development Accounts will be established for individuals upon request. Individual development accounts may be used to set aside funds for home purchase, business capitalization, or higher education in accordance with federal law. Section 9 Statutory Rape Prevention The Personal Responsibility and Work Opportunity Reconciliation Act (PRWORA) requires each state to "conduct a program designed to reach State and local law enforcement officials, the education system, and relevant counseling services, that provides education and training on the problem of statutory rape so that teenage pregnancy prevention programs may be expanded in scope to include men." While not required by state statute, please provide us any information you have about any programs in your county designed to implement this federal requirement. Please use additional pages as necessary. To be best of our knowledge there is not a formalized program of community outreach and education in Eagle County to provide training to law enforcement, educators or counselors on the issue of statutory rape. Eagle County Health & Human Services provides family planning services and community education on teen pregnancy prevention. The Red Ribbon Project, a community non-profit provides community education on sexually transmitted diseases and prevention of teen pregnancy with an emphasis on reaching Hispanic students. Section 10 - Out -of -Wedlock Birth Prevention The Personal Responsibility and Work Opportunity Reconciliation Act (PRWORA) requires each state to "establish goals and take action to prevent and reduce the incidence of out -of -wedlock pregnancies, with special emphasis on teenage pregnancies, and establish numerical goals for reducing the illegitimacy ratio of the State (as defined in section 403(a)(2)(B)) for calendar years 1996 through 2005." While not required by state statute, please provide us any information you have about any programs in your county designed to reduce the incidence of out -of -wedlock births, and particularly those programs that emphasize reducing the incidence of teen-age out -of -wedlock births. Please use additional pages as necessary. Eagle County HHS provides family planning services and services for sexually transmitted diseases through a Title X grant from CDPHE. Referrals to other medical providers to reduce the incidence of unwanted pregnancies are made as appropriate. Information on family planning options is made available. Section 11 - Grandparent Guardianship Per C.R.S. 26-2-709(1)(a.5), which of the following need standards do you use to determine eligibility for an assistance unit containing a grandchild who was in foster care and who exited foster care into the legal custody or legal guardianship of a grandparent? The need standard available for counties to determine eligibility under the Colorado Works program for all applicants and participants The need standard equal to the average foster care home maintenance X payment Section 12 - 60 Month Hardship Extensions Per C.R.S. 26-2-716(5)(a), please describe any additional county -defined hardship criteria that you accept as basis to provide hardship extensions to pay cash assistance to assistance units that have received 60 months of federal TANF assistance. None. Section 13 - Mental Health/Substance Abuse Per C.R.S. 26-2-724, please describe the method you use to screen applicants for mental health and substance abuse issues. Applicants are screened for mental health & substance abuse issues during the basic assessment utilizing the following tools: a. New York State Behavioral Checklist b. The CAGE Questionnaire, if indicated through behavior or response C. Michigan Alcoholism Screen Test, if indicated behavior or response HHS TANF Case Manager connects families in need of mental health and substance abuse services with appropriate providers. TANF funding for professional assessment and treatment services is available under the HHS TANF purchased services program. Section 14 - Community Resource Investment Assistance Per C.R.S. 26-2-707.5(2), please submit policies regarding: 1. the types of community resources in which you invest 2. the purpose of such community resource investment 3. the income eligibility standards 4. the process used to determine eligibility 5. the county's dispute resolution processes See Eagle County Policies. Section 15 - Segregated Funding Per C.R.S. 26-2-714(5.5)(b)(II), please describe your policies in each of the following areas in which you use segregated funding: Eagle County is not using segregated funds at this time. When the decision is made to segregate funds, that segregation will occur according to State rules and regulations. Capital Construction Cash assistance without counting towards the 60 -month limit for federal TANF assistance Non -citizens Medical services Purposes 3 (reducing the incidence of out -of -wedlock pregnancies) and 4 (encourage the formation and maintenance of two-parent families) of TANF to people who would not otherwise meet TANF eligibility criteria Other Program Descriptions If not already addressed previously, for each of the categories listed below, please describe in as much detail as you would like, the benefits or services provided. Details to consider in your description(s) could include the purpose(s) of the program; amounts, frequency and duration of any subsidies; eligibility criteria for receipt of benefits or services; the types of expenditures covered with TANF funds; additional funding source(s) used, e.g. WtW, WIA, etc. Attach any program descriptions or other information as appropriate, and any related county policies. Please use additional pages as necessary. Subsidized Employment Not available in the Eagle County plan. Work Incentives Not available in the Eagle County plan. Education Incentives High school graduation; GED; and post secondary education incentives available on an individual family basis. Housing Assistance available on an individual family basis. See diversion, lump sum payments. Transportation Assistance available on an individual family basis. Postsecondary Education Assistance available on an individual family basis. Noncustodial Parents Assistance available on an individual basis through Other - Assistance -Services and County Diversion Controlled Substance Abuse Policy Assistance available on an individual basis. Additional Types of Benefits or Services Auto Purchase Plan: Assistance available on an individual basis. Up to 6 months equivalent of BCA.