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TANF Family Economic Security (FES)-Employment Services Program

Frequently Asked Questions (FAQ’S)
Updated 4/2014

1. Eligibility
1.1  Age

Q1 Do adults over age 18 need to have children in the home to be eligible for FES?

A1  Yes. This program is funded with TANF monies and must serve “Eligible Families”.  Pregnant women in their last trimester with no other children are eligible.

Q2: Do adults ages 16 to 19 years old have to be considered a household of their own?

A2:  To clarify, we define an adult as anyone over the age of 18, unless they are 18 – 19 and still attending high school.  An individual under the age of 18 or between the ages of 18 -19 and still in high school is not considered an adult, they are considered a minor child. 
Any adult, by the above definition, must have a child in their household to be eligible for FES services, regardless of their living situation.  Any minor child, by the above definition, is eligible for services, if the household gross income is at or below 185% of the Federal Poverty Level, regardless of their living situation. 

Q3: If a dependent under 18 is receiving TANF cash assistance payment, but not the adults, does this make adults ineligible?

A3: If an adult is not receiving TANF cash assistance, they still must be “otherwise TANF-eligible” to receive FES services.  You will need to look at whether or not the adult would be eligible to receive TANF to determine if they are eligible for FES.  Individuals who are sanctioned from TANF, who fail requirements or are receiving SSI are not “otherwise TANF-eligible”.  Please work with your local OPA for assistance if you have questions about TANF non-financial eligibility.

Q4: May multiple household members in an eligible household be separate participants?  Or is it limited to one adult and/or one minor?

A4: Yes, multiple household members may be separate participants.  For instance, Mom, Dad and their 17 year old daughter are not on TANF but have income below 185% of poverty.  Both parents and the minor daughter are eligible for the Specialized Training Program; both parents are eligible for the Subsidized Employment Program services. 

1.2 TANF Eligible

Q1: What defines “otherwise” TANF eligible?

A1: Individuals are considered “otherwise” TANF eligible provided the meet the following criteria:

  • Have a minor child living in the home who is related within the 5th degree of kinship and who is not receiving foster care payments;
  • Are not sanctioned and/or serving an ineligibility period due to a sanction of another household member;
  • Are not an illegal alien;
  • Are not receiving SSI; and
  • Are a resident of Montana. 

Remember, the individual also must meet the income guidelines for the program. 
We have updated the Subsidized Employment Application form to include a self-declaration of non-financial eligibility criteria.  This application form is a required form for those individuals entering into the SEP program; the applicant/participant must sign the form in order to be eligible for services.  The form also contains a disclaimer stating that the information provided is accurate and the individual understands that providing false information will result in termination of the program and potential overpayment of services received.
Individuals entering into the AES program are already receiving TANF, therefore they are TANF eligible.

Q2: Do participants need to have received or been a member of a TANF household at any point in the past?

A2: No. We want to open the program to more people.

Q3: Is an individual who has exhausted 60 months of TANF eligible for SEP?

A3: Yes, provided they meet all other eligibility criteria and are “otherwise” TANF eligible.

Q4: How would I document a potential SEP participant if they are related within the 5th degree of kinship?  Example: Uncle is the caretaker for his minor niece and nephew.

A4: If he is in receipt of TANF – receiving a Child only grant, the relationship has already been established by OPA and documentation that he is currently in receipt of TANF would be suffice. 
If the participant is not receiving TANF then you would need to have birth certificates showing how the uncle is related to the child.  If you had uncles birth certificate and the birth mother or fathers birth certificate you could compare to see if they had one/two parents in common.
Example:   Uncle Joe is caring for his nephew Billy.  Billy’s mother is Louise Lamoure.  Louise and Joe are brother and sister. 
By looking at Billy’s birth certificate you can see that Louise is the birth mother of Billy.  
By looking at Louise’s birth certificate you can see that Louise’s mother is Lulu
By Looking at Joe’s birth certificate you can see that his mother is also Lulu, therefore showing the relationship between Joe, Louise and Billy.

Q5: If an individual is receiving Unemployment Benefits (UI), are they eligible for this program?  Can the UI continue once they begin the program (if they are eligible?)

A5: The individual receiving UI benefits may be eligible for the TANF employment services programs, provided they meet all other eligibility requirements, including the income guidelines and for AESP the receipt of TANF cash assistance. 
Please advise the participant to report the employment income to DOLI to avoid an overpayment of UI.  If DOLI has determined they are still eligible for UI, even with the new employment income, UI can continue.

Q6: Are sanctioned individuals eligible for the SEP Program?

A6: No, when an individual is serving a sanction penalty or ineligibility period base on their own non-compliance, or is in a household that is serving an ineligibility period based on any household member’s non-compliance, they are not considered to be ‘TANF eligible’, therefore they are ineligible for SEP. 
We have updated the SEP application form to include a question about sanction ineligibility periods.


Q7: If a participant is open and working with a WoRC case manager, can that case manager print anything from CHIMES to put in the file confirming eligibility?

A7: WoRC and FES Employment Services are two separate programs.  The participant needs to obtain that information from Office of Public Assistance (OPA) as OPA determines the eligibility.  A Contractors access to CHIMES is for serving WoRC participants not FES participants. 

Family Economic Security Program Combination Application


Q1: If an individual is receiving SEP services, are they eligible for other TANF services, e.g., FES Financial Literacy Services? 

            A1: The answer to this may vary from case to case.  We have talked about the “building” or stacking blocks of programs which lead to upward mobility of the participant.  It is allowable for an AES or SEP participant to receive FES Financial Literacy Services, provided they meet the eligibility criteria for the FES Literacy Services program and are receiving separate types of services that lead to upward mobility. 

Q2: If an individual is receiving TANF at the time they enter the Accelerated Employment Support Program (AESP) or the Subsidized Employment Program (SEP) and the income they earn causes their TANF to close, are they still eligible for the program?

A2: Yes, provided they continue to meet the criteria to be considered “otherwise” TANF eligible.  (See above).

Q3:  Would an individual who is a permanent resident of the U.S., has a Montana Driver’s License and Social Security card be considered eligible for the FES Employment Services program if he meets the other criteria?

A3:  Participants receiving TANF funding or TANF services must be a U.S. Citizen, U.S. National or qualified alien.  A participant that is Lawfully Admitted to the United States for Permanent Resident (LAPR) must meet certain criteria. You will need to contact Stephanie Wilkins, TANF Program Manager for a determination of alien status.

Q4: May individuals enroll in more than one FES Employment Services program.

A4:  Yes, but not at the same time. Participants cannot be duel enrolled in the FES – TANF Employment Services modules.  Example: A participant cannot be enrolled in the TANF Subsidized Employment Program (SEP) and the TANF Specialized Training Program (STP) at the same time. The participant must complete one of the FES – TANF Employment Services modules before being enrolled in another. Participants are not eligible to enroll in both the AESP and SEP programs.
2. Stability
2.1 Housing

Q1: What qualifies as stable housing?  How do we measure this?

A1: We will measure the stability of the family by the individual or family being in a position to take advantage of job advancement, having reliable and available means of transportation and/or determining if the household is current on their rent/mortgage.

2.2 Employment

Q1: How do we measure “stability” in terms of the service population definition? 

A1: We will measure the stability of the family by the individual or family being in a position to take advantage of job advancement, having reliable and available means of transportation and/or determining if the household is current on their rent/mortgage.

2.3 Health

Q1: What qualifies as "stable health"?  Is this health benefits? Or overall general "good" health and how do we measure this?

A1: They can be considered to be in stable health if they do not have a statement from a qualified medical professional indicating they are unable to participate in any activities. A measurement of good health is the ability to participate in the program.

2.4 Transportation

Q1: How do we measure stable transportation?

A1: We will measure the stability of the family by the individual or family being in a position to take advantage of job advancement, having reliable and available means of transportation and/or determining if the household is current on their rent/mortgage.

3. Subsidized Employment
3.1 High Demand Fields

Q1: Is Montana Labor Market Data sufficient to define “high demand” occupations? Are there other data sources you would prefer?

A1: Montana Labor Market Data is sufficient. At this time, it is not necessary to use other data sources; however, keep in mind the changing employment picture in Montana.

Q2: Is the Subsidized Employment (SEP) application form required?

A2: Yes, the SEP application form is a required form and must be completed and signed prior to determining eligibility for the SEP Program.

Family Economic Security Program Combination Application

Q3: Can we use a copy of an un-signed pay stub instead of a signed timesheet?

A3:  No.  As stated in the Service Delivery Agreement, the employer will pay the participant the wages agreed to in the contract.  The employer will then submit an invoice to the FES – Employment Services Contractor for the agreed upon wage percentage reimbursement and must provide a copy of a completed timesheet signed by both the employer and the TANF participant to the FES – Employment Services Contractor with the invoice.

3.2 Contract

Q1:  Can we write two (2) separate contracts for an individual?  For example, we have an employer who wants to hire a participant for 20 hours per week.  The employer has another business where the individual could also work 20 hours per week.  Is this allowable?

A1: Yes, this is allowable, provided the participant does not exceed the 700 hour limit between the 2 placements.  We see this as similar to someone being hired into full-time employment. 

Q2: Is it appropriate to make an SEP placement within a FES contractor’s agency and/or at a federal agency?

A2: It is not appropriate to make an SEP placement within a FES contractor’s own agency; however placements at federal agencies are appropriate. 

3.3 Overtime/Holiday Pay

Q1: The program overview indicates we cannot pay overtime, but we have an employer who pays a differential for Awake, Night or Holiday pay.  Is this an allowable expenditure?

A1: Yes, since these are considered differential pay and not overtime, this is an allowable use of program funds, provided all other non-program employees could receive the same benefit.  A program participant cannot receive pay that other employees would not receive if they were doing the same type of work, hours, etc. 

Q2: We have a question on holiday pay.  In the WIA program, holiday hours can be paid if the individual works the day before and the day after a holiday and the employer observes the holiday.  If the individual does not work full-time the hours are pro-rated.  Will this be allowable in the TANF Employment Services Program?

A2: Our direction is to follow whatever the specific employer does.  If they pay “regular” employees holiday pay under the same guidelines listed for WIA, then yes, we could pay the same under these programs.  If they do not, then the answer is no because we cannot be seen as being more generous to subsidized employees than regular employees. 

Q3: Is the employment income from the TANF Employment Services program (AESP or SEP) countable income for other public assistance programs?

A3: Yes.  Income from these programs is considered employment income and is countable income.  It is not excluded for public assistance programs. 

3.4 Child Support

Q2: Does an SEP participant have to comply with Child Support Enforcement?

A2: No, the SEP participant is not held to any Child Support Enforcement Division requirements.

Q2: Are SEP wages subject to garnishment, e.g., from child support enforcement?

A2: Legal has advised us that the answer to this is no, according to MCA 53-2-101and 53-2-607.

3.5 Worker's Comp

Q1: What scope code do I use for worker’s compensation?

A1: You will need to contact Worker’s Comp for direction/guidance on the correct scope codes to use

3.6 Unemployment

Q1: Should an employer report individuals in the SEP program on their quarterly UI reports?

A1: No, they should not report the names or wages of any individuals who are working under this program on their UI reports as this program meets the requirements to qualify under the exemption for work relief in the unemployment insurance law. 

4. Specialized Training Program
4.1 Applying and Accepting All Other Funding Sources

Q1: May we incorporate cost sharing into trainings that provide information on economic sectors growth and employment so that not only those individuals that are not FES eligible could still participate in the event. An example could be informational events, job fairs, and flagger training (1-3 day trainings/events).

A1: Yes. FES trainings/classes may be open to individuals that are not enrolled in the FES Program. However, Departmental reimbursement of the cost of the training/class will be based on a training/class roster supplied to the Department. The roster and other appropriate documentation of the expenditure will be subject to cost allocation for this program. 

4.2 Cost Sharing

Q1:   If 90-day training is provided outside of Montana (Qualified Rigging Training in Utah, for example), can Specialized Training Program  (STP) funds cover this?  Similarly, if there is online 90-day training programs can STP cover these?  

A1: Yes.  The STP program can be used to cover costs of out of state training and online training courses.  The STP funding cannot be used for room and board even if it is included in the tuition.  Room and board must be paid with other funding. They would need to document that the course was not offered in state and that it was reasonable and necessary to attend the training

4.3 Out of State Training/On-line

Q1: If an individual would like to take a continuing education course (computer education at Great Falls College MSU, for example) can the Specialized Training Program (STP) pay for this?

A1:  Depends on what you mean by continuing education courses.  Continuing education classes typically assist in retaining a professional license. The participant should already have the skills needed to obtain full time employment in a high demand field with increased wages.  However, if you are referring to a participant taking a computer class that would help the participant receive an increased wage or promotion, then yes.  Remember, participants in this program should already have demonstrated qualifications by having stable housing, heath, employment and transportation.

4.4 Continuing Education

Q1:  I understand that the Specialized Training Program (STP) is permitted to cover total 90-day programs, and cannot supplement entire 2-year or 4-year educational programs.  However, as I understand this there may be exceptions to the 90-day term. Our WIA program sees many potential applicants that wish to supplement the cost of their final semester of school. Can STP do something similar, or is this even possible as an exception?  

A1: Yes.  Payment of post-secondary education tuition and fees can be paid for through STP program.

          • A $2,000 limitation per participant,
          •  Verification of enrollment in the education institution and a copy of the class schedule must be obtained and retained in the case file,
          • Participant must be in good standing with the institution (GPA of 2.0 or higher),
          • documentation of the need for the fees, tuition or supplies (e.g., books, calculators, etc. ) for the class retained in the case file,
          • STP funds must be paid to a vendor and be supported by receipts retained in the case file.  
        • Tuition and fees cannot be paid in advance for courses that will be completed after the contract period.  All courses/classes must be completed before the end of the contract period.
        • If the classes/program exceeds the 90 day term, the contractor must request in writing for approval, prior to providing services to the participant, to Stephanie Wilkins, TANF Program Manager.  
4.5 Exception to the 90 Specialized Training Program limit

Q1: If the employer requires a driving record check (e.g., home care attendants, etc.) for employment, can TANF Employment Services funds pay for that driving record check?
A1: As long as the check is required for all employees and is required as an employment requirement, the program can reimburse the employer for the cost of this check.  This is similar to the background checks that may be required for employment purposes. 

5. Background Checks
5.1 Driving Records

Q1: If the employer requires a driving record check (e.g., home care attendants, etc.) for employment, can TANF Employment Services funds pay for that driving record check?

A1: As long as the check is required for all employees and is required as an employment requirement, the program can reimburse the employer for the cost of this check.  This is similar to the background checks that may be required for employment purposes. 

5.2 Basic Background Checks

Q1: If a business requires a background check, are they responsible for the cost or is the FES contractor responsible?

A1: This question is best addressed with the business.  It is our thought that the business will conduct the background check as they would for any employee.  If there a cost associated with the background check, that cost could be invoiced to the contractor for payment. 

6. Record keeping and bookkeeping
6.1 Invoicing

Q1: “Invoicing will be done in accordance with the practices of the Department.” Can you explain this further? Is there a description available? Can you provide a list detailing the process?

A1: The FES Contract is a reimbursable contract. Department follows regulations, contract limitations and OMB guidance.

FES Contractor must bill on the reimbursement form provided by the Department and all expenditures for each separately funded line item listed above must be separated in operator’s accounting systems. The FES Contractor may not receive monies provided through this contract as reimbursement for the costs of services that are reimbursed from other sources. Separate records must be kept that identify the source and application of funds for federal and state sponsored activities. The records must be supported by source documentation. These contract funds cannot be commingled with any other monies for any purpose.

6.2 Check Lists

Q1: Contractors are aware that many items must be saved throughout the program. Is there a checklist available to ensure that no items are missed, or is this something, the contractor should create?

Q1:  Records that pertain to participant benefits (AESP/SEP or STP), eligibility determinations, supportive services and time frame the participant was served in a program must be retained for 7 years.  Fiscal documentation must also be retained for 7 years. 

7. Allowable activities/uses
7.1 Hours of Employment

Q1: We would like to start an individual placement for 10-15 hours per week. Is that allowable?

A1: Our goal is to have the minimum amount of employment hours no less than 20 per week. However, there can be exceptions to this, as long as the goal of the program (full time permanent employment) is considered.

7.2 Hours of Time at Contractor or Contractor’s

Q1:  Are the participants limited to 700 hours in the program or is it limited to 700 hours per employer?

A1: The limit of 700 hours is per participant.  (Note – even though permanent employment is not a requirement of the employer for SEP, it is something to consider prior to placing the individual.  Remember, the goal continues to be permanent, long-term employment.)

8. Other
8.1 Press Releases

Q1: Is it okay for us to issue press releases or announcements of funding received and the opening of applications?

A1:  Any brochures or fliers must be reviewed by the Department prior to distribution, including recruitment materials and press releases.  Please email materials to Stephanie Wilkins.  


Q1: Is there a list of HIPAA training providers that we can have access to for North Central Montana?

A1: The Department requires that contractors be compliant with HIPAA requirements and as part of the contract process will provide an assurance form which lists several federal, state, and public resources regarding HIPAA. However the Department cannot make recommendations or referrals to these resources.  

8.3 Supportive Services

Q1: Can supportive services be issued directly to a participant?

A1: No.  Supportive services must always be issued as a vendor payment.  Also remember that gift or gas cards are NOT an allowable use of supportive service funds. 

Q2: Can gas only gift cards be issued to the participant?

A2: Per the SDA, no gift cards are allowable.  “Please note that for purposes of this program, gift cards, payment of legal fees and purchasing of vehicles are not allowable uses of supportive services.

Q3:  Are fees associated with the NCLEX test an allowable expense for a participant in the Specialized Training Program?

 A3:  The participant must provide verification that financial aid (Pell grants/loans/scholarships, etc.)  is not available to pay for the NCLEX exam or classes.  If the participant has exhausted financial aid on educational expenses, Supportive Services or Specialized Training Program funds can be used to assist with the cost.


Page last updated: 05/06/2014