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TANF Family Economic Security (FES) - Financial Literacy Program

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

Eligibility
1.1 Age

Q1: Are youth 16 -19 years old who are no longer enrolled in high school eligible for Financial Literacy?

A1: Yes.  The RFP language in Section I B 2) states:  “Anyone age 16-18 or up to age 19 if still in high school”, which is interpreted to mean that anyone age 16-18, regardless of school attendance may be served.  If the individual is between the ages of 18-19, they must be attending high school or an equivalent program, e.g., home schooling or alternative learning program, in order to receive services.  This service population matches the TANF service population.  Based on this, high school dropouts can be served, provided they are under the age of 18.


  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 Literacy 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: By serving adults over age 18 “who are not receiving TANF cash assistance,” the grantee will not be able to take referrals from the WoRC program. Is this your intent?

A3: Yes, this was the intent. There can be no duplication of services between TANF and FES Literacy programs.


Q4: If a dependent under 18 is receiving a TANF cash assistance payment, but not the adults, does this make adults ineligible?

A4: 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. 

1.2 TANF Eligible

Q1: Are we required to run a TANF eligibility check on anything other than income and household status size?

A1: The FES contractor must verify initial eligibility for the program by confirming that the adults in the household are not receiving TANF but are “otherwise TANF-eligible. The FES contractor must also ensure that the adults do not begin receiving TANF while on FES.  This can be accomplished with a sign in sheet where the participant checks off the programs they are participating in when they come for FES services.  If they check they are receiving TANF, they would be dis-enrolled from the FES Program.


Q2:  Would an individual who is a permanent resident of the US, has a Montana Driver’s License and Social Security card be considered eligible for the FES SEP program?  If he meets the other criteria.

A2:  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.


Q3: Do we need to verify identity of applicant's household members?

A3: Verification of Identity is not needed for TANF eligibility. TANF participants must be US citizens or 3eligible aliens.


Q4: If a participant is open on TANF Cash and working with a Work Readiness Component (WoRC) case manager, can that case manager use information from CHIMES to put in the file confirming eligibility?

A4: WoRC and FES are two separate programs.  The participant needs to obtain that information from OPA as OPA determines the eligibility. 

1.3 IDA/Matched Savings

Q1: Is there any reason someone who has been a participant in the FES Literacy program could not be a participant in the FES program the following year, provided they meet all the qualifications?


A1: The individual could participate in the next program year, as long as they meet all the qualifications.  There are no limits on the number of years/months a participant can be enrolled in Module 1 programs. Programs must continue to increase the participant’s financial knowledge and budgeting skills. Repeating the same course year after year would not be a benefit to the participant unless the course provides updated information. If a participant is enrolled in a program they have already participated in or completed, documentation should be retained in the case file that would verify the need for the participant to be enrolled in the duplicate program.


Q2: Are GED or HI-SET students eligible?

A2: Yes, as long as they meet all the other eligibility requirements.


Q3: Moving/Funds transfers—what happens if a student moves during the contract year?

A3: If enrolled and would like to continue participating after the move, this would okay.


Q4: If an applicant applies for the program and qualifies under the 185% of percent guidelines, is that proof enough of financial need or do you need other documentation?  If so what do you need?  If there is form, please provide it.

A4:  A completed and signed FES Combination application for Literacy and Employment Services has a self-attestation of eligibility.

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: Must participants in the FES Literacy Program be employed?


A1: No.  However, they must be willing to make the commitment to participate voluntarily in personal, financial and economic growth through education, training or other services.

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.

IDA Accounts and Matched Savings
3.1 Funding Cycle

Q1:  Are FES Literacy Program funds federal TANF dollars?  Can federal FES Literacy Program funds be used as match to access federal IDA funds?

A1: FES funds are federal TANF funds and cannot be used for match funds in another federal program.

3.2 Post- secondary education/Apprentice

Q1: Does the department have a requirement or preference that matched savings funds be used only at Montana post-secondary institutions and training providers?  What about online providers?

A1: In order to maintain consistency between the matched savings funds and the IDA funds, we would require that the institution meet the definition of an “eligible educational institution” as outlined in regulation.


  Q2:  Can the FES Matched Savings program be used to save for a FES match and a MESA matched educational account through Montana College.  They save once but get both FES and MESA match.


A2:  No. These are two separate programs. The Matched Savings program through the TANF FES program can only be used to match participant funds from earned income and must be kept in a financial institution.  Matched funds cannot be used for a match in another program.


Q3: Does “good standing” refer to the participant’s status only as a college student? Or can “good standing” refer to the participant’s current education level (e.g., high school).

A3: This is meant for a college student.



Q4: Would youth participating in our program be able to purchase a vehicle if it fits with their postsecondary goals?

 A4: No, only adults are allowed to purchase vehicles.   Youth are limited to:   Post-secondary education and Electronic devices.  See educational guidelines and electronic guidelines in the Financial Literacy Guideline Document.  


Q5: If the participant’s educational goals include pursuing an apprenticeship rather than traditional postsecondary education, can FES funds be used to assist with that process?

A5: Yes—FES Matched Savings monies can be used to purse apprenticeships.   

3.3 Employment/income

Q1: Must the employment be “formal” employment, or is it acceptable for the employment to be informal, e.g., working for a family member, babysitting, ranch work, etc.

A1: Earned income from either “formal” employment or informal employment must be used.
Formal employment: employment where an employer has a formal tax ID number, such as Taco Johns.
Informal employment: employer has no formal tax ID number, such as the neighbor who you may have watched their children for them or mowed the lawn or shoveled snow for. 


Q2:  What type of documentation is needed for verifying informal employment?

A2:  A letter to verify the informal employment is acceptable—letter from babysitter, etc.


Q3: Must the earned income be the STUDENT’s earned income, or is it allowable to have earned income deposits from the student’s PARENT (s)?

A3:  The earned income used for deposits must be the students.


Q4: Can a stipend be considered earned income? (For example, for students in Job Corps).

A4: Yes. The participant must “do or complete” an action in order to receive the funds.


Q5: Are we correct in our understanding that once participants meet their savings goal and their matched funds are applied to appropriate purchases, the participant’s savings is theirs to use as they see fit? In other words, is there a specific requirement that the participant’s savings be directed towards the same postsecondary education goal being funded by matched funds?

A5: The participant’s money can be used at their discretion.  However, FES funds must be paid to a vendor.  

Record keeping and bookkeeping
4.1 Invoicing

Q1: What records must be retained by the contractor and for what time frame?


A1:  Records that pertain to participant benefits, 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. 

4.2 Check lists

Q1:   For the Year End reports can a participant that completed a High School Diploma/GED in May 2013 be listed as completed HS/GED in June 2013-December 2013 contract extension.


A1:   No.  The participant completed the training/High school diploma in SFY 2013 (May 2013).  They would be considered a newly enrolled participant for SFY 2014 (July 1, 2013 to December 31, 2013).  We need to count unduplicated participants.

Other
5.1 Press releases

Q1: Does DPHHS have any guidelines, requirements, restrictions, etc., about publicizing the grant award and planned program?

A1: Any brochures or fliers must be reviewed prior to distribution, including recruitment materials and press releases.


Q2: Does DPHHS do any media outreach relative to grant awards?

A2: No.

5.2 HIPPA

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.  

5.3 Supportive Services

Q1: Can Family Economic Security program funds be used to purchase eyeglasses, prescriptions, health insurance, etc.


A1: Per the Personal Responsibility and Work Opportunity Act (PRWORA), TANF Federal funds cannot be used for medical purchases including eyeglasses, etc.

5.4 Miscellaneous

Q1: Can contractors purchase snacks for financial literacy sessions when actually incorporated into a lesson?

A1: Yes, Snacks may be purchased for enrolled participants in the FES Literacy program to be used during classes or training related to FES Literacy and must be reasonable and in moderation.


Q2: Is it acceptable for us to sub-contract with MCUCD to manage the participant account tracking component? This would be a modification to our original proposal – is this allowed?

A2.  All requests to subcontract must be submitted in writing to Stephanie Wilkins for approval, prior to services being delivered. 


Q3: Is it allowable for us to purchase and prepare materials for the entire contract period in one transaction – e.g., purchase binders, print materials, etc. Or, must this be done on an as-needed basis? We believe we can obtain cost efficiencies by doing it all upfront.

A3:  Supplies and materials must be purchased and expended during the contract period and must be within the budget guidelines


Q4: May contractors alter our curriculum with some substitutions, with the main elements remaining the same, from that which was listed in the proposal?

A4: Any changes to the Service Delivery plan must be submitted in writing to Stephanie Wilkins and it must be approved by the Department prior to any change in the Service Delivery being taken.


 Q5: May contractors make additions to the application submitted in our proposal to assist in our tracking process?

A5: Yes. The proposed changes will need to be submitted to the department for prior approval.

 

Page last updated: 05/06/2014