Q: We are revising our procedures and have a few questions about the procedures for updating waiver factors.
1. The seven waiver factors “must be in existence and updated in SPARQ during the program year in which the waiver is requested or in the last quarter of the previous program year, if the waiver is requested in the first quarter of a program year”. We are planning on conducting recertifications in March of this year and update waiver factors during the same time. Would we be able to request a waiver for the participants reaching their limit in the first quarter of Program year 2011 based on the March verification date or would we have to check and revalidate it again between April and June?
A: You will need to revalidate the waiver factors after 3/31/11. For participants who will reach their duration limit in Q1 PY 11, you cannot request an extension unless at least one waiver factor has been updated during Q4 PY 10 or Q1 PY 11. If you delay your updating of the waiver factors until April, then you might not have to update them again for this subset of participants who will reach their limit in Q1 PY 11. Note that the new listing of persistent unemployment areas will not be available until mid-April. That might be another reason to delay your updating a bit.
2. To receive MIN credit for any of 6 waiver factors (plus age 75+ automatic) we must validate the 6 waiver factors during the same program year and must do so every program year the participant remains on the program. For example, if a participant waiver is updated in June 2011 and the same participant exits in September 2011, we must validate and update the waiver factor prior to their exit to receive credit for MIN in PY2011. Is our understanding correct here?
3. It is not necessary to update waiver factors for a participant that started their enrollment in PY2010 to receive credit for it for in the same program year. To be more specific: If a participant started in July 2010 and one or more waiver factors were captured and validated, we will get the credit for those waiver factors in PY2010. Is this right also?
4. Do we have to update the waiver factor in the last quarter if a participant starts in July 2011, has one more waiver factors at enrollment, and will be reaching their durational limit in July 2012?
A: If you are updating the waiver factor to support an extension, then yes. See response to question 1. If you are updating the waiver factor for MiN credit in PY 11, then also yes. See response to question 2.
5. The latest QPR specifications released on 1/26/2010 is not enforcing the condition (must be validated each program year) for these two waiver factors: Low literacy skills and Limited English proficiency. This is conflicting with the training and guidance we received, can you clarify?
A: That is because LEP and low literacy are also priorities of service. If they are entered as such at the time of enrollment, the QPR will count them in the MiN measure for as long as the participant is enrolled regardless of whether they are updated. However, if they are being used to support an extension request, then they must be updated like any of the other waiver factors. See response to question 1. It is confusing, and the logic of listing these two barriers in the MiN as both priorities of service and waiver factors has never been apparent to us. The regulations and procedures have tried to do the best we can with the requirements that Congress gave us.