Hotline 6/12: EDP, employment development plan, TAFDC

From the Hotline

If you have any questions on this column or other policy and procedural material, please have your Hotline
designee call the Policy Hotline at 617-348-8478.

Q. 1. What questions should I ask before approving a TAFDC client’s Employment Development Plan
(EDP)?

A. 1. Before approving your client’s EDP, ask:

1. Is the EDP consistent with the rules set forth in the Employment Services Program requirements found in 106 CMR 207.000 through 106 CMR 207.180 and Work Program requirements found in and 106 CMR 203.400?
2. Are the specified activities consistent with the client’s job goal?
3. Is the EDP consistent with the results of the client’s initial assessment or reassessment; and
4. Are there component activities and support services available?

For more information on completing an EDP, see 106 CMR 207.110.

Q. 2. My TAFDC client has an eight-month-old child. She wants to volunteer 20 hours each week at a
community service site. Can I approve this client’s EDP?

A. 2. It depends. To approve this EDP, the limits of the federal Fair Labor Standards Act (FLSA), along
with the more general EDP rules, must be followed. For more information on the FLSA, refer to
106 CMR 207.170. For more information on the EDP rules, see Q.1. and A.1. above.
Note: Since this client’s child is not yet of school age, a referral for child care should be completed
after her EDP is approved. For more information on child care services, refer to
106 CMR 207.210(A).

Q. 3. If my client had one child who is eight years old and she wanted to participate 20 hours each week at
a community service site, could I approve this activity?

A. 3. It depends. Since this client has an eight-year-old child, her work program requirement calls for 30
hours of participation per week. Assuming the community service activity your client selected is
consistent with her assessment and job goal, her other EDP activity(ies) would still need to meet
additional TAFDC requirements. Since this client has chosen to participate in a community service
activity, these other requirements include:

1. compliance with the limits of the FLSA; and
2. an additional activity, such as employment.

The activity in combination with the community service must total 30 hours each week.

Q. 4. My client has one child who is eight years old and because of FLSA requirements, she is planning to
perform 20 hours of community service and ten hours of ESL classes, each month. Is she eligible for a
child care referral now that her EDP has been approved?

A.4 Yes. Since this client has complied with FLSA rules and has an already approved EDP, a child care
referral should be completed. Remember that in addition to FLSA restrictions, ESP regulations
require community service participation hours to correspond with the client’s dependent’s school
hours. However, this is not always possible and a child care referral should still be made. For more
information on child care referrals for community service, see106 CMR 207.170(A).

Note: If this client wanted to do 30 hours of community service and was unwilling to choose an
additional activity to conform with the FLSA requirements, then her EDP would not be approved and
the child care referral could not be completed.

Q. 5. When referring a TAFDC client for child care, how many months should the Child Care Referral
Notice cover?

A. 5. A child care referral for an ESP activity may cover up to six months or continue until the of the
activity, whichever is sooner. If the EDP includes employment, the child care referral should be
generated for twelve months.

• If the ESP activity continues beyond six months and the client continues to meet the participation requirements for the activity, a new Child Care Referral Notice should be given to the client prior to the beginning of the seventh month to avoid any interruption in care and/or activity attendance.

• If the client is participating in overlapping activities, use the activity with the earliest activity end date when completing the Child Care Referral Notice. At the end of that activity, revise the Child Care Referral Notice for the duration of any remaining activity(ies), or for six months, whichever is sooner.