NA Work Requirements
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The NA Work Requirements, the exemptions from the work requirements, and how NA work registration is completed are included in this section.
Policy
All NA participants aged 16 through 59 who do not meet a work requirement exemption are Work Registrants(g). As a condition of eligibility for NA, work registrants are required to comply with all of the following work requirements:
●Register for work with FAA for new and renewal applications once every 12 months.
●Continue employment without voluntarily quitting or reducing work hours below 30 hours per week.
●Accept a job offer paying average weekly earnings equal to or exceeding the federal minimum wage(g) times 30 hours.
●Not to be disqualified from receiving Unemployment Insurance.
●Provide information about employment status and availability to work.
During the interview, FAA registers the participants for work unless exempt from the NA work requirements. See NA Work Registration for more information about participants who are registered for work.
When a participant is a work registrant and 18 through 52 years of age, the participant may also be subject to the Able Bodied Adults Without Dependents (ABAWD) time limits. See ABAWD Time Limits and Work Requirements for more information about ABAWD time limits and work requirements.
NA disqualifications are imposed when a work registrant fails to complete the NA work requirements. FAA reviews good cause with the participant before imposing an NA disqualification to determine whether a disqualification is needed. See Good Cause Reasons for examples of good cause reasons to quit a job, reduce work hours, or refuse a job.
FAA explains the NA work requirements and the exemptions when any of the following occurs:
●When conducting an NA interview, and at least one budgetary unit participant is a work registrant.
●When a change is reported that causes a participant to no longer be eligible for an NA work requirement exemption.
●When adding an NA participant aged 16 through 59 to the budgetary unit.
When screening NA participants for work registration, FAA screens each participant to determine whether a referral to Supplemental Nutrition Assistance Program Career Advancement Network (SNAP CAN) is appropriate. See SNAP CAN Screening and Referral for detailed information.
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NA Work Requirement Exemptions
During the interview, FAA reviews the NA work requirement exemptions for NA participants aged 16 through 59 to determine whether the participant is exempt. When a participant does not meet a work requirement exemption, the participant is a Work Registrant(g). For work registrant requirements, see NA Work Requirements.
A participant may qualify for more than one work requirement exemption. When this occurs, FAA applies the work requirement exemption reason that allows the participant the longest exemption period.
All participants screened for work requirement exemptions are also screened to determine whether a referral is appropriate for SNAP CAN.
When an NA participant is exempt or nonexempt, FAA determines whether a referral to SNAP CAN is appropriate for the participant. (See SNAP CAN Screening and Referral for more information.)
Exemptions from the NA work requirements include all of the following:
●Age
Age Exemption
A participant who meets one of the following is exempt from the NA work requirements:
●Under age 16
NOTE A participant aged 16 or 17 is exempt only when the participant is any of the following:
●Not the Primary Informant, head of household in the CA case.
●Attending school at least half-time, as designated by the school.
●Enrolled in an employment training program on at least a half-time basis.
●Age 60 or older
Alcohol or Drug Treatment Program Exemption
A participant who is either an inpatient or outpatient and participates in an alcohol or drug or treatment or rehabilitation program is exempt from NA work requirements and the Able Bodied Adult without Dependents (ABAWD) work requirement.
CA Jobs Program Participation Exemption
CA participants who are required to participate in the CA Jobs Program are exempt from the NA work requirements.
Care of a Child Under Age Six Exemption
A participant responsible for caring for a dependent child under the age of six is exempt from the NA work requirements.
Only one parent or budgetary unit participant can be exempt for this reason.
Caretaker for an Incapacitated Person Exemption
A participant responsible for the care of an incapacitated person is exempt from the NA work requirements and the ABAWD work requirements.
The incapacitated person is not required to reside in the budgetary unit or the same living quarters.
Cuban and Haitian Entrant Good Cause
Participants who meet the definition of a Cuban and Haitian Entrant may be temporarily exempt from the NA Work Requirement when FAA verifies one of the following:
●FAA verifies the participant is not employment-authorized through one of the following:
The Systematic Alien Verification for Entitlements (SAVE)/Verify Legal Presence (VLP) interface in HEAplus
An external SAVE from the United States Department of Homeland Security (DHS) Verification Information System (VIS) website
●FAA verifies the participant is temporarily employment-authorized for only three calendar months(g) through one of the following:
The SAVE/VLP interface in HEAplus
An external SAVE from the VIS website
Hard copy verification of the participant’s USCIS Form I-766 Employment Authorization Document
Eligibility for the temporary good cause Cuban and Haitian Entrant exemption must be reviewed when any of the following occur:
●During the Renewal process
●Re-application after benefits have been stopped or denied
●The budgetary unit reports a change, using any of the following methods:
Change Report (FAA-0412A) form received in person, by mail, or by fax
Mid-Approval Contact (MAC) form
MAC Unity form
NOTE Completion of a Unity form is done with the assistance of FAA staff. To complete and sign a Unity form, contact FAA by one of the following ways:
●Telephone. (See Customer Care Center for contact information and hours.)
●In person at any FAA office. (See the DES Office Locator webpage found at https://des.az.gov/find-your-local-office and click ‘Find a DES Office’ to locate the nearest FAA office.)
Employed Exemption
A participant who meets any of the following employment criteria is exempt from the NA work requirements:
●Employed with averaged weekly earnings that equal or exceed an amount that is 30 hours multiplied by the federal minimum wage(g).
●Self-employed for a minimum average of 30 hours weekly. For self-employed participants to be exempt, when the participant works fewer than 30 hours weekly, the net self-employed weekly income needs to equal the federal minimum wage multiplied by 30 hours.
NOTE Self-employment net income is the gross income minus the allowable costs of producing the income.
●Employed as a migrant or seasonal farm worker, all of the following apply:
Is following the job stream
Is not living in the participant's home project area
Meets one of the following:
●Is working a minimum of 30 hours weekly
●Is under contract or agreement to begin employment within 30 calendar days
●Receiving in-kind income when work is done for 30 hours per week.
NOTE Do not include hours employed in voluntary work in which no wages, in-kind income, or in-kind benefits(g) are paid when determining the 30 hours per week.
FAA uses the employed NA work requirement exemption only when the participant does not qualify for any other exemption.
NOTE Participants meeting the employment exemption are subject to disqualification due to voluntarily quitting a job or reducing work hours without a good cause reason.
(For more information on meeting the required hours or income per week, see Example 1 and Example 2)
Refugee Exemption
A participant is exempt from ABAWD and NA work requirements when participating at least half time in an Office of Refugee Resettlement (ORR) program.
ORR programs are considered recognized training programs.
Student Exemption
A participant who meets all of the following criteria is exempt from NA work requirements and the ABAWD work requirement:
●Enrolled in any recognized school, including training programs or institutions of higher education(g).
●Attending at least half-time, as defined by the institution. See Adult Student Eligibility for NA to determine whether an NA participant who is a student is eligible.
Consider the participant exempt during normal periods of class attendance, vacation, and recess, until the participant meets one of the following:
●Graduates
●Is suspended
●Is expelled
●Drops out
●Expresses an intention not to register for the next normal school term (excluding summer sessions)
Tribal
A participant mandatory to participate in a CA Tribal Native Employment Works (NEW) Program or a Tribal TANF Employment Program is exempt from NA work requirements. FAA completes referrals as appropriate to the Tribal New and Tribal TANF Employment Program.
See Tribal TANF Assistance Programs for more information about the Tribal NEW Program and the Tribal TANF Employment Program.
Unemployment Insurance
A participant who meets one of the following criteria is exempt from NA work requirements and the ABAWD work requirement:
●Receiving Unemployment insurance (UI).
●Applied and is not yet receiving UI, when the participant is required to register for work with the Job Service office as part of the UI application process.
●Appealing a UI decision. Continued UI eligibility during the UI appeals process requires ongoing participation with the Job Service office.
Unfit for Work
A Participant who is medically certified as mentally or physically unfit for work is exempt from the NA work requirements. Unfit for work can include anything that affects the ability to work, maintain employment, or restricts the range of employment opportunities including, and not limited to, any of the following:
●Mental conditions
Learning disability
Emotional challenge
Difficulty handling stressful situations, or being around people
Victim of domestic violence, sexual harassment, sexual assault, or stalking
●Physical condition
Recovering from surgery
Physical limitations due to disability
Receipt of temporary or permanent disability benefits from a governmental or private source
A participant does not need to have a disability to be unfit for work. Unfitness for work may not always be visible. Unfitness for work may be temporary or permanent.
When the participant claims they are unfit for work, additional verification is not required when the unfitness can be verified through one or more of the following:
●AZTECS interface
●HEAplus hubs
●Worker observation when the unfitness for work is obvious
When the participant claims they are unfit for work, and the unfitness is not obvious, the participant is required to provide verification of unfitness from a medically qualified source(g).
Participants considered temporarily unfit for work are exempt until renewal unless verification is received that specifies an expected end date for the exemption reason.
Participants with a long-term or permanent disability are exempt from the NA work requirements.
NA Work Registration
FAA explains the NA work registration process and the NA requirement work exemptions when at least one member of the budgetary unit is a Work Registrant(g). FAA registers participants for work when any of the following occurs:
●During the interview, a participant is determined to be a work registrant.
●When a reported change causes an NA participant to no longer be eligible for a work requirement exemption.
●When adding a work registrant to an existing NA case.
FAA sends an NA work requirements notice at benefit approval for new or renewal applications and reported changes in all of the following circumstances:
●When at least one budgetary unit participant is a work registrant.
●When a work registrant is added to the budgetary unit.
●When an exempt participant becomes a work registrant.
The NA work requirements notice provides the NA work requirement information to the budgetary unit, which includes all of the following:
●Who in the budgetary unit is subject to the NA work requirements.
●The exemptions from the NA work requirements.
●How a participant can contact FAA to report a change in their circumstances.
●Periods of disqualification for failing to comply with the NA work requirements.
●When the participant is referred to Supplemental Nutrition Assistance Program Career Advancement Network (SNAP CAN), the notice also includes the contact information for SNAP CAN.
●How to request an appeal.
NA Work Requirements Appeals Process
Each budgetary unit has a right to an appeal when benefits are denied, reduced, or stopped due to failure or refusal to comply with the NA work requirements.
The budgetary unit can appeal FAA actions and has the right to examine their case file before the appeal date. When an appeal is scheduled, the Appellate Services Administration (ASA) provides sufficient advance notice.
See Right to an Appeal Hearing for all participants' rights to ask for a legal review of their NA or CA case when they disagree with a decision or action taken by FAA.
Procedures
NA Work Requirements
All NA participants aged 16 through 59 who do not meet a work requirement exemption are Work Registrants(g).
When a work registrant is 18 through 52 years of age, determine whether they are also subject to the Able Bodied Adults Without Dependents (ABAWD) time limits and work requirements. See Able Bodied Adults Without Dependents (ABAWD) time limits and work requirements for more information on ABAWD time limits and work requirements.
Register the participants for work during the interview unless exempt from the NA work requirements.
The NA ABAWD and Work Requirements and SNAP CAN Referral Script (FAA-1786A) includes detailed information about the NA work requirements. Use the FAA-1786A to explain the NA Work Requirements at all interviews and when adding a nonexempt participant to a budgetary unit.
Use the FAA-1786A to explain the NA work requirements and review the exemptions when any of the following occur:
●When conducting an NA interview, and at least one budgetary unit member is a work registrant.
●When a change report causes a participant to no longer be eligible for a work requirement exemption, complete all of the following:
Attempt to contact the participant to complete the SNAP CAN Screening and Referral.
When the participant is unavailable for SNAP CAN Screening and Referral, do not pend benefits for SNAP CAN Screening and Referral
Make any appropriate change on WORW.
●When adding an NA participant aged 16 through 59 to the budgetary unit.
NOTE Explaining the NA Work Requirements is unnecessary when the entire budgetary unit is exempt.
When screening NA participants for NA work registration, also screen each participant to determine whether a referral to Supplemental Nutrition Assistance Program Career Advancement Network (SNAP CAN) is appropriate. (See SNAP CAN Screening and Referral for procedures on how to complete screening and referrals.)
NA Work Requirement Exemptions
During the interview, review the NA Work Requirement exemptions for all participants aged 16 through 59.
A participant may qualify for more than one work requirement exemption. When this occurs, apply the exemption reason that allows the participant the longest exemption period.
All participants screened for exemptions are also screened to determine whether a referral to Supplemental Nutrition Assistance Program Career Advancement Network (SNAP CAN) is appropriate.
When an NA participant states they would like to participate in SNAP CAN, determine whether it is appropriate to refer the participant to SNAP CAN. (See SNAP CAN Screening and Referral on how to complete screening and referrals.)
Cuban and Haitian Entrant Good Cause
When the participant states they are not employment authorized, complete all of the following:
●Determine whether the participant meets any other NA Work Requirement exemption.
●Review the Systematic Alien Verification for Entitlements (SAVE)/Verify Legal Presence (VLP) interface in HEAplus.
●Review the external United States Department of Homeland Security (DHS) Verification Information System (VIS) SAVE, when applicable. The SAVE must be uploaded to the case file(g).
●Review the immigration documents submitted by the participant.
●Document the case file including how the eligibility for good cause was verified.
Verification
System interfaces and the case file(g) must be reviewed before verification is requested.
No additional verification is needed when AZTECS interface or HEAplus hubs have verified any reason for unfit for work.
Unfit for work can be verified by the worker’s observation. Thoroughly document the case file when using this option.
When age is questionable, see Date of Birth Verification for a list of documents FAA accepts as proof of age.
Rehabilitation officials can provide a written statement verifying treatment program participation. FAA can complete a collateral contact to the rehabilitation program to verify participation.
Verification for a caretaker of an incapacitated person includes a statement from a treatment provider(g) indicating the adult participant is needed as a full-time caretaker. Employment is verified when the participant verifies earned income for employment and self-employment. (See the verification section of Wages and Salaries for examples of what can be used for verification.)
School attendance can be verified with any of the following sources when requested by FAA:
●Correspondence from the school
●Registration form
●School records or school official’s statement
●Scholarship awards
For information about adult students and eligibility requirements, see Adult Student Eligibility for NA.
Verification of unfit for work and the extent of limitations and anticipated length of the condition or circumstances includes, and is not limited to, all of the following:
●Receipt of temporary or permanent disability benefits.
●VA disability benefits are required to be rated or paid as a total disability by the Veterans Administration (VA) to qualify.
●Observation by FAA. Thoroughly document the case file(g) when using this option.
●A written statement that supports the extent and anticipated length of the disability from a medical provider(g).
●A completed Verification of Disability (FAA-1249A) form.
●Participation in a sheltered workshop.
●Participation in Vocational Rehabilitation.
●Participation with Rehabilitation Service Administration (RSA).
Verification of a Cuban and Haitian Entrant without employment authorization includes, and is not limited to, any of the following:
●Systematic Alien Verification for Entitlements (SAVE)/Verify Legal Presence (VLP) interface in HEAplus
●External SAVE from the United States Department of Homeland Security (DHS) Verification Information System (VIS) website
●United States Citizenship and Immigration Services (USCIS) Form I-766 Employment Authorization Document
AZTECS Keying Procedures
NA Work Requirements
At each NA interview, complete all of the following:
●Determine which participants are included in the NA benefit (with the IN Participation Code on SEPA).
●Evaluate these participants to determine who is exempt from NA Work Requirements. (See Keying NA Work Requirement Exemptions for AZTECS keying instructions)
●Key the correct Work Requirement Exemption Code in the PAR/EXEM field on WORW for each NA participant with the IN Participation Coded on SEPA.
●Key Y in the REF Y/N field on WORW to make a referral to Supplemental Nutrition Assistance Program Career Advancement Network (SNAP CAN). (See SNAP CAN Screening and Referral on how to complete screening and referrals.)
Key the WR Work Registration Code in the PAR/EXM field on WORW for all non-exempt participants. The WR Work Registration Code indicates the participant is a work registrant.
To ensure the NA Work Requirements (X640) notice is sent, the WR Work Registration Code must be entered in the PAR/EXEM field on WORW.
NOTE When the X640 notice is not sent, send the NA Work Requirements (F040) notice.
When a reported change results in a participant losing their NA Work Requirement exemption, complete all of the following:
●Determine whether the participant meets another Work Requirement Exemption.
●Update WORW with the new Work Requirement Exemption Code.
●Document the case file(g) with the new exemption.
●When the participant does not meet an exemption, register the participant for work.
NOTE When the participant does not meet an exemption and is 18 through 52 years of age, determine whether the participant is subject to the ABAWD time limits. See ABAWD Time Limits and Work Requirements for more information about ABAWD time limits and work requirements.
Keying NA Work Requirement Exemptions
The following NA Work Requirement Exemptions Codes are keyed on WORW. Some NA work requirement exemptions are considered ABAWD exemptions and are keyed on WERE. See each for the following for AZTECS keying information:
Age Exemption
A participant who meets one of the following is exempt from the NA Work Requirements:
●Under age 16
NOTE A participant aged 16 or 17 is exempt only when the participant is one of the following:
●Not the Primary Informant, head of household in a CA case.
●Attending school at least half-time, as designated by the school.
●Enrolled in an employment training program on at least a half-time basis.
●Age 60 or older
Key AG in the PAR/EXEM FS field on WORW.
See ABAWD Exemptions to apply the correct ABAWD exemption policy for age.
Alcohol or Drug Treatment Center Exemption
For the NA Work Requirements exemption, key DR in the PAR/EXEM FS field on WORW.
For the ABAWD exemption, key DR in the EXPT RSN FS field on WERE.
CA Jobs Program Participation Exemption
Participants participating in the CA Jobs Program are exempt from the NA Work Requirements.
When a participant meets this exemption, key WN in the PAR/EXEM field on WORW. For the ABAWD exemption, key WN in the EXPT RSN FS field on WERE.
Care of a Child Under Age Six Exemption
A participant who is responsible for the care of a dependent child under the age of six is exempt from NA Work Requirements.
Key CH in the PAR/EXEM FS field on WORW.
Only one parent or adult budgetary unit participant can be exempt using this code.
See ABAWD Exemptions to apply the correct ABAWD exemption policy for residing with a minor dependent child.
Caretaker for an Incapacitated Person Exemption
A participant responsible for the care of an incapacitated person is exempt from NA Work Requirements and the ABAWD work requirement.
For the NA Work Requirement exemption, key NC in the PAR/EXEM FS field on WORW.
For the ABAWD exemption, key NC in the EXPT RSN FS field on WERE.
Cuban and Haitian Entrant Good Cause
Key CU in the STAT field on NOCS
Key HC in the PAR/EXEM FS field on WORW and WERE for a participant who is verified as a Cuban and Haitian Entrant without employment authorization and does not meet any other NA Work Requirement exemption.
NOTE When NOCS is not keyed properly, the following message displays on WORW and WERE: *ERROR* HC NOT VALID FOR CLIENT. STATUS MUST BE CU ON NOCS.
Employed Exemption
A participant who continues to be employed without voluntarily quitting or reducing work hours below 30 hours per week is exempt:
Key EM in the PAR/EXEM FS field on WORW.
See Keying the WERE Screen for ABAWD Work Requirements to apply the correct ABAWD Employment Exemption Code.
Migrant Seasonal Farm Worker Exemption
A participant who meets all of the following criteria is exempt from NA work requirements and ABAWD work requirements:
●Employed as a migrant or seasonal farm worker, and all of the following apply:
Is following the job stream
Is not living in the participant's home project area
●Meets one of the following:
Is working a minimum of 30 hours weekly
Is under contract or agreement to begin employment within 30 calendar days
For the NA Work Requirement exemption, key EM in the PAR/EXEM FS field on WORW.
For the ABAWD exemption, key MS in the EXPT RSN FS field on WERE.
(See Migrant Farm Workers or Seasonal Farm Workers for additional information.)
Refugee Exemption
A participant who meets the refugee criteria is exempt from ABAWD and NA Work Requirements.
For the NA Work Requirement exemption, key RF in the PAR/EXEM FS field on WORW.
For the ABAWD exemption, key RF in the EXPT RSN FS field on WERE.
See Refugee for policy about participants who are considered a Refugee.
Student Exemption
A participant who is an NA Eligible Student is exempt from NA Work Requirements and the ABAWD work requirement. See Adult Students Eligibility for NA for policy requirements when a participant is enrolled at least half-time in an institution of higher education(g).
For the NA Work Requirement exemption, key ST in the PAR/EXEM FS field on WORW.
For the ABAWD exemption, key ST in the EXPT RSN FS field on WERE.
Tribal Exemption
A participant who is mandatory to participate in a CA Tribal Native Employment Works (NEW) Program or a Tribal TANF Employment Program is exempt from the NA Work Requirements and the ABAWD work requirement.
For the NA Work Requirement exemption, key RT in the PAR/EXEM FS field on WORW.
For the ABAWD exemption, key RT in the EXPT RSN FS field on WERE.
Unemployment insurance (UI) Exemption
Participants who have applied for and are not yet receiving UI and are required to register for work with the Job Service office as part of the UI application process or are appealing a UI decision.
For the NA requirement work exemption, key UI in the PAR/EXEM FS field on WORW.
For the ABAWD exemption, key UI in the EXPT RSN FS field on WERE.
Unfit for Work Exemption
A participant who is mentally or physically unfit for work and incapable of engaging in gainful employment is exempt from the NA Work Requirements.
For the NA requirement work exemption, key UF in the PAR/EXEM FS field on WORW.
For the ABAWD exemption, key UF in the EXPT RSN FS field on WERE.
When verification of unfit for work must be requested for regular and expedited NA applications, do not key the UF Exemption Reason Code until verification is received.
Thoroughly document the case file why written verification is requested.
Examples
1) The working hours of a participant may fluctuate weekly or be paid other than weekly. The weekly average hours needs to equal or exceed 30 hours.
●Fluctuating Weekly Hours
Week 1 20 hours
Week 2 31 hours
Week 3 40 hours
Week 4 29 hours
Total Hours 120
Average Hours÷4 (weeks) = 30
●Fluctuating Bi-weekly or Semi-monthly Hours
Pay Period 1 50 hours
Pay Period 2 70 hours
Total Hours 120÷2 (pay periods) = 60
Average Hours÷2 (weeks) = 30
2) The total gross weekly earnings or in-kind benefit(g) need to total the federal minimum wage multiplied by 30.
●The weekly average income of participants may fluctuate weekly or be paid other than weekly. The weekly average hours needs to equal or exceed 30 hours.
($7.25 X 30 hrs. = $217.50)
Week 1 $200
Week 2 $190
Week 3 $300
Week 4 $180
Total Wages $870
Average Wages÷4 (weeks) = $217.50
●Federal minimum bi-weekly or semi-monthly average:
($7.25 X 30 hrs. = $217.50 X 2 weeks = $435)
Pay Period 1 $390
Pay Period 2 $480
Total Wages $870
Average Wages÷2 (pay periods) = $435
In-Kind Benefit calculated to a monthly amount:
$7.25 X 30 hrs. = $217.50 X 4 weeks = $870
●A participant lives in a relative’s home and works instead of paying rent and utilities by maintaining the yard, landscaping, and repairs to the home. The owner states the participant’s rent is worth $750 a month, and utilities run around $120 per month. The total in-kind benefit is $870.
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Legal Authorities
7 CFR 273.7
7CFR 273.7(b)(1)(iii)
7CFR 273.7(b)(1)(vi)
7CFR 273.7(b)(1)(viii)
7 CFR 273.7(b) & (c)
7 CFR 273.7(c)
7 CFR 273.7(c)(i)
7 CFR 273.7(c)(18)
7 CFR 273.7(d)(4)
7 CFR 273.24(c)(5)
ARS 41-1954(1)(b) and (3)
AAC R6-10-101 to 304
last revised 03/19/2024