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SPSE Policy and Automation Subgroup Feedback
This survey gathers feedback on some unanswered SPSE policy questions. The feedback will guide discussions and inform the SPSE policy development process. SPSE will be a new W-2 placement. So, in all of your responses, please consider how the policy will interact with all of the W-2 program's moving parts.
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- EMPLOYER OF RECORD: DCF is considering whether to allow certain, non-W-2 agency 3rd parties to serve as the SPSE employer of record. For example, an SPSE worker could be the legal employee of a staffing agency, but actually work at a manufacturing company.
Do you think non-W-2 agency organizations (or orgs in which W-2 agencies have a financial interest), should be the SPSE employer of record?
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- EMPLOYER OF RECORD: Please explain your answer to the question above. *
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- EMPLOYER OF RECORD: Please brainstorm (even if you don't think it is good policy) ways that the 3rd party employer of record arrangement could be structured to provide worksite employers with a significantly different product/service than the CSJ program?*
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- EMPLOYER REQUIREMENTS: Statutes require DCF to establish employer requirements for SPSE employers. Please brainstorm what special employer requirements would be necessary if we allowed 3rd party employers of record. For example, the 2010 SPSE workgroup recommended that a W-2 agency or any organization in which the W-2 agency has a financial interest should not serve as SPSE employer of record.*
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- SUBSIDY CHECKS: Would you like DCF to explore CARES-generated SPSE subsidy checks? If you answer no, it is assumed that you would prefer that your agency would generate its own subsidy checks.*
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- The monthly SPSE subsidy is limited to the value of the monthly CSJ benefit. DCF is considering a policy that would not reduce the subsidy to the employer until a participant's monthly compensation falls below the monthly CSJ benefit amount.
For example, an SPSE participant is paid $10/hr and the SPSE agreement states the participant will work 30 hrs/wk, so the employer is reimbursed $673 for $1184 monthly take-home wages paid to the participant. In the second month of the placement, the participant only works 20 hrs/wk, so monthly take-home wages fall to $789. In this case, the employer would still be reimbursed the full $673. In the third month of the placement, the participant only works 15 hrs/wk, so the monthly take-home wages are $592. In this case, the employer is only reimbursed $592.
Consider the example above. From a W-2 agency standpoint, how would you like to respond to it (e.g. cancel the SPSE contract, mediate, don't intervene)?
Do you think this policy would set-up an incentive for employers to reduce SPSE participants' hours to the minimum needed to generate the full subsidy?
Are there any policy tools you would need to respond as you would like to that situation, or any policies that would prevent you from doing so?
Is there anything else we should consider about how the SPSE subsidy is calculated?*
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- MINIMUM COMPENSATION: SPSE law requires SPSE workers to take home at least as much as CSJ participants. To comply with this law, employers must contribute at least $60 per month to the costs of employing the SPSE worker ($60 would make up for the taxes taken from the workers' checks). However, we will most likely require a greater employer contribution.
What amount of employer contribution ensures sufficient employer buy-in without scaring employers away?
What are your general thoughts about how the employer contribution would impact SPSE marketability?
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- BENEFIT RECOVERY: DCF is considering whether to mirror the Trial Jobs benefit recovery policy. In Trial Jobs, subsidies paid on the participant's behalf during a time when that participant was ineligible for placement can be recovered directly from the participant. Do you agree or disagree with adding this policy to SPSE and why?*
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- MILWAUKEE OFFICE TRANSFERS: Please select the option that you would most prefer with respect to how to handel office transfers that would occur in the middle of an SPSE contract.
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- MILWAUKEE OFFICE TRANSFERS: Please provide your thoughts on SPSE office transfers. This is also an opportunity for you to suggest a different option than those listed in the question above. You may also comment on the difference between Milwaukee and BOS office transfers here.
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- REFUSAL TO PARTICIPATE: Both the 2010 SPSE workgroup and DCF management agree that SPSE should be voluntary. Would allowing agencies to close an SPSE participant’s case for non-cooperation compromise the program's voluntary nature? Please provide a recommendation on if and how refusal to participate policy should apply to SPSE.*
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- Should SPSE subsidize hours spent in employer-organized education and training performed by a 3rd party? *
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