The U.S. Department of Labor (DOL) has rethought its stance on Work Opportunity Tax Credit (WOTC) applications submitted in 2014 through 2016 that were rejected for WOTC certification by State Work Agencies (SWAs). The DOL, in Training and Employment Guidance Letter No. 07-17, said that the Social Security Administration (SSA) would be re-evaluating Target Group H submissions, which involve individuals receiving Supplemental Security Income (SSI), that were denied or rejected without any real background for the years 2014 to 2016.
This provides companies a second chance to receive WOTC credits for SSI recipients for the years 2014, 2015, and 2016. Organizations will have the opportunity to resubmit SSI applications in efforts to obtain WOTC certification from their SWA. The SSA has expanded its verification process to include all SSI recipients in the Ticket Program Manager (TPM) business process at no cost to SWAs.
In order to qualify for SSI, an individual must have less than $2,000 in total assets and possess a disability that prevents them from substantial gainful activity. According to the SSA, if an individual is over the age of 65 they do not need to be completely disabled in order to qualify for SSI. A job candidate also must have received SSI within the last 60 days in order for the employer to receive a WOTC certification.
The automated TPM process has been updated to include data about SSI and the individuals who receive this funding. In the past, the TPM process did not contain this information, which resulted in the mass rejections. The TPM process is responsible for facilitating beneficiary access to ticket service providers, including organizations like the Employment Networks (EN), State Vocational Rehabilitation (VR) agencies, Work Incentives Planning Assistance (WIPA) projects, and Protection and Advocacy for Beneficiaries of Social Security (PABSS).
Previously, the means to attain SSI information was not available for many states. Washington state, for instance, was denying all WOTC certifications for submissions for SSI applicants simply because the information was not available.
Other states have not processed the SSI certification requests and rejected the submissions, resulting in a significant application backlog. SWAs now have been instructed to follow the steps regarding the resubmissions of certifications outlined in Training and Employment Guidance Letter No. 7-17, which should cut down the backlog of applications that were rejected.
DOL also is allowing third-party agencies to re-submit applications on behalf of employers if they believe their job candidates were receiving SSI and were eligible for the WOTC. States like Tennessee and Connecticut have opted to review all the denial and rejection letters themselves in order to see which applicants were actually receiving SSI.
Automated technology like TPM has made the process of applying and receiving credits for employers much easier. Organizations unaware of this update should take advantage of the opportunity and re-submit applications from 2014 to 2016 for employees receiving SSI.
This process may be easier to complete for organizations using an automated HR platform containing centralized digital files in combination with a third-party vendor experienced in WOTC application submissions. For some going it alone, digging up old forms may be challenging, if not impossible, to find and organize.
If organizations haven’t already implemented an automated HR platform, it’s not too late. Platforms like Humanefits integrate the WOTC screening process into the hiring process at no cost to you. This allows for a much greater likelihood of having WOTC applications certified to receive federal tax credits. If you aren’t using a tool like this to help you expedite your WOTC applications, you may want to rethink that decision. There is a lot of money to be gained if these WOTC applications are submitted with the correct information.