July 1st, 2013
One of the things we work diligently on at The Next Step is ensuring that the number one tool for assisting ex-offenders with finding employment opportunities is secure. The Work Opportunity Tax Credit is an extremely valuable incentive to employers and enables employers to offer employment.
The letter below is a proposal to the Department of Labor to amend regulations to improve and expedite State WOTC Units processing of Federal ex-offenders.
Our thanks to John White and Julia Peterson of WOTC Solutions, Lenexa, KS who brought this matter to our attention and assisted in preparation of the proposal.
Ms. Carmen Ortiz
National WOTC Coordinator
Department of Labor
A matter has arisen on processing by State WOTC units of certification requests for Federal (not state) ex-offenders. Federal Bureau of Prisons has an online system that allows verification that an individual is an ex-offender by inserting their prison ID number into the FBOP Inmate Locator which anyone can access and you can inspect athttp://www.bop.gov/iloc2/LocateInmate.isp2.
For Federal ex-offenders, WOTC Coalition members are submitting prison ID number as well as name, SSN, and DOB as evidence of ex-offender status, urging the prisoner ID number be matched to the readily available online BOP Inmate Locator to verify ex-offender status (the Locator covers both current and former inmates).
However, State Workforce Agencies have been resisting this because it’s not specifically allowed; they are adhering narrowly to the list of allowable documentation contained in WOTC Handbook, 3rd Edition (copy attached.) We feel sure these allowable methods of documentation weren’t intended to exclude other official sources that are accurate, easy, and fast to consult, but we’ve come to the conclusion States won’t cease the time-consuming process of seeking cumbersome court, correction institution, or parole records for Federal ex-offenders unless DOL authorizes use of the FBOP Inmate Locator.
We propose that the Federal Bureau of Prisons Inmate Locator cited above be added to the source list for documentation to conserve staff time and funds in the verification process for federally-charged ex-felons being considered for certification. We’ve been in touch with FBOP and are assured this web site is an official record that contains accurate and up-to-date information on Federal inmates and former inmates which can be used with a high degree of confidence to determine WOTC eligibility based on full name, date of birth, SSN, and prison ID number of a Federal ex-inmate. Using this automated site will be a great advantage to all WOTC offices and staff and will save the program time and money.
If you agree, please consider issuing an advisory in writing to SWA’s pending revision of the Handbook, and incorporating this advice in training whenever possible.
Many thanks for the opportunity to bring this matter to your attention.
PAUL E. SUPLIZIO
Work Opportunity Tax Credit Coalition