As I wrote yesterday, the recent Training and Employment Guidance Letter (TEGL) 3-09 included the revised WOTC form that we’ve been waiting for  — DOL ETA 9061.   TEGL 3-09 also indicated that within two weeks, WOTC centers would be prohibited from accepting the old version of the form.  The last day to use the old form, therefore, was September 16th.
HOWEVER, my contact in California’s WOTC center tells me today that the U.S. Department of Labor seems to be backing down from that deadline (although perhaps only informally at this point). As a result, the California WOTC center is not yet rejecting WOTC applications that use the old forms.
While RestaWOTC is prepared to use the new form, the extremely short notice given by the U.S. Department of Labor creates a hardship for many employers.  Consider, for example, a multi-unit franchise with 300 locations scattered throughout the nation.  Two weeks is simply not enough time for your HR department to become informed, prepare new materials, and then ship and replace the old forms that have already been inventoried at each of your locations.
If you’ve been following best practices and formally integrating the WOTC forms into your hiring process, you might even have to deconstruct and then reconstruct your entire inventories of new employee orientation packets.
WOTC centers in some states, however, have given notice that as instructed by TEGL 3-09, they will not accept the old forms as of September 17th (yesterday).  We will keep you informed as this issue progresses.  Rest assured that if you are one of RestaWOTC’ clients, we have the situation under control.