Final Guidance about Disconnected Youth and Unemployed Veteran WOTC Groups

I have wanted to write about this for a couple of weeks now, but as you know if you follow the news, there has been a lot going on.
On March 5, 2010 the U.S. Department of Labor’s Employment and Training Administration issued Training and Employment Guidance Letter NO. 3-09 Change 2.  (I’m not complaining, but even the names of these documents are complicated.)
This “TEGL” deals with issues that are critically important for employers who participate in the Work Opportunity Tax Credit (WOTC) program.  I’ll highlight the most pressing here.  If you want all the details, you can download the TEGL yourself by clicking here.
Use the August 2009 Form IRS 8850. First, this TEGL sets a deadline for requiring the use of the newest (August 2009) version of Form IRS 8850 – “Pre-Screening Notice and Certification Request for the Work Opportunity Credit.”  In a nut shell, use it now.  But there is some leeway allowed.
For the two newest target groups of Disconnected Youth and Unemployed Veterans, all submissions as of October 17, 2009 must use the August 2009 form.  I have found that the California WOTC unit will still accept timely applications using older versions, but will not issue a certification unless an August 2009 form is also submitted.
Please note that this absolute requirement applies only to applications under the Disconnected Youth and Unemployed Veteran target groups.  Submissions for other target groups using the June 2007 and May 2009 forms are still accepted.
Official Form for Disconnected Youth Self-Attestation.  Beginning 90 days from the publication date of this TEGL (I believe 90 days will expire on June 3, 2010), WOTC units can only accept a self-attestation from Disconnected Youth if the attestation is made with the DOL’s official ‘Youth Attestation Form.”  Until that date, home-made versions are still acceptable, as long as they meet statutory requirements.
In response to these rules, my team is now distibuting updated survey packets to all of our WOTC services clients.
If you have any questions at all about these developments, please feel welcome to contact me directly.  You can reach me at 800-655-5281, ext 101.  Or send me an e-mail at I will also welcome your call or correspondence.

Blog at