In order to effectively serve employment and training participants across programs in the Department of Employment and Economic Development's (DEED's) Employment and Training Programs Division (ETP), this policy provides guidelines for case management and maintaining case notes for the following programs: Workforce Innovation and Opportunity Act (WIOA) Dislocated Worker and Minnesota Dislocated Worker programs, and Trade Adjustment Assistance (TAA).
Workforce development programs are designed around a case management approach, and case notes are an essential component of effective case management practices. Case notes document and maintain information about participants, their progress, and the process and rationale for providing services to program participants. Case notes also provide information regarding the importance and value of services offered to participants and aid in evaluating and planning future services.
Contact with Participant
Counselors must attempt to contact each participant at least once every 30 days. The participant must make live contact with the service provider at least once every 30 days. The service provider should include the results of the attempts and the participant contact in the case notes. Live contact is one-to-one contact between service provider and participant in any of the following forms:
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In-person conversation
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Telephone conversation (or voicemail from participant);
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Electronic message including email (may not include mass emails, unless the participant responds directly to a mass email with an update), text message (SMS), instant message (IM), or message sent via social media (e.g., Facebook, Twitter, etc); and/or
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Postal mail update from participant.
Case Notes
Case notes must provide a complete, accurate, timely and concise explanation of frequency and type of contact with customers, as well as services provided and the outcomes associated with those services. Case notes must be written so that the reader has all background information for the participant, as well as the purpose of meetings, and the where, why, and how contact took place.
Case notes must record details of the customer's participation in all activities, including:
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Participation in associated programs or activities (e.g. Veterans Program, State Services for the Blind, Trade Adjustment Assistance, Vocational Rehabilitation, etc.)
Privacy
In general, all case notes, including all documentation and work conducted with taxpayer dollars, must remain available to DEED and authorized parties. Information specific to an individual must comply with the Minnesota Government Data Practices Act (M.S. 13).
Case notes in Workforce One that do not contain information classified as private by M.S. 13 must be public, unless one of the following occurs, in which case the case note can be marked "private" in WF1:
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The program participant has disclosed a physical or mental health concern that may result in a barrier to employment, a reason for their individual employment plan to be modified, or a reason for program closure. The case note should be marked private in WF1 if the case manager finds it necessary to include details of the condition.
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Recording the specific case note will be in violation of HIPAA Privacy Rule, which protects the privacy of individually identifiable health information. When this occurs, mark the case note as private.
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The program participant feels he/she is in danger, and is concerned for his/her safety. This would include temporary contact information for the participant if s/he moves to a new location until the concern has ended. Mark the entire case as private.
DEED requires case managers to maintain a separate paper file with required eligibility and paper documentation maintained about a participant's health, mental health, and/or safety concerns in a locked location other than with the original file. The private separate paper file must not be included in the regular file for the participant. The primary and secondary case managers will only share the separate private file with DEED program monitors.
Participant Access to Case Notes
If the participant requests his/her case notes, service providers must provide a copy in paper and/or electronic form as requested. Case notes are subject to subpoena, and can be used during appeal or grievance processes, and in a court of law.
Workforce One Case Note Entry Requirement
DEED requires all service providers enter case notes electronically into Workforce One (WF1). Staff must adhere to DEED's Data Entry Timeliness and Content Policy.