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One-Stop Center Certification

DATE: 6/1/17

IS NEWa REVISED

PURPOSEThe Workforce Innovation and Opportunity Act (WIOA) requires Local Workforce Development

Board to establish objective criteria and procedures to assess the effectiveness, physical and

programmatic accessibility, and continuous improvement ofone-stop centers and the one-stop

delivery system.

The purpose of this policy is to communicate the Northwest Oregon Works Local Workforce

Development Area procedures for evaluating and certifying one-stop WorkSource Oregoncenters in the Northwest Oregon.

POLICYAll Comprehensive and Affiliate One-Stop Centers in the area need to be certified by June 30,

2017 and for every three (3) years afterwards. The certification process includes an on-site in-

person evaluation of each Comprehensive and Affiliate Center in the Northwest Oregon area

including an assessment of center effectiveness, physical and programmatic accessibility, and

will include continuous improvement of centers and the one-stop delivery system (WIOA sec.

121(g)). Northwest Oregon Works staff will evaluate each Center and the one-stop delivery

system to ensure compliance.

REFERENCEWIOA sec. 121(e)- Center programs and programmatic access.

• WIOA sec. 188 and the Americans with Disabilities Act of 1990 - Center

• WIOA see. 116- Center effectiveness.

• Compliance to the WorkSource Oregon Operational Standards

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WorkSource Oregon Center Certification

BACKGROUNDAs required by the Workforce Innovation and Opportunity Act (WIOA) and state policy. Northwest OregonWorks must certify the WorkSource Oregon (WSO) centers as comprehensive or affiliated sites every threeyears. There must be at least one comprehensive WorkSource center in the local workforce area. Below isthe basic criteria for certification of comprehensive and affiliated centers:

Comprehensive WSO Center I

Must provide access to the programs/ slices/ and activities of ALL required one-stop partners (WIOAsec. 121(b)(l)(B)), along with any additional partners as determined by the Local WDB.Must comply with the WSO Operational jStandards[Must be branded WSO and include na pt-oud partner of the American Job Center network"|Must be certified (to receive infrastructure funding under the state funding mechanism)|Must provide physical accessibility to individuals with disabilities

Affiliated WSO Center

pne or more of the required one-stop partners' programs, services, and activities are available to job^eekers and employers (Exception: No stand-alone Wagner-Peyser program center).

|Must comply with the WSO Operational [Standards (ifWIOA Title I and III are present)|Must be branded WSO and include "a p^oud partner of the American Job Center network" (if WIOADtle I and III are present) ]lust be certified (to receive infrastructiire funding under the state funding mechanism)

|Must provide physical accessibility to individuals with disabilities

It is also required in the center certification process to conduct on-site evaluation of each center to assesscenter effectiveness, physical and programmatic accessibility, and continuous improvement of centers andthe one-stop delivery system. Staff of Northwest Oregon Works has recently evaluated each center and theone-stop delivery system to ensure compliance the criteria and requirements.

P.O. Box 140, Lincoln City, OR 97367 541-264-4033 ; www.nworegonworks.org

On June 23, 2017, the Northwest Oregon Board and Local officials approved the certification of the centersfor the period of July 1, 2017 through June 30, 2020 as follows:

One (1) Comprehensive WorkSource CenterWorkSource Oregon- Astoria |450 Marine Dr. Suite 140Astoria, OR 97103 (503) 325-4821,Hours of Operation - Monday through Friday, 8:00 am to 5:00 pm

Five (5) Affiliated WorkSource CentersWorkSource Oregon - Corvallis545 SW 2nd StreetCon/allis, OR 97333 IHours of Operation - Monday through Friday, 8:00 am to 5:00 pm

WorkSource Oregon - Lincoln City4157 NW Hwy 101 Suite 250Lincoln City OR 97367Hours of Operation - Monday through Friday, 8:00 am to 5:00 pm

WorkSource Oregon - Newport120 NE Avery StreetNewport, OR 97365Hours of Operation - Monday through Friday, 8:00 am to 5:00 pm

WorkSource Oregon - St. Helens I500 N. Columbia River Hwy.St Helens, OR 97051Hours of Operation - Monday through Friday, 8:00 am to 5:00 pm

WorkSource Oregon - Tillamook2101 5th StreetTillamook, OR 97141Hours of Operation - Monday through Friday, 8:00 am to 5:00 pm

a^-

Heather DeSartExecutive Director

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One-Stop Center Certification Criteria

Comprehensive WSO (One-Stop) Center - Astoria[Must provide access to the programs, services, and activities of ALL required one-stop partners

|121(b)(l)(B)), along with any additional partners as determined by the Local WDB.

(WIOA see

Must comply with the WSO Operational Standards

Must be branded WSO and include "a proud partner of the American Job Center network"

[Must be certified (to receive infrastructure funding under the state funding mechanism)

Must provide physical accessibility to individuals with disabilities

Affiliate One-Stop Centers

1^33One or more of the required one-stop partnei's' programs, services, and activities are available

to job seekers and employers (Exception: No stand-alone Wagner-Peyser program center).

Must comply with the WSO Operational Standards (if Title I and III are present)Must be branded WSO and include "a proud partner of the American Job Center network" (if

Title I and III are present)

Must be certified (to receive infrastructure funding under the state funding mechanism)

Must provide physical accessibility to individuals with disabilities

Northwest Oregon Works (NOW) Informally monitors the centers for compliance with the certification measures. Ifconcerns arise, there is a meeting held via telephone or in-person to discuss the concern of NOW regarding thepartner compliance. If a suitable justification and/or explanation is not agreed upon, NOW may file a formal correctiveaction plan.

A corrective action plan is considered a formal Memorandum of Understanding (MOU) document. It is initiated byNOW and signed by both parties. The plan calls out required actions to bring the compliance into alignment with MODgoals, and includes timelines for such corrective action to take place. The plan also includes a date by which NOWstaff will meet with the partner to review progress with the corrective action plan. If required corrective actions havenot taken place to a satisfactory level of the board, the board may choose to Initiate MOD termination in accordancewith the terms of the MOU.

The certification process included an on-site in-person evaluation of each Comprehensive and Affiliate Center in theNorthwest Oregon area including an assessment of center effectiveness, physical and programmatic accessibility, andwill include continuous improvement of centers and the one-stop delivery system (WIOA sec. 121(g)).Northwest Oregon Works evaluated each Center and the one-stop delivery system to ensure compliance with thefollowing:WIOA sec. 121(e) - Center programs and prpgrammatic access.WIOA sec. 188 and the Americans with Disabilities Act of 1990 (42 U.S.C. 12101 et seq.) - Center physical access.WIOA see. .116 - Center effectiveness.

P.O. Box 140, Lincoln City, OR 97367 ' 541-264-4033 •.. www.onwib.org

' WORKSOURCE WorkSource Oregon Operational Standards^ OREGON

Performance Measure Checklist

Area: Northwest Oregon Center: Astoria, Corvallis, Lincoln City, Newport, St. Helens Date: 9th of June,2017

The responses to the Performance Measure Checklist are used to inform WSO leadership and stakeholders of the progress with standards implementation—to track on our

improved success as a system and to be able identify trends that require additional attention, support and resource. Each of the areas below is identified in the standards.

Local Leadership Teams should review the standards and all Standards References listed in the right-hand column before responding. To assist you, definitions of each option

are listed below.

• Yes: A response of "Yes" means that a center has fully implemented the standard and meets requirements of all Standards References provided in the right-hand

column. A center must be able to provide or demonstrate achievement of the standard where a "yes" response is indicated.

• In Progress: A response of "In Progress" means that a center has begun work toward implementation and/or has implemented some, but not all, of the Standards

References provided in the right-hand column.

• No: A response of "no" means that a center has not begun work on this area and has not begun implementation of on/of the Standards References provided in the

right-hand column. If indicating "no," please include any assistance that would be helpful and when you anticipate being yellow or green in the comments section.

EXAMPLE: A center has adopted the brand ofWSO and has appropriate signage. However, the center has not developed professional standards. This would be marked as "In

Progress."

This form is fillable and there is a space for comments at the end of the form. If you have any questions regarding this checklist, please contact the technical assistance team at

wsostandards@oregon^gov.

Standard Definition Update Standards Reference

Co-location

Alignment of

Services

In order to be designated as a WorkSource Oregon center, Wagner-Peyser

employment service offices must be co-located with Title IB one-stop centers.

Total staff resources across both (W-P/Title 1) funding streams wilt be pooled

together and allocated collectively to ensure all services are delivered in

accordance with the requirements of these operational standards.

S YesD In Progress

D No

S Yes

D In Progress

D No

CL1Pages 7, 25

AS - AS2

Pages 7,25

Standard Definition Update Standards Reference

Branding

Technology

Infrastructure

local teadership —

Team

Four Services

• Exploratory

• Career

• Training

• Business

Labor Market

Information

• WorkSource Oregon (WSO) is the accepted brand for WorkSource Oregon

centers. All centers will adopt and execute this brand, in accordance with

the Oregon Workforce Investment Board decisions from September 2007

and December 2008.

• Each LLT will establish protocols to ensure that physical structures are kept

clean, neat, professional, and reflective of an aligned and integratedenvironment.

• Additionally, LLTswill develop center/local area-spedfic professional

standards which include expectations for acceptable work apparel.

All WorkSource Oregon centers will maintain a standard level of technology to

ensure comparable access to automated services for customers.

1-tJs-m^yronsist of 1oca1-b^o3rd^taf^(coTTveners)70EE>-Managers; Center——

Managers, contracted service provider management and staff, and

representatives from engaged partners and stakeholders such as the

Department of Human Services/ Vocational Rehabilitation, community colleges,

or Temporary Assistance for Needy Families (TANF).

Services provided through the WSO centers will be customer-centered to ensure

value to each customer experience as close to the front of the customer flow as

possible and at each point along the continuum of services. Rather, there are

Career Services, Training Services and Business Services which may be accessed

at any time based on customer needs.

Labor Market Information will inform sector strategies, career planning, training

decisions/ business engagement and placement services.

S YesD In Progress

D No

n Yes

IE1 In Progress

D No13 Yes -

D In Progress

D No

S YesD In Progress

D No

E Yes

D In Progress

BR1-BR3

Page 7

N/APageS

N/APages 5-6

E2 - E12

Cl - C18

T1-T18

B1-B16

Pages 8-16

LMI 1- LMI 3

Pages 8,26

Continuity of

Service

Work-Ready Criteria

Talent Development

Skills Validation

Placement

Assistance

Recruitment

Services

Feedback

Mechanism

(Job Referral)

FeedbackMechanism

(Training)

The goal is to provide the best customer-focusect service possible through a

continuity of services that are not dependent upon a customer returning to the

same staff person. Any WSO staff person is expected to be able to pick up

where another staff left off at the previous customer engagement.

Customers will be designated as Work Ready once assessed by staff that they

have: a general resume, demonstrated soft skills, demonstrated interview skills,

addressed barriers to employment, acquired necessary application information

and materials, networking/social media and basic computer skills appropriate

for their career goats.

Talent Development increases capacity for someone to learn and/or

demonstrate work-related skills. It may include online trainingand assessment

resources, or staff-led workshops and instruction.

Customers who have been determined Work Ready will be further assessed to

ensure they areappropriate for the specific job referral and have been validated

against all employer expectations for the position, including required work

history, hard skills/ certifications and licenses, and basic skills.

Staff providing placement assistance will understand the local talent poolavailable for referrals, and will manage the "pool" of available work-ready

jobseekers—prioritizing based on business needs and investment strategies

outlined in the local plan. _„

Recruitment Services will support targeted populations and Sector Strategies

recruitments. WSO staff will conduct an on-site employer visit prior to the start

of the recruitment then send qualified candidates to the employer in a timely

manner.

Placement and recruitment activities must include a feedback mechanism

between the WSO and employers.

Mechanisms must be in place to monitor the quality and effectiveness of

training services both from outcome data and business/customer feedback.

D No

S Yes

D In Progress

a No

S Yes

n In Progress

a No

13 YesD In Progress

D No

S Yes

D In Progress

a No

a Yes

D In Progress

n No

S Yes

D In Progress

D No

S Yes

D In Progress

D No

S Yes

D In Progress

D No

COS 1Page 26

C16Page 19-20, 28-29

T6Pages 13-14, 22-24

C-12 - C-13

Pages 20-21, 28

C14 - CIS

Page 12

B1-B6

Page 15

C-17, B-8

Pages 9,12 14-15

C-18, T-3

Pages 9,13,15

Target Populations

placed from talent

pool to any job

Sector Partnerships

Target populations

are placed from

talent pool to sector

opening

Local workforce boards will identify target job-seeker populations to align

resources to serve

Local Boards will identify targeted sectors as part of the planning process. Local

Boards will develop service priorities and dedicate resources based on local

plans and investment strategies.

Staff providing placement assistance will understand the local talent pool

available for referrals, and will manage the "pooF of available work-ready

jobseekers—prioritizing based on business needs and investment strategies

outlined in the local plan.

D Yes[3 In Progress

D No

S YesD In Progress

D NoS Yes

D In Progress

a No

B5Pages 13, 15

SS1-SS2

Pages 9, 28

B5Page 15

COMMENTS:

Technology Infrastructure - Newport does not have WiFi. This will be installed during the redesign in the summer of 2017.

Target Populations -Target populations procedures are being established.

Northwest Oregon Workforce Area Observations and Improvement Plan

Gaps:No cross referral betweenCSC and ResCare listed (thisoccurs but wasn't listed

specifically in process map)

Include co-enrollmentsbetween providers whenappropriate

ResCare to includesupportive services in

process map

ResCare to include VeteranServicesreferrals to process-map

ResCare to include priorityreferrals to process map

Opportunities:ResCare to implement processfrom DHS regarding decision,"Appointment within next 30mins", Same service - NextdayIncreased WorkSource onlinepresence (website, social media,

etc.),

Increased referrals to VeteranServices outlined in plan

Job hires- Thinking ourcustomers^workwithin-ourmultiple systems (someone inRes Care could also accessGoodwill employment services),how to share client hires(without breakingconfidentiality), so the ResCare or Goodwill staff isn'tchasing down a client who isworking but doesn't know theyare working?

Duplication:Goodwill and ResCare offer similarworkshops (resume, cover letter,interview skills)

Employer Development/JobDevelopment and needsassessment duplicated by CSC,OED, Goodwill, Voc Rehab

Hiring Events offered by Goodwilland OED

Skill & Education Assessment-Everyone-doesone^-Canwedoan

audit of the assessments to ensurethey are asking information in astrengths-based way? An auditwould also determine what keydomains departments areassessing . We can see howclosely we are aligned onassessments.

Questions:

What type of outreach are wedoing to attract candidates toJob Fairs, Recruiting events,etc?

Business services for OJT,Placement, Workexperience/internships. Arebusiness services set up bysectors? Its trickycoordinating business servicesbecause they are veryrelationship oriented byperson. What are thecomplaints from our localbusinesses now about workingwith our employment andtraining programs?

Doing well:Learning each other'sprocesses and programs

Referrals are happeningvery often between OED-ResCare-DHS

Northwest Oregon Workforce Area Services Available

WorkSource Astoria

BUSINESS SERVICESServe as a single point of contact for businesses, responding to all requests in a

timely manner

Provide information and services related to Unemployment Insurance taxes and

claims

Assist with disability and communication accommodations, including job coaches

Conduct outreach regarding Local workforce system's services and products

Conduct on-site Rapid Response activities regarding closures and downsizings

Develop On-the-Job Training (OJT) contracts, incumbent worker contracts, or pay-

for-performance contract strategies

Provide access to labor market information

Provide customized recruitment and job applicant screening, assessment and

referral services

Provide employer and industry cluster-driven Occupational Skills Training throughIndividual Training Accounts with eligible training providersAssist with the interpretation of labor market information

Conduct job fairs

Develop customized training opportunities to meet specific employer and/or

industry cluster needs

NOW CSC ResCare Titlell OED VR DHS

OFF WSO WSO wso DL

OFFOFF

wso

wso

wsowso

wso

OFF

wso

wsowso

OFFOFF

DLDL

DLwso

wso

Use of one-stop center facilities for recruiting and interviewing job applicants

Consult on human resources issues

Coordinate with employers to develop and implement layoff aversion strategies OFF

Post Job vacancies in the state labor exchange system and take and fill job ordersProvide information regarding disability awareness issues

Provide incumbent worker upgrade training through various modalities OFF

Provide information regarding workforce development initiatives and programs OFF

Provide information regarding assistive technology and communication

accommodations

Develop, convene, or implement industry or sector partnerships OFF

wsowsowso

wsowsowso

wsowsowso

wsowsowso

wsowso

wsowso

wsoOFF

OFF

JOB SEEKER SERVICESBasic Career Services

Outreach, intake and orientation to the information, services, programs, tools and

resources available through the Local workforce system

Initial assessments of skill level(s), aptitudes, abilities and supportive service needs

In and out of area job search and placement assistance (including provision of

information on in-demand industry sectors and occupations and non-traditional

employment)Access to employment opportunity and labor market information

Performance information and program costs for eligible providers of training,

education, and workforce services

Information on performance of the Local workforce system

Information on the availability of supportive services and referral to such, as

appropriate

Information and meaningful assistance on Unemployment Insurance claim filing

Determination of potential eligibility for workforce Partner services, programs, and

referral(s)

Information and assistance in applying for financial aid for training and education

programs not provided under WIOA

Individualized Career Services

Comprehensive and specialized assessments of skills levels and service needs

-D.eve[c4)-meAtjolaiundivJduaLempioy^Jlity_dfiyj&topmeaLplantoJdenti1y_

employment goals, appropriate achievement objectives/ and appropriate

combination of services for the customer to achieve the employment goals

Referral to training services

Group counseling

Literacy activities related to work readiness

Individual counseling and career planning

Case management for customers seeking training services; individual in and out of

area job search/ referral and placement assistance

OFFOFF

OFF

OFF

OFF

wsowso

wso

wso

wso

wso

wso

wsowso

wsowsowso

wso

wsowso

wso

wso

wso

wso

wso

wsowso

wsowsowso

wso

OFF

OFF

OFF

OFF

OFF

OFFOFFOFF

OFF

wso

wso

wsowso

wso

wsowso

wso

wso

wso

wso

wso

wso

OFF

OFF

OFF

OFF

OFF

OFF

OFF

OFFOFF

OFFOFF

OFF

OFF

DL

DL

DL

DL

DL

DL

DLDL

DLDLDL

DL

JOB SEEKER SERVICES CONTINUEDWork experience, transitional jobs, registered apprenticeships, and internships WSO WSO OFF DL

Workforce preparation services (e.g., development of learning skills, punctuality,

communication skills, interviewing skills, personal maintenance, literacy skills,

financial literacy skills, and professional conduct) to prepare individuals for

unsubsidized employment or training WSO WSO OFF DL

Post-employment follow-up services and support (This is not an individualized career

service, but listed here for completeness.) WSO WSO OFF DL

Training

Occupational skills training through Individual Training Accounts (ITAs) WSO WSO OFF

Adult education and literacy activities, including English language acquisition (ELA),provided in combination with the training services described above WSO OFF

On-the-Job Training (OJT) WSO WSO OFF DL

Incumbent Worker Training WSO

Programs that combine workplace training with related instruction which may

include cooperative education WSO WSO OFF DLTraining programs operated by the private sector WSO WSO

Skill upgrading and retraining WSO WSO OFF

Entrepreneurial training WSO WSO OFF

Customized training conducted with a commitment by an employer or group of

_e.mplo_yer_sJp_enaploy_anJndMduaLup.o_n_sjj£.^^^^^^_ _ W.SO___0£E—__Other training services as determined by the workforce partner's governing rules OFF

Services eligible to youth WSO* OFF = Offsite referral system, WSO = Available at WorkSource Oregon center, DL = Direct Link (Another suite at the WSO location)

Northwest Oregon Workforce Area Required Partner Connections

RequiredOne-StopPartnerProgramsauthorizedunder title I ofWIOA JobCorpsThe SeniorCommunityServiceEmploymentProgramauthorizedunder title V ofthe OlderAmericans Actof 1965Employmentand trainingactivities^ -

carried outunder theCommunityServicesBlock GrantEmploymentand trainingactivitiescarried out bytheDepartmentof Housing

Astoria -ComprehensiveCenter2

1

3

Tongue PointJob Corps KimShillinger 503-325-2131

Easter Seals -Catherine Todd503-228-5100x301; orcell 971-678-7463

CommunityAction Team -

Dan-Brown— —

(CAT) 541-397-3511X2003

NorthwestOregonHousingAuthority,Todd Johnston503-994-5034x112

St. Helens

3 CommunityAction Team -

Dan-Bcown_(CAT) 541-397-3511 x2003

NorthwestOregon HousingAuthority, ToddJohnston 503-994-5034x112

Tillamook

3 CommunityAction Team -

J3an Brown(CAT)541-397-3511X2003

NorthwestOregonHousingAuthority,Todd Johnston503-994-5034x112

Lincoln City

3 CommunityServices

-Consortium.-

Diana Teem541-574-2277

HousingAuthority ofLincoln County- Joanne Troy

Newport

2

3

RobertMacGregor(Angell) 541-547-5641

CommunityServicesConsortiumDiana Teem541-574-

2277

HousingAuthority ofLincolnCounty -Joanne Troy

Corvallis

3 CommunityServicesConsortiumDiana Teem541-574-2277

Linn-BentonHousingAuthority -Donna Holt

and UrbanDevelopment

Programsauthorizedunder sec. 212of the SecondChance Act of2007Career andtechnicaleducationprograms atthepostsecondarylevelauthorizedunder the CarlD. PerkinsCareer andTechnicalEducation Actof 2006Programsauthorizedunder title I ofWIOA NativeAmericanPrograms(Thisprogram isnot requiredtoparticipate inthe centers)

3 Clatsop/Western Columbia:DebbyRoberston503-338-2506drobertson@clatsopcc.edu

3 Beth MolenkampEasternColumbia 971-722-7736elizabeth.molenkamp@pcc.edu

3 NWESD: TamiSchild 503-842-8223 x1840tschild@nwresd-kl2.or.us

3

3

OCCC - DanLara 541-867-8506

ConfederatedTribes of Siletz-Indians -Kurtis Barker

3

3

OCCC - DanLara 541-867-8506

ConfederatedTribes ofSiletz Indians- KurtisBarker

3 Linn-BentonDale Moon541-917-4219dale.moon@linnbenton.edu

The AdultEducationand FamilyLiteracy Act(AEFLA)programauthorizedunder title II ofWIOAProgramsauthorizedunder title I ofWIOA AdultsProgramsauthorizedunder title I ofWIOADislocatedworkersProgramsauthorizedunder title I ofWIOA YouthTheWagner-Peyser ActEmploymentServiceprogramauthorizedunder theWagner-

Peyser Act/ asamended byWIOA title m

3

1

r

CCC - DonnaLewelling

3 PCC - DonnaLewelling

3 OCCC - DonnaLewelling

3 occc-DonnaLewelling

3 LBCC - DonnaLewelling

Northwest Oregon Works - Heather DeSart

Oregon Employmentt>epartment^~.]imPfarrer———~—

TradeAdjustmentAssistanceactivitiesauthorizedunder chapter2 of title 11 ofthe Trade Actof 1974Jobs forVeteransState GrantsprogramsProgramsauthorizedunder title I ofWIOAMigrant andseasonalfarmworkerprograms(MSFW)Programsauthorized'under Stateunemploymentcompensation lawsTheVocationalRehabilitation(VR)programauthorizedunder title I of

3 Department ofHumanServices -

RhondaMeidinger

3 Department ofHuman Services- RhondaMeidinger

2 Department ofHumanServices -

RhondaMeidinger

1 Department ofHumanServices -

RhondaMeidinger

3 Departmentof HumanServices -

RhondaMeidinger

3 Department ofHumanServices -

RhondaMeidinger

theRehabilitationAd of 1973, asamended byWIOA title IV

TemporaryAssistance forNeedy Families(TANF) JobOpportunityand BasicSkills (JOBS)programservices

Department ofHumanServices - AmyYoungflesh;MarcoBenavides

Department ofHuman Services-Amy

Youngflesh;Marco Benavides

Department ofHumanServices - AmyYoungflesh;MarcoBenavides

Department ofHumanServices - AmyYoungflesh;MarcoBenavides

Departmentof HumanSen/ices -

AmyYoungflesh;MarcoBenavides

Department ofHumanServices - AmyYoungflesh;MarcoBenavides

SupplementalNutritionAssistanceProgram(SNAP)Employmentand Trainingsen/ices

_Qption l._Havmg a_pmgram.staflLniembecphysIcaliy_presentaUhe^meric^^

Option 2. Having a staff member from a different partner program physically present at the American Job Center and appropriately trained toprovide information to customers about the programs, services, and activities available through all partner programs.Option 3. Making available a direct linkage through technology to a program staff member who can provide meaningful information orservices. A direct linkage, can take many forms as well. As described in 20 CFR 678.305(d)(3), 34 CFR 361.305(d)(3), and 34 CFR463.305(d)(3), a "direct linkage" means providing a direct connection at the American Job Center within a reasonable time, by phone or througha real-time Web-based communication, to a program staff member who can provide program information or services, including career services,to the customer. Solely providing a phone number. Web site, information, pamphlets, or materials does not constitute a "direct linkage".