WIOA Planning and Discussion

CCRY Fall 2015 Meeting

Denver, CO

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New Opportunities for Low-Income and Low-Skilled Adults and Youth

Increases the focus on serving the

most vulnerable workers—low-

income adults and youth

Expands proven education and

training options to help participants access good jobs and advance in

their careers

Helps disadvantaged and

unemployed adults and youth earn while they

learn

Aligns planning and accountability

policies across core programs to

support more unified

approaches

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WIOA Expands Education and Training Options: Enabling People to Earn While They Learn

• Clarifies that WIOA Title I adult training funds can be used for individuals who are unable to obtain Pell grants

• Pay-for-Performance contracts are allowable (up to 10 percent of youth funds)

• OJT (on the job training) 75% wage reimbursement in WIOA Title I adult

• Up to 10% of funds available for transitional jobs for individuals with barriers to employment in WIOA Title I adult

• Paid work experiences for Youth (including summer jobs)

• Workplace Adult Education and contextualized learning (IET model)

• Encourages Career Pathways for adults and youth

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WIOA Expands and Improves Services to Disadvantaged Youth

• 75% of Youth funds required to be spent on out-of-school youth

• New 16-24 age range for out-of-school youth eligibility

• Requires at least 20 percent of Youth Formula Funds be spent on paid and unpaid work experiences (including Summer Jobs programs)

• Adds youth “living in a high-poverty area” to the low-income criterion for youth activities

• In-school youth eligibility includes low-income individuals ages 14 to 21 who are English language learners and those who have a disability

1. Well-connected and transparent education, training, credentials, and support services

2. Multiple entry points – for both well-prepared students and targeted populations

3. Multiple exit points

Three Essential Features of Career Pathways

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What’s next?

• Federal Regulation Process, Guidance and Technical Assistance

• State Planning and Visioning (March 2016)

• Local Planning & Redesigning and/or Expanding Service Strategies

• Transitioning to new performance measures, data systems (July 2016)

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Advancing Federal, State and Local Policy Implementation

1. Polices we hope to see in the Federal Regulations, Guidance, and Technical Assistance

2. Policies advocates and stakeholders can advance at the state level

3. Polices advocates and stakeholders can advance at the local level

• Youth Committees

• State, Local and Regional Plans

• Career Pathways, Measurable Skills Gain

Governance and

Planning

• Attending “school”

• Out-of-school youth status

• Self-attestation or self-certification

• High poverty area

Eligibility

• Title I adult and youth, Title II, Title IV

• What performance measures count?

Co-Enrollment

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Governance and Planning

• Standing Youth Committees How the local board will facilitate co-enrollment of participants across core programs,

which is of particular importance for youth and young adults ages 18-24 who can be served through Title I, Title II, and Title IV.

How the local board will implement specific provisions related to career pathways—such as the requirement that local areas use youth funds to conduct an objective assessment “for the purpose of identifying appropriate services and career pathways for participants”—and broader career pathways for youth and young adults across core programs.

How the procurement processes and requests for proposals will, when possible, be adapted an aligned across the core programs to encourage longer-term and more intensive services for out-of-school youth.

How connections will be made with Temporary Assistance for Needy Families (TANF) partners at One-Stops to ensure policy and programmatic alignment for the young adult population under 25, who may receive a different set of services if they are not served through Title I – Youth programs. This is important because while a large percentage of TANF recipients are under 25 and would benefit from out-of-school youth programs, federal requirements and outcomes vary for the two programs. As WIOA and TANF differ greatly from each other, it will require specific “policy and programmatic alignment” by the state and local workforce boards to serve TANF recipients in a WIOA program.

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Eligibility for Youth Services

1. What does “school” refer to in the “not attending or attending any school” in the out-of-school and in-school definitions? – Allowing state law to determine the definitions of “attending any

school” and “alternative education” could prevent access to WIOA OSY dollars for youth who have dropped out of high school and are in nontraditional programs in states with broad definitions of school.

– Support the clarifications that individuals enrolled in Title II programming, YouthBuild, and Jobs Corps are not considered to be attending school for the purposes of WIOA; we believe that young people who are in similar programming (e.g., GED and other high school equivalency programming funded with non-WIOA sources) should also be considered to be “out of school.”

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Eligibility for Youth Services

2. When do local youth programs verify dropout status, particularly for youth attending alternative schools?

– The Department makes clear that youth who are enrolled in an alternative school at the time of enrollment in the WIOA Title I Youth program are not considered out-of-school youth. However, if the youth is determined to be out of school at the time of enrollment—and is subsequently placed into an alternative school or any other school—then he/she is considered an out-of-school youth. We support this proposed rule and believes the status of initial program eligibility determination should prevail.

3. How does the Department define the “requires additional assistance to complete an educational program, or to secure and hold employment” criterion in this part?

– The proposed rule gives states and/or local boards the responsibility to determine the meaning of “requires additional assistance to complete an educational program, or to secure and hold employment.”

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Eligibility for Youth Services

4. How does the Department define the ‘‘basic skills

deficient’’ criterion in this part? This proposed section reiterates the basic skills deficient criterion that is

part of the eligibility criteria for both OSY and ISY, for purposes of title I of

WIOA. The State and/or Local Board must further define how the State or Local Board will determine if a youth is unable to demonstrate these skills well enough to function on the job, in their family, or in society as part of its respective State or local plan.

5. How does the Department define “high-poverty area” for the purposes of the special rule for low-income youth in Workforce Innovation and Opportunity Act? (see page 12 of CLASP comments for detailed

recommendations)

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Eligibility for Youth Services

7. Must youth participants enroll to participate in the youth program? In the proposed rule, the Department defines enrollment as the collection of information to support an eligibility determination and participation in any one of the 14 program elements.

– Department of Labor clarify that the “collection of information” can be supported by self-attestation for upfront eligibility determination, particularly for youth in high-risk categories

– Department make explicit that self-attestation is allowable or even preferred and that services can begin immediately for youth who provide such statements

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Co-enrollment • The proposed definition of ‘‘concurrent

enrollment’’ or ‘‘co-enrollment’’ would clarify its meaning specific to enrollment in two or more of the four core programs in WIOA to provide consistency with how it is used throughout the statute. (Found in Programs and Activities Authorized by the Adult Education and Family Literacy Act).

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Co-enrollment • Encourage co-enrollment and provide guidance

and technical assistance in the data collection, reporting, and tracking outcomes.

• What performance measures count? – For a youth (age 18-24) who is co-enrolled, the Title I – Youth

Performance Measures and Definition of Participant should prevail… building on experiences from PPP for Disconnected Youth, we believe that Department should allow flexibility and waivers where appropriate.

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Facilitated Discussion

• Where are you now? At the local level? State level?

• What opportunities are you excited about?

• What barriers are you encountering when implementing WIOA?

• What would you want to see included in guidance and regulations from US DOL and US DOE?

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For each category

• Governance and Planning

• Enrollment and Eligibility

• Performance and Accountability

• Movement Across Funding Streams (Title I and Title II Interactions)

• New Programmatic Ideas/Partnerships

• Where are you now? At the local level? State level?

• What opportunities are you excited about?

• What barriers are you encountering when implementing WIOA?

• What would you want to see included in guidance and regulations from US DOL and US DOE?

TELL US