WIOA Frequently Asked Questions
Do infrastructure cost requirements include affiliate and specialized centers for PY 18?
TEGL 17-16 expands the infrastructure cost requirements for affiliate and specialized service locations. In the absence of a state policy, if a local workforce board designates a service location as an affiliate or specialized center, then required partners who choose to make their programs and services available in that affiliate or specialized center must contribute a proportionate share of the infrastructure costs for that center (Governor’s Guidelines, Supplemental Guidance for Program Year 2018 (SFY 2019)).
What constitutes an affiliate site?
The State of Illinois is in the process of developing policy regarding affiliates and specialized centers. The requirements of the Governor’s Guidelines, Supplemental Guidance for Program Year 2018 (SFY 2019) to expand infrastructure cost-sharing requirements to affiliates will be changed as needed due to issuance of any new or additional Federal or State policy or guidance about affiliate and specialized service locations.
In the absence of a state policy, if a local workforce board designates a service location as an affiliate or specialized center, then required partners who choose to make their programs and services available in that affiliate or specialized center must contribute a proportionate share of the infrastructure costs for that center. (Governor’s Guidelines, Supplemental Guidance for Program Year 2018 (SFY 2019))
Annual Budget (Infrastructure Funding Agreement)
How are building resources used by non-WIOA staff accounted for in the one-stop operating budget spreadsheet?
These resources are not relevant to the MOU negotiations or agreed upon MOU. Costs to be allocated among required partners in a local area only consist of those costs which are incurred to provide federally funded workforce programs and services under WIOA.
How should one-stop operator costs be recorded on the one-stop operating budget spreadsheet?
New line items were inserted into the one-stop operating budget spreadsheet to identify the cost of the one-stop operator for PY18. The One-Stop Operator model must be selected in line 70 (single entity, consortium or other). If one-stop operator costs are allocated to all partners for the respective center, the cost should be entered into row 80. If the one-stop operator costs are allocated to only some partners, the cost should be entered into row 82. If costs are only allocated to some partners, an explanation must be included in the “notes” section of the one-stop operating budget spreadsheet and the MOU narrative, Section 12 (Governor’s Guidelines, Supplemental Guidance for Program Year 2018 (SFY 2019)).
Is a personnel contribution allowed as a shared delivery system cost?
required partner’s contribution to shared costs to operate the local delivery
system can be made through cash, non-cash, or third-party in-kind
An example of a non-cash
contribution is in-kind staffing.
with the description of each contribution type in § 678.720, a contribution of
personnel may be considered a non-cash service contributed by a required
partner and used by the local one-stop delivery system as long as the following
conditions are met, according to the Governor’s Guidelines – Revision 2,
Section 3, Item 3:
- The contribution is recognized and accepted by all other partners,
- The contribution has the effect of offsetting a cash contribution toward local one-stop delivery system costs that would otherwise be due from the partner making the non-cash contribution, and
- The contribution is valued consistent with 2 CFR part 200.306 to ensure the contribution is fairly evaluated and meets the contribution partner’s proportionate share.
- Contributions of personnel time as non-cash contributions are not permissible contributions for infrastructure costs
Is providing sign language interpreters in the comprehensive one-stop center considered a shared cost?
There are several considerations to take into account. If the accommodation is for a participant in one program, the costs go to that program only. If the accommodation is for a participant of multiple programs, it should be split among the applicable programs. If the accommodation is a standby resource that all partners desire, then the cost would be shared among all partners (subject to local agreement).
Is the local area bound to the numbers calculated on the one-stop operating budget spreadsheet as long as everyone is in agreement with the partner contributions?
The expectation is that each partner will be bound by its contribution commitments as reflected in the agreed-upon final budget. Partners will need to periodically reconcile budgeted costs with actual costs (§ 678.715(a)(4)). Federal guidance requires that the “one-stop operating budget must be periodically reconciled against actual costs incurred and adjusted accordingly” to ensure the budget reflects a cost allocation methodology that demonstrated how infrastructure costs and shared service delivery system costs are charged to each partner in proportion to the partner’s use of the one-stop center and relative to the benefit received (TEGL 17-16, page 3).
Should the one-stop operating budget spreadsheet and the MOU include organizations located outside of the comprehensive one-stop center?
The MOU and one-stop operating budget spreadsheet shall include all partners in the one-stop delivery system. The local area has discretion as to the “local delivery system” (e.g., affiliate center, specialized center, or corporation). In the absence of a state policy, if a local workforce board designates a service location as an affiliate or specialized center, then required partners who choose to make their programs and services available in that affiliate or specialized center must contribute a proportionate share of the infrastructure costs for that center (Governor’s Guidelines, Supplemental Guidance for Program Year 2018 (SFY 2019)).
Some local partners claim that they are only the funder of last resort. Is this true?
§678.760 states “WIOA neither requires programs to examine if other funds are available before using program funds to pay for a service, nor does it establish a requirement that any program can only be a ‘payer of last resort.’”
What are the requirements in Illinois for reconciling budgeted versus actual shared costs among required partners?
1) Reconciliation must occur at least semi-annually.
The Governor’s Guidelines, Supplemental Guidance for Program Year 2018 (SFY 2019) and Additional Guidance for Reconciliation of Budgeted to Actual Shared Costs for PY 2017 (SFY 2018) provides additional direction and guidance for the requirement to reconcile budgeted to actual costs and to adjust each partner’s contribution toward shared infrastructure costs and shared service delivery system costs:
2) Reconciliation of budgeted to actual shared costs is based on actual costs incurred compared with budgeted amounts of each line item.
Further details are available in the Governor’s Guidelines, Supplemental Guidance for Reconciliation of Budgeted to Actual Shared Costs for PY 2017 (SFY 2018) and the Handbook for Conducting Periodic Reconciliation.
What does impartial individual mean for negotiation of the one-stop operating budget?
The Governor’s Guidelines – Revision 2 state that the chair will designate a private sector member of the board, or other impartial individual, as having lead responsibility for negotiation of comprehensive one-stop center infrastructure and local service delivery system costs. The impartial individual may not be a local core or required partner. Furthermore, each local board is responsible for identifying the lead MOU and budget negotiators, as well as to document the appointments. If any questions are raised about the impartiality of the individual appointed to lead budget negotiations, then the local board is also responsible for justifying how its appointment complies with the direction provided in the Governor’s Guidelines. Local boards should document their justification at a minimum in board meeting minutes.
What if a single required partner does not agree to the one-stop operating budget?
Where can I find the most up-to-date version of the one-stop operating budget spreadsheet?
Who is responsible for approving the draft one-stop operating budget prior to submission to the State?
As described in the Governor’s Guidelines - Revision 2 - March 2016, at the second MOU negotiation meeting, the required partners will review the draft budget and make all agreed-upon revisions. The chair of the Local Workforce Innovation Board (LWIB), is to submit the final budget with the signed MOU.
Can you provide further guidance on data sharing and protecting personally identifiable information for the MOU submittal?
State-level partners are continuing to explore best practices and are in the process of considering the development of policy to guide data sharing and protection of personally identifiable information.
Data sharing and having a common database is one major cost that is necessary to make the one-stop center successful. Will that cost be subsidized by the State?
Ongoing conversations are taking place at the State level and there is a desire to streamline data collection and availability while ensuring appropriate levels of privacy and security. Work enabling movement in that direction is underway.
Is there a state level data sharing agreement? Is there an established mechanism for each state partner to provide information on what local partners can legally share at the local level?
Currently data sharing agreements exist between several core and required partners.
Will data sharing agreements just be the agreements through the State level or will local level areas have to create their own data sharing agreement?
A hybrid approach is needed. Data sharing arrangements will be handled simultaneously at the State and local levels.
Can partner referrals constitute a direct linkage communication in Illinois?
In addition to the forms of communication cited in §678.305(d)(3)(ii) as not complying with direct linkage requirements (providing only a phone number, computer Web site, information, pamphlets or materials), none of the following forms of communication may be used as a direct linkage connection from customers to partner staff designated to provide direct linkage services.
Though these forms of communication are adequate as a supplement to compliant forms of direct linkage communication and can be a crucial part of the service delivery process, do not cite these forms of communication as a form of direct linkage in any formal documentation (i.e. MOUs). These methods are not technologies that satisfy the real-time, on-demand communications requirements.
Is any partner staff person qualified to provide direct linkage services via the approved forms of direct linkage communication?
As defined in the Governor’s Guidelines – Revision 2, Appendix Item 4, qualified individuals are only program staff members who have been specifically identified as trained and knowledgeable regarding the needed partner’s services and programs and for whom providing direct linkage is a formal part of his/her job.
Is direct linkage required to be provided through video?
Illinois has established additional requirements to provide services via “direct linkage” technology in the Governor’s Guidelines – Revision 2, Appendix Item 4. Direct linkage can be provided via phone or real-time web-based communication (e.g., Skype, Google Hangout). The requirements for providing direct linkage via video include: high-speed internet capability; dedicated, two-way video and audio-enabled communication between two devices at two or more locations; and a back-up appointment scheduling capability if services are unavailable at the time of contact. Immediate access to services should be the norm, and all appointment scheduling messages from customers must be responded to within a “reasonable period of time,” which is defined as 24 business hours in Illinois.
The requirements for providing direct linkage by phone include: a specific dedicated phone number, phone coverage during normal business hours on all normal business days and voicemail or other capability enabling customers to leave a message if access to services via phone is unavailable at the time of contact. Immediate access to services should be the norm, and all voicemails must be returned within 24 business hours.
A direct linkage checklist is now available for local partners to assure that they are in compliance with the direct linkage requirement.
Are FTEs determined based on shared delivery system costs, infrastructure or both?
The number of FTEs is based on the number of staff the required partner is committing to provide services under WIOA in the comprehensive one-stop center. The FTE commitment then serves as the cost allocation methodology that carries through the one-stop operating budget spreadsheet to calculate each partner’s proportionate share of infrastructure costs, as well as local service delivery system costs.
Are FTEs the required method of allocating costs?
No, not under the local funding mechanism when all partners agree. However, other methods are strongly discouraged. FTEs is the required cost allocation methodology under the state funding mechanism when required partners have reached a budget impasse (Governor’s Guidelines – Revision 2, Section 2).
Can an LWIB require core and required partners to commit a minimum of one FTE at a comprehensive one-stop center?
No. Under WIOA law and final regulations each core and required partner has flexibility to determine how it will meet WIOA service access requirements. Onsite staff, contractor staff, staff cross-training and technology meeting the “direct linkage” requirements described in proposed regulation § 678.305 are all options available to most required partners (Wagner-Peyser and Title IB partners must be physically present at a comprehensive one-stop center).
Each partner’s determination of the method of service delivery must assure that all one-stop center customers can access information and services on demand. Depending on known or anticipated demand for services at a comprehensive on-stop center, this may or may not require a partner to commit one FTE to a comprehensive one-stop center.
The specific services each required partner will provide at a comprehensive one-stop center, the methods of service delivery that will be used to provide these services and the cost implications associated with these decisions are all encompassed by MOU negotiations involved local boards, chief elected officials and required partners.
The Governor’s Guidelines, Supplemental Guidance for PY 2018 (SFY 2019) affirm that the minimum FTE requirement for a required partner is .25.
Does having a fractional FTE mean services can only be available a fraction of the time at a comprehensive one-stop center?
No. Required partners under WIOA must make their applicable services available in a comprehensive one-stop center during all regular business hours. A required partner’s FTE commitments should be based on demand for services in that local area. However, every required partner is expected to make its services available and accessible on demand to customers who enter a comprehensive one-stop center during regular business hours through onsite staff, cross-trained staff or direct linkage technology.
Doesn’t WIOA require that each program commit a minimum of one full-time equivalent (FTE) since services have to be available at comprehensive one-stop centers during normal business hours?
No, WIOA does not require that each program commit a minimum of one full-time equivalent. Each required partner—some of which administer multiple required programs— must provide staffing sufficient to ensure required services are available during all normal business hours. Staff can be onsite at the one-stop center or available via technology satisfying the “direct linkage” requirement in WIOA (Illinois has implemented further direct linkage requirements). Depending on the actual demand for program services and the geographic scope of responsibility for staff providing services (e.g., responsibility for all LWIAs in a region), a partner’s minimum staff contribution may be less than, equal to, or more than one full FTE for each comprehensive one-stop center (the minimum FTE is .25 per the Governor’s Guidelines, Supplemental Guidance for Program Year 2018 (SFY 2019)). The number of FTES that each required partner commits is to be agreed upon during negotiations of local memoranda of understanding (MOUs). Partners with responsibility for multiple programs (e.g. ICCB which is responsible for Adult Education and Postsecondary career education programs can meet the service access requirements with an individual or individuals as long as the staff providing services are trained and able to provide services under multiple programs).
How will the reconciled costs be collected from all partners?
The Handbook for Conducting Periodic Reconciliation sets out a general process for reconciliation. The Local Workforce Innovation Board (LWIB) Chair determines the frequency at which the local area will reconcile budgeted to actual costs. The LWIB Chair also identifies the individual who will be responsible for both leading the reconciliation process and performing the reconciliation. The individual responsible for reconciliation develops a process for identifying actual costs at the end of each reconciliation period.
If a required partner has a staff person that is providing career services at an affiliate or an office outside the comprehensive one-stop center, should that person be counted as an FTE?
Yes, individuals who are providing WIOA-related services at an affiliate or specialized center should be included if the local workforce board designates the service location as an affiliate or specialized center.
Is each partner required to commit at least one FTE to every comprehensive one-stop center?
No. The minimum each partner is required to commit is .25 FTEs (Governor’sGuidelines, Supplemental Guidance for Program Year 2018 (SFY 2019)). If local partners agree to accept less than .25 FTEs, the local partners risk being out of compliance with the Governor’s Guidelines.
What if one required partner will not agree to commit .25 FTEs?
Local areas are responsible for meeting all cost allocation requirements under WIOA and the “Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards.” It is incumbent on local partners to document at the local level the rationale and approval of alternative cost allocation methodologies for shared costs.
When multiple contractors administer a required program in an LWIA, is each entity responsible for the required minimum .25 FTE or is this a “collective responsibility.”
The required partner as a whole is required to commit at a minimum .25 FTE to each comprehensive one-stop center. The .25 can be made up of several entities, but it must reach .25.
From TEGL No. 17-16: “Partner Programs with Multiple Grant Recipients. Partner programs and additional partners that carry out a program in the local area are required to share infrastructure costs and certain additional costs (20 CFR 678.700(c)), 34 CFR 361.700(c), and 34 CFR 463.700(c)). When two or more grant recipients or contractors of a required partner program carry out a program in a local area, these entities are considered one-stop partners and must reach out to the Local WDB and carry out the roles and responsibilities of one-stop partners, including negotiating their share of infrastructure costs. For instance, there may be multiple YouthBuild and SCSEP grant recipients along with a few Job Corps contractors in a local area. In this situation, each grant or contract recipient carrying out the program in that local area must contribute towards infrastructure costs, and those contributions must be based on the proportionate use and relative benefits received by those partners from the one-stop centers.”
Can you provide an example of how infrastructure costs would be treated if 25 of the 50 total onsite staff are directly involved with WIOA services?
The 25 employees that are directly involved in providing services authorized under WIOA would be counted towards FTEs in the one-stop operating budget spreadsheet.
Is it acceptable to use Federal and State grant dollars to pay infrastructure costs to a for-profit company?
Yes. The allowability of infrastructure costs is not contingent on the type of entity.
What is the state funding mechanism?
From the Governor’s Guidelines – Revision 2 glossary on page 18, the state one-stop infrastructure cost funding mechanism is “the method used to cover infrastructure costs of the comprehensive one-stop center(s) in a local area when required partners are unable to agree on how to share those costs. The amount that each required partner can contribute to one-stop infrastructure costs is capped under the State funding mechanism. Funding under the State infrastructure funding mechanism is available only to certified comprehensive one-stop centers in local areas that cannot reach agreement on an MOU at the end of a 30-day remediation period.”
Local Service Matrix
What information is required for “service delivery method” in the Local Service Matrix for Comprehensive One-Stop Centers in the MOU template?
Per § 678.305(d) the options for service delivery methods include on-site, cross-training of staff, or direct linkage (Wagner-Peyser and Title IB partners must be physically present at a comprehensive one-stop center). Examples are encouraged in the “Service Delivery Method through the Local Comprehensive One-Stop Centers,” such as “direct linkage will be made available through Skype.”
What is considered an “other program and activity” in the Local Service Matrix for Comprehensive One-Stop Centers in the MOU template?
Other programs and activities are any value-added service provided to participants. Examples include a mobile workforce center, apprenticeship information and referral, resume writing and interview skills training and sector based job fairs.
MOU - Budget Reconciliation
Are individuals responsible for reconciliation required to submit the completed Reconciliation Spreadsheet or Matrix of Benefits Received by Partner?
The “Handbook for Conducting Periodic Reconciliation” in PY 2017 provides guidance that if any local area needs to request technical assistance or cannot reach agreement under the process agreed upon in Section 13 of the local MOU, then the individual responsible for reconciliation should provide to Michael Baker at Commerce, email@example.com, a report signed by the local workforce board chair with justification for non-payment or disagreement.
Does a one-stop operator consortium need to approve the person identified by the local workforce board chair as the individual responsible for reconciliation?
No. It is recommended that the local workforce board chair work in consultation with the one-stop operator consortium.
Does the threshold for whether a line-item variance warrants an MOU/budget amendment apply to both when actual costs significantly exceed budgeted costs and when actual costs are significantly less than budgeted?
No. The threshold for whether a significant line item variance warrants a full MOU/budget agreement only applies when actual costs exceed the budgeted amount by 15% and account for 10% of the total budget.
If actual costs are significantly less than budgeted, then an MOU/budget amendment is not required. Partners can simply receive a credit as part of the reconciliation process.
Even if the one-stop operator invoices required partners for actual costs as they come in, does the one-stop operator also need to complete the “Matrix of Benefits Received by Partner?” What is the purpose of the “Matrix of Benefits..."?
The reconciliation process is intended to ensure partners’ share of the costs of the one-stop center is proportionate to the benefit they receive by providing services in that service location. Even if the reconciliation is not performed because actual costs are billed to partners as costs are incurred, required partners still need to demonstrate that their share of the costs are proportionate to the benefit they receive. The Sample Matrix of Benefits Received by Partner is one way to demonstrate each partner’s benefits received. The local area may identify other ways to demonstrate that costs are shared proportionately to the benefits received by partner, but it should be documented.
If the one-stop operator invoices required partners for actual costs as bills come in, does the local area still need to perform the periodic reconciliation using the Reconciliation Spreadsheet?
If actual costs are billed to required partners as costs are incurred throughout the program year, then the process of reconciling budgeted to actual cost would not be necessary. The invoices of actual amounts already account for any variances between budgeted and actual costs shared among partners.
What documentation is required to verify actual costs or to include in a Final Notice about additional amounts owed?
The “Handbook for Conducting Periodic Reconciliation” in PY 2017 does not require specific documentation. The individual responsible for performing reconciliation in the local area should develop the local process and documentation needed to verify actual costs in collaboration with the required partners that actually incur the expense of each line item in the budget.
What is the difference between the reconciliation period and the reconciliation process?
The reconciliation period is the time between the one-stop operating budget’s effective date and the identification of actual costs at a minimum of every six months. In a semi-annual reconciliation for PY 2017:
- Reconciliation Period 1 incurs costs between July 1, 2017 and December 31, 2017.
- Reconciliation Period 2 incurs costs between January 1, 2018 and June 30, 2018.
The process of reconciliation occurs after the reconciliation period ends. In general, required partners will make payments of any additional amounts owed within 60 calendar days from the end of the reconciliation period.
When are payments of additional amounts owed due?
The “Handbook for Conducting Periodic Reconciliation” in PY 2017 suggests, generally, payments of additional amounts owed as a result of reconciliation should be paid within 60 calendar days of the end of the reconciliation period. The sample timeline on page 2 of the “Handbook for Conducting Periodic Reconciliation” provides specific examples of dates for each step of the reconciliation process.
Negotiation of MOUs
Can comprehensive one-stop center staff and core and required partners be cross-trained to provide services for multiple programs?
Yes. Local comprehensive one-stop center partners can cross-train staff so they are able to provide services in multiple programs. The extent to which staff are cross-trained and the impact this has on each partner’s FTE commitment will be part of local MOU negotiations regarding both the method of service delivery and each partner’s share of delivery system costs.
Can fair share or proportionate share be based on the number of clients served by each agency in the one-stop center?
Can required programs designate multiple individuals to negotiate local MOUs?
Ideally, each required program should identify one individual to negotiate local MOUs on behalf of the program representatives in each local area. However, that may not always be feasible or preferable for every program in every local area. As these individuals are identified they are included on the updated “Summary of Individuals to Negotiate MOUs” document on the WIOA Implementation portal.
Does Revision 2 of the Governor’s Guidelines replace all previous versions?
Yes, Governor’s Guidelines – Revision 2 replaces all other versions. Please note that Supplemental Guidance to the Governor’s Guidelines for PY 18 (SFY 19) was issued in the Spring of 2018.
How does a local area manage required partners who are engaged in local negotiations about services, but not shared costs?
The expectation is that local partners will be engaged in negotiations about both services and costs. If this is not happening, contact should be made with your respective liaison at the state-level.
Is there a requirement that an LWIA provide physical space in the comprehensive one-stop center for a required partner?
If a partner chooses to make services accessible at a comprehensive one-stop center with onsite staff, then the local area should make every effort to provide space. The individual partner decides how it will make its services accessible at a comprehensive one-stop center. Staffing is an option, but so is direct linkage. All of this is part of local negotiations, including raising issues as needed about the adequacy of the size of space available.
What if a comprehensive one-stop center has empty desks? Is this “idle capacity,” and would it be considered a disallowed cost for other federally funded programs to pay for this space?
Idle capacity is generally unallowable. However, it may be allowable to the extent that it is necessary to meet fluctuating workload requirements, it was previously necessary and is now temporarily idle, or it is a normal cost of doing business. Refer to the Uniform Guidance at 2 CFR 200.446 for more information.
What if a required partner does not attend MOU negotiation meetings?
If a required partner is absent from MOU negotiation meetings, the local area should reach out to their state-level liaison as soon as possible.
What is the definition of “fair share?”
What is the definition of “proportionate share?”
The determination or each partner’s proportionate share is a specific requirement incumbent upon the Governor. Proportionate share is the Governor’s Guidelines, Revision 2, Appendix Item 1, as “an amount determined by the Governor that represents a required partner’s portion of comprehensive one-stop infrastructure costs State-wide for purposes of the State infrastructure funding mechanism. This amount is determined through a reasonable cost allocation methodology that assigns costs to required partners in proportion to relative benefits received.”
What is the MOU submittal due date?
Agreed upon and signed MOUs, including the one-stop operating budget are due to the State of Illinois by July 2, 2018. MOUs must be submitted to Michael Baker at firstname.lastname@example.org.
Who is the party to the MOU for SCSEP?
Authorized by the Older Americans Act, the Senior Community Service Employment Program is a community service and work-based job training program for older Americans, including through the American Job Centers. SCSEP in Illinois is administered by the Illinois Department on Aging (State) sub-grantees namely the Area Agencies on Aging, a community action agency, and an agency that focuses on senior employment, as well as by seven national contractors. In Chicago the Senior Services Area Agency on Aging is based at the Chicago Department of Family and Support Services, with other State sub-grantee and other national contractors providing services throughout Cook and surrounding counties, as well.
Based on recent federal guidance issued in TEGL 17-16, required partners with two or more grant recipients or contractors that carry out a program in a local area must each contribute towards infrastructure costs based on a proportionate use and relative benefits received by each.
That means that if multiple SCSEP providers in any given area administer the program, both entities (the State sub-grantees and the national contractors) are parties to the MOU and must participate in negotiations of service delivery and cost sharing.
Why is the “subject to the availability of funds” language only applicable to state agency partners?
This language is required under the State Finance Act (30 ILCS 105/30) and applies to State agencies only. This language is a technical change to the MOU intended solely to meet the requirements of State law. The workforce Innovation and Opportunity Act (WIOA) does not allow core or required partners to opt out of their responsibility to share infrastructure and other costs due to insufficient funding. The Interagency Technical Assistance Team will not approve an MOU expanding the “subject to the availability of funds” language to a required partner that is not a State agency.
One-Stop Delivery System
Is the one-stop operator a shared cost?
competitive procurement of a one-stop operator may constitute a shared
cost if all required partners agree and proportionately share the cost
based on the benefit received. Required partners must share costs to pay
additional costs relating to the operation of the local one-stop
delivery system (§ 678.760(a)). Shared costs of the local one-stop
delivery system are determined locally and must be agreed upon by all
required partners in the local area.
Who is responsible for collecting all the shared costs?
Ultimately the LWIB is responsible for submitting a complete MOU. However, collection of specific costs will depend on the type of costs being shared. For infrastructure costs, this will generally be the leaseholder. It could be another entity, such as the LWIB for other types of shared system costs.
Is the one-stop operator a shared cost?
The competitive procurement of a one-stop operator may constitute a shared cost if all required partners agree and proportionately share the cost based on the benefit received. Required partners must share costs to pay additional costs relating to the operation of the local one-stop delivery system (§ 678.760(a)). Shared costs of the local one-stop delivery system are determined locally and must be agreed upon by all required partners in the local area.
Can an LWIB use Title IB funds to contract with a service provider to meet the requirement that adult education services under Title II or WIOA be accessible at a comprehensive one-stop center?
No. The Title II provider must have an approved contract or grant with the Illinois Community College Board for Adult Education/Title II services.
Is the Second Chance Program a required partner in Illinois?
Recidivism programs funded by a Second Chance grant in Illinois are administered by the Illinois Department of Corrections and funded through a grant from the U.S. Department of Justice, not the U.S. Department of Labor. Only U.S. Department of Labor grantees under Section 212 of the Second Chance Act of 2007 are required partners under WIOA. Because Illinois’ Second Chance grant was awarded by the U.S. Department of Justice, the Second Chance grantee in Illinois is not a required partner under WIOA.
Local workforce boards and partners may decide to include the Second Chance grantee as an additional partner in one-stop centers.
What is the difference between the National Farmworker Job Program and the Migrant and Seasonal Farmworker Program, and how should their FTEs be accounted for?
The Illinois Department of Employment Security (IDES) administers the Migrant and Seasonal Farmworker program, which is a required program under WIOA. The Illinois Migrant Council administers the National Farmworker Jobs Program, which is a separate program under Title I of WIOA. Each required partner enters its own and separate FTE commitments.
Regional and Local Plans
Do CEOs have to approve WIOA Regional and Local plan modifications before submittal?
Yes. The standard cover letter must be signed by the LWIB Chair and CEO(s) indicating their approval of the plan. CEOs that already have agreements on file to designate a lead CEO authorized to sign on behalf of all CEO’s in the area may continue that practice under WIOA. (Source: WIOA Notice No. 15-NOT-07, page 3, Part 1. B. 1)
Do Regional and Local Plans for FY 17 (SFY 18) need to be submitted in track changes mode?
Regional and Local Plans for FY 17 (SFY 18) need to be submitted in final form. However, it is suggested to maintain a track changes version for internal record keeping purposes.
How does the MOU tie into the Regional and Local Plans?
There should be a correlation between all three documents. The regional plans set the overarching priorities and strategies. The local plans describe how the partners in each local workforce area will address the regional priorities and strategies. The MOUs further refine this planning by specifically describing how the required partners agree to provide services and fund the one-stops. Local boards will want to ensure that their local implementation plan and MOUs include investments in activities that support the regional plan. We are looking for alignment between the regional plan, local plan and MOU.
If we need to make changes to our WIOA Regional and Local plans after they are out for public comment, do the plans need to be posted a second time for public comment?
No. There is no requirement for second public comment period.
Should all of the core partners’ program-specific plans be submitted within the Local Plan?
Core partner programs are required by their authorizing statute to complete program-specific plans, which are different than the WIOA-required Local Plans. Per WIOA, local boards and partners must jointly develop the Local Plan. The WIOA Local Plan is intended to incorporate information about how all of the required partners under WIOA will provide services and how those services will be coordinated and integrated. Local Plans should be developed in close consultation to the “Regional and Local Planning Process Guide – Updated December 2016,” which will serve as the basis against which Local Plans are assessed for state approval.
What is meant by “Local Plans?”
WIOA-required Local Plans apply to all required partners under WIOA in the local area. Detailed requirements for Local Plans can be found in final regulation (§ 6769.550, § 679.560, § 679.570)). Instructions for Local Plans have been provided in the “Regional and Local Planning Process Guide – Updated December 2016”. There is one WIOA Local Plan in each LWIA. This one WIOA plan should include information on all required partner programs and how they will be integrated and aligned to provide services in the area.
Workforce Innovation and Opportunity Act (WIOA)
How do we find out who is on our STAT team?
What is WIOA?
Public Law 113-128, the Workforce Innovation and Opportunity Act (WIOA), will replace the Workforce Investment Act (WIA) of 1998 to authorize the federal workforce programs in 2015.
The WIOA will modernize the nation’s workforce system and emphasizes the demand-driven approach that Illinois has developed over the past several years. The Illinois Department of Commerce and Economic Opportunity will coordinate with state and local workforce and economic development partners to implement the requirements associated with the two-year implementation of WIOA in coordination with the Illinois Economic Development Plan (published by Commerce in July 2014).
WIOA requires the strategic coordination of four core programs:
- Employment and training services for adults, dislocated workers and youth,
- Wagner-Peyser employment services,
- Adult education and literacy programs, and
- Vocational Rehabilitation programs serving individuals with disabilities in obtaining employment.
Where can I find out more?
The WIOA Implementation Portal is a resource with up-to-date information about the workforce system innovations in Illinois and the impact of those workforce innovations on our state.
The WIOA Resources page also provides material from the State and Federal workforce agencies.
The U.S. DOL’s website for the Workforce Innovation and Opportunity Act offers many related guidelines and technical assistance tools.
The WIOA Public Law is here.
STAT leaders can be found here.