Can the grantee’s paid leave policy charge the federal grant for employees (including subrecipients and contractors) that are not working due to COVID-19 closures or disruptions?
Beginning November 1, 2020, grant recipients and subrecipients must make every effort to provide services remotely or, where feasible and consistent with state and local laws, in-person. Any paid leave to staff beyond this time must be approved by the Grant Officer.
Can the WIOA youth programs continue to pay participants wages if the worksite is canceled due to COVID-19?
If the program participant’s time commitment, wage/stipend structure, and/or other academic or work terms were established before the national health emergency declaration, grantees should continue to pay the participant for the remainder of the established term. Grantees should not pay participants beyond the established term, regardless of stay-at-home orders.
Fiscal Management Q1: Will the local workforce areas continue to have access to post costs and request cash from the Grant Reporting System?
Yes, the Department of Commerce and Economic Opportunity (DCEO) accounting office have staff that are assigned to process the cash requests. The
Office of Employment and Training (OET) staff will review each cash request remotely.
Fiscal Management Q10: Can DCEO give us flexibility with the IWT line item of the budget so that we don’t need to make multiple mods to change the dollar amount allocated to it?
It is recognized that Incumbent Worker Training (IWT) can be a significant tool in response to the COVID crisis and the challenges that businesses are currently facing. The Office of Employment and Training (OET) knows that the Incumbent Worker Tracking System (IWTS) in workNet doesn’t allow users to enter new project plans once the total of the budgets for all of the IWT projects entered into the system for a program year have reached the total amount budgeted in the Incumbent Worker lines in grantee’s formula grant budgets. The amount shown in IWTS is the maximum amount the grantee has budgeted for IWT and must remain in place to prevent accidental obligations and expenditures beyond the allowable budgeted amount. We suggest LWIAs engaging in IWT to move larger amounts less frequently to reduce the need for multiple modifications.
Fiscal Management Q11: Incumbent Worker Training projects are being impacted by Covid-19, how should we handle these unexpected disruptions?
The IWTS system is being updated to allow flexibility for grantees and employers to capture the nature of impact of COVID-19 on incumbent worker projects. Users will be given the option to indicate when a project currently in IWTS is impacted by COVID-19 and then submit a request to either modify or cancel the project. IWTS users may then identify the project changes and the rationale using the normal project modification or cancellation request process in IWTS. Additional information with the details on the procedure will be forthcoming. Please direct questions on formula grant projects to Keelin.Valenti@illinois.gov or Michael.Baker@illinois.gov and for non-formula grant projects, contact your grant manager to discuss the best way to handle your specific situation.
Fiscal Management Q12: Can grantees use funds to purchase cleaning supplies?
Yes, to the extent that the supplies are used for the benefit of the grant program (e.g., in grantee spaces, or a proportionate share of shared spaces).
Fiscal Management Q13: Will the state provide funding for LWIAs to pay for additional cleaning services and Personal Protective Equipment at the workforce center?
The cost of additional cleaning services and personal protective equipment for staff that work in the workforce center is an allowable cost on the WIOA grant. Local administrators should contact DCEO regarding additional funding needs for this purpose.
Fiscal Management Q14 NEW: Will there be funding assistance for one-stop centers for masks, sanitation, hand sanitizer, reception plexiglass divider, other required equipment/purchases to ensure safety of all staff including partner staff at the one stop?
The procurement, funding and distribution of personal protection equipment, sanitation and materials to promote/enforce social distancing is an allowable shared cost. It is anticipated that the state and local COVID-19 reopening working groups will make recommendations and help identify the procurement and funding strategies for these materials.
Fiscal Management Q15 NEW: Will security at the AJCs during the reopening phase be an allowable expense?
Yes. The cost of security at an American Job Center is an allowable cost. Generally, speaking this is a shared cost that is frequently included in the annual Memorandum of Understanding Budget. Safety considerations is an important priority. It is anticipated that the state and local COVID-19 reopening working groups will develop guidelines and best practices regarding the safety and security of the AJCs.
Fiscal Management Q16 NEW: Regarding the Families First Coronavirus Response Act, can WIOA funds be used to pay an employee who qualifies for leave related to COVID-19 under this Act?
Yes. 2 CFR 200.431(b) states that a leave policy is allowable if is an established, written policy that applies equitably and consistently to all staff regardless of employee class, and if it is reasonable. (please see Fiscal Management Q4).
Fiscal Management Q17 NEW: If a County receives a federal appropriation to offset COVID-related expenses, can WIOA-funded COVID expenses be reimbursed through those County funds for AJCs that are part of the County?
The ultimate determination regarding the allowability of reimbursable costs will be up to the federal agency that is providing the reimbursement. WIOA funds may be able to be reimbursed if the COVID-19 response costs can be identified and tracked. The OET has requested additional information from the US Department of Labor and State of Illinois Office of Management and Budget on this topic. Additional information will be provided as soon as it is available.
Fiscal Management Q18 NEW: Some of our agencies received a loan under the Paycheck Protection Program and they are looking for guidance on how that grant can be used with their WIOA funds.
Agencies should follow the US Small Business Administration guidelines regarding the appropriate uses of the PPP loans (see
PPP Loans Guidance). Costs that are paid through the PPP funds are generally not allowed to also be reimbursed with WIOA funds. The LWIA's agency partners are required to document the expenditures in accordance with the Uniform Administrative Guidelines. Additional information is also posted at the IL Department of Human Service website at:
IDHS Paycheck Protection Program FAQs
Fiscal Management Q2: Will the local workforce areas be allowed to request “additional cash”?
No, unless there is an extenuating circumstance that should be communicated to DCEO as soon as possible. At this point, the OET has not changed the cash request approval guidelines.
Fiscal Management Q3: If the American Job Center / Illinois WorkNet site is closed by the lease‐holder or governing body, can the local workforce area continue to use WIOA funds to pay staff?
WIOA funds are provided to grantees on a reimbursement basis for the costs incurred including
the salaries and benefits of staff. Local workforce areas grantees must document the time of
staff and “charge” the grant based on the work that is performed. From a fiscal management
perspective, the regulations do not specify where the work must be performed. Therefore,
charging the grant for authorized activities that are performed remotely would be considered
Fiscal Management Q4: Are the costs of a grantee’s leave policy that provides paid leave to employees when their work hours have been reduced due to COVID-19 closures or disruptions allowable costs of the Federal gra
Yes. 2 CFR 200.431(b) states that a leave policy (including part-time employees and employees of subrecipients) is allowable if it is an established, written policy that applies equitably and consistently to all staff regardless of employee class, and if it is reasonable. However, a state or grantee may only charge an employee's paid-time-off to the Federal grant if it is the state's/grantee's overarching policy to pay all employees in this situation, regardless of the funding source used to cover such an expense. If a grantee amends its existing leave policy or develops a new emergency leave policy applicable to all employees affected by the COVID-19 pandemic (e.g., if a grantee’s offices are shut down due to COVID-19) , costs incurred under that policy would be allowable provided they meet the requirements in 2 CFR 200.431(b). For any change in policy that impacts the budget, competitive or discretionary grantees may need to submit a budget realignment request. If the change in policy impacts an approved indirect cost rate or cost allocation plan, the grantee must request a change or obtain an extension from its federal cost negotiator. Grant recipients and subrecipients must maintain appropriate records and cost documentation as required by 2 CFR § 200.302 - Financial management and 2 CFR § 200.333 - Retention requirement of records to substantiate the charging of any salaries and other project activities costs related to interruption of operations or services. Salary and Bonus limitations (Pursuant to P.L. 115-141, Division H, Title I, Section 105) remain in effect. At this time, no additional funds will be provided by ETA to cover these expenses. Should the need for such leave be longer than 60 days, ETA will provide additional guidance on these paid leave policies.
Fiscal Management Q5 NEW: Will the State of Illinois relax the expenditure and obligation requirement of the WIOA formula grants?
At this time the Department does not have the authority to relax the expenditure and obligation
requirements for the WIOA formula grants. The Department is monitoring the developments
and will remain in contact with the US Department of Labor to identify a potential response.
4-13-20 UPDATE FROM USDOL: ETA acknowledges work experiences for youth during this time period may be harder to provide. Program expenditures on this program element may include more than just wages paid to youth. When determining the types of expenditures that are allowable to help meet this requirement, additional information can be found in TEGL 08-15 and TEGL 21-16, p.15. If state and local areas do not meet this requirement at the end of their period of performance, the Department will follow standard monitoring procedures for this program element.
5-27-20 UPDATE: WIOA Section 132(c) establishes the requirement that states obligate at least 80 percent of each WIOA Title I-B formula grant or face recapture of those funds by the U.S. Department of Labor. Consistent with the requirement that the U.S. Department of Labor (DOL) imposes on states, it has been the State's practice, to hold LWIBs to the same 80 percent obligation standard for the WIOA Title I-B formula grant funds. Because the COVID-19 emergency has resulted in disruptions to local area service delivery, the State is suspending the requirement on LWIBs to obligate at least 80 percent of WIOA Title I-B Adult, Dislocated Worker, and Youth formula grants in PY'19.
Fiscal Management Q6: Are additional funds available to assist in the COVID-19 response?
Yes, the Department of Commerce and Economic Opportunity has Rapid Response funds
available to support the immediate needs of the local workforce areas. It is important to note
that these funds must be used for allowable activities under the Workforce Innovation and
Opportunity Act. The Department continues to work with the US Department of Labor to
request additional flexibility in the use of Rapid Response and WIOA funds for recovery efforts.
UPDATED 5-27-20: In order to support the Local Workforce Innovation Areas that face the financial impacts from the COVID-19 response, the Illinois Department Commerce and Economic Opportunity (DCEO) has identified $1,000,000 in Statewide WIOA funds to support the extraordinary WIOA infrastructure and shared system costs associated with the operation of the local workforce centers. It is recommended that LWIBs consider using these funds to support the provision of career services in the one-stop delivery system and carry out activities to facilitate remote access to training services provided through the one-stop delivery system.
Fiscal Management Q7: Will the 50% minimum training expenditure requirement be waived?
The Illinois Workforce Innovation Board (IWIB) has not met to discuss the impact COVID‐19
might have on Local Workforce Innovation Boards’ (LWIB) ability to meet the minimum training
expenditure requirement found in WIOA Policy 8.4 Training Expenditure Requirement. In the
absence of relief provided by the IWIB action regarding the required minimum rate and
potential incentives or sanctions, the policy provides provisions for LWIBs to request an application
of a Hold Harmless Clause by submitting a written explanation as to the conditions that
contributed to the unplanned inability to meet the minimum rate.
UPDATED 5-27-20: The Illinois Workforce Innovation Board has authorized a change in WIOA Policy Chapter 8.4.7 that includes a hold harmless clause for LWIBs that failed to meet the minimum training expenditure level.
Fiscal Management Q8 NEW: If the worksite for a customer that is enrolled in On-the-Job Training or Paid Work Experience is closed, can WIOA funds continue to pay for the OJT or Paid Work Experience?
4-13-20 UPDATE FROM USDOL: If the program participant’s time commitment,
stipend structure, and/or other academic or work terms were established prior
to the national health emergency declaration, grantees should continue to pay
the participant for the remainder of the established term.
Q8a. Does this guidance apply to both OJT and Work Experience?
Yes. Note that OJT reimbursement can only be made if the participant and other employees are still getting paid during the shutdown due to COVID-19.
Q8b. Does the LWIA retroactively pay back to the first day that the participant was not paid due to the businesses shut down due to COVID-19?
Yes. However, if retroactive pay is made available, the Local Area must consider the impact of Unemployment Compensation paid to the participant if received during the shutdown, as referenced in UIPL 10-20.
Q8c. The LWIA normally pays based on a time sheet signed by the employer and participant but that is going to be difficult. We assume electronic signature and a case note will be acceptable.
Yes. Internal controls should be in place where a process is required to obtain participant signatures for payments based on time worked. Documenting the process, whether through actual or electronic signatures will verify an authorized representative reviewed and approved the documentation for payment. The electronic process must include internal controls to ensure that authorized representatives' signatures cannot be duplicated by non-authorized personnel.
Q8d. If we have a customer who is in work experience and works various hours a week, can we average out their hours to pay them while not working?
According to the USDOL, ensuring fair and reasonable compensation payments should be based on the State of Illinois' established policies. It is the State of Illinois' policy to base these payments on the planned services that are outlined in the participant's Individual Employment Plan or Individual Service Strategy. The LWIA must also base the work-based training payments based on the terms of the work site agreement including but not limited to the hourly rate of payment and the length of the service (number of hours per week and the number of total weeks). If the number of hours that the participant varies from week to week, then it is allowable to average the number of hours as long as there is a reasonable and equitable basis for the providing the payments. A detailed case note is required for LWIAs that make these payments.
Q8e. Can the state provide the date when the LWIAs can begin paying work-based customers whose worksites were closed as a result of COVID-19?
LWIAs are authorized to pay work-based customers whose worksites were closed as a result of COVID-19 back to March 1, 2020. This is the same date that is referenced in the President's Proclamation on Declaring a National Emergency Concerning the Novel Coronavirus Disease (COVID-19) Outbreak. The FAQ posted by the US Department of Labor indicates that "WIOA formula and competitive grants can continue to pay wages or stipends if program participants were actively being served prior to the pandemic or if they were in a work experience placement (e.g. subsidized employment, OJT, paid internship) that was recently cancelled due to COVID-19". On March 11, 2020, the World Health Organization announced that the COVID-19 outbreak can be characterized as a pandemic, as the rates of infection continue to rise in many locations around the world and across the United States. Note that this guidance applies to worksite placements that were cancelled at any time after March 1, 2020 as a result of COVID-19.
Q8f. Can the LWIA pay work-based learning customers that were dismissed from worksites as a result of COVID-19 even if the worksites were not closed?
Yes. The FAQ posted by the US Department of Labor indicates that "WIOA formula and competitive grants can continue to pay wages or stipends if program participants were actively being served prior to the pandemic or if they were in a work experience placement (e.g. subsidized employment, OJT, paid internship) that was recently cancelled due to COVID-19 (emphasis added).
Q8g. Is there a "cut-off date" for when a work-based training agreement would need to be in place to apply this guidance and continue to pay the participant?
The US Department of Labor FAQ indicates that this guidance applies to customers that were actively being served prior to the pandemic or if the worksite was recently cancelled due to COVID-19. Although there is not a specific cut-off date for when a worksite agreement must have been in place, the LWIAs must consider this guidance and the reasonableness of the cost.
Q8h. If a work experience customer has been "laid off" due to COVID, but has accepted another position working elsewhere, is the LWIA required to pay the customer until the contractual hours have been expended or until the customer has been called back to the worksite?
No. The LWIA is not required to pay the customer until the end of the work experience in this situation. The DOL has advised that the WIOA formula and competitive grants can continue to pay wages or stipends if program participants were actively being served prior to the pandemic or if they were in a work experience placement (e.g. subsidized employment, OJT, paid internship) that was recently cancelled due to COVID-19".
Q8i. If a customer was in a work experience position and working another job at the same time, do they still qualify for the continued pay if they were "laid off" at their WIOA worksite because of COVID, but they are still employed at the other job?
This is a LWIA decision based on the specific circumstance and the reasonableness of the cost. The DOL has advised that the WIOA formula and competitive grants can continue to pay wages or stipends if program participants were actively being served prior to the pandemic or if they were in a work experience placement (e.g. subsidized employment, OJT, paid internship) that was recently cancelled due to COVID-19".
Q8j. If the work experience worksite has reopened and the participant does not go back to work or quits, is the customer still eligible for "COVID pay" for the remainder of their hours/term of the agreement?
Q8k. If a participant that is placed in a WIOA-Funded Paid Work Experience contracts COVID-19 or is quarantined, is it allowable to pay the work experience cost during the time the participant is quarantined and not allowed by the public health guidelines to report to the worksite?
This cost may be allowable if the local workforce area's paid leave policy includes work experience participants. The policy should include the conditions for providing leave payments for excused absences and must be applied equitably and consistently to applicable participants. The wages for the work-based learning customers may continue to be paid based on the local leave policy and a review of applicable scenarios including, but not limited to:
- Local health guidelines for quarantined customers due to COVID;
- Customer is testing for COVID;
- Customer is awaiting the results of a COVID test; or
- Customer is recovering from COVID.
- There is a temporary shutdown of the work site due to a potential COVID infection.
Fiscal Management Q9: What costs are allowable for staff who are working remotely? Toner, printers, scanners, internet costs, etc.
Supplies that are charged to the federal workforce grants must meet the requirements of the Uniform Administrative Requirements at 2 CFR 200. The cost of office supplies must be reasonable, allocable and allowable. Workforce professionals must follow the grantee's financial management policy and procedures for procuring office supplies that are used in the American Job Center and/or in remote locations. Note that the cost of Internet, utilities or other occupancy costs of a home office are generally not allowed.
For employers that obtain PPP forgivable loans, are they also eligible to obtain WIOA funding such as for On-the-Job Training grants?
A company that has received a Payment Protection Program loan remains eligible to obtain WIOA funding such as On the Job Training; however, companies are advised not to “double-dip” and pay the required matching portion of the OJT employee’s salary with PPP funds. The matching portion of OJT must be made with nonfederal funds. Companies are advised to review the terms of the PPP Loan for complete information regarding the allowable costs, and conditions of the loan.
IE COVID19 Response Layoff Adversion Funding Q19 NEW: When will the funds be distributed to the LWIAs?
The Office of Employment and Training will issue COVID-19 Layoff Aversion grants as soon as feasible. The goal is to have the new grants established before the end of the State Fiscal Year on 6-30-20. The OET will provide updates that includes the total grant amount and the list of projects that have been approved with a "funding commitment" under this program as soon as the information is available. The OET will request a "quick turn-around" of the grant documents from the LWIAs (by 6-15-20) to allow enough time to process the grants before the end of the state fiscal year.
IE COVID19 Response Layoff Adversion Funding Q20 NEW: Do “modifications” (i.e. social distancing barriers) made to a workplace in response to COVID-19 require compliance with Federal Labor Standards Provisions including payment of Federal prevailing wages
Yes, if WIOA funds are used for this purpose.
IE COVID19 Response Layoff Aversion Funding Q1 UPDATED: What are the essential businesses in Illinois according to the Governor’s Executive Order?
UPDATED: Executive Order 20-32 requires all non-essential businesses and operations to cease all activities except for minimum basic operations. Non-essential businesses may also continue operations consisting exclusively of employees or contractors working from home. Please review the Illinois Essential Business FAQ for more information.
IE COVID19 Response Layoff Aversion Funding Q10: What is the local workforce area’s responsibility to verify in terms of the application?
Administrators should follow the local policy and procedures that are established for entering into agreements with employers. It is the employer’s responsibility to attest to the conditions of the award. Administrators should also plan to include a risk-based sample of the layoff aversion awards as part of the local monitoring schedule to verify compliance.
For more information regarding a risk-based monitoring sample, please see 2 CFR 200.205 that outlines the key risk categories to consider when developing a monitoring plan of the entity / applicant including:
- Financial stability;
- Quality of management systems
- History of performance.
- Reports and findings from audits
- The applicant's ability to effectively implement the requirements of the award
IE COVID19 Response Layoff Aversion Funding Q11: How do we verify number of employees affected, the number kept on after the 45 days?
Administrators may request supporting documentation from the employer to verify the number of employees affected. Administrators should also plan to include a risk-based sample of the layoff aversion awards as part of the local monitoring schedule to verify compliance.
IE COVID19 Response Layoff Aversion Funding Q12: Are IT consulting expenses to analyze our current system and determine what we would need to do to create virtual customer interactions an allowable expense?
IE COVID19 Response Layoff Aversion Funding Q13: Will the eligible employers change for the 1E Statewide Rapid Response Grant now that the Governor revised his Order to allow non‐essential businesses to open with restrictions?
Funding is available for businesses to operate in compliance with the Governor’s Executive Order. This includes all businesses that are operating in compliance with the Governor’s Executive Orders. IE funds will not support activities that violate the Executive Orders. IE funds could be used to support companies that resume operations as soon as they are allowed to reopen.
IE COVID19 Response Layoff Aversion Funding Q14: Are extended warrantees for computers purchased with IE Layoff Aversion Funds an allowable expense?
Allowability of a warranty will be determined on a case‐by‐case basis if it benefits the project is reasonable and necessary.
IE COVID19 Response Layoff Aversion Funding Q15 NEW: Are employers that are participating in the Paycheck Protection Program eligible to apply under this this grant?
Employers that meet the IE Program requirements that are also participating in the Paycheck Protection Program may be allowed to use WIOA funds; however, the employer is not allowed to charge both programs. The employer would be required to document the expenditures in accordance with the Uniform Administrative Guidelines. DCEO LWIAs are advised to carefully scrutinize the reasonableness of these applications. Note that the OET cannot advise on the terms and conditions of the Paycheck Protection Program.
IE COVID19 Response Layoff Aversion Funding Q16 NEW: Will employers be required to submit receipts to the state before they are reimbursed for the costs that are included in the award?
Employers must follow the local workforce area's fiscal procedures for submitting reimbursement requests. The LWIA is not required to submit these receipts to the State; however, the LWIA should retain documentation to verify the costs.
IE COVID19 Response Layoff Aversion Funding Q17 NEW: How will these grants be monitored?
The Office of Employment and Training will include the IE grants as a part of the annual WIOA monitoring. A representative sample of the projects funded under this grant will be included as a part of this review. The LWIAs are also advised to include these projects as part of the local area's monitoring schedule.
IE COVID19 Response Layoff Aversion Funding Q18 NEW: How will the funds be distributed to the LWIAs?
The Office of Employment and Training (OET) will issue new grants to each of the local workforce areas that have projects that receive funding commitments. Although the OET intended to modify the Program Year 2019 Rapid Response grants; we have been directed by the Illinois Office of Management and Budget that new grant awards must be issued to track the COVID-19 related response efforts.
IE COVID19 Response Layoff Aversion Funding Q2: How can you verify that an employer is in good standing and not on the federal excluded parties list?
IE COVID19 Response Layoff Aversion Funding Q3: How do you define “small business”?
For the purpose of the Emergency (IE) Assistance Application in Response to COVID-19, DCEO is using the United States Small Business Administration definition of a small business. Please visit the SBA websites for more information. SBA Size Standards and SBA Table of Size Standards
IE COVID19 Response Layoff Aversion Funding Q4: Can the IE COVID Response Funds pay for business consultants that provide employers with an analysis of how to implement the recommendations of public health officials?
Yes, if the consultant services directly result in the employer implementing strategies that are recommended by public health officials including but not limited to social distancing, cross training and remote working.
IE COVID19 Response Layoff Aversion Funding Q5: Can the IE COVID Response Funds pay for business service navigators to identify funding to help employers stay in business?
Assisting businesses to locate financing to avoid layoffs is an allowable Rapid Response activity. In many LWIAs the business service team members perform this important function. LWIAs that need additional support for these activities are encouraged to contact Lorraine Wareham at Lorraine.firstname.lastname@example.org with detailed information regarding these specific needs.
IE COVID19 Response Layoff Aversion Funding Q6: Does the IE COVID Response Funds pay for administrative costs?
Limited administrative costs may be provided on a case by case basis to cover the administrative costs that cannot be absorbed by the local business service teams and program monitors.
IE COVID19 Response Layoff Aversion Funding Q7: If an employer already purchased computers for remote work, would we be able to apply for grant funds to reimburse those costs? Are pre-award costs allowed?
Per the terms of the grant award, Pre-award costs for layoff aversion activities will be allow going back to January 1, 2020.
IE COVID19 Response Layoff Aversion Funding Q8: Will DCEO review and fund other IE requests – including requests that were submitted prior to the IE COVID Response Notice?
Yes. LWIA administrators are advised to contact Lorraine Wareham at Lorraine.email@example.com.
IE COVID19 Response Layoff Aversion Funding Q9: If an employer filed WARN for one location, would other locations be eligible under this funding opportunity?
If someone is not eligible for regular Unemployment Insurance (UI), but is receiving Pandemic Unemployment Assistance (PUA) benefits (they were self-employed), what is the required documentation for determining 1D eligibility?
There are several different ways an individual may be determined eligible as a WIOA Dislocated Worker and 1D eligibility can usually be handled more easily than attempting to make UI or PUA the key factor. We will describe how to do handle 1D eligibility for a formerly self-employed worker either way.
The most straightforward path to 1D eligibility for an individual who was self-employed, but became unemployed due to general economic conditions or a flood or natural disaster, is under the WIOA Dislocated Worker criteria of Formally Self-Employed, but now Unemployed. This criteria does not include any component tied to UI status, either traditional UI or PUA.
The only 1D eligibility criteria tied to UI (either traditional UI or PUA) is Unlikely to Return to Previous Industry or Occupation. The receipt of either traditional UI or PUA works the same under this criteria, however additional conditions must to be met, such as: 1) dislocation job from either a declining industry or low growth occupation; OR 2) six months unemployed with one month documented job search; OR 3) requires additional assistance justified by Career Planner staff in the assessment. The documentation of receipt of PUA may be handled using the same methods used to document receipt of UI.
So while it is possible to use the receipt of PUA as one of several required factors when using Unlikely to Return to Previous Industry or Occupation, in most cases it is simpler and recommended to use Formally Self-Employed, but now Unemployed which avoids the need to document the receipt of benefits.
National Dislocated Worker Grant Program Q1 NEW: Is the cost of instructing a participant in “contact tracing” an allowable cost?
Yes, if the cost is reasonable and necessary for the participant's placement in a Disaster Recovery job. Note that the LWIA will need to work with the Department to determine if the instruction should be classified as a WIOA Career Service or Training Service.
National Dislocated Worker Grant Program Q2 NEW: Do the training programs under the NDWG grants have to be listed on the State WIOA Eligible Training Provider List?
National Dislocated Worker Grant Program Q3 NEW: Can the LWIA hire a participant to act as a Project Coordinator?
National Dislocated Worker grant Program Q4 NEW: Can the cost of hiring a third party (staffing agency) be considered an allowable cost to the grant?
Yes, as long as the costs are reasonable and necessary and that local procurement procedures are followed. When performing a cost/price analysis, the "contract plus a percentage of cost" method of contracting must not be used. There is no rule of thumb for a reasonable profit margin, but a profit margin above 10% is going to receive more attention and analysis as to whether it is reasonable based on the complexity of the service being provided. Any profit that exceeds 10% must be reviewed and pre-approved by DCEO in consultation with the USDOL grant manager.
National Dislocated Worker Grant Program Q5 NEW: What is the administrative cost limit for the NDWG awards?
Administrative costs are limited to 10% at the local level.
National Dislocated Worker Grant Program Q6 NEW: The current On the Job Training regulations does not allow LWIAs to place participants with employers that have recently laid off workers. Will this be modified?
At this time the Department does not have the authority to relax the regulation. The Department has requested additional guidance from the US Department of Labor.
National Dislocated Worker Grant Program Q7 NEW: Are the wages for Disaster Relief Employment (temporary workers) participants subject to the unemployment withholding requirements?
Yes. Please note the Office of Employment and Training is requesting a clarification with the Illinois Department of Employment Security to see if there is any flexibility with this requirement – specifically for employers that are governmental entities.
National Dislocated Worker Grant Program Q8 NEW: Are the work experience wages for participants that are placed in work experience/paid internships/transitional jobs subject to the unemployment withholding requirements?
No, If it is as part of an approved training program.
Planning and Governance Q1: Will the due date for the Regional / Local Workforce Development Plans be extended?
The regional and local plans currently have a due date of March 31, 2020.
Please e‐mail firstname.lastname@example.org if you need assistance or need to request an extension.
Planning and Governance Q2: Will the state be flexible regarding the signature requirements for the regional and local plans?
Yes. When submitting regional and local plans to the State, it is acceptable to use a signature block with all caps followed by an /s/ to indicate formal approval on the submittal letter. If a signature block is used for the CEO and LWIB on the submittal letter, it should appear as follows: “FIRST AND LAST NAME /s/”. The “/s/” signature is currently used on the accessible version of guidance that is posted on DOL’s Employment & Training Administration’s system. As the COVID-19 pandemic evolves, DOL is temporarily modifying the way ETA advisories are signed. ETA advisories with the “/s/” signature are considered official guidance. Once social distancing efforts are lifted, DOL will revert to posting signed versions of advisories.
Planning and Governance Q3: Will the due date for the Memorandum of Understanding and the Annual MOU Budget be extended?
UPDATED 3‐20‐20 A “Report of Outcomes” is due to the State on April 15, 2020 to indicate the status of your local workforce area’s MOU negotiations and whether all required partners have agreed to the MOU and annual budget for Program Year 2020. While the Interagency TA Team continues to monitor developments, the April 15 due date for the Report of Outcomes still applies. Please email email@example.com if you need assistance or need to request an extension to complete the negotiations in your local workforce area.
Planning and Governance Q4: Can the local workforce boards use technology to meet and conduct business?
Yes. During the duration of the Gubernatorial Disaster Proclamation, the provisions of the Open
Meetings Act, 5 ILCS 120, requiring or relating to in‐person attendance by members of a public
body are suspended. Specifically, the requirement in 5 ILCS 120/2.01 that "members of a public
body must be physically present" is suspended; and (2) the conditions in 5 ILCS 120/7 limiting
when remote participation is permitted are suspended. Public bodies are encouraged to
postpone consideration of public business where possible. When a meeting is necessary, public
bodies are encouraged to provide video, audio, and/or telephonic access to meetings to ensure
members of the public may monitor the meeting, and to update their websites and social media
feeds to keep the public fully apprised of any modifications to their meeting schedules or the
format of their meetings due to COVID‐19, as well as their activities relating to COVID‐19.
Planning and Governance Q5: What impact will the COVID-19 National Health Emergency have on the local Memorandum of Understanding Narrative, MOU Budget, and the payment of shared costs outlined in the MOU?
The COVID-19 National Health Emergency has resulted in an unprecedented number of individuals that have filed for Unemployment Insurance. State agency partners including the Illinois Department of Employment Security have focused all available resources to address the immediate crisis. Please be advised that during this time it is anticipated that there will be delays in the review of the MOU narrative and budgets from state agency partners. It is also anticipated that state payments of shared costs will be delayed. We appreciate your patience as work through this emergency.
Planning and Governance Q6: Will the June 30, 2020 Deadline for One Stop Certification be extended? If not, how should LWIAs proceed, as there are items on the checklist that may not be complete due to COVID issues.
At this time the Department does not have the authority to extend the deadline for One Stop Certification. The Department is monitoring the developments and will remain in contact with the US Department of Labor to identify a potential response.
Program Oversight Q1: Can the local workforce area suspend or reschedule the on‐site monitoring of subrecipients and contractors?
Yes. Local workforce area staff are allowed to reschedule on‐site monitoring reviews. Staff are
encouraged to complete enhanced desk reviews that should expedite the on‐site monitoring
when it is rescheduled based on the information provided by local public health officials.
Program Oversight Q2: Can the local workforce area suspend the on‐site monitoring for Work Experience and/or On‐ the‐Job Training participants?
Local workforce areas have a responsibility to keep participants safe and ensure that the host employers are following the current OSHA safety guidelines. Local areas should implement monitoring based on the risk factors of the work site. If the work sites are higher risk, then in‐ person monitoring may be warranted. If the work sites are lower risk, then it would be acceptable to monitor the worksite remotely using technology including, but not limited to, teleconference including facetime, email, text and other social media platforms. Additional information is available at:
CDC Guidance for Businesses and Employers.
TAA Q1: Are there exceptions for computer purchases not required or on a syllabus? Participants are requesting we buy computers to allow continued training, when training institutions have not provided documentation stating a computer is required.
If the training institution is now requiring that students take courses online and the
participant does not have the equipment needed to continue their classes, then it IS a
requirement, and that cost should be covered accordingly. As ever, this is not an open
authorization for participants to request elaborate equipment, and steps should be taken
to set parameters around the reasonable cost of purchasing the computer. USDOL does
not support a specific device or operating system. However, there are certain devices
(e.g. Chromebook) that are available at a nominal cost which meet the necessary
technical requirements to access online systems.
Note: Additionally, if the purchase of a laptop/computer will place the worker over the
states ‘soft cap’ policy, the state should consider ongoing and unexpected circumstances
to serve as justification for exceeding the states ‘soft cap’.
TAA Q10: Should states continue to provide rapid response services for any layoff event impacting 50+ in light of COVID-19?
States should continue to provide Rapid Response information to affected employees.
States have flexibility in whether to provide this in-person or through other means. States should consult CDC guidance and local government directives on large
TAA Q2: Should a state modify a training plan to lengthen the time needed to complete their individual training program?
TEGL No. 5-15, Change 1, Attachment A, Section D.4 (Length of Training) provides a
maximum amount of 130 weeks of TAA training (not calendar weeks) for 2015
Program participants and any training can be modified for the individual to
accommodate the individual’s completion of TAA training. An individual’s training
plan should always be modified/amended to reflect a change in the length of training.
TAA Q3: Can the state modify a plan to extend beyond two years?
Training completion can extend beyond two calendar years. However, the worker is
only allowed up to 130-weeks of actual training.
TAA Q4: If a school shuts down and an individual cannot participate in online classes, do we move them to a Work Search Status until they return to school?
The state should request and document an explanation as to why the individual cannot
participate in online classes. If it is due to a lack of supplies (such as a computer), then
that could be covered by TAA training funds. If the school is not offering online
classes, and is therefore on a break, then the EB work test does not apply in this case.
TAA Q5: If the individual finds a job while training was ceased due to COVID, can they later come back to the program and resume training or apply for a new training program?
The individual may return or resume their approved TAA training plan. Amending or
modifying that training plan is best addressed on a case by case basis. No individual
shall be entitled to more than one training plan under a single certification, in
accordance with 20 CFR 617.22(f)(2).
TAA Q6: The state closing all Job Centers to the public. Is the state allowed to waive attendance verification, waiver deadlines, benchmark reviews?
The state is not permitted to waive attendance verification requirements, deadlines, or
benchmark reviews. The state should make a “reasonable” attempt to meet deadlines,
verification requirements, and benchmark reviews.
However, due to ongoing circumstances surrounding COVID, the state should account
for current challenges in obtaining or completing these requirements. If the state is
unable to obtain the necessary verification after a “reasonable” attempt, the state should
document the inability to meet certain requirements as a justification for not being able
to obtain the required information.
TAA Q7: Would it be an allowable charge if the employee came to work but worked on COVID- 19 related functions (i.e., sanitizing the building, etc.) and not grant-related functions?
Assisting in the cleaning and sanitizing of dedicated and common space that is used to
house and serve program staff and participants is an allowable grant function.
TAA Q8: If we are closing our AJC, should we tell anyone?
Yes, please inform your Regional Office of AJCs or SWA closures. ETA will use this info to update the Service Locator website, and to update information disseminated by the Toll Free Helpline.
TAA Q9: Covid-19 will affect the #s of people I can serve, and may impact performance. Will I be held accountable for those performance measures? Will future FOAs that use previous performance as a scoring criteria take related disruptions into account?
ETA understands there will be disruptions to services to participants that ultimately
may impact performance. As we see how long these disruptions last, we will provide
guidance for competitive performance measures. ETA does not anticipate these
potential disruptions impacting current Funding Opportunity Announcements (FOAs
being awarded by June 30, 2020). These grant competitions generally use prior
performance for activities that have already taken place, and would not be impacted by
any COVID-related disruptions.
Technical Assistance Q1: Will the 2020 WIOA Summit still be held?
No, the 2020 WIOA Summit, scheduled for April 28‐29, 2020 has been cancelled. There are no
plans to reschedule the event, so the next Summit is tentatively planned for April 2021.
Technical Assistance Q2: What will happen to all of the sessions scheduled to be presented at the 2020 WIOA Summit?
The plan is to review each of the sessions and identify which topics are able to be presented in a
webinar format. The WIOA Wednesday Webinar series will be utilized to present the
information. Once the topics are reviewed and prioritized, and speakers/presenters will be
contacted to determine if they can provide the information, a schedule of webinars will be
developed. Information will be provided through the Career Connect email series that has been
provided to the field from the Illinois Center for Specialized Professional Support (ICSPS) at
Illinois State University.
Technical Assistance Q3: What other technical assistance is being planned to follow when the COVID‐19 precautionary plans subside?
In addition to utilizing WIOA Wednesday Webinars, plans will be to provide regional roundtables
to present information that may not be suitable for the webinar platform. Notifications on
emerging information from the POTUS Office, Federal and State Agencies, and the Illinois Governor’s Office will continue to be disseminated through emails and posted on Illinois
workNet® when possible and a clear message is available.
Technical Assistance Q4 NEW: Where are the Governor’s Executive Orders posted?
TRA Q1: If the school is on an unscheduled break due to COVID-19 for more than 30 days can we issue TRA payments?
If the school is on an unscheduled break, then BTRA is not be payable for the time
being. The school must consider the break scheduled and less than 30 days in order to
pay BTRA. However, BTRA maintains an exception that would allow for payment if
the worker completes the states EB work search test.
If the school is on an unscheduled break, then ATRA is not payable unless the worker is
attending training full-time according to the schools definition of full-time status. The
school must consider the break scheduled and less than 30 days in order to pay ATRA.
CTRA is not payable during a breaks in training. CTRA can only be paid if the worker
is participating full-time, according to the schools definition of full-time status.
Note: We are actively evaluating the policies surrounding TRA to explore opportunities
to re-evaluate some of the requirements since many participants depend on TRA
payments as a source of income. However, for the time being, normal TRA payment
requirements are still in place.
TRA Q10: An individual is on “Additional” TRA and the school closes. Because the law states “Additional” TRA is not payable as a work search how do we handle these cases? Due to COVID, is there an exception to the “Additional” payment rule?
No payment of additional TRA is permitted without participation in TAA training.
TRA Q11: If the payment of TRA benefits are allowed, will individuals be required to satisfy the Extended Benefit Work Test for each week they are not in school?
Without participation in TAA training only basic TRA payments could be allowed. If
there is a cessation in TAA training, the EB work test does not apply but nothing
prevents the individual from continuing to seek employment.
Additional and Completion TRA are not payable without participation in TAA training.
Accordingly, conducting the EB work test is not required but nothing prevents the
individual from continuing to seek employment.
TRA Q12: An individual is on “Completion” TRA and the school closes. Because the law states “Completion” TRA is not payable as a work search how do we handle these cases? Due to COVID-19 emergency, is there an exception to the “Completion” payment rule.
There are no exceptions. CTRA is not payable during breaks. CTRA is only payable
during the final 20-weeks of a training plan and when participating in full-time
coursework, as defined by the training institution.
TRA Q2: Are workers eligible for TRA if the employer closes operations because of COVID-19 precautions?
Eligibility for TRA requires that workers be a member of a group certified as eligible to
apply for TAA benefits. Worker’s separation must be for lack of work and while the
closure appears to be a lack of work, workers’ must first be eligible for UI benefits
under State law. Once UI benefits are exhausted, the individual may be eligible for
TRA Q3: Is a worker who tests positive, becomes sick, or is quarantined for COVID-19 eligible for TRA?
See A2. Eligibility for TRA requires that workers be a member of a group certified as
eligible to apply for TAA benefits. Worker’s separation must be for lack of work and
while the closure appears to be a lack of work, workers’ must first be eligible for UI
benefits under State law. Once UI benefits are exhausted, the individual may be eligible
TRA Q4: Do workers remain eligible for TRA if they are currently in TAA training and the training institution closes due to COVID? If workers experience the conditions in #2 above or if the training institution closes, do they remain eligible to TRA?
Workers undergoing TAA training and collecting TRA may remain eligible for Basic
TRA, as permitted by the regulations (e.g. EB work search or Participation in full-time
Additional or Completion TRA is not available because both require actual
participation/attendance the approved-training program.
TRA Q5: Will a worker remain eligible for TRA if the worker is sick or quarantined due to COVID-19?
Workers undergoing TAA training and collecting TRA may remain eligible for Basic
TRA, as permitted by the regulations (e.g. EB work search or Participation in full-time
Additional or Completion TRA is not available because both require actual
participation/attendance the approved-training program.
TRA Q6: The workers training was suspended due to COVID-19 (e.g. sickness, quarantine, closure of training institution) and the workers TRA eligibility period is scheduled to expire. Is an extension of the eligibility period permissible?
Once the COVID-19 event ends, the TAA training resumes, and there is Justifiable
Cause, the eligibility period(s) for Additional and/or Completion TRA may be
extended. The worker should contact their case manager to extend the period and
schedule a date to resume training.
States should document a justification (e.g. Eligibility period extended due to COVID-
19 mitigation strategies) for the extension of the eligibility period in the workers case
TRA Q7: Training was suspended due to COVID-19 (e.g. sickness, quarantine, closure of training institution). Should the state continue paying UI/TRA until they return to school?
An individual receiving Basic TRA who has ceased participation in TAA approved
training may continue receiving such benefits because the event falls under the
regulatory citation at 20 CFR 617.18(b)(2). There is justifiable cause for the cessation
in training. Additional and Completion TRA are not payable without participation in
TRA Q8: Individual is on a Waiver from training and stops looking for work because of the COVID-19 national emergency. They have not identified that they are sick but do not want to look for work at this time. Do we continue to pay TRA?
All TRA requires the individual to meet the EB work test unless the individual is
participating in TAA training. The EB work test provisions within State law govern
whether this individual may be eligible. Please refer to 20 CFR 615.8(d), (e), (f), (g).
TRA Q9: Can the 104 week “Basic” Eligibility Period be extended due to a national emergency?
The Trade Act of 1974, as amended, provides for the extension of the eligibility periods
for TRA for justifiable cause.
Section 233(h) of the Trade Act of 1974, as amended provides:
“SPECIAL RULE FOR JUSTIFIABLE CAUSE.—If the Secretary determines that
there is justifiable cause, the Secretary may extend the period during which trade
readjustment allowances are payable to an adversely affected worker under paragraphs
(2) and (3) of subsection (a) (but not the maximum amounts of such allowance that are
payable under this Section).
Guidance provided via TEGL No 5-15, Change 1, Attachment A, Section C.2.2
(Justifiable Cause to Extend the Program) provides the following: A worker may
receive weeks of Basic TRA and Additional TRA only during the eligibility periods set
by the statute, except for a limited statutory exception. As under the 2011 Act, Section
233(h) allows for an extension of these eligibility periods for “justifiable cause,”
meaning circumstances determined by the CSA to be beyond the worker’s control.
In making this determination, the State will apply the criteria described under the
discussion above for the Federal Good Cause provision, as well as regulations, policies,
and practices applicable to administration of the State’s UI laws. Please also see
Section C.5.2.( Completion TRA Eligibility Period Established by the Secretary) of
these Operating Instructions for more information on justifiable cause and Completion
Accordingly, the periods in which an individual is eligible for any TRA may be
extended. This means that any individual who ceases participation in TAA training and
as a result becomes ineligible for TRA may resume such eligibility once the individual
returns to training as benefits will not be lost.”
Trade Program Management Q1: Please provide an update regarding the initial trade application data requirements given that Trade‐affected workers have specific requirements and deadlines to meet.
IDES is currently not sending outreach notices, but is accepting and reviewing TRA claims. Good
Cause and Equitable Tolling will be considered on a case‐by‐case basis when determining if the
26/26 deadline was met. Additionally, Good Cause and Equitable Tolling will be invoked as
necessary for date extensions.
Trade Program Management Q2: Do TRADE case managers need to enroll clients in remote or distance learning due to their programs being moved to all online?
Yes. In addition, case managers should revise the Individual Employment Plan following the normal approval procedures. Please note that the participant signature to the IEP can be obtained later if you document via e-mail that the customer has the revised IEP.
Trade Program Management Q3: Can you provide clarification of what you mean by “immediate release of Trade funds"?
Trade funds are directly associated with dislocated workers that were laid off as a result of foreign trade. Expanding these funds for use to other allowable activities associated with layoffs in general, such as Rapid Response services which provides a coordinated approach to layoffs, will give funding flexibility to serve more individuals impacted the COVID-19 National Emergency. Illinois is requesting the US Department of Labor direct the administrators of the Trade Adjustment and Assistance program to certify Trade Act petitions that are associated with a layoff that was a result of the COVID-19 National Emergency. Additionally, Illinois is seeking permission to expand the use of Trade funds for allowable services such as Rapid Response layoff aversion activities.
We are receiving new applications from people who are temporarily laid off. For example restaurant workers. What services can be provided for these applicants? They will be receiving UI but will be returning to work once they are called back.
Individuals who are
laid off, even temporarily, may be eligible for WIOA Career and Training
services. These decisions should be made on a case by case basis.
Basic Career Services are available to everyone. Beyond that,
Individualized Career Services should be provided, if determined appropriate, in
order for an individual to obtain or retain self-sufficient employment.
Training services can be provided if it is determined, based upon an assessment
and individual employment plan, the individual is unlikely or unable to obtain
or retain employment that leads to economic self-sufficiency or wages
comparable to or higher than wages from previous employment. If an
individual intends to return to his or her former employment when called back,
then Individualized Career Services or short-term Training Services may be
appropriate. If an individual intends to change career paths, then
consideration should be given to all available training programs as
We have an employer who is requesting a COVID test for a client we are placing in a work experience. How do we handle this? Reimbursement only? A voucher of some sort if the client cannot pay? Other? Thank you.
LWIAs that place
participants into a work-based learning work-site should follow local fiscal
procedures in paying for a COVID test (similar to other “pre-employment”
requirements such as a drug test). In many instances a reimbursement of
reasonable costs would be appropriate if a free testing option is not available.
It is advisable for the customer and case manager to research free COVID
testing options that are available throughout the region before scheduling a
What other documentation is allowable besides a Social Security Card to verify SSN? Would we be able to use an IBIS or Public Benefit system printout showing SSN if the person provided their SSN verbally and sent in a copy of a valid government ID?
For acceptable documentation to support the actual Social Security Number, there are 3 options:
- Social Security Card (must be signed)
- Social Security Administration Printout (with full Social Security Number)
- Any Social Security Administration Document Showing Full Social Security Number
In regards to the 2nd and 3rd choices, the Social Security Administration (SSA) has an instant online verification where the documentation can be attained by the user creating a "my" Social Security Account or calling SSA to obtain a verification letter.
SSA website provides steps to apply for a replacement card online.
- Log into your my Social Security account.
- Navigate to the "My Home" tab and then to the "Overview" tab. On the right side of the page:
- Click the link: "Replacement Documents",
- Click the link: "Request a Replacement Card",
- Answer the screening questions to confirm eligibility; and
- Enter personal information such as name, Social Security number, address, and state driver's license or ID information.
Will LWIAs be able to use the basic skills eligibility tool past June 30, 2020?
Yes. Notice 19-NOT-01, Change 1 will be released to announce the Test for Adult Basic Education (TABE) 11&12 and Comprehensive Adult Student Assessment Systems (CASAS) GOALS are the approved assessments for Fiscal Year (FY) 2021 for English Speaking Individuals. Additionally, since the ability to conduct/proctor assessment tests are still limited at this time due to COVID-19, the option for Career Planners to use the 'Can't Complete Test' is being extended to September 30, 2020.
WIOA Program Management Q1: Should I consider closing a workforce center’s resource room to the public?
Local one‐stop operators and administrators should follow the guidance issued by the local and state public health officials as it relates to social gatherings. Depending on the facility lease holder, there may be additional implications. Appointments with career planner staff should be conducted by telephone, Skype, etc. to the extent possible. Additional information is available at
IDPH Business and Organization Guidance.
WIOA Program Management Q10: Some workforce areas have special training grants that are due to be expended by the end of March or June. Due to the possible delay of training, can these grants be extended?
The DCEO grant managers will work with the local workforce areas and other grantees on a case‐by‐case basis to review each modification request. It is anticipated that reasonable modification requests will be approved as long as DCEO has the expenditure authority.
WIOA Program Management Q11: Performance measures could greatly be impacted such as the entered employment rate at the 2nd and 4th quarter, wages earned at six months, credential attainments, obtaining measurable skills gains.
At this time the Department does not have the authority to relax this requirement. The Department will continue to monitor developments and will remain in contact with the US Department of Labor to identify additional guidance.
WIOA Program Management Q12: Do WIOA case managers need to enroll clients in remote or distance learning due to their programs being moved to all online?
The only place that captures the mechanism for provision of training is in the Eligible Training Providers (ETP) reporting where a provider must choose - on-line learning, classroom, or both. Because it would be very laborious to update this question for the length of time the providers have changed mechanisms due to the COVID-19 pandemic and then change it back once on-site classes resume, the state is going to ask for guidance from DOL which could include a "hold-harmless" on this provision during the pandemic. Continue to record the services as it is traditionally recorded. When OET receives any guidance from DOL whether it be in the form of a Q&A or an email, we will notify the field collectively.
WIOA Program Management Q13: With the school closures participants requesting we purchase computers to allow for continued training participation, when the training institution has not provided any documentation stating a computer is required for program.
If the training institution is now requiring that students take courses online and the participant does not have the equipment needed to continue their classes, then it IS a requirement, and that cost should be covered accordingly. As ever, this is not an open authorization for participants to request elaborate equipment, and steps should be taken to set parameters around the reasonable cost of purchasing the computer. USDOL does not support a specific device or operating system. The case manager should note this change in the participants Individual Employment Plan or Individual Service Strategy
WIOA Program Management Q14: With the school closures many training programs have moved to an on-line training environment. Is the cost of internet service an allowable WIOA cost?
No. The cost of internet service is considered a utility and WIOA training funds are not allowed to pay for this cost. Case managers are encouraged to direct participants to local companies that provide assistance for low-income residents in accessing the internet. Please see:
Your Guide to Internet Service During COVID-19 Outbreak.
UPDATED 8-25-20: Per the USDOL COVID-19 FAQs, WIOA funds can be used to pay for devices and broadband internet service that will allow a participant to create or maintain a wireless connection for distance learning, searching for jobs, and other employment and training services where such services are already allowable. Grant recipients are expected to use sound fiscal prudence to maximize value for each taxpayer dollar spent by reaching as many participants as possible while also considering the cost and length of time remaining in the period of performance.
- In Illinois, the cost of providing broadband service for a participant can be an allowable cost if it is allowed by the local training and supportive service policies. Local policy should direct case managers to analyze and ensure that the costs are reasonable and necessary.
- Case managers should also work with the customer to identify the most cost-effective method of obtaining the internet service. For example: case managers direct participants to local companies that provide assistance for low-income residents in accessing the internet. Please see: Your Guide to Internet Service During COVID-19 Outbreak.
WIOA Program Management Q15: Do local areas have to do TABE testing during the COVID-19 pandemic given that tests have to be proctored?
In Illinois, the state has aligned with the Title II Illinois Adult Education Assessment policy when determining the basic skills levels of customers for enrollment. This includes the requirement that local areas use the Test of Adult Basic Education (TABE) test for assessment purposes so that customers aren’t unnecessarily having to complete multiple assessments to achieve the same purpose. Additionally, aligning Title I and Title II policy ensures a coordinated approach to services for WIOA customers. At this time due to the COVID-19 pandemic, all testing with the TABE has been temporarily suspended by Adult Education. Our WIOA Title II partners have reached out to the test publishers to get direction and determine if they have any strategies for remote assessment.
As a reminder WIOA prescribes a holistic, on-going assessment process for customers rather than just a one-time event. This comprehensive and objective assessment process should use a variety of mechanisms to evaluate and identify the employment goals, appropriate achievement objectives, and the needed combination of services to address barriers. Multiple assessment tools may be necessary since there is no standard approach that will work for all customers. The TABE test is only one mechanism to assess a customer.
During intake, there must be an assessment for determining a customer’s basic skills. In assessing basic skills, local programs must use assessment instruments that are valid and appropriate for the target population and must provide reasonable accommodation in the assessment process, if necessary, for individuals with disabilities. A Basic Skills Screening Tool has been developed and will be disseminated via a WIOA Notice. The Tool must be used, as appropriate, along with other assessments that determine vocational skills, etc. and is to be used for referral purposes.
For Adults, this tool not only determines potential basic skills deficiency but also is used to identify priority of service. This alleviates customers from having to take a TABE test solely to determine basic skills deficiency and to identify priority of service. As mentioned above, the assessment given to determine reading, math, or language levels is not enough for qualifying placements into vocational or technical skills training and other factors acquired from a full assessment of the customer such as suitability of the training program must be considered.
The Tool will be incorporated into the Illinois Workforce Development System (IWDS) at a future date. Until that time, use the form found in Attachment A to the Notice. This form must be kept in the customer’s file and noted in the case notes and IEP/ISS (career plan) as applicable. The IWDS has not been changed to allow for only a TABE Reading assessment TABE-R (Reading) to be entered. Until then, both a Reading and Math entry must be made in the system.
Any assessment given must be recorded in the Test screens of IWDS. Upon completion of the assessment(s), identified needs must be documented in an Individual Employment Plan (IEP) or in the instance of Youth an Individual Service Strategy (ISS). The Career Planner and the customer must jointly develop the plan and select the services that will best enable the individual to seek and retain self-sufficient employment. Like the assessment, the IEP or the ISS is an on-going process and requires routine updates, particularly as additional needs, are identified or goals achieved. Since the internal logic of IWDS requires a Math and Reading assessment test, career planners must use the ‘Can't Complete Test’ option in the Test drop-down on the Add a Test screen for both Reading and Math and enter “Unable to Conduct/Proctor Test Due to COVID-19” in the Comments boxes in IWDS during this timeframe. When ‘Can’t Complete Test’ is selected, the Grade Level Equivalency (GLE) needs to be recorded as “99” for both Reading and Math.
Note that this will limit the ability for a customer to receive a measurable skill gain via an increase in Educational Functioning Level (EFL) and the measure will need to be obtained in another fashion. See TEGL 10-16 Performance Accountability Guidance for Workforce Innovation
and Opportunity Act (WIOA) Title I, Title II, Title III and Title IV Core
Programs and TEGL 14-18 Aligning Performance Accountability Reporting,
Definitions, and Policies Across Workforce Employment and Training Programs
Administered by the U.S. Department of Labor (DOL).
WIOA Program Management Q16: Can the State waive the requirement for TABE for youth just entering work-based learning?
No. Section 681.290 of the WIOA Final Rule provides states with the authority to develop policy on section (b) of the Basic Skills Deficient definition, therefore, with supporting documentation policy will provide exceptions for Adults or Dislocated Workers who are entering only WIOA On-the-Job Training, Paid Work Experience or Customized Training. Since the WIOA youth program design requires an objective assessment of academic levels, skill levels, and service needs of each participant, which includes a review of basic skills, occupational skills, prior work experience, employability, interests, aptitudes, supportive service needs, and developmental needs, an assessment for basic skills such as TABE cannot be waived. However, due to the limitations of conducting proctored TABE tests during the COVID-19 crisis, career planners are to follow the guidance on that subject provided in this Q&A document. TEGL 21-16 provides further guidance on assessments in the youth program particularly for providing reasonable accommodation for individuals with disabilities.
WIOA Program Management Q17:Can the State waive the requirement for TABE for individuals with disabilities?
For individuals with disabilities the basic skills assessment portion of the objective assessment need not be approved for use in the Department of Education’s National Reporting System (NRS), nor are they required to determine an individual’s grade level equivalent or educational functioning level (EFL). Rather, local programs may use other formalized testing instruments designed to measure skills-related gains. In addition, for youth with disabilities skills related gains may also be determined through less formal alternative assessment techniques such as observation, folder reviews, or interviews. Local programs may use previous basic skills assessment results if such previous assessments have been conducted within the past six months.
WIOA Program Management Q18: Will case managers have to go back and test participants once ICCB resumes testing or will those people be waived from this requirement?
The assumption is that the question is referring to the TABE test. Career planners will not need to go back and test customers using the TABE test if other mechanisms to evaluate a customers’ employment goals, appropriate achievement objectives, and the needed combination of services to address those barriers were used during the COVID-19 emergency. However, career planners should remember that customers will be unable to receive a measurable skill gain via an increase in Educational Functioning Level (EFL) and the measure will need to be obtained in another fashion. See TEGL 10-16 Performance Accountability Guidance for Workforce Innovation and Opportunity Act (WIOA) Title I, Title II, Title III and Title IV Core Programs and TEGL 14-18 Aligning Performance Accountability Reporting, Definitions, and Policies Across Workforce Employment and Training Programs Administered by the U.S. Department of Labor (DOL).
WIOA Program Management Q19: Can WIOA Adult funds be used to support layoff aversion activities?
A state may use up to 25% of their Dislocated Worker allotment to provide Rapid Response activities, which can be used for layoff aversion activities. States may also leverage the Governor's Reserve to conduct additional rapid response activities. At the local level, Boards may use up to 20% of their combined adult and dislocated worker funds to provide incumbent worker training, which can be used for layoff aversion. ETA will consider waivers of this 20% cap as needed. Individuals involved in layoff aversion activities who meet program eligibility requirements may be served by the Adult and Dislocated Worker programs. States may approve transfers of up to 100% of adult and dislocated worker funds.
WIOA Program Management Q2: How should the local workforce area handle Rapid Response?
The WIOA requires the provision of on‐site Rapid Response services. The state and local rapid
response team should work with the impacted companies to explore the options of providing
the information remotely via technology. If a technology solution is not available, state and
local teams are advised to follow the guidance of state and local public health officials regarding
the steps that can be taken to minimize the risk to the impacted workers and rapid response
team including the screening of participants / presenters and meeting with smaller groups of
workers rather than a large workshop of more than 10‐15 people.
3‐20‐20 UPDATE FROM USDOL: States should continue to provide Rapid Response information to affected employees. States have flexibility in whether to provide this in‐person or through other means. States should consult CDC guidance and local government directives on large gatherings.
WIOA Program Management Q20: Can On-The-Job Training (OJT) funds be used for layoff aversion activities for current workers in the same company?
Employed workers may be eligible for WIOA-funded OJT if the requirements of 20 CFR 680.710 are met. Additionally, rapid response or statewide WIOA funds may be used for layoff aversion activities including incumbent worker training. See TEGL 19-16, Section 18 for current flexibilities related to rapid response activities. States and local areas may also utilize incumbent worker training for layoff aversion activities as discussed in TEGL 19-16 Section 13.
WIOA Program Management Q21 NEW: Will the LWIAs be required to expend 75% or 50% of the WIOA Youth funds on Out of School Youth for Program Year 2020?
The State of Illinois' waiver that allows the State and LWIAs to expend 50% of the WIOA Youth funds on Out of School Youth fund expires with the current Unified State Plan on June 30, 2020. The State has included this waiver request with the submission of the 2020 Unified State Plan that will take effect on July, 1, 2020. If the waiver is approved, LWIAs will continue to be required to expend at least 50% of the WIOA Youth funds on Out of School Youth.
WIOA Program Management Q3: There has been a significant increase in the number of customers requesting information about Unemployment Insurance. How do I find the latest information?
The Illinois Department of Employment Security’s website has posted specific information including a “Q and A” that provides information regarding unemployment insurance for individuals impacted by a business closure as a result of the COVID‐19 response. Visit the IDES COVID-19 FAQ page. Individuals are encouraged to file on‐line. There is also a 1‐800 number available; however, there may be increased “wait” times because of the increased call volume.
WIOA Program Management Q4 - Will there be repercussions to LWIAs if in-person career services are suspended such as on‐site workshops, job fairs and eligibility determination?
The career services that must be made available are outlined in WIOA Section 134(b)(2) and in TEGL 19-16. At this time the Department does not have the authority to relax this requirement. It should be noted that local workforce areas can make the career services available using on‐demand technology. As for on‐site workshops and job fairs, LWIAs are directed to follow the guidance issued by the Illinois Department of Public Health as it relates to social gatherings. Depending on the facility lease holder, there may be additional implications.
Appointments with career planner staff should be conducted by telephone, Skype, etc. to the extent possible. Additional information is available at
IDPH COVID Business and Organization Guidance. The Department will continue to monitor developments and will remain in contact with the US Department of Labor to identify additional guidance.
WIOA Program Management Q5 NEW: What are the case management and follow up requirements during the COVID‐19 national emergency?
Follow‐up services is one of the required 14 program elements to be made available for Youth and is outlined in WIOA Section 129(c)(2) and in TEGL 21‐16. Career planners are responsible for conducting follow‐up services to participants to determine if they need additional services to be successful. The OET recommends two‐way communication be made every 30 days for the first 3 months of employment for Adults and Dislocated Workers or exit for Youth, but at a minimum at least once a quarter. Services may be offered as often as necessary throughout the 12 months, but at a minimum of once each quarter for the next 3 quarters. This aligns with quarterly post‐exit reporting requirements. Communication between the career planner and the participant can be conducted by telephone, Skype, etc. At this time the Department does not have the authority to relax this requirement. The Department will continue to monitor developments and will remain in contact with the US Department of Labor to identify additional guidance. LWIAs may record a "Holding" service which allows a customer to be held without receiving training or services if his other program is interrupted due to illness or other unforeseen circumstances and during normal breaks in the academic or vocational training schedule. LWIAs should continue to Exit customers (in IWDS) who have not received a service in 90 days to remain in compliance with the current Exit Policy, Chapter 3. Section 3, General Requirements for Program Exit, and DOL/ETA TEGL 10-16 Change 1.
WIOA Program Management Q6: Are digital signatures allowed?
Yes, it is allowable and acceptable for digital signatures to be used so long as the LWIA or grantee follows the requirements of the Uniform Administrative Guidance. Additionally, per DCEO’s Legal Department digital signatures are allowed as long as it is the actual electronic signature and not something that was “auto generated” from an electronic system (for example – using the “script” font in Microsoft Word). Therefore, “signing pads” which would allow a participant to sign their name on a pad and it writes their signature on the application on the computer as a pdf document so that it cannot be altered would meet the requirements of the Uniform Administrative Guidance (see 2 C.F.R§200.335 Methods for Collection, Transmission and Storage of Information.)
WIOA Program Management Q7: What tools are least expensive most frequently used when documents require (electronic signautres) E signatures from clients and training provivers?
The Department is working with the US Department of Labor to respond to this question. Additional information will be provided as soon as it is available.
WIOA Program Management Q8: What will DCEO accept in lieu of actual customer signatures on new WIOA applications during this time?
The Department is working with the US Department of Labor to respond to this question. Additional information will be provided as soon as it is available.
WIOA Program Management Q9: Is there a way that customers could upload information directly into IWDS?
IWDS currently allows case managers to upload documents into the system. The Trade Program requires documents to be uploaded to IWDS as part of the State Merit Staff approval process. This feature can also be used for WIOA customers. At this time customers do not have access to the customer screens in IWDS. DCEO is working to identify document management options and possible workflows for case managers that are working remotely.