NIWA (Local) POLICIES REGARDING WIA TITLE I-B … update... · NIWA (Local) POLICIES REGARDING ....

55
1 Northern Illinois Workforce Alliance (NIWA) Workforce Investment Board for Boone, Winnebago, and Stephenson Counties NIWA (Local) POLICIES REGARDING WIA TITLE I-B SERVICES/ACTIVITIES TRADE SERVICES/ACTIVITIES ACCELERATED TRAINING IN MANUFACTURING (ATIM) SERVICES Intensive Services Policies................................................................................................................ 2 Provider Certification and Individual Training Account (ITA) Policies .......................................... 3 On the Job Training (OJT) Program Policies ................................................................................. 10 Work Experience Policies ............................................................................................................... 14 On-Going Supportive Services Policies.......................................................................................... 15 Supplemental Supportive Services Policies .................................................................................... 19 Self-Sufficiency Definitions for Adults and Dislocated Workers .................................................. 21 Adult Service Priority System Policy ............................................................................................. 22 Definitions Relating to Youth Eligibility Requirements ................................................................ 23 Needs Related Payments Policy...................................................................................................... 25 Incumbent Worker Training Policy ................................................................................................ 32 Youth Follow-Up Policy ................................................................................................................. 37 Selective Service Policy.................................................................................................................. 38 Policy on Medical Data and Information Collection and Maintenance .......................................... 43 Policy on Handling and Protection of Personally Identifiable Information (PII) .......................... 45 Allowable Trade Training-Related Expenses Policy ...................................................................... 49 ATIM Transportation Assistance Policy ........................................................................................ 52 ATIM Adult Service Priority System for Enrollment of Individuals Not Meeting Low-Income Guidelines ....................................................................................................................................... 54 Updated: 4/7/15 Posted on WIB Website: 4/9/15 With the April 2013 expansion of the Workforce Investment Area to include Stephenson County, the WIB’s name changed from Boone and Winnebago Counties Workforce Investment Board to the Northern Illinois Workforce Alliance. The Boone and Winnebago Counties WIB Policies for WIA Title I-B of WIA became the Northern Illinois Workforce Alliance’s Policies. The Programmatic Committee’s name was changed to Program Oversight Committee in July 2003. In November 2010 the Program Oversight Committee was dissolved and the responsibilities transferred to the newly formed Service Delivery Committee. In these WIB Policies references to the Programmatic Committee and Program Oversight Committee have been changed to Service Delivery Committee except in instances when the Committee’s specific action on an item is given.

Transcript of NIWA (Local) POLICIES REGARDING WIA TITLE I-B … update... · NIWA (Local) POLICIES REGARDING ....

1

Northern Illinois Workforce Alliance (NIWA) Workforce Investment Board for Boone, Winnebago, and Stephenson Counties

NIWA (Local) POLICIES

REGARDING WIA TITLE I-B SERVICES/ACTIVITIES

TRADE SERVICES/ACTIVITIES ACCELERATED TRAINING IN MANUFACTURING (ATIM) SERVICES

Intensive Services Policies ................................................................................................................ 2 Provider Certification and Individual Training Account (ITA) Policies .......................................... 3 On the Job Training (OJT) Program Policies ................................................................................. 10 Work Experience Policies ............................................................................................................... 14 On-Going Supportive Services Policies .......................................................................................... 15 Supplemental Supportive Services Policies .................................................................................... 19 Self-Sufficiency Definitions for Adults and Dislocated Workers .................................................. 21 Adult Service Priority System Policy ............................................................................................. 22 Definitions Relating to Youth Eligibility Requirements ................................................................ 23 Needs Related Payments Policy...................................................................................................... 25 Incumbent Worker Training Policy ................................................................................................ 32 Youth Follow-Up Policy ................................................................................................................. 37 Selective Service Policy .................................................................................................................. 38 Policy on Medical Data and Information Collection and Maintenance .......................................... 43 Policy on Handling and Protection of Personally Identifiable Information (PII) .......................... 45 Allowable Trade Training-Related Expenses Policy ...................................................................... 49 ATIM Transportation Assistance Policy ........................................................................................ 52 ATIM Adult Service Priority System for Enrollment of Individuals Not Meeting Low-Income Guidelines ....................................................................................................................................... 54 Updated: 4/7/15 Posted on WIB Website: 4/9/15 With the April 2013 expansion of the Workforce Investment Area to include Stephenson County, the WIB’s name changed from Boone and Winnebago Counties Workforce Investment Board to the Northern Illinois Workforce Alliance. The Boone and Winnebago Counties WIB Policies for WIA Title I-B of WIA became the Northern Illinois Workforce Alliance’s Policies. The Programmatic Committee’s name was changed to Program Oversight Committee in July 2003. In November 2010 the Program Oversight Committee was dissolved and the responsibilities transferred to the newly formed Service Delivery Committee. In these WIB Policies references to the Programmatic Committee and Program Oversight Committee have been changed to Service Delivery Committee except in instances when the Committee’s specific action on an item is given.

Northern Illinois Workforce Alliance ITA Policies

2

Northern Illinois Workforce Alliance

INTENSIVE SERVICES POLICIES Items 1-5 adopted by the LWIB 1/9/01

Item 6 adopted by the LWIB 3/6/01 Item 6 date of reconsideration by LWIB Programmatic Committee--

modified by Programmatic Committee 2/14/02, 9/19/02 Items 6 removed by WIB and Item 5 modified by WIB 8/4/09

Committee name updated 12/15/10. The Intensive Services Policies also included in the ITA Policies.

ITA programs changed to Eligible Training programs—modified 6/5/12 Clarification on Basic Skills, GED, and ESL Classes – modified 2/3/2015

Participants who are determined to be in need of pre-vocational services in order to obtain or retain employment that leads to self-sufficiency may be enrolled in individual credit or non-credit courses that do not lead to certification; these courses will be classified as Intensive Services.

1. Courses must be directed toward growth occupational employment; job readiness;

or literacy activities related to basic work readiness (i.e. basic academic skills upgrading, GED preparation, English Second Language classes);

2. Courses must be specifically approved by the LWIB (initially approved by Service

Delivery Committee) as Intensive Services or be included in an ITA program certified by an LWIB;

3. Individuals must be unable to obtain other funding sources to cover the cost to the

Intensive Services courses; 4. Courses that are prerequisites for certified Eligible Training programs but are not

listed in the certified program’s course requirements will be automatically classified as Intensive Services.

5. In all cases, a participant’s Individual Employment Plan (IEP) must include a

detailed career plan that shows how the Intensive Services course(s) the participant will take will enhance his/her ability to be employed/reemployed. The career plan must be based on an assessment of the participant’s skills and abilities.

GED Preparation as an Intensive Service: Program participants without a High School Diploma shall be encouraged to pursue attainment of a GED as appropriate to achieve training and employment goals. Adult Basic Education classes and GED preparation classes are available in the community for no cost. For cost classes are also available, and use of program funding is allowable for this activity if community classes do not meet the individual needs. GED Testing and Related Fees – WIA program funds can be used to pay for practice-GED tests and GED tests. Practice-tests are encouraged to minimize chances for failing individual GED tests. Re-tests may be paid for at the discretion of the Program Director (Adult and Dislocated Worker) in consultation with the GED preparation provider; however a practice-test is required prior to the re-test. Documentation of GED attainment will be maintained in the participant file.

Northern Illinois Workforce Alliance ITA Policies

3

Northern Illinois Workforce Alliance PROVIDER CERTIFICATION POLICIES

and INDIVIDUAL TRAINING ACCOUNT (ITA) POLICIES

Adopted 10/3/00

ITA Policy 8.a. Appeals Process--Adopted 1/9/01 Policy Regarding Individual Courses Submitted for WIA Funding--Adopted 1/9/01

Amendment to Item 6. of Policy Regarding Individual Courses Submitted for WIA Funding-- Adopted 3/6/01

ITA Cap Policy–Adopted 7/3/01 Modification to Provider Certification Policies, Item 2. – Adopted 5/7/02

ITA Cap Policy Modified–10/7/03 Amendment to II.2, policy regarding the application of financial aid—Adopted 8/2/05

Provider Certification Item 3, Appeals Process for Programs Denied Certification/Recertification—Adopted 12/6/05 Amendment to II. 6. regarding development of training plan—Adopted 2/7/06

Amendment to II.10. regarding cap for TAA participants—Adopted 2/7/06 Addition of II.11.—Adopted 2/7/06

Modification to Item 10—Cap increased to $6,000—Adopted 11/6/07 Addition to Item 10 regarding criteria for enrollment in ITAs, re-enrollment, and appeals—Adopted 11/6/07

Modification to Item 10—Cap increased to $10,000—Adopted 9/1/09 Modification to Item II.2. –Grant assistance replaces words financial aid; other education-related expenses replaces

word fees—Adopted 2/2/10 Committee name updated 12/15/10; other updates made to comply with DCEO Policy Letter No. 09-PL-57 Change 1. Revisions made to the following items: 2, 6, 8, 10, 11; the $10,000 Training Cap definition of items included in the cap has been expanded; GED

or high school diploma is now a prerequisite for occupational training; two-year time limit on Training has been replaced with “reasonable timeframe, preferable within two years”; other information related to these adjustments has been revised.—Adopted 6/5/12

Addition to II.10-- Credentialing exam fees and license fees –Adopted 2/5/13 Modification to Addition II.10 – adopted by WIB 11/6/07, 1 – diploma/GED

requirement exception – Adopted 10/3/14

Preliminary Note: Under the Workforce Investment Act, tuition-based training for participants will be conducted under Individual Training Accounts (ITAs) with training providers that are certified by local Workforce Investment Boards (WIBs). The provider certification process “is intended to ensure that a minimum standard of quality has been met by providers that want to offer programs to Title I WIA-eligible individuals” (from State of Illinois Training Provider Certification Policy for Initial Eligibility). All programs certified by local Workforce Investment Boards are placed on a statewide list of certified training programs. This statewide list of WIA certified training programs is available at www.iwds.state.il.us. Using an ITA, “WIA Title I adult and dislocated workers purchase training services from eligible providers they select in consultation with the case manager. Payment from ITAs may be made in a variety of ways, including electronic transfer of funds through financial institutions, vouchers, or other appropriate methods” (final Federal Regulations, § 663.410). From the statewide list of certified training programs and after consultation with a case manager, participants may select any program that addresses their training needs. They will be required to adhere to local WIB ITA policies. To be eligible for an ITA, a participant must:

• Have not been able to become employed or retain employment through Intensive Services; • Must have a high school diploma or GED (added 6/5/12); unless the program of study

does not require a high school diploma and results in an industry recognized credential (i.e. truck driving CDL) or the individual is concurrently enrolled and attending a GED program (modified 10/3/14);

Northern Illinois Workforce Alliance ITA Policies

4

• Have the skills and qualifications to successfully participate in the selected training program (as determined by one-stop operator after participant interview, assessment or evaluation, and case management);

• Select a program directly linked to employment opportunities in the local area or another area to which the individual is willing to relocate;

• Be unable to obtain grant assistance (Pell or other forms of financial aid); or requires assistance beyond the assistance made available under grant assistance programs (including Pell) and other applicable forms of financial aid at the federal, state, or local level.

The Northern Illinois Workforce Alliance Provider Certification and ITA Policies follow. The Internal ITA Procedures follow the ITA Policies. I. PROVIDER CERTIFICATION POLICIES

1. Programs approved in WIA 3 for funding must train for one or more occupations listed on the

DCEO-issued Demand Occupations Lists for Economic Development Regions 4 or 5 referenced in WIA Policy Letter No. 09-PL-57 and subsequent changes to the policy.

2. The Northern Illinois Workforce Alliance (LWIB) gives the Service Delivery Committee the

authority to initially certify/recertify training programs that meet the criteria in 1 above. A sub-committee of the Service Delivery Committee, meeting the minimum requirements identified in WIA Policy Letter No. 09-PL-57, reviews data related to Eligible Training Provider program submissions and recommends approval to the Service Delivery Committee. (Then the LWIB, at its next meeting, will act on the program certification recommendations of the Service Delivery Committee.)

3. Provider’s Request for Reconsideration of Program(s) Denied Certification as Individual Training

Account (ITA) Program(s)—Appeals Process for Programs Denied Certification/Recertification (adopted 12/6/05)

a. The Northern Illinois Workforce Alliance (WIB) has the right to deny a Provider certification for a training program(s) during both the initial and subsequent phases of the certification process.

b. A Provider whose program(s) was/were rejected will be notified of its program’s(s’)

rejection, the reason for the rejection, and the appeals process (Provider’s Request for Reconsideration of Program Denied Certification as an ITA Program) via e-mail or letter within five days of the rejection if the provider was not in attendance at the Service Delivery Committee meeting at which its program(s) was/were presented for approval. (The reasons for a program’s rejection will be discussed during the meeting at which the program is rejected and the Provider, if present at the meeting, will be given a copy of the appeals process.)

c. A Provider that applied for certification of a training program(s) and has been denied

certification has a right to file an appeal with the WIB’s Executive Director. This appeal must be presented via letter or e-mail within 21 calendar days of the date the program was denied approval.

Northern Illinois Workforce Alliance ITA Policies

5

d. The appeal will then be reviewed by the Service Delivery Committee within 21 days of the WIB Executive Director’s receipt of the appeal. The appealing Provider may address the Committee at the time the appeal is considered.

e. The Service Delivery Committee will either accept or reject the Provider’s appeal.

f. The Provider will be notified via e-mail or letter of the Service Delivery Committee’s

decision regarding the appeal.

g. A Provider that has appealed to the Service Delivery Committee and has had its appeal denied, may file a second appeal with the WIB’s Executive Director. This second appeal must be presented via letter or e-mail within 21 calendar days of the date the program was denied for the second time.

h. This second appeal will be reviewed by the WIB’s Executive Committee within 21 days of

the WIB Executive Director’s receipt of the appeal. The appealing Provider may address the Committee at the time its second appeal is considered.

i. The WIB’s Executive Committee’s decision regarding the appeal will be final. j. If the Program Provider’s appeal is denied by the WIB’s Executive Committee, the

Provider may, in accordance with the State’s WIA Training Provider Certification Policy (, WIA Policy Letter No. 09-PL-57, Change 1, reapply to have its program(s) certified/recertified not less than one year from the date of the denial of program certification.

II. INDIVIDUAL TRAINING ACCOUNT (ITA) POLICIES 1. ITAs will be used only for funding vocational (occupational skills) training programs. 2. All participants must apply for Pell and any other appropriate grant assistance, and provide proof

of application for this aid. The Pell grant funding received by a participant must be applied toward the participant’s tuition and other education-related expenses. If funding is required beyond available grant funds (i.e., PELL grants, WIA funds, etc.), participants are required to arrange other means of financial aid, such as loans; or they have the option of choosing a less expensive training program.

3. For approved programs, WIA will also pay the reasonable cost of participants’ required books and

special supplies, including uniforms and tools. 4. Supportive Services for participants in ITA training will be determined on an individual basis and

based on participants’ needs. 5. Supportive Services (e.g., transportation, child care, emergency housing) will not be available to

participants choosing to attend ITA-approved programs beyond 100 miles from their homes. (This policy does not apply to TAA participants.)

6. The participant and his/her WIA counselor must jointly develop a plan for a participant to

complete the training (including pre-requisite courses) within a reasonable timeframe, preferably within two years.

Northern Illinois Workforce Alliance ITA Policies

6

7. Participants must complete three core services and at least one intensive service activity (such as a workshop, class, etc.), as well as meet the ITA eligibility criteria, before receiving an ITA.

8. To continue to receive ITA funding, participants must:

a. Maintain an overall C or equivalent average; b. Bring/send their grade or progress records to their WIA Case Manager prior to the start of

a new semester/quarter to prove they maintained a C or equivalent average; and c. Report their progress in training to their WIA Case Manager at least once each month.

9. WIA Title I-B funds may not be used for participants to retake classes. 10. Revised 6/5/12: A per participant Individual Training Account cap of $10,000 applies to the total

Training and Training-related costs for approved Eligible Training programs, pre-requisite courses, and other courses (excluding Basic Skills Upgrading/GED Preparation course, English as a Second Language upgrading courses, Employment Transitions course, and transportation/child care costs). The Training and Training-related costs covered under the $10,000 Individual Training Account cap include:

• Tuition • Fees • Books • Supplies • Tools • Uniforms • Anything necessary for the training that is on the class syllabus • Credentialing exam fees and license fees (approved 2/5/13)

No exceptions to the $10,000 ITA cap policy will be granted.

Addition to Item 10 adopted by the WIB 2/7/06: If an individual is TAA eligible and must begin or continue training under WIA funding because TAA funds have been exhausted or are not available, the amount of ITA training assistance that the participant receives under WIA 1D or 1S/1E may exceed the $10,000 cap. [9/1/09: Cap increased to $10,000.] ITA training for WIA/TAA participants will be paid from WIA funds only in instances when TAA funds are exhausted or unavailable. (This addition to the ITA Policy is retroactive to July 1, 2005.) Addition to Item 10 adopted by WIB 11/6/07: Initial Enrollment in ITA Training An in-depth assessment of an individual participant’s training needs must be made to determine what is best for the participant and best for the overall program. The filters that will be applied during the individual’s assessment and program selection process include the following: 1. The individual has a high school diploma or GED (added 6/5/12); unless the program of

study does not require a high school diploma and results in an industry recognized credential (i.e. truck driving CDL) or the individual is concurrently enrolled and attending a GED program (modified 10/3/14);

Northern Illinois Workforce Alliance ITA Policies

7

2. The individual is in need of training; 3. The individual has the skills and qualifications to complete successfully the selected

training program; 4. The individual is unable to obtain grant assistance from other sources to pay the costs of

selected training; 5. The selected training program is directly linked to employment opportunities in the area

(or another area to which the individual is willing to relocate); 6. Training will lead to the individual’s self-sufficiency. Re-enrollment in ITA Training If a program participant has received funding under an ITA previously, re-enrollment will be

considered only if: • The completion of the previous training program occurred at least 24 months prior to the

re-enrollment date; and • The credential received from the previous training program is no longer in demand based

upon industry and labor market data for the northern Illinois region. All decisions to re-enroll participants into additional ITA funded training, even after the 24 month wait period, must have program’s director approval and such approval must be documented in the participant’s case file.

Participants’ Appeal Process Participants may appeal the training decisions of counseling staff directly to the administrator of the Adult Program or Dislocated Worker Program. Participants may appeal the decisions of the Adult Program or Dislocated Worker Program’s administrator to the WIB’s Service Delivery Committee. The Committee will then uphold the administrator’s decision or render a new decision. The decision of the Committee is final.

11. The following policy applies to youth who are in a subcontracted youth program, have earned a high-school diploma or GED, and are subsequently enrolled in an approved ITA program: The Program Provider is responsible for counseling of their program youth before, during and after their participation in an eligible training program to assist participants in problem solving, making informed decisions regarding class selection, and employment search options and opportunities and for providing a year of follow-up with these youth after they exit WIA (adopted 2/7/06 and modified 6/5/12).

Appeals Process for Policy 8.a., “Maintain an overall C or equivalent average”

A participant may request a review of special circumstances(s) affecting the first semester/quarter

grades by: • Submitting a written request for review of the special circumstances affecting

grades and class standing to the program’s supervisor. The written request will summarize the “special circumstances” why the appeal is sought.

• Submitting the request within one week of receipt of grades and prior to the start of the next semester.

• Submitting proof of attendance in all classes.

Northern Illinois Workforce Alliance ITA Policies

8

The supervisor and participant’s counselor/case manager will review the appeal and schedule a meeting with the participant.

If, after the meeting with the participant, the supervisor determines the appeal is valid, he(she) may waive the policy for the participant. The waiver must be signed by the Supervisor and the participant.

POLICY REGARDING INDIVIDUAL COURSES SUBMITTED FOR WIA FUNDING

[These are the Intensive Services Policies effective 8/4/09.] Participants who are determined to be in need of short-term pre-vocational services in order to obtain or retain employment that leads to self-sufficiency may be enrolled in individual credit or non-credit courses that do not lead to certification; these courses will be classified as Intensive Services. [Note: An R&R must have been distributed specifically listing the course as an Intensive Services course before a voucher is completed.]

1. Courses must be directed toward growth occupational employment; 3. Courses must be specifically approved by the LWIB (initially approved by the

Service Delivery Committee) as Intensive Services or be included in an ITA program certified by the LWIB (Service Delivery Committee);

3. Individuals must be unable to obtain other funding sources to cover the cost to the

Intensive Services courses; 5. Courses that are prerequisites for prerequisites for certified Eligible Training

programs but are not listed in the certified program’s course requirements will be automatically classified as Intensive Services.

5. In all cases, a participant’s Individual Employment Plan (IEP) must include a

detailed career plan that shows how the Intensive Services course(s) the participant will take will enhance his/her ability to be employed/reemployed. The career plan must be based on an assessment of the participant’s skills and abilities.

Northern Illinois Workforce Alliance ITA Policies

9

INTERNAL PROCEDURES RELATED TO INDIVIDUAL TRAINING ACCOUNTS

Participants may receive ITAs only for programs that are on the state-approved list.

1. RRTC (fiscal agent) must have a Master ITA-Vendor Agreement completed with the program provider before a participant may begin attending an approved program.

2. A Referral & Recruitment form listing the programs that WIB (RRTC fiscal agent) will

fund with the Vendor must be issued (posted on the WIB’s website) before vouchers may be issued for a participants’ enrollment in a program.

3. A RRTC Voucher will be used for tuition, fees, and books.

Northern Illinois Workforce Alliance OJT Policies

10

Northern Illinois Workforce Alliance ON-THE-JOB TRAINING (OJT) PROGRAM POLICIES

Adopted 11/7/00 Modified 12/3/00 and 1/9/01

Certificate finalized 4/01 Modified 8/3/04

Modified 5/4/10—former Item 2 removed; Wages item modified; OJT Policies renumbered Modified 11/5/13—OJT Policies, Item 7, first paragraph replaced; Item 11, first paragraph replaced

Introduction The Northern Illinois Workforce Alliance’s On-the-Job Training (OJT) Program helps area employers obtain reliable employees whom they hire under a Workforce Investment Act (WIA) OJT contract and then train for their specific needs. The Workforce Investment Act defines on-the-job training (OJT) as:

...training by an employer that is provided to a paid participant while engaged in productive work in a job that–

A. provides knowledge or skills essential to the full and adequate performance of the

job; B. provides reimbursement to the employer of up to 50 percent of the wage rate [now

waived for IL—reimbursement can be more—see item 11] for the extraordinary costs of providing the training and additional supervision related to the training; and

C. is limited in duration as appropriate to the occupation for which the participant is being trained, taking into account the content of the training, the prior work experience of the participant, and the service strategy of the participant, as appropriate.

WIA section 101(31)

On-the-Job Training (OJT) Program Policies 1. The employer can have no regular employee, currently on lay off from the same or similar

position, as the position for which OJT funding is being sought. 2. The LWIB reserves the right to deny future OJT contracts to employers who have not honored

previous OJT contract obligations. 3. Emphasis will be placed on OJT positions that provide identifiable and transferable skills that can

be used by the trainee on a long-term basis. 4. All OJT contracts must be approved by Rock River Training Corporation’s Executive Director,

who will submit an updated listing of OJT contracts written to the LWIB periodically. 5. Participant Eligibility: Individuals who are interested and in need of OJT will complete a

comprehensive assessment process which includes math and reading assessment and evaluation of their work history and job skills. An individual will be eligible for an OJT when the training eligibility requirements of the WIA are met.

6. Occupational Eligibility: WIA staff will seek and receive job orders for permanent occupations

from companies and businesses in both the public and private sector. OJT will be an allowable activity for quality occupations that, coupled with the participant’s capabilities, contribute to their:

Northern Illinois Workforce Alliance OJT Policies

11

a. economic self-sufficiency b. skill development c. occupational upward mobility d. permanent employment beyond the end of the OJT contract.

Occupations for which training will not be approved include, but are not limited too, the

following: a. intermittent or seasonal occupations b. occupations that have not traditionally required any specific occupational training c. occupations which require less than four weeks of training.

7. Contract Period:

The training program should generally no exceed a total of 1,040 full-time hours of actual training (the equivalent of full-time training for 6 months). a) The OJT training program should not be more than six (6) months in length as that indicates

there may be too large a gap in the customer’s skill(s) level and employer needs; 1) As a guide for determining the length of a training program, WIA staff will determine the

SOC Code for each OJT occupation. Each OJT occupation falls within a SOC Code which is assigned a Specific Vocational Preparation (SVP) level. The SVP levels represent the amount of training time required to be proficient in an occupation. (See attachment for further information.) WIA staff will only write OJT contracts for occupations which have a SVP level of 2 to 7—but training time will be limited to 6 months; therefore, participants placed in OJTs for which the training time is generally over 6 months must have an appropriate background that is applicable to the amount of training needed for the position for which they are being trained.

b) Training may exceed six (6) months if there are extenuating circumstances such as lengthy illness, plant shutdown, holidays, etc.; and

c) An employee in OJT may work overtime hours, but overtime hours are not eligible for reimbursement.

Individuals selected for an OJT contract will not be placed in an occupation in which they have had prior experience, unless some of the skills required are in a new area for which technology and skills have changed significantly enough to warrant additional training. In these cases, the OJT contract will result in a shorter training period because of the individual possessing some prior experience. This will be strictly an exception to the regular OJT placement procedure.

Reasonable tools, equipment, and clothing not provided by the employer on all OJT contracts may be provided by WIA funds, based on the participant’s need. If the trainee does not complete the OJT, the local WIA program will retain ownership of tools and/or equipment. A reasonable cost for required tools is a cost that does not exceed $300 per trainee.

8. Working Conditions: All OJT participants shall be subject to the same working conditions (i.e.,

benefits, bonuses, etc.) as other employees hired by the employer 9. Employees’ Wages: The minimum starting wage rate for all OJT employees shall be the

employer’s normal entry wage rate for the occupation for which they are being employed. 10. Collective Bargaining Agreements: As applicable, the employer will obtain the concurrence of the

collective bargaining representative regarding the on-the-job training position and the rate of pay for the position.

Northern Illinois Workforce Alliance OJT Policies

12

11. Reimbursement for Training: On-the Job Training is provided for a WIA customer in exchange

for a negotiated reimbursement of up to ninety percent (90%) of the wage rate to compensate for the employer’s extraordinary costs of training and additional supervision related to the training (WIA Section 101(31)(B) & CFR 663.700(a)).

1) The reimbursement rate shall be on a sliding scale based on the size of the business entering into the OJT contract. Under the current state waiver, the following reimbursement amounts will be permitted:

a) Up to ninety percent (90%) for employers with 50 or fewer employees, b) Up to seventy-five (75%) for employers with 51-250 employees c) Up to fifty percent (50%) for employers with more than 250 employees.

2) During negotiation of an OJT contract, the training costs of the employer should be estimated by the LWIA and used as a basis for negotiating the percentage of the wage to be reimbursed during the training period. However, employers are not required to document the extraordinary costs of training as OJT is implemented (20 CFR 663.710 (c).

3) The size of the business is determined by the location where the training will take place, or (in instances where training may occur offsite) the location to which the trainee reports.

4) When determining the negotiated reimbursement, the LWIA should consider the overall size of the company and its ability to pay for training without WIA support, the total available funds for OJT programs, the number of employers interested in OJT programs, and other factors in order to maximize the impact of OJT funds

On a monthly basis the employer must submit the following to Rock River Training Corporation: (a) invoice form, (b) payroll records showing the gross wages paid to the trainee, and (c) time records showing actual hours worked. RRTC will reimburse employers for the regular hours a trainee actually worked up to 40 hours per week.

12. Evaluation: After a participant has been active in an OJT contract position for approximately one

month, an evaluation will be completed by the employer to evaluate the participant’s performance and progress for that period of time. The OJT Employer Evaluation form will be kept in the contract monitoring file.

13. Monitoring: Monitoring of an OJT contract will be done on site by WIA staff at least once for a 1-

3 month contract or twice for a 4-6 month contract to determine the progress of the participant during that training period. The WIA staff will complete an OJT Monitoring Summary which will be kept in the contract monitoring file.

14. Corrective Action: If there are findings or problem areas identified during OJT monitoring,

corrective action will be recommended to the employer. A date will be agreed upon by the employer and WIA staff to correct the findings and/or problems. The WIA staff will follow-up to determine if the corrective action was completed. If the corrective action is not completed, steps may be taken to terminate the agreement.

The Boone/Winnebago/Stephenson OJT program must also adhere to any applicable rules contained in the WIA legislation or applicable federal or state regulations.

Northern Illinois Workforce Alliance OJT Policies

13

[The length of OJT agreements are determined on an individual basis by the OJT position’s Specific Vocation Preparation—SVP—code, the position’s job description, and the job experience of the OJT employee.]

OJT Policies Attachment [See also Item 11, preceding page.]

Information on Specific Vocational Preparation Levels

Section updated and revised 11/28/07

Occupational projections for the state and sub-state areas are developed by the Illinois Department of Employment Security (IDES). These growth rate projections are listed for occupations classified by O*Net-SOC (Standard Occupational Classification) codes. Each O*Net SOC code has been matched to a Specific Vocational Preparation (SVP) level. SVP levels represent the amount of time required for one to obtain the knowledge and skills needed for average performance on the job. Scale of Specific Vocational Preparation (SVP): [See also Item 11 above.]

Level Time 1 Short demonstration only 2 Beyond short demonstration up to 30 days 3 Over 30 days up to 3 months 4 Over 3 months up to 6 months 5 Over 6 months up to 1 year 6 Over 1 year up to 2 years 7 Over 2 years up to 4 years 8 Over 4 years up to 10 years 9 Over 10 years

To determine an occupation’s SVP, WIA staff use information available on the website O*Net Online. www.online.onetcenter.org. (To find SVP level, WIA staff enter occupation’s O*Net-SOC code, then click on occupation’s name, then click on Job Zone. More information on the SVP is available on the O*Net Online website under the Help feature.)

Northern Illinois Workforce Alliance Work Experience Policies

14

Northern Illinois Workforce Alliance

WORK EXPERIENCE POLICIES Adopted 12/5/00 Modified 10/2/01 Modified 5/5/09

1. Work experiences may be in the private-for-profit sector, the non-profit sector or in the public

sector, for participants whose objective assessment and individual service strategy indicate that work experiences are appropriate. Work experiences may be paid or unpaid.

2. Work experiences will be in positions that are “entry-level.” 3. For paid work experiences, WIA will pay the participants’ wages and related benefits. Wages will

be paid at the same entry-level rate paid trainees or employees in the same or similar positions at the worksite. However, no position will be paid less than the federally established minimum wage.

4. Generally participants in work experience will work 30 hours or less a week; and the duration of

their work experience will not exceed 360 hours. Exceptions include:

• Special circumstances when it has been determined that an individual participant needs additional work experience to enable him/her to gain unsubsidized employment. (All such exceptions must be approved by the WIB Service Delivery Committee.); and

• American Recovery & Reinvestment Act Summer Employment Program. 5. No participant will work in any subsidized work experience position when the same or

substantially equivalent position is vacant due to a hiring freeze. 6. The WIB reserves the right to deny future work experience requests from worksites that have not

honored the requirements set forth in previous work experience agreements. 7. All work experience agreements must be approved by the RRTC Director who will submit an

updated list of Work Experience Agreements to the WIB’s Service Delivery Committee at each of their meetings.

8. All participants in work experience will be required to participate in job readiness/job search skills

activities. Participants in subcontracted programs will be required to follow the class/workshop attendance procedures required by their program provider.

Boone/Winnebago Workforce Investment Board Work Experience Policies

15

Northern Illinois Workforce Alliance WIA On-Going Supportive Services Policies

Policies Adopted by WIB on March 6, 2001 Child Care and Transportation Sections Modified by WIB 9/6/05

Transportation Section Modified by WIB 3/4/08—Transportation Amounts Increased Participant Eligibility Section Modified by WIB 2/5/13

On-Going Supportive Services, Child-Care for Boone and Winnebago Counties, Child-care for Stephenson County Sections Modified by WIB 4/7/15

Applicable Federal Register citations: 20 CFR 663.800 - What are supportive services for adults and dislocated workers? Supportive services for adults and dislocated workers are defined at WIA sections 101(46)and 134(e)(2) and (3). They include services such as transportation, child care, dependent care, housing, and needs-related payments, that are necessary to enable an individual to participate in activities authorized under WIA title I. Local Boards, in consultation with the One-Stop partners and other community service providers, must develop a policy on supportive services that ensures resource and service coordination in the local area, such policy should address procedures for referral to such services, including how such services will be funded when they are not otherwise available from other sources. The provision of accurate information about the availability of supportive services in the local area, as well as referral to such activities, is one of the core services that must be available to adults and dislocated workers through the One-Stop delivery system. (WIA section 134(d)(2)(H).) 20 CFR 663.805 - When may supportive services be provided to participants? (a) Supportive services may only be provided to individuals who are: (1) Participating in core, intensive or training services; and (2) Unable to obtain supportive services through other programs providing such services. (WIA section 134(e)(2)(A) and (B).) (b) Supportive services may only be provided when they are necessary to enable individuals to participate in title I activities. (WIA section 101(46).) 20 CFR 663.810 - Are there limits on the amounts or duration of funds for supportive services? (a) Local Boards may establish limits on the provision of supportive services or provide the One-Stop operator with the authority to establish such limits, including a maximum amount of funding and maximum length of time for supportive services to be available to participants. (b) Procedures may also be established to allow One-Stop operators to grant exceptions to the limits established under paragraph (a) of this section.

Participant Eligibility Supportive Services are available for WIA program enrollees. Individual programs will establish procedures to document the participant’s need for supportive services. Documentation of the participant’s need for supportive services will be maintained by the programs and staff will ensure case notes reflect the receipt of such support. Training Participants attending training will only be eligible for assistance under this policy if the program/classes they are attending have been approved by the Workforce Investment Board, whether or not that training is actually being funded by WIA. The program/classes may be classified as either Intensive or Training services. This requirement will help staff in providing services that comply with previously approved Board policies and plans.

Boone/Winnebago Workforce Investment Board Work Experience Policies

16

On-Going Supportive Services The availability of On-going Child Care and Transportation assistance is based upon the availability of funds and the participant’s demonstrated need. All rates (Child Care rates for Licensed Day Care Center, License-Exempt Day Care Center, Licensed Day Care Home or Licensed Group Day Care Home, and License-Exempt Day Care Home or Care in Child’s Home) are based on the State rate. If the State rate for these categories changes, the WIB-approved rates will be adjusted to remain consistent with the State rate. Child Care reimbursement to a custodial or non-custodial parent will not be approved.

CHILD-CARE for Boone and Winnebago Counties (not-to-exceed payments)*

Under Age 2

Age

2

Age 3

and Older

Full-Day per child

Part-Day per Child (less than 5 hours)

Full-Day per

Child

Part-Day per child (less than 5 hours)

Full-Day per Child

Part-Day per Child

(less than 5 hours)

School-Age Day

Licensed Day Care Center

$46.49 $23.25 $36.73 $18.37 $27.55 $13.78 $13.78

License-Exempt Day Care Center

$40.50 $20.25 $32.00 $16.00 $24.00 $12.00 $12.00

Licensed Day Care Home or Licensed Group Day Care Home

$35.30 $17.65 $32.89 $16.45 $29.92 $14.96

Same as Part- Day

Non-Licensed Care

$16.22 $8.11 $16.22 $8.11 $16.22 $8.11 Same as Part- Day

CHILD-CARE for Stephenson County (not-to-exceed payments)*

Under Age

2

Age

2

Age 3

and Older

Full-Day per child

Part-Day per Child (less than 5 hours)

Full-Day per

Child

Part-Day per child (less than 5 hours)

Full-Day per Child

Part-Day per Child

(less than 5 hours)

School-Age Day

Licensed Day Care Center

$33.53 $16.77 $28.46 $14.23 $23.77 $11.89 $11.89

License-Exempt Day Care Center

$29.20 $14.60 $24.80 $12.40 $20.70 $10.35 $10.74

Licensed Day Care Home or Licensed Group Day Care Home

$29.39 $14.70 $27.25 $13.63 $24.96 $12.48

Same as Part- Day

Non-Licensed Care

$16.22 $8.11 $16.22 $8.11 $16.22 $8.11 Same as Part- Day

* Child Care figures-- effective for WIA and Trade participants: 1/1/13. See http://www.dhs.state.il.us/page.aspx?item=75772 (updated figures as of 12/1/14).

Boone/Winnebago Workforce Investment Board Work Experience Policies

17

TRANSPORTATION The following revised transportation policy was approved by the WIB 3/6/12, was effective 3/12/12, and was then revised 11/5/13 (and was effective 11/1/13). Exception for participants using Freeport area public transportation approved 6/3/14, revised 11/4/14. Reimbursement rate for usage of RRTC bus approved 11/4/14, was effective 11/3/14.

The following Transportation policy approved by the WIB on 3/6/12 was effective:

• March 12, 2012 for new WIA-funded Training participants who need transportation assistance to attend Training;

• July 1, 2012 for participants in WIA-funded Training prior to March 12, 2012.

Revised Transportation Policy—Effective November 1, 2013 for all WIA participants:

Participants in WIA-funded Training who need WIA-transportation assistance to attend training will receive a transportation allowance of $55 or a RMTD monthly bus pass (cost: $55) according to the schedule listed below.

• If a participant begins training on or before the 15th day of the month, he/she will receive a transportation allowance of $55 for this month.

• If a participant begins training after the 15th day of the month, he/she will receive a transportation allowance of $27.50 for this month.

• If a participant ends training on or before the 15th day of the month, he/she will receive transportation allowance of $27.50 for this month.

• If a participant ends training after the 15th day of the month, he/she will receive the full $55 transportation allowance for this month. If a participant is receiving a monthly RMTD bus pass, he/she will receive the bus pass for the full month he/she begins training, regardless of when in the month this occurs.

• If a participant is receiving a monthly RMTD bus pass, he/she will receive the bus pass for the full month he/she ends training, regardless of when in the month this occurs.

Exception: Participants using Freeport area public transportation will receive transportation assistance equal to the amount of the fare needed to attend their scheduled training classes; assistance for one round trip per scheduled training day will be allowed. Proof that the participants attended training on the days for which they receive assistance must be submitted.

For WIA and other grant program participants utilizing the RRTC bus, transportation, costs will be reimbursed to RRTC based upon the miles traveled reimbursed at the current federal mileage reimbursement rate plus a pick-up and drop-off fee of $5.00 per participant. The total mileage for the trip will be divided by the number of participants to get a per participant cost of travel plus the pick-up and drop-off fee. This reimbursement arrangement will only apply to program enrollees who live or must travel to work-related training, job fairs, and worksites in Boone County, Stephenson County or points outside of LWIA3. Winnebago County / Rockford area RRTC bus trips will be paid based upon the already established participant rate.

If a WIA participant is co-enrolled in the TAA program, the amount of transportation assistance that the participant receives will be based on the federal TAA transportation assistance regulations. Transportation assistance for WIA/TAA participants will be paid from WIA funds only in instances when TAA funds are exhausted. Approval All requests for On-Going Supportive Services will be approved by the Case Manager’s supervisor.

Boone/Winnebago Workforce Investment Board Work Experience Policies

18

Documentation Proper justification for a participant’s receipt of on-going supportive services must be documented in the DCEO case notes of the participant and correspond with the participant’s Individual Employment Plan. As required by law, the case notes should also support the Case Manager’s attempts to find funding for the participant’s needs through other sources. Day Care Providers and participants must sign a Day Care Attendance Sheet for each child whose day care costs are entirely or partially paid by WIA supportive services monies.

Northern Illinois Workforce Alliance Supplemental Supportive Services Policies

19

Northern Illinois Workforce Alliance

WIA Supplemental Supportive Services Policies Policies Adopted by WIB on February 6, 2001

Modifications to Participant Eligibility, Normal Support Items, Job Search Allowance sections adopted by WIB 2/5/2013.

Modifications to Normal Support Items, Auto Insurance/License/Registration, Job Related, Job Search Allowance (now Job Reach Assistance), Approval sections adopted by the Workforce Board 4/7/2015

Applicable Federal Register citations: 20 CFR 663.800 - What are supportive services for adults and dislocated workers? Supportive services for adults and dislocated workers are defined at WIA sections 101(46)and 134(e)(2) and (3). They include services such as transportation, child care, dependent care, housing, and needs-related payments, that are necessary to enable an individual to participate in activities authorized under WIA title I. Local Boards, in consultation with the One-Stop partners and other community service providers, must develop a policy on supportive services that ensures resource and service coordination in the local area, such policy should address procedures for referral to such services, including how such services will be funded when they are not otherwise available from other sources. The provision of accurate information about the availability of supportive services in the local area, as well as referral to such activities, is one of the core services that must be available to adults and dislocated workers through the One-Stop delivery system. (WIA section 134(d)(2)(H).) 20 CFR 663.805 - When may supportive services be provided to participants?

(a) Supportive services may only be provided to individuals who are: (1) Participating in core, intensive or training services; and

(2) Unable to obtain supportive services through other programs providing such services. (WIA section 134(e)(2)(A) and (B).)

(b) Supportive services may only be provided when they are necessary to enable individuals to participate in title I activities. (WIA section 101(46).)

20 CFR 663.810 - Are there limits on the amounts or duration of funds for supportive services? (a) Local Boards may establish limits on the provision of supportive services or provide the One-Stop operator with the authority to establish such limits, including a maximum amount of funding and maximum length of time for supportive services to be available to participants. (b) Procedures may also be established to allow One-Stop operators to grant exceptions to the limits established under paragraph (a) of this section

Participant Eligibility Participants enrolled in a WIA program will be eligible for assistance under this policy. All requests for support must be documented and must further the employment goal of the participant. Training Participants attending training will only be eligible for assistance under this policy if the program/classes they are attending have been approved by the Workforce Investment Board, whether or not that training is actually being funded by WIA. The program/classes may be either Intensive or Training services. This requirement will help staff in providing services that comply with previously approved Board policies and plans.

Northern Illinois Workforce Alliance Supplemental Supportive Services Policies

20

(An example of an inappropriate supportive service request would be providing supportive service assistance to a participant in training in a non-growth occupation, which would result in spending WIA funds for an employment goal which is counter-productive to attaining WIA goals, including performance goals.) Normal Support Items This policy applies to items not required by a training agency. All required items will be stated on the Recruitment & Referral Form. Below is a list of items which can be purchased as a one-time option, based upon individual need:

Maximum Item Paid by WIA

Automobile related needs* $

(This item includes car repairs, licenses, car insurance. See below for more specific policies regarding this item) Auto Repairs ………………………………… 500 Auto Insurance/License/Registration ………. 700

Clothing . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 150 Eye exam & glasses . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 250 Job Related Tools . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 500 Protective Shoes . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 150 Utilities* . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 300 Occupational certification exam fees and occupational license fees … actual cost

* To be eligible for an assistance with Automobile related needs (repairs, insurance, license, or registration) or utility payments, the vehicle or residence must belong to or be leased to the individual enrolled in the program and must be documented. Utility payments will be made to the utility company, not an individual. Car Repairs During a participant’s enrollment in WIA, automobile related needs described above will paid up to a total (cap) of $500. Car repairs will be provided for a participant only with proof of insurance, copy of registration and a valid driver’s license. The repairs to the vehicle must make it able to provide reliable transportation. Auto Insurance/License/Registration If a participant has access to a vehicle that is in working order, but does not have the vehicle registered or is not carrying insurance on the vehicle, the program can assist with costs for these items if other transportation options are not suitable for the individual (i.e. public transportation). Job Related Tools Normal procurement policies will be followed to purchase job related tools. If the tools are being purchased by the employer for a program participant the employer’s procurement will be accepted.

Northern Illinois Workforce Alliance Supplemental Supportive Services Policies

21

Job Search Assistance All Job Search activities must be documented and reflected in the participant file and appropriate case notes maintained. No Job Search assistance supportive services will be provided without proper documentation of need and case notes. Participants enrolled in Staff-assisted Job Search and/or Job Development may request a $ 30/month job search assistance stipend to cover activities such as dry cleaning interview clothes, getting a haircut, etc. Participants may also request bus tokens or bus passes to help them during their job search. If the individual has access to a properly registered and licensed vehicle and has a valid driver’s license, they may receive a monthly transportation stipend. The stipend will be paid in the same manner as transportation stipends for individuals participating in training activities (identified in the Transportation Policy). Background checks, drug screening, and physicals may be identified as needed supportive services for job search or job placement. These supportive services are allowable and can be paid as long as job search and job placement activities are properly documented. Approval All requests for the items listed above will be approved in writing by the Case Manager’s supervisor. Any item other than those listed above must have prior written approval from the Rock River Training Corporation’s Director, in addition to that of the supervisor before authorization can be given to purchase the item. The written approval of the Program Director will be included in the documentation submitted to the Accounting Department. Documentation Proper justification for any purchase under this policy must be documented in the case notes of the participant on IWDS, thus supporting that participant’s Individual Employment Plan. Also included in the case notes will be statements which support the Case Manager’s attempts to find funding for the participant’s need through other sources, as required under the law.

Northern Illinois Workforce Alliance Self-Sufficiency Definitions

22

Northern Illinois Workforce Alliance

SELF-SUFFICIENCY DEFINITIONS FOR ADULTS AND DISLOCATED WORKERS Adopted 7/11/00 Modified 10/2/01

(LLIL adjustments made when necessary.)

Modified Self-Sufficiency Definitions: Self-sufficiency for Adults: Employment that pays at least 125 %* of the lower living standard income level, which is defined in the Section 101 (24) of WIA as: “...the income level (adjusted for regional, metropolitan, urban, and rural differences and family size) determined annually by the Secretary [of Labor] for the most recent lower living standard family budget issued by the Secretary.” * 125% of LLIL as of March 31, 2014 for Winnebago/Boone/Stephenson Family of:

One-- $16,526.25; Two--$27,088.75; Three--$37,181.25; Four--$45,900; Five--$54,163.75; Six-- $63,355; for family members with more than six members, add $9,191.25 for each additional member.

Self-Sufficiency for Dislocated Workers: Employment that pays 1) at least 90% of the pre-dislocation wage of the individual or 2) 125% of the lower living standard wage (defined above), whichever is higher.

* 125% of the LLS figures issued by DOL3/27/14 and by DCEO 4/22/14. See DCEO WIA Notice No. 13-NOT-05, Attachment C. .

Northern Illinois Workforce Alliance Adult Service Priority System Policy

23

Northern Illinois Workforce Alliance

POLICY REGARDING ADULT SERVICE PRIORITY SYSTEM Adopted 7/11/2000

WIA requires that at least 51% of adult participants enrolled in intensive and training* services must be TANF or low-income participants or 51% of adult monies must be spent for intensive and training services for TANF or low-income participants.

As the initial local Adult Service Priority System for WIA, the WIB adopted the JTPA adult service priority system:

All participants must be from low-income** families except that 10% of the adult participants’ family income levels may be above the “low-income” levels providing they have one or more barriers to employment.” These barriers to employment for adults include:

• older individual • veteran • limited English proficiency • drug/alcohol dependency • disability affecting employment • offender • displaced homemaker • migrant worker

* Intensive Services include activities such as comprehensive and specialized assessment, full development

of individual employment plans, group counseling and career planning, case management, short tem pre-vocational, follow-up services. Training Services include: occupational skills training, on-the-job training, workplace and cooperative education programs, private sector training programs, skill upgrading and retraining, entrepreneurial training, job readiness training, adult education and literacy activities in combination with training, customized training.

** Use the current Winnebago/Boone/Stephenson low income levels by family size.

Northern Illinois Workforce Alliance Definitions Relating to Youth Eligibility Criteria

24

Northern Illinois Workforce Alliance

DEFINITIONS RELATING TO

WIA YOUTH ELIGIBILITY REQUIREMENTS Adopted 5/2/01

The youth eligibility requirements listed below incorporate the local definitions of:

(1) an individual who requires additional assistance to complete an educational program or to secure and hold employment -- approved by the WIB July 11, 2000; and

(2) other youth who face serious barriers to employment as identified by the local board -- approved

by the WIB on May 1, 2001. 1. Eligibility Criteria for Not Less that 95% of the Youth: In order to be provided services under the youth funding stream, an individual must meet the general eligibility requirements, and be:

1. Age 14 through 21; 2. A low income individual; and 3. A person who has one or more of the following barriers to employment:

a. Deficient in basic literacy skills*, b. A school dropout, c. Homeless, d. Runaway, e. A foster child, f. Pregnant, g. A parent, h. An offender, or i. An individual who requires additional assistance to complete an educational program, or to secure

and hold employment—The individual: (1) Is one or more grade levels below the grade level appropriate to the individual’s age, (2) Possess one or more disabilities, or (3) Faces serious barriers to employment as identified by local boards, i.e.

(a) Is a victim of domestic violence, or (b) Has a substantial substance abuse problem, or (c) Is a victim of sexual assault.

* An individual deficient in basic skills computes or solves problem, reads, writes, or speaks English at or below grade

8.9; or is unable to compute or solve problems, read, write or speak English at a level necessary to function on the job, in the individual’s family or society. Anyone who meets the definition of deficient in basic skills is considered to be basic skills deficient.

Northern Illinois Workforce Alliance Definitions Relating to Youth Eligibility Criteria

25

II. Eligibility Criteria for No More than 5% of the Youth:

In addition to the above persons, up to five percent of the youth participants served in a local area may be individuals who do not meet the income criterion for eligible youth, provided that they are within one or more of the following categories:

A. A school dropout, B. Basic skills deficient (same as deficient in basic skills), C. One or more grade levels below the grade level appropriate to the individual’s age, D. Pregnant, E. A parent, F. Possess one or more disabilities, including learning disabilities, G. Homeless, H. Runaway, I. An offender, or J. Face serious barriers to employment as identified by local board– i.e.,

1) Has a substantial abuse problem, 2) Is a victim of domestic violence, or 3) Is a victim of sexual assault.

Northern Illinois Workforce Alliance Needs Related Payment Policy

26

Northern Illinois Workforce Alliance Needs Related Payments Policy

Policy Adopted by WIB on June 2, 2009

Applicable Federal Register citations: 20 CFR 663.815 – What are needs –related payments? Needs-related payments provide financial assistance to participants for the purpose of enabling individuals to participate in training and are one of the supportive services authorized by WIA section 134(e)(3). 20 CFR 663.820 – What are the eligibility requirements for adults to receive needs-related payments? Adults must:

a. Be unemployed, b. Not qualify for, or have ceased qualifying for, unemployment compensations; and c. Be enrolled in a program of training services under WIA section 134(d)(4).

20 CFR 663.825 – What are the eligibility requirements for dislocated workers to receive needs-related payments? To receive needs related payments, a dislocated worker must:

a. Be unemployed, and; 1. Have ceased to qualify for unemployment compensations or trade readjustment allowance under TAA

or NAFTA-TAA; and 2. Be enrolled in a program of training services under WIA section 134(d)(4) by the end of the 13th week

after the most recent layoff that resulted in a determination of the worker’s eligibility as a dislocated worker, or, if later, by the end of the 8th week after the worker is informed that a short-term layoff will exceed 6 months; or

3. Be unemployed and did not qualify for unemployment compensation or trade readjustment assistance under TAA or NAFTA-TAA.

20 CFR 663.830 – May needs-related payments be paid while a participant is waiting to start training classes? Yes, payments may be provided if the participant has been accepted in a training program that will begin within 30 calendar days. The Governor may authorize local areas to extend the 30 day period to address appropriate circumstances. 20 CFR 663.840 –How is the level of needs-related payments determined?

a. The payment level for adults must be established by the Local Board. b. For dislocated workers, payments must not exceed the greater of either of the following levels:

1. For participants who were eligible for unemployment compensation as a result of the qualifying dislocation, the payment may not exceed the applicable weekly level of the unemployment compensation benefit; or

2. For participants who did not qualify for unemployment compensations as a result of the qualifying layoff, the weekly payment may not exceed the poverty level for an equivalent period. The weekly payment level must be adjusted to reflect changes in total family income as determined by Local Board policies. (WIA sec. 134(e)(3)(C).)

Applicable State Policy: WIA Policy Letter No. 07-PL-35 – issued August 29, 2007 Participant Eligibility Adult Eligibility:

a. Be unemployed, b. Not qualify for , or have ceased qualifying for, unemployment compensation; and c. Be enrolled in a program of training services under WIA section 134(d)(4). d. Current family income, includes all sources (UI, TRA, SSI, SSDI, etc), does not exceed 100% of the

LLSIL. e. Complete a Financial Needs Assessment to determine Needs Related Payment need. f. Student must maintain satisfactory progress of a C average or above.

Northern Illinois Workforce Alliance Needs Related Payment Policy

27

Dislocated Worker Eligibility:

a. Be unemployed, and 1. Have ceased to qualify for Unemployment Insurance (UI) compensation or Trade Readjustment

Allowance (TRA) under Trade Adjustment Act (TAA) or North American Free Trade Agreement-Transitional Adjustment Assistance (NAFTA-TAA) (Note: Dislocated workers who received and exhausted TRA benefits are not eligible unless laid off from a new event.) ; and

2. Be enrolled in a program of training services under WIA section 134(d)(4) by the end of the 13th week after the most recent layoff that resulted in a determination of the worker’s eligibility as a dislocated worker, or, if later, by the end of the 8th week after the worker is informed that a short-term layoff will exceed 6 months.

OR b. Be unemployed, and

1. Did not qualify for unemployment compensation or trade readjustment assistance under TAA or NAFTA-TAA; and

2. Be enrolled in a program of training services under WIA section 134(d)(4) by the end of the 13th week after the most recent layoff that resulted in a determination of the worker’s eligibility as a dislocated worker, or, if later, by the end of the 8th week after the worker is informed that a short-term layoff will exceed 6 months.

c. Customer cannot be receiving UI, State Training Benefits, On-the-Job Training, TRA, or Relocation Allowances. d. Current family income, includes all sources, (UI, TRA, SSI, SSDI, etc), does not exceed 100% of the

LLSIL. e. Complete a Financial Needs Assessment to determine Needs Related Payment need. f. Student must maintain satisfactory progress of a C average or above.

If these eligibility requirements are met, individuals may be awarded needs related payments from WIA funding prior to the start date of training classes for the purpose of enabling them to participate in program of employment and training services that begin within thirty (30) calendar days. At that point or sooner, as appropriate, all participants must be enrolled in Training Services in IWDS . Payment Determination

a. The level of needs-related payments made to Adults may not exceed the equivalent weekly amount of the LWIA’s annual 100% LLSIL for a family of one.

b. The level of needs-related payments made to Dislocated Workers shall not exceed the greater of: 1. The applicable weekly level of Unemployment Insurance compensation (for participants who were

eligible for unemployment insurance as a result of a qualifying dislocations); or 2. If the worker did not qualify for unemployment insurance compensation, the weekly payment may not

exceed the poverty level for an equivalent period. c. The week payment level must be adjusted to reflect changes in total family income. Monthly, or more often if

necessary, verifications of income and training will be required to maintain eligibility. Eligibility may be re-determined at any time based on the verifications.

Administration and Oversight

a. A copy of any UI entitlement decision or confirmation of UI benefits being exhausted will be maintained in each customer file.

b. A copy of the requests for training classes for each period of training (quarter, semester, block, class, etc.) will be maintained in each customer file. A copy of the customers Individual Training Account (ITA) will be used as documentation.

c. Verification of enrollment/registration, participation, grades, and completion of training classes (confirmation from Registrar’s office and course instructor) will be maintained in each customer file. A copy of each class schedule and grades will be maintained in each customer files and will be used documentation. Monthly verifications of attendance and training progress will be reviewed.

Northern Illinois Workforce Alliance Needs Related Payment Policy

28

d. Each customer determined eligible and receiving Needs Related Payments (NRPs) will have signed a copy of this policy as a testament to his/her understanding of the requirements and instruction.

e. All eligibility will be documented and maintained in the customer file. f. A comprehensive reporting system of all NRPs will be maintained and quarterly internal monitoring will be

administered. g. A Needs Related Payments Analysis form and Weekly Verification of Income & Training forms will be

completed and maintained in the customer file. Fraud

a. All cases of fraud or suspected fraud will be forwarded to the appropriate legal authorities for prosecution per WIA Policy Letter No. 06-PL-28.

b. In the event of fraudulent activity, all payments to the fraudulent party will cease and all funds paid will be recovered.

c. To prevent fraudulent payment activity LWIA staff will: 1. Perform a cross check with UI to ensure that participants are not receiving UI, TRA, and State Training

Benefits while receiving NRPs. Staff will also ensure that participants are not enrolled and participating in On-the-Job Training (OJT) while receiving NRPs.

2. All training participation will be verified before payments are authorized. 3. Fraud will be immediately reported and investigated. The collection process from appropriate sources

will be initiated immediately as applicable. d. NRPs have been classified as non-taxable income by the Internal Revenue Service (IRS).

Attachments – Needs Related Payments Analysis Form and Instructions Needs Related Payments Weekly Verification of Income & Training and Instructions

[The forms are in WORD and are fill-in forms. Download them from WIA Policy Letter No. 07-PL-35. Go to http://www.illinoisworknet.com/vos_portal/WIA_Works/en/Home/policyMakers/Policies.]

Northern Illinois Workforce Alliance Needs Related Payment Policy

29

[Download fill-in form in WIA

Policy Letter 07-PL-35.]

Participant Information

Needs Related Payments Analysis Form

1. Name: Last First M.I.

2. Home Address Street Address (Include Apartment Number)

City State Zip Code 3. Phone Number(s) ( ) - ( ) -

Home Mobile

Needs Analysis Please Note that a “No” answer to Question A would disqualify you for NRPs.

4. Question A Are you unemployed or have you received notification of

layoff?

Yes

No

Please Note that a “Yes” answer to Question B would disqualify you for NRPs.

5. Question B

Do you qualify for Unemployment Insurance (UI) benefits, additional State UI benefits (Training Benefits) or Trade Readjustment Allowance (TRA) benefits?

Yes

No

Please Note that a “No” answer to Question C would disqualify you for NRPs.

6. Question C

Have you ceased to qualify for Unemployment Insurance (UI) benefits, additional State UI benefits (Training Benefits) or Trade Readjustment Allowance (TRA) benefits?

Yes

No

7. Additional Comments:

8. Based upon the responses to questions A-C, is the participant eligible to receive NRPs?

Yes

No

9. Have you considered all "other resources" available that will help you successfully participate in your full-time training program? Examples of other resources include but are not limited to: Pell grants, severance pay, other family income (spouse’s income).

Yes

No

10. Will "other resources" meet your need to support you while attending school full-time?

Yes

No

11. All of the answers and information are true and complete to the best of my knowledge. I have read, understand, and agree to comply with the policies for Needs Related Payments.

/ / Participant Signature Date

12. To Be Completed By LWIA Case Manager I have reviewed these policies with the participant, have determined their eligibility to receive Needs Related Payments, and have explained the procedures for collecting Needs Related Payments.

/ /

Case Manager Signature Date

Revised August 2007 Page 1 of 1 DCEO/NRP Form # 001

Northern Illinois Workforce Alliance Needs Related Payment Policy

30

Needs Related Payments Analysis Form Instructions

[Download fill-in form in WIA Policy Letter 07-PL-35.]

Participant Information 1. Name Enter the name of the person who is requesting Needs Related Payments (NRP).

2.

Home Address

Enter the home address of the participant. Include the street address (including apartment number if applicable), city, state, and zip code.

3.

Phone Number(s)

Enter the home phone number for the participant. Also, enter a cellular telephone number if the participant wants an alternate method of contact.

Needs Analysis 4. Question A Check “Yes” or “No” to indicate whether the participant is currently unemployed or has

received notification of layoff from their current employer. Note: A “No” answer to this question would disqualify the participant from NRPs.

5. Question B Check “Yes” or “No” to indicate whether the participant currently qualifies for

Unemployment Insurance (UI) benefits, additional State UI benefits (training benefits), or Trade Readjustment Allowances (TRA) benefits.

Note: A “Yes” answer to this question would disqualify the participant from NRPs.

6. Question C Check “Yes” or “No” to indicate whether the participant has ceased to qualify for Unemployment Insurance (UI) benefits, additional State UI benefits (training benefits), or Trade Readjustment Allowances (TRA) benefits. Note: A “No” answer to this question would disqualify the participant from NRPs.

7. Additional Comments Enter any additional comments you feel could be beneficial to determining a person’s

eligibility for Needs Related Payments. Information might include the employer for whom the person has received a layoff notice and the anticipated date of layoff.

8. Eligibility

Determination Check “Yes” or “No” to indicate whether the person qualifies for Needs Related Payments based on the answers to Questions A, B, and C.

9. Consideration of

“Other Resources” Check “Yes” or “No” to indicate whether the person has considered the availability of all “other resources” to help successfully participate in a full-time training program. Other resources might include, but are not limited to, Pell grants, severance pay, other family income, etc.

10. “Other Resources” Check “Yes” or “No” to indicate whether any of the other resources considered in

Question 8 above would meet the need to support the participant while attending school full-time.

11. Participant Signature The person requesting the NRPs must acknowledge they have entered (or assisted in the entering) all information on this form to the best of their knowledge and that they have read, understand, and agree to comply with the policies for Needs Related Payments. Once they agree to all information, they must sign this form and enter the date of their signature.

12. LWIA Case Manager

Signature The LWIA case manager having oversight of this particular analysis must acknowledge that they have reviewed all NRP policies with the participant, have determined their eligibility to receive NRPs, and have explained the procedures for collecting NRPs. Upon acknowledgment of this information, the LWIA Case Manager must sign this form and enter the date of their signature

Northern Illinois Workforce Alliance Needs Related Payment Policy

31

Needs Related Payments Weekly Verification of Income & Training [Download fill-in form in WIA Policy Letter 07-PL-35.]

Participant Information

1. Name: Last First M.I.

2. Home Address: Street Address (Include Apartment Number)

City State Zip Code 3. Phone Number(s): ( ) - ( ) -

Home Mobile

Needs Related Payment Information 4. Needs-Related

Payment Amount: $ /week

5. Training Week

Beginning/Ending: / / to / /

Individual Assessment Questions: 6. Did you claim, or intend to claim any type of unemployment benefits for

the training week? Yes $

No

7. Did you receive any payments for full-time-work, part-time work, work experience, or work study for the training week?

Yes $

No

8. Did you receive TAA or Trade Readjustment Allowance payments for the training week?

Yes $

No

9. Were you enrolled in or receiving paid job training for the training week? Yes $

No

10. Did you maintain full-time hours as defined by the training institute?

Yes

No, explain:

Yes

No, explain:

12. Additional Comments:

13. All of the answers and information are true and complete to the best of my knowledge. I have read, understand, and agree to comply with the policies for Needs Related Payments.

/ / Participant Signature Date

14. To Be Completed By LWIA Case Manager I have reviewed these policies with the participant, have determined their eligibility to receive Needs Related Payments, and have explained the procedures for collecting Needs Related Payments.

/ /

Case Manager Signature________________________________________________ Date

Revised August 2007 Page 1 of 1 DCEO/NRP Form #002

31

Needs Related Payments Weekly Verification of Income & Training Instructions

[Download fill-in form in WIA Policy Letter 07-PL-35.] Participant Information 1. Name Enter the name of the person who is requesting Needs Related Payments (NRP). 2.

Home Address

Enter the home address of the participant. Include the street address (including apartment number if applicable), city, state, and zip code.

3.

Phone Number(s)

Enter the home phone number for the participant. Also, enter a cellular telephone number if the participant wants an alternate method of contact.

Needs Related Payment Information 4. Needs Related

Payment Amount Enter the agreed upon NRP weekly payment amount.

5. Training Week Enter the beginning and ending dates of the week being verified.

Verification of Income and Training 6. Claim of

Unemployment Benefits

Check “Yes” or “No” to indicate whether the participant claimed or intends to claim any type of unemployment benefits for the training week being verified. If “Yes” has been checked, enter the amount of such benefits received or anticipated to be received.

7. Payments for Work Check “Yes” or “No” to indicate whether the participant received any payments for full- time or

part-time work, work experience, or work study for the training week being verified. If “Yes” has been checked, enter the amount of such benefits received or anticipated to be received.

8. TAA or TRA

Payments Check “Yes” or “No” to indicate whether the participant received any TAA or TRA payments for the training week being verified. If “Yes” has been checked, enter the amount of such benefits received or anticipated to be received.

9. Job Training

Payments Check “Yes” or “No” to indicate whether the participant was enrolled in job training or received any job training payments for the training week being verified. If “Yes” has been checked, enter the amount of such benefits received or anticipated to be received.

10. Maintain Full-Time

Status Check “Yes” or “No” to indicate whether the participant has maintained full-time status as defined by the training institute. If “No” is checked, provide a brief explanation as to why they did not successful maintain full-time status.

12. Additional Comments Enter any additional comments you feel could be beneficial in verifying the participant has in

fact complied with the policies related to receiving Needs Related Payments.

13. Participant Signature The person requesting the NRPs must acknowledge they have entered (or assisted in the entering) all information on this form to the best of their knowledge and that they have read, understand, and agree to comply with the policies for Needs Related Payments. Once they agree to all information, they must sign this form and enter the date of their signature.

14. LWIA Case Manager the LWIA case manager having oversight of this particular analysis must acknowledge that they have reviewed all NRP policies with the participant, have determined their eligibility to receive NRPs, and have explained the procedures for collecting NRPs. Upon acknowledgment of this information, the LWIA Case Manager must sign this form and enter the date of their signature.

Northern Illinois Workforce Alliance Incumbent Worker Training Policy

32

Northern Illinois Workforce Alliance

Workforce Investment Act (WIA) Incumbent Worker Training Policy

Policy adopted by WIB on 8/4/09 Technical Changes Made 5/29/12

Lay-Off Aversion Explanation Addition Approved 6/3/14 Purpose This policy provides information and guidance on implementing the State-approved waiver granting authority to local workforce investment boards to transfer up to ten percent (10%) of dislocated worker Workforce Investment Act (WIA) allocation to support incumbent worker training programs. References - WIA Policy Letter No. 07-PL-33, Change 4 (December 19, 2011)Workforce Investment Act of 1998,

117(e), 118©, and Section 134(a)(3)(iv)(I) - Workforce Investment Act Final Rule; Section 661.345, 665.220, 665.268, and 667.268 - 29 CFR 97.24

USDOL-ETA Training and Employment Guidance Letter (TEGL) 30-09, Layoff Aversion Definition and Appropriate Use of Workforce Investment Act Funds for Incumbent Worker Training for Layoff Aversion Using a Waiver - (June 8, 2010)

- PY’00 WIA PL 00-14, Pre-Award Survey for Relocating Establishments (December 28, 2000) - PY’01 WIA PL 01-33 change 1. Reporting of Obligations and Re-allotment under the Workforce

Investment Act (WIA) (May 13,2009) WIA Policy Letter No. 07-PL-33, Change 2, Incumbent Worker Training (May

- 26, 2010) WIA Policy Letter No. 07-PL-40 Training Expenditure Requirement - (November 14, 2007)

- WIA Policy Letter No. 07-PL-41 Change 1, Local Plan Modifications (October 29, 2008) WIA Policy Letter No. 10-PL-58, Reporting of Accrued Expenditures, Obligations and Reallocation (July 1, 2010)

- U.S. Dept. of Labor Waiver Approval Letter (November 16, 2009) - U.S. Dept. of Labor Waiver Approval Letter (July 12, 2005) - U.S. Dept. of Labor Waiver Approval Letter (February 26, 2008) Background Per the Policy Letter NO. 07-PL-33, Change4: These programs will assist Economic Development Regions and/or Local Workforce Investment Areas in developing a full continuum of training services that address the needs of the existing workforce, the unemployed, underemployed, and new entrants to the labor force. Training allowable will focus on occupations that are in high growth areas, based on labor market data, industry, and economic development. Per the Northern Illinois Workforce Alliance’s Workforce Investment Area Strategic Plan, utilizing WIA incumbent worker training is an opportunity to address skill gaps, prevent dislocation, and open entry level

Northern Illinois Workforce Alliance Incumbent Worker Training Policy

33

positions for WIA participants. Definitions Employed Worker An individual who is employed and is determined to be in need of intensive

service to obtain or retain employment. Grant Recipient A grant recipient (or grantee) for Incumbent Worker

Training programs may include: a) Formula grant projects funded with local ten percent

(10%) transfer authority: 1) Established grantee of WIA formula funds.

b) Statewide discretionary grant projects funded with fifteen percent (15%) state discretionary funds: 1) Training providers; 2) Employers whose incumbent workers are receiving the training; or 3) Other organizations qualified to receive Department of Commerce and Economic Opportunity (DCEO) WIA incumbent worker grants.

Incumbent Worker a) An individual (or group of individuals) with an employment relationship with a participating employer or group of participating employers in a targeted industry (as sited in the local plan); and b) An individual who is receiving upgraded skills training: - To increase his or her skills in an occupation in which the individual is

already an incumbent; or - To prepare the worker for entry into a new occupation within the

targeted workforce (i.e., the workforce of the participating employer or group of employers).

Layoff Aversion ETA considers a layoff averted when: a) A worker's job is saved with an existing employer that is

at risk of downsizing or closing; or b) A worker at risk of dislocation transitions to a different job with the same

employer or a new job with a different employer and experiences no or minimal unemployment.

(See explanation of Lay-Off Aversion, including At-Risk Indicators at the end of this Policy.)

Participating Employer The primary customers for incumbent worker training services are the

participating employers or group of employers, as cited in “a” above under Incumbent Worker definition. Such employers must be actively participating in a WIA funded incumbent worker training program. And, such employers must be industry focused. For example, a group of employers may be associated due to supply relationships, such as an original equipment manufacturer (OEM) and the firms in the OEM’s supply chain. Or a group of employers may be associated through an industry-related organization.

Northern Illinois Workforce Alliance Incumbent Worker Training Policy

34

Targeted Industries Targeted industries in the Boone, Winnebago, and Stephenson Counties Workforce Investment Area are healthcare, manufacturing (including aerospace manufacturing), transportation/warehousing and logistics, information technology, and green technology.

Policy Training is primarily delivered in two ways; one is through group instruction, the other through “off the shelf” programs that lead to a certificate or degree. Due to the variance in costs of training and to who is responsible for the costs incurred, two separate criteria for approving training are being introduced. All projects requests exceeding $10,000 in grant resources will be reviewed for approval by a team. This team will consist of the business services members responsible for incumbent worker training and a member of the WIB Board. Group Instruction:

Employer Match Percentage of employer match will be based on the size of the employer. Match can be costs toward curriculum development, training materials and supplies, vendor/contractor trainer costs, travel expenses for trainers, training facility costs, wages and fringe benefits of trainees while in training, and fees for training certifications.

Employer Number of Employees Percentage Match Required Large Employer 101+ 50% Mid-sized Employer 51-100 25% Small Employer 1-50 10%

*Employers will be required to report monthly until the project is complete. *Employers/Trainers will be required to bill within 20 days of the completion of training. Billing may be required monthly for projects which exceed more than one (1) month of training. Payments to be reimbursed will require employers/trainers to provide all required supporting documentation. Payments will not be made for incomplete requests or requests not provided on a timely basis. (*Details will be defined in the Operating and Billing Procedures Manual.)

Incumbent Worker Grant Award Grants must be awarded prior to start of training. Grants can be used for costs for training, instructor’s fees, and materials. Training for Lean Manufacturing will not exceed $5000.00 in incumbent worker grant funds per employer. The Business Services Unit will approve vendors proposed by employers to deliver training to ensure a competitive procurement and justification for training is complete.

Individual Instruction: Employer Match Percentage of employer match will be 25%, regardless of the size of the employer. Match can be delivered through tuition reimbursement or commitment to projects approved by the Board.

Northern Illinois Workforce Alliance Incumbent Worker Training Policy

35

Incumbent Worker Grant Award Grant awards will not exceed 75% of the cost of training. The amount of tuition per individual is not to exceed $10,000 in incumbent worker funds per year per individual. The grant can be for costs toward tuition, fees, materials, and supplies directly related to training. Vendors to deliver training will be based on customer choice and an off-the-shelf price.

Reporting Projects will be reported periodically to the Business Relations Committee. Incumbent Worker “Layoff Aversion” Layoff Aversion (TEGL 30-09): ETA considers a layoff averted when: 1) a worker’s job is saved with an existing employer that is at risk of downsizing or closing; or 2) a worker at risk of dislocation transitions to a different job with the same employer or a new job with a different employer and experiences no or a minimal spell of unemployment What LWIAs should do?

• Consult with at-risk businesses to explore refocusing or retooling a company to serve new markets and/or targeted industries

• Establish contact with business intermediaries with known expertise in business assessment and viability studies for skills upgrade to at-risk employees

• Confirm with the Company and quantify any and all of the “at risk” company indicators and/or “at risk” worker indicators

What is an “at-risk” company? An “at-risk” company is one that is experiencing one or more of the following Layoff Aversion “At-Risk” Indicators:

1. Declining sales 2. Supply chain issues 3. Adverse industry/market trends 4. Changes in management behavior or ownership 5. Other “at risk” indicators – Additional indicators or causes for potential layoffs that are gathered in

consultation with the employer that puts part of their workforce “at-risk” for layoff. The other “at-risk” indicators will be explained in detail for each project, and will directly correlate to “lay off aversion”.

Who is an “at risk” worker? An at-risk worker is a worker who, without upgrading his/her skills, could lose his/her job. “At Risk” Indicators for Workers:

1. Unless provided with training, the worker does not have marketable, in-demand skills. 2. There exists a strong possibility of a job, either with the existing employer or a new employer, if

the potentially laid-off worker attains new skills.

When can training be provided? • A worker receives a layoff notice • An employer has been determined to be “at risk” for layoff unless workers receive training on a new

production technology or skills upgrade

Northern Illinois Workforce Alliance Incumbent Worker Training Policy

36

• If a worker can move jobs within or outside of “at risk” company by being trained on new skills

What type of training can be provided? • Retraining employees or adapting their skills to better take advantage of current or anticipated jobs

presented by new markets or targeted industries • Training for managers and supervisors to provide skills needed to assume new functions and

responsibilities within an “at risk” business • Training within an “at risk” company that allows a potentially laid off worker to move jobs within or

outside of the company

Northern Illinois Workforce Alliance Selective Service Policy

37

Northern Illinois Workforce Alliance

Youth Follow-Up Policy

Adopted by WIB 2/1/11 All youth will receive 12 months of follow-up services after their exit from WIA. Monthly, not less than one case note describing the follow-up services that each exited youth has received during the past month will be entered into the Illinois Workforce Development System (IWDS). The follow-up services that a youth receives will be based on the individual needs of the youth. Those services may include the following (from WIA Regulations Sec. 664.450):

1. Leadership development and supportive services listed in WIA Regulations Sec. 664.420* and Section 664.440**;

2. Regular contact with a youth participant’s employer, including assistance in addressing work-related problems that arise;

3. Assistance in securing better paying jobs, career development and further education; 4. Work-related peer support groups; 5. Adult mentoring; and 6. Tracking the progress of youth in employment and training.

All youth participants must receive some form of follow-up services for a minimum duration of 12 months, as required by WIA Regulations 664.450; and case notes will sufficiently describe the follow-up service provided.

* Section 664.420 Leadership Development:

Leadership development opportunities are opportunities that encourage responsibility, employability, and other positive social behaviors such as:

(a) Exposure to postsecondary educational opportunities; (b) Community and service learning projects;

(c) Peer-centered activities, including peer mentoring and tutoring; (d) Organizational and team work training, including team leadership training; (e) Training in decision-making, including determining priorities; and (f) Citizenship training, including life skills training such as parenting, work behavior training, and

budgeting of resources [WIA sec. 129(c)(2)(F)].

** Section 664.440 Supportive Services:

Supportive services for youth, as defined in WIA section 101(46), may include the following: (a) Linkages to community services; (b) Assistance with transportation; (c) Assistance with child care and dependent care; (d) Assistance with housing; (e) Referrals to medical services; and (f) Assistance with uniforms or other appropriate work attire and work-related tools, including

such items as eye glasses and protective eye gear [WIA sec. 129(c)(2)(G)].

Northern Illinois Workforce Alliance Selective Service Policy

38

Northern Illinois Workforce Alliance

SELECTIVE SERVICE POLICY Adopted by WIB 6/7/11

Modified on 3/22/12 to meet DOLETA TGEL 11-11 Change 1 Requirements Further modified on 6/5/12 to meet DCEO WIA Policy Letter No. 11-PL-02 Requirements

Background: From Illinois Department of Commerce and Economic Opportunity (DCEO) WIA Policy Letter No 11-PL-02: All programs and services established or funded under Title I of WIA must comply with Selective Service registration requirements… Specifically, section 3 of the Military Selective Service Act (MSSA) requires that every male, residing in the United States, register with the Selective Service System between their 18th and 26th birth dates. WIA section 189(h) and 20 CFR Part 667.250 requires that male job seekers be in compliance with these registration requirements to participate in WIA-funded activities and services. Furthermore, in 1986, Public Law 99-661 amended the MSSA to make it a requirement that a male customer's registration status be examined and confirmed. A person can be denied the right or privilege under federal law by reason of failing to submit a registration to the Selective Service unless he meets the following exemption:

1) The person shows by a preponderance of the evidence that the failure of the person to register

was not a knowing and willful failure to comply. POLICY: (Most of the language for this Policy is taken from DCEO WIA Policy Letter No 11-PL-02.)

A. For WIA eligibility, the Northern Illinois Workforce Alliance (WIB) will ensure each male customer has complied with the following Selective Service guidelines.

1. If the male customer has not reached age 18, and will not within the next 30 days, or was

born before January 1, 1960, the Military Selective Service Act (MSSA) is not applicable to that individual. Selective Service Compliance within the Illinois Workforce Development System (IWDS) will be marked "not applicable" in this instance.

2. A male WIA participant who attains the age of 18 while participating in the program will be

registered with Selective Service by the 30th day after his 18th birthday to remain eligible. He may also register in the 30 days prior to his 18th birthday.

a. If the customer fails to register within 30 days after his 18th birthday, all existing WIA

services that were obtained before the age of 18 will be closed.

1) All WIA services provided after the customer is determined to be non-compliant will be disallowed.

3. All other male customers must be registered prior to their 26th birthday, unless the

following exceptions apply:

a. For United States citizens, Selective Service registration is not required while the male meets one of the following conditions:

1) A male who is serving in the military on full-time active duty;

Northern Illinois Workforce Alliance Selective Service Policy

39

2) A male attending the service academies; 3) A disabled male who is continually confined to a residence, hospital or institution; 4) A male who is hospitalized, institutionalized, or incarcerated; or 5) If a male is released from any of the above conditions before he reaches the age of

26, he is required to register with Selective Service within 30 days of his release.

b. For non-United States citizens, Selective Service registration is required within 30 days of becoming a resident unless the man falls within one of the following categories:

1) A male who came into this country for the first time after his 26th birthday.

a) Acceptable forms of documentation for this exemption include: i) Date of entry stamp on passport; ii) I-94 with date of entry stamp on it; or iii) Letter from the U.S. Citizenship and Immigration Services (USCIS)

indicating the date the man entered the United States presented in conjunction with documentation establishing the individual's age.

2) A male who entered the country illegally after his 26th birthday and can provide proof that he was not living in the United States from age 18-25.

3) A male on a valid, non-immigrant visa.

c. If a non-compliant male customer is receiving non-Core A, staff assisted, services at the time this policy becomes effective, he will receive a grace period of 30 days to begin the compliance process. This can mean registration for males under 26 or completion of the Request for Status Information Letter (RSIL) and the Selective Service Verification Form (DCEO/SS Form #001) for males 26 years of age and older. At the conclusion of the 30 day grace period, any non-compliant male that has not begun the compliance process will be removed from WIA funded services and any costs associated with servicing this customer after that time will be disallowed.

4. Any male customer who is beyond his 26th birthday can no longer register but is required to

provide documentation of his compliance to the Selective Service requirement in order to be considered eligible for any WIA Title I benefits and services.

a. Acceptable forms of documentation can be found below in Section A.5.a. below.

b. Failure to produce authorized documentation requires that the individual acquire a

Status Information Letter (SIL) from Selective Service indicating whether he was required to register.

1) If the SIL indicates that he was not required to register, he can then be enrolled in

WIA-funded services. 2) If the SIL indicates that he was required and failed to register and now is unable to,

as a result of being 26 years of age or older, he is to be disqualified from WIA-funded programs and services until it is determined that his failure was not knowing or willful.

a) All WIA services, beyond Core A non-staff assisted self-services should be discontinued, until it is determined that it was not a knowing and willful failure, as they will be disallowed.

Northern Illinois Workforce Alliance Selective Service Policy -

40

5. The grantee must verify whether the customer has complied with the MSSA requirements

and place documentation in the case file. a. Verification may be made in any one of the following ways:

1) Contacting the Selective Service at www.sss.gov to determine if the customer has registered.

2) Phone the Selective Service Registration Office (telephone number 847-688-6888). A phone confirmation coupled with a case note will be sufficient for WIA verification.

3) Acquiring any one of the following forms of documentation: a) Selective Service Acknowledgement Letter; b) Form DD-214, "Report of Separation;" c) Screen printout from the Selective Service Verification site:

www.sss.gov/RegVer/wfVerification.aspx; d) Selective Service Registration Card; e) Selective Service Verification Form (Form 3A); or Stamped f) Post Office Receipt of Registration.

4) Additional registration information can be found by visiting www.sss.gov or by viewing the "Who Must Register Chart" attached to this policy.

b. Once verification has been completed:

1) If the male customer has complied with MSSA, he may be entered as such in IWDS and no further action is necessary.

2) If the male customer has not complied with MSSA: a) All WIA services, beyond Core A non-staff-assisted self-services should be

discontinued, as they will be disallowed until it is determined that they are in compliance.

b) The grantee should advise the customer to go to www.sss.gov to register. Enrollment in non-core A, staff assisted, services should not occur until registration is confirmed.

c) However, if the customer has failed to comply with Selective Service and is over the age of 26, he can no longer register to achieve compliance and must fill out the Request for Status Information Letter (RSIL) form explaining why he did not register. A copy of the RSIL and the Selective Service Verification Form (DCEO/SS Form #001) must be signed by the male customer and maintained in the customer's file. i) The RSIL form can be found by accessing http://www.sss.gov/Status.html

and clicking on "Request for Status Information Letter." The instructions can be accessed at http://www.sss.gov/PDFs/instructions.pdf.

ii) The Status Information Letter (SIL) may take from 4 to 6 weeks to arrive. iii) If the SIL dictates that the customer was required and failed to register,

the WIA One-Stop Operator will make the decision regarding the customer’s eligibility for WIA services in accordance with the local policy given in C. below.

B. The Selective Service requirement is not an eligibility criterion for Trade customers.

Northern Illinois Workforce Alliance Selective Service Policy -

41

1) In the event a Trade customer is not Selective Service compliant, case management must be conducted by a State Merit Staff employee.

a. This must begin as soon as it is known that the customer is not compliant with the

MSSA. b. In this event, contact the Illinois Department of Commerce and Economic Opportunity

(DCEO) Trade Coordinator for guidance.

C. Local Policy and Procedures for Northern Illinois Workforce Alliance’s Workforce Investment Area

1. All males born on or after January 1, 1960, must present documentation showing compliance

with the Selective Service registration requirement to be eligible for WIA services and must complete the Selective Service Verification Form (DCEO/SS Form #001) found on-line with DCEO WIA Policy Letter No. 11-PL-02.

2. Documentation/verification of registration will be in the participant’s file.

3. Male WIA program participants who turn 18 during program participation will be required to register with Selective Service within the 30 days following their 18th birthday for continued program participation.

4. If an individual customer has not complied with the MSSA requirements for registration, the

decision regarding customer’s eligibility for WIA services will be made by the WIA Dislocated Worker Program Director or the WIA Adult Program Director in accordance with the guidance issued in DOLETA’s TGEL 11-11 Change 1 and DCEO’s WIA Policy Letter 11-PL-02. (Exception: For Trade MSSA non- compliant customers, see Section B of this policy’s for the procedure to follow.) The WIA Dislocated Worker Program Director or the WIA Adult Program Director will make the determination regarding the individual’s “non-knowing and non-willful failure to comply” with the Selective Service requirement. In cases of determining the “knowing and willful failure to comply” for the purpose of granting a Locally Approved Selective Service Waiver, the customer must request a Status Information Letter from Selective Service. See A.5.b. above. A Locally Approved Selective Service Waiver may be issued only under circumstances in which time is a factor for enrolling a customer in services or training and the 4 to 6 weeks that the Status Information Letter will take to arrive may harm the customer’s progress through the program.

a) Justification for the earlier granting of the waiver must be documented and placed within the customer's case file.

b) Upon arrival of the Status Information Letter, the Dislocated Worker Program Director or Adult Program Director must examine the letter to determine if the additional information gained through the Status Information Letter eliminates the possibility of a” non-knowing and non-willful failure to register.”

c) If the failure is deemed “not knowing and willful,” then he may be granted the Locally Approved Selective Service Waiver and registered and enrolled in services or benefits.

Northern Illinois Workforce Alliance Selective Service Policy -

42

d) If the failure is deemed “knowing and willful,” then he must be denied WIA

services. Any costs associated with services provided beyond Core A non-staff assisted self-services will be considered disallowed.

e) Decisions will be made on a case-to-case basis. f) Documentation of the rationale for denying or accepting the applicant as a WIA

registrant must be retained in the participant’s file.

5. Individuals denied services must be advised of available WIA grievance procedures as outlined in WIA Policy Letter No. 04-PL-05.

D. Selective Service Compliance within IWDS will have three acceptable reporting choices that would

allow a customer to be determined eligible for WIA services:

1. "Yes" - is appropriate for a male customer, born on or after January 1, 1960 and who has registered with Selective Service.

2. "Not Applicable" - is appropriate for any one of the following:

a. A female customer; b. A male customer who has not reached 18 years of age; or c. A male customer born before January 1, 1960.

3. "Locally Approved Waiver" - is appropriate for a male customer, 26 years of age and older

who was born on or after January 1, 1960 and is not Selective Service compliant, but has demonstrated that his failure to comply was not knowing or willful, and has received a Locally Approved Selective Service Waiver.

a. The "Locally Approved Selective Service Waiver" may also be appropriate for

any one of the following:

1) A male customer who can prove that they had entered the country for the first time after their 26th birthday;

2) A male who served continuously in the Armed Forces from ages 18-26; or 3) A male who can show they were confined to a residence, hospital, institution or was

incarcerated continuously from age 18-25. 4. If the answer to the question of Selective Service compliance is "No" in IWDS, the client will

never be determined eligible for WIA.

Northern Illinois Workforce Alliance Medical Data & Information Collection Policy

43

Northern Illinois Workforce Alliance

POLICY ON MEDICAL DATA AND INFORMATION COLLECTION AND MAINTENANCE

Policy Adopted February 5, 2013.

I. PURPOSE

This policy provides guidance on medical data and information collection and maintenance in files of Illinois Workforce Investment Area 3 applicants, registrants, eligible applicants/registrants, participants, program completers, employees, and applicants for employment.

II. REFERENCES This Policy is based on the Equal Opportunity Policies / Requirements referenced below: • US Department of Labor Regulations at 29 CFR Part 37 – Implementation of the

Nondiscrimination and Equal Opportunity Provisions of the Workforce Investment Act of 1998;

• Workforce Investment Act or 1998 Sections 134(b), 136(d)(2)(F), 1369e), 172(a), 183(c)(2), 185 (d)(I)(E), 186, 187 and 188;

• The Americans with Disabilities Act; • IL WIA EO Policy Letter No. 00-06; and • LWIA #3 – Methods of Administration (MOA) – Element 6 – Data and Information

Collection and Maintenance. III. SUBJECT INDEX:

Equal Opportunity / Nondiscrimination IV. BACKGROUND

The Workforce Investment Act of 1998 (WIA), Section 188, contains equal opportunity and nondiscrimination provisions. 29 CFR Part 37 implements the nondiscrimination and equal opportunity provisions of WIA. WIA also requires the collection and maintenance of data on program applications, registrants, participants, and program completers.

V. POLICY This policy provides guidance on medical data and information collection and maintenance in case files.

• Generally, medical records will not be maintained; therefore, a case note indicating that the “necessary medical information” was obtained should be entered in the Illinois Workforce Development System (IWDS) and the actual paperwork sent to the school or employer requiring the information.

• If drug testing or a physical is required by an employer as a condition of employment, arrangements will be made with the clinic to have the results mailed directly to the employer.

• If drug screening is required by a training provider (e.g., a CDL training provider) results will be mailed to the training provider and a case note noting that drug test results were mailed to the training provider entered into IWDS.

Northern Illinois Workforce Alliance Medical Data & Information Collection Policy

44

• If medical information/documentation is necessary to determine possible accommodation for individuals for job placement and / or training, such information will be given to the participant and not maintained by the program.

• In exceptional circumstances when medical information must be maintained, a separate file will be established and maintained under strict control by the program agency management.

VI. ACTION REQUIRED

This policy should be distributed to all WIA and WIA/Trade staff, including subcontracted program staff. Participant files will be reviewed by program supervisory staff to ensure compliance. A sampling of files will be reviewed by the EO Officer periodically to ensure compliance with this policy.

VII. EFFECTIVE DATE

Upon issuance

VIII. EXPIRATIOM DATE Continuing

Northern Illinois Workforce Alliance Personally Identifiable Information Policy

45

The following Northern Illinois Workforce Alliance Policy is based on the Personally Identifiable Information (PII) Requirements in U.S. Department of Labor Employment and Training Administration’s Training and Employment Guidance Letter (TGEL) No. 39-11, Guidance on the Handling and Protection of Personally Identifiable Information, issued June 28, 2012. Most of the language of the Policy below is taken directly from TGEL No. 39-11.

Northern Illinois Workforce Alliance

POLICY ON THE HANDLING AND PROTECTION

OF PERSONALLY IDENTIFIABLE INFORMATION (PII)

Policy Adopted 2/5/13

Purpose: To provide guidance to 1) the Northern Illinois Workforce Alliance’s WIB staff, 2) the Fiscal Agent for funds approved by the WIB, 3) One-Stop Operators, and 4) subcontracted Workforce Investment Act (WIA) programs (hereafter collectively referred to as local WIA administrative and service providers) on compliance with the requirements of handling and protecting PII for customers of the One-Stop system who receive services funded with federal Department of Labor (DOL) Employment and Training (ETA) funds channeled to the local area directly or through the state. Definitions:

• PII-- OMB Memorandum M-07-16, Safeguarding Against and Responding to Breach of Personally Identifiable Information (May 22, 2007) defines PII as information that can be used to distinguish or trace an individual’s identity, either alone or when combined with other personal or identifying information that is linked or linkable to a specific individual.

• Sensitive Information—Any unclassified information whose loss, use, misuse, or unauthorized

access to or modification of could adversely affect the interest or the conduct of Federal programs, or privacy to which individuals are entitled under the Privacy Act of 1974.

• Protected PII and non-sensitive PII -- DOL has defined two types of PII, protected PII and non-sensitive PII. The differences between protected PII and non-sensitive PII are primarily based on an analysis regarding the “risk of harm” that could result from the release of the PII. 1. Protected PII is information that if disclosed could result in harm to the individual whose

name or identity is linked to that information. Examples of protected PII include, but are not limited to, social security numbers (SSNs), credit card numbers, bank account numbers, home telephone numbers, ages, birthdates, marital status, spouse names, educational history, biometric identifiers (fingerprints, voiceprints, iris scans, etc.), medical history, financial information and computer passwords.

2. Non-sensitive PII, on the other hand, is information that if disclosed, by itself, could not reasonably be expected to result in personal harm. Essentially, it is stand-alone information that is not linked or closely associated with any protected or unprotected PII. Examples of non-sensitive PII include information such as first and last names, e-mail addresses, business addresses, business telephone numbers, general education credentials, gender, or race. However, depending on the circumstances, a combination of these items could potentially be categorized as protected or sensitive PII.

Northern Illinois Workforce Alliance Personally Identifiable Information Policy

46

To illustrate the connection between non-sensitive PII and protected PII, the disclosure of a name, business e-mail address, or business address most likely will not result in a high degree of harm to an individual. However, a name linked to a social security number, a date of birth, and mother’s maiden name could result in identity theft.

Requirements: Federal law, Office of Management and Budget (OMB) Guidance, DOL and ETA polices require that PII and other sensitive information be protected. To ensure compliance with Federal law and regulations, local WIA Administrative and service providers must secure transmission of PII and sensitive data developed, obtained, or otherwise associated with grants/contracts funded by ETA directly or through the state. In addition to the above requirement, local WIA administrative and service providers must comply with all of the following:

• To ensure that such PII is not transmitted to unauthorized users, all PII and other sensitive

data transmitted via e-mail or stored on CDs, DVDs, thumb drives, etc., must be encrypted using a Federal Information Processing Standards (FIPS) 140-2 compliant and National Institute of Standards and Technology (NIST) validated cryptographic module (http://csrc.nist.gov/publications/fips/fips140-2/fips1402.pdf). Local WIA administrative and service providers must not e-mail unencrypted sensitive PII to any entity.

• Local WIA administrative and service providers must take the steps necessary to ensure the

privacy of all PII obtained from participants and/or other individuals and to protect such information from unauthorized disclosure. They must maintain such PII in accordance with the standards for information security described in this Policy and any updates to such standards issued by DOL.

• Local WIA administrative and service providers shall ensure that any PII used during the

performance of their grant/contract has been obtained in conformity with applicable Federal and state laws governing the confidentiality of information. They shall further acknowledge that all PII data obtained through grants/contracts funded with federal monies shall be stored in an area that is physically safe from access by unauthorized persons at all times and the data will be processed using equipment, managed information technology (IT) services, at designated locations approved by the WIB. Accessing, processing, and storing of PII data on personally owned equipment, at off-site locations, e.g., employee’s home, and non-grantee managed IT services, e.g., Yahoo mail, is strictly prohibited unless approved by the WIB.

• Employees and other personnel who will have access to

sensitive/confidential/proprietary/private data must be advised of the confidential nature of the information, the safeguards required to protect the information, and that there are civil and criminal sanctions for noncompliance with such safeguards that are contained in Federal and state laws.

• Local WIA administrative and service providers must have their policies and procedures in

place under which their employees and other personnel, before being granted access to PII, acknowledge their understanding of the confidential nature of the data and the safeguards with which they must comply in their handling of such data as well as the fact that they may be liable to civil and criminal sanctions for improper disclosure.

Northern Illinois Workforce Alliance Personally Identifiable Information Policy

47

• Local WIA administrative and service providers must not extract information from data supplied by their funding source for any purpose not stated in the grant or contract agreement.

• Access to any PII created by the grant or contract funded with federal monies must be

restricted to only those employees of the grant/contract recipient who need it in their official capacity to perform duties in connection with the scope of work in the grant/contract agreement.

• All PII data must be processed in a manner that will protect the confidentiality of the

records/documents and is designed to prevent unauthorized persons from retrieving such records by computer, remote terminal or any other means. Data may be downloaded to, or maintained on, mobile or portable devices only if the data are encrypted using NIST validated software products based on FIPS 140-2 encryption. In addition, wage data may only be accessed from secure locations.

• PII data obtained by local WIA administrative or service providers through a request from

their funder must not be disclosed to anyone but the individual requestor except as permitted by the grant/contract provider.

• Local WIA administrative and service providers must permit their funder to make onsite

inspections during regular business hours for the purpose of conducting audits and/or conducting other investigations to assure that they are complying with the confidentiality requirements described above. In accordance with this responsibility, local WIA administrative and service providers must make records applicable to the grant/contract Agreement available to authorized persons for the purpose of inspection, review, and/or audit.

• Local WIA administrative and service providers must retain data received from ETA-

funded grants only for the period of time required to use it for assessment and other purposes, or to satisfy applicable local/ state/ Federal records retention requirements, if any. Thereafter, the grantee agrees that all data will be destroyed, including the degaussing of magnetic tape files and deletion of electronic data.

An ETA-funded grantee’s/subcontractor’s failure to comply with the requirements identified in this Policy, or any improper use or disclosure of PII for an unauthorized purpose, may result in the termination or suspension of the grant/contract, or the imposition of special conditions or restrictions, or such other actions as the applicable grant/contract administrator may deem necessary to protect the privacy of participants or the integrity of data.

Recommendations: Protected PII is the most sensitive information that staff may encounter in the course of their ETA-funded grant/contract work, and it is important that it stays protected. Grantees/subcontractors are required to protect PII when transmitting information, but are also required to protect PII and sensitive information when collecting, storing and/or disposing of information as well. Outlined below are some recommendations to help protect PII:

• Before collecting PII or sensitive information from participants, have participants

sign releases acknowledging the use of PII for grant purposes only.

• Whenever possible, ETA recommends the use of unique identifiers for participant

Northern Illinois Workforce Alliance Personally Identifiable Information Policy

48

tracking instead of SSNs. While SSNs may initially be required for performance tracking purposes, a unique identifier could be linked to the each individual record. Once the SSN is entered for performance tracking, the unique identifier would be used in place of the SSN for tracking purposes. If SSNs are to be used for tracking purposes, they must be stored or displayed in a way that is not attributable to a particular individual, such as using a truncated SSN.

• Use appropriate methods for destroying sensitive PII in paper files (i.e., shredding or

using a burn bag) and securely deleting sensitive electronic PII.

• Do not leave records containing PII open and unattended.

• Store documents containing PII in locked cabinets when not in use.

• Immediately report any breach or suspected breach of PII to the funding source administrator responsible for the grant/contract. This individual will investigate the breach and, when necessary, report it to state and DOL (Jerry Yeoward, Illinois Department of Commerce and Economic Opportunity Office of Employment and Training [email protected] ETA Information Security at [email protected], 202-693-3444). Local staff will follow any instructions received from officials of the state or Department of Labor.

Northern Illinois Workforce Alliance Allowable Trade Training-Related Expenses Policy

49

ALLOWABLE TRADE TRAINING-RELATED EXPENSES POLICY

Effective February 5, 2014 Approved by Northern Illinois Workforce Alliance: 3/4/14

The language in this Policy is from IL Department of Commerce and Economic Opportunity TRADE NOTICE NO. 13-TAA-02 issued February 5, 2014. BACKGROUND The TAA regulations allow for the payment of tuition associated with Trade approved training classes or programs, as well as reasonable expenses when a participant attends training. The IL Department of Commerce and Economic Opportunity, Office of Employment and Training (OET) clarified those expenses considered allowable and the reasonable amount of such expenses. Training related consumables has been added to the list of allowable expenses that includes supplies, transportation, and subsistence. In conjunction with TAA Notice 12-TAA-01, Trade Travel Assistance (April 9, 2013), the case manager should have the information necessary to determine the allowable expenses available to participants in training. This change applies to all participants of the Trade Adjustment Assistance (TAA) Act, Trade and Globalization Adjustment Assistance Act (TGAAA) of 2009, Trade Adjustment Assistance Extension Act (TAAEA) of 2011, and Trade Adjustment Assistance Reversion of 2014 (Reversion of 2014) programs, as well as new or amended programs signed into law. POLICY The Trade Program, encompassing TAA, TGAAA, TAAEA, and Reversion of 2014 and subsequent new or amended programs, allows for the payment or reimbursement of training related expenses that may be incurred by an eligible participant while participating in TAA approved training.

A. Illinois has set a “soft cap” of $20,000 on the complete cost of training. This includes all of the below listed categories of allowable costs. (Please refer to WIA Policy Letter 09-PL-52 and WIA Notice 08-NOT-37, Change 1 for more details on determining reasonableness of costs for training.)

B. Those items that are considered allowable include:

1. Tuition including the cost of the training class or program and any academic fees associated with enrollment and participation in the training as assessed by the training provider such as registration and graduation fees, student activity, health service, and laboratory.

2. Supplies that are required by all students attending the training class or program. a. Only items detailed in the syllabus of a class(es) as necessary for all students

participating will be reimbursed. b. Items must be reasonable in cost--i.e., if a similar item is available at a lesser cost, the

lesser cost should be the reimbursement rate. c. The list of supplies may include books, tools, equipment, uniforms, and other required

items. 1) Examples of required items could include mechanic’s tools, medical devices,

scientific or business calculators, cameras, cutlery, etc.)

Northern Illinois Workforce Alliance Allowable Trade Training-Related Expenses Policy

50

2) Case managers should consult with the training provider to determine the number and style of supplies when the syllabus is not clear in this matter. For example, how many uniforms must a participant have when attending a nursing program, how many knives (and what type) and other utensils must a participant in the

culinary arts program have to adequately perfect his/her skills, or how many (and what type) hand and power tools does a participant in the automotive program need to adequately perform service.

3. Training related consumables are those general supplies required by a student to successfully complete his/her training class or program. a. Only items generally used by the majority of students will be allowed. b. Items must be reasonable in cost--i.e., if a similar item is available at a lesser cost, the

lesser cost should be the reimbursement rate. c. Consumables can be classified in two categories for reimbursement purposes:

1) Disposable – items that have a relatively short life such as writing utensils (pens, pencils and highlighters), notebooks, notepads, binders and folders, index cards, post-it notes, paper clips, staples, tape, and glue. (While this list may not be comprehensive, reasonableness of additional items as necessary should be evaluated before determining if reimbursement is allowed.)

2) Non-disposable – items that will need to be purchased only one time and with normal use will remain usable for the entirety of the training program such as a book bag or backpack, computer storage media, stapler, scissors, manual pencil sharpener, and basic calculator.

4. Transportation for those participants required to travel outside their commuting area to attend training. (Please refer to TAA Notice 12-TAA-01 for more details on determining transportation.)

5. Subsistence for those participants required to travel outside their commuting area to attend training. (Please refer to TAA Notice 12-TAA-01 for more details on determining subsistence.)

C. Items that are NOT allowable for reimbursement purposes include licensing, registration, or

expenses related to engaging in an occupation following exit from a training program, computers, printers, electronic devices (not otherwise listed as allowable), desks, chairs, lights, etc. Students should utilize the availability of these items at their home, a library, and/or a dorm rather than seek reimbursement for them.

D. A participant of a Trade approved training class or program, requesting reimbursement and

deemed to be in need of allowable expenses will be subject to the following limits:

1. Tuition, supplies, transportation, and subsistence allowances are detailed in separate policy. The limits are determined by policy and are to be considered when determining the reasonableness of a training class or program for the participant relative to the soft cap.

2. Training related consumables will have the following limits: a. Disposable items will have a maximum combined allowance of $100 per calendar

year. 1) This maximum amount should be prorated according to the number of months the

individual will actually be participating in training. (A single day of participation in any given month can be considered as a month in training for purposes of this calculation.)

2) A student entering training in the Fall semester would have only 5 months of training

Northern Illinois Workforce Alliance Allowable Trade Training-Related Expenses Policy

51

remaining in the year, thus he/she would be entitled to only $42 (5 months of 12, or 42% of a calendar year) of reimbursable allowable items.

3) No reimbursement will be provided to current customers for calendar year 2013.

b. Non-disposable items will have a maximum combined allowance of $200 for the entire program. 1) Individual items (and the like) should only be reimbursed once. 2) Students should be informed that they will be provided this reimbursement only once

so that they know to maintain the items in working condition throughout the program-- i.e., if a student has previously requested and received reimbursement for a new book bag but indicates he/she has damaged it or would like the newest style and color or a new manual stapler but have lost it during the summer months, then the reimbursement request should be denied.

c. ALL requests for reimbursement must be accompanied by a receipt. 1) All receipts should be maintained in the participant’s file and be utilized in

determining remaining balances for a given calendar year or program and made available for monitoring purposes.

d. ALL participants in training must be provided the opportunity to request reimbursement.

Northern Illinois Workforce Alliance ATIM Transportation Assistance Policy

52

ATIM TRANSPORTATION ASSISTANCE POLICY

Effective January 1, 2014 Approved by Northern Illinois Workforce Alliance 3/4/14

Exception for participants using Freeport area public transportation approved 6/3/14, revised 11/4/14. Reimbursement rate for usage of RRTC bus approved 11/4/14, was effective 11/4/14.

Accelerated Training in Manufacturing (ATIM) participants who have a proven need for transportation assistance to attend training, may receive the following transportation assistance: A. Participant Lives 10 or More Miles From Training Site:

Policy: Participants living ten (10) or more miles from training site may receive transportation assistance in the amount approved by GSA. (At the time the policy was effective, the rate was $.56 per mile.) Procedure:

• The participant’s need for transportation assistance will be well documented in case notes. Need will be established by documenting the participant’s attested income and comparing that with the participant’s identified expenses. Case notes will state what other resources to assist participant with transportation have been reviewed and deemed not available/appropriate for the participant.

• The ATIM case manager will complete the Trade Transportation Form #005 to calculate the reimbursement the participant will receive for each day he/she attends ATIM training (to include work experience and OJT). The case manager will use the approved mapping service to determine a participant’s shortest route from home to training site.

• Once need is established a gas card may be issued to address immediate need for transportation assistance to cover the initial 10 days of the training activity. After 10 days of participation in the training activity, reimbursement will based upon attendance will be utilized. Case managers are expected to obtain attendance records and request transportation reimbursement in a manner that does not result in interruption of assistance.

• Transportation reimbursements will be given only for days the participant’s attendance in training is verified via time sheets signed by the participant and the trainer or employer.

• For training activities such as work experience and OJT, as well as initial unsubsidized employment, transportation assistance will only be provided to the program participant until the 1st pay check is received.

• Reimbursement may be issued to the participant through a prepaid gas card rather than a check.

B. Participant Lives Less than 10 miles from Training Site:

Policy: Participants in ATIM-funded Training who live less than 10 miles from training site may receive a transportation allowance of $55 per month or a RMTD monthly bus pass (cost: $55) according to the schedule listed below.

• If a participant begins training on or before the 15th day of the month, he/she will receive a transportation allowance of $55 for this month.

• If a participant begins training after the 15th day of the month, he/she will receive a transportation allowance of $27.50 for this month.

• If a participant ends training on or before the 15th day of the month, he/she will receive transportation allowance of $27.50 for this month.

Northern Illinois Workforce Alliance ATIM Transportation Assistance Policy

53

• If a participant ends training after the 15th day of the month, he/she will receive the full $55 transportation allowance for this month. If a participant is receiving a monthly RMTD bus pass, he/she will receive the bus pass for the full month he/she begins training, regardless of when in the month this occurs.

• If a participant is receiving a monthly RMTD bus pass, he/she will receive the bus pass for the full month he/she ends training, regardless of when in the month this occurs.

Exception: Participants using Freeport area public transportation will receive transportation assistance equal to the amount of the fare needed to attend their scheduled training classes; assistance for one round trip per scheduled training day will be allowed. Proof that the participants attended training on the days for which they receive assistance must be submitted. For WIA and other grant program participants utilizing the RRTC bus, transportation, costs will be reimbursed to RRTC based upon the miles traveled reimbursed at the current federal mileage reimbursement rate plus a pick-up and drop-off fee of $5.00 per participant. The total mileage for the trip will be divided by the number of participants to get a per participant cost of travel plus the pick-up and drop-off fee. This reimbursement arrangement will only apply to program enrollees who live or must travel to work-related training, job fairs, and worksites in Boone County, Stephenson County or points outside of LWIA3. Winnebago County / Rockford area RRTC bus trips will be paid based upon the already established participant rate. Procedure:

• The participant’s need for transportation assistance will be well documented in case notes. Need will be established by documenting the participant’s attested income and comparing that with the participant’s identified expenses. Case notes will state what other resources to assist participant with transportation have been reviewed and deemed not available/appropriate for the participant.

• Transportation allowances will be given only if the participant’s attendance in class is verified via time sheets signed by the participant and the trainer or employer.

• For training activities such as work experience and OJT, as well as initial unsubsidized employment, transportation assistance will only be provided to the program participant until the 1st pay check is received.

The monthly transportation allowance may be issued to the participant through a prepaid gas card rather than a check.

Northern Illinois Workforce Alliance ATIM Adult Service Priority System for Enrollment…

54

ACCELERATED TRAINING IN MANUFACTURING GRANT (ATIM) ADULT SERVICE PRIORITY SYSTEM FOR ENROLLMENT OF INDIVIDUALS

NOT MEETING LOW-INCOME GUIDELINES

Approved by Northern Illinois Workforce Alliance 4/1/14 Revised income eligibility criteria policy 10/3/14

BACKGROUND The Advanced Training in Manufacturing (ATIM) program follows state and federal WIA eligibility for adult program participants: Public Law 105-220 SEC. 134(E) PRIORITY – In the event that funds allocated to a local area for adult employment and training activities under paragraph (2)(A) or (3) of section 133(b) are limited, priority shall be given to recipients for public assistance and other low-income individuals for intensive service and training services. The appropriate local board and the Governor shall direct the one-stop operators in the local area with regard to making determinations related to such priority. IL DCEO requires the local workforce investment board to identify criteria, directly linked to difficulties to securing employment, be used when determining an individual eligible for services if they do not meet the low income eligibility provision. DCEO further requires that the majority of individuals (51%) served as a WIA adult program participant meet the eligibility requirement for income (WIA Policy Letter No. 99-1; August 4, 1999). POLICY In the Accelerating Training in Manufacturing Grant up to 49% of those individuals not meeting eligibility criteria as a designated “dislocated worker” may exceed the low income guidelines for the adult eligibility criteria as long as they meet one or more of the following:

1) Be at least 18 years of age. 2) Be unemployed or employed less than fulltime. 3) If employed, earning less than a self-sufficient income based upon 125% of the LLIL for the County of residence. 4) Have obsolete or outdated marketable skills identified and documented with

unsuccessful job search records and/or lack of required credentials. 5) Meet one or more of the following criteria:

• older individual • veteran • limited English proficiency • previous drug/alcohol dependency • disability affecting employment • offender • displaced homemaker • migrant worker

Criteria will be documented and maintained in the participant file.