I.Purpose
The purpose of this policy is to identify the parameters for
development of a local area Individual Training Account (ITA) policy and to
standardize the delivery of ITAs so local workforce development areas (local
areas) consistently provide training opportunities to participants leading to
employment in an in-demand occupation or critical job.
II.Effective
Date
Immediately
III.Rescission
ODJFS, Workforce Innovation and Opportunity Act Policy Letter
No. 15-11.1, Use of Individual Training Accounts (ITAs), (January 8, 2018).
IV.Background
A program of training services is one or more courses or
classes, or a structured regimen that provides the services that are listed in
20 C.F.R. 680.200 and leads to:
- An industry-recognized certificate or
certification, a certification of completion of a registered apprenticeship, a
license recognized by Ohio or the Federal government, or an associate or
baccalaureate degree;
- A secondary school diploma or its equivalent;
- Employment; or
- Measurable skill gains toward a credential
described in paragraphs 1 and 2 of this section or employment.
To be eligible for training services, the local area or the
Comprehensive Case Management and Employment Program (CCMEP) lead agency must
determine whether adult, dislocated worker, out-of-school youth, and – per
waiver authority – in-school youth participants, are appropriate for training
services.
Determination of appropriateness should be done by completion of
an interview, evaluation or assessment, and career planning. Assessment may
include, among other things;
- A combination of standardized tests;
- Inventory of participant's interests, skills
assessment, career exploration; and
- Available labor market information.
Training services must be provided in a manner which maximizes
informed consumer choice in selecting an eligible provider. When participants
and local areas select an eligible training provider, they should consider
providers who are eligible for financial aid to ensure best utilization of
Workforce Innovation and Opportunity Act (WIOA) funds.
A.Individual
Training Accounts
Eligibility information, combined with assessment information,
help determine the need for training assistance. Additionally, local areas or
CCMEP lead agencies must review family self-sufficiency if the ITA is provided
to an adult or youth participant age 18-24. WIOAPL No. 15-09.1, Training Services for Adults and Dislocated Workers,
and WIOAPL No. 15-10, Youth Program Services,
provide further direction for determining appropriateness for training services
for adults, dislocated workers, and youth. Limits to training services may be
based on the needs of the adult, dislocated worker, or youth and identified in
the individual employment plan or the individual service strategy, such as the
participant’s occupational choice or goal and the level of training to succeed
in that goal.
Training services for adults, dislocated workers, and youth are
typically delivered by training providers who receive payment for their
services through an ITA. An ITA is a key tool used in the delivery of training
services and is the primary method through which training is financed and
provided. ITAs are established on behalf of the WIOA participant to purchase a
program of training services from eligible providers selected in consultation
with the case manager. Additionally, the cost of training, time commitment of
the participant, fees and books, tuition, and other associated costs should be
considered when conducting a cost benefit analysis for the ITA.
Per WIOAPL No. 15-09.1, WIOAPL No. 15-10, and rule 5101:14-1-02
of the Administrative Code, training services for which ITAs are used shall
only be delivered by providers who have met the provider eligibility criteria
and have at least one approved program on the Workforce Inventory of Education
and Training (WIET) pursuant to section 122 of WIOA.
Training services under ITAs must be provided in a manner that
maximizes informed customer choice in selecting an eligible training provider. Each
local workforce development board (WDB), through the OhioMeansJobs center, must
make the State list of eligible training providers available to job seekers.
The local WDB may also coordinate funding for ITAs with funding
from other Federal, State, local, or private job training programs or sources
to assist the individual in obtaining training services.
Priority consideration must be given to training programs that
lead to recognized postsecondary credentials that are aligned with in-demand
industry sectors or critical jobs in the local area.
B.Registered Apprenticeship Programs and
Individual Training Accounts
Registered apprenticeship is a proven model of job preparation
that combines paid on-the-job training (OJT) with related instruction to
progressively increase a workers’ skill levels and wages.Registered apprenticeship is also a
proven business-driven model that provides an effective way for employers to
recruit, train, and retain highly skilled workers Graduates of registered
apprenticeship programs receive nationally recognized, portable credentials,
and in some instances their training may be applied toward further
postsecondary education.
Only registered apprenticeship programs that have been approved
by the Ohio Department of Job and Family Services (ODJFS) as recognized State
apprenticeship programs, will be permitted to enter into ITAs with local areas
to fund the educational portion of the registered apprenticeship for eligible
apprentices.
All registered apprenticeship programs approved by ODJFS are
automatically approved as eligible training providers and included on Ohio’s
eligible training provider list contained on WIET.
ITAs may also be used to finance State-recognized
pre-apprenticeship training in preparation for the formal registered
apprenticeship training if the pre-apprenticeship program training provider has
been approved as an Ohio eligible training provider and is listed on WIET per
WIOAPL No. 16-02.1, Eligible Training Providers.
C.Industry-Recognized Apprenticeship
Programs and Individual Training Accounts
Industry-Recognized Apprenticeship Programs (IRAPs) are
high-quality apprenticeship programs recognized as such by a Standards
Recognition Entity (SRE) pursuant to the DOL’s standards. These programs
provide individuals with opportunities to obtain workplace-relevant knowledge
and progressively higher skills. IRAPs include a paid-work component and an
educational component and result in an industry-recognized credential. An IRAP
is developed or delivered by entities such as trade and industry groups,
corporations, non-profit organizations, educational institutions, unions, and
joint labor-management organizations.
IRAPs fall under the umbrella of training services under WIOA
section 134(c)(3)(D). ITAs may be used to finance the training component
of IRAPs if the program and training provider has been approved as an Ohio
eligible training provider and is listed on WIET per WIOAPL No. 16-02.1, Eligible Training Providers.
D.Considerations
for Funding Individual Training Accounts
Duration of ITAs
The duration of an ITA is determined by a participant’s course
of study. Realistic and attainable training plans must be considered.
Generally, training is either short-term or long-term. Short-term training is
training which is completed in 12 months or less. Short-term training is the
preferred method since the goal is to attain employment quickly.
However, the local areas must keep in mind the participant's
career pathway, and the training and services necessary to meet the
participant's goal. For instance, the classroom training portion of a
Registered Apprenticeship program is typically longer than a year. However,
this training is part of a career pathway involving longer training, and the
apprentice is also simultaneously employed.
Long-term training is training whose length does not exceed 24
months. Four-year degree programs may be funded when the customer can document
that he or she is in the last two years of the program (e.g., remaining hours
are equal to or less than 50 percent of the total credit hours required for the
degree) and is in an in-demand occupation or critical job.
The following exceptions to the 24-month limit on long-term ITA
training are permitted:
1.ITA-funded
training necessary to enter occupations of state
strategic priority may continue for up to 48 months. This is to enable and
encourage the completion of baccalaureate degrees in vital career fields, such
as critical jobs which directly support the health and well-being of Ohioans.
2.Because of all
the benefits of a registered apprenticeship program, including an established
career pathway and simultaneous employment, the classroom training portion of
the Registered Apprenticeship programs may be up to 4 years in length. For this
program, the local areas may fund the full length of the training.
3.In instances
where a participant is unable to complete the training program within the time
frame outlined in the ITA, the ITA may be extended. While determinations have
to be based on the factual circumstances of each case, some instances when more
time may be warranted include, but are not limited to, those directly related
to:
- A participant's military service or
military-related leave time;
- Lack of availability of classes;
- Cancellations of classes; or
- Unforeseen illness (of the participant or an
immediate family member of the participant). For the purposes of this policy,
immediate family members include the participant’s parents (including
step-parents), spouse, domestic partner, and children (including step-children
or children of whom the participant has been awarded custody through a court).
Funding ITAs
The cost for ITAs are determined by the average cost of training
for specific in-demand occupations or critical jobs within the local area as
well as the following criteria:
1.
Whether the training investment is in line with
the future expected earnings of the participant;
2.
Whether the training is being provided as part
of the registered apprenticeship program; and
3.
Consideration of the full cost of participating
in training services, including costs for fees and books, tuition and other
associated costs.
Allowable Individual Training Account
Costs
ITA expenditures are costs required by the training institution
to complete the training. ITA costs required to complete the training may
include, but are not limited to:
1.Tuition and
fees;
2.Books;
3.Tools;
4.Uniforms;
5.Tests; and
6.Medical
immunizations/tests.
ITA costs do not include any supportive services' costs related
to the ITA (e.g. transportation or childcare).
E.In-Demand
Occupations and Critical Jobs
To receive an ITA, a participant must select a training program
that is directly linked to employment that is in high demand or considered
critical through state strategic priority.
1.State In-Demand Occupations and Critical Jobs (85 Percent)
In-demand occupations were chosen using various industry- and
occupation-focused measures. These measures include: projected openings;
projected growth; select JobsOhio industry cluster occupations; and historic
job posting data. The list of in-demand occupations will be validated or
further enhanced using business data from the online Workforce Information
Exchange job forecasts monthly.
Critical jobs are determined through state strategic priority
and considered critical to the health and well-being of Ohioans, their
families, and our communities. Some examples of critical jobs may include
occupations in early childhood education, mental/behavioral health, and
recovery.
Each program year, at least 85 percent of new ITA enrollments
for the local area must be in an in-demand occupation or critical job as
defined by the state of Ohio. Participants who have a current program year
training service start date and whose ITA will carry into the next program
year, will not be counted in the next program year’s percentage.
Ohio's Top Jobs List includes both In-Demand Jobs and Critical
Jobs. TheTop Jobs link below provides access to in-demand occupation and
critical jobs data: https://topjobs.ohio.gov/wps/portal/gov/indemand/top-jobs-list.
2.Local Area In-Demand Occupations (15 Percent)
The remaining 15 percent of ITA enrollments for the local area
may be for occupations defined as in-demand within the local area. Some
examples of local area in-demand occupations may include, but are not limited
to:
- A local in-demand occupation in a geographic
area to which the participant is willing to work or relocate;
- Employment associated with a regional industry
sector or career pathway consortium for workforce development;
- A written guarantee of a bona fide job upon
completion of training.
Appropriate documentation must be maintained in the case files.
ODJFS will review adherence to this policy and the federal law during
comprehensive monitoring visits.
V.Local
Workforce Development Area Requirements
A.Development
of a Local ITA Policy
Each local WDB is required to develop an ITA policy. There may
be instances where dislocated workers from multiple local areas or a planning
region are impacted from one business downsizing or one dislocation event.
Local areas are encouraged to work with contiguous local areas and other local
areas in the same planning region to develop consistent eligibility
requirements and delivery of services for ITAs. Consistency between contiguous
local areas and planning regions is particularly crucial if the ITAs are funded
through the rapid response program because of a mass layoff or employer closing
or through a national dislocated worker grant.
The local WDB’s ITA policy must include, but is not limited to,
the following criteria:
Maximum duration of an ITA
For the Registered Apprenticeship program, the length of
training and the skills and competencies required for mastery of an occupation
are set by industry. Traditional registered apprenticeship programs are
time-based and require a specific number of hours of OJT and related
instruction. As such, local WDBs should make allowances in their local ITA
policies to accommodate the required training hours for a registered
apprenticeship program.
Similarly, the local WDB may permit up to 48 months of training
for critical jobs of state strategic priority as approved by ODJFS. In this
case, the local ITA policy must identify the ODJFS-approved occupations for
which the local WDB will permit the extended training period, such as by
referencing critical job data at this link:
https://topjobs.ohio.gov/wps/portal/gov/indemand/top-jobs-list
Maximum funding for training financed
through ITAs
The local WDB may establish a range of amounts and/or a maximum
amount applicable to all ITAs. This limitation must not be implemented in a
manner that undermines WIOA’s requirement for training services to be provided
in a manner that maximizes customer choice in the selection of an eligible
training provider.
The local WDB may also allow for additional ITA funding limits
for those enrolled in a registered apprenticeship program. Additional federal
funding for registered apprenticeship programs is available through several
federal agencies to support business investments in apprentices and to assist
educators and intermediaries in strengthening the tie between training and
employment through registered apprenticeship. The Department of Labor’s
Training and Employment Guidance Letter No. 13-16 provides websites for several
registered apprenticeship funding resources.
Furthermore, the policy must contain language that would allow a
way to override the maximum funding cap based upon the needs of the individual,
the selected program of training services, and/or other criteria established by
the local board.
Allowable costs to complete training
financed through ITAs
Costs must be reasonable and necessary and must represent a
sound investment of public funds.
Other locally defined considerations
A comprehensive assessment of the cost of the ITA, which
involves accessing other grants or funding, including Federal Pell Grants,
Trade Adjustment Assistance (TAA), and scholarships, must be conducted to
ensure best utilization of WIOA funds. The local area should utilize all
financial aid resources available to minimize any out-of-pocket expense to the
participant. The local ITA policy should not be so limited that a participant
cannot be served because the training in an in-demand occupation or critical
job exceeds the maximum ITA funding limit.
Local WDBs may implement evaluation and performance requirements
for those training providers and programs, which the State and/or local area
has approved to be on the statewide Eligible Training Provider (ETP) list
contained on WIET. Local WDBs may want to review the performance of a provider
to determine whether the training provider meets established local program and
cost requirements. If a training provider does not meet the performance
requirements, local areas may choose not to use the provider. Criteria to be
considered for evaluation may include, but is not limited to, ability to accept
financial aid and grants, availability of student support, graduation rates,
placement rates, and wage rates of the graduates from the institution.
B.Waiver
Request
Each program year, at least 85 percent of new ITA enrollments
for the local area must be in in-demand occupations or critical job as defined
by the State. The remaining 15 percent of ITA enrollments for the local area
may be for occupations defined as in-demand for the local area.
In situations where the local area may exceed the 15 percent
enrollment requirement for local “in-demand” occupations, the local WDBs may
request a waiver to exceed this requirement. Waivers will be approved on a case
by case basis. The waiver template must be completed providing the appropriate
justification for the waiver and submitted to WIOAQNA@JFS.OHIO.GOV. The subject of the
email should read, "ITA Waiver Request."
VI.Reporting
Requirements
Pursuant to rule 5101:9-30-04 of the Administrative Code, the
local board shall ensure, within 30 days, accurate reporting of WIOA
participants, activities, case management, and performance information by using
the Ohio Workforce Case Management System (OWCMS).
VII. Monitoring
At the local level, the local area must conduct oversight of the
implementation of the WIOA programs to ensure that participants are enrolled in
the programs and have been provided identified services.
Through the state’s monitoring system, program monitors will
review the local area’s implementation of the WIOA programs, including a
participant file review, during the annual onsite monitoring review for
compliance with federal and state laws and regulations. Any issues will be
handled through the state’s monitoring resolution process.
VIII. Technical
Assistance
For technical assistance, you may send your request to the
Office of Workforce Development: WIOAQNA@jfs.ohio.gov.
IX.References
Workforce Innovation and Opportunity Act, §§ 122 and 134, Pub.
L. 113-128
20 C.F.R. §§ 680.300-680.340, 680.410-420, and 680.450.
29 U.S.C. 3101 et seq.
O.A.C. 5101:9-30-04, and 5101:14-1-02.
USDOL, Training and Employment Guidance Letter No. 19-16,
Guidance on Services provided through the Adult and Dislocated Worker Programs
under the Workforce Innovation and Opportunity Act (WIOA) and the Wagner-Peyser
Act Employment Services (ES), as amended by Title III of WIOA, and for
Implementation of the WIOA Final Rules, (March 1, 2017).
USDOL, Training and Employment Guidance Letter No. 13-16,
Guidance on Registered Apprenticeship Provisions and Opportunities in the
Workforce Innovation and Opportunity Act (WIOA), (January 12, 2017).
USDOL, Training and Employment Guidance Letter No. 41-14,
Workforce Innovation and Opportunity Act (WIOA or Opportunity Act) Title I
Training Provider Eligibility Transition, (June 26, 2015).
ODJFS, Workforce Innovation and Opportunity Act Policy Letter
No. 15-09.1, Training Services for Adults and Dislocated Workers, (January 8,
2018).
ODJFS, Workforce Innovation and Opportunity Act Policy Letter
No. 15-10, Youth Program Services, (July 15, 2015).
ODJFS, Workforce Innovation and Opportunity Act Policy Letter
No. 16-02.1, Eligible Training Providers, (May 28, 2019).
Attachment A: Use of
Individual Training Accounts Glossary