WIOAPL 15-11 (Use of Individual Training Accounts [ITA])
Workforce Innovation and Opportunity Act Policy Letter No. 15-11
July 15, 2015
TO: Local Workforce Development Boards (WDBs), Fiscal Agents, and OhioMeansJobs Center Operators
FROM: Cynthia C. Dungey, Director
SUBJECT: Use of Individual Training Accounts (ITA)

I.Purpose

The purpose of this policy is to identify the parameters for development of a local area ITA policy and to standardize the delivery of ITAs so local areas consistently provide training opportunities to participants leading to employment in an in-demand occupation.

II.Effective Date

July 1, 2015

III.Background

Program training services are a structured regimen leading to recognized post-secondary credentials, industry-recognized credentials, employment, and measurable skill gains toward credentials or employment.

To be eligible for training services, the local area must determine whether or not adult or dislocated worker participants, or out-of-school youth participants ages 18-24 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 participants' interests, skills assessment, career exploration, and available labor market information. Eligibility information, combined with assessment information, help determine the need for training assistance. Additionally, local areas must review family self-sufficiency if the ITA is provided to an adult participant ages 18-24 or an out-of-school youth participant. Workforce Innovation and Opportunity Act (WIOA) Policy Letter No. 15-09, Training Services for Adults and Dislocated Workers, and WIOA Policy Letter No. 15-10, Youth Program Services, provide further direction for determining appropriateness for training services for adults, dislocated workers, and out-of-school youth ages 18-24.

An ITA is one of the primary methods through which training is financed and provided for unemployed or underemployed participants. 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.

IV.Requirements

To ensure training is in high demand occupations, and there is consistent service throughout OhioMeansJobs Centers, this policy must be adhered to by Ohio's local workforce development areas.

A.Development of a Local ITA Policy

Each local area is required to develop an ITA policy that includes, but is not limited to, the following criteria:

  • Maximum duration of an ITA;
  • Maximum funding for training financed through ITAs;
  • Allowable costs to complete training financed through ITAs;
  • Other locally defined considerations.

There may be instances where dislocated workers from multiple workforce investment areas are impacted from one business downsizing or one dislocation event. Local areas are encouraged to work with contiguous workforce investment areas to develop consistent eligibility requirements and delivery of services for ITAs. Consistency between contiguous areas is particularly crucial if the ITAs are funded through the rapid response program as a result of a mass lay-off or plant closing or through a national dislocated worker grant.

Maximum Duration of an ITA

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. 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.

There may be instances where a participant is unable to complete the training program within the time frame outlined in the ITA, and the ITA may be extended. These circumstances include, but are not limited to:

  • Military service or leave time;
  • Lack of availability of classes;
  • Cancellations of classes;
  • 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 who the participant has been awarded custody of through a court).

Maximum Funding for Training

When local areas determine the maximum amount for an ITA, the cost must be determined by the average cost of training for specific in-demand occupations within the local area as well as the following criteria:

  • The training investment should be in line with the future wages earned by the participant;
  • The full cost of participating in training services, including the cost of dependent care and transportation, and other appropriate costs; and
  • Factors, such as the cost of training, fees and books, tuition, and other associated costs, should be considered.

Allowable ITA 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:

  • Tuition and fees;
  • Books;
  • Tools;
  • Uniforms;
  • Tests;
  • Medical immunizations/tests.

ITA costs do not include any supportive services' costs related to the ITA (e.g. transportation or child care).

Costs must be reasonable and necessary and must represent a sound investment of public funds.

Other Considerations for Inclusion in Local ITA Policies

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 WIOA funds.

In relation to training, it is the intent that the WIOA funding is the payer of last resort. 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 exceeds the maximum ITA funding limit.

Local areas may implement evaluation and performance requirements for those training providers and programs, which the local area has approved to be on the statewide Eligible Training Provider (ETP) list. Areas may want to review the performance of a provider to determine whether or not 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.In-Demand Occupations

To receive an ITA, a participant must select a training program that is directly linked to employment that is in high demand.

State In-Demand Occupations (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 on a monthly basis.

Each program year, at least 85 percent of new ITA enrollments for the local area must be in an "in-demand" occupation 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.

The link below provides access to in-demand occupation data:

http://jfs.ohio.gov/owd/OMJResources/In-DemandOccupations.stm.

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 (15 percent) may include, but are not limited to:

  • An occupation in a geographic area in which the participant is willing to work or relocate;
  • Employment associated with 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. Ohio Department of Job and Family Services will review adherence to this policy and the federal law during comprehensive monitoring visits.

C.Waiver Request

Waivers may be requested to exceed the 15 percent enrollment 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 be submitted to WIAQNA@JFS.OHIO.GOV. The subject of the email should read, "ITA Waiver Request".

V.Reporting Requirements

Pursuant to rule 5101:9-30-04 of the Administrative Code, the local board shall ensure the timely and accurate reporting of WIOA participants, activities, and performance information by using the Ohio Workforce Case Management System (OWCMS).

VI.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.

VII.Technical Assistance

For additional information, you may send your questions to the Office of Workforce Development: OWDPOLICY@jfs.ohio.gov.

For technical assistance, you may send your request to the Office of Workforce Development: WIAQNA@jfs.ohio.gov.

VIII.References

Workforce Innovation and Opportunity Act, Pub. L. 113-128

20 C.F.R. Parts 603 et al.

29 U.S.C. 3101 et seq.

Ohio Administrative Code rule 5101:9-30-04, Mandated Use of Ohio Workforce Case Management System (OWCMS).

ODJFS, Workforce Innovation and Opportunity Act Policy Letter No. 15-09, Training Services for Adults and Dislocated Workers, (July 1, 2015).

ODJFS, Workforce Innovation and Opportunity Act Policy Letter No. 15-10, Youth Program Services, (July 1, 2015).

Rescission

ODJFS, Workforce Investment Act Policy Letter No. 13-07, Use of Individual Training Accounts (ITA), (March 6, 2014).