WIOAPL 15-15.2 (Rapid Response Program Requirements - Employer Closure, Mass Layoff, Disaster Mass Job Dislocation, and Trade Adjustment Assistance Events)
Workforce Innovation and Opportunity Act Policy Letter No. 15-15.2
April 11, 2018
TO: Workforce Innovation and Opportunity Act Local Workforce Development Boards Directors, Fiscal Agents, and OhioMeansJobs Center Operators
FROM: Cynthia C. Dungey, Director
SUBJECT: Rapid Response Program Requirements - Employer Closure, Mass Layoff, Disaster Mass Job Dislocation, and Trade Adjustment Assistance Events

I.          Purpose

Ohio is committed to providing workforce solutions throughout the business cycle, including the delivery of rapid response (RR) activities. The purpose of this policy is to outline the requirements for delivery of RR program services during an employer closure, mass layoff, disaster mass job dislocation, and/or filing of a Trade Adjustment Assistance (TAA) petition event.

II.         Effective Date

Immediately

III.        Rescission

ODJFS, Workforce Innovation and Opportunity Act Policy Letter No. 15-15.1, Rapid Response Program Requirements – Employer Mass Layoff, Employer Closure, and Trade Adjustment Assistance Events, (January 23, 2017).

IV.       Background

RR is a series of activities provided by the State in partnership with the local workforce development areas (local area), to assist dislocated workers in obtaining reemployment as soon as possible, when one or more of the following circumstances occur:

1.         Announcement or notification of a permanent closure, regardless of the number of workers affected;

2.         Announcement or notification of a mass layoff;

3.         A mass job dislocation resulting from a natural or other disaster; or

4.         The filing of a TAA petition.

The purpose of RR is to promote economic recovery and vitality by developing ongoing, comprehensive approaches to identifying, planning for, or responding to layoffs and dislocations, and preventing or minimizing their impacts on workers, businesses, and communities. Ohio's RR delivery system strengthens partnership, communication, professional development, accountability, and timely access to needed services for employers and impacted workers. Rapid reemployment is the central purpose of RR and is done by helping workers impacted by an employer closure, mass layoff, disaster mass job dislocation, and/or TAA petition filing event quickly transition to new employment, minimizing the duration of unemployment, or averting layoff when possible.

Under section 134(a)(2)(A)(i) of the Workforce Innovation and Opportunity Act (WIOA) and 20 C.F.R. 682.310, each state is responsible for providing RR activities. Through coordinated efforts, Ohio will utilize a combination of state/local teams, as well as eligible service providers to be most effective in serving at-risk workers and employers.

Collaboratively, building and preserving relationships with employers will improve local team effectiveness by enhancing the focus on current and future workforce needs of local businesses and industry. Through this partnership, teams can strategically avert layoffs or minimize their impact, reduce the duration of unemployment, and positively affect the local economy. Ohio's RR program can and should bring together government, education and training resources to not only meet the needs of the business community, but to exceed those needs throughout all phases of the business cycle.

The Ohio Department of Job and Family Services (ODJFS), Office of Workforce Development (OWD) is the agency responsible for the administration of WIOA and RR programs. The OWD RR Unit will oversee Ohio's RR program to ensure compliance with federal and state requirements.

If a layoff occurring in the local area does not meet the RR event definition, the local area is still required to provide WIOA Title I services to eligible dislocated workers affected by the layoff. Pursuant to section 134(c)(1) of WIOA, dislocated worker formula funds allocated to the local area shall be used to establish a workforce delivery system, to provide career services to dislocated workers, to provide training services to dislocated workers, to establish and develop relationships with large and small employers, and to develop, convene, or implement industry and sector partnerships. The local workforce development boards (WDBs) determine the most appropriate mix of these services, and both career and training services must be available to eligible dislocated workers. It is expected that the local area will provide career and/or training services to dislocated workers whose dislocation does not meet the threshold for RR program services using the local area's dislocated worker program formula funds.

A.        Rapid Response Employer Event Determination

The classification of an event is without regard to the industry, size of the employer, number of individuals potentially impacted, or the time between notification and layoff date. Pursuant to section 134(a)(2)(A)(i)(II) of WIOA, RR activities provide additional assistance to local areas that experience employer closures, mass layoffs, disaster mass job dislocations, or TAA petition filings that precipitate substantial increases in the number of unemployed individuals. RR services and activities should be provided to all employers who experience an RR event regardless of how the RR team was notified of the event.

There are two types of RR events:

1.         Worker Adjustment and Retraining Notification (WARN) Event – Any employer that provides written notice of a mass layoff or closure with intent to meet the federal WARN requirements.

2.         Non-WARN Event – Any employer experiencing a mass layoff or closure, even if it is not subject to the federal WARN requirements.

B.        Provision of Required Rapid Response Activities for RR Events

As part of the local area RR service delivery system and pursuant to 20 C.F.R. 682.330, the State, working in conjunction with the local WDBs and American Job Centers (which in Ohio are known as OhioMeansJobs centers), must have the following array of services available, as needed, for local employers and affected workers:

1.         Immediate and on-site contact with the employer, representatives of the affected workers, and the local community, including an assessment of and plans to address the:

a.         Layoff plans and schedules of the employer;

b.         Background and probable assistance needs of the affected workers;

c.         Reemployment prospects for workers; and

d.         Available resources to meet the short and long-term assistance needs of the affected workers;

2.         The provision of information about and access to unemployment compensation benefits and programs, such as short-time compensation (e.g., SharedWork Ohio), comprehensive OhioMeansJobs Center services, and employment and training activities, including information on the TAA program, Pell Grants, the GI Bill, and other resources;

3.         The delivery of other available services and resources including workshops and classes, use of worker transition centers (which must complement, not replace, the OhioMeansJobs center), and job fairs, to support reemployment efforts of affected workers;

4.         Partnership with the local WDBs and chief elected official(s) to ensure a coordinated response to the dislocation event and, as needed, obtain access to State and local economic development assistance. Such coordinated response may include the development of an application for a national dislocated worker grant;

5.         The provision of emergency assistance adapted to the mass layoff;

6.         Delivery of services to worker groups for which a petition for TAA has been filed; and

7.         The provision of limited, additional assistance to local areas that experience RR events when such events exceed the capacity of the local area to respond with existing resources.

The above list represents the minimum services that must be readily available and should be offered with the end goal of rapid reemployment. Pursuant to 20 C.F.R. 682.340, a state or designated entity may devise RR strategies or conduct activities that are intended to minimize the negative impacts of dislocation on workers, businesses, and communities, to ensure rapid reemployment for workers affected by RR events. When circumstances allow, the RR team may provide guidance.

Activities for Unemployment Compensation Claimants

Additionally, to assist workers impacted by employer layoff and closure events, House Bill 2 (130th General Assembly) made changes to Ohio Revised Code section 4141.29 of Ohio's Unemployment Compensation law by requiring claimants to connect with job opportunities and to participate in reemployment activities through the OhioMeansJobs.com system and/or OhioMeansJobs centers. The JFS 55213, Worker's Guide to Unemployment Compensation, provides additional guidance on required reemployment activities and may be found at http://www.odjfs.state.oh.us/forms/file.asp?id=2187&type=application/pdf

C.        The Rapid Response Team

1.         Responsibility of the Rapid Response Team

For RR events that have occurred within the previous 6 months, the RR team will work collaboratively to:

a.         Develop a process to address calls from employers and potentially affected workers (PAWs) requesting information regarding federal and state programs and their requirements (e.g., WARN, Short-term Compensation, Unemployment Compensation, or TAA);

b.         Identify the range of skills and abilities of the affected workforce and compare with local workforce needs to match the affected workers with job vacancies for rapid reemployment;

c.         Develop a coordinated service delivery plan that identifies the strategies to engage local employers in rapid reemployment activities and identifies the outreach strategies needed to highlight the skills of the PAWs. The plan must utilize resources, such as on-the-job training (OJT) and/or customized training, which will most effectively serve both the PAWs and the targeted employer's needs;

d.         Examine the potential impact of an RR event on other employers whose business is dependent on the employer experiencing an RR event (e.g., upstream and downstream customers) to determine an appropriate course of action to connect impacted companies to RR early intervention services; and

e.         Ensure PAWs register in OhioMeansJobs.com to increase reemployment opportunities.

2.         Rapid Response Team Protocol

Establishing a standard local area protocol among all RR team members results in a more effective local team response to layoffs and closures, impacts the service delivery outcome, and creates an environment for proactive RR.

The RR team protocol is a result of conducting a responsibility assignment exercise known as the RACI (Responsible, Accountable, Consulted, Informed), which clearly describes the role(s) of each team member in the completion of RR tasks and activities. The RACI should provide a clear depiction of each RR activity and associated tasks and the role each team member needs to perform in order to deliver workforce solutions effectively and efficiently to RR customers. The protocol should take into consideration the role of the TAA representative as it pertains to administration of RR activities when a TAA petition has been filed.

The RACI, when applied to the RR process, looks at each role and function of RR and helps local teams determine who is:

a.         Responsible – the individual who does the job;

b.         Accountable – the individual(s) who is/are ultimately accountable for the action, task, or function;

c.         Consulted – the individual(s) who need(s) to be consulted prior to a final decision or action being taken; and

d.         Informed – the individual(s) who need(s) to be informed after a final decision or action is taken.

3.         RR Events Affecting Multiple Local Areas and Planning Regions

WIOA envisions a workforce development system that is customer-focused on both the job seeker and business, and anticipates and responds to the needs of regional economies. It requires that local WDBs and chief elected officials design and govern the system regionally, aligning workforce policies and services with regional economies and supporting service delivery strategies tailored to those needs. As businesses pull resources and employees from various workforce development areas, it is important that local areas and planning regions address RR processes on a regional basis, ensuring that policies and procedures pertaining to the delivery of RR services are aligned to minimize confusion for the business community. Specifically, local areas must coordinate with one another should an employer closure, mass layoff, disaster mass job dislocation, or TAA petition filing occur affecting multiple local areas, including reemployment service delivery and requests for funding.

V.        Definitions

Disaster mass job dislocation: Any reduction in force, due to a disaster as defined by state or local emergency management policy, that does not result in a total plant/branch/office closing, but still results in the filing of a Worker Adjustment and Retraining Notification Act notice, regardless of the number of workers affected by the layoff announced; or, if no WARN correspondence is issued, employment loss at a single site of employment for:

1.         At least 25 percent of employees; or

2.         At least 50 employees.

Employer: An individual, business, company, firm, agency, organization, etc. that employs one or more people.

Employer closure: The permanent shutdown of an Ohio business, facility or agency.

Event: Any situation in which workers are at risk of layoff from a downsizing or closure of an employer’s Ohio business, facility, or agency.

Layoff: A separation due to the lack of work or other factor(s) not related to the behavior or performance of the employee.

Local rapid response coordinator (LC): An individual representing the local WDB, local area, and the OhioMeansJobs centers on the RR team.

Local plan: A comprehensive 4-year plan developed by the local WDB, in partnership with the chief elected official, and submitted to the State which provides descriptions of the strategic planning elements and services provided in the local area. Requirements for local plans are outlined in Workforce Innovation and Opportunity Act Policy Letter (WIOAPL) No. 16-03, Regional and Local Planning.

Mass layoff: Any reduction in force that does not result in a total plant/branch/office closing, but still results in the filing of a WARN Act notice, regardless of the number of workers affected by the layoff announced; or, if no WARN correspondence is issued, employment loss at a single site of employment for:

1.         At least 25 percent of employees; or

2.         At least 50 employees.

Notification: The process by which an individual on the RR team is made aware of a possible layoff or employer closing. A notification can come from a variety of sources, including, but not limited to: a WARN letter, word of mouth, the media, local Chamber of Commerce, ODJFS Trade Unit, OhioMeansJobs Center, union officials, local government, affected workers, etc.

ODJFS regional rapid response coordinator (RC): An ODJFS workforce specialist assigned to a specific local workforce development area or planning region of Ohio to maintain contact with the employer and to ensure all the activities of the local RR team are completed.

OhioMeansJobs center operator: The entity or a consortium of entities designated or certified through a competitive process to operate a one-stop center under section 121(d) of the Workforce Innovation and Opportunity Act, 29 U.S.C. 3151(d).

OhioMeansJobs.com: The statewide electronic system for labor exchange and job placement activity operated by the state.

Ohio Rapid Event Data (OhioRED): An information tracking system that records all employer event information and data on the delivery of RR services.

Ohio Rapid Response Workforce Survey (RRWS): The standardized survey (JFS 08124) used in Ohio to identify demographics of the affected workforce and serve as a preliminary needs assessment.

Ohio Workforce Case Management System (OWCMS): A system used by workforce professionals to gather and report program data and information for the following programs: WIOA, Wagner-Peyser, Veteran, Apprenticeship, Migrant and Seasonal Farmworker, Foreign Labor Certification, and Trade.

Planning region: Two or more local workforce development areas assigned by the State to align workforce development activities and resources with larger regional economic development areas and available resources to provide coordinated and efficient services to both job seekers and employers.

Potentially affected workers (PAW): Employees at risk of becoming unemployed due to an event.

Rapid Response Emergency Assistance Funds (RREAF): State rapid response funding allocated to local areas for the provision of reemployment services outlined in the service plan to workers and employers who have been affected by a mass layoff, employer closure, disaster mass job dislocation, or TAA petition.

Rapid response (RR) event: When one or more of the following circumstances occur:

1.         Announcement or notification of a permanent closure, regardless of the number of workers affected;

2.         Announcement or notification of a mass layoff;

3.         A mass job dislocation resulting from a natural or other disaster; or

4.         The filing of a TAA petition.

Rapid response team: Individuals from state and local workforce entities that respond collectively to mass layoffs, employer closures, disaster mass job dislocations, and TAA petition filing that occur within their local area or planning region and assist in providing RR services to employers and affected workers.

Rapid response worker reemployment session: The provision of reemployment information to the affected workers on the benefits, services, and resources available to rapidly transition them before layoff date or/and during their layoff to new employment.

Service plan: A plan which details all RR services that will be provided to an affected workforce and a timeline of when the services will be delivered.

Trade Adjustment Assistance (TAA): A program which provides assistance, including reemployment and training services, to workers whose jobs have been threatened or lost due to foreign imports, or shifts in production and/or services to a country outside the United States.

Worker Adjustment Retraining Notification Act (WARN): The Federal Act that protects workers, their families, and communities by requiring most employers with 100 or more employees to provide notification 60 calendar days in advance of plant closings and mass layoffs. General provisions of WARN covers employers with 100 or more employees, not counting those who have worked less than 6 months in the last 12 months and those who work an average of less than 20 hours a week. Additional material for compliance and assistance can be found at http://www.doleta.gov/layoff/warn.cfm .

Workforce development board (WDB) director: The individual hired or designated by the local WDB to assist in completion of duties for the local WDB, including oversight of workforce development employment and training programs and development of the budget for the local area.

VI.       Local Workforce Development Area Requirements

A.        Identification of the Rapid Response Team

Each local area must identify members of its RR team. The RR team, in coordination with the RC, shall develop a protocol to ensure the team works together so services are provided to employers and affected workers in a timely, efficient and quality manner.

The local area's RR team is made up of the following partners fulfilling the following roles when responding to an RR event:

1.         ODJFS Rapid Response Coordinator: The RC will:

a.         Ensure that the initial contact is made with the business;

b.         Conduct and/or participate in the initial meeting, in conjunction with the LC as appropriate, and ensure effective and consistent communication with the employer throughout RR activities;

c.         Disseminate information regarding the RR event to the RR team;

d.         Conduct rapid response worker reemployment sessions or work with the LC to ensure such sessions are conducted;

e.         Coordinate team members to effectively deliver RR program and other services to employers and affected workers;

f.          Assist in coordination of resources within the defined region, which includes coordination with other workforce areas and/or planning region(s) as necessary to ensure timely, effective, and consistent delivery of RR services;

g.         Collaborate with other RCs and other local RR teams for events and initiatives that are regional or statewide;

h.         Collaborate with LC on the development of the reemployment strategy and service delivery plan, in conjunction with the RR team, that best fits the situation; and

i.          Discuss with the team the best course of action when other employers are at risk of downsizing or closing due to an event.

2.         Local Rapid Response Coordinator: The LC will:

a.         Conduct and/or participate in the initial meeting, in conjunction with the RC, as appropriate;

b.         Collaborate among partners;

c.         Collaborate with the RC on the development of the reemployment strategy, in conjunction with the RR team, that best fits the situation;

d.         Coordinate with LCs in other local areas when the event affects multiple local areas regarding reemployment strategy and RR service delivery plan;

e.         Develop a customized RR service delivery plan for every employer event;

f.          Determine the need for Rapid Response Emergency Assistance Funds (RREAF) and collaborate with RC in completing the application;

g.         Collaborate with the local area's fiscal agent and local WDB to mutually agree on funding amounts to support the plan for services;

h.         Guide the team through the funding application process, including applying for funds and submitting the form to the WDB director for signature and approval; and

i.          Assist in the implementation of the RR service delivery plan.

3.         WDB Director: The WDB Director reviews the RR team protocol and its effectiveness every four years as part of the development of the local area's plan, or after two years as part of the local area plan review and modification, or as needed. The WDB Director (or designee) also signs and submits the RREAF application.

In addition to the RR team members listed above, local RR teams should also include the following members so that the team has quality representation in the delivery of RR services:

1.         OhioMeansJobs center operator;

2.         Economic development agency, including the regional JobsOhio agency, as appropriate;

3.         Representative of business services in the local area or the local area's business resource network, if applicable;

4.         Representative of TAA;

5.         Representative of WIOA Title I Programs;

6.         Representative of WIOA Title III Wagner-Peyser Employment Services Program; and

7.         Representative of Unemployment Insurance (UI).

B.        Establish Rapid Response Team Protocol

Local areas shall utilize the RACI exercise to delineate functions for each RR process or activity and the responsibility and accountability for completion of such functions to establish an RR team protocol. The protocol should be developed to ensure communication amongst the team members and to maintain the flexibility to customize for the needs of individual employers and employees impacted by an event.

The RR processes, which will be outlined using the RACI tool, include, but are not limited to, the following activities:

1.         Notify team of new event;

2.         Enter event information into OhioRED;

3.         Conduct research;

4.         Make initial contact with the employer to gather information using the JFS 01810;

5.         Develop a proposed reemployment strategy for the affected workforce, which is driven by talent needs of local workforce development area and regional employers, and presented at the initial employer meeting;

6.         Conduct initial employer meeting to establish rapport, collect needed information, and develop a proposed plan of service. Representatives of the RR team attending this meeting, for most events, should be the RC, a local representative, and representative(s) of UI or TAA, as applicable. Other attendees may include State and/or local economic development agencies and other State agencies, as appropriate;

7.         Issue the RRWS to provide local teams with demographics and characteristics of the workforce that will be potentially affected by layoff or closure, captures desired worker services, and will be used in the strategy for service delivery;

8.         Develop a service plan;

9.         Develop an RR budget, including potential application for RREAF. The RREAF application process is outlined in WIOAPL No. 17-05, Funding for Rapid Response– Employer Closure, Mass Layoff Disaster Mass Job Dislocation, and Trade Adjustment Assistance Events;

10.       Conduct the rapid response worker reemployment session using the standard, core presentation developed by ODJFS;

11.       Update OhioRED and OWCMS;

12.       At least monthly, update RR team on activities and results;

13.       Check the effectiveness of the service plan and modify as needed; and

14.       Conduct post rapid response follow-up.

Collaboration and coordination by all RR team members is crucial to successful provision of RR services to employers and employees.

The local area must review team protocols to ensure their effectiveness, at a minimum, every two years as part of local area planning, development or modification. The local WDB Director will submit any revised RR team protocol for the local area to the OWD Rapid Response Unit at RAPDRESP@jfs.ohio.gov with the subject line of Rapid Response Team Protocol.

C.        Use of RRWS

Local RR teams must utilize RRWS to identify the demographics of an impacted workforce for a preliminary needs assessment that will be used by the RR team to develop a service delivery plan as described in Section VI. A. RRWS is completed on the JFS 08124, Ohio Rapid Response Event Data.

All RR team members, service providers and contractors that receive or access personally identifiable information (PII) on impacted workers must safeguard the information from disclosure in accordance with federal and state confidentiality laws, rules, and policies. However, de-identified data can be disclosed in aggregate to provide insight on workforce trends and labor availability.

D.        Transitioning from Rapid Response Services to the Local Area WIOA Adult and Dislocated Worker Programs

Local area procedures must be in place to identify the workers served under the RR program and RR services received. All RR services that individuals receive prior to determination of WIOA eligibility must be considered when developing service delivery strategies for workers who will be eligible to receive additional services under WIOA. Such consideration will help prevent duplication of services and ensure that workers can quickly access needed services.

E.        Transitioning from Rapid Response Services to TAA Program

Local areas must have procedures in place to identify the workers served under the RR program and RR services received. If individuals who are potentially Trade eligible also received WIOA services prior to Trade certification, these services must also be identified. All RR and, possibly, WIOA services that individuals received must be considered when developing service strategies for workers eligible to receive additional services under TAA. Such consideration will help prevent duplication of services, ease transition of services, and help ensure that workers can quickly access needed services. Individuals may be co-enrolled in both TAA and WIOA programs to receive ongoing reemployment services.

VII.      Reporting Requirements

Accurate and up-to-date information on closure and layoff events is critical to stakeholders within the workforce development system. This data is also a key factor in assessing the need for financial assistance at the state and federal levels.

There are two levels of reporting for employer closure and mass layoff events:

1.         Employer/event data tracking in OhioRED; and

2.         Worker data in OWCMS.

A.        OhioRED

ODJFS has implemented an RR information tracking system, OhioRED. This system records all significant information and data from each event, beginning with notification and initial contact with the employer, through the transition of affected workers to the OhioMeansJobs Centers and the local workforce development system.

Based upon the RACI, the team member responsible for entering information into OhioRED must record WARN and non-WARN events and any subsequent updates in OhioRED on a timely basis. At a minimum, a local RR team member must enter all the following required information into OhioRED, preferably within the next business day, but prior to application for RR funds, as appropriate:

1.         Company information, including company contact information, identification of RR team leader, notification of event, and event information;

2.         Layoff information, including number of affected workers, layoff date, and specifics regarding the layoff or closure; and

3.         Business and initial planning information.

B.        OWCMS

Based upon the RACI, the team member responsible for OWCMS data entry must record all individual workers who attend a reemployment session or receive other RR services. Data for OWCMS can be acquired, among other methods, by using the JFS 08124. The rapid response identification (RRID) number assigned at the point of data entry into OhioRED will be entered into OWCMS to track individual workers accessing services from each event. Although data elements are minimal for workers at this level of service, it is the beginning of a log of services that can then be used to ensure a smooth transition to WIOA program enrollment, should additional services be needed.

Depending on the RR funded activities associated with the substantial layoff or employer closure, the team member may be required to enter participant information into OWCMS under Special Grants. By reporting information into OWCMS, the local area may report outcomes.

VIII.     Monitoring

The local WDB's oversight and monitoring must include a review of the effectiveness of the area's rapid response program. This may include:

1.         An assessment of collaboration among RR teams and members;

2.         The efficiency of service delivery to employers and PAWs; and

3.         Timeliness and completeness of data entry into OhioRED and/or OWCMS.

IX.       Technical Assistance

The OWD Rapid Response Unit will oversee Ohio's RR service delivery to identify notable practices and document RR activity throughout the state. The OWD Rapid Response Unit will also provide oversight of the activities of the local RR teams.

The RR unit provides the following types of assistance:

1.         Technical assistance for the development of an RR team protocol;

2.         Ongoing support, guidance, training, and technical assistance to local RR teams, local business resource teams or other business teams, local WDBs, and OhioMeansJobs centers;

3.         Reviewing, managing, and reporting out on data derived from local activity; and

4.         Providing financial resources to the local RR teams and stakeholders.

For additional information, questions may be sent to the OWD Rapid Response Unit: RAPDRESP@jfs.ohio.gov.

X.        References

Workforce Innovation and Opportunity Act § 134, Pub. L. 113-128.

Worker Adjustment and Retraining Notification Act (WARN), Pub. L. 100-379, 29 U.S.C. 2101 et seq., 20 C.F.R. Part 639.

20 C.F.R. §§ 682.300 - 682.370.

USDOL, Training and Employment Guidance Letter WIOA N0. 19-16 Operating Guidance for the Workforce Innovation and Opportunity Act, 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 Service (ES), as amended by Title III of WIOA, and for Implementation of the WIOA Final Rules, (March 1, 2017).

O.R.C. §§ 4141.29(A)(4), 4141.29(A)(7), as amended by H.B. 2 (130th General Assembly).

ODJFS, Workforce Innovation and Opportunity Act Policy Letter No. 16-03, Regional and Local Planning, (October 21, 2016).

ODJFS, Workforce Innovation and Opportunity Act Policy Letter No. 17-05, Funding for Rapid Response– Employer Closure, Mass Layoff, Disaster Mass Job Dislocation, and Trade Adjustment Assistance Events,
(May 25, 2018).

ODJFS, Worker's Guide to Unemployment Compensation, (Last revised January 2018).