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WIATL 19A (Youth ITA Waiver)
Workforce Investment Act Transmittal Letter No. 19A
December 20, 2007
TO: Local Elected Officials, WIA Local Workforce Investment Boards (WIBs), Fiscal Agents, Administrative Entities, and One-Stop Operators
FROM: Helen E. Jones-Kelley, Director
SUBJECT: Waiver on Individual Training Account (ITA) for Youth Participants, ages 16-21

I.Purpose

This communication provides guidance on the waiver to use Individual Training Accounts (ITAs) for WIA youth participants who are ages 16-21. WIA administrative entities should convey this guidance to subrecipients and other entities that provide WIA activities and services.

II.Effective Date

July 1, 2007 through June 30, 2009

III.Background

The Workforce Investment Act, Public Law 105-220, dated August 7, 1998, Section 134 (d) (4) (G) requires the use of an ITA for training services for the adult and dislocated worker programs. WIA, 20 Code of Federal Regulations, Section 664.510 allows youth, who are 18 years of age and above, to use an ITA for training services if they are co-enrolled in the adult and/or dislocated worker programs.

On July 25, 2005, the U.S. Department of Labor (DOL) granted Ohio a waiver allowing the use of ITAs for youth participants who are ages 16-21, and/or who are out-of-school without co-enrolling in the adult and/or dislocated worker program for training services requiring an ITA.

IV.Guidance Statements

This waiver allows the administrative entity to use ITAs for youth participants who are ages 16-21 who are out of school, or ages 16-21 who are in school and at risk.

Local areas can provide ITA to these categories of youth participants without co-enrolling them in the adult and/or dislocated worker program. Local areas must use their local youth formula allocations to provide ITAs to the eligible youth participants who are enrolled in the WIA youth program. This waiver applies statewide. A local Workforce Investment Board (WIB) does not need to make a formal request to implement this waiver.

Youth who are ages 14 - 15 cannot receive an ITA even if they are out-of-school. The administrative entity must procure the occupational skills training youth program element for individuals not using an ITA.

The definition of out-of-school youth is as follows: Out-of-school youth is an eligible youth who is a school dropout, or who has received a secondary school diploma or its equivalent but is basic skills deficient, unemployed, or underemployed.

For reporting purposes, out-of school youth includes all youth except those who are attending any school and have not received a secondary school diploma or its recognized equivalent and except those who are attending post-secondary school and who are not basic skills deficient.

An ITA must be a part of a youth's individual service strategy (ISS). The decision to use an ITA is based on an objective assessment. The participant must have the qualifications to succeed in an occupational skills training program and funding must be available. A determination must be made that occupational skill training is necessary and is for a demand occupation. Youth should be cautioned and encouraged not to use an ITA as an enticement to drop out of high school or terminate other academic programs.

The administrative entity must ensure that youth have access to and select providers and programs from the State Eligible Training Provider list (ETP).

You will be able to record in the Sharing Career Opportunities and Training Information (SCOTI) system that a youth received an ITA. If a youth is receiving services through the ten youth program elements and an ITA, the youth performance measures apply. When you co-enroll a youth in both the ten youth elements and the adult and/or dislocated programs, the performance measures apply as appropriate. The WIB should provide policy direction to the administrative entity staff to evaluate outcomes at least quarterly to determine any impact of the waiver.

V.Technical Assistance

For additional information, you may send your questions to the Bureau of Workforce Services, wiaqna@odjfs.state.oh.us.

VI.References

Workforce Investment Act (WIA) 1998, Public Law 105-220, August 7, 1998, Sections 101 (33) 123, 129 (c), 134 and 189 (i) (4) (B);

WIA, 20 Code of Federal Regulations, Final Rules, August 11, 2000, Sections 661.340 661.420(c) and (e), 664.405 (4) and 664.510;

Training and Employment Guidance Letter (TEGL) 17-05, February 17, 2006

Waiver Request Plan, May 9, 2005; and U.S. DOL waiver approval letter, July 25, 2005

Waiver Request Plan, May 9, 2007; and USDOL waiver approval letter, Sept. 26, 2007