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.
II. Effective Date
Immediately
III. Rescission
ODJFS, Workforce Innovation and Opportunity Act Policy Letter
No. 15-11, Use of Individual Training Accounts (ITAs), (July 15, 2015).
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:
1. 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;
2. A secondary
school diploma or its equivalent;
3. Employment; or
4. 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, or out-of-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;
1. A combination
of standardized tests;
2. Inventory of
participant's interests, skills assessment, career exploration, and
3. 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 participant age 18-24 or an out-of-school youth participant. 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 out-of–school youth. Limits
to training services may be based on the needs of the adult, dislocated worker,
or out-of-school 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
out-of-school youth are typically provided 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
one of the primary methods 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 eligibility criteria and are
listed 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 American Job Center (which in Ohio is known
as an OhioMeansJobs center), must make available to job seekers the State list
of eligible training providers. 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 occupations 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. ITAs may also be used to
finance pre-apprenticeship training in preparation for the formal registered
apprenticeship training if the pre-apprenticeship program provider has been
approved as an Ohio eligible training provider and listed on WIET per WIOAPL
No. 16-02, Eligible Training Providers.
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.
C. Considerations
for Funding Individual Training Accounts
1. 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 2 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.
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.
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. 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. A participant's
military service or military-related leave time;
b. Lack of
availability of classes;
c. Cancellations
of classes; or
d. 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).
2. Funding
ITAs
The cost for ITAs are determined by the average cost of training
for specific in-demand occupations within the local area as well as the
following criteria:
a. Whether the
training investment is in line with the future expected earnings of the
participant;
b. Whether the
training is being provided as part of the registered apprenticeship program;
and
c. Consideration
of the full cost of participating in training services, including costs for
fees and books, tuition and other associated costs.
An adult, dislocated worker, or out-of-school youth participant
may select training that costs more than the maximum amount available for ITAs
when other sources of funds are available to supplement the ITA.
3. 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:
a. Tuition and
fees;
b. Books;
c. Tools;
d. Uniforms;
e. Tests; and
f. Medical immunizations/tests.
ITA costs do not include any supportive services' costs related
to the ITA (e.g. transportation or child care).
D. 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.
1. 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 monthly.
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: https://jfs.ohio.gov/owd/OMJResources/In-DemandOccupations.stm.
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. A local
in-demand occupation in a geographic area to which the participant is willing
to work or relocate;
b. Employment
associated with a regional industry sector or career pathway consortium for
workforce development;
c. 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. Definitions
Comprehensive Case Management and Employment
Program (CCMEP): An integrated
intervention program that combines the Temporary Assistance for Needy Families
(TANF) program and WIOA Youth program to provide employment and training
services to individuals ages 14 through 24 years.
Eligible training provider: An
entity that receives funding for training services through an ITA; must be
included on the State list of eligible training providers and programs; must
provide a program of training services; and must be one of the following
entities:
1. Institution of
higher education that provides a program which leads to a recognized
postsecondary credential;
2. Entity that
carries out programs registered under the National Apprenticeship Act (29
U.S.C. 50 et seq.); or
3. Other public or
private provider of training services, which may include:
a. Community-based
organizations;
b. Joint
labor-management organizations; and
c. Eligible
providers of adult education and literacy activities under Title II of WIOA if
such activities are provided in combination with training services described in
20 C.F.R. 680.350.
In-demand occupation: As
determined by the State or local board, an occupation that currently has or is
projected to have a number of positions (including positions that lead to
economic self-sufficiency and opportunities for advancement) in an industry
sector so as to have a significant impact on the State, regional, or local
economy, as appropriate.
Lead agency: The local participating agency designated
under section 5116.22 or the Revised Code to serve for a fiscal biennial
period, or part thereof, as a county's lead agency for the purpose of CCEMP.
Planning region: A region
comprised of two or more local areas that are collectively aligned with the
region.
Pre-apprenticeship program:
Programs or sets of strategies designed to prepare individuals to enter and
succeed in Registered Apprenticeship programs and have documented partnership
with at least one, if not more, Registered Apprenticeship programs.
Recognized postsecondary credential:
A credential consisting of an industry recognized certificate or certification,
a certificate of completion of an apprenticeship, a license recognized by the
State involved or Federal Government, or an associate or baccalaureate degree.
Registered apprenticeship program:
A program meeting Federal and State standards of job preparation that combines
paid on-the-job training and related instruction to progressively increase
workers’ skill levels and wages.
VI. 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 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:
1. 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.
2. 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.
3. Allowable costs to complete training financed through ITAs
Costs must be reasonable and necessary and must represent a
sound investment of public funds.
4. 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 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 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."
VII. 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).
VIII. 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.
IX. Technical Assistance
For technical assistance, you may send your request to the
Office of Workforce Development: WIOAQNA@jfs.ohio.gov.
X. 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, Eligible Training Providers, (November 10, 2016).