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. 15-11.2, Use of Individual Training
Accounts (ITAs), (August 11, 2020).
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 (RA), 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, 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;
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 training provider (ETP). When
participants and local areas select an ETP, 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 ETP list contained on 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 ETP. Each local area through the OhioMeansJobs center,
must make the State list of ETPs available to job seekers.
The local area
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
RA is a proven model of job preparation that combines paid on-the-job
training (OJT) with related instruction to progressively increase a worker’s
skill levels and wages. RA 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 (RAPs) receive nationally
recognized, portable credentials, and in some instances their training may be
applied toward further postsecondary education.
All RAPs are considered in-demand occupations and automatically eligible
for inclusion on Ohio’s ETP list contained on WIET. These RAPs must opt-in to
the ETP list to be added, as not all sponsors are currently hiring new
apprentices and may not want to be included, despite automatic eligibility. Any
local ETP list, where they exist, must be a subset of the statewide ETP list.
All RAPs on a statewide ETP list must be included on any local ETP lists.
ITAs may also be used to finance State-recognized pre-apprenticeship
training in preparation for the formal RA training if the pre-apprenticeship program
training provider has been approved as an Ohio ETP and is listed on WIET per
WIOAPL No. 16-02.1, Eligible Training Providers.
C.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 RAP 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 RAP, including an established career pathway and simultaneous
employment, the classroom training portion of RAPs 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.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 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 RAP; 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).
A.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. These areas have been determined a priority because of their impact
on the lives of Ohioans at every stage of life.
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.
The Top 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.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.Local
Workforce Development Area Requirements
A.Development
of a Local ITA Policy
Each local area 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 area’s ITA policy must include, but is not limited to,
the following criteria:
Maximum duration of an ITA
For the RAP, the length of training and the skills and competencies
required for mastery of an occupation are set by industry. Traditional RAPs are
time-based and require a specific number of hours of OJT and related
instruction. As such, local areas should make allowances in their local ITA policies
to accommodate the required training hours for a RAP.
The local area may also 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 area 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 area 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 ETP.
The local area may also allow for additional ITA funding limits
for those enrolled in a RAP. Additional federal funding for RAPs 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 RA. The Department of Labor’s Training and Employment
Guidance Letter (TEGL) No. 13-16 provides websites for several RA 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 areas 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 ETP list contained on WIET. Local areas 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 area 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
Ohio’s designated case management system.
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); and, TEGL
13-16, Change 1 (May 17, 2021).
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