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Questions & Answers
WIA responses from the WIB Director
Questions may be e-mailed to gwend@jtpa.cvrdc.org or Vandy88@aol.com.

What are the foreseeable consequences to a technical college for registering students for WIA who later fail to meet WIA performance standards? - Lucy, Coosa Valley Tech

The Workforce Investment Act (WIA) requires that the State include in its Plan expected levels of performance for the State's Workforce Investment Board (WIB) areas. It also requires the provider of training services (such as Coosa Valley Technical College) make available past performance information of individuals that are applying for or receive ITA's. Hence, the first problem of performance failure is that this information will be provided by program to new applicants who will use this performance information to determine if they want to be an applicant of that particular school.

The second problem is that in the process for determining eligible providers of training services, past performance must be considered. Therefore, after the initial period of automatic eligibility, the WIB must consider the performance when determining eligible training providers.

Is there any expectation of a grace period (next year) during which poor WIA performance would be forgiven for those students enrolled when WIA was new and processes for protecting performance were unclear, or not in place? Lucy, Coosa Valley Tech

Although the State has assured us that there will be no sanctions the first year, please note that the first year of WIA performance began with terminees from JTPA last October 1, 1999. Hence, the first year is almost over. Additionally, there are customer satisfaction criteria which will address the up-front and supporting One Stop Service System services which must be considered and dealt with if our area fails to meet these. If an area fails to meet performance, technical assistance will be provided.

How will technical colleges access WIA training account:
*  by a lump sum grant from which the school chooses which students to fund?
*  by individual applications for specific students?
*  by other methods? - Lucy, Coosa Valley Tech

During the next few weeks, every attempt will be made by our staff to assist you in assuring that anyone who appears to need WIA assistance may apply for this assistance. They should apply for school admission for Pell and HOPE. A cost of attendance work sheet or its equivalent will be completed to assure that there is not duplication of payment. However, WIA may still be used to supplement the unmet need. Priorities have also been adopted by the Northwest Georgia WIB which should be considered. The Service Priority as stated in the Individual Training Account Policy is as follows:

"Priority for training services will be given to individuals who have met the minimum eligibility, but have one or more characteristics that may act as a barrier to obtaining and/or maintaining employment. These are as follows (in no order of priority): (a) unemployed (b) lacks a high school diploma or GED (c) poor work history, (d) offender, (e) poor basic skills, (f) food stamps recipient, (g) welfare recipient (TANF), (h) lacks self-sufficiency, (i) underemployed, (j) limited English proficiency.

Training funds will be used to build on existing skills first. An individual who may be trained for a quality job more quickly and economically by building on existing skills first may take precedence over training an individual in an entirely new occupation. However, the person's interests, demands of the labor market, and limited training dollars must be taken into consideration."

The definitions of most of the items are consistent with JTPA thought. The WIB, however, did adopt a definition of underemployed which is provided in the "ITA Policy."

The technical colleges should be identifying those individuals which can receive priority services. However, anyone who desires must be allowed to apply. As you may know, our area has recently also had several closings which will naturally receive attention.

Although the Board may elect at a later date to establish funding limits by school, there is currently no limitation. Therefore, we will be developing individual training accounts by person at this time. The State WIA Training Account System Technical Assistance Guide and the Northwest Georgia Training Account Account Policies adopted by the Northwest Georgia WIB are resources. Please note that the Northwest Georgia policies are slightly different from the proposed State policies.

How will the WIA Board determine the split of WIA dollars between schools, agencies, and other WIA service providers? - Lucy, Coosa Valley Tech

The Northwest Georgia WIB made several WIA funding decisions: it provided money to the vocational technical colleges to complete training for those individuals enrolled in JTPA who were transferred to WIA; it provided on-going support for those individuals through staff assistance and support monies; it procured On-the-Job Training (OJT) services and awarded WIA contracts to the Department of Labor for this purpose; and it procured youth services since only a small amount of money was available for the summer youth program to begin in June and a grant for out-of-school to offset this in-school commitment was also necessary. A portion of the youth program funds was awarded and there are other programs on the contingency list.

We are currently in the process of procuring other ITA's which were not automatically approved by the State. These areas of training may be added by the WIB.

Approximately $475,000 in WIA monies remain to fund the gaps in the One Stop System, ITA's and support for individuals who receive ITA's. Therefore, the Region 1 Consortium (if approved as the One Stop operator) will need to make requests regarding how to best utilize this small amount of money.

Can technical colleges use WIA dollars to:
*  pay salary-fringe for staff providing WIA services, and/or overseeing administration of WIA funded activities?
*  pay for training of staff providing WIA services or overseeing WIA activities? - Lucy, Coosa Valley Tech

Please refer to the response above. Other than the dollars earmarked for ITA's, the remaining dollars should be designated to the One Stop staff which can be Department of Labor, Department of Technical and Adult Education, Department of Human Resources, or Vocational Rehabilitation as agreed to by the Consortium, if approved by the WIB.

Will the WIA Board write guidelines for selection of students for training using WIA dollars? For example, will the WIB instruct technical colleges to give priority for WIA sponsored training to students whose earnings before training, as compared to their projected earnings after training, are likely to meet WIA wage enhancement standards? Or, would a technical college be responsible for devising its own selection procedure in order to protect its WIA performance? - Lucy, Coosa Valley Tech

See the priority for services designed in the second question above. The Northwest Georgia WIB may adopt additional guidelines at a later date; it has not at this time. It is prudent for every case manager, however, to know the earnings, credentials, etc. of an applicant prior to registration and to determine what outcome will be necessary for that individual to be successful and for the area to be successful.

What, if any, procedures have been devised to help WIA training providers avoid bad WIA performance result from difficulties in exiting participants from WIA? Could end of training constitute an automatic exit? - Lucy, Coosa Valley Tech

End of training does not constitute an automatic exit. WIA registrants continue to be considered active WIA participants as long as they are receiving any partner services. However, care must be taken to maintain current records on service participation through case management or tracking systems. (Mandatory and optional partner programs are listed in Appendix A Reference: May 31, 2000 correspondence from Georgia Department of Labor.) Other information provided in the correspondence may be helpful:
*  Outcomes are counted and reported quarterly.
*  For all measures except the skill attainment rate for younger youth (age 14 to 18) and the employer customer satisfaction measure, measures are based on customers exiting in the quarter being reported.
*  Customers who exit, return, and exit again are counted once in each quarter in which they exit.
*  USDOL has distinguished between "hard" and "soft" exits. Hard exits occur upon case closure or completion. Soft exits occur when a registrant has not received any WIA or WIA partner funded service for 90 days and is not scheduled to receive any future services. Because soft exits occur automatically, it will be important for local areas to maintain current data on customer services, including partner services.
*  A customer's exit date is the last date of WIA funded or partner service. It determines his/her exit quarter. (Notice that soft exits will consistently generate exits in the previous quarter.)
*  Planned gaps in serivce of more than 90 days due to a delay in the beginning of training or a medical condition that prevents an individual from participating will not trigger a soft exit.

An example was also provided for tracking participants in partner programs:
"Suppose a customer enrolls in a technical institute following WIA funded intensive assessment and career counseling at his local One Stop. The One Stop assigns a case manager to maintain contact with the participant, offering additional services as needed and recording the customer's activities and progress. When the customer finishes training and goes to work, the case manager records placement data and information on the credential earned and closes the case (hard exit). Subsequent employment and earnings are tracked automatically through UI wage record match.

But what if the One Stop doesn't follow-up with the customer while he/she was in training? After 90 days with no record of receipt of services, the customer's case would be closed automatically (soft exit) and, again, subsequent employment and earnings would be tracked. Even if the customer worked part-time while he/she was in school, the effect on the local area's performance would be negative since post-participation earnings would be low and the area would not receive credit for the credential when it was earned. The bottom line is that partners need to communicate about their shared customers."

Please note that a registrant could exit himself/herself by not participating in any training for 90 days.

Are negative WIA performance consequences possible/likely if a student's self-attestation of wage searned prior to WIA sponsored training was underestimated (by Georgia student) so that this student's after training wages compared to actual before training wages failed to meet the WIA wage enhancement performance standard? - Lucy, Coosa Valley Tech

Yes, pre-program earnings and post-termination earnings will be determined by UI. Hence, performance will be based on what can be proven, rather than self-attestation for pre-program earnings.

Will the technical college be responsible for inaccuracies in the student's self-attestation of prior wages? - Lucy, Coosa Valley Tech

The technical college will only have the same problem as the Workforce Investment Area as a whole for adult and dislocated workers performance results. An adverse effect on performance in this instance might result if the case manager/registrant had low earnings goals since the individual's employment goals were based on an inaccurate assumption.

Youth must be determined eligible fgor youth monies by being determined economically disadvantaged. Since this is an eligibility issue with associated disallowed costs, the WIB may elect to require documentation of income. This should not impact the technical colleges through the ITA system, however, since ITA's can oinly be offered through the Adult/Dislocated Worker funds. Hence, older youth would need to be served through the Adult/Dislocated Worker in order to receive an ITA. Any other service procured, however, for youth serviced at the technical college or other site would need to take this into consideration.

When/how do you expect resolution of the lack of clear exit points in current WIA guidelines for terminating WIA services? What procedures can be used to avoid failing to meet WIA performance because of having no exit point where performance can be claimed? Could end of WIA sponsored training constitute an automatic exit point for students? - Lucy, Coosa Valley Tech

See previous questions and responses. Resolution of case management and follow-up issues will be resolved by the One Stop Operator, which may be the Consortium if approved by the WIB. The technical colleges must address how this can best be implemented through the MOU between the Consortium partners to assure roles are clearly delineated.




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Revised: Friday, 14 November 2008 11:42 AM