Narrative: III. b. 2.

With the passage of the Workforce Innovation and Opportunity Act of 2014, the Arkansas Division of Workforce Services and its Adult Education Section, Arkansas Rehabilitation Services, and Division of Services for the Blind began meeting to discuss the implication of the new legislation and begin necessary discussions for the successful implementation of the federal law in Arkansas.

In November 2014, representatives from each of these agencies formed a WIOA Roundtable that met monthly and soon were joined by additional representatives from Registered Apprenticeship, higher education, secondary education, two- and four-year educational institutions, Carl D. Perkins secondary and post-secondary programs, Career and Technical Education, Temporary Assistance for Needy Families, human services, and elected officials to engage in discussions about integration of services provided by a multitude of service providers. This planning team established committees to focus on critical areas in WIOA implementation to include: finance, IT system integration, policy development, core performance measures, sector strategies, and the development of the state workforce development plan.

The WIOA Roundtable Policy Committee meets routinely and has engaged the use of work groups formed from staff members across all agencies to draft policies for consideration by the policy committee. Each agency has representation on the policy committee in order to coordinate and align activities. After the WIOA Roundtable Policy Committee has reviewed and approved the policy, it goes to the appropriate committee of the Arkansas Workforce Development Board for consideration and adoption. The Arkansas Division of Workforce Services as staff support for the AWDB takes lead on posting policies for public comment and making WIOA Title I-B policies available for all staff to access on the WIOA page of the website www.dws.arkansas.gov/wioa.htm.

In Fall 2017, the initial WIOA Title I-B Policy Manual was presented to and approved by the Arkansas Workforce Development Board, which included the following:

Co-Enrollment and Co-Funding- Policy Number: WIOA I-B- 2.7

PURPOSE:

The purpose of this policy is to describe the requirements and regulations concerning co-enrollment and/or co-funding of WIOA Title I-B participants with various WIOA Title I-B programs, with other WIOA programs, with Arkansas Job Center partners, and with other appropriate entities, in accordance with the Workforce Innovation and Opportunity Act of 2014 (WIOA), the WIOA Final Rule, Training and Employment Guidance Letters (TEGLs) published by the Employment and Training Administration of the U.S. Department of Labor (ETA), and policies of the Arkansas Workforce Development Board (AWDB).

REFERENCE:

WIOA § 134(b)(2)(A)(v)

20 CFR 680.230

20 CFR 680.350

20 CFR 681.430 - 440

TEGL 19-16

A.C.A. 15-4-3711(a)(10)(D)

POLICY:

Under WIOA I-B, participants may be eligible for youth, adult, and/or dislocated worker services. The participant may also be eligible for the services of other one-stop partners, as well as services for non-one-stop partners. WIOA I-B case managers must be informed about the services of all WIOA funding streams (including other titles and subtitles). Case managers must coordinate with other agencies as appropriate to provide the full array of services documented as needed by the participant [WIOA § 134(b)(2)(A)(v); 20 CFR 680.230]. Co-enrollment (or dual-enrollment) and/or co-funding with other entities is encouraged in order to give participants the best array of services [TEGL 19-16].

Co-enrollment within WIOA Title I Adult, Dislocated Worker, and Youth programs

Individuals who meet the respective program and service eligibility requirements may participate in Adult/Dislocated Worker and Youth programs concurrently. Local programs operators may determine the appropriate level and balance of services under the Youth and Adult/Dislocated Worker programs. This determination depends not only on the eligibility requirements of each program, but also on the services needed by each participant [TEGL 19-16].

Services available under each funding stream will depend on eligibility for services under that funding stream. Local program operators may determine the appropriate level and balance of services for each individual under each program. Local program operators must identify and track the funding streams that pay the costs of services and ensure no duplication of services [20 CFR 681.430]. However, if it is determined that only the Youth or the Adult/Dislocated Worker program array of services is appropriate for an individual aged 18 - 24, then the local program provider may enroll the participant in only one program [20 CFR 681.440].

Co-enrollment and Co-funding with Other Programs

WIOA Title I-B program providers are encouraged to work with other Workforce Center partners and other entities to provide a full array of needed services to participants. Not only does this strategy provide more services, it provides more case management to the participant, thus providing greater probability for success.

WIOA funding for training is limited to participants who are unable to obtain grant assistance from other sources to pay the costs of their training or require assistance beyond that available under grant assistance from other sources to pay the costs of such training. WIOA Title I-B Service Providers must not only ensure that participants apply for Pell Grants and other appropriate grants, but they must also coordinate funding with other one-stop partners and other entities for which the participant is eligible [20 CFR 680.230]. In order to appropriately coordinate funding and co-enrollment, case managers must be trained in programs and eligibility requirements of other one-stop partners and other local and state entities providing services needed by their participants so they can leverage the funding of other sources to provide all services needed by WIOA Title I-B participants [A.C.A. 15-4-3711(a)(10)(D)]. DOL has established a goal of co-enrolling 50% of TAA participants in either WIOA Title I Adult or Dislocated Worker programs. Therefore, co-enrollment of TAA participants into the WIOA Title I Dislocated Worker or Adult program is strongly encouraged if the TAA participant meets eligibility requirements. The specific services provided to these participants will depend on the needs of the participant and funding availability in the local area. Some of these potential entities include, but are not limited to:

• • Career Pathways Initiative for custodial parents attending Arkansas two-year colleges
  • Single Parent Scholarship Funds for each county (www.aspsf.org/scholarships)
  • Arkansas Rehabilitation Services and Division of Services for the Blind
  • TEA / Work Pays
  • TAA
  • WIOA Title I-D Dislocated Worker Grants and other Discretionary Grants
  • Veterans’ Services
  • State and institutional scholarships
  • Department of Human Services
  • Food Stamp Employment and Training Programs
  • Arkansas Human Development Corporation (National Farmworker Jobs Program)
  • American Indian Center of Arkansas
  • Local housing authority
  • Local homeless shelter(s)
  • Local food banks and distribution centers
  • Local provider of assistance with utilities
  • Local provider of older worker services (Title V of the Older Americans Act of 1965, 42 U.S.C. § 3056 et seq.)
  • Community Service Block Grants
  • Programs funded by the Second Chance Act
  • Other Arkansas Job Center partners, as appropriate

WIOA Title 1-B Adult, Dislocated Worker, and Youth participants should be referred to and co-enrolled (or co-funded) with these services and other available services as appropriate. Local areas should have policies and procedures in place to ensure that other funds are leveraged [A.C.A. 15-4-3711(a)(10)(D), 20 CFR 680.230(b)].

WIOA Title I-B Adult and Dislocated Worker funds may support adult education and literacy activities of the Adult Education Section, the Arkansas Literacy Council, and other programs providing adult education and literacy activities if the participant is also engaged in one of the following [20 CFR 680.350]:

• • Occupational skills training, including training for nontraditional employment
  • On-the-job training (OJT)
  • Incumbent worker training, as described in ADWS Policy No. WIOA I-B - 3.6 (Incumbent Worker Training)
  • Programs that combined workplace training and related instruction, which may include cooperative education programs
  • Training programs operated by the private sector
  • Skill upgrading and retraining
  • Entrepreneurial training

Local areas must ensure that services are not duplicated for individuals enrolled in multiple programs.

FUNDING FOR INFRASTRUCTURE COSTS

ADWS developed a comprehensive Memorandum of Understanding (MOU) template that detailed the requirements for funding infrastructure costs. This MOU template stated that Boards, with the agreement of CEO’s, must develop and enter into memoranda of understanding (MOUs) with statutorily required one-stop partners for operation and funding of a one-stop delivery system in the local area. The One-Stop Operating Budget and Infrastructure Funding Agreement, attachments to the MOU template, establish a financial plan, including terms and conditions, to fund the services and operating costs of the Local Area Arkansas Workforce Center network.

This MOU template included a Dispute Resolution Process that allows a one-stop partner to file appeals regarding infrastructure costs and the appeal results in a change to the one-stop partner’s infrastructure cost contributions, the MOU must be updated to reflect the final one-stop partner infrastructure cost contributions.

During the 92nd General Assembly - Regular Session (2019), the Arkansas General Assembly  consolidated the core WIOA programs (Titles I, II, III, IV) under the newly-created Department of Commerce.

State partners have been given technical assistance and guidance throughout the Infrastructure Funding Agreement negotiation process that focused on the various methods of allocating shared costs, distinguishing what costs are and are not required to be in the Memorandum of Understandings/ Infrastructure Funding Agreements among partner programs, and Title I has taken the lead in coordinating the Accounts Payable and Accounts Receivables following the quarterly reconciliation process to ensure that these standards are adhered to on the state-level.  Although several basis of allocating infrastructure costs were discussed in each local area, the primary basis for allocation is square footage, which is used to allocate shared costs.  Costs are allocated by square footage unless the costs can be directly assigned to a partner or program in accordance with the 2 CFR 200 guidelines that distinguish direct and indirect costs.  Following these guidelines, all 10 Local Workforce Development Boards have entered MOUs with their local partners and have implemented cost sharing across the state with partner programs.