Narrative: b. 3.

Colorado is currently updating the policy guidance letter regarding the training provider elgilibity procedure to meet all requirements outlined in TEGL 8-19. The draft policy is availlable at this link. The policy is expected to be finalized and fully executed by May 31, 2020.

In summary, the PGL provides guidance on the following items:

• The initial eligibility online application process, to include data regarding:
  • A description of each program of training services to be offered;
  • Information on cost of attendance, including costs of tuition and fees;
  • Whether the training program leads to an industry-recognized certificate or credential, including recognized post-secondary credentials;
  • Whether the provider has developed the training in partnership with one or more businesses (and the names of the businesses);
  • Which in-demand industry sectors and occupations best fit with the training program;
  • A description of the prerequisites or skills and knowledge required prior to the commencement of training; and
  • Social security numbers for all students residing in Colorado, regardless of funding source.
  • Factor related to WIOA performance indicators: Initial eligibility criteria requires the training program to identify whether it leads to an industry-recognized certificate or credential, including recognized post-secondary credentials, and to identify the credential.
• The continued eligibility online application process, to include updates to the initial eligibility data and the following information:
  • The total number of participants enrolled in the program;
  • The total number of participants completing the program;
  • The total number of participants exiting the program;
  • Information on recognized post-secondary credentials received by program participants;
  • Information on the program completion rate for such participants;
  • Description of how the provider will ensure access to training services throughout the State, including rural areas and through the use of technology;
  • Description of how the providers provide training services to individuals who are employed and/or individuals with barriers to employment;
  • Information reported to State agencies on Federal and State training programs other than programs within WIOA title I-B; and
  • Social security numbers for all participants in Colorado for the two previous years, regardless of funding source, which will be used to calculate the performance measures
  • Program Quality and Performance data: 

    Colorado policy states “Minimum performance targets have not been set as eligibility criteria for training programs to remain on the ETPL. Available performance information for each program will be posted on the ETPL to help consumers make an informed decision. Once a full cycle of WIOA performance information becomes available, this policy will be revised to establish minimum performance targets for programs to remain on the ETPL.” (p. 6)

    Colorado has experienced technical delays and as a result it is still building out its ETPL system to collect Social Security Numbers and calculate the WIOA performance indicators. Brighthive, our data trust vendor, has developed a tool called "Abacus" to assist with this process. Abacus will calculate the following indicators:

    • Percent of participants employed 2Q after the program exit date
    • Percent of participants employed 4Q after the program exit date
    • Mean wage for participants 2Q after the program exit date
    • Mean wage for participants 4Q after the program exit date
    • Median wage for participants 2Q after the program exit date
    • Median wage for participants 4Q after the program exit date
    • Count of participants earning a credential

The plan is to have the SSN uploader complete by June 2020 and accessible to the providers to use during July - August. In September CDLE will scrub the data with a deadline to lock the cycle on October 1. Assuming all goes well, matching with Unemployment Insurance data would happen during October, so the data should be available by November. Our goal is to have the outcome data publicly available by the end of 2020.

• Accessibility: Under the continued eligibility criteria, the Colorado policy states “Applications for continued eligibility must...include the following:...Description of how the provider will ensure access to training services throughout the State, including rural areas and through the use of technology;” (p. 5-6). If providers do not provide an adequate description of how they will ensure accessibility, then the provider will not be approved for continued eligibility.
   
• Process for WIA approved training providers to transition to WIOA approved training providers
• The roles of the three entities involved in the determination of training provider eligibility:
  • The Colorado Department of Labor and Employment establishes the eligibility criteria and approval process, submits performance reports, and takes enforcement actions against providers that provide false information or violate the requirements of WIOA.
  • The Colorado Department of Higher Education hosts the ETPL website, reviews applications for minimum eligibility and/or performance requirements, and notifies local boards and CDLE regarding new requests for initial or subsequent eligibility once online applications are completed and reviewed. They also mark programs eligible for WIOA funding that have been approved by Local Boards and remove programs that don’t meet required criteria or performance standards.
  • Local Workforce Development Boards may identify local eligibility criteria in addition to those set by the state, plus they will review initial and subsequent applications and either approve or disapprove programs according to state and local standards. The decision of each local board determines whether a program may be utilized in its respective local area. Local boards may also request the removal of a program for cause based on local and state standards.

Registered Apprenticeships: In partnership with USDOL’s Denver Office of Registered Apprenticeship, all active apprenticeship programs are automatically eligible for ETPL placement. Registered Apprenticeship Programs apply through the online system and are only required to provide the five data elements per the TEGL. The Colorado policy states “When a registered apprenticeship program submits an online application, the state will verify the registered apprenticeship program number and the program will be automatically approved statewide.” (p. 5). Registered apprenticeship programs will not be subject to the same application or performance reporting requirements as other training providers because they go through a detailed application and vetting procedure to become a Registered Apprenticeship program sponsor with USDOL. Any apprenticeship program may remain on the ETPL as long as it wishes if it remains registered by the USDOL Office of Registered Apprenticeship.