Narrative: III. b. 2.

III. b. 2. The State policies that will support the implementation of the State’s strategies (e.g., co-enrollment policies and universal intake processes where appropriate).  In addition, provide the State’s guidelines for State-administered one-stop partner programs’ contributions to a one-stop delivery system

Co-enrollment – 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. Co-enrollment offers the opportunity to access additional program services and funds to help address a participant’s specific barriers to employment and/or education. Local programs operators determine the appropriate level and balance of services under the Youth and Adult/Dislocated Worker programs. Case managers must include a case note of justification in the participant file explaining why the co-enrollment is appropriate. Participants must meet the eligibility requirements of each program and will become part of each program’s performance.  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 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].

LWC continues to evaluate the process for the development and modification of MOUs with core and required partners. The purpose of the MOU is to:

1. Articulate a coordinated vision for organizing the broadly defined public workforce system in Louisiana to produce the best possible outcomes for customers — job seekers and businesses.

2. Describe the manner in which the WIOA program partners are legally authorized to participate in the delivery of services, under the provision of the Workforce Innovation and Opportunity Act, through Local Workforce Development Boards, the American Job Centers/One-Stop Career Centers and WIOA Core Program partners.

3. Establish agreement at the state level focused on designing partnerships and service delivery systems through the WIOA Core Program partners to ensure that Louisiana businesses and job seekers, including those individuals with disabilities, low-income status, Veteran status, education or language barriers, and other individuals “shared” by the core program partners, achieve/demonstrate measurable and better outcomes in the areas of education, training, job placement, and wages.

4. Establish a definition and set of shared infrastructure costs to support newly designed partnerships and service delivery between the core program partners, specialized centers and/or affiliated centers, and the local workforce development boards, American Job Centers/One-Stop Career Centers in local areas as authorized by WIOA.

5. Guide the establishment of local area partnerships and MOU agreements on how services can be connected, integrated or enhanced by sharing staffing, resources or jointly designed services in ways that improve outcomes for “shared” customers – job seekers and businesses.

The Office of Workforce Development Monitoring Unit reviews and evaluates executed MOUs annually to ensure alignment with State infrastructure policy, that partners follow the identify MOU purposes listed above, as well as have a method to identify shared common customers, have a system in place to provide and track referrals, and enroll shared customers in the State’s HiRE case management system to serve as a data warehouse to report on outcomes of both job seeker and business customers. Agreements must also have clearly defined infrastructure cost-sharing requirements for all core and required partners. 

LWC’s various departments reviews, updates, and develops policy guidance on an ongoing basis to support the implementation of workforce activities throughout the state. Policies provide guidance on local board membership and responsibilities, regional and local planning, one-stop certification, priority of service, program eligibility, and one-stop partner requirements for access in the system ensuring one-stop operators and all partners have a mutual understanding of what is required.

LWC, as the lead agency for the implementation of the WIOA Combined State Plan, has developed a foundational set of policies that provide guidance for LWDBs to implement WIOA Core Programs and other associated services.  The chart below presents an overview of the state’s policies designed to support effective implementation of WIOA and the One-Stop delivery system:

One-Stop Partner Programs' Contributions

The Workforce Innovation and Opportunity Act of 2014 (WIOA) requires that all mandated partners (as defined in TEGL 17-16) provide access to service in at least one Comprehensive American Job Center in each of Louisiana's fifteen Workforce Development Areas. WIOA also requires that each mandated partner contribute to infrastructure funding of the Comprehensive American Job Centers in each of Louisiana fifteen Workforce Development Areas and any Affiliate American Job Centers through which individual partner entities provide access to services.

Funding contributions for infrastructure costs and additional costs, such as shared costs and shared services which may be in the form cash, non-cash, third-party in-kind contributions, funding from philanthropic organizations, other private entities, or other alternative financing options, as described in WIOA sec. 121(c)(2)(A)(ii) and 20 CFR 678.715, 34 CFR 361.715 and 34 CFR 463.715

WIOA requires that all mandated partners provide access to services in each of Louisiana's Comprehensive American Job Centers. WIOA also requires that the mandated partners contribute to infrastructure costs in each Comprehensive American Job Centers.

Workforce development areas in Louisiana are not required to operate Affiliate American Job Centers; however, partners who provide access to services in any Affiliate American Job Center are also required to contribute to infrastructure costs within those Affiliate Centers.

Infrastructure Costs

WIOA defines infrastructure costs of Comprehensive and Affiliate American Job Centers to be non-personnel costs that are necessary for the general operation of the American Job Center:

• Non-personnel costs that are necessary for the general operation of the One-Stop Center include but are not limited to:
  • Rental costs of facilities
  • Costs of utilities and maintenance
  • Equipment , including assessment related products
  • Assistive technology for individuals with disabilities
  • Supplies
  • Telecommunications

Infrastructure Agreement Development

Negotiating sessions with mandated partners are held as frequently as possible to meet the deadline for developing Infrastructure Agreements and submitting MOUs. Not all mandated partners are able to attend in person infrastructure funding negotiation meetings. In these instances, provisions are made to communicate these partners via teleconference or other means.

The steps in determining infrastructure costs are as follows:

1. Local boards and chief elected officials of Louisiana's fifteen workforce development areas finalize the list of One-Stop delivery system partners who are required to provide access to services within the Comprehensive American Job Centers in their respective areas. Documentation must be kept relative to any mandated partner(s) who are not located in an area and are unable to provide access to services.
2. Local boards, chief elected-officials, and partners determine the services to be provided through the one-stop delivery system and the method through which access to services will be provided for each mandated partner.
3. Local boards, chief elected-officials, and partners develop an operating budget listing line item cost objects listing infrastructure and other costs.
4. Local boards, chief elected-officials, and partners determine the cost base to be used to allocate each of the cost objects within the operating budget. It is recommended that the parties involved concentrate and reach an agreement on infrastructure costs first. In determining the cost base, the parties involved will consider each partner's proportionate use of the system and the relative benefit received from each line item cost object.
5. Local boards, chief elected-officials, and partners determine the method by which partners will contribute their allocated share of infrastructure costs.
6. Local boards, chief elected-officials, and partners will determine the point at which the operational infrastructure budget will be reconciled. It will be Louisiana's policy to require that reconciliation of infrastructure budgets occur no less than once per quarter. A monthly reconciliation is recommended.
7. The local boards, chief elected-officials, and partner entities will enter into an MOU no later than December 1, 2017 that includes an Infrastructure Funding Agreement.

State Infrastructure Funding Mechanism

The State, with the Governor's approval, will use a method to determine infrastructure costs of the American Job Center(s) in a Local Area when partners are unable to agree on how to share costs. The amount that each required partner can contribute is capped per WIOA section 121(h)(3)(B). The State Infrastructure Funding Mechanism only applies to certified comprehensive Centers in Local Areas that cannot reach agreement on a cost sharing agreement.