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2 Year Modification

Plan: Colorado PYs 2022-2023 (Mod)
Combined Plan C

Section: WIOA State Plan Common Elements

Narrative: III. b. 7.

Published
Located in:
  • III. Operational Planning Elements

    The Unified or Combined State Plan must include an Operational Planning Elements section that supports the State’s strategy and the system-wide vision described in Section II(c) above.  Unless otherwise noted, all Operational Planning Elements apply to Combined State Plan partner programs included in the plan as well as to core programs.  This section must include—

    • b. State Operating Systems and Policies

      The Unified or Combined State Plan must include a description of the State operating systems and policies that will support the implementation of the State strategy described in section II Strategic Elements.  This includes—

III. b. 7. Priority of Service for Veterans

Describe how the State will implement and monitor the priority of service provisions for veterans in accordance with the requirements of the Jobs for Veterans Act, codified at section 4215 of 38 U.S.C., which applies to all employment and training programs funded in whole or in part by the Department of Labor.  States should also describe the referral process for veterans determined to have a significant barrier to employment to receive services from the Jobs for Veterans State Grants (JVSG) program’s Disabled Veterans’ Outreach Program (DVOP) specialist.

Current Narrative:

Since the enactment of the Jobs for Veterans Act in 2002, Priority of Service has been established in the State of Colorado under policy guidance issued by the Colorado Department of Labor and Employment. Priority of Service, as required by 38 U.S.C §4215 and 20 C.F.R. 1001 and 1010, is provided to ensure veterans and covered persons receive consideration for all opportunities, for which they qualify, funded in whole or part by the United States Department of Labor. After receipt of state policy, local AJC’s are required to develop and implement internal veterans’ Priority of Service policies and procedures after review and approval by the State 

Veterans Program Coordinator. Each year they are required to submit their local policy to the State Coordinator for review, particularly when changes have been made. The Priority of Service regulations require that local AJC’s implement policies and procedures that: 

  • Identify veterans and eligible persons at point of entry (physical locations, web sites, and other virtual service delivery resources); 
  • Advise veterans and eligible persons of their entitlement to Priority of Service; 
  • Make veterans and eligible persons aware of the full array of employment, training and placement services available; and 
  • Identify applicable eligibility requirements for programs and services. 

Services are made available and provided to eligible veterans transitioning service members, chapter 31 veterans, Native American veterans, and other groups targeted for special consideration like SBE veterans on a priority basis. If “entry” is made via Colorado Department of Labor and Employment website under “Veterans”, “Veteran Priority”, and “Veterans are a priority” Veterans are made aware of their entitlement to Priority in all of Colorado’s Workforce Center services, and have the opportunity to work with the highly skilled, professional workforce Center staff to find a job that maximizes potential.  If a veteran or covered person is making “entry” via the Connecting Colorado statewide database they are made aware of their entitlement to Priority of Service through information on the registration page as well as at the end of the registration process. Additionally, veterans or covered persons who enter the workforce system via a local workforce center office are made aware of their entitlement to Priority of Service by signage posted in the local office. The signage advises veterans of their entitlement for Priority of Service and directs them to speak with workforce center staff regarding their eligibility for Priority of Service and the eligibility requirements for a particular program or service. 

Priority of Service in Programs: AJCs that operate programs which deliver services to the public as a whole (without targeting specific groups), veterans and eligible persons will receive Priority of Service over all other program participants. The primary universal access services are the “core” services delivered through the AJC staff under the Wagner-Peyser and WIOA programs. Veterans and eligible persons receive the first level of priority in universal access programs. 

  1. Some programs are required by law to provide a priority for a particular group of individuals or require the program to spend a certain portion of program funds on a particular group of persons. For programs with this type of statutory priority, AJC program operators will determine the status of each individual veteran or eligible persons and apply Priority of Service as described below:  
    1. Veterans and eligible persons who meet the mandatory priorities and program eligibility must receive the highest level of priority for the program or service; 
    2. Veterans and eligible persons who do not meet the program-specific mandatory priority or spending requirement or limitation then receive the third level of priority for the program or service; 
    3. Non-covered person who meet the program-specifics mandatory priorities and program eligibility then receive the second level of priority for the program or service; 
    4. Non-covered persons outside the program-specific mandatory priority or spending requirement or limitation then receive the fourth level of priority for the program or service. 
  2. Some qualified job training programs may include a focus on a particular group or make efforts to provide a certain level of service to a particular group without the authorizing law specifically mandating that the target group be served before other eligible individuals. For this type of discretionary focus, Priority of Service will be applied as described below:  
    1. Veterans and eligible persons who meet program eligibility and target population; 
    2. Veterans  and eligible persons who meet program eligibility but not target population; 
    3. Non-covered persons who meet program eligibility and target population; 
    4. Non-covered persons who meet program eligibility but not target population. 
  3. State policy requires that all AJC’s establish policy on recruitment, intake and enrollment of Veterans within programs offered, to ensure that veterans are notified, reviewed, and enrolled before non-veterans. In incidents where it has been noted that the veterans who have applied for but not completed the registration and/or enrollment requirements within a program, AJC staff are required to outreach to the veterans encouraging them to complete the process. Their outreach efforts must be documented before the application and/or enrollment is closed. Documentation must show that various means were used to outreach to the veterans. 

Priority of Service in Employment Opportunities: When job orders are entered into the state’s automated database, Connecting Colorado, whether manually or virtually, they are placed in a 4 hour “vet hold” status. This allows only Veterans who have all required skills and who meet all required qualifications to be identified and contacted as suitable candidates before being released for review by non-veterans. The veterans are contacted about this job opportunity using our Integrated Voice Response (IVR) system which automatically emails all qualified veterans first and relays the information about the job opportunity and how to apply for the position. After each IVR email, a note is automatically entered into the applicant’s record with information about the job posting. This noted information allows the JVSG supported staff and AJC staff to assist the Veterans if and when the Veterans call in regards to the job posting(s). 

  1. When the automated email generated by the IVR fails to reach the targeted Veteran due to a bad email address, a non-delivered notice is posted within the system. In the demonstration of providing Priority of Service, state policy requires that an attempt to contact the Veteran is made and can be by phone and/or post card. These additional attempts to contact the veteran are the responsibility of the AJC staff - not the JVSG staff. 
  2. When a job order is placed in Connecting Colorado system, a list of qualified veterans can be generated and viewed by the posting Employer, JVSG and/or AJC staff. This generated list places all Veterans, beginning with Special disabled, disabled and then all other veterans, ahead of qualified non-veterans in accordance with 20 CFR Part 1001. When the automated applicant list is generated and AJC staff notices that the generated list contains little to no qualified veterans, they will conduct a manual search as a demonstration of Priority of Service. This manual applicant search acts as a safeguard to ensure that qualified veterans, even if there is one, is given priority within job search services. 

The demonstration of Priority of Service is the responsibility of AJC staff. It is also the responsibility of the State and County leadership to ensure that Priority of Service is being successfully demonstrated by providing training, technical assistance and monitoring accomplished by the Local Veteran Employment Representative, CDLE Monitors, State Veterans Program Coordinator, CDLE Regional Directors, and Veteran Program Managers. Methods and means used to verify whether or not Priority of Service is being provided will be the following but are not limited to:  

  • Vets 9002 and 200 Report 
  • Interviewing of AJC staff 
  • State monitoring tool 
  • Review of program files and documentation 
  • Customer surveys 
  • Site visits 
  • Accompanying DVET during federal audits 
  • Quarterly Managers Report 

Regarding the referral process for veterans with significant barriers to employment to Disabled Veteran Outreach Program specialists, the local American Job Center (AJC) staff is responsible for providing an initial assessment at the physical workforce center point of entry or if the triage form is submitted virtually, contacting the veteran by phone. This triage is a two-part triage process that is conducted first for the purpose of determining whether or not a service member, veteran and/or spouse/eligible person is eligible to receive DVOP services. Secondly, SBE eligible veterans and/or other eligible persons may be referred for DVOP services only after they have received an initial assessment to address and determine their level of need. This part of the assessment includes, but is not limited to, verifying the accuracy of information provided during the Connecting Colorado registration, and determining the basic job readiness and the extent of AJC services needed by the individual. 

Once a service member, veteran and/or eligible spouse/eligible person has been deemed eligible for DVOP services, the AJC staff member then notifies the DVOP specialist either through email, phone or physically walking the individual over to the DVOP specialist. The triage checklist, or the locally approved version, must be uploaded to Connecting Colorado by the AJC staff and attached to the individual’s CC record to prevent veterans returning to the AJC or crossing regions from being subjected to multiple triages. Although the two-part triage process identifies those eligible for DVOP services, the AJC is ultimately responsible for providing employment services to all registered individuals who are seeking assistance. The intent for assigning DVOP and LVER staff to the AJC is to supplement and not supplant the duties of the AJC staff when providing services to veteran customers. In addition, in offices where no DVOPs are stationed, the AJC staff is expected to provide the same level of needed intensive services while providing the service member, veteran and/or spouse/eligible person the option of making an appointment to be seen by a DVOP specialist during a scheduled meeting.