Narrative: c. 3.

State WIOA Policy 3.2, Services for Youth, describes and defines the required and permitted services for Youth in accordance with WIOA.  This policy also states that WIOA eligible youth must participate in at least one of the program elements as required for program participation. Program elements should be selected based on the youth's objective assessment and individual need. 

State WIOA Policy 3.2, Services for Youth may be found at:

https://www.dws.arkansas.gov/src/files/3.2-Services-for-Youth-Updated-8-27-18.pdf

14 Program Elements
Fourteen program elements must be available to all Youth participants. WIOA Youth funds are not required to be spent on these services. Local programs are encouraged to partner with existing local, state, and national entities that can provide program elements at no cost to the local Youth program [20 CFR 681.460(c); 20 CFR 681.470]. The local area, however, must ensure that if a program element is not funded with WIOA title I Youth funds, the local program has an agreement in place with a partner organization to ensure that the program element will be offered. The LWDB must ensure that program
elements provided by other entities are closely connected and coordinated with the WIOA Youth program [20 CFR 681.470].

Local programs have the discretion to determine what specific program services a youth participant receives based on each participant’s objective assessment and individual service strategy. Local programs are not required to provide all program services to each participant [20 CFR 681.460(b)].

Local programs must make each of the following 14 program elements available to Youth participants who need such services [WIOA § 129(c)(2); 20 CFR 681.460(a); TEGL 23-14; TEGL 21-16]. Local area Youth programs should ensure that services received are reported in AJL. Documenting receipt of program elements is critical to ensure that youth who are actively participating in programs do not get unintentionally exited due to 90 days of no services. Note that case management (the act of connecting youth to appropriate services) is not a program element, and should not be reported as one of the 14 Youth program elements [TEGL 21-16].

Program Element 1: Tutoring, study skills training, instruction, and dropout prevention services that lead to completion of the requirements for a secondary school diploma or its recognized equivalent (including a recognized certificate of attendance or similar document for individuals with disabilities) or for a recognized postsecondary credential [20 CFR 681.460(a)(1); TEGL 21-16].
The following services and activities are reported under Program Element 1 [TEGL 21-16]:
a. Tutoring, study skills training, and instruction that lead to a high school diploma. Such services focus on providing academic support, helping a youth identify areas of academic concern, assisting with overcoming learning obstacles, and providing tools and resources to develop learning strategies. Tutoring, study skills training, and instruction can be provided one-on-one, in a group setting, through resources and workshops.
b. Secondary school dropout prevention intended to lead to a high school diploma. Such services include services and activities that keep a young person in school and engaged in a formal learning and/or training setting. Strategies include, but are not limited to, tutoring, literacy development, active learning experiences, after-school opportunities, and individualized instruction.
The following strategies are listed in 20 CFR 681.460(a)(1), (Program Element 1), but they overlap with other program elements and are reported under other program elements [TEGL 21- 16]:
a. Dropout recovery strategies that are aimed at getting a youth who has dropped out of secondary education back into a secondary school or alternative secondary/high school equivalency program and preparing them for high school equivalency attainment are reported in Program Element 2.
b. Services, including training services, leading to recognized postsecondary credentials are reported in Program Element 4.
Program Element 2: Alternative secondary school services or dropout recovery services [20 CFR 681.460(a)(2); TEGL 21-16]. Alternative secondary school services, such as basic education skills training, individualized academic instruction, and English as a Second Language training, are those that assist youth who have struggled in traditional secondary education. Dropout recovery services, such as credit recovery, counseling, and educational plan development, are those that assist youth who have dropped out of school [TEGL 21-16]
Program Element 3: Paid and unpaid work experiences that have academic and occupational education as a component of the work experience. Work experience as a planned, structured learning experience that takes place in a workplace for a limited period of time. The types of work experiences may include the categories of [20 CFR 681.460(a)(3) & 681.600(c)]:

a. Summer employment opportunities and other employment opportunities available throughout the school year;
b. Pre-apprenticeship programs;
c. Internships and job shadowing; and
d. On-the-job training opportunities.

A pre-apprenticeship is a program designed to prepare individuals to enter and succeed in a registered apprenticeship program. It includes all of the following elements [20 CFR 681.480; TEGL 21-16]:
a. Training and curriculum that aligns with the skill needs of employers in the economy of the state or region involved
b. Access to educational and career counseling and other supportive services, directly or indirectly
c. Hands-on, meaningful learning activities that are connected to education and training activities, such as exploring career options and understanding how the skills acquired through coursework can be applied toward a future career
d. Opportunities to attain at least one industry-recognized credential e. A partnership with one or more registered apprenticeship programs that assists in placing individuals who complete the pre-apprenticeship program in a registered apprenticeship program

Job shadowing is a work experience option where youth learn about a job by walking through the work day as a shadow to a competent worker. It is a temporary, unpaid exposure to the workplace in an occupational area of interest to the participant, where the youth experiences firsthand the work environment, occupational skills in practice, the value of professional training, and potential career options. It is designed to increase career awareness, help model youth behavior through
examples, and reinforce in the youth the link between academic classroom learning and occupational work requirements [TEGL 21-16].
Although OJT is a training service for Adults/Dislocated Workers and a work experience for Youth, the guidelines and policies for both are the same [20 CFR 681.600(c)(4)]. Each youth who has been determined eligible either as an In-school Youth or an Out-of-school Youth may receive OJT if appropriate, as determined by the local area. The appropriateness of this program element for a eligible youth is established through the participant’s objective assessment and individual service strategy [20 CFR 681.460(b). Out-of-school Youth may participate in Registered Apprenticeship Programs (RA) [TEGL 13-16]. RAs provide the required occupational and academic component required for Program Element 3 [TEGL 21-16].

A work experience may take place in the private for-profit sector, the non-profit sector, or the public sector. Labor standards apply in any work experience where an employee/employer relationship, as defined by the Fair Labor Standards Act or applicable State law, exists [20 CFR 681.600(a)]. Additional information on the employer/employee relationship may be found on DOL’s Wage and Hour Division website [TEGL 21-16]. For additional guidance concerning work experience regulations in general, see ADWS Policy No. WIOA I-B – 3.8 (Work Experience). For additional guidance concerning
on-the-job training, see ADWS Policy No. WIOA I-B – 3.4 (On-the-Job Training).

Not less than 20% of the youth funds allocated to a local area (minus area administrative costs) must be spent to provide ISY and OSY with paid and unpaid work experiences. Local youth programs musttrack program funds spent on paid and unpaid work experiences, including wages and staff costs for the development and management of work expenses, and report such expenditures as part of the local youth financial reporting. The percentage of funds spent on work experience is calculated as
the total amount spent on ISY and OSY work experience divided by the total allocated youth funds (minus administrative costs) [WIOA § 129(c)(4); 20 CFR 681.590; TEGL 23-14; TEGL 21-16]. Leveraged resources cannot be used to fulfill any part of the 20% minimum [TEGL 21-16].

Allowable work experience expenditures that may be included in the 20% minimum are [TEGLs 23-14, 8-15, & 21-16]:
a. Wages/stipends paid for participation in a work experience (including employment costs such as FICA match and workers’ compensation insurance)
b. Staff time working to identify and develop a work experience opportunity, including staff time spent working with employers to identify and develop the work experience
c. Staff time spent working with employers to ensure a successful work experience, including staff time spent managing the work experience
d. Staff time spent evaluating the work experience
e. Participant work experience orientation sessions
f. Employer work experience orientation sessions
g. Classroom training or the required academic education component directly related to the work experience
h. Incentive payments directly tied to the completion of work experience
i. Employability skills/job readiness training to prepare youth for a work experience

Supportive services are a separate program element, and funds spent for supportive services cannot be counted toward the 20% work experience work expenditure requirement, even if supportive services assist the youth in participating in the work experience [TEGL 21-16].
The academic and occupational education component that must be included with work experiences refers to contextual learning that accompanies a work experience. It includes the information necessary to understand and work in specific industries and/or occupations. The component may include learning the general duties of workers in the occupation, specific knowledge related to the occupation, specific skills needed to work in the occupation, or such. The component is not general
education, such as GED® classes. The component may occur concurrently or sequentially with the work experience, inside or outside the work site. The work experience employer may provide the academic and occupational component, or such components may be provided separately in the classroom or through other means [20 CFR 681.600(b); TEGL 21-16].

Program Element 4: Occupational skill training, which includes priority consideration for training programs that lead to recognized postsecondary credentials that align with in-demand industry sectors or occupations in the local area involved, if the LWDB determines that the programs meet the quality criteria for eligible providers of Youth workforce investment activities described in WIOA § 123 [20 CFR 681.460(a)(4) & 681.540(b); TEGL 21-16]. Occupational skills training is defined as an organized program of study that provides specific vocational skills that lead to proficiency in performing actual tasks and technical functions required by certain occupational fields at entry, intermediate, or advanced levels. Local areas must give priority consideration to training programs that lead to recognized postsecondary credentials that align with in-demand industry sectors or occupations in the local area [20 CFR 681.540].

Occupational skills training for youth must meet all of the following requirements [20 CFR 681.540(a); TEGL 21-16]:
a. Be outcome-oriented and focused on an occupational goal specified in the individual service strategy
b. Be of sufficient duration to impart the skills needed to meet the occupational goal
c. Lead to the attainment of a recognized postsecondary credential Individual Training Accounts (ITAs) may be provided to Out-of-School Youth (OSY) ages 16 to 24 with Youth funds [20 CFR 681.550; TEGL 21-16]. Youth funds may not be used to provide ITAs to In-School Youth (ISY), but ISY between the ages of 18 and 21 may co-enroll in the WIOA Adult program if the
youth’s needs, knowledge, skills, and interests align with the WIOA adult program, the youth meets priority requirements, and the ITA is funded by the Adult program [TEGL 21-16]. More information may be found in ADWS Policy No. WIOA I-B – 2.3 (Eligibility for Adult Program), ADWS Policy No. WIOA I-B – 2.7 (Co-enrollment), and ADWS Policy No. WIOA I-B – 3.3 (Occupational Skills Training).

Program Element 5: Education offered concurrently with workforce preparation and training for a specific occupation or occupational cluster [20 CFR 681.460(a)(50); TEGL 21-16] . This program element reflects an integrated education and training model that describes how workforce preparation activities, basic academic skills, and hands-on occupational skills training are to be taught within the same time frame and connected to training in a specific occupation, occupational cluster, or pathway [20 CFR 681.630].
Program Element 5 is the concurrent delivery of Program Element 2, Program Element 3, and Program Element 4 to create an integrated education and training model. When the program elements occur concurrently to train for a particular occupation, occupational cluster, or career pathways, the services are reported in Program Element 5. When the activities occur separately and at different times, they are reported in the Program Element 2, 3, or 4, as appropriate [TEGL 21-16].

Program Element 6: Leadership development opportunities, including community service and peer-centered activities encouraging responsibility and other positive social and civic behaviors [20 CFR 681.460(a)(6)]. Leadership development opportunities are opportunities that encourage responsibility, confidence, employability, self-determination, and other positive social behaviors, such as [20 CFR 681.520; TEGL 21-16]:
a. Exposure to postsecondary educational possibilities
b. Community and service learning projects
c. Peer-centered activities, including peer mentoring and tutoring
d. Organizational and team work training, including team leadership training
e. Training in decision-making, including determining priorities and problem solving
f. Citizenship training, including life skills training, such as parenting and work behavior training
g. Civic engagement activities that promote the quality of life in a community                                                                                                h. Other leadership activities that place youth in leadership roles, such as serving on youth
leadership committees, such as a Standing Youth Committee

Program Element 7: Supportive services that are necessary to enable an individual to participate in Youth activities [WIOA 3(59); 20 CFR 681.460], including, but not limited to [20 CFR 681.460(a)(7) & 681.570; TEGL 21-16]:
a. Linkages to community services
b. Assistance with transportation
c. Assistance with child care and dependent care
d. Assistance with housing
e. Assistance with educational testing
f. Reasonable accommodations for youth with disabilities
g. Legal aid services
h. Referrals to health care
i. Assistance with uniforms or other appropriate work attire and work-related tools, including such items as eyeglasses and protective eye gear
j. Assistance with books, fees, school supplies, and other necessary items for students enrolled in postsecondary education classes
k. Payments and fees for employment and training-related applications, tests, and certifications
For more information concerning supportive services, see ADWS Policy No. WIOA I-B – 3.9 (Supportive Services).

Program Element 8: Adult mentoring for a duration of at least 12 months, which may occur both during and following exit from the program. It must be a formal relationship between a youth participant and an adult mentor. There must be structured activities where the mentor offers guidance, support, and encouragement to develop the competence and character of the mentee.
Group mentoring and mentoring through electronic means are allowed as part of the mentoring activities, the local youth program must match the youth with an individual mentor with whom the youth interacts on a face-to-face basis. Mentoring may include workplace mentoring where the local program matches a youth participant with an employer or employee of a company [20 CFR 681.460(a)(8) & 681.490; TEGL 21-16]. Local programs should ensure appropriate policies and processes
are in place to adequately screen and select mentors [TEGL 21-16]. DOL strongly prefers that case managers not serve as mentors, but case managers may serve as mentors in areas where adult mentors are sparse [TEGL 21-16].

Program Element 9: Follow-up services for not less than 12 months after completion of participation [20 CFR 681.460(a)(9)], to ensure the youth is successful in employment and/or postsecondary education and training. Follow-up services may include, as appropriate [20 CFR 681.580]:
a. Regular contact with a youth participant’s employerb. Assistance in addressing work-related problems that arise
c. Supportive services, as described in Program Element 7
d. Adult mentoring, as described in Program Element 8
e. Financial literacy education, as described in Program Element 11
f. Services that provide labor market and employment information about in-demand industry sectors or occupations available in the local area, such as career awareness, career counseling, and career exploration services
g. Activities that help youth prepare for and transition to postsecondary education and training

When these services are given as follow-up services (after the expected exit date), they should be coded in AJL as follow-up services, as opposed to program services provided prior to exit. In addition, follow-up services should be documented in case files that they were provided as followup services post exit [TEGL 21-16].

Follow-up services may begin immediately following the last expected date of service in the programs included in the Common Exit date, when no future services are scheduled [TEGL 21-16].
Once 90 days of no services, other than follow-up services, self-service, and information-only services and activities, has elapsed and the participant has an official exit date applied retroactively to the last date of service, the program continues to provide follow-up services for the remaining 275 days of the 12-month follow-up requirement. The 12-month follow-up requirement is completed upon one year from the date of exit [TEGL 21-16].

All youth participants must be offered an opportunity to receive follow-up services that align with their individual service strategies. Follow-up services do not have to be provided if the participant declines to receive services or if the participant cannot be located or contacted. Follow-up services may be provided beyond 12 months at the discretion of the LWDB and the program provider. The types of services provided and the duration of the services must be determined based on the needs of the individual. Follow-up services must include more than only a contact attempted or made for securing documentation in order to report a performance outcome [20 CFR 681.580(c)]. Youth should be informed at the time of enrollment that follow-up services will be provided for 12 months following exit. Local programs should have policies in place to establish how to document and record when a participant cannot be located or contacted. Documentation must be placed in the case file if a youth requests not to receive or continue follow-up services [TEGL 21-16].

Program Element 10: Comprehensive guidance and counseling, which may include drug and alcohol abuse counseling, mental health counseling, and referral to partner programs, as appropriate to the needs of the individual youth. When referring participants to necessary counseling that cannot be provided by the local youth program or its program providers, the local youth program must coordinate with the organization it refers to in order to ensure continuity of service [20 CFR 681.510]. When resources exist within the local program or its service providers, it is allowable to provide counseling services directly to participants rather than refer youth to partner programs [TEGL 21-16].

Program Element 11: Financial literacy education, which may include the following activities [20 CFR 681.460(a)(11) & 681.500; TEGL 21-16]:
a. Support the ability of participants to create budgets, initiate checking and savings accounts at banks, and make informed financial decisions
b. Support participants in learning how to effectively manage spending, credit, and debt, including student loans, consumer credit, and credit cards
c. Teach participants about the significance of credit reports and credit scores, what their rights are regarding their credit and financial information, how to determine the accuracy of a credit report and how to correct inaccuracies, and how to improve or maintain good credit
d. Support a participant’s ability to understand, evaluate, and compare financial products, services, and opportunities and to make informed financial decisions
e. Educate participants about identity theft, ways to protect themselves from identity theft, and how to resolve cases of identity theft and in other ways understand their rights and protection related to personal identity and financial data
f. Support activities that address the particular financial literacy needs of non-English speakers, including providing the support through the development and distribution of multilingual financial literacy and education materials
g. Support activities that address the particular financial literacy needs of youth with disabilities, including connecting them to benefits planning and work incentives counseling
h. Provide financial education that is age appropriate, timely, and provides opportunities to put lessons into practice, such as by access to safe and affordable financial products that enable money management and savings
i. Implement other approaches to help participants gain the knowledge, skills, and confidence to make informed financial decisions that enable them to attain greater financial health and stability by using high quality, age-appropriate, and relevant strategies and channels, including, where possible, timely and customized information, guidance, tools, and instruction.

Program Element 12: Entrepreneurial skills training [20 CFR 681.460(a)(12)],which is training that develops the skills associated of starting and operating a small business. Such skills may include, but are not limited to, the ability to [20 CFR 681.560(a)]:
a. Take initiative
b. Creatively seek out and identify business opportunities
c. Develop budgets and forecast resource needs
d. Understand various options for acquiring capital and the trade-offs associated with each option
e. Communicate effectively and market oneself and one’s ideas

Approaches to teaching youth entrepreneurial skills include, but are not limited to [20 CFR 681.560(b); TEGL 21-16]:
a. Entrepreneurship education that provides an introduction to the values and basics of starting and running a business. Entrepreneurship education programs often guide youth through the development of a business plan and may also include simulations of business start-up and operation.
b. Enterprise development, which provides support and services that incubate and help youth develop their own businesses. Enterprise development programs go beyond entrepreneurship education by helping youth access small loans or grants needed to begin business operation and by providing individualized attention to the development of viable business ideas.
c. Experiential programs that provide youth with experience in the day-to-day operation of a business. Some of these programs may involve the development of a youth-run business that young people participating in the program work in and manage. Other experiential programs may facilitate placement in apprentice or internship positions with adult entrepreneurs in the community.

Program Element 13: Services that provide labor market and employment information about in-demand industry sectors or occupations available in the local area, such as career awareness, career counseling, and career exploration services [20 CFR 681.460(a)(13)]. Workforce and labor market information is the body of knowledge that describes the relationship between labor demand and supply [20 CFR 651.10]. Youth program providers should be familiar with state Labor market
information (LMI) tools. LMI tools identify in-demand industries and occupations and employment opportunities and provide knowledge of job market expectations. LMI also provides information about education, skill requirements, and potential earnings. Such information can help youth make appropriate decisions about education and careers [TEGL 21-16].
Career awareness begins the process of developing knowledge of the variety of careers and occupations available, their skill requirements, working conditions, training prerequisites, and job opportunities across a wide range of industry sectors. Career exploration is the process in which youth choose an educational path and training or a job that fits their interests, skills and abilities.
Career counseling or guidance provides advice and support in making decisions about what career paths to take. Career counseling services may include providing information about resume preparation, interview skills, potential opportunities for job shadowing, and the long-term benefits of postsecondary education and training [TEGL 21-16].

Program Element 14: Postsecondary preparation and transition activities [20 CFR 681.460(a)(14)]. Postsecondary preparation and transition activities and services prepare youth for advancement to postsecondary education after attaining a high school diploma or its recognized equivalent, although the services may be given before a youth earns the diploma or GED®.

These services include exploring postsecondary education options, such as technical schools, two-year colleges, four-year
colleges and universities, and registered apprenticeships. Additional services include, but are not limited to, assisting youth to prepare for SAT/ACT tests, assisting with college admission applications, searching and applying for scholarships and grants (including the FAFSA), and connecting youth to postsecondary education programs [TEGL 21-16].

Our Monitoring process includes reviewing each local areas' implementation of all 14 program elements annually.