Narrative: III. b. 2.

Based on Policy 18-001, titled "Co-Enrollment Requirements for all One-Stop Partners," is designed to support the co-enrollment in multiple programs delivers comprehensive services to customers who have barriers to employment. 20 C.F.R §679.560 describes the creation and content of the Local Board’s state plan. More specifically, (b)(2)(ii) dictates that Local Boards must describe how they will work with entities carrying out core programs to develop career pathways and co-enrollment, as appropriate.

Coordinating services and eliminating barriers to success early in the process will reduce the likelihood that customers will have to re-enter the public workforce system in the future. WIOA gives states the authority to establish policies and guidelines related to verifying WIOA and Employment Services eligibility as long as the policies are consistent with WIOA, the WIOA regulations, the Wagner-Peyser Act, the Trade Adjustment Assistance Act, among other regulations, and federal statutes.

The One Workforce System embraces a culture of a united workforce so that any staff member within a Kentucky Career Center may serve a customer (job-seeker or business). In order to implement co-enrollment, individuals enrolled in WIOA Title I Adult and Dislocated Worker Programs must be co-enrolled in both Wagner-Peyser and the Trade Adjustment Assistance (TAA) Programs, if applicable. Although WIOA encourages co-enrollment in all four core programs (i.e., WIOA Title I, Wagner-Peyser, Vocational Rehabilitation and Adult Education), the efforts of co-enrollment addresses REQUIRED co-enrollment of participants under the WIOA Title I Adult and Dislocated Worker (DW) programs, Wagner-Peyser, and the Trade Adjustment Assistance.

In addition to the United States Department of Labor (USDOL) required co-enrollment with the WIOA DW program, based on the needs of the trade-affected worker, co-enrollment can be further enhanced and expanded to include a broad range of services available through other workforce programs in order to produce successful outcomes. Such programs include, but are not limited to, Wagner-Peyser Act Employment Service (ES) activities, WIOA Adult program, WIOA Dislocated Worker Grant (DWG) program, Unemployment Insurance (UI), other WIOA partner programs, faith-based and community-based programs, vocational rehabilitation services, and services for veterans. Partnerships may be facilitated at the state and local board level, as that leadership is deemed vital to the success of co-enrollment.

The policy in Kentucky states that adults and dislocated workers who receive KCC services other than self-service and informational activities will be co-enrolled in Wagner-Peyser, WIOA, and if eligible Trade Adjustment Assistance through an automated process in the state’s official system of record. Staff shall ensure the correct activities are recorded for the respective programs and verify date of birth (DOB) / Veteran (VETS) information in the system of record. Customers will then be co-enrolled and counted in both Wagner-Peyser, WIOA, and if eligible Trade Adjustment Assistance (TAA) performance measures.

Under 20 CFR §680.110(a), registration is the process of collecting information to support a determination of eligibility. Participation occurs after the registration process when the individual receives a staff-assisted WIOA service, which does not include self-service or information activities. Under 20 §CFR §680.110 (b), adults and dislocated workers who receive services funded under Title I other than self-service or informational activities must be registered and must be a participant.

As part of the Welcome, Orientation, and Assessment (WOA), staff will verify the customer’s DOB and VETS information, if applicable and record any activities that have been completed. An overnight batch process will then look for activities that trigger co-enrollment and the customer will be enrolled in both WIOA, Wagner-Peyser, and if eligible, Trade Adjustment Assistance.

Eligible registrants may access self-service and informational services available at all locations. Customers may not receive any funded career or training services until additional WIOA eligibility documentation has been completed. Staff should check the DOB/VETS Verification tab in the system of record on prior registered customers who return to any Career Center for services and update the record with proper DOB/VETS information as legacy records will not have complete information. Staff should determine if the current DOB documentation has expired and update it as needed. Failure of the customer to provide needed documentation shall not preclude delivery of services to the customer.

TAA Program, WIOA DW, and DWG co-enrollment may provide trade-affected workers with career and supportive services that are not available through the TAA Program. DWG co-enrollment can be used to provide potential trade-affected workers with career, training, and supportive services when state WIOA DW funds are not sufficient to provide such services. Eligible trade-affected workers may receive DWG- funded training only if the TAA Program does not cover the available training.

DWG and TAA funds must be managed in a coordinated manner to best meet the needs of the trade-affected workers while abiding by all applicable statutes, regulations, and federal policies. The DWG project guidance, TEGL No. 12-19, provides more details on the circumstances for provisions of training. The Trade Act, as amended, allows states to pay for a training program approved under the Act with TAA funds or from other sources, but does not allow duplication of payment of training costs. (See 20 CFR §618.625.) Under certain circumstances, a state can use funding from more than one program to fund training; however, TAA funds can only reimburse training costs incurred after a trade-affected worker was certified and determined individually eligible for TAA, and that training must be TAA-approved.

Additionally, 20 CFR §618.625(c) requires that the TAA Program be the primary source of assistance to trade-affected workers. To the extent trade-affected workers enrolled in the TAA Program require assistance or services not authorized under the TAA Program, or for which TAA Program funds are unavailable or insufficient (including for required employment and case management services), states must provide such assistance through other federal programs, including programs in the AJC network.

Additional guidance for one-stop partner contributions is provided through our WIOA Memorandum of Understanding (MOU) and an Infrastructure Funding Agreement (IFA) process addressing services for building up the workforce. The memorandum of understanding (MOU) is a formal document that spells out what everyone agrees on about running and managing One-Stop Career Centers in a certain Local Workforce Development Board Area (LWDA). The parties usually include the Chief Elected Official (CEO), the Local Workforce Development Board (LWDB), and other partners that offer services to the workforce. The MOU covers shared customers, shared services, and shared costs for workforce development and services that help people find jobs and improve their skills, companies, and businesses. The MOU has a part called the IFA that talks about funds for the infrastructure costs of running the One-Stop Career Centers. It spells out how the LWDB, CEO, and partners will handle and distribute money to meet the infrastructure needs of the centers. The IFA lets the LWDB and each partner talk about changes to the funding for services and running costs under the MOU because funds are usually allocated once a year.

WIOA requires the MOU and IFA to be made. The process includes finding locations for the centers, making a running budget that includes infrastructure costs, and preparing and agreeing to the IFA. The legal paperwork is the result, but the attention is not just on service sites; it's also on how well partners work together.

In Kentucky, the MOU defines the roles and responsibilities of each partner as mutually agreed by the parties for the operation of the Kentucky Career Center (KCC) service delivery system in the WIOA Local Workforce Area as required under WIOA and includes the following:

• WIOA Section 121(c) requires that each Local Workforce  Development Board (LWDB), with the agreement of the Area’s Chief Elected Official (CEO), develop and enter into a memorandum of understanding (between the local board and the one-stop partners), with all the entities that serve as partners in the KCC delivery system that operates in each LWDB’s local area.
• WIOA Section 121(b)(1)(A)(iii) mandates all entities that are required partners in a local area to enter into a memorandum of understanding with the LWDB in the respective area pursuant to WIOA Section 121(c).
• WIOA Section 121(b)(1) identifies the federal programs and requires that the services and activities under each of those programs must be made available through each local area’s KCC delivery system. The entities that receive the federal funds for each of these programs and/or have the responsibility to administer the respective programs in the Area are required partners under WIOA Section 121(b)(1).
• WIOA Section 121(b)(2) prescribes how entities that provide programs other than those required under WIOA Section 121(b)(1)(B) may participate in a local area’s KCC delivery system as “additional partners” and provide the services available under their programs through the KCC delivery system.
• Per WIOA Section 121(b)(2)(A), both required, and additional partners are included as parties to the MOU.  Therefore, all entities that participate in an Area’s KCC delivery system as KCC partners (Partners), whether required or additional, must be parties to this MOU and must abide by the terms prescribed herein and by all applicable federal, state, and local rules, plans, and policies as applicable and authorized under the Partner’s program and in keeping with federal guidelines.
• WIOA Section 121(b)(1)(A)(iv) indicates that the requirements of each partner’s authorizing legislation continue to apply under the KCC system and that participation in the KCC delivery system is in addition to other requirements applicable to each partner’s program under each authorizing law.
• The Department of Labor (DOL) is the federal agency responsible for administering workforce development programs, including WIOA.
• The DOL recognizes the Kentucky Education and Labor as the agency responsible for the administration and oversight of workforce development and employment-related programs in the Commonwealth of Kentucky—including WIOA. The Department of Workforce Development (DWD) fulfills this role on behalf of the Cabinet.

In essence, the WIOA MOU IFA method is a crucial framework that ensures all stakeholders work in unison to deliver comprehensive workforce services. This approach not only keeps costs in check but also underscores the importance of each partner's role in the work.