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Plan: Colorado PYs 2024-2027
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

  • A. Describe how the State will implement the priority of service provisions for covered persons 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.

  • B. Describe how the State will monitor priority of service provisions for veterans.

  • C. Describe the triage and referral process for eligible veterans and other populations determined eligible to receive services from the Jobs for Veterans State Grants (JVSG) program’s Disabled Veterans’ Outreach Program (DVOP) specialist/Consolidated Position.

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.

(A) DESCRIBE HOW THE STATE WILL IMPLEMENT THE PRIORITY OF SERVICE PROVISIONS FOR COVERED PERSONS 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.

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 to ensure that procedures are in place for the provision of Priority of Service to all veterans and covered persons. 

These Priority of Service policies and procedures will be submitted for review and approval by the State Veterans Program Coordinator. Each year local areas 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 AJCs implement policies and procedures that: 

  • Identify veterans and eligible persons at the point of entry (physical locations, websites, 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 veterans and spouses who are eligible for priority of service. If “entry” is made via the Colorado Department of Labor and Employment website under “Veterans”, “Veteran Priority”, and “Veterans are our 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 their 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 the “more information” link on the registration page which takes them to the “veteran’s are our priority” link which describes veterans priority of service. 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 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. 

(B) DESCRIBE HOW THE STATE WILL MONITOR PRIORITY OF SERVICE PROVISIONS FOR VETERANS.

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 utilized by providing training, technical assistance and monitoring accomplished by CDLE. CLDE staff that will assist with these items are the Regional Services Unit (RSU),  Local Veteran Employment Representatives (LVER), Consolidated Veteran Services Representatives (CVSR: consolidated DVOP/LVER), CDLE Monitors, the State Veterans Program Coordinator, CDLE Regional Directors, and Veteran Program Managers. JVSG funded staff are not responsible for applying priority of service but will have a foundational understanding of how the measure is applied and calculated and LVERs/CVSRs will meet with local AJC staff regularly  to assist with assessing POS outcomes and assist with modifying processes, as needed.

Methods and means used to monitor and verify whether or not Priority of Service is being provided will be the following but are not limited to:  

  • Wagner-Peyser “Vet Priority of Service” report
  • ETA 9173
  • 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 

CDLE and USDOL/VETS monitor and review the provision of services to veterans at the state and local levels tri-annually or as directed, and provide the Executive Director, Local Area Directors, and the local workforce center manager with the findings, recommendations and/or corrective actions. LVERs and CVSRs will conduct Priority of Service overview and training annually or as needed for additional training in their local area. A Priority of Service slide presentation is available to AJC staff to utilize as a training tool. This presentation, in the absence of a LVER or CVSR, can be used for training purposes of AJC new hires. As a condition of receiving any USDOL funds for programs, local areas will provide Priority of Service to veterans and covered persons. This annual agreement is a contract between the State of Colorado and the local areas. The contract must be signed by both the state and local areas as a condition to receive all US Department of Labor funds. 

(C)DESCRIBE THE TRIAGE AND REFERRAL PROCESS FOR ELIGIBLE VETERANS AND OTHER POPULATIONS DETERMINED ELIGIBLE TO RECEIVE SERVICES FROM THE JOBS FOR VETERANS STATE GRANTS (JVSG) PROGRAM’S DISABLED VETERANS’ OUTREACH PROGRAM (DVOP) SPECIALIST/CONSOLIDATED POSITION.

 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 or email. 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/CVSR services. Secondly, SBE eligible veterans and/or other eligible persons may be referred for DVOP/CVSR 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/CVSR services, the AJC staff member then notifies the DVOP specialist or CVSR 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/CVSR services, the AJC is ultimately responsible for providing employment services to all registered individuals who are seeking assistance. The intent for assigning DVOP, CVSR, 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/CVSRs 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 meet with a DVOP specialist or CVSR during a scheduled meeting.