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Plan: Missouri PYs 2024-2027
Combined Plan C

Section: Adult, Dislocated Worker, and Youth Activities

Narrative: e.

Published
Located in:

e. Waiver Requests (optional) (e1-e6)

States wanting to request waivers as part of their title I-B Operational Plan must include a waiver plan that includes the following information for each waiver requested:

  • 1. Identifies the statutory or regulatory requirements for which a waiver is requested and the goals that the State or local area, as appropriate, intends to achieve as a result of the waiver and how those goals relate to the Unified or Combined State Plan;

  • 2. Describes the actions that the State or local area, as appropriate, has undertaken to remove State or local statutory or regulatory barriers;

  • 3. Describes the goals of the waiver and the expected programmatic outcomes if the request is granted;

  • 4. Describes how the waiver will align with the Department’s policy priorities, such as:

    • A. Supporting employer engagement;

    • B. Connecting education and training strategies;

    • C. Supporting work-based learning;

    • D. Improving job and career results, and

    • E. Other guidance issued by the department.

  • 5. Describes the individuals affected by the waiver, including how the waiver will impact services for disadvantaged populations or individuals with multiple barriers to employment; and

  • 6. Describes the processes used to:

    • A. Monitor the progress in implementing the waiver;

    • B. Provide notice to any local board affected by the waiver;

    • C. Provide any local board affected by the waiver an opportunity to comment on the request;

    • D. Ensure meaningful public comment, including comment by business and organized labor, on the waiver.

    • E. Collect and report information about waiver outcomes in the State’s WIOA Annual Report.

  • 7. The most recent data available regarding the results and outcomes observed through implementation of the existing waiver, in cases where the State seeks renewal of a previously approved waiver.

Current Narrative:

Waiver Request #1

1. The statutory and/or regulatory requirements the State would like to waive:

WIOA Section 129(a)(4)(A) and 20 CFR 681.410; Missouri is requesting to waive the requirement that states, and local areas expend 75 percent of all Governor’s reserve and local formula youth funds on out-of-school youth based on school status. Missouri is requesting that this percentage be lowered to 50 percent for both local and statewide funded activities for PY2024 & PY2025 funds.

2. Actions the State has undertaken to remove State or local barriers:

There are currently no state or local statutory or regulatory barriers to implementing the requested waiver. The state of Missouri regulations, policy guidance and issuances are in compliance with federal law.

3.  A discussion of how the waiver complements Department of Labor priorities (i.e. expansion of apprenticeship, improved employer engagement, etc.);

The State of Missouri is a lead state in the nation for its apprenticeship programs. Missouri supports the registered apprenticeship program and continues to expand the program with statewide funds and other grants. The Department of Higher Education and Workforce Development has pledged to support opportunities for students and workers in high growth industries in the state including the healthcare, information technology, and advanced manufacturing sectors by engaging youth and providing opportunities in work-based learning, training, and other workforce services.

The Office of Workforce Development (OWD) and the Missouri Department of Elementary and Secondary Education (DESE) continue to develop apprenticeship opportunities for youth and young adults ages sixteen and older. Both pre-apprenticeships and registered apprenticeships allow high school juniors and seniors to simultaneously further education options and earn wages. Youth apprentices face a lower risk of dropping out of high school and are engaged in a transition to post-secondary education. The Missouri Research and Information Center (MERIC) has found that job openings that require education and skill level beyond high school are in high growth occupational fields and pay higher salaries.

With the approval of this waiver, the State of Missouri and Local Workforce Development Boards will have the flexibility to utilize federal funding to increase the number of youth and young adults enrolled in services, such as pre-apprenticeship and apprenticeship activities. Local Boards and youth staff will also have the ability to provide the comprehensive services needed and personal contact required to ensure student success. 

4. Quantifiable projected programmatic outcomes resulting from implementation of the waiver;

The goals and outcomes for this waiver are:

    1. Develop and/or expand registered apprenticeship programs with Missouri High Schools and Career and Technical Education (CTE) programs: An average of two apprenticeship programs per school year will be impacted. OWD currently works with the CTEs to expand and develop new registered apprenticeship programs through Apprenticeship Missouri grants, which are funded with WIOA discretionary funds and other federal funds. Grant awards are expected to be released by October 2023, with enrollments starting shortly after. Industries will include: healthcare, educational services, information technology, welding, construction, and more.  
    1. Increase in measurable skills gains for the In-School (IS) students based off PY2022 achieved measure of 54.23%: Year 1-1%; Year 2-2%; Year 3-3%; & Year 4-4%;

 

    1. Increase attainment of industry recognized credentials for high school youth based off PY2022 achieved measure of 60.83%: Year 1-1%; Year 2-1%; Year 3-1%; & Year 4-1%;

5. Individuals, groups or populations benefitting from the waiver or otherwise impacted by the waiver from the waiver:  

This waiver request will provide OWD and Local Workforce Development Boards (LWDBs) the flexibility to serve more youth and young adults in work-based learning and the apprenticeship model regardless of school status. It will facilitate the provision of the necessary funding and the ease of current regulations essential to designing programs that will aid youth and young adults in the preparation for long-term participation in the Missouri labor force. Economic growth in Missouri and its high-growth industries will be sustained with the infusion of skilled workers ready to fill current job openings and adequately trained for future openings.

Missouri will continue to train OSY through its WIOA funding. Local areas will not be required to utilize the waiver, however, will be required to submit a request to utilize the waiver locally, should it fall within the local area's local plan for serving both OSY and ISY.

Missouri students and eligible youth population, Missouri’s employers and high-growth industries will benefit from this waiver.

6. How the State plans to monitor waiver implementation, including collection of waiver outcome information: 

Once it is approved, OWD will issue guidance to the local workforce development boards (LWDB) that outlines the process to request the use of the waiver, as well as the mandatory reporting process. The reporting at a minimum will require the WDBs monitor the waiver and the utilization and submit quarterly reports to the state regarding enrollments that impact the waiver; outcomes of the trainings received; and the impact it has had on enrollments and WIOA metrics. The implementation and progress of the waiver utilization will be reviewed, at a minimum, quarterly by programmatic, compliance, and fiscal staff with technical assistance being providing as needed. 

In addition to the quarterly reports submitted by the WDBs, OWD units will utilize the state’s electronic case management system (MoJobs) to verify customer enrollments and outcomes. OWD’s financial monitoring will utilize the Financial Reporting System (FRS) to monitor expenditures and lines items applicable to the waiver.   

Most recent data regarding this waiver is provided.

In-School Youth Served

Previous data for measurable skill gains and credentials: 

Performance Data

Waiver Request #2

1. The statutory and/or regulatory requirements the State would like to waive:

20 CFR 681.550: Missouri is requesting a waiver to allow local areas and the state to provide in-school youth, ages 16-21 with Individual Training Accounts (ITAs).  This will allow Missouri to collaborate with education institutions to prepare students for employment through registered apprenticeship opportunities or through post-secondary education opportunities. 

2. Actions the State has undertaken to remove State or local barriers:

There are currently no state or local statutory or regulatory barriers to implementing the requested waiver. The state of Missouri regulations, policy guidance and issuances are in compliance with federal law.

3. State strategic goal(s) and Department of Labor priorities (i.e. expansion of apprenticeship, improved employer engagement, etc.) supported by the waiver:

Missouri would like to waive this requirement in order to allow ITAs for out of school youth and expand the flexibility to in-school youth, ages 16-21. This will expand training options and allow these youth to explore and consider various post-secondary career pathway options, such as registered apprenticeship programs and college. 

4. Projected programmatic outcomes resulting from implementation of the waiver:

The goals and outcomes for this waiver are to:

  1. Develop and/or expand registered apprenticeship programs with Missouri High Schools and Career and Technical Education (CTE) programs: An average of two apprenticeship programs per school year will be impacted. OWD is currently working with the CTEs to expand and develop new registered apprenticeship programs through Apprenticeship Missouri grants, which are funded with WIOA discretionary funds and other federal funds. Grant awards are expected to be released by October 2023, with enrollments starting shortly after. Industries will include: healthcare, educational services, information technology, welding, construction, and more.

 

  1. Increase in measurable skills gains for the In-School (IS) students based off PY2022 achieved measure of 54.23%: Year 1-1%; Year 2-2%; Year 3 3%; & Year 4-4%;

 

  1. Increase obtainment of industry recognized credentials for high school youth based off PY2022 achieved measure of 60.83%: Year 1-1%; Year 2-1%; Year 3-1%; & Year 4-1%;

 

5. Individuals, groups or populations benefitting from the waiver:

This waiver will benefit the WIOA in-school youth population, ages 16-21, which includes disadvantaged youth and youth with multiple barriers to employment.

Missouri will continue to provide ITA for OSY through its WIOA funding. Local areas will not be required to utilize the waiver request, however, will be required to submit a request to utilize the waiver locally, should it fall within the local area’s local plan for the delivery of training services for ISY. Through this waiver, the state will provide ITAs for ISY ages 18-24.

6. How the State plans to monitor waiver implementation, including collection of waiver outcome information:

Once it is approved, OWD will issue guidance on the waiver which will include a mandatory reporting process for the Workforce Development Boards (WDBs) that request and utilize the specific waiver. The reporting at a minimum will require the WDBs monitor the waiver and the utilization and submit quarterly reports to the state regarding enrollments that impact the waiver; outcomes of the trainings received; and the impact it has had on enrollments and WIOA metrics.  The implementation and progress of the waiver utilization will be reviewed at a minimum, quarterly by programmatic, compliance, and fiscal staff with technical assistance being providing if needed.

In addition to the quarterly reports submitted by the Workforce Development Boards, OWD units will utilize the state’s electronic case management system (MoJobs) to verify customer enrollments and outcomes. OWD’s financial monitoring will utilize the Financial Reporting System (FRS) to monitor expenditures and lines items applicable to the waiver.  

Waiver Request #3

1. The statutory and/or regulatory requirements the State would like to waive:

WIOA 134(c)(3)(H)(i) and 20 CFR 680.720(b); Waiver to increase on-the-job training employer reimbursement up to 90 percent for businesses.   

2. Actions the State has undertaken to remove State or local barriers:

There are currently no state or local statutory or regulatory barriers to implementing the requested waiver. The state of Missouri regulations, policy guidance and issuances are in compliance with federal law.

3. State strategic goal(s) and Department of Labor priorities (i.e. expansion of apprenticeship, improved employer engagement, etc.) supported by the waiver:

The State of Missouri will utilize this waiver to offer businesses with work-based learning opportunities to re-establish their workforce and provide job seekers the opportunity to connect with the workforce and learn skills to establish self-sufficiency. This waiver is intended to improve employer engagement and allow for more businesses to be supported through WIOA funding. Additionally, this waiver will support expansion of apprenticeship programs and support future grant funding currently under application status to help move Missourians into good, quality jobs.  

4. Projected programmatic outcomes resulting from implementation of the waiver:

This waiver request will assist Missouri to further enhance its existing efforts designed to establish a talent pipeline that will address the labor market needs of local Missouri businesses. 

PY2022 data shows that OJT has decreased significantly. In 2023, OWD hired an apprenticeship and work-based learning program coordinator; this staff member will be crucial in increasing awareness of OJT and waivers available and providing local workforce areas with program guidance, materials, and other technical assistance identified. Staffing support is expected to yield an increase in OJT enrollments. Meanwhile, staff continue to market OJT as WIOA programmatic support for apprenticeship and will offer a valuable resource to local workforce development areas looking to expand business service offerings.

The goal is to increase the number of OJTs being utilized by 20% each year, using PY2022 data (29) as the baseline.

5. Individuals, groups or populations benefitting from the waiver:

This waiver request will provide Local Workforce Development Boards (LWDBs) the flexibility to work with businesses in their community, following the targeted businesses outlined in local policy, and assist job seekers with barriers to employment and in need of additional training to secure employment.

Local areas have had difficulty using OJT at the rate allowed by law due to the decrease in local business outreach staff. The state has a statewide OJT policy in place which requires every local board to establish OJT policy that establishes factors used to determine when increasing the OJT wage reimbursement rates above 50% to 75%, as required under 20 CFR 680.730, which includes employers qualified as small businesses. In following WIOA regulations, the intent is not for the reimbursement to go only to large businesses. However, with staff turnover and being a large business, it is costly and time consuming to train individuals.

Additionally, the statewide policy mandates that every employer must undergo a pre-award review. The pre-award review assesses the employer’s previous OJT history, among other requirements. Policy states: OJTs must not be entered into with employers that consistently fail to retain OJT participants. 

The State Workforce Development Board and the Governor both have reviewed and approved Missouri’s state plan.

6. How the State plans to monitor waiver implementation, including collection of waiver outcome information: 

Once it is approved, OWD will issue guidance on the waiver which will include a mandatory reporting process for the Workforce Development Boards (WDBs) that request and utilize the specific waiver. The reporting at a minimum will require the WDBs monitor the waiver and the utilization and submit quarterly reports to the state regarding enrollments that impact the waiver; outcomes of the trainings received; and the impact it has had on enrollments and WIOA metrics. The implementation and progress of the waiver utilization will be reviewed at a minimum, quarterly by programmatic, compliance, and fiscal staff with technical assistance being providing if needed. 

In addition to the quarterly reports submitted by the WDBs, OWD units will utilize the state’s electronic case management system (MoJobs) to verify customer enrollments and outcomes. OWD’s Regulatory Compliance team will monitor expenditures to ensure WDBs are following established written policies to allow for the use of the increase reimbursement rate.     

Most recent data regarding current waiver request provided.

On-the-Job Training by Region

Waiver Request #4

1. The statutory and/or regulatory requirements the State would like to waive:

 WIOA 134(d)(4) and 20 CFR 680.800(a)

Missouri requests to waive the ability of the local areas to reserve more than 20% of Adult and Dislocated Worker funds for incumbent worker training for PY2023 and PY2024.

2. Actions the State has undertaken to remove State or local barriers:

There are currently no state or local statutory or regulatory barriers to implementing the requested waiver. The state of Missouri regulations, policy guidance and issuances are in compliance with federal law.

3. State strategic goal(s) and Department of Labor priorities (i.e. expansion of apprenticeship, improved employer engagement, etc.) supported by the waiver:

In an effort to assist employers with upskilling current employers to remain marketable and competitive, the State of Missouri is requesting this waiver to allow the local areas the flexibility to offer additional incumbent worker training opportunities within their service area. This waiver will assist local workforce development areas support in improving employer engagement efforts.  

 4. Projected programmatic outcomes resulting from implementation of the waiver:

The use of these strategies will increase skills for underemployed workers in an effort to advance these workers to more skilled positions with the same employer or industry sector leading to an increase in earnings through more work hours or an increase in pay.

The availability to access Incumbent Worker Training has increased over the past three years from one region to seven regions. IWT training for this year (PY22) served a total of 171 participants throughout Missouri. During the waiver period, OWD’s Work Based Learning Coordinator hosted a cohort of Local Workforce Development Board (LWDB) Directors or other key staff to the board. The cohort met bi-monthly and were provided with technical assistance on work-based learning and apprenticeship with an increased emphasis on incumbent worker training. These cohort calls discontinued in the spring of 2023 due to staff transition, notably, enrollments in IWT decreased slightly. In summer 2023 hired a new apprenticeship and work-based learning program coordinator who will resume those cohorts to support IWT and other work-based learning needs/supports. There are 7 local boards who have engaged in IWT in their areas. The goal of this waiver will be to increase participants served by 10% (188), increase the number of employer served by 10% (18), and assist at least one new local board to engaging in IWT as an available service.

5. Individuals, groups or populations benefitting from the waiver:

This waiver request will provide Local Workforce Development Boards (LWDBs) the flexibility to work with businesses in their community to re-build their workforce and possibly alleviate business closures and lay-off.  It will also provide an opportunity for incumbent workers to retain employment and upgrade skills.

Missouri would like to request a threshold of up to 50%. The 20 percent threshold limits local areas who are actively providing incumbent worker training services. By allowing an increase in this area, local areas can provide services to employers, increase skill levels of Missouri’s workers, and overall lead to better economic growth and higher wages.

6. How the State plans to monitor waiver implementation, including collection of waiver outcome information:

Once it is approved, OWD will issue guidance on the waiver which will include a mandatory reporting process for the Workforce Development Boards (WDBs) that request and utilize the specific waiver. The reporting at a minimum will require the WDBs monitor the waiver and the utilization and submit quarterly reports to the state regarding enrollments that impact the waiver; outcomes of the trainings received; and the impact it has had on enrollments and WIOA metrics.  The implementation and progress of the waiver utilization will be reviewed at a minimum, quarterly by programmatic, compliance, and fiscal staff with technical assistance being providing if needed. 

In addition to the quarterly reports submitted by the Workforce Development Boards, OWD units will utilize the state’s electronic case management system (MoJobs) to verify customer enrollments and outcomes. OWD’s financial monitoring will utilize the Financial Reporting System (FRS) to monitor expenditures and lines items applicable to the waiver.   

Most recent data regarding current waiver request provided.

Incumbent Worker Training by Region

Incumbent Worker Employers by Region