MEMO: AP 00-05
November 15, 2016
DATE: June 20, 2000
TO: RWDB Directors; RWDB Chairpersons; Grant Recipients
FROM: Lorna Joseph, Acting Director of Operational Support
SUBJECT: Policy and Procedures for the
State Level Review of the Workforce Investment Act Eligible Training Program
The Department of Labor has been designated as
the agency responsible to administer the statewide list of WIA eligible training
programs. The process for approving programs was described in the 5-year WIA
Plan. It involves two review stages, one conducted by the Boards at the local
level, and the second conducted at the state level. Staff from CTDOL will
conduct the second-level review. The review procedures are constructed to ensure
that the review will be completed within a brief timeframe. The attached
outlines the criteria to be used.
If you have any questions, please call Adele
DeFrancesco in the Performance Measurement Unit at (860) 263-6741.
CT DOL Second Level Eligible Training
Program Approval Process
Each local board must submit a list of their
approved eligible training programs (ETPs) to CTDOL within 45 days of the
closing of the application period. In turn, CTDOL will review those lists to
determine if providers have a record of any employment law non-compliance that
may have a bearing on whether the provider should remain on the statewide list.
The State’s 5-year plan stipulates that ETPs
may be removed from the list of certified providers for one of several reasons:
1. Failure to provide information for
2. Failure to meet one or more performance standards.
3. Fraud or other non-compliance issues.
Reasons one and two are program-related, and
the local boards will identify issues related to these as the programs are
delivered. However, reason three applies directly to the reliability of the
provider and the appropriateness of purchasing services from that provider using
public funds. It is this concern that will be addressed by the second-level
review. In addition, CTDOL has the authority through WIA regulation, to take
appropriate enforcement action against providers in the case of the intentional
provision of inaccurate information.
The state level approval process will include
the following steps:
(1) (a) the provider’s record of fraud and/or
non-compliance is substantial, and
Workforce Boards will forward their local lists to
CTDOL will review the entities named on each list
and check with the following divisions to determine if there is a record of any
employment law non-compliance:
CTDOL Wage and Workplace Standards Division
Quality Program Review
Their review will encompass the current and
previous fiscal year records.
If the review identifies any substantive
violations or inaccuracies, CTDOL will notify the local boards.
The local boards will notify the provider that its
application cannot receive final approval until the provider and the enforcing
agency have agreed to a remedy.
CTDOL’s review will result in a decision to remove
a provider from the approved list only when it determines that:
(b) no remedy has been implemented; or
Or (2) the provider has intentionally provided
(c) a remedy has been implemented but the provider’s recent record of
employment law non-compliance is so extensive that, in CTDOL’s judgment,
certification should be withheld.
Or (3) the provider is found to have
substantially violated any WIA requirements.
The certification process includes a number of
steps that involve significant time periods, and regardless of the number of
applicants, it takes five to six months to complete. Consequently, additions to
the certified list will be made on a semi-annual basis, in January and July.
Applications requested in January will provide a list that can be used in July.
Applications requested in July will provide the list for use in January.
Finally, each second-level review will include
all new applicants as well as all previously approved applicants to ensure that
any intervening non-compliance issues are noted and considered. Such
non-compliance may be sufficient cause for removal from the statewide list.