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MEMO: AP 00-05

Last Updated: 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 List

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.

Attachment
 


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 calculating performance.
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:

  • Workforce Boards will forward their local lists to CTDOL.
  • 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
  • UI Tax
  • 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:
(1) (a) the provider’s record of fraud and/or non-compliance is substantial, and

(b) no remedy has been implemented; or
(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 (2) the provider has intentionally provided inaccurate information.

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.

Administrative Procedures Memos


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