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MEMO: AP 01-16

Last Updated: June 25, 2018

 April 23, 2001

TO: WIB Directors, WIB Chairpersons, Grant Recipients

FROM: Lorna Joseph, Director of Program Support

SUBJECT: Guidance to WIB Areas on Client Registration and Flow Process

America's Workforce Network

Background:  In an AP draft memo dated February 23, 2001, we provided WIB areas with guidance on the client registration and flow process.  That draft resulted in comments from two areas.  We have reviewed those comments and have made some additional clarifications to the issuance and are now issuing it as final policy.

Policy:  The following is adopted as state guidance policy on the client registration and flow process.

Local Coordination of Policies

Any and all policies impacting WIA client flow and services must at a minimum, be shared with the One-Stop Operator and all local MOU partners.

We further recommend that the Board and the One-Stop Operator, and other partners as necessary, review all Board policies on the areas discussed in this guidance to ensure staff is aware of all pertinent policy and is following such policy.

WIA Title IB Registration

The State provided in AP 00-09, specific requirements that areas need to comply with regarding when a client should be registered into the state’s WIA reporting system.  That policy stated that each Board must develop a local policy that defines the “point of registration” for core activities based upon two factors:

  1. the service requires a significant amount of staff assisted time;

  2. the service is individualized.

Each area must make a determination on an individual’s need to be registered based upon those two principles.  We believe principle 1 can be answered through each local Board developing a standard for when core services to an individual has reached the level of “significant amount of staff assisted time”.  The definition that you adopt and how staff applies it should be easily understood by all staff making registration decisions and be kept readily available for review.

On the second principle, we are advising that each area only register those individuals receiving individual staff assistance.  You do not need to register individuals enrolling in only group sessions.

We expect that at this time, all areas should have a “point of registration in WIA IB” policy in place and operational.  We recommend that each area specifically identify those core services considered pre-registration activities and those activities requiring registration.

Initial Intake and Referral

Each area must have in place, a policy that defines the process for a client to enter the One-Stop system (based on the particular programs and partners included in the local system) whether or not the client is registered for WIA IB.

The intent of this requirement is to have an easily understood process in place in each area for an individual to access universal services.

Initial Core Services (Adults and Dislocated Workers)

As stated earlier, each Board must identify non-registerable core services.  They must have procedures in place to identify when a client will be referred to these universal services.  They should also be utilizing the Job Center swipe card to record such services or any comparable system that exists, which collects core services.

Gateway Activities (Adults and Dislocated Workers)

These are those core services that would cause a service provider to make a referral to the case manager (i.e., job hunting > 3 months participation in workshops without securing a job).  There must be a clear awareness for all those involved in the client flow process as to when and where this is expected to occur.  These activities would have to occur before an individual is referred to intensive services.

There is no minimum time period for activities.  Each area will need to determine the appropriate progression of services based on individual needs.

Priority of Services

Pages 50 and 51 of Connecticut’s Five Year WIA Plan contains the following requirement on adult funds:

Under conditions of limited funding availability, a specific priority of the state of Connecticut in the implementation of its workforce investment system under WIA will be the delivery of services to Temporary Family Assistance (TFA) public assistance recipients and other low-income job seekers and “at-risk workers” (as defined in P.A. 99-195, enacted by the Connecticut Legislature).  The overall goal for the delivery of services to these populations will be the attainment of stable, full-time employment that meets the self-sufficiency measurement calculated by the Office of Policy and Management, pursuant to C.G.S. Sec. 4-66e.

Connecticut recognizes both the expressed goal of WIA to reduce welfare dependency and the specific statutory mandate of WIA to prioritize the delivery of adult intensive and training services to recipients of public assistance and other low-income individuals in situations where local area funding allocations for adult employment and training activities are limited.  The state assumes, unless specifically demonstrated to the contrary by a RWDB, that local area funding allocations under WIA for adult employment and training activities are limited.  However, in prioritizing service delivery, the availability of TANF funds must also be considered.

Accordingly, the RWDBs will be directed to implement the following:

  • Document in their local plans an assessment of local area needs for employment and training programs, particularly those of TFA recipients and other low-income persons;

  • Identify in their local plans how TFA recipients and other low-income persons will be prioritized in the delivery of intensive and training services within their local areas.  This prioritization process must include an assessment of:  (a) how local area funding allocations will be specifically targeted toward these populations; (b) how the local area One-Stop delivery system will prioritize resources toward service delivery directed at these populations; (c) how local area resources will be directed toward the goal of stable, full-time employment meeting the self-sufficiency measurement for each individual participant served in these populations; and

  • Document in their periodically required performance measurement reporting data the outcomes of service delivery targeted to these populations.  These will include both the WIA core indicators of performance and the applicable customer satisfaction indicators.

Adult Intensive and Training Services

Each area must have a local policy for adult priority of service.  Local policy must define the process and procedures for the required registration of adults enrolled into any intensive and/or training services.  This policy must address specific eligibility and documentation requirements for both intensive and training services.

Section 663.220 of the Final WIA Regulations sets forth certain conditions for an individual to move from core to intensive services.  Those criteria are:

  1. the individual is an unemployed adult or dislocated worker who received at least one core service and was unable to obtain employment through core services and has been determined by the One-Stop Operator to be in need of more intensive services to obtain employment;

  2. the individual is an employed adult or dislocated worker who has received at least one core service and has been determined by the One-Stop Operator to be in need of intensive services to obtain or retain employment that leads to self-sufficiency.

Self-sufficiency is to be defined by the local Board.  Section 663.230 of the Final WIA Regulations provides general guidance to local Boards on criteria for determining self-sufficiency.

Dislocated Workers

Connecticut DOL has issued specific policy on eligibility requirements for dislocated workers contained in AP 00-16 and Change 1.

While this policy sets forth specific eligibility for dislocated workers, there is a variety of other dislocated worker client flow issues to address.  Local areas should identify as they have for adults, specific differences that may apply to dislocated workers from the eligible adult population.  The issues for dislocated workers should include:

  1. is there a “local” priority of service policy;

  2. what are the Gateway Activities for dislocated workers;

  3. what assessment tool(s) are used for dislocated workers;

  4. what prioritization for training has the local Board developed and how should it be utilized (i.e., occupations in demand, employer needs);

  5. how will it be ensured that training decisions made are labor market driven;

  6. leave room for making individualized judgment.

All youth provided services under WIA are registered.  Local policy should provide guidance on how youth are to be determined eligible, referred and assessed.  It should identify whether younger youth or older youth have differences in this process.  It should help identify what services will be best for a youth also eligible under the adult program.  It should identify priority of service and Board adopted barriers.

In your youth policies, you may want to consider the fact that 30 percent of youth funds must be spent on youth that meet the definition of out-of-school youth as defined in the WIA Act.

Program Integration

It has been brought to our attention that some areas may be unintentionally screening out TANF clients from the ability to pursue training by imposing requirements for prerequisite core activities that may not account for similar activities from another funding source.

Please be aware that you can have a local policy that contains prerequisite core and/or intensive services before training, as long as the policy treats all applicants in the same manner.  Additionally, we strongly urge you to develop a policy that appropriately provides consideration for comparable activities funding through other funding sources.

Board Input

We recommend that your local Board approve all local policy requested in this issuance.  Only through this type of involvement can we be assured that those interests represented on the Board can be heard and that the local policies developed and approved have been subject to the appropriate review.

As stated previously, we are prepared to assist you with technical assistance on the development of local policy or in providing specific training as necessary.  We look forward to working with you on this and other areas of mutual concern.

Any questions on this issuance can be directed to your WIA area liaison.

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