MEMO: AP 01-16
November 15, 2016
DATE: April 23, 2001
TO: WIB Directors, WIB Chairpersons, Grant
FROM: Lorna Joseph, Director of Program Support
SUBJECT: Guidance to WIB Areas on Client Registration
and Flow Process
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
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
develop a local policy that defines the “point of registration” for core
activities based upon two factors:
the service requires a significant amount of staff
- 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
Initial Core Services (Adults and Dislocated
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
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
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
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:
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
- 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
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
Connecticut DOL has issued specific policy on
eligibility requirements for dislocated workers contained in AP 00-16 and Change
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:
is there a “local” priority of service
what are the Gateway Activities for dislocated
what assessment tool(s) are used for dislocated
what prioritization for training has the local Board
developed and how should it be utilized (i.e., occupations in demand, employer
how will it be ensured that training decisions made
are labor market driven;
- 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.
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.
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
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.