WIOA Frequently Asked Questions

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2020 COVID-19

Can the grantee’s paid leave policy charge the federal grant for employees (including subrecipients and contractors) that are not working due to COVID-19 closures or disruptions?

Beginning November 1, 2020, grant recipients and subrecipients must make every effort to provide services remotely or, where feasible and consistent with state and local laws, in-person. Any paid leave to staff beyond this time must be approved by the Grant Officer.
Can the WIOA youth programs continue to pay participants wages if the worksite is canceled due to COVID-19?

If the program participant’s time commitment, wage/stipend structure, and/or other academic or work terms were established before the national health emergency declaration, grantees should continue to pay the participant for the remainder of the established term. Grantees should not pay participants beyond the established term, regardless of stay-at-home orders.
Fiscal Management Q1: Will the local workforce areas continue to have access to post costs and request cash from the Grant Reporting System?

Yes, the Department of Commerce and Economic Opportunity (DCEO) accounting office have staff that are assigned to process the cash requests. The Office of Employment and Training (OET) staff will review each cash request remotely.
Fiscal Management Q10: Can DCEO give us flexibility with the IWT line item of the budget so that we don’t need to make multiple mods to change the dollar amount allocated to it?

It is recognized that Incumbent Worker Training (IWT) can be a significant tool in response to the COVID crisis and the challenges that businesses are currently facing. The Office of Employment and Training (OET) knows that the Incumbent Worker Tracking System (IWTS) in workNet doesn’t allow users to enter new project plans once the total of the budgets for all of the IWT projects entered into the system for a program year have reached the total amount budgeted in the Incumbent Worker lines in grantee’s formula grant budgets. The amount shown in IWTS is the maximum amount the grantee has budgeted for IWT and must remain in place to prevent accidental obligations and expenditures beyond the allowable budgeted amount. We suggest LWIAs engaging in IWT to move larger amounts less frequently to reduce the need for multiple modifications.
Fiscal Management Q11: Incumbent Worker Training projects are being impacted by Covid-19, how should we handle these unexpected disruptions?

The IWTS system is being updated to allow flexibility for grantees and employers to capture the nature of impact of COVID-19 on incumbent worker projects. Users will be given the option to indicate when a project currently in IWTS is impacted by COVID-19 and then submit a request to either modify or cancel the project. IWTS users may then identify the project changes and the rationale using the normal project modification or cancellation request process in IWTS. Additional information with the details on the procedure will be forthcoming. Please direct questions on formula grant projects to Keelin.Valenti@illinois.gov or Michael.Baker@illinois.gov and for non-formula grant projects, contact your grant manager to discuss the best way to handle your specific situation.
Fiscal Management Q12: Can grantees use funds to purchase cleaning supplies?

Yes, to the extent that the supplies are used for the benefit of the grant program (e.g., in grantee spaces, or a proportionate share of shared spaces).
Fiscal Management Q13: Will the state provide funding for LWIAs to pay for additional cleaning services and Personal Protective Equipment at the workforce center?

The cost of additional cleaning services and personal protective equipment for staff that work in the workforce center is an allowable cost on the WIOA grant. Local administrators should contact DCEO regarding additional funding needs for this purpose.
Fiscal Management Q14 NEW: Will there be funding assistance for one-stop centers for masks, sanitation, hand sanitizer, reception plexiglass divider, other required equipment/purchases to ensure safety of all staff including partner staff at the one stop?

The procurement, funding and distribution of personal protection equipment, sanitation and materials to promote/enforce social distancing is an allowable shared cost. It is anticipated that the state and local COVID-19 reopening working groups will make recommendations and help identify the procurement and funding strategies for these materials.
Fiscal Management Q15 NEW: Will security at the AJCs during the reopening phase be an allowable expense?

Yes. The cost of security at an American Job Center is an allowable cost. Generally, speaking this is a shared cost that is frequently included in the annual Memorandum of Understanding Budget. Safety considerations is an important priority. It is anticipated that the state and local COVID-19 reopening working groups will develop guidelines and best practices regarding the safety and security of the AJCs.
Fiscal Management Q16 NEW: Regarding the Families First Coronavirus Response Act, can WIOA funds be used to pay an employee who qualifies for leave related to COVID-19 under this Act?

Yes. 2 CFR 200.431(b) states that a leave policy is allowable if is an established, written policy that applies equitably and consistently to all staff regardless of employee class, and if it is reasonable. (please see Fiscal Management Q4).
Fiscal Management Q17 NEW: If a County receives a federal appropriation to offset COVID-related expenses, can WIOA-funded COVID expenses be reimbursed through those County funds for AJCs that are part of the County?

The ultimate determination regarding the allowability of reimbursable costs will be up to the federal agency that is providing the reimbursement. WIOA funds may be able to be reimbursed if the COVID-19 response costs can be identified and tracked. The OET has requested additional information from the US Department of Labor and State of Illinois Office of Management and Budget on this topic. Additional information will be provided as soon as it is available.
Fiscal Management Q18 NEW: Some of our agencies received a loan under the Paycheck Protection Program and they are looking for guidance on how that grant can be used with their WIOA funds.

Agencies should follow the US Small Business Administration guidelines regarding the appropriate uses of the PPP loans (see PPP Loans Guidance). Costs that are paid through the PPP funds are generally not allowed to also be reimbursed with WIOA funds. The LWIA's agency partners are required to document the expenditures in accordance with the Uniform Administrative Guidelines. Additional information is also posted at the IL Department of Human Service website at: IDHS Paycheck Protection Program FAQs
Fiscal Management Q2: Will the local workforce areas be allowed to request “additional cash”?

No, unless there is an extenuating circumstance that should be communicated to DCEO as soon as possible. At this point, the OET has not changed the cash request approval guidelines.
Fiscal Management Q3: If the American Job Center / Illinois WorkNet site is closed by the lease‐holder or governing body, can the local workforce area continue to use WIOA funds to pay staff?

WIOA funds are provided to grantees on a reimbursement basis for the costs incurred including the salaries and benefits of staff. Local workforce areas grantees must document the time of staff and “charge” the grant based on the work that is performed. From a fiscal management perspective, the regulations do not specify where the work must be performed. Therefore, charging the grant for authorized activities that are performed remotely would be considered allowable costs.
Fiscal Management Q4: Are the costs of a grantee’s leave policy that provides paid leave to employees when their work hours have been reduced due to COVID-19 closures or disruptions allowable costs of the Federal gra

Yes. 2 CFR 200.431(b) states that a leave policy (including part-time employees and employees of subrecipients) is allowable if it is an established, written policy that applies equitably and consistently to all staff regardless of employee class, and if it is reasonable. However, a state or grantee may only charge an employee's paid-time-off to the Federal grant if it is the state's/grantee's overarching policy to pay all employees in this situation, regardless of the funding source used to cover such an expense. If a grantee amends its existing leave policy or develops a new emergency leave policy applicable to all employees affected by the COVID-19 pandemic (e.g., if a grantee’s offices are shut down due to COVID-19) , costs incurred under that policy would be allowable provided they meet the requirements in 2 CFR 200.431(b). For any change in policy that impacts the budget, competitive or discretionary grantees may need to submit a budget realignment request. If the change in policy impacts an approved indirect cost rate or cost allocation plan, the grantee must request a change or obtain an extension from its federal cost negotiator. Grant recipients and subrecipients must maintain appropriate records and cost documentation as required by 2 CFR § 200.302 - Financial management and 2 CFR § 200.333 - Retention requirement of records to substantiate the charging of any salaries and other project activities costs related to interruption of operations or services. Salary and Bonus limitations (Pursuant to P.L. 115-141, Division H, Title I, Section 105) remain in effect. At this time, no additional funds will be provided by ETA to cover these expenses. Should the need for such leave be longer than 60 days, ETA will provide additional guidance on these paid leave policies.
Fiscal Management Q5 NEW: Will the State of Illinois relax the expenditure and obligation requirement of the WIOA formula grants?

At this time the Department does not have the authority to relax the expenditure and obligation requirements for the WIOA formula grants. The Department is monitoring the developments and will remain in contact with the US Department of Labor to identify a potential response.
4-13-20 UPDATE FROM USDOL: ETA acknowledges work experiences for youth during this time period may be harder to provide. Program expenditures on this program element may include more than just wages paid to youth. When determining the types of expenditures that are allowable to help meet this requirement, additional information can be found in TEGL 08-15 and TEGL 21-16, p.15. If state and local areas do not meet this requirement at the end of their period of performance, the Department will follow standard monitoring procedures for this program element.

5-27-20 UPDATE: WIOA Section 132(c) establishes the requirement that states obligate at least 80 percent of each WIOA Title I-B formula grant or face recapture of those funds by the U.S. Department of Labor. Consistent with the requirement that the U.S. Department of Labor (DOL) imposes on states, it has been the State's practice, to hold LWIBs to the same 80 percent obligation standard for the WIOA Title I-B formula grant funds. Because the COVID-19 emergency has resulted in disruptions to local area service delivery, the State is suspending the requirement on LWIBs to obligate at least 80 percent of WIOA Title I-B Adult, Dislocated Worker, and Youth formula grants in PY'19.
Fiscal Management Q6: Are additional funds available to assist in the COVID-19 response?

Yes, the Department of Commerce and Economic Opportunity has Rapid Response funds available to support the immediate needs of the local workforce areas. It is important to note that these funds must be used for allowable activities under the Workforce Innovation and Opportunity Act. The Department continues to work with the US Department of Labor to request additional flexibility in the use of Rapid Response and WIOA funds for recovery efforts.

UPDATED 5-27-20: In order to support the Local Workforce Innovation Areas that face the financial impacts from the COVID-19 response, the Illinois Department Commerce and Economic Opportunity (DCEO) has identified $1,000,000 in Statewide WIOA funds to support the extraordinary WIOA infrastructure and shared system costs associated with the operation of the local workforce centers. It is recommended that LWIBs consider using these funds to support the provision of career services in the one-stop delivery system and carry out activities to facilitate remote access to training services provided through the one-stop delivery system.
Fiscal Management Q7: Will the 50% minimum training expenditure requirement be waived?

The Illinois Workforce Innovation Board (IWIB) has not met to discuss the impact COVID‐19 might have on Local Workforce Innovation Boards’ (LWIB) ability to meet the minimum training expenditure requirement found in WIOA Policy 8.4 Training Expenditure Requirement. In the absence of relief provided by the IWIB action regarding the required minimum rate and potential incentives or sanctions, the policy provides provisions for LWIBs to request an application of a Hold Harmless Clause by submitting a written explanation as to the conditions that contributed to the unplanned inability to meet the minimum rate.

UPDATED 5-27-20: The Illinois Workforce Innovation Board has authorized a change in WIOA Policy Chapter 8.4.7 that includes a hold harmless clause for LWIBs that failed to meet the minimum training expenditure level.
Fiscal Management Q8 NEW: If the worksite for a customer that is enrolled in On-the-Job Training or Paid Work Experience is closed, can WIOA funds continue to pay for the OJT or Paid Work Experience?

4-13-20 UPDATE FROM USDOL: If the program participant’s time commitment, stipend structure, and/or other academic or work terms were established prior to the national health emergency declaration, grantees should continue to pay the participant for the remainder of the established term.
Q8a. Does this guidance apply to both OJT and Work Experience?
Yes. Note that OJT reimbursement can only be made if the participant and other employees are still getting paid during the shutdown due to COVID-19.
Q8b. Does the LWIA retroactively pay back to the first day that the participant was not paid due to the businesses shut down due to COVID-19?
Yes. However, if retroactive pay is made available, the Local Area must consider the impact of Unemployment Compensation paid to the participant if received during the shutdown, as referenced in UIPL 10-20.
Q8c. The LWIA normally pays based on a time sheet signed by the employer and participant but that is going to be difficult. We assume electronic signature and a case note will be acceptable.
Yes. Internal controls should be in place where a process is required to obtain participant signatures for payments based on time worked. Documenting the process, whether through actual or electronic signatures will verify an authorized representative reviewed and approved the documentation for payment. The electronic process must include internal controls to ensure that authorized representatives' signatures cannot be duplicated by non-authorized personnel.
Q8d. If we have a customer who is in work experience and works various hours a week, can we average out their hours to pay them while not working?
According to the USDOL, ensuring fair and reasonable compensation payments should be based on the State of Illinois' established policies. It is the State of Illinois' policy to base these payments on the planned services that are outlined in the participant's Individual Employment Plan or Individual Service Strategy. The LWIA must also base the work-based training payments based on the terms of the work site agreement including but not limited to the hourly rate of payment and the length of the service (number of hours per week and the number of total weeks). If the number of hours that the participant varies from week to week, then it is allowable to average the number of hours as long as there is a reasonable and equitable basis for the providing the payments. A detailed case note is required for LWIAs that make these payments.
Q8e. Can the state provide the date when the LWIAs can begin paying work-based customers whose worksites were closed as a result of COVID-19?
LWIAs are authorized to pay work-based customers whose worksites were closed as a result of COVID-19 back to March 1, 2020. This is the same date that is referenced in the President's Proclamation on Declaring a National Emergency Concerning the Novel Coronavirus Disease (COVID-19) Outbreak. The FAQ posted by the US Department of Labor indicates that "WIOA formula and competitive grants can continue to pay wages or stipends if program participants were actively being served prior to the pandemic or if they were in a work experience placement (e.g. subsidized employment, OJT, paid internship) that was recently cancelled due to COVID-19". On March 11, 2020, the World Health Organization announced that the COVID-19 outbreak can be characterized as a pandemic, as the rates of infection continue to rise in many locations around the world and across the United States. Note that this guidance applies to worksite placements that were cancelled at any time after March 1, 2020 as a result of COVID-19.
Q8f. Can the LWIA pay work-based learning customers that were dismissed from worksites as a result of COVID-19 even if the worksites were not closed?
Yes. The FAQ posted by the US Department of Labor indicates that "WIOA formula and competitive grants can continue to pay wages or stipends if program participants were actively being served prior to the pandemic or if they were in a work experience placement (e.g. subsidized employment, OJT, paid internship) that was recently cancelled due to COVID-19 (emphasis added).
Q8g. Is there a "cut-off date" for when a work-based training agreement would need to be in place to apply this guidance and continue to pay the participant?
The US Department of Labor FAQ indicates that this guidance applies to customers that were actively being served prior to the pandemic or if the worksite was recently cancelled due to COVID-19. Although there is not a specific cut-off date for when a worksite agreement must have been in place, the LWIAs must consider this guidance and the reasonableness of the cost.
Q8h. If a work experience customer has been "laid off" due to COVID, but has accepted another position working elsewhere, is the LWIA required to pay the customer until the contractual hours have been expended or until the customer has been called back to the worksite?
No. The LWIA is not required to pay the customer until the end of the work experience in this situation. The DOL has advised that the WIOA formula and competitive grants can continue to pay wages or stipends if program participants were actively being served prior to the pandemic or if they were in a work experience placement (e.g. subsidized employment, OJT, paid internship) that was recently cancelled due to COVID-19".
Q8i. If a customer was in a work experience position and working another job at the same time, do they still qualify for the continued pay if they were "laid off" at their WIOA worksite because of COVID, but they are still employed at the other job?
This is a LWIA decision based on the specific circumstance and the reasonableness of the cost. The DOL has advised that the WIOA formula and competitive grants can continue to pay wages or stipends if program participants were actively being served prior to the pandemic or if they were in a work experience placement (e.g. subsidized employment, OJT, paid internship) that was recently cancelled due to COVID-19".
Q8j. If the work experience worksite has reopened and the participant does not go back to work or quits, is the customer still eligible for "COVID pay" for the remainder of their hours/term of the agreement?
No.
Q8k. If a participant that is placed in a WIOA-Funded Paid Work Experience contracts COVID-19 or is quarantined, is it allowable to pay the work experience cost during the time the participant is quarantined and not allowed by the public health guidelines to report to the worksite?
This cost may be allowable if the local workforce area's paid leave policy includes work experience participants. The policy should include the conditions for providing leave payments for excused absences and must be applied equitably and consistently to applicable participants. The wages for the work-based learning customers may continue to be paid based on the local leave policy and a review of applicable scenarios including, but not limited to:
- Local health guidelines for quarantined customers due to COVID;
- There is a temporary shutdown of the work site due to a potential COVID infection.
Fiscal Management Q9: What costs are allowable for staff who are working remotely? Toner, printers, scanners, internet costs, etc.

Supplies that are charged to the federal workforce grants must meet the requirements of the Uniform Administrative Requirements at 2 CFR 200. The cost of office supplies must be reasonable, allocable and allowable. Workforce professionals must follow the grantee's financial management policy and procedures for procuring office supplies that are used in the American Job Center and/or in remote locations. Note that the cost of Internet, utilities or other occupancy costs of a home office are generally not allowed.
For employers that obtain PPP forgivable loans, are they also eligible to obtain WIOA funding such as for On-the-Job Training grants?

A company that has received a Payment Protection Program loan remains eligible to obtain WIOA funding such as On the Job Training; however, companies are advised not to “double-dip” and pay the required matching portion of the OJT employee’s salary with PPP funds. The matching portion of OJT must be made with nonfederal funds. Companies are advised to review the terms of the PPP Loan for complete information regarding the allowable costs, and conditions of the loan.
For individuals who were on Pandemic Unemployment Assistance (PUA) who still had PUA benefits available when the PUA program officially ended (week beginning 9/4/2021), what is the correct response to the individual’s Unemployment Insurance (UI) status?

Based on feedback from the Illinois Department of Employment Security (IDES), based on UI Law, if an individual was drawing PUA when the program ended, (even if that individual still had a balance remaining when the PUA program ended,) the individual should be considered to have “Exhausted” their UI benefits. An important distinction, if the individual had/has obtained full-time self-sustaining employment since they had last received PUA, their UI status would then be related to the most recent employment, and not the circumstances that led to the individual receiving PUA benefits.
IE COVID19 Response Layoff Adversion Funding Q19 NEW: When will the funds be distributed to the LWIAs?

The Office of Employment and Training will issue COVID-19 Layoff Aversion grants as soon as feasible. The goal is to have the new grants established before the end of the State Fiscal Year on 6-30-20. The OET will provide updates that includes the total grant amount and the list of projects that have been approved with a "funding commitment" under this program as soon as the information is available. The OET will request a "quick turn-around" of the grant documents from the LWIAs (by 6-15-20) to allow enough time to process the grants before the end of the state fiscal year.
IE COVID19 Response Layoff Adversion Funding Q20 NEW: Do “modifications” (i.e. social distancing barriers) made to a workplace in response to COVID-19 require compliance with Federal Labor Standards Provisions including payment of Federal prevailing wages

Yes, if WIOA funds are used for this purpose.
IE COVID19 Response Layoff Aversion Funding Q1 UPDATED: What are the essential businesses in Illinois according to the Governor’s Executive Order?

UPDATED: Executive Order 20-32 requires all non-essential businesses and operations to cease all activities except for minimum basic operations. Non-essential businesses may also continue operations consisting exclusively of employees or contractors working from home. Please review the Illinois Essential Business FAQ for more information.
IE COVID19 Response Layoff Aversion Funding Q10: What is the local workforce area’s responsibility to verify in terms of the application?
Administrators should follow the local policy and procedures that are established for entering into agreements with employers. It is the employer’s responsibility to attest to the conditions of the award. Administrators should also plan to include a risk-based sample of the layoff aversion awards as part of the local monitoring schedule to verify compliance.
For more information regarding a risk-based monitoring sample, please see 2 CFR 200.205 that outlines the key risk categories to consider when developing a monitoring plan of the entity / applicant including:
- Financial stability;
- Quality of management systems
- History of performance.
- Reports and findings from audits
- The applicant's ability to effectively implement the requirements of the award
IE COVID19 Response Layoff Aversion Funding Q11: How do we verify number of employees affected, the number kept on after the 45 days?

Administrators may request supporting documentation from the employer to verify the number of employees affected. Administrators should also plan to include a risk-based sample of the layoff aversion awards as part of the local monitoring schedule to verify compliance.
IE COVID19 Response Layoff Aversion Funding Q12: Are IT consulting expenses to analyze our current system and determine what we would need to do to create virtual customer interactions an allowable expense?

Yes.
IE COVID19 Response Layoff Aversion Funding Q13: Will the eligible employers change for the 1E Statewide Rapid Response Grant now that the Governor revised his Order to allow non‐essential businesses to open with restrictions?

Funding is available for businesses to operate in compliance with the Governor’s Executive Order. This includes all businesses that are operating in compliance with the Governor’s Executive Orders. IE funds will not support activities that violate the Executive Orders. IE funds could be used to support companies that resume operations as soon as they are allowed to reopen.
IE COVID19 Response Layoff Aversion Funding Q14: Are extended warrantees for computers purchased with IE Layoff Aversion Funds an allowable expense?

Allowability of a warranty will be determined on a case‐by‐case basis if it benefits the project is reasonable and necessary.
IE COVID19 Response Layoff Aversion Funding Q15 NEW: Are employers that are participating in the Paycheck Protection Program eligible to apply under this this grant?

Employers that meet the IE Program requirements that are also participating in the Paycheck Protection Program may be allowed to use WIOA funds; however, the employer is not allowed to charge both programs. The employer would be required to document the expenditures in accordance with the Uniform Administrative Guidelines. DCEO LWIAs are advised to carefully scrutinize the reasonableness of these applications. Note that the OET cannot advise on the terms and conditions of the Paycheck Protection Program.
IE COVID19 Response Layoff Aversion Funding Q16 NEW: Will employers be required to submit receipts to the state before they are reimbursed for the costs that are included in the award?

Employers must follow the local workforce area's fiscal procedures for submitting reimbursement requests. The LWIA is not required to submit these receipts to the State; however, the LWIA should retain documentation to verify the costs.
IE COVID19 Response Layoff Aversion Funding Q17 NEW: How will these grants be monitored?

The Office of Employment and Training will include the IE grants as a part of the annual WIOA monitoring. A representative sample of the projects funded under this grant will be included as a part of this review. The LWIAs are also advised to include these projects as part of the local area's monitoring schedule.
IE COVID19 Response Layoff Aversion Funding Q18 NEW: How will the funds be distributed to the LWIAs?

The Office of Employment and Training (OET) will issue new grants to each of the local workforce areas that have projects that receive funding commitments. Although the OET intended to modify the Program Year 2019 Rapid Response grants; we have been directed by the Illinois Office of Management and Budget that new grant awards must be issued to track the COVID-19 related response efforts.
IE COVID19 Response Layoff Aversion Funding Q2: How can you verify that an employer is in good standing and not on the federal excluded parties list?

LWIA staff can verify if the employer is in good standing with the State of Illinois and also check the federal Excluded Parties List.
IE COVID19 Response Layoff Aversion Funding Q3: How do you define “small business”?

For the purpose of the Emergency (IE) Assistance Application in Response to COVID-19, DCEO is using the United States Small Business Administration definition of a small business. Please visit the SBA websites for more information. SBA Size Standards and SBA Table of Size Standards
IE COVID19 Response Layoff Aversion Funding Q4: Can the IE COVID Response Funds pay for business consultants that provide employers with an analysis of how to implement the recommendations of public health officials?

Yes, if the consultant services directly result in the employer implementing strategies that are recommended by public health officials including but not limited to social distancing, cross training and remote working.
IE COVID19 Response Layoff Aversion Funding Q5: Can the IE COVID Response Funds pay for business service navigators to identify funding to help employers stay in business?

Assisting businesses to locate financing to avoid layoffs is an allowable Rapid Response activity. In many LWIAs the business service team members perform this important function. LWIAs that need additional support for these activities are encouraged to contact Lorraine Wareham at Lorraine.wareham@illinois.gov with detailed information regarding these specific needs.
IE COVID19 Response Layoff Aversion Funding Q6: Does the IE COVID Response Funds pay for administrative costs?

Limited administrative costs may be provided on a case by case basis to cover the administrative costs that cannot be absorbed by the local business service teams and program monitors.
IE COVID19 Response Layoff Aversion Funding Q7: If an employer already purchased computers for remote work, would we be able to apply for grant funds to reimburse those costs? Are pre-award costs allowed?

Per the terms of the grant award, Pre-award costs for layoff aversion activities will be allow going back to January 1, 2020.
IE COVID19 Response Layoff Aversion Funding Q8: Will DCEO review and fund other IE requests – including requests that were submitted prior to the IE COVID Response Notice?

Yes. LWIA administrators are advised to contact Lorraine Wareham at Lorraine.wareham@illinois.gov.
IE COVID19 Response Layoff Aversion Funding Q9: If an employer filed WARN for one location, would other locations be eligible under this funding opportunity?

Yes.
If someone is not eligible for regular Unemployment Insurance (UI), but is receiving Pandemic Unemployment Assistance (PUA) benefits (they were self-employed), what is the required documentation for determining 1D eligibility?

There are several different ways an individual may be determined eligible as a WIOA Dislocated Worker and 1D eligibility can usually be handled more easily than attempting to make UI or PUA the key factor. We will describe how to do handle 1D eligibility for a formerly self-employed worker either way.

The most straightforward path to 1D eligibility for an individual who was self-employed, but became unemployed due to general economic conditions or a flood or natural disaster, is under the WIOA Dislocated Worker criteria of Formally Self-Employed, but now Unemployed. This criteria does not include any component tied to UI status, either traditional UI or PUA.

The only 1D eligibility criteria tied to UI (either traditional UI or PUA) is Unlikely to Return to Previous Industry or Occupation. The receipt of either traditional UI or PUA works the same under this criteria, however additional conditions must to be met, such as: 1) dislocation job from either a declining industry or low growth occupation; OR 2) six months unemployed with one month documented job search; OR 3) requires additional assistance justified by Career Planner staff in the assessment. The documentation of receipt of PUA may be handled using the same methods used to document receipt of UI.
So while it is possible to use the receipt of PUA as one of several required factors when using Unlikely to Return to Previous Industry or Occupation, in most cases it is simpler and recommended to use Formally Self-Employed, but now Unemployed which avoids the need to document the receipt of benefits.
National Dislocated Worker Grant Program Q1 NEW: Is the cost of instructing a participant in “contact tracing” an allowable cost?

Yes, if the cost is reasonable and necessary for the participant's placement in a Disaster Recovery job. Note that the LWIA will need to work with the Department to determine if the instruction should be classified as a WIOA Career Service or Training Service.
National Dislocated Worker Grant Program Q2 NEW: Do the training programs under the NDWG grants have to be listed on the State WIOA Eligible Training Provider List?

Yes.
National Dislocated Worker Grant Program Q3 NEW: Can the LWIA hire a participant to act as a Project Coordinator?

Yes.
National Dislocated Worker grant Program Q4 NEW: Can the cost of hiring a third party (staffing agency) be considered an allowable cost to the grant?

Yes, as long as the costs are reasonable and necessary and that local procurement procedures are followed. When performing a cost/price analysis, the "contract plus a percentage of cost" method of contracting must not be used. There is no rule of thumb for a reasonable profit margin, but a profit margin above 10% is going to receive more attention and analysis as to whether it is reasonable based on the complexity of the service being provided. Any profit that exceeds 10% must be reviewed and pre-approved by DCEO in consultation with the USDOL grant manager.
National Dislocated Worker Grant Program Q5 NEW: What is the administrative cost limit for the NDWG awards?

Administrative costs are limited to 10% at the local level.
National Dislocated Worker Grant Program Q6 NEW: The current On the Job Training regulations does not allow LWIAs to place participants with employers that have recently laid off workers. Will this be modified?

At this time the Department does not have the authority to relax the regulation. The Department has requested additional guidance from the US Department of Labor.
National Dislocated Worker Grant Program Q7 NEW: Are the wages for Disaster Relief Employment (temporary workers) participants subject to the unemployment withholding requirements?

Yes. Please note the Office of Employment and Training is requesting a clarification with the Illinois Department of Employment Security to see if there is any flexibility with this requirement – specifically for employers that are governmental entities.
National Dislocated Worker Grant Program Q8 NEW: Are the work experience wages for participants that are placed in work experience/paid internships/transitional jobs subject to the unemployment withholding requirements?

No, If it is as part of an approved training program.
Planning and Governance Q1: Will the due date for the Regional / Local Workforce Development Plans be extended?

The regional and local plans currently have a due date of March 31, 2020.
Please e‐mail wioaplans@illinoisworknet.com if you need assistance or need to request an extension.
Planning and Governance Q2: Will the state be flexible regarding the signature requirements for the regional and local plans?

Yes. When submitting regional and local plans to the State, it is acceptable to use a signature block with all caps followed by an /s/ to indicate formal approval on the submittal letter. If a signature block is used for the CEO and LWIB on the submittal letter, it should appear as follows: “FIRST AND LAST NAME /s/”. The “/s/” signature is currently used on the accessible version of guidance that is posted on DOL’s Employment & Training Administration’s system. As the COVID-19 pandemic evolves, DOL is temporarily modifying the way ETA advisories are signed. ETA advisories with the “/s/” signature are considered official guidance. Once social distancing efforts are lifted, DOL will revert to posting signed versions of advisories.
Planning and Governance Q3: Will the due date for the Memorandum of Understanding and the Annual MOU Budget be extended?

UPDATED 3‐20‐20 A “Report of Outcomes” is due to the State on April 15, 2020 to indicate the status of your local workforce area’s MOU negotiations and whether all required partners have agreed to the MOU and annual budget for Program Year 2020. While the Interagency TA Team continues to monitor developments, the April 15 due date for the Report of Outcomes still applies. Please email wioaplans@illinoisworknet.com if you need assistance or need to request an extension to complete the negotiations in your local workforce area.
Planning and Governance Q4: Can the local workforce boards use technology to meet and conduct business?

Yes. During the duration of the Gubernatorial Disaster Proclamation, the provisions of the Open Meetings Act, 5 ILCS 120, requiring or relating to in‐person attendance by members of a public body are suspended. Specifically, the requirement in 5 ILCS 120/2.01 that "members of a public body must be physically present" is suspended; and (2) the conditions in 5 ILCS 120/7 limiting when remote participation is permitted are suspended. Public bodies are encouraged to postpone consideration of public business where possible. When a meeting is necessary, public bodies are encouraged to provide video, audio, and/or telephonic access to meetings to ensure members of the public may monitor the meeting, and to update their websites and social media feeds to keep the public fully apprised of any modifications to their meeting schedules or the format of their meetings due to COVID‐19, as well as their activities relating to COVID‐19.
Planning and Governance Q5: What impact will the COVID-19 National Health Emergency have on the local Memorandum of Understanding Narrative, MOU Budget, and the payment of shared costs outlined in the MOU?

The COVID-19 National Health Emergency has resulted in an unprecedented number of individuals that have filed for Unemployment Insurance. State agency partners including the Illinois Department of Employment Security have focused all available resources to address the immediate crisis. Please be advised that during this time it is anticipated that there will be delays in the review of the MOU narrative and budgets from state agency partners. It is also anticipated that state payments of shared costs will be delayed. We appreciate your patience as work through this emergency.
Planning and Governance Q6: Will the June 30, 2020 Deadline for One Stop Certification be extended? If not, how should LWIAs proceed, as there are items on the checklist that may not be complete due to COVID issues.

At this time the Department does not have the authority to extend the deadline for One Stop Certification. The Department is monitoring the developments and will remain in contact with the US Department of Labor to identify a potential response.
Program Oversight Q1: Can the local workforce area suspend or reschedule the on‐site monitoring of subrecipients and contractors?

Yes. Local workforce area staff are allowed to reschedule on‐site monitoring reviews. Staff are encouraged to complete enhanced desk reviews that should expedite the on‐site monitoring when it is rescheduled based on the information provided by local public health officials.
Program Oversight Q2: Can the local workforce area suspend the on‐site monitoring for Work Experience and/or On‐ the‐Job Training participants?

Local workforce areas have a responsibility to keep participants safe and ensure that the host employers are following the current OSHA safety guidelines. Local areas should implement monitoring based on the risk factors of the work site. If the work sites are higher risk, then in‐ person monitoring may be warranted. If the work sites are lower risk, then it would be acceptable to monitor the worksite remotely using technology including, but not limited to, teleconference including facetime, email, text and other social media platforms. Additional information is available on CDC's website.
TAA Q1: Are there exceptions for computer purchases not required or on a syllabus? Participants are requesting we buy computers to allow continued training, when training institutions have not provided documentation stating a computer is required.

If the training institution is now requiring that students take courses online and the participant does not have the equipment needed to continue their classes, then it IS a requirement, and that cost should be covered accordingly. As ever, this is not an open authorization for participants to request elaborate equipment, and steps should be taken to set parameters around the reasonable cost of purchasing the computer. USDOL does not support a specific device or operating system. However, there are certain devices (e.g. Chromebook) that are available at a nominal cost which meet the necessary technical requirements to access online systems.
Note: Additionally, if the purchase of a laptop/computer will place the worker over the states ‘soft cap’ policy, the state should consider ongoing and unexpected circumstances to serve as justification for exceeding the states ‘soft cap’.
TAA Q10: Should states continue to provide rapid response services for any layoff event impacting 50+ in light of COVID-19?

States should continue to provide Rapid Response information to affected employees. States have flexibility in whether to provide this in-person or through other means. States should consult CDC guidance and local government directives on large gatherings.
TAA Q2: Should a state modify a training plan to lengthen the time needed to complete their individual training program?

TEGL No. 5-15, Change 1, Attachment A, Section D.4 (Length of Training) provides a maximum amount of 130 weeks of TAA training (not calendar weeks) for 2015 Program participants and any training can be modified for the individual to accommodate the individual’s completion of TAA training. An individual’s training plan should always be modified/amended to reflect a change in the length of training.
TAA Q3: Can the state modify a plan to extend beyond two years?

Training completion can extend beyond two calendar years. However, the worker is only allowed up to 130-weeks of actual training.
TAA Q4: If a school shuts down and an individual cannot participate in online classes, do we move them to a Work Search Status until they return to school?

The state should request and document an explanation as to why the individual cannot participate in online classes. If it is due to a lack of supplies (such as a computer), then that could be covered by TAA training funds. If the school is not offering online classes, and is therefore on a break, then the EB work test does not apply in this case.
TAA Q5: If the individual finds a job while training was ceased due to COVID, can they later come back to the program and resume training or apply for a new training program?

The individual may return or resume their approved TAA training plan. Amending or modifying that training plan is best addressed on a case by case basis. No individual shall be entitled to more than one training plan under a single certification, in accordance with 20 CFR 617.22(f)(2).
TAA Q6: The state closing all Job Centers to the public. Is the state allowed to waive attendance verification, waiver deadlines, benchmark reviews?

The state is not permitted to waive attendance verification requirements, deadlines, or benchmark reviews. The state should make a “reasonable” attempt to meet deadlines, verification requirements, and benchmark reviews.
However, due to ongoing circumstances surrounding COVID, the state should account for current challenges in obtaining or completing these requirements. If the state is unable to obtain the necessary verification after a “reasonable” attempt, the state should document the inability to meet certain requirements as a justification for not being able to obtain the required information.
TAA Q7: Would it be an allowable charge if the employee came to work but worked on COVID- 19 related functions (i.e., sanitizing the building, etc.) and not grant-related functions?

Assisting in the cleaning and sanitizing of dedicated and common space that is used to house and serve program staff and participants is an allowable grant function.
TAA Q8: If we are closing our AJC, should we tell anyone?

Yes, please inform your Regional Office of AJCs or SWA closures. ETA will use this info to update the Service Locator website, and to update information disseminated by the Toll Free Helpline.
TAA Q9: Covid-19 will affect the #s of people I can serve, and may impact performance. Will I be held accountable for those performance measures? Will future FOAs that use previous performance as a scoring criteria take related disruptions into account?

ETA understands there will be disruptions to services to participants that ultimately may impact performance. As we see how long these disruptions last, we will provide guidance for competitive performance measures. ETA does not anticipate these potential disruptions impacting current Funding Opportunity Announcements (FOAs being awarded by June 30, 2020). These grant competitions generally use prior performance for activities that have already taken place, and would not be impacted by any COVID-related disruptions.
Technical Assistance Q1: Will the 2020 WIOA Summit still be held?

No, the 2020 WIOA Summit, scheduled for April 28‐29, 2020 has been cancelled. There are no plans to reschedule the event, so the next Summit is tentatively planned for April 2021.
Technical Assistance Q2: What will happen to all of the sessions scheduled to be presented at the 2020 WIOA Summit?

The plan is to review each of the sessions and identify which topics are able to be presented in a webinar format. The WIOA Wednesday Webinar series will be utilized to present the information. Once the topics are reviewed and prioritized, and speakers/presenters will be contacted to determine if they can provide the information, a schedule of webinars will be developed. Information will be provided through the Career Connect email series that has been provided to the field from the Illinois Center for Specialized Professional Support (ICSPS) at Illinois State University.
Technical Assistance Q3: What other technical assistance is being planned to follow when the COVID‐19 precautionary plans subside?

In addition to utilizing WIOA Wednesday Webinars, plans will be to provide regional roundtables to present information that may not be suitable for the webinar platform. Notifications on emerging information from the POTUS Office, Federal and State Agencies, and the Illinois Governor’s Office will continue to be disseminated through emails and posted on Illinois workNet® when possible and a clear message is available.
Technical Assistance Q4 NEW: Where are the Governor’s Executive Orders posted?

The Governor's Executive Orders are posted at: Governor's Executive Orders.
TRA Q1: If the school is on an unscheduled break due to COVID-19 for more than 30 days can we issue TRA payments?

BTRA:
If the school is on an unscheduled break, then BTRA is not be payable for the time being. The school must consider the break scheduled and less than 30 days in order to pay BTRA. However, BTRA maintains an exception that would allow for payment if the worker completes the states EB work search test.
ATRA:
If the school is on an unscheduled break, then ATRA is not payable unless the worker is attending training full-time according to the schools definition of full-time status. The school must consider the break scheduled and less than 30 days in order to pay ATRA.
CTRA:
CTRA is not payable during a breaks in training. CTRA can only be paid if the worker is participating full-time, according to the schools definition of full-time status.
Note: We are actively evaluating the policies surrounding TRA to explore opportunities to re-evaluate some of the requirements since many participants depend on TRA payments as a source of income. However, for the time being, normal TRA payment requirements are still in place.
TRA Q10: An individual is on “Additional” TRA and the school closes. Because the law states “Additional” TRA is not payable as a work search how do we handle these cases? Due to COVID, is there an exception to the “Additional” payment rule?

No payment of additional TRA is permitted without participation in TAA training.
TRA Q11: If the payment of TRA benefits are allowed, will individuals be required to satisfy the Extended Benefit Work Test for each week they are not in school?

Without participation in TAA training only basic TRA payments could be allowed. If there is a cessation in TAA training, the EB work test does not apply but nothing prevents the individual from continuing to seek employment.
Additional and Completion TRA are not payable without participation in TAA training. Accordingly, conducting the EB work test is not required but nothing prevents the individual from continuing to seek employment.
TRA Q12: An individual is on “Completion” TRA and the school closes. Because the law states “Completion” TRA is not payable as a work search how do we handle these cases? Due to COVID-19 emergency, is there an exception to the “Completion” payment rule.

There are no exceptions. CTRA is not payable during breaks. CTRA is only payable during the final 20-weeks of a training plan and when participating in full-time coursework, as defined by the training institution.
TRA Q2: Are workers eligible for TRA if the employer closes operations because of COVID-19 precautions?

Eligibility for TRA requires that workers be a member of a group certified as eligible to apply for TAA benefits. Worker’s separation must be for lack of work and while the closure appears to be a lack of work, workers’ must first be eligible for UI benefits under State law. Once UI benefits are exhausted, the individual may be eligible for TRA.
TRA Q3: Is a worker who tests positive, becomes sick, or is quarantined for COVID-19 eligible for TRA?

See A2. Eligibility for TRA requires that workers be a member of a group certified as eligible to apply for TAA benefits. Worker’s separation must be for lack of work and while the closure appears to be a lack of work, workers’ must first be eligible for UI benefits under State law. Once UI benefits are exhausted, the individual may be eligible for TRA.
TRA Q4: Do workers remain eligible for TRA if they are currently in TAA training and the training institution closes due to COVID? If workers experience the conditions in #2 above or if the training institution closes, do they remain eligible to TRA?

Workers undergoing TAA training and collecting TRA may remain eligible for Basic TRA, as permitted by the regulations (e.g. EB work search or Participation in full-time training).
Additional or Completion TRA is not available because both require actual participation/attendance the approved-training program.
TRA Q5: Will a worker remain eligible for TRA if the worker is sick or quarantined due to COVID-19?

Workers undergoing TAA training and collecting TRA may remain eligible for Basic TRA, as permitted by the regulations (e.g. EB work search or Participation in full-time training).
Additional or Completion TRA is not available because both require actual participation/attendance the approved-training program.
TRA Q6: The workers training was suspended due to COVID-19 (e.g. sickness, quarantine, closure of training institution) and the workers TRA eligibility period is scheduled to expire. Is an extension of the eligibility period permissible?

Once the COVID-19 event ends, the TAA training resumes, and there is Justifiable Cause, the eligibility period(s) for Additional and/or Completion TRA may be extended. The worker should contact their case manager to extend the period and schedule a date to resume training.
States should document a justification (e.g. Eligibility period extended due to COVID- 19 mitigation strategies) for the extension of the eligibility period in the workers case file.
TRA Q7: Training was suspended due to COVID-19 (e.g. sickness, quarantine, closure of training institution). Should the state continue paying UI/TRA until they return to school?

An individual receiving Basic TRA who has ceased participation in TAA approved training may continue receiving such benefits because the event falls under the regulatory citation at 20 CFR 617.18(b)(2). There is justifiable cause for the cessation in training. Additional and Completion TRA are not payable without participation in TAA training.
TRA Q8: Individual is on a Waiver from training and stops looking for work because of the COVID-19 national emergency. They have not identified that they are sick but do not want to look for work at this time. Do we continue to pay TRA?

All TRA requires the individual to meet the EB work test unless the individual is participating in TAA training. The EB work test provisions within State law govern whether this individual may be eligible. Please refer to 20 CFR 615.8(d), (e), (f), (g).
TRA Q9: Can the 104 week “Basic” Eligibility Period be extended due to a national emergency?

The Trade Act of 1974, as amended, provides for the extension of the eligibility periods for TRA for justifiable cause.
Section 233(h) of the Trade Act of 1974, as amended provides:
“SPECIAL RULE FOR JUSTIFIABLE CAUSE.—If the Secretary determines that there is justifiable cause, the Secretary may extend the period during which trade readjustment allowances are payable to an adversely affected worker under paragraphs (2) and (3) of subsection (a) (but not the maximum amounts of such allowance that are payable under this Section).
Guidance provided via TEGL No 5-15, Change 1, Attachment A, Section C.2.2 (Justifiable Cause to Extend the Program) provides the following: A worker may receive weeks of Basic TRA and Additional TRA only during the eligibility periods set by the statute, except for a limited statutory exception. As under the 2011 Act, Section 233(h) allows for an extension of these eligibility periods for “justifiable cause,” meaning circumstances determined by the CSA to be beyond the worker’s control.
In making this determination, the State will apply the criteria described under the discussion above for the Federal Good Cause provision, as well as regulations, policies, and practices applicable to administration of the State’s UI laws. Please also see Section C.5.2.( Completion TRA Eligibility Period Established by the Secretary) of these Operating Instructions for more information on justifiable cause and Completion TRA.
Accordingly, the periods in which an individual is eligible for any TRA may be extended. This means that any individual who ceases participation in TAA training and as a result becomes ineligible for TRA may resume such eligibility once the individual returns to training as benefits will not be lost.”
Trade Program Management Q1: Please provide an update regarding the initial trade application data requirements given that Trade‐affected workers have specific requirements and deadlines to meet.

IDES is currently not sending outreach notices, but is accepting and reviewing TRA claims. Good Cause and Equitable Tolling will be considered on a case‐by‐case basis when determining if the 26/26 deadline was met. Additionally, Good Cause and Equitable Tolling will be invoked as necessary for date extensions.
Trade Program Management Q2: Do TRADE case managers need to enroll clients in remote or distance learning due to their programs being moved to all online?

Yes. In addition, case managers should revise the Individual Employment Plan following the normal approval procedures. Please note that the participant signature to the IEP can be obtained later if you document via e-mail that the customer has the revised IEP.
Trade Program Management Q3: Can you provide clarification of what you mean by “immediate release of Trade funds"?

Trade funds are directly associated with dislocated workers that were laid off as a result of foreign trade. Expanding these funds for use to other allowable activities associated with layoffs in general, such as Rapid Response services which provides a coordinated approach to layoffs, will give funding flexibility to serve more individuals impacted the COVID-19 National Emergency. Illinois is requesting the US Department of Labor direct the administrators of the Trade Adjustment and Assistance program to certify Trade Act petitions that are associated with a layoff that was a result of the COVID-19 National Emergency. Additionally, Illinois is seeking permission to expand the use of Trade funds for allowable services such as Rapid Response layoff aversion activities.
We are receiving new applications from people who are temporarily laid off. For example restaurant workers. What services can be provided for these applicants? They will be receiving UI but will be returning to work once they are called back.

Individuals who are laid off, even temporarily, may be eligible for WIOA Career and Training services. These decisions should be made on a case by case basis. Basic Career Services are available to everyone. Beyond that, Individualized Career Services should be provided, if determined appropriate, in order for an individual to obtain or retain self-sufficient employment. Training services can be provided if it is determined, based upon an assessment and individual employment plan, the individual is unlikely or unable to obtain or retain employment that leads to economic self-sufficiency or wages comparable to or higher than wages from previous employment. If an individual intends to return to his or her former employment when called back, then Individualized Career Services or short-term Training Services may be appropriate. If an individual intends to change career paths, then consideration should be given to all available training programs as appropriate.
We have an employer who is requesting a COVID test for a client we are placing in a work experience. How do we handle this? Reimbursement only? A voucher of some sort if the client cannot pay? Other? Thank you.

LWIAs that place participants into a work-based learning work-site should follow local fiscal procedures in paying for a COVID test (similar to other “pre-employment” requirements such as a drug test). In many instances a reimbursement of reasonable costs would be appropriate if a free testing option is not available. It is advisable for the customer and case manager to research free COVID testing options that are available throughout the region before scheduling a paid test.
What other documentation is allowable besides a Social Security Card to verify SSN? Would we be able to use an IBIS or Public Benefit system printout showing SSN if the person provided their SSN verbally and sent in a copy of a valid government ID?
For acceptable documentation to support the actual Social Security Number, there are 3 options:
- Social Security Card (must be signed)
- Social Security Administration Printout (with full Social Security Number)
- Any Social Security Administration Document Showing Full Social Security Number
In regards to the 2nd and 3rd choices, the Social Security Administration (SSA) has an instant online verification where the documentation can be attained by the user creating a "my" Social Security Account or calling SSA to obtain a verification letter.
SSA website provides steps to apply for a replacement card online.
1. Log into your my Social Security account.
2. Navigate to the "My Home" tab and then to the "Overview" tab. On the right side of the page:
3. Click the link: "Replacement Documents",
4. Click the link: "Request a Replacement Card",
5. Answer the screening questions to confirm eligibility; and
6. Enter personal information such as name, Social Security number, address, and state driver's license or ID information.
Will LWIAs be able to use the basic skills eligibility tool past June 30, 2020?

Yes. Notice 19-NOT-01, Change 1 will be released to announce the Test for Adult Basic Education (TABE) 11&12 and Comprehensive Adult Student Assessment Systems (CASAS) GOALS are the approved assessments for Fiscal Year (FY) 2021 for English Speaking Individuals. Additionally, since the ability to conduct/proctor assessment tests are still limited at this time due to COVID-19, the option for Career Planners to use the 'Can't Complete Test' is being extended to September 30, 2020.
WIOA Program Management Q1: Should I consider closing a workforce center’s resource room to the public?

Local one‐stop operators and administrators should follow the guidance issued by the local and state public health officials as it relates to social gatherings. Depending on the facility leaseholder, there may be additional implications. Appointments with career planner staff should be conducted by telephone, Skype, etc. to the extent possible. Additional information is available at IDPH.
WIOA Program Management Q10: Some workforce areas have special training grants that are due to be expended by the end of March or June. Due to the possible delay of training, can these grants be extended?

The DCEO grant managers will work with the local workforce areas and other grantees on a case‐by‐case basis to review each modification request. It is anticipated that reasonable modification requests will be approved as long as DCEO has the expenditure authority.
WIOA Program Management Q11: Performance measures could greatly be impacted such as the entered employment rate at the 2nd and 4th quarter, wages earned at six months, credential attainments, obtaining measurable skills gains.

At this time the Department does not have the authority to relax this requirement. The Department will continue to monitor developments and will remain in contact with the US Department of Labor to identify additional guidance.
WIOA Program Management Q12: Do WIOA case managers need to enroll clients in remote or distance learning due to their programs being moved to all online?

The only place that captures the mechanism for provision of training is in the Eligible Training Providers (ETP) reporting where a provider must choose - on-line learning, classroom, or both. Because it would be very laborious to update this question for the length of time the providers have changed mechanisms due to the COVID-19 pandemic and then change it back once on-site classes resume, the state is going to ask for guidance from DOL which could include a "hold-harmless" on this provision during the pandemic. Continue to record the services as it is traditionally recorded. When OET receives any guidance from DOL whether it be in the form of a Q&A or an email, we will notify the field collectively.
WIOA Program Management Q13: With the school closures participants requesting we purchase computers to allow for continued training participation, when the training institution has not provided any documentation stating a computer is required for program.

If the training institution is now requiring that students take courses online and the participant does not have the equipment needed to continue their classes, then it IS a requirement, and that cost should be covered accordingly. As ever, this is not an open authorization for participants to request elaborate equipment, and steps should be taken to set parameters around the reasonable cost of purchasing the computer. USDOL does not support a specific device or operating system. The case manager should note this change in the participants Individual Employment Plan or Individual Service Strategy
WIOA Program Management Q14: With the school closures many training programs have moved to an on-line training environment. Is the cost of internet service an allowable WIOA cost?
No. The cost of internet service is considered a utility and WIOA training funds are not allowed to pay for this cost. Case managers are encouraged to direct participants to local companies that provide assistance for low-income residents in accessing the internet. Please see: Your Guide to Internet Service During COVID-19 Outbreak.

UPDATED 8-25-20: Per the USDOL COVID-19 FAQs, WIOA funds can be used to pay for devices and broadband internet service that will allow a participant to create or maintain a wireless connection for distance learning, searching for jobs, and other employment and training services where such services are already allowable. Grant recipients are expected to use sound fiscal prudence to maximize value for each taxpayer dollar spent by reaching as many participants as possible while also considering the cost and length of time remaining in the period of performance.
- In Illinois, the cost of providing broadband service for a participant can be an allowable cost if it is allowed by the local training and supportive service policies. Local policy should direct case managers to analyze and ensure that the costs are reasonable and necessary.
- Case managers should also work with the customer to identify the most cost-effective method of obtaining the internet service. For example: case managers direct participants to local companies that provide assistance for low-income residents in accessing the internet. Please see: Your Guide to Internet Service During COVID-19 Outbreak.
WIOA Program Management Q15: Do local areas have to do TABE testing during the COVID-19 pandemic given that tests have to be proctored?

In Illinois, the state has aligned with the Title II Illinois Adult Education Assessment policy when determining the basic skills levels of customers for enrollment. This includes the requirement that local areas use the Test of Adult Basic Education (TABE) test for assessment purposes so that customers aren’t unnecessarily having to complete multiple assessments to achieve the same purpose. Additionally, aligning Title I and Title II policy ensures a coordinated approach to services for WIOA customers. At this time due to the COVID-19 pandemic, all testing with the TABE has been temporarily suspended by Adult Education. Our WIOA Title II partners have reached out to the test publishers to get direction and determine if they have any strategies for remote assessment.

As a reminder WIOA prescribes a holistic, on-going assessment process for customers rather than just a one-time event. This comprehensive and objective assessment process should use a variety of mechanisms to evaluate and identify the employment goals, appropriate achievement objectives, and the needed combination of services to address barriers. Multiple assessment tools may be necessary since there is no standard approach that will work for all customers. The TABE test is only one mechanism to assess a customer.

During intake, there must be an assessment for determining a customer’s basic skills. In assessing basic skills, local programs must use assessment instruments that are valid and appropriate for the target population and must provide reasonable accommodation in the assessment process, if necessary, for individuals with disabilities. A Basic Skills Screening Tool has been developed and will be disseminated via a WIOA Notice. The Tool must be used, as appropriate, along with other assessments that determine vocational skills, etc. and is to be used for referral purposes.
For Adults, this tool not only determines potential basic skills deficiency but also is used to identify priority of service. This alleviates customers from having to take a TABE test solely to determine basic skills deficiency and to identify priority of service. As mentioned above, the assessment given to determine reading, math, or language levels is not enough for qualifying placements into vocational or technical skills training and other factors acquired from a full assessment of the customer such as suitability of the training program must be considered.

The Tool will be incorporated into the Illinois Workforce Development System (IWDS) at a future date. Until that time, use the form found in Attachment A to the Notice. This form must be kept in the customer’s file and noted in the case notes and IEP/ISS (career plan) as applicable. The IWDS has not been changed to allow for only a TABE Reading assessment TABE-R (Reading) to be entered. Until then, both a Reading and Math entry must be made in the system.

Any assessment given must be recorded in the Test screens of IWDS. Upon completion of the assessment(s), identified needs must be documented in an Individual Employment Plan (IEP) or in the instance of Youth an Individual Service Strategy (ISS). The Career Planner and the customer must jointly develop the plan and select the services that will best enable the individual to seek and retain self-sufficient employment. Like the assessment, the IEP or the ISS is an on-going process and requires routine updates, particularly as additional needs, are identified or goals achieved. Since the internal logic of IWDS requires a Math and Reading assessment test, career planners must use the ‘Can't Complete Test’ option in the Test drop-down on the Add a Test screen for both Reading and Math and enter “Unable to Conduct/Proctor Test Due to COVID-19” in the Comments boxes in IWDS during this timeframe. When ‘Can’t Complete Test’ is selected, the Grade Level Equivalency (GLE) needs to be recorded as “99” for both Reading and Math.

Note that this will limit the ability for a customer to receive a measurable skill gain via an increase in Educational Functioning Level (EFL) and the measure will need to be obtained in another fashion. See TEGL 10-16 Performance Accountability Guidance for Workforce Innovation and Opportunity Act (WIOA) Title I, Title II, Title III and Title IV Core Programs and TEGL 14-18 Aligning Performance Accountability Reporting, Definitions, and Policies Across Workforce Employment and Training Programs Administered by the U.S. Department of Labor (DOL).
WIOA Program Management Q16: Can the State waive the requirement for TABE for youth just entering work-based learning?

No. Section 681.290 of the WIOA Final Rule provides states with the authority to develop policy on section (b) of the Basic Skills Deficient definition, therefore, with supporting documentation policy will provide exceptions for Adults or Dislocated Workers who are entering only WIOA On-the-Job Training, Paid Work Experience or Customized Training. Since the WIOA youth program design requires an objective assessment of academic levels, skill levels, and service needs of each participant, which includes a review of basic skills, occupational skills, prior work experience, employability, interests, aptitudes, supportive service needs, and developmental needs, an assessment for basic skills such as TABE cannot be waived. However, due to the limitations of conducting proctored TABE tests during the COVID-19 crisis, career planners are to follow the guidance on that subject provided in this Q&A document. TEGL 21-16 provides further guidance on assessments in the youth program particularly for providing reasonable accommodation for individuals with disabilities.
WIOA Program Management Q17:Can the State waive the requirement for TABE for individuals with disabilities?

For individuals with disabilities the basic skills assessment portion of the objective assessment need not be approved for use in the Department of Education’s National Reporting System (NRS), nor are they required to determine an individual’s grade level equivalent or educational functioning level (EFL). Rather, local programs may use other formalized testing instruments designed to measure skills-related gains. In addition, for youth with disabilities skills related gains may also be determined through less formal alternative assessment techniques such as observation, folder reviews, or interviews. Local programs may use previous basic skills assessment results if such previous assessments have been conducted within the past six months.
WIOA Program Management Q18: Will case managers have to go back and test participants once ICCB resumes testing or will those people be waived from this requirement?

The assumption is that the question is referring to the TABE test. Career planners will not need to go back and test customers using the TABE test if other mechanisms to evaluate a customers’ employment goals, appropriate achievement objectives, and the needed combination of services to address those barriers were used during the COVID-19 emergency. However, career planners should remember that customers will be unable to receive a measurable skill gain via an increase in Educational Functioning Level (EFL) and the measure will need to be obtained in another fashion. See TEGL 10-16 Performance Accountability Guidance for Workforce Innovation and Opportunity Act (WIOA) Title I, Title II, Title III and Title IV Core Programs and TEGL 14-18 Aligning Performance Accountability Reporting, Definitions, and Policies Across Workforce Employment and Training Programs Administered by the U.S. Department of Labor (DOL).
WIOA Program Management Q19: Can WIOA Adult funds be used to support layoff aversion activities?

A state may use up to 25% of their Dislocated Worker allotment to provide Rapid Response activities, which can be used for layoff aversion activities. States may also leverage the Governor's Reserve to conduct additional rapid response activities. At the local level, Boards may use up to 20% of their combined adult and dislocated worker funds to provide incumbent worker training, which can be used for layoff aversion. ETA will consider waivers of this 20% cap as needed. Individuals involved in layoff aversion activities who meet program eligibility requirements may be served by the Adult and Dislocated Worker programs. States may approve transfers of up to 100% of adult and dislocated worker funds.
WIOA Program Management Q2: How should the local workforce area handle Rapid Response?

The WIOA requires the provision of on‐site Rapid Response services. The state and local rapid response team should work with the impacted companies to explore the options of providing the information remotely via technology. If a technology solution is not available, state and local teams are advised to follow the guidance of state and local public health officials regarding the steps that can be taken to minimize the risk to the impacted workers and rapid response team including the screening of participants / presenters and meeting with smaller groups of workers rather than a large workshop of more than 10‐15 people.
3‐20‐20 UPDATE FROM USDOL: States should continue to provide Rapid Response information to affected employees. States have flexibility in whether to provide this in‐person or through other means. States should consult CDC guidance and local government directives on large gatherings.
WIOA Program Management Q20: Can On-The-Job Training (OJT) funds be used for layoff aversion activities for current workers in the same company?

Employed workers may be eligible for WIOA-funded OJT if the requirements of 20 CFR 680.710 are met. Additionally, rapid response or statewide WIOA funds may be used for layoff aversion activities including incumbent worker training. See TEGL 19-16, Section 18 for current flexibilities related to rapid response activities. States and local areas may also utilize incumbent worker training for layoff aversion activities as discussed in TEGL 19-16 Section 13.
WIOA Program Management Q21 NEW: Will the LWIAs be required to expend 75% or 50% of the WIOA Youth funds on Out of School Youth for Program Year 2020?

The State of Illinois' waiver that allows the State and LWIAs to expend 50% of the WIOA Youth funds on Out of School Youth fund expires with the current Unified State Plan on June 30, 2020. The State has included this waiver request with the submission of the 2020 Unified State Plan that will take effect on July, 1, 2020. If the waiver is approved, LWIAs will continue to be required to expend at least 50% of the WIOA Youth funds on Out of School Youth.
WIOA Program Management Q3: There has been a significant increase in the number of customers requesting information about Unemployment Insurance. How do I find the latest information?

The Illinois Department of Employment Security’s website has posted specific information including a “Q and A” that provides information regarding unemployment insurance for individuals impacted by a business closure as a result of the COVID‐19 response. Visit the IDES COVID-19 FAQ page. Individuals are encouraged to file online. There is also a 1‐800 number available; however, there may be increased “wait” times because of the increased call volume.
WIOA Program Management Q4 - Will there be repercussions to LWIAs if in-person career services are suspended such as on‐site workshops, job fairs and eligibility determination?
The career services that must be made available are outlined in WIOA Section 134(b)(2) and in TEGL 19-16. At this time the Department does not have the authority to relax this requirement. It should be noted that local workforce areas can make career services available using on‐demand technology. As for on‐site workshops and job fairs, LWIAs are directed to follow the guidance issued by the Illinois Department of Public Health as it relates to social gatherings. Depending on the facility leaseholder, there may be additional implications.
Appointments with career planner staff should be conducted by telephone, Skype, etc. to the extent possible. Additional information is available at IDPH COVID Guidance. The Department will continue to monitor developments and will remain in contact with the US Department of Labor to identify additional guidance.
WIOA Program Management Q5 NEW: What are the case management and follow up requirements during the COVID‐19 national emergency?

Follow‐up services is one of the required 14 program elements to be made available for Youth and is outlined in WIOA Section 129(c)(2) and in TEGL 21‐16. Career planners are responsible for conducting follow‐up services to participants to determine if they need additional services to be successful. The OET recommends two‐way communication be made every 30 days for the first 3 months of employment for Adults and Dislocated Workers or exit for Youth, but at a minimum at least once a quarter. Services may be offered as often as necessary throughout the 12 months, but at a minimum of once each quarter for the next 3 quarters. This aligns with quarterly post‐exit reporting requirements. Communication between the career planner and the participant can be conducted by telephone, Skype, etc. At this time the Department does not have the authority to relax this requirement. The Department will continue to monitor developments and will remain in contact with the US Department of Labor to identify additional guidance. LWIAs may record a "Holding" service which allows a customer to be held without receiving training or services if his other program is interrupted due to illness or other unforeseen circumstances and during normal breaks in the academic or vocational training schedule. LWIAs should continue to Exit customers (in IWDS) who have not received a service in 90 days to remain in compliance with the current Exit Policy, Chapter 3. Section 3, General Requirements for Program Exit, and DOL/ETA TEGL 10-16 Change 1.
WIOA Program Management Q6: Are digital signatures allowed?

Yes, it is allowable and acceptable for digital signatures to be used so long as the LWIA or grantee follows the requirements of the Uniform Administrative Guidance. Additionally, per DCEO’s Legal Department digital signatures are allowed as long as it is the actual electronic signature and not something that was “auto generated” from an electronic system (for example – using the “script” font in Microsoft Word). Therefore, “signing pads” which would allow a participant to sign their name on a pad and it writes their signature on the application on the computer as a pdf document so that it cannot be altered would meet the requirements of the Uniform Administrative Guidance (see 2 C.F.R§200.335 Methods for Collection, Transmission and Storage of Information.)
WIOA Program Management Q7: What tools are least expensive most frequently used when documents require (electronic signautres) E signatures from clients and training provivers?

The Department is working with the US Department of Labor to respond to this question. Additional information will be provided as soon as it is available.
WIOA Program Management Q8: What will DCEO accept in lieu of actual customer signatures on new WIOA applications during this time?

The Department is working with the US Department of Labor to respond to this question. Additional information will be provided as soon as it is available.
WIOA Program Management Q9: Is there a way that customers could upload information directly into IWDS?

IWDS currently allows case managers to upload documents into the system. The Trade Program requires documents to be uploaded to IWDS as part of the State Merit Staff approval process. This feature can also be used for WIOA customers. At this time customers do not have access to the customer screens in IWDS. DCEO is working to identify document management options and possible workflows for case managers that are working remotely.

MOU - Affiliate Sites

Can you take out student loans if WIOA doesn’t cover your full tuition?

Yes, you can fill out the FASFA for the college you are attending to see if you qualify for a Pell grant or subsidized and unsubsidized loans. Keep in mind: You may not be eligible for financial assistance if you have previous loans from the past, that are not paid off, or have a GPA lower than 2.5.
Do infrastructure cost requirements include affiliate and specialized centers?

TEGL 17-16 expands the infrastructure cost requirements for affiliate and specialized service locations. Designated affiliate and specialized centers must share in infrastructure costs as negotiated and represented in the Memorandum of Understanding (MOU). Designated affiliate and specialized centers are optional and subject to local negotiations (Governor’s Guidelines – Revision 4, Appendix B).
What constitutes an affiliate site?

A center that makes available to job seekers and employer customers one or more of the one-stop partners’ programs, services, and activities. Designated affiliate centers must share in infrastructure costs as negotiated and represented in the Memorandum of Understanding (MOU). Designated affiliate centers are optional and subject to local negotiations. Designated affiliate centers must be included in the local certification of one-stop centers process to occur at least once every three years.

Note that Wagner-Peyser Employment Services provided by the Illinois Department of Employment Security may not serve as a stand-alone designated affiliate center and must be co-located with at least one or more other partners with the physical presence of combined staff more than 50 percent of the time the center is open (Governor’s Guidelines – Revision 4, Appendix B).

MOU - Annual Budget (Infrastructure Funding Agreement)

How are building resources used by non-WIOA staff accounted for in the one-stop operating budget spreadsheet?

These resources are not relevant to the MOU negotiations or agreed upon MOU. Costs to be allocated among required partners in a local area only consist of those costs which are incurred to provide federally funded workforce programs and services under WIOA.
How should one-stop operator costs be recorded on the one-stop operating budget spreadsheet?

The One-Stop Operator model must be selected in Tab D, line 76 (single entity, consortium or other). If one-stop operator costs are allocated to all partners for the respective center, the cost should be entered into row 77. If the one-stop operator costs are allocated to only some partners, the cost should be entered into row 79. An explanation of the one-stop operator must be included in the “notes” section of the one-stop operating budget spreadsheet and the MOU narrative, Section 10 (Governor’s Guidelines – Revision 4, Appendices J & K).
Is a personnel contribution allowed as a shared delivery system cost?

Each required partner’s contribution to shared costs to operate the local delivery system can be made through cash, non-cash, or third-party in-kind contributions. An example of a non-cash contribution is in-kind staffing. Consistent with the description of each contribution type in § 678.720, a contribution of personnel may be considered a non-cash service contributed by a required partner and used by the local one-stop delivery system as long as the following conditions are met:
- The contribution is recognized and accepted by all other partners,
- The contribution has the effect of offsetting a cash contribution toward local one-stop delivery system costs that would otherwise be due from the partner making the non-cash contribution, and
- The contribution is valued consistent with 2 CFR part 200.306 to ensure the contribution is fairly evaluated and meets the contribution partner’s proportionate share.
- Contributions of personnel time as non-cash contributions are not permissible contributions for infrastructure costs.
Is providing sign language interpreters in the comprehensive one-stop center considered a shared cost?

There are several considerations to take into account. If the accommodation is for a participant in one program, the costs go to that program only. If the accommodation is for a participant of multiple programs, it should be split among the applicable programs. If the accommodation is a standby resource that all partners desire, then the cost would be shared among all partners (subject to local agreement).
Is the local area bound to the numbers calculated on the one-stop operating budget spreadsheet as long as everyone is in agreement with the partner contributions?

The expectation is that each partner will be bound by its contribution commitments as reflected in the agreed-upon final budget. Partners will need to periodically reconcile budgeted costs with actual costs (§ 678.715(a)(4)). Federal guidance requires that the “one-stop operating budget must be periodically reconciled against actual costs incurred and adjusted accordingly” to ensure the budget reflects a cost allocation methodology that demonstrated how infrastructure costs and shared service delivery system costs are charged to each partner in proportion to the partner’s use of the one-stop center and relative to the benefit received (TEGL 17-16, page 3).
Should the one-stop operating budget spreadsheet and the MOU include organizations located outside of the comprehensive one-stop center?

The MOU and one-stop operating budget spreadsheet shall include all partners in the one-stop delivery system. The local area has discretion as to the “local delivery system” (e.g., designated affiliate center, designated specialized center, or corporation). In the absence of a state policy, if a local workforce board designates a service location as an affiliate or specialized center, then required partners who choose to make their programs and services available in that affiliate or specialized center must contribute a proportionate share of the infrastructure costs for that center (Governor’s Guidelines – Revision 4, Appendix B).
Some local partners claim that they are only the funder of last resort. Is this true?

§678.760 states “WIOA neither requires programs to examine if other funds are available before using program funds to pay for a service, nor does it establish a requirement that any program can only be a ‘payer of last resort.’”
What are the requirements in Illinois for reconciling budgeted versus actual shared costs among required partners?

The Governor’s Guidelines – Revision 4 and the Handbook for Conducting Periodic Reconciliation provide additional direction and guidance for the requirement to reconcile budgeted to actual costs and to adjust each partner’s contribution toward shared infrastructure costs and shared service delivery system costs:

1) Reconciliation must occur at least semi-annually.
2) Reconciliation of budgeted to actual shared costs is based on actual costs incurred compared with budgeted amounts of each line item.

Further details are available in the Handbook for Conducting Periodic Reconciliation.
What does impartial individual mean for negotiation of the one-stop operating budget?

The Governor’s Guidelines – Revision 4 state that the chair will designate a private sector member of the board—or other impartial individual—to have lead responsibility for negotiation of the annual one-stop operating budget, including local infrastructure costs and agreed-upon, local one-stop delivery system costs. The impartial individual may not be a local core or required partner. If required partners in the local area determine the individual designated to lead annual budget negotiations is not an impartial individual, then a waiver must be requested as described in Section 4 of the Governor’s Guidelines – Revision 4.

Furthermore, each local board is responsible for identifying the lead MOU and budget negotiators, as well as to document the appointments. If any questions are raised about the impartiality of the individual appointed to lead budget negotiations, then the local board is also responsible for justifying how its appointment complies with the direction provided in the Governor’s Guidelines. Local boards should document their justification at a minimum in board meeting minutes.
What if a single required partner does not agree to the one-stop operating budget?

If, after the 30-day State-level remediation period, required partners cannot reach agreement on infrastructure costs of the one-stop centers in the local area, the State infrastructure funding mechanism will be instituted.

The State infrastructure funding mechanism may be considered for all one-stop centers and designated affiliates for which required partners have reached an impasse on the local infrastructure funding agreement (TEGL 17-16).

More information can be found in the Governor’s Guidelines – Revision 4, Section 3.
Where can I find the most up-to-date version of the one-stop operating budget spreadsheet?

The most current version of the one-stop operating budget spreadsheet (Appendix K) is available on the WIOA Implementation Portal under “Documents and Updates."
Where can I locate the final FY19 MOU One-Stop Operational Budget?

This can be found on the Regional/Local Plan & MOU Approval Status Dashboard
Additional information about One Stop MOU Development can be found here: Implementation Documents & Updates
Who is responsible for approving the draft one-stop operating budget prior to submission to the State?

As described in the Governor’s Guidelines - Revision 4, at the second MOU negotiation meeting, the required partners will review the draft budget and make all agreed-upon revisions. The chair of the Local Workforce Innovation Board (LWIB) is to submit the final budget with the signed MOU.

MOU - Budget Reconciliation

Are individuals responsible for reconciliation required to submit the completed Reconciliation Spreadsheet or Matrix of Benefits Received by Partner?

The “Handbook for Conducting Periodic Reconciliation” provides guidance that if any local area needs to request technical assistance or cannot reach agreement under the process agreed upon in the local MOU, then the individual responsible for reconciliation should provide to Michael Baker at Commerce, wioaplans-mous@illinoisworknet.com, a report signed by the local workforce board chair with justification for non-payment or disagreement.
Does a one-stop operator consortium need to approve the person identified by the local workforce board chair as the individual responsible for reconciliation?

No. It is recommended that the local workforce board chair work in consultation with the one-stop operator consortium.
Does the threshold for whether a line-item variance warrants an MOU/budget amendment apply to both when actual costs significantly exceed budgeted costs and when actual costs are significantly less than budgeted?

No. The threshold for whether a significant line item variance warrants a full MOU/budget agreement only applies when actual costs exceed the budgeted amount by 15% and account for 10% of the total budget.
If actual costs are significantly less than budgeted, then an MOU/budget amendment is not required. Partners can simply receive a credit as part of the reconciliation process.
Even if the one-stop operator invoices required partners for actual costs as they come in, does the one-stop operator also need to complete the “Matrix of Benefits Received by Partner?” What is the purpose of the “Matrix of Benefits..."?

The reconciliation process is intended to ensure partners’ share of the costs of the one-stop center is proportionate to the benefit they receive by providing services in that service location. Even if the reconciliation is not performed because actual costs are billed to partners as costs are incurred, required partners still need to demonstrate that their share of the costs are proportionate to the benefit they receive. The Sample Matrix of Benefits Received by Partner is one way to demonstrate each partner’s benefits received. The local area may identify other ways to demonstrate that costs are shared proportionately to the benefits received by partner, but it should be documented.
If the one-stop operator invoices required partners for actual costs as bills come in, does the local area still need to perform the periodic reconciliation using the Reconciliation Spreadsheet?

If actual costs are billed to required partners as costs are incurred throughout the program year, then the process of reconciling budgeted to actual cost would not be necessary. The invoices of actual amounts already account for any variances between budgeted and actual costs shared among partners.
What documentation is required to verify actual costs or to include in a Final Notice about additional amounts owed?

The “Handbook for Conducting Periodic Reconciliation” does not require specific documentation. The individual responsible for performing reconciliation in the local area should develop the local process and documentation needed to verify actual costs in collaboration with the required partners that actually incur the expense of each line item in the budget.
What is the difference between the reconciliation period and the reconciliation process?
The reconciliation period is the time between the one-stop operating budget’s effective date and the identification of actual costs at a minimum of every six months. In a semi-annual reconciliation:
- Reconciliation Period 1 incurs costs between July 1 and December 31.
- Reconciliation Period 2 incurs costs between January 1 and June 30.
The process of reconciliation occurs after the reconciliation period ends. In general, required partners will make payments of any additional amounts owed within 60 calendar days from the end of the reconciliation period.
When are payments of additional amounts owed due?

The “Handbook for Conducting Periodic Reconciliation” suggests, generally, payments of additional amounts owed as a result of reconciliation should be paid within 60 calendar days of the end of the reconciliation period. The sample timeline on page 2 of the “Handbook for Conducting Periodic Reconciliation” provides specific examples of dates for each step of the reconciliation process.

MOU - Data Sharing

Can you provide further guidance on data sharing and protecting personally identifiable information for the MOU submittal?

State-level partners are continuing to explore best practices and are in the process of considering the development of policy to guide data sharing and protection of personally identifiable information.
Data sharing and having a common database is one major cost that is necessary to make the one-stop center successful. Will that cost be subsidized by the State?

Ongoing conversations are taking place at the State level and there is a desire to streamline data collection and availability while ensuring appropriate levels of privacy and security. Work enabling movement in that direction is underway.
Is there a state level data sharing agreement? Is there an established mechanism for each state partner to provide information on what local partners can legally share at the local level?

Currently data sharing agreements exist between several core and required partners.
Will data sharing agreements just be the agreements through the State level or will local level areas have to create their own data sharing agreement?

A hybrid approach is needed. Data sharing arrangements will be handled simultaneously at the State and local levels.

MOU - Direct Linkage

Can partner referrals constitute a direct linkage communication in Illinois?
In addition to the forms of communication cited in §678.305(d)(3)(ii) as not complying with direct linkage requirements (providing only a phone number, computer Web site, information, pamphlets or materials), none of the following forms of communication may be used as a direct linkage connection from customers to partner staff designated to provide direct linkage services.
- Referrals
- Email
- Fax
Though these forms of communication are adequate as a supplement to compliant forms of direct linkage communication and can be a crucial part of the service delivery process, do not cite these forms of communication as a form of direct linkage in any formal documentation (i.e. MOUs). These methods are not technologies that satisfy the real-time, on-demand communications requirements (Governor's Guidelines – Revision 4, Appendix I).
Is any partner staff person qualified to provide direct linkage services via the approved forms of direct linkage communication?

As defined in the Governor’s Guidelines – Revision 4, Appendix I, qualified individuals are only program staff members who have been specifically identified as trained and knowledgeable regarding the needed partner’s services and programs and for whom providing direct linkage is a formal part of his/her job.
Is direct linkage required to be provided through video?

Illinois has established additional requirements to provide services via “direct linkage” technology, which are described in the Governor’s Guidelines – Revision 4, Appendix I. Direct linkage can be provided via phone or real-time web-based communication (e.g., Skype, Google Hangout). The requirements for providing direct linkage via video include: high-speed internet capability; dedicated, two-way video and audio-enabled communication between two devices at two or more locations; and a back-up appointment scheduling capability if services are unavailable at the time of contact. Immediate access to services should be the norm, and all appointment scheduling messages from customers must be responded to within a “reasonable period of time,” which is defined as 24 business hours in Illinois.

The requirements for providing direct linkage by phone include: a specific dedicated phone number, phone coverage during normal business hours on all normal business days and voicemail or other capability enabling customers to leave a message if access to services via phone is unavailable at the time of contact. Immediate access to services should be the norm, and all voicemails must be returned within 24 business hours.

A direct linkage checklist is now required for local partners to assure that they are in compliance with the direct linkage requirement.

MOU - FTEs

Are FTEs determined based on shared delivery system costs, infrastructure or both?

The number of FTEs is based on the number of staff the required partner is committing to provide services under WIOA in the comprehensive one-stop center. The FTE commitment then serves as the cost allocation methodology that carries through the one-stop operating budget spreadsheet to calculate each partner’s proportionate share of infrastructure costs, as well as local service delivery system costs.
Are FTEs the required method of allocating costs?

No, not under the local funding mechanism when all partners agree. However, other methods are strongly discouraged. FTEs is the required cost allocation methodology under the state funding mechanism when required partners have reached a budget impasse (Governor’s Guidelines – Revision 4, Section 2).
Can an LWIB require core and required partners to commit a minimum of one FTE at a comprehensive one-stop center?

No. Under WIOA law and final regulations each core and required partner has flexibility to determine how it will meet WIOA service access requirements. Onsite staff, contractor staff, staff cross-training and technology meeting the “direct linkage” requirements described in proposed regulation § 678.305 are all options available to most required partners (Wagner-Peyser and Title IB partners must be physically present at a comprehensive one-stop center).

Each partner’s determination of the method of service delivery must assure that all one-stop center customers can access information and services on demand. Depending on known or anticipated demand for services at a comprehensive on-stop center, this may or may not require a partner to commit one FTE to a comprehensive one-stop center.

The specific services each required partner will provide at a comprehensive one-stop center, the methods of service delivery that will be used to provide these services and the cost implications associated with these decisions are all encompassed by MOU negotiations involved local boards, chief elected officials and required partners.
Does having a fractional FTE mean services can only be available a fraction of the time at a comprehensive one-stop center?

No. Required partners under WIOA must make their applicable services available in a comprehensive one-stop center during all regular business hours. A required partner’s FTE commitments should be based on demand for services in that local area. However, every required partner is expected to make its services available and accessible on demand to customers who enter a comprehensive one-stop center during regular business hours through onsite staff, cross-trained staff or direct linkage technology.
For LWIAs that use the FTE cost allocation methodology, can a partner commit to less than .25 FTEs?
A required partner can commit less than a .25 FTE if three conditions are met:
- A rationale is articulated for why the .25 FTE minimum does not align with the required partner's proportionate share of infrastructure costs and benefit received by participating in the designated center. This may include actual data for the utilization that supports the lower FTE commitment.
- All required partners in the LWIA agree for a partner to commit less than .25 FTE.
- The local workforce board chair submits a letter to the State to request the waiver, providing the rationale and supporting data as an indication that all required partners agree to that FTE commitment level.
For LWIAs that use the FTE cost allocation methodology, can an individual required partner request a waiver from the .25 FTE minimum?
A required partner who wishes to seek a waiver must first negotiate in good faith its FTE commitment with all required partners in the local area. All required partners must approve an FTE commitment less than the .25 FTE minimum stated in the Governor's Guidelines – Revision 4. A local workforce board seeking a waiver to any provision of the Governor's Guidelines must submit a written request to the individual annually designated by the Governor. This request must:
- Specify the provision in the latest version of the Governor's Guidelines for which a waiver is being requested;
- Indicate whether all required partners in the local area agree to seek a waiver of the provision identified;
- Provide a detailed rationale for the waiver request, including a description of the negative consequences or impact that will result in the absence of a waiver;
- Affirm that the waiver requested complies with the "Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards" when applicable;
- Document that the waiver request has been presented to and approved by the local workforce board chair; and
How does Illinois ensure services are available during all regular business hours, as required by 20 CFR 678.730 – 678.738?

Final Rule requires that all required partners in a one-stop center make their programs and services available during all regular business hours. Illinois has established a guideline of committing at least one quarter-time staff equivalent (.25 FTE) for each core and required program in LWIAs that select the FTE cost allocation methodology. Committing less than .25 FTE generally equates to a staff person dedicating less than 10 hours per week to providing access to services within a one-stop center. Partners have flexibility in how they meet the .25 FTE minimum through onsite staff, onsite contractors, cross-training of other required partner staff or offsite staff using direct linkage technology.
How will the reconciled costs be collected from all partners?

The Handbook for Conducting Periodic Reconciliation sets out a general process for reconciliation. The Local Workforce Innovation Board (LWIB) Chair determines the frequency at which the local area will reconcile budgeted to actual costs. The LWIB Chair also identifies the individual who will be responsible for both leading the reconciliation process and performing the reconciliation. The individual responsible for reconciliation develops a process for identifying actual costs at the end of each reconciliation period.
If a required partner has a staff person that is providing career services at an affiliate or an office outside the comprehensive one-stop center, should that person be counted as an FTE?

Yes, individuals who are providing WIOA-related services at an affiliate or specialized center should be included if the local workforce board designates the service location as an affiliate or specialized center.
What if one required partner will not agree to commit .25 FTEs?

If all required partners agree to allow a partner to commit less than a .25 FTE, and the local board chair concurs, the local board chair may submit a waiver using the waiver request form included in the Report of Outcomes template (Governor's Guidelines – Revision 4, Section2, Item 13).
When multiple contractors administer a required program in an LWIA, is each entity responsible for the required minimum .25 FTE or is this a “collective responsibility.”

The required partner as a whole is required to commit at a minimum .25 FTE to each comprehensive one-stop center. The .25 can be made up of several entities, but it must reach .25. If all required partners agree to allow a partner to commit less than a .25 FTE, and the local board chair concurs, the local board chair may submit a waiver using the waiver request form included in the Report of Outcomes template (Governor's Guidelines – Revision 4, Section2, Item 13).
From TEGL No. 17-16: "Partner Programs with Multiple Grant Recipients. Partner programs and additional partners that carry out a program in the local area are required to share infrastructure costs and certain additional costs (20 CFR 678.700(c)), 34 CFR 361.700(c), and 34 CFR 463.700(c)). When two or more grant recipients or contractors of a required partner program carry out a program in a local area, these entities are considered one-stop partners and must reach out to the Local WDB and carry out the roles and responsibilities of one-stop partners, including negotiating their share of infrastructure costs. For instance, there may be multiple YouthBuild and SCSEP grant recipients along with a few Job Corps contractors in a local area. In this situation, each grant or contract recipient carrying out the program in that local area must contribute towards infrastructure costs, and those contributions must be based on the proportionate use and relative benefits received by those partners from the one-stop centers."
Why are FTEs (full-time equivalents) the preferred cost allocation methodology for shared costs in Illinois?
A common cost allocation methodology helps standardize MOU tools and technical assistance available to local areas, and the proportion of FTEs that staff a designated center is an allowable method to allocate costs. Other cost allocation methodologies are allowable provided they are agreed upon by all required partners in the local area and are consistent with the "Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards" (2 CFR part 200: Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards: Final Rule. December 26, 2013; 2 CFR part 2900: Office of Management Budget (OMB) approved exceptions for DOL). For example, any cost allocation methodology must:
- Be reasonable in determining appropriate partner contributions based on proportionate use and relative benefits received in the one-stop centers.
- Be based on actual demand for services within a service location.
- Be reliable, predictable and not frequently fluctuating, allowing the timely management of the cost allocation.
- Be a cost base that is simple and efficient.
- Take into account data that is already tracked by required partners and does not require new recordkeeping or reporting systems, if not necessary.

MOU - Infrastructure Costs

Can you provide an example of how infrastructure costs would be treated if 25 of the 50 total onsite staff are directly involved with WIOA services?

The 25 employees that are directly involved in providing services authorized under WIOA would be counted towards FTEs in the one-stop operating budget spreadsheet.
Is it acceptable to use Federal and State grant dollars to pay infrastructure costs to a for-profit company?

Yes. The allowability of infrastructure costs is not contingent on the type of entity.
What is the state funding mechanism?

From the Governor’s Guidelines – Revision 4 glossary on page 38, the state one-stop infrastructure cost funding mechanism is “the method used to cover infrastructure costs of the comprehensive one-stop center(s) in a local area when required partners are unable to agree on how to share those costs. The amount that each required partner can contribute to one-stop infrastructure costs is capped under the State funding mechanism. Funding under the State infrastructure funding mechanism is available only to certified comprehensive one-stop centers in local areas that cannot reach agreement on an MOU at the end of a 30-day remediation period.”

MOU - Local Service Matrix

What information is required for “service delivery method” in the Local Service Matrix for Comprehensive One-Stop Centers in the MOU template?

Per § 678.305(d) the options for service delivery methods include on-site, cross-training of staff, or direct linkage (Wagner-Peyser and Title IB partners must be physically present at a comprehensive one-stop center). Examples are encouraged in the “Service Delivery Method through the Local Comprehensive One-Stop Centers,” such as “direct linkage will be made available through Skype.”
What is considered an “other program and activity” in the Local Service Matrix for Comprehensive One-Stop Centers in the MOU template?

Other programs and activities are any value-added service provided to participants. Examples include a mobile workforce center, apprenticeship information and referral, resume writing and interview skills training and sector based job fairs.

MOU - One-Stop Delivery System

Is the one-stop operator a shared cost?

The competitive procurement of a one-stop operator may constitute a shared cost if all required partners agree and proportionately share the cost based on the benefit received. Required partners must share costs to pay additional costs relating to the operation of the local one-stop delivery system (§ 678.760(a)). Shared costs of the local one-stop delivery system are determined locally and must be agreed upon by all required partners in the local area.
Who is responsible for collecting all the shared costs?

Ultimately the LWIB is responsible for submitting a complete MOU. However, collection of specific costs will depend on the type of costs being shared. For infrastructure costs, this will generally be the leaseholder. It could be another entity, such as the LWIB for other types of shared system costs.

MOU - One-Stop Operator

Does the one-stop operator need to be procured if the operator is a consortium of required partners who currently operate the one stop?
Audience: Adult

Yes. Regardless of whether the one-stop operator is a consortium model or single entity, one-stop operator procurement procedures are not affected by the type of one-stop operator or by an entity’s current status as one-stop operator at a comprehensive one-stop center. The local board must competitively procure the one-stop operator at least once every 4 years, in accordance with 20 CFR Part 678.605 and sec. 121(d)(2)(A) of WIOA. For more information, please see the following Training and Employment Guidance Letter released by DOL: TEGL 15-16.
If a local area has not competitively procured a one-stop operator for PY20 during MOU planning, how should Section 10 of the MOU address the second dot point of required content? Should the procurement process be described in the current or upcoming MOU?
Audience: Adult

For One-Stop Operator agreements that expire by June 30, 2020, enter the functions and scope that will be used for your upcoming competitive procurement process. Local WIBs may wish to retain the same functions and scope for the new procurement or they may wish to make adjustments from the current one-stop operator agreement based on the experience gained since the agreement was executed. For One-Stop Operator agreements that expire after June 30, 2020, the MOU should list the functions and scope of the current agreement.
Is the one-stop operator a shared cost?

The competitive procurement of a one-stop operator may constitute a shared cost if all required partners agree and proportionately share the cost based on the benefit received. Required partners must share costs to pay additional costs relating to the operation of the local one-stop delivery system (§ 678.760(a)). Shared costs of the local one-stop delivery system are determined locally and must be agreed upon by all required partners in the local area.
Is this new one-stop operator invoice for PY 2021 a separate invoice from the reconciliation invoice?
Yes. Required partners should establish an invoicing process to document the value of the one-stop operator services provided by the one-stop operator, whether a consortium or single entity. The Supplemental Guidance offers two options:
1. Option 1: Designate an invoice showing the value of the shared cost of the OSO services and the required partners' contribution toward that allocated cost (even if a non-cash contribution results in a $0 cash balance owed).
2. Option 2: Issue an invoice that sums a required partner's total allocated costs across all shared cost line items, delineating a line item for OSO services.

MOU - Program Specific

Can an LWIB use Title IB funds to contract with a service provider to meet the requirement that adult education services under Title II or WIOA be accessible at a comprehensive one-stop center?

No. The Title II provider must have an approved contract or grant with the Illinois Community College Board for Adult Education/Title II services.
Is the Second Chance Program a required partner in Illinois?

Recidivism programs funded by a Second Chance grant in Illinois are administered by the Illinois Department of Corrections and funded through a grant from the U.S. Department of Justice, not the U.S. Department of Labor. Only U.S. Department of Labor grantees under Section 212 of the Second Chance Act of 2007 are required partners under WIOA. Because Illinois’ Second Chance grant was awarded by the U.S. Department of Justice, the Second Chance grantee in Illinois is not a required partner under WIOA.
Local workforce boards and partners may decide to include the Second Chance grantee as an additional partner in one-stop centers.
What is the difference between the National Farmworker Job Program and the Migrant and Seasonal Farmworker Program, and how should their FTEs be accounted for?

The Illinois Department of Employment Security (IDES) administers the Migrant and Seasonal Farmworker program, which is a required program under WIOA. The Illinois Migrant Council administers the National Farmworker Jobs Program, which is a separate program under Title I of WIOA. Each required partner enters its own and separate FTE commitments.

MOU - Suggested Improvements

A conversion chart showing the actual hours required by a specific FTE commitment would be helpful in illustrating the exact time commitment required by a certain FTE commitment

The possibility of including an FTE conversion chart as a part of State guidance is currently being explored.
An evolving list of those individuals authorized to sign MOUs on behalf of required partners would be helpful to ensure the correct signature is sought during the negotiations process.

The feasibility of distributing a list of authorized signatories for each required partner, updated for each program year, is being explored.
Can you please share practices for completing sections of the MOU Template and engaging with less communicative service providers to ensure compliance with State guidance and Federal statute?

Best practices for successfully completing and submitting required elements of WIOA implementation are updated on Illinois workNet. The expansion of the best practices displayed on the WIOA Implementation Portal to include MOU narrative content is being explored.
To further streamline the description of all partners that each partner will make referrals to, a checkbox could be added to the Referral System matrix that when checked would affirm that all partners agree to refer to all other partners.

To ensure compliance with WIOA statute ((Sec. 121 (c)(2)(iii))), each partner must affirm to which partners it will make referrals.

MOU - Waiver Requests

How is a waiver approved?

A waiver request may be submitted to the individual designated by the Governor by the local board only after local board approval and approval by all partners. The WIOA Interagency Technical Assistance Team will assess each waiver request on an individual basis. Determinations will be made as part of the annual State-level review process described in Section 6 of the Governor's Guidelines – Revision 4.
To which provisions of the Governor’s Guidelines – Revision 4 can required partners request a waiver?

Only waiver requests regarding provisions of the Governor's Guidelines over which the State has complete discretion will be considered. The State does not have authority to consider waivers of any requirement specified in Federal law, regulation or other authoritative Federal guidance.

MOU Development

Are all partners aware that they are to participate in good faith negotiations?

The Governor's Guidelines – Revision 4, Section 1, Item 6) states that all individuals participating in the development and negotiation of local MOUs will negotiate as equals and in good faith to reach an agreement and to bring about a unified vision for the local one-stop delivery system. This includes participating in required partner meetings from the beginning of each negotiation period and addressing issues or requests for changes during each step of the development and approval of the MOU and one-stop operating budget.

Through indicating on the Pre-Program Year Planning Form, local areas can ensure the State is aware of any staff or partner programs new to the WIOA implementation process in Illinois that would benefit from a WIOA orientation.
Can comprehensive one-stop center staff and core and required partners be cross-trained to provide services for multiple programs?

Yes. Local comprehensive one-stop center partners can cross-train staff so they are able to provide services in multiple programs. The extent to which staff are cross-trained and the impact this has on each partner’s FTE commitment will be part of local MOU negotiations regarding both the method of service delivery and each partner’s share of delivery system costs.
Can fair share or proportionate share be based on the number of clients served by each agency in the one-stop center?

Yes. Although FTEs are the preferred method to be used at the local level to determine proportionate share and are the basis the Governor will use to make the required determination of proportionate share at the State level, local areas can choose any methodology that is in compliance with the Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards.
Can only minor, technical changes be made to an MOU each program year an MOU Amendment is submitted to the State for approval, or can substantive changes be submitted for approval?

On each occasion that an MOU or MOU Amendment and one-stop budget are submitted, the documents are reviewed in their entirety to ensure that all aspects and sections of the submittal comply with State guidance and WIOA statute. Any required revisions to the MOU, MOU Amendment or one-stop budget to incorporate required revisions for compliance purposes must be performed by the local area before approval is granted (§678.505).
Can required programs designate multiple individuals to negotiate local MOUs?

Ideally, each required program should identify one individual to negotiate local MOUs on behalf of the program representatives in each local area. However, that may not always be feasible or preferable for every program in every local area. As these individuals are identified they are included on the updated “Summary of Individuals to Negotiate MOUs” document on the WIOA Implementation portal.
Can the State require a local area to provide a call-in option for MOU and budget negotiations to avoid potential scheduling conflicts?

According to the Final Rule, the MOU is a product of local discussion and negotiation (§678.500). Local workforce boards and partners must enter into good-faith negotiations as well (§678.510), though there is no stipulation as to how these meetings must occur. In Illinois, the scheduling of meetings during MOU and budget negotiations is up to local discretion, ensuring that all partners have ample opportunities to participate.
Do physical and programmatic accessibility apply to all service locations or just designated service sites?

Physical and programmatic accessibility requirements under WIOA ((Sec. 121 (c)(2)(iv)) do apply to all service locations, regardless of designation status. The MOU only concerns designated comprehensive one-stop centers, affiliate sites, and specialized centers; therefore, only the physical and programmatic accessibility of designated service locations must be described in the MOU narrative.
Does the one-stop operator model selected by the local area (i.e., consortium, single entity) affect the activities that are prohibited from being performed by the one-stop operator?

No. The prohibited functions of the one-stop operator are not contingent upon the type of one-stop operator model selected by the local area.
How does a local area manage required partners who are engaged in local negotiations about services, but not shared costs?

The expectation is that local partners will be engaged in negotiations about both services and costs. If this is not happening, contact should be made with your respective liaison at the state-level.
If the consortium model is selected as the one-stop operator model, is the local workforce innovation board responsible for convening system stakeholders for local planning?

According to 20 CFR §679.370(d), the local workforce innovation board must “convene local workforce development system stakeholders to assist in the development of the local plan under §679.550 and in identifying non-Federal expertise and resources to leverage support for workforce development activities. Such stakeholders may assist the Local WDB and standing committees in carrying out convening, brokering, and leveraging functions at the direction of the Local WDB.” This is applicable regardless of the one-stop operator model selected.
Is there a requirement that an LWIA provide physical space in the comprehensive one-stop center for a required partner?

If a partner chooses to make services accessible at a comprehensive one-stop center with onsite staff, then the local area should make every effort to provide space. The individual partner decides how it will make its services accessible at a comprehensive one-stop center. Staffing is an option, but so is direct linkage. All of this is part of local negotiations, including raising issues as needed about the adequacy of the size of space available.
Should non-designated service connection (access) sites be listed in Section 6: “Name and Location of All Service Locations” of the MOU?

No. Non-designated connection (access) sites are only required to be listed in the Pre-Program Year Planning Form (Appendix C to the Governor’s Guidelines – Revision 4).
Should services funded through a special grant and provided to limited cohorts, meaning not available to all eligible walk-in customers, be included in the Career Services Matrix?

Do not include services related to a short-term grant in the MOU Service Matrix.
Under what circumstances are abbreviations and acronyms prohibited in the MOU?

The use of acronyms and abbreviations is prohibited on all signature pages, as required by the Office of the Illinois Comptroller for purposes of using the MOU as a contract for payment. Please ensure that any abbreviations or acronyms used in any other section of the MOU, such as Section 1: “Parties to the MOU,” are accurate and up to date.
What are the proscribed functions the one-stop operator may not perform?

The list of proscribed functions is included as part of Section 10: “Procurement of One-Stop Operator” of the MOU Template and 20 CFR §678.620. The local area must affirm that none of the proscribed functions will be performed by marking the checkboxes.
What if a comprehensive one-stop center has empty desks? Is this “idle capacity,” and would it be considered a disallowed cost for other federally funded programs to pay for this space?

Idle capacity is generally unallowable. However, it may be allowable to the extent that it is necessary to meet fluctuating workload requirements, it was previously necessary and is now temporarily idle, or it is a normal cost of doing business. Refer to the Uniform Guidance at 2 CFR 200.446 for more information.
What if a required partner does not attend MOU negotiation meetings?

If a required partner is absent from MOU negotiation meetings, the local area should reach out to their state-level liaison as soon as possible.
What information on referrals should be included in Section 11?

Be sure to respond to all the dot points in the template. Include information on how each partner will make and track referrals to other agencies and describe the role of the one-stop operator in helping coordinate referrals. You no longer need to include a narrative list of agencies to which referrals will be made in Section 11, that information is provided on the Referral System Matrix form.
What is the definition of “fair share?”

Fair share is a complex determination that is made locally. It is rooted in federal cost allocation principles (Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards). The One-Stop Financial Management TAG is a good resource for determining a fair share.
What is the definition of “proportionate share?”

The determination or each partner’s proportionate share is a specific requirement incumbent upon the Governor. Proportionate share is described in the Governor’s Guidelines, Revision 4, Appendix B, as “an amount determined by the Governor that represents a required partner’s portion of comprehensive one-stop infrastructure costs State-wide for purposes of the State infrastructure funding mechanism. This amount is determined through a reasonable cost allocation methodology that assigns costs to required partners in proportion to relative benefits received.”
What is the MOU submittal due date?

Agreed upon and signed MOUs, including the one-stop operating budget are due to the State of Illinois by June 30. MOUs must be submitted to Michael Baker at wioaplans-mous@illinoisworknet.com.
When revising the MOU for a specific program year after its initial submission to the State, does the submittal of the revised MOU require new signatures from required partners?

No. The letter from the LWIB Chair to the individual designated by the Governor (included as Appendix L to the Governor’s Guidelines – Revision 4) affirms that all parties to the MOU and the LWIB have agreed to the revisions included in the submitted revised MOU. This affirmation is important as the MOU and, in some cases, the one-stop operating budget has undergone changes since the parties to the MOU last reviewed it.

It is encouraged that this affirmation is received through an in-person meeting, but the method through which the local area ultimately gathers this affirmation is determined at the local level (i.e., in-person meeting, phone, email, etc.). It is only required that the letter from the LWIB Chair to the individual designated by the Governor (affirming that the LWIB and all parties to the MOU affirm the required revisions made) be submitted within 5 days of the LWIB meeting immediately following the submission of revisions.

If a local area is in need of technical assistance in completing this process, please contact Mike Baker at Michael.baker@illinois.gov or Cameron Sweatman at camerons@kebcpa.com.
Which partners are responsible for providing follow-up services for youth?

As described in WIOA Sec. 129(c)(2)(I), program partners providing career services to youth (as described in WIOA Sec. 129(c)(1)) must provide follow-up services for youth placed in employment for no less than 12 months.
Who in the negotiations process is responsible for overseeing the negotiations process in regard to formal partner cross-training arrangements and fulfillment of these commitments?

The one-stop operator may be a source that ensures that cross-training between partners occurs in a compliant manner, in alignment with the MOU and one-stop operating budget. Ultimately, the successful cross-training of partner staff to provide services is contingent upon the partners involved.
Who is the party to the MOU for SCSEP?

Authorized by the Older Americans Act, the Senior Community Service Employment Program is a community service and work-based job training program for older Americans, including through the American Job Centers. SCSEP in Illinois is administered by the Illinois Department on Aging (State) sub-grantees namely the Area Agencies on Aging, a community action agency, and an agency that focuses on senior employment, as well as by seven national contractors. In Chicago the Senior Services Area Agency on Aging is based at the Chicago Department of Family and Support Services, with other State sub-grantee and other national contractors providing services throughout Cook and surrounding counties, as well.
Based on recent federal guidance issued in TEGL 17-16, required partners with two or more grant recipients or contractors that carry out a program in a local area must each contribute towards infrastructure costs based on a proportionate use and relative benefits received by each.
That means that if multiple SCSEP providers in any given area administer the program, both entities (the State sub-grantees and the national contractors) are parties to the MOU and must participate in negotiations of service delivery and cost sharing.
Why is the “subject to the availability of funds” language only applicable to state agency partners?

This language is required under the State Finance Act (30 ILCS 105/30) and applies to State agencies only. This language is a technical change to the MOU intended solely to meet the requirements of State law. The workforce Innovation and Opportunity Act (WIOA) does not allow core or required partners to opt out of their responsibility to share infrastructure and other costs due to insufficient funding. The Interagency Technical Assistance Team will not approve an MOU expanding the “subject to the availability of funds” language to a required partner that is not a State agency.

Regional and Local Plans

Do CEOs have to approve WIOA Regional and Local plan modifications before submittal?

Yes. The standard cover letter must be signed by the LWIB Chair and CEO(s) indicating their approval of the plan. CEOs that already have agreements on file to designate a lead CEO authorized to sign on behalf of all CEO’s in the area may continue that practice under WIOA. (Source: WIOA Notice No. 15-NOT-07, page 3, Part 1. B. 1)
How does the MOU tie into the Regional and Local Plans?

There should be a correlation between all three documents. The regional plans set the overarching priorities and strategies. The local plans describe how the partners in each local workforce area will address the regional priorities and strategies. The MOUs further refine this planning by specifically describing how the required partners agree to provide services and fund the one-stops. Local boards will want to ensure that their local implementation plan and MOUs include investments in activities that support the regional plan. We are looking for alignment between the regional plan, local plan and MOU.
If we need to make changes to our WIOA Regional and Local plans after they are out for public comment, do the plans need to be posted a second time for public comment?

No. There is no requirement for second public comment period.
Should all of the core partners’ program-specific plans be submitted within the Local Plan?

Core partner programs are required by their authorizing statute to complete program-specific plans, which are different than the WIOA-required Local Plans. Per WIOA, local boards and partners must jointly develop the Local Plan. The WIOA Local Plan is intended to incorporate information about how all of the required partners under WIOA will provide services and how those services will be coordinated and integrated. Local Plans should be developed in close consultation to the “Regional and Local Planning Process Guide,” which will serve as the basis against which Local Plans are assessed for state approval.
What is meant by “Local Plans?”

WIOA-required Local Plans apply to all required partners under WIOA in the local area. Detailed requirements for Local Plans can be found in final regulation (§ 6769.550, § 679.560, § 679.570)). Instructions for Local Plans have been provided in the “Regional and Local Planning Process Guide”. There is one WIOA Local Plan in each LWIA. This one WIOA plan should include information on all required partner programs and how they will be integrated and aligned to provide services in the area.

WIOA (Workforce Innovation and Opportunity Act)

Can a client be enrolled in ITA training for 18 months or more than get a degree or credential and never get a job?

If a participant doesn’t obtain a positive outcome as described in the respective policy chapters for a particular performance measure indicator, then the participant doesn’t meet the indicator and has a negative outcome for that indicator. The goal for all career planners is to provide appropriate services and career planning that assist the participant in achieving the goals set in their IEP (i.e., employment, credential).
Can WIOA pay the out-of-district fees, for adults and dislocated workers, at a community college?

The Workforce Innovation and Opportunity Act (WIOA) indicates that training services for adults and dislocated workers must be directly linked to an in-demand industry sector or occupation in the local area or planning region, or in another area in which an adult or dislocated worker receiving services is willing to relocate.

An ITA is one available training option and must lead to a recognized postsecondary credential as defined by WIOA and result in employment leading to economic self-sufficiency or wages comparable to or higher than wages from previous employment. ITA expenditures are costs required by the training institution to complete the training. ITA costs required to complete the training may include but are not limited to: Tuition and fees; Books; Tools; Uniforms; Tests; and medical immunizations/tests. The ITA is limited in cost and duration by the Local Workforce Innovation Board’s (LWIB) local training policy.

The ITA is established on behalf of the participant who has worked with a career planner to select the most suitable training programs from the Eligible Training Provider List (ETPL). The ETPL is comprised of entities determined eligible to receive WIOA Title IB funds according to the Governor’s eligibility criteria and procedure outlined in the Eligibility of Training Providers and Programs section of the policy manual.

The selection of training services should be conducted in a manner that maximizes customer choice, is linked to in-demand occupations on the current Demand Occupation Training List (DOTL), is informed by the performance of relevant training providers, and is coordinated to the extent possible with other sources of assistance, including federal Pell Grants.
What is the WIOA policy for how long a client should be enrolled in an ITA training course in order to get employed in a job?

Training services can contribute to the employment success of many adults and dislocated workers. Under the Workforce Innovation and Opportunity Act (WIOA) these training services may be made available to employed and unemployed adults and dislocated workers who meet the appropriate eligibility requirements. Training services include the full range of occupational skills training, adult education and literacy services, and customized training.

Career Planners may determine whether training services are appropriate, regardless of whether the individual first received career services. The career planner must document in the Individual Employment Plan (IEP) the reasons for the training after a thorough comprehensive assessment (interview, evaluation, and formal assessments) with a participant, it is determined the individual needs training to obtain or retain employment that leads to self-sufficiency or higher wages.

Training funded through an Individual Training Account (ITA) is required to be from an appropriate program of training services from the state’s Eligible Training Provider List (ETPL) that is linked to the employment opportunities in the local area or the planning region, or in another area to which the individual is willing to commute or relocate. The selection of training services should be conducted in a manner that maximizes consumer choice, is linked to in-demand occupations on the current Demand Occupation Training List (DOTL), is informed by the performance of relevant training providers, and is coordinated to the extent possible with other sources of assistance, including federal Pell Grants.

The duration of an ITA is determined by a participant’s course of study. Realistic and attainable training plans must be considered. Training is either short-term or long-term. Short-term training is the preferred method since the goal is to attain employment quickly. However, the local areas must keep in mind the participant's career pathway, and the training and services necessary to meet the participant's goal.

Local Workforce Innovation Boards (LWIBs) are required to establish local policies regarding training limits, duration, and other related requirements for ITAs.

Under WIOA, there are five performance measure indicators for each program, Adult, Dislocated Worker, and Youth – Employment Rate 2nd Quarter After Exit (see policy 3.1.1), Employment Rate 4th Quarter After Exit (see policy 3.1.2), Median Earnings 2nd Quarter After Exit (see policy 3.1.3), Credential Attainment (see policy 3.1.4), and Measurable Skill Gains (see policy 3.1.5). Any WIOA participant receiving training services through an ITA (regardless of the length or completion status (successful or unsuccessful) of their training) will be included in the denominator of the Credential Attainment Rate (Credential) and the Measurable Skill Gains (MSG) performance measure indicators. All WIOA participants will be included in the denominator for Employment Rate 2nd and 4th Quarter Post Exit. All registrants employed in the 2nd Quarter Post Exit will be included in the denominator of the Median Earnings measure.
What is WIOA?
Public Law 113-128, the Workforce Innovation and Opportunity Act (WIOA), will replace the Workforce Investment Act (WIA) of 1998 to authorize the federal workforce programs in 2015.

The WIOA will modernize the nation’s workforce system and emphasizes the demand-driven approach that Illinois has developed over the past several years. The Illinois Department of Commerce and Economic Opportunity will coordinate with state and local workforce and economic development partners to implement the requirements associated with the implementation of WIOA.

WIOA requires the strategic coordination of four core programs:
1. Employment and training services for adults, dislocated workers and youth,
2. Wagner-Peyser employment services,
3. Adult education and literacy programs, and
4. Vocational Rehabilitation programs serving individuals with disabilities in obtaining employment.
Where can I find more information?

The WIOA Implementation Portal is a resource with up-to-date information about the workforce system innovations in Illinois and the impact of those workforce innovations on our state.

The WIOA Resources page also provides material from the State and Federal workforce agencies.

The U.S. DOL’s website for the Workforce Innovation and Opportunity Act offers many related guidelines and technical assistance tools.

The WIOA Public Law is here.

WIOA Frequently Asked Questions // <![CDATA[ _spBodyOnLoadFunctionNames.push("setupPageDescriptionCallout"); // ]]>

WIOA Frequently Asked Questions

Audience

Subjects

2020 COVID-19

MOU - Affiliate Sites

MOU - Annual Budget (Infrastructure Funding Agreement)

MOU - Budget Reconciliation

MOU - Data Sharing

MOU - Direct Linkage

MOU - FTEs

MOU - Infrastructure Costs

MOU - Local Service Matrix

MOU - One-Stop Delivery System

MOU - One-Stop Operator

MOU - Program Specific

MOU - Suggested Improvements

MOU - Waiver Requests

MOU Development

Regional and Local Plans

WIOA (Workforce Innovation and Opportunity Act)

WIOA Frequently Asked Questions