CLASP: Tough Questions for WIOA Realignment

President Obama signing WIOA into law

President Obama signing WIOA into law

As states update the plans for workforce training program under the new Workforce Innovation and Opportunity Act (WIOA), advocates should ask state planners whether their reorganized WIOA programs are really prepared to help underserved youth and adults.

A new Center for Law and Social Policy (CLASP) report suggests that community activists ask tough questions when reviewing state plans. These questions will act as a template to help strengthen the implementation of key provisions of WIOA that can improve economic and career success for low-income youth, CLASP said.

The Education and Labor Dept’s are publishing proposed regulations to implement provisions of WIOA, enacted July 22, 2014. DOL programs impacted include: Wagner-Peyser Act/employment services and Job Corps. For example, WIOA restructures Job Corps (CFDA Number: 17.259) to ensure career and technical education and training is geared toward in-demand occupations and disadvantaged youth (such as out-of-school youth) receive a regular high school diploma or a recognized postsecondary credential.

CLASP suggested that advocates focus on whether co-enrollment encouraged for specific populations and specific service models? This would include WIOA Title I Youth and WIOA Title II Adult Education & Literacy; WIOA Title I Adult and WIOA Title II Adult Education & Literacy; and WIOA Title I Youth and WIOA Title IV Vocational Rehabilitation? Also, how does the state plan describe the coordination, alignment, and non-duplication of core WIOA services with employment and training activities provided through human services programs (such as TANF and SNAP)? How does the draft state plan describe the coordination, alignment, and non-duplication of core youth WIOA services with employment and training activities provided under other employment programs, the group said.

Questions on Youth Eligibility and Planning:

  • Does the draft state plan require local workforce development boards to create standing youth committees? If so, who are the required members?
  • Does the draft state plan reference how the state and/or local board will facilitate co-enrollment of youth participants across core programs, in particular for youth ages 18-24 who can be served through titles I, II, and IV?
  • Does the draft state plan outline implementation of specific provisions related to career pathways—such as the requirement that local areas use youth funds to conduct an objective assessment “for the purpose of identifying appropriate services and career pathways for participants?”
  • Does the draft state plan address how the procurement processes and requests for proposals will be adapted and aligned across the core programs to encourage longer-term and more intensive services for out-of-school youth?
  • Does the draft state plan include or address eligibility policies beyond what is required from the DOL? For example, is self-attestation acceptable for upfront eligibility determination for out-of-school youth in high-risk categories (e.g., those who are pregnant or parenting, subject to the juvenile or adult justice system, homeless and/or runaway, or youth without a secondary credential)?
  • Do the required definitions of “attending school” and “not attending school” limit access to WIOA services for out-of-school youth who are in high-risk categories but may be enrolled in an education service or intervention?

Finally, does the required definition of “basic skills deficient” utilize criteria that encourage services to youth who have low basic skills, lack a secondary credential, or are limited English Skills proficient, the group said.


About Frank Klimko

Frank Klimko is a nationally known journalist, grants expert and speech writer/speaker. He has years of experience helping nonprofits devise lists of the right funding opportunities and secure funding from these foundations and corporate entities. Clients have focused on an array of areas including child care, homeless, hunger and K-12 education. Additionally, he is a Freedom of Information Act expert, who has helped numerous clients with securing proprietary information from the federal government. Currently, Frank Klimko writes the Children & Youth Funding Report and Private Grants Alert, which are Washington DC-based publications. CYF is a daily publication covering Congress, the Education Dept. and the various federal regulatory agencies. PGA, another daily publication, covers the world of private philanthropy.
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