Q&A – WIOA Youth Services

Questions and Answers

 

1. How are you defining "low-income" and "lacking basic skills" in regards to youths' eligibility?

The definition of “low income” and “lacking basic skills” in regards to youths’ eligibility is defined by policy governing this program. 

WIOA Youth providers are expected to follow Procedure: Low-income and Self-sufficiency Guidelines 2020c which is updated annually when the federal Lower Living Standard Income Level (LSIL) Guidelines are released.

Workforce Snohomish allows for the use of the Title I Youth Low-Income Exception of up to five percent of newly enrolled Youth participants in a program year who would ordinarily be required to meet low-income requirements, but do not, still enroll if they meet all other eligibility requirements as outlined in the Eligibility, Registration and Enrollment Policy 2020.

Additional references:

Per 20 CFR 681.290, a youth is “basic skills deficient” if he or she:

  1. Have English reading, writing, or computing skills at or below the 8th grade level on a generally accepted standardized test; or
  2. Are unable to compute or solve problems, or read, write, or speak English at a level necessary to function on the job, in the individual's family, or in society.
    1. The State or Local WDB must establish its policy on paragraph (a)(2) of this section in its respective State or local plan.
    2. 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.

Per state Policy 1011 CASAS for Basic Skills Deficiency, CASAS Reading Goals, Life and Work Listening (forms 981-986), CASAS Math Goals and CASAS Appraisal (form 900) are used to determine Basic Skills Deficiency. Currently, WorkSource Information Notice 0107, Change 11 provides a temporary suspension of this policy through June 2025 and allows for the use of a transcript with a failing grade in math or reading during the most recent academic year or school records showing test scores from a generally accepted standardized test within the last year showing grade level below 9th grade in addition to the CASAS assessment.

All referenced policies should be reviewed in their entirety for full explanations of eligibility criteria.

2. For out-of-school youth meeting eligibility through being a" low-income individual who requires additional assistance to enter or complete an educational program or to secure or hold employment", should this refer to being unable to secure any kind of employment, or specifically the types of jobs and careers the bidders' program is focused on? (For example, our program includes helping local youth meet the eligibility to pursue entry level forestry technician positions they would otherwise not be qualified for.)

Likewise, if they are interested in pursuing higher education in a particular field and feel they should gain some relevant jobs skills and work experience to ensure admission to a program, would they be considered an eligible youth for this funding as long as they were also low income?

“Requires additional assistance” is defined for both out-of-school youth and in-school youth at the local level. The current local definitions are located in Eligibility, Registration and Enrollment Policy 2020. This policy addresses many of the proposed questions. If there are additional questions that result from a review of this information, please follow-up with additional questions.

For the second part of your question, each potential participant is subject to eligibility determination as you have indicated above. In addition, each participant is required to have choices in developing their “individual service strategy,” that supports their education/training and/or employment goals. Secondly, matriculation to post-secondary education or entered employment are both outcomes of the WIOA Youth program.  The RFP states, “Individual Service Strategy (ISS)/Employment Plan: The subrecipient must use the results of the Youth’s objective assessment to develop the ISS with the participant. The ISS is an age appropriate, individualized, documented plan with short- and long-term goals that include career pathways, education and employment goals, involvement in WIOA Title I youth program elements, supportive services, and incentives, as applicable.”

3. What are eligible costs for funds? Are equipment purchases acceptable?

Allowable costs are detailed in local Workforce Snohomish Allowable Costs and Prior Approval Policy 1000. Equipment purchases do require prior written approval. Note that equipment is defined by 2 CFR 200 (https://www.ecfr.gov/current/title-2/part-200#p-200.1(Equipment) as “something that costs $10,000 or more and has a usable lifespan of more than 1 year.”

4. Would it be acceptable to use a portion of these funds to finalize the development of our current program into a pre-apprenticeship or even Registered Apprenticeship Program? (Ie, would activities related to further development and capacity building of the program to help it meet the formal definition for a pre-apprenticeship or apprenticeship program be an acceptable use of WOIA funds?)

  1. For context on the last question, our organization ran a workforce development program last year that met all requirements of a pre-apprenticeship program, with the exception that we did not have a formal relationship to a RAP. A challenge we ran into is that our program is focused on outdoor career exploration and skill development related to natural resource and forestry jobs and there are currently no pre-apprenticeship programs or RAPs for those fields (the closest so far seems to be programs for arborists, landscaping, and firefighting). This both limits logical next steps for our graduating youth who don't want to pursue college (though many did go that route) but is also a gap and need identified by other stakeholders and employers. We have already begun formal curriculum development for what could ultimately be a pre-apprenticeship or registered apprenticeship program in forestry and natural resources but could use more capacity/funding to complete it, as well as the opportunity to pilot it. We still want to use these funds to continue our program as a paid job learning and career exploration opportunity for local rural youth, but with an eye towards developing a more robust program that fills a major gap for job training and pathways in those fields.

All expenditures must follow the Workforce Snohomish Allowable Costs and Prior Approval Policy 1000. These funds will be used to deliver the WIOA Youth project in Snohomish County to provide the 14 elements of WIOA Youth Services as outlined in the finalized subaward agreement for Program Year 2025. Funds are used to support participant costs, staff time and case management costs associated with the direct needs of the eligible youth enrolled in the program.

5. Finally, let me know if the bidder's conference will be recorded and if I should go ahead and register even though I can't make it.

If you cannot attend the webinar, it will be posted to the Workforce Snohomish website. You do not need to register if you cannot make it to the live bidder’s conference.

6. How do you define "disabled" in terms of WOIA Youth Services' eligibility requirements?

Per WIOA Section 3(25), WIOA programs use Section 3 of the Americans with Disabilities Act of 1990 (42 U.S.C. 12102), to define an “individual with a disability".

7. And is self-attestation sufficient for ensuring an individual's program eligibility?

Data validation is a crucial component of determining eligibility for WIOA Youth services. As outlined in TEGL 23-19 Change 1 and TEGL 09-22, while other documentation sources are preferred when practical, self-attestation is an important option for populations with barriers to obtaining eligibility and reporting documents, including disconnected youth. The use of self-attestation is allowable for determining eligibility to not delay or prevent enrollment and receipt of services from the program. Allowable documentation for all WIOA Youth ISY and OSY eligibility elements is provided in the Eligibility Policy Handbook from Washington State WorkSource System Policy 1019 Revision 11. Self-attestation is not permitted for documenting eligibility under “basic skills deficient” or for proof of selective service registration for those individuals who are required to register for selective service.

As clarified in Attachment II - Source Documentation for WIOA Core/Non-Core Programs (PDF Version) of  TEGL 23-19, Change 2, self-attestation means a written, or electronic/digital declaration of information for a particular data element, signed and dated by the participant. DOL broadly interprets what is considered an electronic/digital signature. Electronic signatures or a submission from the participant such as an email, text, or unique online survey response is considered an electronic signature or verification; it must be participant generated and traceable to the participant. Grantees must retain documentation of the self-attestation. 

Additional References:

Washington State WorkSource System Policy 1003 Revision 6 Data Element Validation

Workforce Snohomish Policy 2020 Eligibility, Registration and Enrollment