May a client receive supportive services while enrolled in on-the-job training (OJT) and earning an income?
Answer: There are no federal or state prohibitions specific to providing supportive services to OJT clients; however, Section 663.810 of Title 20 of the Code of Federal Regulations allows local areas directly, or through their One-Stop operators, to establish limits on the provision of supportive services. If your Local Workforce Investment Board has not established any such policy and has not authorized its One-Stop operators to do so, then you have only to ensure that the supportive services meet the federal guidelines in the WIA and its regulations.
Can supportive services be provided retroactively? We have a client who did not request supportive services and declined them at initial completion of an individual employment plan; then, three months into the training, the client requested reimbursement for mileage costs. Is such reimbursement allowable under WIA?
Answer: The use of WIA funds for supportive services is allowable only if those services are necessary for the individual to participate in WIA Title I activities, and the individual is unable to obtain those supportive services through other programs (Title 20 Code of Federal Regulations (20CFR) 663.805). To document those two conditions retroactively would be very difficult.
Most likely, such attempt would lead to questioned costs.
An example would be that if an individual has been participating in WIA Title I activities to date without those supportive services, then it would be difficult to argue that those supportive services were necessary for the client to participate in WIA activities.
Also, to document the lack of alternative funding sources for a period of time that has passed, would be difficult in some cases and impossible in others.
Consideration should also be given to the concern that Local Workforce Investment Boards may establish their own limits on the provision of supportive services; so, in some cases, retroactive supportive services may be unallowable in your local area (20 CFR 663.810).
To take that question further, if the client is in danger of dropping out of WIA-funded activities, perhaps consideration should be given to addressing the new need created by the lack of prior support services to the client.
In conclusion, if the individual no longer needs those supportive services but is requesting reimbursement to compensate for a passed opportunity, the only other alternative would be to use non-WIA funds.
Do WIA performance measures apply when WIA grant funding is used in combination with other funding, such as TANF, or ARRA?
Answer: If WIA formula funds are used in any combination with other funding, such as TANF or ARRA, all WIA performance measures will apply.
For which services may Individual Training Accounts (ITA), be used?
Answer: The ITAs may be used to obtain training services listed on the State's Eligible Training Provider List (ETPL). All training must be directly linked to employment opportunities either in the local area or in an area to which the individual is willing to relocate. An occupation is considered an employment opportunity for a local area if it appears on the Projected Employment Opportunities List for the State or local area. Some examples include: occupational skills training, including training for nontraditional employment, on-the-job training, programs that combine workplace with related training, which may include cooperative education programs, retraining and skill upgrading, entrepreneurial training, and customized training.