WORKFORCE IMPLEMENTATION GUIDANCE (WIG) LETTER. 1. Purpose. To provide guidance for incentive payments to WIOA youth participants.

Transcription

1 WORKFORCE IMPLEMENTATION GUIDANCE (WIG) LETTER DATE: January 29, 2018 NO: TO: FROM: SUBJECT: WIG PS LOCAL WORKFORCE SYSTEM STAKEHOLDERS MENELIK ALLEYNE, WIOA SERVICES DIRECTOR YOUTH INCENTIVES 1. Purpose. To provide guidance for incentive payments to WIOA youth participants. 2. References. 20 CFR ; TEGL 8-15; TEGL Definitions. WIOA Workforce Innovation and Opportunity Act TEGL Training and Employment Guidance Letter LWDA Local Workforce Development Area ISS Individual Service Strategy LWDB Local Workforce Development Board 4. Background. WIOA Regulations state that incentive payments to WIOA youth participants are permitted for recognition and achievement directly tied to training activities and work experiences. LWDBs must have written policies and procedures in place governing the award of incentives and must ensure that such incentive payments are: a) Tied to the goals of the specific program; b) Outlined in writing before the commencement of the program that may provide incentive payments; c) Align with the local program's organizational policies; and d) Are in accordance with the requirements contained in 2 CFR part 200 Eligibility to Receive Incentive Payments WIOA Youth Participants that have successfully achieved a pre-determined milestone that is directly tied to education and training activities or work experiences are eligible to receive an incentive payment. This incentive payment must be tied to a work experience or education and training activity that is reflected in the participant s individual services strategy (ISS). The participant must be active in a WIOA youth program or follow-up activity. 1

2 5. Administration of Youth Incentive Payments. Awarding Criteria to Receive Incentive Payments: The following are some, but not all, recognized criteria for incentive payments: 1. Attainment of a Degree or Certificate; a. The participant must have earned a diploma or certificate that they did not possess prior to enrollment. 2. Measurable Skills Gain (as defined by the LWDB) 3. Employment and Retention a. The participant must obtain full-time unsubsidized employment in the targeted occupation/industry in the participant s ISS. LWDB should also consider participant s employment retention with the same occupation/industry in their local policy on youth incentives. 4. Completion of a WIOA youth program a. The participant must complete a training activity or work-based education program. LWDB must consider a specific limit to the amount of funds awarded to a participant in the form of youth incentives for completion of WIOA youth programs. Incentive Amounts and Maximums: LWDBs are encouraged to set Incentive amount maximum awards and to limit the number of incentive payments per youth. Youth Incentives as Allowable Expenditures: TEGL No provides discussion of allowable expenditures that may be counted toward the work experience expenditure requirement and articulates that program expenditures on the work experience program element can be more than just wages paid to youth in work experience. Allowable work experience expenditures may include incentive payments directly tied to the completion of work experience. For youth participants, work experience, GED and follow-up services are classified as Career Services and incentive expenditures for these activities would follow the activity. Incentive expenditures for participants in training would be classified as training expenditures. Documenting Incentive Payments: All incentive payments with supporting documentation for the achievement must be fully documented in the participant s case file or the Georgia Work Ready Online Participant Portal or other LWDA participant file management system (such as TrackSource). Youth Incentive amounts are to be recorded in Activity Code 484. The code will be open for input after the participant is recorded in youth services activities. Unallowable Incentive Payments: As stated in TEGL 21-16, all incentive payments paid with WIOA funds must be in compliance with outlined Cost Principles in 2 CFR part 200. This TEGL emphasizes that

3 incentives must not include entertainment, such as movie or sporting event tickets or gift cards to movie theaters or other venues whose sole purpose is entertainment. Additionally, the following are other unallowable uses of WIOA funds for incentive payments: 1. Recruitment or referrals; 2. Rewards for submitting eligibility documentation; 3. Possession of a credential attained prior to enrollment; and 4. Regular attendance or participation in a WIOA program where payment is to sustain participant s ongoing attendance or participation. Use of non-wioa funds as Incentives TEGL permits LWDAs to leverage private funds for incentives that WIOA cannot fund. LWDAs must adhere to and maintain documentation in accordance to 2 CFR 200 Cost Principles and other related federal and state regulatory requirements when leveraging such funds, which are subject to federal and state monitoring review. 6. Action Requested. WFD requires that LWDAs review their local policies and procedures in order to ensure compliance with federal regulations and guidance on youth incentive payments. Additionally, LWDAs are encouraged to design a comprehensive youth incentives policy and incorporate this policy guidance into their local policy. 7. Inquiries. Inquiries regarding this guidance should be directed to the designated programmatic technical assistance representative. 8. Expiration. Continuing 9. Attachments. Federal Regulations and Guidance Letter clarifying the use of Incentive Payments for WIOA youth participants.

4 Attachment 1: WIOA Federal Regulations related to Incentive Payments 20 CFR Are incentive payments to youth participants permitted? Yes, incentive payments to youth participants are permitted for recognition and achievement directly tied to training activities and work experiences. The local program must have written policies and procedures in place governing the award of incentives and must ensure that such incentive payments are: a) Tied to the goals of the specific program; b) Outlined in writing before the commencement of the program that may provide incentive payments; c) Align with the local program's organizational policies; and d) Are in accordance with the requirements contained in 2 CFR part 200. Commentary : Section Are incentive payments to youth participants permitted? This section clarifies that incentives under the WIOA youth program are permitted. The Department has included the reference to the Uniform Guidance at 2 CFR part 200 to emphasize that while incentive payments are allowable under WIOA, the incentives must be in compliance with the requirements in 2 CFR part 200. For example, Federal funds may not be spent on entertainment costs. Therefore, incentives may not include entertainment, such as movie or sporting event tickets or gift cards to movie theaters or other venues whose sole purpose is entertainment. Additionally, there are requirements related to internal controls to safeguard cash, which also apply to safeguarding of gift cards, which are essentially cash. Department Response to Comments: While the Department recognizes the importance of incentives as motivators for various activities such as recruitment, submitting eligibility documentation, and participation in the program, the Department concluded that incentives must be connected to recognition of achievement of milestones in the program tied to work experience or training. Such incentives for achievement could include improvements marked by testing or other successful outcomes. While WIOA funds cannot be used for incentives for recruitment and eligibility documentation, local areas may leverage private funds for such incentives.

5 Attachment 2: TEGL (p. 9-10), Excerpt related to Incentive Payments Incentives 20 CFR states that incentive payments to youth participants are permitted for recognition and achievement directly tied to training activities and work experiences. The local program must have written policies and procedures in place governing the award of incentives and must ensure that such incentive payments are tied to the goals of the specific program; outlined in writing before the commencement of the program that may provide incentive payments; align with the local program s organizational policies; and are in accordance with the requirements contained in 2 CFR part 200. DOL included the reference to the Uniform Guidance at 2 CFR part 200 to emphasize that while incentive payments are allowable under WIOA, the incentives must be in compliance with the Cost Principles in 2 CFR part 200. For example, Federal funds must not be spent on entertainment costs. Therefore, incentives must not include entertainment, such as movie or sporting event tickets or gift cards to movie theaters or other venues whose sole purpose is entertainment. Additionally, there are requirements related to internal controls to safeguard cash, which also apply to safeguarding of gift cards, which are essentially cash. While DOL recognizes that incentives could be used as motivators for various activities such as recruitment, submitting eligibility documentation, and participation in the program, incentives paid for with WIOA funds must be connected to recognition of achievement of milestones in the program tied to work experience, education, or training. Such incentives for achievement could include improvements marked by acquisition of a credential or other successful outcomes. Local areas may leverage private funds for incentives that WIOA cannot fund. Incentive payments may be provided to both ISY and OSY as long as they comply with the requirements of 20 CFR