Construction Plus training in YouthBuild

CLASSIFICATION
   EMPLOYMENT AND TRAINING ADMINISTRATION                 YouthBuild
               ADVISORY SYSTEM                            CORRESPONDENCE SYMBOL
          U.S. DEPARTMENT OF LABOR                        OWI-DYS
             Washington, D.C. 20210                       DATE
                                                          August 17, 2017


ADVISORY:       TRAINING AND EMPLOYMENT GUIDANCE LETTER NO. 07-14,
                Change 1

TO:             STATE WORKFORCE AGENCIES
                STATE WORKFORCE LIAISONS
                ALL YOUTHBUILD GRANTEES

FROM:           ROSEMARY LAHASKY /s/
                Deputy Assistant Secretary

SUBJECT:        Updated Guidance for Implementing the Construction Plus Component of the
                YouthBuild Program, as authorized by the Workforce Innovation and
                Opportunity Act (WIOA)

1. Purpose. To provide further guidance for YouthBuild grantees implementing the
   Construction Plus component of the YouthBuild program, including a synopsis of what it
   entails, and to provide further clarity to workforce partners about the Construction Plus
   model.

2. References.
    Workforce Innovation and Opportunity Act (WIOA), Pub. L. 113-128,
      https://www.gpo.gov/fdsys/pkg/PLAW-113publ128/pdf/PLAW-113publ128.pdf;
    WIOA Regulations at 20 CFR Part 681 and 688,https://www.gpo.gov/fdsys/pkg/FR-
      2016-08-19/pdf/2016-15975.pdf;
    Training and Employment Guidance Letter (TEGL) No. 15-10, “Increasing Credential,
      Degree, and Certificate Attainment by Participants of the Public Workforce System,”
      http://wdr.doleta.gov/directives/corr_doc.cfm?DOCN=2967;
    TEGL 10-16, Change 1, “Performance Accountability Guidance for Workforce
      Innovation and Opportunity Act (WIOA) Title I, Title II, Title III, and Title IV Core
      Programs,” https://wdr.doleta.gov/directives/corr_doc.cfm?DOCN=3255;
    CareerOneStop Toolkit, https://www.careeronestop.org/Toolkit/toolkit.aspx;
    CareerOneStop Credentials Center, https://www.careeronestop.org/credentials/; and
    Labor Market Information Central, https://lmi.workforcegps.org/.

3. Background. YouthBuild is a workforce development program that provides employment,
   education, pre-apprenticeship and apprenticeship opportunities, and leadership development
   training to disconnected youth between the ages of 16 and 24 who are high school dropouts.
   Those eligible may be a member of a low-income family, a foster care youth, an offender, a
   youth with a disability, a child of an incarcerated parent, or a migrant youth. The Workforce
   Innovation and Opportunity Act of 2014 (WIOA) reauthorized the YouthBuild program in
 RESCISSIONS                                              EXPIRATION DATE
 None                                                     Continuing

   the U.S. Department of Labor (DOL). WIOA authorizes grants for job training and
   educational activities for YouthBuild participants who, as part of their training, help build or
   rehabilitate housing for low-income or homeless individuals and families in their respective
   communities.

   In the YouthBuild Final WIOA regulations, published as part 688 of the WIOA Final Rule on
   August 19, 2016, at 20 CFR part 688, DOL expanded the occupational skills training
   component of the YouthBuild program from solely construction skills training to include
   skills training in other in-demand jobs toward the goal of economic self-sufficiency. This
   guidance refers to these additional training industries as Construction Plus industries.

4. What is Construction Plus? Construction Plus refers to the inclusion of occupational skills
   training opportunities for YouthBuild participants in in-demand occupations other than
   construction. All DOL-funded YouthBuild programs are required to offer construction skills
   training to program participants. Whether Construction Plus training is provided
   consecutively or in tandem, the required training time of educational skills (50 percent of the
   time) and occupational skills (40 percent of the time) for each participant must be
   maintained, as identified in the Final Rule. Further, the participation timeframe must not
   exceed 24 months, regardless of the participant’s occupational skills training track, and must
   allow for a follow-up period of 12 months, as identified in the Final Rule.

   In the DOL WIOA Final Rule at 20 CFR 688.120, YouthBuild programs funded by DOL are
   recognized as pre-apprenticeship programs. Grantees are expected to develop Construction
   Plus program models that align with pre-apprenticeship as described in part 681.480 of the
   Final Rule:

   A pre-apprenticeship is a program designed to prepare individuals to enter and succeed in an
   apprenticeship program registered under the Act of August 16, 1937 (commonly known as
   the “National Apprenticeship Act”; 50 Stat.664, chapter 663; 29 U.S.C. 50 et seq.) (referred
   to in this part as a “registered apprenticeship” or “registered apprenticeship program”) and
   includes the following elements:

        1) Training and curriculum that aligns with the skill needs of employers in the economy
           of the State or region involved;
        2) Access to educational and career counseling and other supportive services, directly
           or indirectly;
        3) Hands-on, meaningful learning activities that are connected to education and training
           activities, such as exploring career options, and understanding how the skills
           acquired through coursework can be applied toward a future career;
        4) Opportunities to attain at least one industry-recognized credential; and
        5) A partnership with one or more registered apprenticeship programs that assists in
           placing individuals who complete the pre-apprenticeship program in a registered
           apprenticeship program.

   DOL expects grantees to develop the connection points described above and relationships
   and pathways that lead to employment and placements in apprenticeships. This expectation

   applies to both the traditional YouthBuild model with construction skills training and the
   occupational skills training expanded under Construction Plus.

   Some YouthBuild programs have strong partnerships and refer participants after exit to
   training partners who provide ongoing training. However, this is not Construction Plus and
   is instead a placement outcome. The goal of the Construction Plus model is to allow
   YouthBuild programs to build the capacity to provide training in in-demand industries for
   participants who are not interested in pursuing a construction career or in local areas where
   construction may not be as much of a growth industry as other fields. In order to be
   considered a Construction Plus program, YouthBuild grantees must be providing additional
   industry training, either directly or through a contract, in which DOL grant funds are also
   supporting some part of the additional training, such as the payment of stipends or subsidized
   wages during the required Construction Plus work experience or through payment to the
   training providers or staff. As with the construction training, the Construction Plus
   component focuses on attainment of industry-recognized certifications.

   Construction Plus grantees must have demonstrated in their statements of work, through the
   use of local labor market data, that the proposed additional occupational skills trainings will
   lead to or prepare participants for employment in high-demand or locally in-demand jobs.
   Programs that propose to provide additional certifications that do not rise to the level of
   industry-recognized credentials described in Section 7 below, such as CPR or ServSafe, are
   not providing a Construction Plus component and cannot count those credentials as
   participant outcomes. Programs that are proposing to do specialized construction industry
   training, such as weatherization, solar paneling, and green building are also not doing
   Construction Plus, as these are still considered to be part of the construction industry and are
   therefore a component of the traditional YouthBuild program model.

5. Labor Market Information Resources. DOL has many labor market information resources
   available to grantees for assistance in identifying appropriate Construction Plus industries
   within their local communities; the CareerOneStop Toolkit Web page includes links to State
   Information pages
   (https://www.careerinfonet.org/select_state.asp?from=&next=lmi1&id=11&nodeid=13&socc
   ode=) which provide State resources on local labor market information. Additionally,
   grantees must use comprehensive curricula that, upon completion, lead to the attainment of
   industry-recognized credentials for program participants. The Labor Market Information
   Central Collection on WorkforceGPS (https://lmi.workforcegps.org/) provides valuable
   information on additional data sources useful for determining in-demand occupations and
   skills. Information on related credentials such as industry-recognized certifications and
   required State occupational licenses are available through the CareerOneStop Credentials
   Center (http://www.careeronestop.org/credentials/). This information helps in developing the
   required curricula and credentialing pathways.

6. Implementing Construction Plus in Your YouthBuild Program. YouthBuild grantees
   offering approved Construction Plus training must provide the same level of opportunity and
   benefit to Construction Plus participants that are available to participants in the core
   construction training. As with the core construction training, Construction Plus programs

   must offer participants eligible education activities during at least 50 percent of the time and
   eligible workforce investment activities during at least 40 percent of the time during which
   they participate in the program. Up to ten percent of the time of participation may be used
   for leadership development and community service activities.

   Like the core construction training, Construction Plus training must balance project-based
   learning and occupational skills training that prepare disconnected youth to gain placement
   into career pathways and/or further education or training. Construction Plus training must
   not be limited to classroom learning and must incorporate hands-on training similar to that
   offered in the core construction training. Additionally, Construction Plus must incorporate
   community service, youth leadership development, and work experience opportunities like
   those required in the core construction training.

   Grantees have flexibility in determining how the program model includes Construction Plus
   industries. However, they are required to enroll a sufficient number of participants in the
   construction skills training component to build or renovate at least one unit of affordable
   housing for low-income individuals and families or transitional housing for homeless
   individuals during the grant period of performance. Youth may be divided between
   construction training and Construction Plus industry(ies) training, based on assessments of
   interest and skills match or all youth may first be placed in construction training for
   development of broadly-applicable professional skills, including soft skills (teamwork,
   leadership, communication) and hard skills (math, reading comprehension) before being
   further trained in the chosen Construction Plus industry. The grant period of performance
   and budget should be considered in designing the program model for the addition of
   Construction Plus.

   All program performance measures are the same for the Construction Plus training(s). In
   particular, grantees should take into consideration the eligibility of YouthBuild participants
   for industry-recognized credentials and placement opportunities in selected Construction Plus
   field(s) (see Attachment, “Considerations Guide for Credential Attainment for US
   Department of Labor (DOL) YouthBuild Grantees,” for additional information).

7. What is an Industry-Recognized Credential? Within the workforce system, the term
   credential refers to the attestation of qualification or competence issued to an individual by a
   third party with the relevant authority or competence to issue such a credential. There are
   many different types of industry-recognized credentials offered or awarded by various types
   of third-party organizations, such as an educational institution or an industry- or
   occupational-certifying organization. You can find more information on credentials in TEGL
   10-16, Change 1 (https://wdr.doleta.gov/directives/corr_doc.cfm?DOCN=3255) and in TEGL
   15-10 (http://wdr.doleta.gov/directives/corr_doc.cfm?docn=2967).

   For the purposes of credential attainment, WIOA distinguishes between a secondary school
   diploma (or its recognized equivalent) and postsecondary credentials. A recognized
   postsecondary credential is defined in TEGL 10-16, Change 1, as a credential consisting of
   an industry-recognized certificate or certification, a certificate of completion of an
   apprenticeship, a license recognized by the State involved or Federal government, or an

associate or baccalaureate degree, as well as graduate degrees for purposes of the Vocational
Rehabilitation program as required by section 103(a)(5) of the Rehabilitation Act of 1973, as
amended by title IV of WIOA.

A recognized postsecondary credential is awarded in recognition of an individual’s
attainment of measurable technical or industry/occupational skills necessary to obtain
employment or advance within an industry/occupation. These technical or
industry/occupational skills generally are based on standards developed or endorsed by
employers or industry associations. Neither certificates awarded by workforce development
boards (WDBs), nor work readiness certificates, are included in this definition because
neither type of certificate documents the measurable technical or industry/occupational skills
necessary to gain employment or advance within an occupation. Likewise, such certificates
must recognize technology or industry/occupational skills for the specific
industry/occupation rather than general skills related to safety, hygiene, etc., even if such
general skills certificates are broadly required to qualify for entry-level employment or
advancement in employment.

A variety of different public and private entities issue recognized postsecondary credentials.
Below is a list of the types of organizations and institutions that award recognized
postsecondary credentials (not all credentials by these entities meet the definition of
recognized postsecondary credential):
     A State educational agency or a State agency responsible for administering vocational
       and technical education within a State;
     An institution of higher education described in Section 102 of the Higher Education
       Act (20 USC 1002) that is qualified to participate in the student financial assistance
       programs authorized by title IV of that Act. This includes community colleges,
       proprietary schools, and all other institutions of higher education that are eligible to
       participate in Federal student financial aid programs;
     An institution of higher education that is formally controlled, or has been formally
       sanctioned or chartered, by the governing body of an Indian tribe or tribes;
     A professional, industry, or employer organization (e.g., National Institute for
       Automotive Service Excellence certification, National Institute for Metalworking
       Skills, Inc., Machining Level I credential) or product manufacturer or developer (e.g.,
       recognized Microsoft Information Technology certificates, such as Microsoft
       Certified IT Professional (MCITP), Certified Novell Engineer, a Sun Certified Java
       Programmer, etc.) using a valid and reliable assessment of an individual’s knowledge,
       skills and abilities;
     ETA’s Office of Apprenticeship or a State Apprenticeship Agency;
     A public regulatory agency, which awards a credential upon an individual’s
       fulfillment of educational, work experience, or skill requirements that are legally
       necessary for an individual to use an occupational or professional title or to practice
       an occupation or profession (e.g., Federal Aviation Administration aviation mechanic
       license, or a State-licensed asbestos inspector);
     A program that has been approved by the Department of Veterans Affairs to offer
       education benefits to veterans and other eligible persons; and

          Job Corps, which issues certificates for completing career training programs that are
           based on industry skills standards and certification requirements.

   TEGL 15-10 provides further attributes of qualifying credentials that are important in the
   workforce. In particular, TEGL 15-10 describes the importance of stackability and
   portability as factors to consider in identifying credentials that will assist with career
   pathways. The stackability and portability of credentials are important factors in determining
   whether to pursue a particular course of credentialing in the Construction Plus component. A
   credential is considered “stackable” when it is part of a sequence of credentials that can be
   accumulated over time to build an individual’s qualifications and help the individual to move
   along a career pathway or up a career ladder to different and potentially higher-paying jobs
   within the same industry. A credential is considered “portable” when it is recognized and
   accepted as verifying the qualifications of an individual in other settings, such as in other
   geographic areas, at other educational institutions, or by other industries or employers. To the
   extent possible, YouthBuild grantees that incorporate Construction Plus into their programs
   should strive to identify occupational skills training fields that will lead to both stackable and
   portable credentials within the chosen Construction Plus industries.

8. Qualifying Credentials for the YouthBuild Program. Qualifying credentials for
   YouthBuild must meet the definition of industry-recognized credentials provided above. A
   qualifying credential is one that provides a participant with the documentation of education
   and/or technical or occupational skills necessary to gain employment or advance within an
   occupation. These skills are measureable, based on industry standards, and developed or
   endorsed by employers. Only qualifying credentials may be reported as a performance
   indicator outcome under WIOA. The Credential Attainment performance indicator measures
   the number of participants in an education or training program (such as YouthBuild) who
   attain a diploma, a State-recognized high school equivalency credential, or an industry-
   recognized certificate during participation in or within one year of program exit. DOL does
   not recognize a diploma or State-recognized high school equivalency credential as a
   successful outcome unless such participants also attain a placement outcome within one year
   of exit.

   A non-qualifying credential is any diploma or certificate that does not meet the definition in
   the previous section as it does not document individuals’ attainment of measurable technical
   or industry/occupational skills necessary to obtain employment or advance within an
   industry/occupation. DOL will not count non-qualifying credentials toward the “Certificate
   Attainment” performance indicator for WIOA in the YouthBuild web-based Management
   Information System. However, such credentials can be of value to participants as building
   blocks for educational and/or occupational success. Examples of non-qualifying credentials
   include: certificates awarded by Workforce Development Boards (WDBs); single skill
   certificates, such as CPR, First Aid, Occupational Safety and Health Administration (OSHA)
   Safety Training, and ServSafe; and work readiness certificates, such as the Jobs for
   America’s Graduates (JAG) Certificate of Mastery and the WorkKeys National Career
   Readiness Certificate (NCRC).

   At the State level, the workforce system can recognize specific programs of study and
   determine if they meet the WIOA definition of a credential, as defined in TEGL 10-16,
   Change 1, and further detailed in TEGL 15-10. Local WIOA service providers may be of
   assistance to YouthBuild grantees in determining if a certificate offered for a particular
   completed program of study qualifies as a credential within their State. YouthBuild grantees
   should consult their assigned Federal Project Officers with any questions regarding
   qualifying credentials.

   DOL developed a tool to help determine potential Construction Plus industries and the
   related credentials, particularly as they relate to the guidance in TEGL 15-10 on qualifying,
   stackable, and portable credentials. Attachment, “Considerations Guide for Credential
   Attainment for US Department of Labor (DOL) YouthBuild Grantees,” provides a series of
   framing questions that can help programs determine whether a Construction Plus credential
   pathway is the right fit for their YouthBuild program participants.

9. Inquiries. Questions on this TEGL may be addressed to the appropriate ETA regional office.

10. Attachment. Considerations Guide for Credential Attainment for US Department of Labor
    (DOL) YouthBuild Grantees

Attachment (official PDF: https://www.dol.gov/sites/dolgov/files/ETA/advisories/TEGL/2018/TEGL_7-14_Change1_Attachment_Acc.pdf)

Attachment

Considerations Guide for Credential Attainment for US Department of Labor (DOL)
YouthBuild Grantees

DOL YouthBuild grantees should become familiar with TEGL 15-10, “Increasing Credential,
Degree, and Certificate Attainment by Participants of the Public Workforce System,” which
describes the criteria for ensuring that credentials are career-enhancing and meet the standards
for the Certificate Attainment performance indicator (see also TEGL 10-16, Change 1). Some of
the important criteria to consider are whether credentials are stackable and portable. A credential
is considered “stackable” when it is part of a sequence of credentials that can be accumulated
over time to build up an individual’s qualifications and help him/her to move along a career
pathway or up a career ladder to different and potentially higher-paying jobs. A credential is
considered “portable” when it is recognized and accepted as verifying the qualifications of an
individual in other settings, such as a different geographic area, across educational institutions, or
by other industries or employers. See TEGL 15-10 for further explanation of the attributes of
career-enhancing credentials.

To be consistent with TEGL 15-10, the considerations outlined below should be used to help
YouthBuild grantees determine which certifications they should offer to participants. These
considerations help grantees to focus on the value-added aspects of certifications as they relate to
career entry and advancement. Grantees should use these considerations as a guiding tool for
designing occupational skills training and certification opportunities for youth. The
considerations outlined below provide a lens through which DOL YouthBuild grantees can
ensure that they incorporate key components for successful attainment of credentials into their
program design. There are no right or wrong answers to the considerations questions. Rather,
these questions frame the intent of providing career-enhancing occupational skills training to
youth participants and illustrate what can be gained by selecting stackable and portable
credentials, certifications, or degrees that have labor market value; in other words, credentials
that are recognized by employers and considered valuable in hiring decisions.

This Considerations Guide provides insight to grantees to consider when selecting occupational
skills training curricula that the program will use and the types of credentials to be pursued
within each industry. DOL requires each program to offer construction training that will result in
an industry-recognized credential, regardless of whether they offer Construction Plus training.

Industry-recognized credentials provide an opportunity for YouthBuild participants to
demonstrate and document skills, and may lead to advantages in the hiring process, higher
earnings, enhanced job security, or advancement along a career pathway. According to the
Bureau of Labor Statistics (BLS), between 2016 and 2026, 18 of the 30 fastest growing
occupations will require some form of post-secondary education (Bureau of Labor Statistics,
Employment Projections - 2016-2026, January 2018).


                                                 I-1

Definition of Credential

TEGL 10-16, Change 1 identifies two types of credentials—either secondary or postsecondary in
nature. Postsecondary credentials broadly encompass industry-recognized certificates or
certifications, certificates of completion of an apprenticeship, licenses recognized by the State
involved or Federal government, or an associate or baccalaureate degree.

Considerations:

    1. What is the labor market value of the proposed credential?
        a. Is the skills training responsive to employer needs and employer-driven (i.e., does
             the industry drive the curriculum of the credential)?
        b. Does it meet the skills and competencies as identified by the industry/employer?
        c. Is the credential recognized by employers and taken into consideration in hiring,
             promotion, and compensation decisions?
        d. Are the skills documented through the credential currently in demand in the local
             labor market?
        e. Does the training increase the participant’s employment potential in a demand
             occupation, either nationally or locally?

    2. What is the length and intensity of the skills training course of study?
        a. Are the design, delivery, and duration of the curriculum sufficient to achieve
             learning outcomes? What is the minimum length of time required to attain the
             necessary skills for certification?
        b. Are there opportunities for on-the-job training or internships affiliated with the
             course of study? Is there a minimum requirement for work-based training?
        c. Is an apprenticeship required to gain the credential?

    3. What are the pre-requisites for the credentialing (educational or otherwise)?
        a. Is an entrance examination required?
        b. Is a high school diploma or equivalency required? Can career and technical
            training be started concurrently with secondary education?
        c. Are there minimum requirements beyond a high school diploma for each
            credential offered?

    4. What are the affiliated or stackable credentials related to the field(s) under consideration?
        a. Does it allow students to achieve the skills to get, keep, and progress in a chosen
            job or to enter further post-secondary or vocational training options?
        b. Does it incorporate some other educational components beyond the vocational
            field of study, such as college credit or foundational coursework?
        c. Are there opportunities for further post-secondary study or training in a related
            field that lead to additional credentials?
        d. Is the credential embedded in a larger career pathway model (such as the
            progression from Paramedic or Certified Nursing Assistant to Licensed Practical
            Nurse to Registered Nurse in which skills demonstrated in each credential provide


                                               I-2

          foundations for the next level) that provides opportunities to continue developing
          income-enhancing skills and competencies?
       e. Does the vocational training include apprenticeable fields or lead to
          apprenticeship opportunities?
       f. Are other public agencies, including educational institutions, economic
          development organizations, and human services providers, included in
          certification development, to ensure the effective leveraging and targeting of
          public resources aimed at increasing the skills of American workers?

5. Does the credential assist participants with specific barriers to employment to access
   career pathways?
       a. Does it provide a demonstration of additional training for youth populations that
           may often be overlooked in hiring (such as justice-involved youth)?
       b. Are there credentials from which specific populations are excluded—either from
           attaining the degree or being gainfully employed in the affiliated industry?


                                           I-3