WIOA Title I youth formula program guidance

CLASSIFICATION
   EMPLOYMENT AND TRAINING ADMINISTRATION                WIOA/Youth
               ADVISORY SYSTEM                           CORRESPONDENCE SYMBOL
          U.S. DEPARTMENT OF LABOR                       OWI/DYS
             Washington, D.C. 20210                      DATE
                                                         March 2, 2023

ADVISORY:       TRAINING AND EMPLOYMENT GUIDANCE LETTER NO. 09-22

TO:             STATE WORKFORCE AGENCIES
                STATE WORKFORCE ADMINISTRATORS
                STATE WORKFORCE LIAISONS
                STATE AND LOCAL WORKFORCE BOARD CHAIRS AND DIRECTORS

FROM:           BRENT PARTON
                Acting Assistant Secretary

SUBJECT:        Workforce Innovation and Opportunity Act Title I Youth Formula Program
                Guidance

1. Purpose. To provide guidance and planning information to states, local workforce areas, and
   other recipients of Workforce Innovation and Opportunity Act (WIOA) Title I youth formula
   funds on the activities associated with the implementation of WIOA.

2. Action Requested. Share with all staff who administer the WIOA Youth program. States
   and local areas should review their youth program policies and procedures to comply with
   this guidance.

3. Summary and Background.

   a. Summary – This guidance addresses the Employment and Training Administration
      (ETA’s) priorities for youth programs, and further clarifies WIOA Youth program
      policies. It also provides information to help states and local areas improve services,
      supports, and outcomes for youth, particularly opportunity youth (out-of-school and out-
      of-work youth), by integrating equity and job quality principles into program design and
      service delivery as well as elevating youth voice and addressing mental health.

   b. Background – This is the first WIOA Youth program guidance since the COVID-19
      pandemic required states and local areas to shift service delivery strategies and develop
      innovative approaches to serving youth. Since then, ETA has set priorities for programs
      serving youth as well as a vision for coordination and impact, many based on lessons
      learned from the pandemic and best practices used in states and local areas. This
      guidance highlights different ways to meet the evolving needs of youth participants.
      Section 4 includes important policy clarifications that States and local areas need to be
      aware of when developing and implementing the WIOA Youth program.

  RESCISSIONS                                             EXPIRATION DATE
  None                                                    Continuing

4. Priorities and Policy Clarifications: ETA has set a vision and several priorities for youth
   workforce development, including priorities of advancing equity, ensuring job quality,
   addressing mental health, and elevating youth voice. The overarching vision is to achieve a
   no-wrong-door workforce system with critical partners committed to quality career pathways
   and paid work experiences. States and local workforce boards are encouraged to incorporate
   this vision and priorities in their planning and implementation of programs. For additional
   information about these priorities, see Attachment I. Included in the attachment are several
   ways states and local workforce boards can integrate these, including through the provision
   of quality work experiences that are a part of a broader career pathway strategy. We
   encourage states and local boards to provide direction and support to assist local youth
   programs in integrating these priorities. Additionally, local programs should work to
   incorporate youth voice into decisions about programming that ultimately impact the young
   people they serve. Youth, as partners and co-designers of programs, can provide critical
   insights and recommend strategies to improve outreach, recruitment and other service
   delivery strategies. Attachment I provides additional detail on the benefits of engaging youth
   and resources for how to effectively incorporate youth voice.

   Additionally, over the last two years, ETA has identified program areas that warrant further
   clarification and direction. This section addresses their related requirements around
   programming and reporting.

   a. Documenting WIOA Youth Eligibility. ETA recognizes that documenting WIOA Youth
      participant eligibility can appear, and sometimes be, burdensome. It is important that
      local programs are aware of flexibilities within WIOA statute, regulations, and guidance
      that may help reduce barriers for WIOA Youth programs to document eligibility. First,
      WIOA eliminated the need to document low-income status for eligibility determination
      for the majority of out-of-school youth. There are only three instances where low-income
      status must be documented for OSY. Only those out-of-school youth who are determined
      eligible by virtue of using: 1) the “basic skill deficient,” 2) “English Language Learner,”
      or 3) “an individual who requires additional assistance to enter or complete and
      educational program or to secure or hold employment” barriers to document the WIOA
      Section 129(a)(1)(B)(iii) portion of out-of-school youth eligibility must be low income.
      Other out-of-school youth do not need to be low-income or document their income.
      Secondly, WIOA permits individuals who receive or are eligible to receive free or
      reduced lunch, foster youth, homeless youth, and youth living in a high-poverty area to
      automatically be considered low income. Lastly, self-attestation is an acceptable source
      of documenting almost all program elements related to WIOA Youth eligibility. As
      stated in TEGL 23-19, Change 1, the following youth eligibility data elements allow self-
      attestation as an acceptable source of documentation: school status at program entry, date
      of birth, individual with a disability, pregnant or parenting, youth who needs additional
      assistance, foster youth, homeless youth, offender, low income, and English Language
      Learner. The only data element related to WIOA Youth eligibility that does not permit
      the use of self-attestation for documentation is “basic skills deficient.”

       Please note that as stated in TEGL 23-19, Change 1, self-attestation means a written, or
       electronic/digital declaration of information for a particular data element, signed and

   dated by the participant. ETA broadly interprets what is 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.

   As stated in TEGL 23-19, Change 1, ETA encourages grant recipients to consider the
   impacts on equity and accessibility when developing their source documentation policies
   and procedures. For example, grantees considering restrictions on the use of self-
   attestation should consider that while other documentation sources are preferred when
   practical, self-attestation is an important option for populations with barriers to obtaining
   eligibility and reporting documents (such as disconnected youth, American Indian and
   Alaska Native populations, individuals experiencing homelessness, justice involved
   individuals, refugees, disaster impacted individuals, and others) and help ensure such
   populations are able to equitably access services. As a best practice, once enrolled,
   programs should assist the participant in obtaining the required documents through the
   use of supportive service funds as these documents are likely needed for employment and
   training related activities.

b. Mental Health Assessment, Referrals, and Training for Staff. The youth workforce
   system plays a critical role in supporting the mental health of participants through
   assessments, comprehensive guidance and counseling, including referrals to partner
   organizations, as well as providing sufficient supportive services to help alleviate
   additional barriers to education and work. Understanding the challenges and building
   new or strengthening existing partnerships with local mental health agencies and
   organizations can help ensure that youth are receiving the support and treatment they
   need.

   Comprehensive guidance and counseling is one of the WIOA Youth program’s 14
   program elements. As defined in 20 CFR 681.510 of the WIOA final rule,
   comprehensive guidance and counseling “provides individualized counseling to
   participants. This includes drug and alcohol abuse counseling, mental health counseling,
   and referral to partner programs, as appropriate.” When referring participants to
   necessary counseling that cannot be provided by the local youth program or its service
   providers, the providers must coordinate with the organization to which it refers in order
   to ensure continuity of service in the WIOA Youth program.

   In its August 2022 survey, the National Youth Employment Coalition found that most
   youth employment programs indicated that their youth cannot access mental health
   services when they need them. Sixty percent of respondents estimated that fewer than
   half the youth could access mental health support in their community when needed. Two
   other major findings from the survey include:

       •   64% of respondents did not have a process for screening and/or monitoring young
           people for mental health needs. Moreover, 60% of these respondents estimated
           that more than half of their youth need mental health support.

       •   89% of respondents indicated they did not have sufficient resources to deliver
           quality mental health training to staff. 72% of respondents do not track if youth
           receive needed mental services.

   It is important to note that while youth workforce development practitioners are not
   expected to be experts in mental health, there are many ways to assess mental health
   needs at program enrollment and throughout their participation in the program and that
   mental health assessments are an allowable cost under WIOA. ETA strongly encourages
   integrating mental health assessments into the objective assessment process to identify
   potential mental health needs that must be addressed through mental health services or
   through referrals to mental health professionals for youth to be successful in the program.

   Additionally, professional development for youth workforce development practitioners is
   essential for ensuring staff have the appropriate skills, knowledge, and abilities to
   effectively serve the young adults in the WIOA Youth program. Professional
   development is an allowable cost under WIOA. ETA strongly encourages local
   workforce development boards to offer professional development training to all staff that
   work with youth, and quality mental health training along with training related to trauma-
   informed care principles should be included.

c. Virtual Work Experiences. Virtual work experiences are allowable under the WIOA
   youth program. With COVID-19 pandemic, virtual services, such as virtual work
   experiences, became necessary. Virtual work experiences can offer more flexibility and
   broaden work experience opportunities, particularly in rural areas. They can also
   promote equity and access for youth that might not otherwise have the opportunity for
   certain types of work experiences. Therefore, local WIOA Youth programs are permitted
   to continue to provide virtual work experiences beyond the COVID-19 pandemic. And
   while WIOA section 681.600 states that work experiences must take place in a
   workplace, this includes a virtual workplace when remote work experiences are possible
   and practical. For technical assistance resources, visit:
   https://youth.workforcegps.org/resources/2020/06/18/13/10/Resources-on-Virtual-
   Engagement.

d. Digital Literacy and Access. Section 101 of WIOA authorizes state workforce
   development boards to use WIOA funding to support digital literacy efforts.
   Additionally, Section 107 states that local boards shall “identify strategies for better
   meeting the needs of individuals with barriers to employment, including strategies that
   augment traditional service delivery, and increase access to services and programs of the
   one-stop delivery system, such as improving digital literacy skills.” Jobs in almost every
   industry are increasingly requiring workers to have digital literacy skills. While many
   youth are considered “digital natives,” or people who have grown up with technology and
   the internet, it is still important to ensure that young people have the digital skills needed
   to successfully enter and remain in the workforce.

   It is important to note that WIOA funds can also be used to pay for devices and
   broadband internet service that will allow a participant to create or maintain a wireless
   connection for distance learning, search for jobs, and engage in other employment and
   training services where such services are already allowable. A local area must have
   written policies and procedures in place that outlines the steps/factors it will consider to
   approve a cost and ensure that costs are reasonable, necessary, allowable, and allocable to
   the WIOA grant. In addition, ETA encourages local WIOA Youth programs to inform
   participants about the Affordable Connectivity Program that helps families access
   affordable broadband. For more information, visit: Emergency Broadband Benefit |
   Federal Communications Commission (fcc.gov).

e. Assessment. WIOA requires an objective assessment of academic levels, skill levels, and
   service needs of each participant, which includes a review of basic skills, occupational
   skills, prior work experience, employability, interests, aptitudes, supportive service
   needs, and developmental needs. TEGL 21-16 stated that “local programs may use
   previous basic skills assessment results if such previous assessments have been
   conducted within the past six months.” While this continues to be true, state and/or local
   programs may use previous assessments older than six months if they deem appropriate
   and if there is a state/local policy in place that allows the use of such assessments. It is
   important that assessments do not serve as a deterrent to program enrollment. In
   addition, it is critical that local programs incorporate the results of the objective
   assessment into a participant’s Individual Service Strategy and the services, such as
   career counseling, that participants receive.

f. Supportive Services. Supportive services allow participants to persist in and complete
   program activities and are vital ingredients in youth success.

            i. Supportive services as an allowable work experience expenditure: TEGL 21-
               16 stated that “supportive services are a separate program element and cannot
               be counted toward the work experience expenditure requirement even if
               supportive services assist the youth in participating in the work experience.”
               However, ETA’s policy on this issue has evolved. ETA recently determined
               that supportive services that enable WIOA participants to participate in
               training can count toward training expenditures. Therefore, to be consistent
               with this policy, supportive services that enable WIOA participants to
               participate in work experience can now count toward the work experience
               expenditure requirement.

           ii. Food. A frequently asked question is whether food is an allowable cost for
               youth participants in WIOA. ETA’s policy continues to be that on a limited
               basis and in certain situations, food at a reasonable cost may be provided to
               youth-serving program participants as a supportive service. Food may be
               provided to eligible youth when it will assist or enable the participant to
               participate in allowable youth program activities and to reach his/her
               employment and training goals, thereby achieving the program’s overall
               performance goals. The use of grant funds for food should be limited to

              reasonable and necessary purchases that are coordinated, when possible, with
              other community, state, or federal services that provide food for low-income
              individuals. Local areas should have written policies and procedures in place
              for purchasing and distributing food to ensure consistent treatment of these
              types of expenses. When developing written policies and procedures, please
              review the Uniform Guidance at 2 CFR 200.403.

g. Reporting and Expenditures for Pre-Apprenticeship and Apprenticeship. WIOA and 20
   CFR § 681.590(a) require that a minimum of 20 percent of local area funds for the Title I
   Youth program be spent on work experience. TEGL Nos. 8-15 and 21-16 provide further
   discussion of allowable expenditures that may be counted toward the work experience
   expenditure requirement and articulate that program expenditures on the work experience
   program element can be more than just wages paid to youth in work experience.

   An important reminder is that expenditures for pre-apprenticeships count toward the
   work experience expenditure requirement. In addition, if the pre-apprenticeship program
   includes an occupational skills training component, separate from the work experience,
   WIOA Youth programs may report pre-apprenticeship under both the work experience
   program element and the occupational skills training program element. Also, while not
   explicitly listed in WIOA as a type of work experience, WIOA Youth expenditures
   related to Registered Apprenticeship programs count toward the minimum work
   experience expenditure requirement.

h. Comprehensive Guidance and Counseling Reporting. As noted elsewhere in this
   guidance, local area staff should prioritize delivering services over administrative
   functions. However, accurate reporting provides enough administrative data to assess
   what strategies are working and can also contribute to building evidence on effective
   services for youth. Therefore, ETA also notes where program elements may not be
   accurately reported. Where feasible, states should review their policies, systems, and
   training so that services can be accurately recorded. In reviewing reporting data, ETA
   observed that many states may not be accurately reporting the comprehensive guidance
   and counseling program element. For example, in the most recent data reported, five
   states report 100 percent of participants receive this program element, two additional
   states report over 90 percent of participants receive this program element, and three more
   report over 70 percent as receiving comprehensive guidance and counseling. It appears
   some states report certain program services as comprehensive guidance and counseling
   that should be categorized in other program elements, or they are reporting general case
   management as comprehensive guidance and counseling. As stated in TEGL 21-16, case
   management is the act of connecting youth to appropriate services and is not considered a
   program element.

   Another program element that often is misreported as comprehensive guidance and
   counseling is the program element entitled “services that provide labor market and
   employment information about in-demand industry sectors or occupations available in the
   local area, such as career awareness, career counseling, and career exploration services.”
   As discussed in TEGL 21-16, career counseling services may include providing

   information about resume preparation, interview skills, potential opportunities for job
   shadowing, and the long-term benefits of postsecondary education and training. This
   type of career counseling, often provided by a case manager, should be reported as the
   “services that provide labor market information” program element and should not be
   reported as the comprehensive guidance and counseling program element. As mentioned
   above, youth are experiencing significant mental health and substance abuse issues, and it
   is important to have a clear understanding of when WIOA Youth providers deliver
   services within the comprehensive guidance and counseling program element to youth
   participants. Technical assistance resources related to comprehensive guidance and
   counseling can be found at:
   https://youth.workforcegps.org/resources/2017/03/22/09/55/~/~/link.aspx?_id=E98DB3B
   477814B1DAD1754299248AE86&_z=z

i. Follow-up Services and Mentoring Reporting. In reviewing reporting data, ETA
   observed fewer participants than expected receiving the program elements of mentoring
   and follow-up services. Only 10 percent of youth nationally are reported as receiving
   mentoring in the current program year and nine states report zero participants receiving
   mentoring services. In addition to those nine states, 17 more states report fewer than
   three percent of participants as receiving mentoring services. Likewise, only 18 percent
   of youth nationally are reported as receiving follow-up services despite follow-up
   services being a required program element for all participants. Five states reported zero
   youth as receiving follow-up services, an additional nine states reported less than five
   percent of participants receiving follow-up services, and 13 more states reported less than
   10 percent of participants receiving follow-up services.

   Both mentoring and follow-up services provide critical support to youth that help youth
   succeed in their career pathway progression. One potential explanation for the low
   numbers in these two program elements is that perhaps these services are being provided,
   just not for the full twelve months specified in WIOA. While both program elements
   require their provision for a minimum of 12 months, it is not necessary to wait until a
   participant receives these services for the full 12 months prior to reporting them. For
   example, if a participant receives mentoring services, such services can be reported in the
   first quarter in which mentoring is received. Likewise, follow-up services can be
   reported in the first quarter in which it is received. As a reminder, as stated in WIOA
   section 681.580, mentoring is one of the types of services that is permitted during follow-
   up.

   Technical assistance resources related to Mentoring can be found at:
   https://youth.workforcegps.org/resources/2017/03/22/09/55/~/~/link.aspx?_id=1D201FB
   7BEAA404EA16918E772D45F68&_z=z.

   Technical assistance resources related to Follow-up can be found at:
   https://youth.workforcegps.org/resources/2017/03/22/09/55/~/~/link.aspx?_id=C8899A8
   18F794561941389237DF746CC&_z=z.

   j. Reporting Barriers, Including In-School Youth Who Require Additional Assistance. In
      order to ensure the program is serving a diverse mix of youth and that it is accessible to
      all youth, reporting youth demographic information, including eligibility barriers, is very
      important. In addition, programs should make sure to report all eligibility barriers for
      youth when youth have multiple barriers, so that program staff, states, and ETA and have
      an accurate representation of the youth we serve.

       There is one exception to the reporting of all youth eligibility barriers -- in-school youth
       who require additional assistance to complete an education program or secure or hold
       employment. For this particular barrier, it is important that local programs report it only
       when it is a participant’s sole eligibility barrier. WIOA includes a limitation where in
       each local area only five percent of in-school youth in a given program year can be
       determined eligible using the “youth who require additional assistance to complete an
       education program or secure or hold employment” barrier. Based on the most recent
       data, 24.3 percent of in-school youth nationally are reported as having the “youth who
       require additional assistance” barrier. In order to more accurately track this five percent
       limitation, WIOA Youth programs should only report youth as having this barrier if it is
       their only barrier, and therefore, the barrier used for eligibility determination.

       In the most recent report, 43 states had more than five percent of their youth with this
       barrier, meaning that at least one local area in each of those states report more than five
       percent of their youth as having this barrier. While this does not necessarily indicate that
       all such reported youth have the “youth who require additional assistance” as their only
       barrier, for tracking purposes of the five percent limitation, in-school youth with multiple
       barriers should not be reported as having the “youth who require additional assistance”
       barrier. States must ensure that each local area in their state has less than five percent of
       their in-school youth per program year that report this barrier for eligibility
       determination.

5. Inquiries. Please direct inquiries to the appropriate Regional Office.

6. References.

       •   Workforce Innovation and Opportunity Act, Pub. L. 113-128
       •   Training and Employment Guidance Letter (TEGL) No. 21-16: Third Workforce
           Innovation and Opportunity Act (WIOA) Title I Youth Formula Program Guidance
       •   Training and Employment Guidance Letter (TEGL) No. 8-15: Second Title 1 WIOA
           Youth Program Transition Guidance
       •   Training and Employment Guidance Letter (TEGL) No. 23-19 Change 1: Guidance
           for Validating Required Performance Data Submitted by Grant Recipients of U.S.
           Department of Labor (DOL) Workforce Programs

7. Attachment:

   Attachment I: Departmental Vision and Priorities for Youth

                                                                                Attachment I

                     ETA Priorities for Youth Workforce Development:
                    Equity, Job Quality, Mental Health, and Youth Voice.

Vision
The Department envisions a no-wrong-door youth workforce system that offers seamless
access to resources, programs, and wrap around services; offers guaranteed paid work
experiences for young people; and coordinates with critical partners—including but not
limited to employers, sector-based industry coalitions, workforce intermediaries, labor
unions, and philanthropy—committed to high quality career pathways for young workers.

Priorities
Equity: On January 21, 2021, his first day in office, President Biden issued Executive Order
13985 On Advancing Racial Equity and Support for Underserved Communities Through the
Federal Government. The Executive Order defines equity “as the consistent and systemic,
fair, just, and impartial treatment of all individuals, including individuals who belong to
underserved communities that have been denied such treatment.”

Advancing equity to ensure youth have equal access to and outcomes in high quality
education and training is a key priority for the Department. Equity must be integrated into
everything programs do; from outreach and recruitment to service delivery strategies to
partnership development and to using data to inform decision making. Equity in the WIOA
Youth program means that not only do youth have equitable access to services and supports
but also that youth are achieving equitable outcomes.

On January 20, 2022, ETA hosted a webinar, “Technical Assistance to Meet Equity Goals in
WIOA Youth Programs” which reviewed resources and provided audience members an
opportunity to share their technical assistance needs as it relates to how WIOA youth
providers can improve youth outcomes through more equitable and inclusive programming.
Presenters and audience members on this webinar engaged in a rich discussion of what
integrating equity principles into WIOA youth programming can look like. ETA encourages
those who were unable to attend the webinar to view the recording of the webinar at:
https://www.workforcegps.org/events/2021/10/25/19/36/Technical-Assistance-to-Meet-Equity-Goals-in-WIOA-Youth-Programs. For additional resources on equity, visit:
https://youth.workforcegps.org/resources/2022/08/08/19/05/Resources-on-Advancing-Workforce-Equity-for-Youth.

Additional information on integrating equity into workforce development programming can
be found at: https://youth.workforcegps.org/resources/2022/08/08/19/05/Resources-on-Advancing-Workforce-Equity-for-Youth

Job Quality: Ensuring equity in WIOA Youth programs means that programs must not only
connect youth to a job, but ensure youth have access to quality jobs by creating opportunities
for on-ramps to quality career pathways. The Department leads the Good Jobs Initiative,
focused on job quality by providing “critical information to workers, employers, and

    government as they work to improve job quality and create access to good jobs free from
    discrimination and harassment.” The Department, in partnership with the U.S. Department
    of Commerce created eight principles framework, known as the Good Jobs Principles, for a
    shared vision of job quality. These principles focus on hiring and recruitment; family-
    sustaining benefits for full- and part-time workers; diversity, equity, inclusion, and
    accessibility (DEIA) in the workplace; empowerment and representation; job security and
    working conditions that include a safe and healthy workplace; pay that is stable and a living
    wage; and skills and career advancement opportunities to progress to good jobs.

    TEGL 07-22, Increasing Employer and Workforce System Customer Access to Good Jobs, defines a
    good job, explains why job quality is important, and outlines how the workforce system
    integrates good job strategies into its employer relationships and workforce training. It also
    clarifies the workforce system’s role as supporter and developer of good jobs, in an effort to
    make the workforce system more equitable and responsive to worker and business needs.
    Strong State and Local Workforce Development Boards and State Workforce Agencies use
    the information in that guidance to develop a strategy for identifying and creating long-term
    partnerships with employers offering good jobs; helping other employers to provide good
    jobs; and creating strategic, flexible career pathways to good jobs that respond to local labor
    market needs.

    Quality Work Experiences: Integrating equity and job quality principles into the WIOA
    Youth program is achieved by ensuring youth have access to quality work experiences, in
    particular, paid work experience whenever possible, that have on-ramps to career pathways.
    The decade between ages 14 and 24 is marked by critical transitions as youth begin to enter
    adulthood and make decisions about how to continue their education or enter the workforce.
    The opportunities and support available to young people during this time influences their
    long-term trajectories into adulthood. 1 Early employment represents one experience that is
    generally associated with better labor and wage outcomes in the future, potentially because it
    helps youth to develop soft skills, a job history, and connections to employer networks. 2

    Early employment is also an experience that youth and young adults from low-income
    households have greater difficulty accessing than higher-income peers. 3 Black and Hispanic
    teenagers from low-income households experience even greater challenges in the labor
    market due to structural barriers to opportunities faced by people of color in the American
    job market. 4 This inherent inequity makes it critical that the WIOA Youth program provide
    quality work experience opportunities to youth participants.

1
  Abdul Latif Jameel Poverty Action Lab (J-PAL);
https://www.povertyactionlab.org/sites/default/files/publication/SYEP_EvidenceReview-5.25.22.pdf
2
  1 Kahn, Lisa B. 2010. “The Long-Term Labor Market Consequences of Graduating from College in a Bad
Economy.” Labour Economics 17, no. 2 (April): 303–316. doi: https://doi.org/10.1016/j.labeco.2009.09.002;
Neumark, David. 2002. “Youth Labor Markets in the United States: Shopping around vs. Staying Put.” The Review
of Economics and Statistics 84, no. 3: 462–482. https://doi.org/10.1162/003465302320259475.
3
  2 Sum, Andrew, Ishwar Khatiwada, Mykhaylo Trubskyy, Martha Ross, Walter McHugh, and Sheila Palma. 2014.
“The Plummeting Labor Market Fortunes of Teens and Young Adults.” Brookings Institution.
https://www.brookings.edu/wp-content/uploads/2014/03/Youth_Workforce_Report_FINAL-1.pdf.
4
  Spievack. 2019. “For People of Color, Employment Disparities Start Early.” Urban Institute.
https://www.urban.org/urban-wire/people-color-employment-disparities-start-early.

    According to MDRC’s meta-analysis on career pathway programs, systematic biases,
    especially against people of color and women, social networks that limit which jobs and
    employers workers can connect to, and employers’ strong preference to hire those who
    already have relevant work experience can all combine to make it difficult for people to get
    access to employers and careers that offer family-supporting wages. Work-based learning
    can help offset those disadvantages by using a college or training program’s relationships and
    credibility to open doors. Apprenticeships offer another potential avenue by which work-
    based learning could increase college completion rates, earnings, and equity, if they were
    expanded to include more diverse participants. Apprenticeships are already often connected
    to colleges that deliver classroom training components leading to college credentials.”

    In addition to ensuring youth have access to paid work experience opportunities, it is critical
    that such work experiences be in industries and occupations that put youth on a career
    pathway to high quality jobs. As discussed in CLASP’s research brief entitled Toward a
    Vision of Quality Summer Employment for All Youth, recent interviews with Summer Youth
    Employment Program funders, providers, advocates, and participants in six U.S. cities
    explored what it would take to guarantee a high-quality summer job to all youth. Among the
    insights that emerged, one theme became clear: Young people want more than a summer job;
    they want career-focused work experience that is worth their time and responsive to their
    day-to-day realities. 5 Creating targeted job opportunities with deliberate focus on equity and
    exposing youth to careers and connecting them to social networks in fields where they are
    underrepresented will help youth enter career pathways that will lead to family-sustaining
    wages.”

    Apprenticeships and Pre-Apprenticeships: One way to connect youth to work experiences
    that will lead to career pathways is through pre-apprenticeship and Registered
    Apprenticeship opportunities. Registered Apprenticeship programs (RAP) offer learn while
    you earn opportunities and are appropriate for many youth participants. The average wage
    for a RAP completer is $70,000, and 94 percent of completers retain employment. 6
    Furthermore, RAP participants earn an average of $98,718 more than nonparticipants over
    their career. 7

    Historically, many individuals, including youth, have faced significant barriers to accessing
    RAPs. Quality pre-apprenticeship programs, however, can play a key role in removing these
    barriers and creating accessible pathways to RAPs and to rewarding careers. While a quality
    pre-apprenticeship program can play a valuable role in providing work-based learning for all
    Americans, as identified in recent evaluations of the American Apprenticeship Initiative
    (AAI) grant program, pre-apprenticeship programs may also serve as an effective tool for
    promoting DEIA by helping individuals facing barriers to employment acquire the practical
    and foundational skills needed to successfully participate in the workforce and to gain entry
    into RAPs. Pre-apprenticeship programs use varied program strategies which place an

5
  CLASP, https://www.clasp.org/wp-content/uploads/2022/05/2022_TowardAVision.pdf
6
  “Career Seeker Fact Sheet,” (September 2020), Department of Labor;
7
  Reed, Debbie, et al., “An Effectiveness Assessment and Cost-Benefit Analysis of Registered Apprenticeship in 10
States,” (July 2012), Mathematica.

    individual on the potential career pathway to employability through a RAP. They utilize a
    wide range of program designs and approaches, and often vary in duration to meet the needs
    of diverse populations and employers.

    The Department has invested significant funding in recent years on building pre-
    apprenticeship and RAPs for youth and encourages states and local areas to work with their
    apprenticeship partners to leverage and align WIOA Youth program resources and further
    expand these quality work and learning opportunities. The Department encourages states and
    local areas to develop or strengthen existing relationships with their State Apprenticeship
    Agency in those states that have them or with an ETA Apprenticeship and Training
    Representative in states that don’t have a State Apprenticeship Agency.

    Mental Health: The workforce system must play a key role in addressing the youth mental
    health crisis. Even before the pandemic, demand for mental health services was increasing,
    especially for our nation’s young people. The COVID-19 pandemic intensified the situation,
    subjecting many young Americans to social isolation, loss of routines, and traumatic grief 8.
    These challenges are documented in the White House’s Fact Sheet: Improving Access and
    Care for Youth Mental Health and Substance Use Conditions found at:
    https://www.whitehouse.gov/briefing-room/statements-releases/2021/10/19/fact-sheet-
    improving-access-and-care-for-youth-mental-health-and-substance-use-conditions/.
    Additionally, in December 2021, the Office of the Surgeon General released an advisory
    report, “Protecting Young People’s Mental Health,” found at
    https://www.hhs.gov/sites/default/files/surgeon-general-youth-mental-health-advisory.pdf in
    which the devastating impacts of the pandemic and the alarming increases in mental health
    needs of young people are outlined.

    In August 2022, the Department hosted a webinar entitled: Supporting Youth Mental Health
    in the Workforce System, where the Office of the Surgeon General presented on its Advisory
    mentioned above, National Youth Employment Coalition provided an overview of the
    findings from their report summarizing findings from their national survey, entitled:
    Identifying Gaps in Youth Employment Programs' Capacity to Address Youth Mental Health
    Needs, and offered policy and practice solutions, and Substance Abuse and Mental Health
    Services Administration showcased a number of resources that may be useful to program
    practitioners when helping youth access mental health services and supports. The webinar
    recording is available at:
    https://www.workforcegps.org/events/2022/07/01/18/50/Supporting-Youth-Mental-Health-
    in-the-Workforce-System.

    During the webinar, ETA showcased the Youth Mental Health Resource Guide which was
    designed to help youth workforce practitioners deliver on the WIOA youth program element
    of providing youth with comprehensive guidance and counseling. The Resource guide can
    be found at: https://youth.workforcegps.org/resources/2022/08/16/15/26/Youth-Mental-
    Health-Resource-Guide.

8
 The White House, FACT SHEET: Improving Access and Care for Youth Mental Health and Substance Use
Conditions, https://www.whitehouse.gov/briefing-room/statements-releases/2021/10/19/fact-sheet-improving-access-and-care-for-youth-mental-health-and-substance-use-conditions/.

Trauma-Informed Care. Trauma is a major contributor of poor mental health. When
working with youth it is important to understand the effects trauma may have. Trauma
affects the way a person learns, plans, and interacts with others; a young person may be
combative, non-responsive at times, or misuse substances to cope with these past traumas.
Youth programs have increasingly adopted different types of trauma-informed care
approaches, which seek to support individuals who have experienced trauma or distressing
events in their lives. Several local programs have adopted trauma-informed care into their
program offering. ETA encourages all WIOA Youth program providers to fully incorporate
trauma-informed care principles and practices into program planning, staffing, training, and
implementation.

Resources on Trauma and Trauma-Informed Care can be found at:
https://youth.workforcegps.org/resources/2020/03/24/11/13/Resources-on-Trauma-and-Trauma-Informed-Care. These resources can help workforce system providers better
understand the impacts of trauma on the young people they serve and that professional
development and training in trauma-informed care is critical to achieving positive outcomes.
ETA will continue to share up-to-date resources and research and encourages the system to
fully integrate trauma-informed practices into service delivery to help youth feel safe,
supported, and engaged while participating in education, training, and employment.

Youth Voice: Youth play an important role in strengthening programs and improving youth
outcomes. Empowering youth to identify and respond to community needs helps them
become leaders and assist them in civic engagement. Finding ways to incorporate youth in
program development, recruitment strategies, and execution of activities is pivotal. The
Interagency Working Group on Youth Programs, composed of representatives from 22
federal agencies that support programs and services focusing on youth, created a tool,
“Assessing Youth Involvement and Engagement,” to assist organizations and community
partnerships in determining how they involve youth in programs, whether youth are
becoming more engaged in the community, and if certain strategies are helping to retain
youth. ETA created a tip sheet entitled, “Civic Engagement for Leadership Development,”
which notes that by supporting youth in finding the issues they are passionate about increases
their investment. Involving youth as partners in making decisions that affect them increases
the likelihood the decisions will be accepted and adopted. Further, providing participants a
safe platform to express their ideas, opinions, and advice to others is pivotal in developing
leadership skills, which is a requirement of the WIOA Youth program.

Youth involvement can benefit organizations and their programs as well as the youth
themselves. Youth voices assist programs with assessing the resources required to meet the
needs of current and future participants. Learning from best practices shared from the
IWGYP, programs developed in partnership with youth are more likely to be effective at
engaging the population and, therefore, to have a greater impact. States and local programs
are encouraged to engage youth in leadership development opportunities to enhance their
confidence, employability, self-determination, and other positive social behaviors.

For more resources on how programs can engage youth and incorporate youth voices into
their programs, visit: https://youth.workforcegps.org/resources/2022/08/08/17/41/Resources-on-Engaging-Youth-Voice.