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WIOA youth formula program guidance
Summary ETA gave states and local workforce areas operating guidance for WIOA Title I youth formula programs, including eligibility, service elements and reporting. Its attachments provide references and guidance on determining whether youth live in a high-poverty area. ETA lists this advisory as Active.
Document
Federal guidance
Agency
U.S. Department of Labor, Employment and Training Administration (ETA)
Document number
TEGL No. 21-16
Date issued
March 2, 2017
Status
Active
ETA lists this advisory Active as of 2026-10-24.
Status last verified October 24, 2026
Topics
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About this page: The full text below is the official document from U.S. Department of Labor, Employment and Training Administration (ETA). Ezel adds the plain-English summary and tracks the document's status. The official source linked on this page is authoritative for any reliance.
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, 2017
ADVISORY: TRAINING AND EMPLOYMENT GUIDANCE LETTER WIOA NO. 21-16
OPERATING GUIDANCE for the WORKFORCE INNOVATION AND
OPPORTUNITY ACT
TO: STATE WORKFORCE AGENCIES
STATE WORKFORCE ADMINISTRATORS
STATE WORKFORCE LIAISONS
STATE AND LOCAL WORKFORCE BOARD CHAIRS AND DIRECTORS
FROM: Byron Zuidema /s/
Deputy Assistant Secretary
SUBJECT: Third Workforce Innovation and Opportunity Act (WIOA) Title I Youth
Formula Program Guidance
1. Purpose. To provide guidance and planning information to states, local workforce areas, and
other recipients of WIOA Title I youth formula funds on the activities associated with the
implementation of WIOA.
WIOA became law on July 22, 2014 and supersedes Titles I and II of the Workforce
Investment Act of 1998 (WIA), and amends the Wagner-Peyser Act and the Rehabilitation
Act of 1973. The Departments of Labor and Education published a set of regulations for
implementing WIOA. These WIOA Final Rules were made public on July 1, 2016, and the
rules covering the Title I youth formula program became effective on October 18, 2016.
2. References. See attachment 1.
3. Background. Title I of WIOA outlines a broad youth vision that supports an integrated
service delivery system and provides a framework through which states and local areas can
leverage other Federal, state, local, and philanthropic resources to support in-school youth
(ISY) and out-of-school youth (OSY). Title I of WIOA affirms the Department of Labor’s
(DOL) commitment to providing high-quality services for youth, beginning with career
exploration and guidance, continued support for educational attainment, opportunities for
skills training, such as pre-apprenticeships or internships, for in-demand industries and
occupations, and culminating with employment, enrollment in postsecondary education, or a
Registered Apprenticeship.
On March 26, 2015, DOL published Training and Employment Guidance Letter (TEGL) No.
23-14 which provided guidance on WIOA youth program transition. On November 17, 2015
DOL published TEGL No. 8-15 which provided additional WIOA youth transition guidance.
RESCISSIONS EXPIRATION DATE
None Continuing
This issuance is the third TEGL that addresses key provisions in WIOA and provides
guidance to assist states and local areas in implementing the WIOA youth program.
4. Eligibility.
Determining School Status
Different eligibility criteria apply to in-school youth (ISY) and out-of-school youth (OSY),
and WIOA shifts the Youth formula program to focus primarily on OSY. As discussed in 20
CFR § 681.240, school status is determined at the time of program enrollment. Because the
process of program enrollment can occur over a period of time, school status must be based
on status at the time the eligibility determination portion of program enrollment is made.
Once the school status of a youth is determined, that school status remains the same
throughout the youth’s participation in the WIOA youth program. This distinction is drawn
for purposes of reporting against the OSY expenditure requirement.
If a youth is enrolled in the WIOA youth program during the summer and is in between
school years, the youth is considered an ISY if they are enrolled to continue school in the
fall. If a youth is enrolled in the WIOA youth program between high school graduation and
postsecondary education, the youth is considered an ISY if they are registered for
postsecondary education, even if they have not yet begun postsecondary classes at the time of
WIOA youth program enrollment. However, if a youth graduates high school and registers
for postsecondary education, but does not ultimately follow through with attending
postsecondary education, then such a youth would be considered an OSY if the eligibility
determination is made after the point that the youth decided not to attend postsecondary
education.
Non-credit-bearing postsecondary classes. DOL received a number of questions related to
what counts as attending postsecondary education for purposes of determining school status.
If the youth participant is enrolled in any credit-bearing postsecondary education classes,
including credit-bearing community college classes and credit-bearing continuing education
classes, then they are considered attending postsecondary education, and, therefore, an ISY.
If the youth is only enrolled in non-credit-bearing postsecondary classes, they would not be
considered attending postsecondary school and, therefore, an OSY.
Individuals 22 and older attending postsecondary education. Local programs should keep in
mind that ISY, including those attending postsecondary education, must be between the ages
of 14 through 21. A youth attending postsecondary education who is 22 at time of eligibility
determination would not be eligible for the WIOA youth program because they are in school
and over the age of 21. That individual could be served through the WIOA adult program.
Exception for youth with disabilities. There is one exception to age eligibility for youth
attending school. Youth with disabilities who have an Individualized Education Program
(IEP) may be enrolled as ISY after the age of 21, if their state law allows youth with
disabilities to be served by the K-12 public school system beyond the age of 21. Such youth
may only be enrolled as ISY up to the age allowed by their state law to receive secondary
education services.
High school equivalency programs and dropout re-engagement programs. In 20 CFR §
681.230, DOL uses the terms high school equivalency program and dropout re-engagement
program. As stated in 20 CFR § 681.230, for purposes of WIOA, providers of adult
education under Title II of WIOA, YouthBuild programs, the Job Corps program, high
school equivalency programs, and dropout re-engagement programs are not considered to be
schools for the purposes of determining school status. However, there is one exception.
Youth attending high school equivalency (HSE) programs, including those considered to be
dropout re-engagement programs, funded by the public K–12 school system that are
classified by the school system as still enrolled in school are considered ISY.
An HSE program offers preparation for, and the taking of, tests which lead to a HSE degree.
The “High School Equivalency: Resource Guide for the Workforce System” provides
information about the options for high school equivalency and can be found at: High School
Equivalency Resource Guide. A dropout re-engagement program conducts active outreach
to encourage out-of-school youth to return to school and assists such youth in resuming their
education and/or training to become career ready. A re-engagement program or center may
provide case management and other services to support youth in overcoming barriers that
prevent them from returning to school or work. To learn more about dropout re-engagement
centers and programs, see “Bringing Students Back to the Center: A Resource Guide for
Implementing and Enhancing Re-Engagement Centers for Out-of-School Youth” and can be
found at: Re-Engagement Center Resource Guide.
Homeschooling. DOL has received a number of questions about how to classify youth who
are homeschooled. State education agencies and/or local education agencies have policies
regarding the classification of youth who are home-schooled. WIOA youth programs must
classify homeschooled youth as ISY or OSY based on their state education agency (or local
education agency, if relevant) policy.
Eligibility Barriers
To be eligible for the WIOA youth program, individuals must meet one or more conditions
listed in WIOA Section 129(a)(1)(B)(iii) for OSY and (a)(1)(C)(iv) for ISY. This guidance
refers to these conditions as eligibility barriers. DOL received questions regarding whether
youth self-attestation of eligibility characteristics is acceptable. DOL will address self-
attestation as part of data validation guidance, which is due to be published later in 2017.
Below is further explanation of some of the eligibility barriers:
English Language Learner. WIOA Section 203(7) defines the term ‘‘English language
learner’’ as an individual who has limited ability in reading, writing, speaking, or
comprehending the English language, and (A) whose native language is a language other
than English; or (B) who lives in a family or community environment where a language other
than English is the dominant language.”
Dropout. A “school dropout” is defined in WIOA Section 3(54) as an individual who is no
longer attending any school and who has not received a secondary school diploma or its
recognized equivalent. As discussed in TEGL 08-15, an individual who has dropped out of
postsecondary education is not a “school dropout” for purposes of youth program eligibility.
A youth’s eligibility status is determined at the time of enrollment; therefore, if a youth has
not received a high school diploma, or a recognized equivalent, AND is not attending any
school, he/she is considered a dropout and is an OSY. A dropout only includes an individual
who is currently a secondary school dropout and does not include a youth who previously
dropped out of secondary school but subsequently returned. For example, a youth who
dropped out of high school in 2015 and returned to high school in 2016 prior to enrollment in
WIOA is not considered a dropout.
Age of compulsory school attendance, but not attending. In 20 CFR § 681.210(c)(2), the
second eligibility barrier is “a youth who is within the age of compulsory school attendance,
but has not attended school for at least the most recent complete school year calendar
quarter.” This section of the final rule further states that a “school year calendar quarter is
based on how a local school district defines its school year quarters. In cases where schools
do not use quarters, local programs must use calendar year quarters.”
An offender. The WIOA statute uses slightly different wording to describe the criteria for
ISY and OSY who are eligible because they have been subject to any stage of the criminal
justice process. For OSY, one eligibility barrier under WIOA Section 129(a)(1)(B)(iii)(IV) is
that the youth is “[a]n individual who is subject to the juvenile or adult justice system.” For
ISY, Section 129(a)(1)(C)(iv)(III) uses the term “offender” as the relevant criteria. The term
‘‘offender’’ is defined in WIOA Section 3(38) as “an adult or juvenile (A) who is or has been
subject to any stage of the criminal justice process, and for whom services under this Act
may be beneficial; or (B) who requires assistance in overcoming artificial barriers to
employment resulting from a record of arrest or conviction.” The Department concluded that
the intent of the OSY eligibility criterion is not to treat youth who were subject to the
juvenile or adult system differently, but rather to call attention to the fact that both the
juvenile and adult justice systems may include OSY. Therefore, to be clear that the same
eligibility criteria apply to both OSY and ISY, both 20 CFR § 681.210, which provides the
eligibility criteria for OSY, and 20 CFR § 681.220, which provides the eligibility criteria for
ISY, use the term “offender.”
Homeless and foster care youth. In WIOA, an individual who is homeless is eligible under
the same barrier category as an individual in the foster care system or one who has aged out
of the foster care system. In order to make the regulation easier to understand, DOL
separated foster care youth and homeless and runaway youth into two separate eligibility
barrier categories in the Final Rule. In addition, the Final Rule also includes “ an individual
who has attained 16 years of age and left foster care for kinship guardianship or adoption” in
the foster care eligibility barrier in 20 CFR §s 681.210 and 681.220 to encompass youth who
were formerly in foster care, but may have returned to their families before turning 18.
An individual who is pregnant or parenting. An individual who is parenting can be a mother
or father, custodial or non-custodial. As long as the youth is within the WIOA youth age
eligibility, the age when the youth became a parent does not factor in to the definition of
parenting. A pregnant individual can only be the expectant mother.
Additional assistance barrier. A state may establish definitions and eligibility
documentation requirements for criteria for “an individual who requires additional assistance
to enter or complete an educational program or to secure or hold employment.” If the state
does not establish these definitions and eligibility documentation, the local area must do so if
it uses this criterion. These policies established at the state or local level should be
reasonable, quantifiable, and based on evidence that the specific characteristic of the youth
identified in the policy objectively requires additional assistance.
Low-Income Determination
In some regards, WIOA makes low-income determination more complex than under WIA
because not all youth need to be low-income in order to qualify for the program. To
determine whether a youth must be low income, first consider whether the participant is OSY
or ISY. As provided in 20 CFR §s 681.210 and 681.250, if the youth is OSY, the low-
income requirement applies only to the following categories of youth – (1) a recipient of a
secondary school diploma or its recognized equivalent who is either basic skills deficient or
an English language learner; and (2) an individual who requires additional assistance to enter
or complete an educational program or to secure or hold employment. All ISY must be low
income unless they are served under the five percent exception discussed below.
Low income is defined in WIOA Section 3(36) as an individual who:
(i) receives, or in the past 6 months has received, or is a member of a family that is receiving
or in the past 6 months has received, assistance through the supplemental nutrition assistance
program established under the Food and Nutrition Act of 2008 (7 U.S.C. 2011 et seq.), the
program of block grants to States for temporary assistance for needy families program under
part A of Title IV of the Social Security Act (42 U.S.C. 601 et seq.), or the supplemental
security income program established under Title XVI of the Social Security Act (42 U.S.C.
1381 et seq.), or State or local income-based public assistance;
(ii) is in a family with total family income that does not exceed the higher of—
(I) the poverty line; or
(II) 70 percent of the lower living standard income level;
(iii) is a homeless individual (as defined in Section 41403(6) of the Violence Against Women
Act of 1994 (42 .S.C. 14043e–2(6))), or a homeless child or youth (as defined under Section
725(2) of the McKinney-Vento Homeless Assistance Act (42 U.S.C. 11434a(2)));
(iv) receives or is eligible to receive a free or reduced price lunch under the Richard B.
Russell National School Lunch Act (42 U.S.C. 1751 et seq.);
(v) is a foster child on behalf of whom State or local government payments are made; or
(vi) is an individual with a disability whose own income meets the income requirement of
clause (ii), but who is a member of a family whose income does not meet this requirement.
There is one additional low-income category not included in WIOA Section 3(36) above that
applies only to youth. According to Section 129(a)(2) of WIOA, for both ISY and OSY, a
youth qualifies as low income if the youth lives in a high-poverty area. See Attachment II for
additional information on determining if a youth is living in a high-poverty area.
In addition, as discussed above, an ISY who receives or is eligible to receive free or reduced
price lunch would meet the low-income requirement. Note that some school districts
subsidize all student meals from the Community Eligibility Provision (CEP) Healthy,
Hunger-Free Kids Act of 2010. When a school does not use individual eligibility criteria to
determine who is eligible for free or reduced price lunch, whole school receipt of free or
reduced price lunch cannot be used to determine WIOA low-income status for ISY. In
schools where the whole school automatically receives free or reduced price lunch, WIOA
programs must base low-income status on an individual student’s eligibility to receive free or
reduced price lunch or on meeting one of the other low-income categories under WIOA.
Local programs can check with their local school districts for determining whether individual
students are eligible to receive free or reduced price lunch. While the free/reduced lunch
low-income category primarily applies to ISY, there is one exception where it could apply to
an OSY. If an OSY is a parent living in the same household as a child who receives or is
eligible to receive free or reduced price lunch based on their income level, then such an OSY
would meet the low-income criteria based on his/her child’s qualification.
As described in WIOA 20 CFR § 681.250(c), WIOA allows a low-income exception where
five percent of WIOA youth may be participants who ordinarily would be required to be low-
income for eligibility purposes and meet all other eligibility criteria for WIOA youth except
the low-income criteria. A program must calculate the five percent based on the percent of
newly enrolled youth in the local area’s WIOA youth program in a given program year who
would ordinarily be required to meet the low-income criteria. It is not based on all youth
since many of the OSY categories do not require low-income status. In fact, as discussed
above, only two categories of OSY require low-income status. Because not all OSY are
required to be low-income, the 5 percent low-income exception under WIOA is calculated
based on the 5 percent of youth enrolled in a given program year who would ordinarily be
required to meet the low-income criteria.
For example, a local area enrolled 200 youth and 100 of those youth were OSY who were not
required to meet the low-income criteria, 50 were OSY who were required to meet the low-
income criteria (i.e., either 20 CFR § 681.210(c)(3) or (c)(9)), and 50 were ISY. In this
example the 50 OSY required to be low-income and the 50 ISY are the only youth factored
into the 5 percent low-income exception calculation. Therefore, in this example, 5 of the 100
youth who ordinarily would be required to be low-income do not have to meet the low-
income criteria based on the low-income exception. This percent is calculated at the end of a
program year based on new enrollees in that program year.
Lower Living Standard Income Level (LLSIL). Another option for determining low-income
eligibility is based on family income. A youth is considered low income if the youth is in a
family with a total family income that does not exceed the higher of the poverty line or 70
percent of the LLSIL, except in cases where only the youth’s income is considered as
discussed below. The LLSIL is published annually by ETA at: LLSIL and includes income
charts that are used by state and local workforce investment areas to determine income
eligibility based on family size and income for the WIOA youth and certain adult services.
What counts as income? DOL received several questions asking about what counts as
income when determining a youth’s low-income status. The definition of what counts as
income when determining a youth’s low-income status has changed under WIOA. It is
important to know that the definition of a low-income individual at Section 3(36) does not
exclude unemployment compensation or child support payments from income calculations.
Therefore, WIOA youth programs must include Unemployment Insurance and child support
payments as income when determining a youth’s eligibility based on low-income status. As
discussed above in the list of low income qualifications in WIOA Section 3(36), homeless
and foster youth are considered low income and do not need to meet any additional low-
income criteria.
When do you consider only a youth’s income? There are circumstances where only the
youth’s income is considered in determining whether the youth satisfies WIOA income limits
for the program. 20 CFR § 681.280 provides that OSY with a disability are not required to
be low-income and for ISY with a disability, the youth’s own income, rather his or her
family’s income, must meet the low-income definition and not exceed the higher of the
poverty line or 70 percent of the LLSIL.
Additionally, if an individual is not living in a single residence with other family members,
that individual is not a member of a family for the purpose of WIOA income calculations. 20
CFR § 675.300 defines family as “two or more persons related by blood, marriage, or decree
of court, who are living in a single residence, and are included in one or more of the
following categories: (1) A married couple and dependent children; (2) A parent or guardian
and dependent children; or (3) A married couple.”
5. Program Design.
Program Expenditures Prior to Participation
There are limited instances where WIOA youth funds may be expended on costs related to
individuals who are not yet participants in the WIOA youth program. Youth funds can be
expended on outreach and recruitment or assessment for eligibility determination (such as
assessing basic skills level) prior to eligibility determination, but they cannot be spent on
youth program services, such as the 14 program elements which are described in section 7,
prior to eligibility determination.
Assessment Requirements
The WIOA youth program design 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. Assessments must also consider a youth’s strengths
rather than just focusing on areas that need improvement.
As discussed in 20 CFR § 681.290, “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.” For purposes of the basic skills assessment portion of the objective
assessment, local programs are not required to use assessments approved for use in the
Department of Education’s National Reporting System (NRS), nor are they required to
determine an individual’s grade level equivalent or educational functioning level (EFL),
although use of these tools is permitted. Rather, local programs may use other formalized
testing instruments designed to measure skills-related gains. It is important that, in addition
to being valid and reliable, any formalized testing used be appropriate, fair, cost effective,
well-matched to the test administrator’s qualifications, and easy to administer and interpret
results. Alternatively, skills related gains may also be determined through less formal
alternative assessment techniques such as observation, folder reviews, or interviews. The
latter may be particularly appropriate for youth with disabilities given accessibility issues
related to formalized instruments. Local programs may use previous basic skills assessment
results if such previous assessments have been conducted within the past six months.
In contrast to the initial assessment described above, if measuring EFL gains after program
enrollment under the measurable skill gains indicator, local programs must use an NRS-
approved assessment for both the EFL pre- and post-test to determine an individual’s
educational functioning level.
Career-Related Assessments
All youth, including youth with disabilities, can benefit from participation in career
assessment activities, including, but not limited to, assessments of prior work experience,
employability, interests, and aptitudes. Multiple assessment tools may be necessary since
there is no standard approach that will work for all youth, including youth with disabilities.
Career assessments help youth, including those with disabilities, understand how a variety of
their personal attributes (e.g., interests, values, preferences, motivations, aptitudes, and skills)
affect their potential success and satisfaction with different career options and work
environments. Youth also need access to reliable information about career opportunities
(based on labor market information) that provide a living wage, including information about
education, entry requirements, and income potential. Youth with disabilities also may need
information on benefits planning, work place supports (e.g., assistive technology), and
accommodations, and also may benefit from less formalized career-related assessments such
as discovery techniques. These assessments may be provided directly through WIOA youth
program staff, and/or through referrals to national and community-based partners and
resources.
Serving 18 to 24 year old youth
As discussed in 20 CFR § 681.430, “individuals who meet the respective program eligibility
requirements may participate in WIOA Title I adult and youth programs concurrently. Such
individuals must be eligible under the youth or adult eligibility criteria applicable to the
services received. Local program operators may determine, for these individuals, the best
mix of services under the youth and adult programs.”
School status at time of enrollment may determine which program options are appropriate for
this population because young adults who are in school are only eligible for the Title I youth
program if they are 21 or younger at the time of enrollment.
Some 18 to 24 year olds may be ready for adult services due to life experiences such as
having gained occupational skills through education or training, prior work experiences,
adult schedules, family responsibilities, and the participant’s needs. Others need specific
youth services covered in the 14 WIOA youth program elements based on characteristics
such as maturity, drug and alcohol abuse, homelessness, foster care status, family
abuse/neglect, literacy challenges, pregnancy, and lack of employability skills. Assessments
of their skills, career-readiness, literacy, and supportive service needs should be taken into
consideration when determining the appropriate program(s) for young adults.
As discussed in 20 CFR § 681.430, if a young adult’s needs can best be met by co-enrollment
in the WIOA Title I youth and adult programs, “local program operators must identify and
track the funding streams which pay the costs of services provided to individuals who are
participating in youth and adult programs concurrently, and ensure no duplication of
services.”
Use of Statewide Funds
20 CFR § 681.410(a) provides that “only statewide funds spent on direct services to youth
are subject to the OSY expenditure requirement. Funds spent on statewide youth activities
that do not provide direct services to youth, such as many of the required statewide youth
activities, are not subject to the out-of-school expenditure requirements.” The following
services under Section 129(b)(1) of WIOA, which lists the required statewide youth
activities, are not considered direct services: conducting evaluations, disseminating a list of
eligible providers of youth services, providing assistance to local areas, operating fiscal and
management accountability information systems, and providing additional assistance to local
areas that have high concentration of eligible youth.
DOL considers “direct services” as those services delivered by local program staff or service
providers (e.g., staff-assisted services). For example, demonstration projects related to
meeting the education and employment needs of eligible youth is an allowable statewide
youth activity. Youth participating in such demonstration projects would be considered
receiving direct services from statewide funds. When a youth accesses services through a
self-service process such as job searches, career exploration, or use of career center
resources, these activities are not considered direct services. If the services provided with
statewide funds are “direct services”, the eligibility requirements for youth are the same as
those that apply to Title I Youth services provided by local areas. Youth who receive direct
services funded by statewide funds are considered WIOA youth participants provided that
they otherwise meet the definition of participant in 20 CFR § 677.150 and must be reported
as such in the WIOA DOL-only Participant Individual Record Layout (PIRL).
Incentives
20 CFR § 681.640 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 § 681.640.
Braiding funds
WIOA does not prohibit the braiding of funds. This resource allocation strategy occurs when
different funding streams are used together to support different needs for the same customer
while maintaining documentation to support the charging and allocation of costs to multiple
separate funding streams or programs. As specified in the Uniform Guidance at 2 CFR
405(d), if a cost benefits two or more projects or activities in proportions that can be
determined without undue effort or cost, the cost must be allocated to the programs or
activities based on the proportional benefit. In addition each funding stream maintains its
statutory requirements, including eligibility criteria and scope of authorized activities.
Braiding funds allows a WIOA youth program to provide more comprehensive services to
participants while maximizing partner resources available to assist youth. For example, the
Title I WIOA Youth program and the WIOA Title II Adult Education program can provide
complementary services to youth and can be used together (braided) to serve eligible youth
ages 16-24 where each program’s age eligibility overlaps. When used together, these two
funding sources can increase the capacity of programs to help young adults meet their
employment and educational goals. An organization that receives both Title I Youth funding
and Title II Adult Education funding or partners with a program that receives Title II funding
may braid these funds and enroll eligible youth into both programs. Title I resources can be
utilized to provide youth with such services as career guidance, exploration, and planning;
work experience; and leadership development; Title II resources support adult education and
literacy activities, including preparation for obtaining a recognized high school equivalency,
or workplace adult education and literacy activities, family literacy activities, English
language acquisition activities, integrated English literacy and civics education, workforce
preparation activities, or integrated education and training. WIOA sec. 203(2). Integrated
education and training, a service approach that provides adult education and literacy
activities concurrently and contextually with workforce preparation activities and workforce
training for a specific occupation or occupational cluster for the purpose of educational and
career advancement, is particularly well-suited to a braided funding model. WIOA sec.
203(11).
6. Competitive Procurement.
One of the responsibilities of Local Workforce Development Boards (Local WDBs) includes
selection of providers of youth workforce investment activities through competitive grants or
contracts. Competition is expected to improve the delivery of efficient, effective youth
workforce services. When a Local WDB awards grants or contracts to youth service
providers to carry out youth workforce investment activities, it must identify youth service
providers based on criteria established in the State Plan and take into consideration the ability
of the provider to meet performance accountability measures based on the primary indicators
of performance for youth programs. The Local WDB must also award such grants or
contracts on a competitive basis and in accordance with the Procurement Standards found at
Uniform Guidance at 2 CFR parts 200 and 2900, in addition to applicable State and local
procurement laws. The Uniform Guidance at 2 CFR 200.317 requires States to adhere to the
same procurement procedures it uses for non-Federal funds for procurements using Federal
funds when it is responsible for conducting the procurement. There is one exception to the
requirement of competitive procurement--a Local WDB may award sole-source contracts if it
determines an insufficient number of providers exist in the local area (see Section 107(d)(10),
20 CFR § 679.370(l)(1), and Section 123).
The Department interprets the competitive selection provisions discussed in WIOA Section
107(d)(10) and 123 to apply only if the Local WDB provides youth services by awarding
grants or contracts to youth service providers. Consistent with 20 CFR § 681.400, a Local
WDB may determine that the grant recipient or designated fiscal agent may “provide directly
some or all of the youth workforce investment activities.” DOL intends for the flexibility
provided by 20 CFR § 681.400 to allow Local WDBs to determine whether to directly
provide the WIOA youth program elements that they can most efficiently and cost-
effectively provide, such as labor market and employment information and services that are
part of program design including assessment, supportive services and follow-up services.
While this rule represents a change from WIA by providing Local WDBs with flexibility to
determine how to most efficiently provide youth services, DOL expects Local WDBs to use
youth service providers best positioned to provide program elements resulting in strong
outcomes. DOL encourages Local WDBs to award contracts to youth service providers,
using a competitive procurement process, when local areas have access to experienced and
effective youth service providers.
If a State chooses to do so, it has the authority to set policy requiring Local WDBs to
competitively select some or all youth services. The State as grant recipient has the ultimate
accountability to DOL for the performance of the Youth program, including outcomes and
fiscal integrity. States, therefore, have the authority to establish statewide policies regarding
the provision of youth activities that the State determines are likely to enhance the
performance of the Youth program.
If Local WDBs decide to directly provide youth services, DOL recognizes that situations
may arise where a single entity performs multiple roles, such as fiscal agent, service
provider, or One-Stop operator. In such situations, 20 CFR § 679.430 requires “a written
agreement with the Local WDB and Chief Elected Official (CEO) to clarify how the
organization will carry out its responsibilities while demonstrating compliance with WIOA
and corresponding regulations, relevant Office of Management and Budget circulars, and the
State’s conflict of interest policy.” Furthermore, separation of roles for staff to the Local
WDB and the role of the fiscal agent described in 20 CFR §s 679.400 and 679.420,
respectively, provide more clarity on the distinct functions of these entities. When youth
services are provided by an entity that fulfills another role in the local area, the agreement
with the Local WDB and CEO must provide clarity on the expectations for those roles and
clear methods of tracking effective execution and accountability for the distinct roles.
7. Program Elements.
This section contains descriptions for each of the 14 WIOA youth program elements. 20 CFR
§ 681.460 lists all of the program elements and provides further explanation of some of the
elements, but not all of them. Additionally, there is overlap between portions of some
program elements. The following discussion further clarifies the 14 program elements and
explains the services to be reported under each specific program element. In addition, the
table below provides an overview and easy reference for finding applicable program element
citations, identifies which program elements relate to one another, and lists applicable DOL-
only PIRL data elements. These clarifications will facilitate the consistent reporting of
services across states and local areas and prevent duplicated reporting of the same service in
multiple reporting categories.
Is the element
further described Relates to or
WIOA Youth Program Applicable PIRL Data
in Final Rule? If overlaps with other
Element Section 129(c)(2) Element Number(s)
so, applicable program element1
citations
1. Tutoring, study skills training,
Program elements 2 and
instruction, and dropout No 1402
prevention
2. Alternative secondary school
services or dropout recovery No Program element 1 1403
services
3. Paid and unpaid work Yes, 681.600,
1205, 1405
experience 681.590, 681.480
Yes, 681.540, 1300, 1302, 1303, 1306,
4. Occupational skills training Program element 1
681.550 1307, 1308,
5. Education offered concurrently
Program elements 2, 3,
with workforce preparation and Yes, 681.630 1407
and 4
training for a specific occupation
6. Leadership development Yes, 681.520,
opportunities 681.530
7. Supportive services Yes, 681.570 1409
8. Adult mentoring Yes, 681.490 1410
Program elements 7, 8,
9. Follow-up services Yes, 681.580 1412
11, 13, and 14
10. Comprehensive guidance and
Yes, 681.510 1411
counseling
11. Financial literacy education Yes, 681.500 1206
12. Entrepreneurial skills training Yes, 681.560 1413
13. Services that provide labor
Yes, 651.10 1414
market information
14. Postsecondary preparation
No 1415
and transition activities
1 Section 7 of the TEGL describes how overlapping portions of each element should be categorized.
Program Element 1: Tutoring, study skills training, instruction, and dropout prevention
services
In 20 CFR § 681.460 (a)(1), this is the first program element listed and includes “tutoring,
study skills training, instruction and evidence-based dropout prevention and recovery
strategies that lead to completion of the requirements for a secondary school diploma or its
recognized equivalent (including a recognized certificate of attendance or similar document
for individuals with disabilities) or for a recognized postsecondary credential.” This program
element was not further explained in the final rule.
Tutoring, study skills training, and instruction that lead to a high school diploma are reported
under this program element. Such services focus on providing academic support, helping a
youth identify areas of academic concern, assisting with overcoming learning obstacles, and
providing tools and resources to develop learning strategies. Tutoring, study skills training,
and instruction can be provided one-on-one, in a group setting, through resources and
workshops.
Secondary school dropout prevention strategies intended to lead to a high school diploma are
also reported under this program element. Secondary school dropout prevention strategies
include services and activities that keep a young person in-school and engaged in a formal
learning and/or training setting. Strategies include, but are not limited to tutoring, literacy
development, active learning experiences, after-school opportunities, and individualized
instruction.
On the other hand, while dropout recovery strategies that lead to completion of a recognized
high school equivalency are included in both this first program element and in program
element 2 in 20 CFR § 681.460 (a)(2) described below, those services are not reported under
this program element. For documentation purposes, those services aimed at getting a youth
who has dropped out of secondary education back into a secondary school or alternative
secondary school/high school equivalency program and preparing them for high school
equivalency attainment, should be counted under program element 2 (20 CFR § 681.460
(a)(2)).
Furthermore, while the statutory and regulatory language for both program elements 1 and 4
(discussed below) include language discussing services leading to recognized postsecondary
credentials, training services that lead to recognized postsecondary credentials should be
reported under program element 4, occupational skills training to avoid duplicated reporting
of services.
Program Element 2: Alternative secondary school services or dropout recovery services
This element was not further explained in the Final Rule. Under 20 CFR § 681.460 (a)(2),
alternative secondary school services, such as basic education skills training, individualized
academic instruction, and English as a Second Language training, are those that assist youth
who have struggled in traditional secondary education. Dropout recovery services, such as
credit recovery, counseling, and educational plan development, are those that assist youth
who have dropped out of school. While the activities within both types of services may
overlap, each are provided with the goal of helping youth to re-engage and persist in
education that leads to the completion of a recognized high school equivalent.
Program Element 3: Paid and unpaid work experience
20 CFR § 681.600 further defines work experience as “a planned, structured learning
experience that takes place in a workplace for a limited period of time. Work experience
may be paid or unpaid, as appropriate. A work experience may take place in the private for-
profit sector, the non-profit sector, or the public sector. Labor standards apply in any work
experience where an employee/employer relationship, as defined by the Fair Labor Standards
Act or applicable State law, exists. Consistent with § 680.840 . . . , funds provided for work
experiences may not be used to directly or indirectly aid in the filling of a job opening that is
vacant because the former occupant is on strike, or is being locked out in the course of a
labor dispute, or the filling of which is otherwise an issue in a labor dispute involving a work
stoppage. Work experiences provide the youth participant with opportunities for career
exploration and skill development.” Additional information on the employer/employee
relationship may be found on DOL’s Wage and Hour Division website.
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. As explained in 20 CFR §
681.590(b), local area administrative costs are not subject to the 20 percent minimum work
experience expenditure requirement. Leveraged resources cannot be used to fulfill any part
of the 20 percent minimum.
TEGL No. 8-15 provides further 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 include the following:
• Wages/stipends paid for participation in a work experience;
• Staff time working to identify and develop a work experience opportunity, including
staff time spent working with employers to identify and develop the work experience;
• Staff time working with employers to ensure a successful work experience, including
staff time spent managing the work experience;
• Staff time spent evaluating the work experience;
• Participant work experience orientation sessions;
• Employer work experience orientation sessions;
• Classroom training or the required academic education component directly related to
the work experience;
• Incentive payments directly tied to the completion of work experience; and
• Employability skills/job readiness training to prepare youth for a work experience.
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.
Academic and occupational education component. As discussed in 20 CFR § 681.600, work
experiences must include academic and occupational education. The educational component
may occur concurrently or sequentially with the work experience. The academic and
occupational education component may occur inside or outside the work site. The work
experience employer can provide the academic and occupational component or such
components may be provided separately in the classroom or through other means. States and
local areas have the flexibility to decide who provides the education component.
The academic and occupational education component refers to contextual learning that
accompanies a work experience. It includes the information necessary to understand and
work in specific industries and/or occupations. For example, if a youth is in a work
experience in a hospital, the occupational education could be learning about the duties of
different types of hospital occupations such as a phlebotomist, radiology tech, or physical
therapist. Whereas, the academic education could be learning some of the information
individuals in those occupations need to know such as why blood type matters, the name of a
specific bone in the body, or the function of a specific ligament. Local programs have the
flexibility to determine the appropriate type of academic and occupational education
necessary for a specific work experience.
Categories of work experience. WIOA identifies four categories of work experience: (1)
summer employment opportunities and other employment opportunities available throughout
the school year; (2) pre-apprenticeship programs; (3) internships and job shadowing; and (4)
on-the-job training (OJT) opportunities as defined in WIOA Section 3(44) and in 20 CFR §
680.700. Two of the categories, job shadowing and pre-apprenticeship, are discussed below.
Job shadowing is a work experience option where youth learn about a job by walking
through the work day as a shadow to a competent worker. The job shadowing work
experience is a temporary, unpaid exposure to the workplace in an occupational area of
interest to the participant. Youth witness firsthand the work environment, employability and
occupational skills in practice, the value of professional training, and potential career options.
A job-shadowing experience can be anywhere from a few hours, to a day, to a week or more.
Job shadowing is designed to increase career awareness, help model youth behavior through
examples, and reinforce in the youth and young adult the link between academic classroom
learning and occupational work requirements. It provides an opportunity for youth to
conduct short interviews with people in their prospective professions to learn more about
those fields. Job shadowing can be thought of as an expanded informational interview. By
experiencing a workplace first-hand, youth can learn a great deal more about a career than
through research in print publications and on the Internet.
As discussed in 20 CFR § 681.480, 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. . . [and] referred to
... as a registered apprenticeship or registered apprenticeship program) and includes the
following elements: (a) training and curriculum that aligns with the skill needs of employers
in the economy of the State or region involved; (b) access to educational and career
counseling and other supportive services, directly or indirectly; (c) 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; (d) opportunities to attain at least one industry-recognized credential;
and (e) 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.
Program Element 4: Occupational skills training
As stated in 20 CFR § 681.540 of the final rule, occupational skills training is defined as an
organized program of study that provides specific vocational skills that lead to proficiency in
performing actual tasks and technical functions required by certain occupational fields at
entry, intermediate, or advanced levels. Local areas must give priority consideration to
training programs that lead to recognized postsecondary credentials that align with in-
demand industry sectors or occupations in the local area. Such training must:
(1) be outcome-oriented and focused on an occupational goal specified in the individual
service strategy;
(2) be of sufficient duration to impart the skills needed to meet the occupational goal;
and
(3) lead to the attainment of a recognized postsecondary credential.
In addition, the chosen occupational skills training must meet the quality standards in WIOA
Section 123.
As discussed in 20 CFR § 681.550 “in order to enhance individual participant choice in
education and training plans and provide flexibility to service providers, the Department
allows WIOA Individual Training Accounts (ITAs) for OSY, ages 16 to 24, using WIOA
youth funds, when appropriate.” ITAs allow participants the opportunity to choose the
training provider that best meets their needs. To receive funds from an ITA, the training
provider must be on the Eligible Training Provider List as outlined in § 680.400 and 680.410.
ISY cannot use youth program-funded ITAs. However, ISY between the ages of 18 and 21
may co-enroll in the WIOA Adult program if the young adult’s individual needs, knowledge,
skills, and interests align with the WIOA adult program and may receive training services
through an ITA funded by the adult program.
Program Element 5: Education offered concurrently with workforce preparation and training
for a specific occupation
20 CFR § 681.630 states that this program element reflects an integrated education and
training model and describes how workforce preparation activities, basic academic skills, and
hands-on occupational skills training are to be taught within the same time frame and
connected to training in a specific occupation, occupational cluster, or career pathway.
While programs developing basic academic skills, which are included as part of alternative
secondary school services and dropout recovery services (program element 2), workforce
preparation activities that occur as part of a work experience (program element 3), and
occupational skills training (program element 4) can all occur separately and at different
times (and thus are counted under separate program elements), this program element refers to
the concurrent delivery of these services which make up an integrated education and training
model.
Program Element 6: Leadership development opportunities
20 CFR § 681.520 defines this program element as opportunities that encourage
responsibility, confidence, employability, self-determination, and other positive social
behaviors such as: (a) exposure to postsecondary educational possibilities; (b) community
and service learning projects; (c) peer-centered activities, including peer mentoring and
tutoring; (d) organizational and team work training, including team leadership training; (e)
training in decision-making, including determining priorities and problem solving; (f)
citizenship training, including life skills training such as parenting and work behavior
training; (g) civic engagement activities which promote the quality of life in a community;
and (h) other leadership activities that place youth in a leadership role such as serving on
youth leadership committees, such as a Standing Youth Committee.
Program Element 7: Supportive services
20 CFR § 681.570 describes supportive services for youth as defined in WIOA Sec. 3(59),
are services that enable an individual to participate in WIOA activities. These services
include, but are not limited to, the following: (a) linkages to community services; (b)
assistance with transportation; (c) assistance with child care and dependent care; (d)
assistance with housing; (e) needs-related payments; (f) assistance with educational testing;
(g) reasonable accommodations for youth with disabilities; (h) legal aid services; (i) referrals
to health care; (j) assistance with uniforms or other appropriate work attire and work-related
tools, including such items as eyeglasses and protective eye gear; (k) assistance with books,
fees, school supplies, and other necessary items for students enrolled in postsecondary
education classes; and (l) payments and fees for employment and training-related
applications, tests, and certifications.
Program Element 8: Adult mentoring
20 CFR § 681.490 states that adult mentoring must last at least 12 months and may take place
both during the program and following exit from the program and be a formal relationship
between a youth participant and an adult mentor that includes structured activities where the
mentor offers guidance, support, and encouragement to develop the competence and
character of the mentee. The final rule also states that while group mentoring activities and
mentoring through electronic means are allowable as part of the mentoring activities, at a
minimum, the local youth program must match the youth with an individual mentor with
whom the youth interacts on a face-to-face basis. Mentoring may include workplace
mentoring where the local program matches a youth participant with an employer or
employee of a company. Local programs should ensure appropriate processes are in place to
adequately screen and select mentors.
DOL acknowledges that in a few areas of the country finding mentors may present a burden
to a program. While DOL strongly prefers that case managers not serve as mentors, the final
rule allows case managers to serve as mentors in areas where adult mentors are sparse.
Program Element 9: Follow-up services
20 CFR § 681.580 describes follow-up services as “critical services provided following a
youth’s exit from the program to help ensure the youth is successful in employment and/or
postsecondary education and training. Follow-up services may include regular contact with a
youth participant's employer, including assistance in addressing work-related problems that
arise.” Follow-up services may begin immediately following the last expected date of
service in the Youth program (and any other DOL program in which the participant is co-
enrolled if the state is using a common exit policy as discussed in TEGL No. 10-16) when no
future services are scheduled. Follow-up services do not cause the exit date to change and do
not trigger re-enrollment in the program.
The exit date is determined when the participant has not received services in the Youth
program or any other DOL-funded program in which the participant is co-enrolled for 90
days and no additional services are scheduled. At that point, the date of exit is applied
retroactively to the last date of service. Once 90 days of no services, other than follow-up
services, self-service, and information-only services and activities, has elapsed and the
participant has an official exit date applied retroactively to the last date of service, the
program continues to provide follow-up services for the remaining 275 days of the 12-month
follow-up requirement. The 12-month follow-up requirement is completed upon one year
from the date of exit.
The final rule also states that follow-up services for youth also may include the following
program elements: (1) supportive services; (2) adult mentoring; (3) financial literacy
education; (4) 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; and (5) activities that help youth prepare
for and transition to postsecondary education and training. Provision of these program
elements must occur after the exit date in order to count as follow-up services. DOL
recommends that when these services are provided as follow-up services they are coded as
follow-up services in state/local management information systems as opposed to program
services provided prior to program exit so that management information systems clearly
differentiate follow-up services from those services provided prior to exit. In addition, such
follow-up services should be documented in the case file that they were provided as follow-
up services post exit.
20 CFR § 681.580 states that all youth participants must be offered an opportunity to receive
follow-up services that align with their individual service strategies. Furthermore, follow-up
services must be provided to all participants for a minimum of 12 months unless the
participant declines to receive follow-up services or the participant cannot be located or
contacted. Follow-up services may be provided beyond 12 months at the State or Local
WDB's discretion. The types of services provided and the duration of services must be
determined based on the needs of the individual and therefore, the type and intensity of
follow-up services may differ for each participant. Follow-up services must include more
than only a contact attempted or made for securing documentation in order to report a
performance outcome.
DOL recognizes the concerns that some youth may not be responsive to attempted contacts
for follow-up, and other youth may be difficult to locate making it impossible to provide
follow-up services for such individuals. Local programs should have policies in place to
establish how to document and record when a participant cannot be located or contacted. At
the time of enrollment, youth must be informed that follow-up services will be provided for
12 months following exit. If at any point in time during the program or during the 12 months
following exit the youth requests to opt out of follow-up services, they may do so. In this
case, the request to opt out or discontinue follow-up services made by the youth must be
documented in the case file.
Program Element 10: Comprehensive guidance and counseling
20 CFR § 681.510 states that 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 local youth program must coordinate with the organization it refers to
in order to ensure continuity of service. When resources exist within the local program or its
service providers, it is allowable to provide counseling services directly to participants rather
than refer youth to partner programs.
Program Element 11: Financial literacy education
20 CFR § 681.500 states that this program element may include the following activities:
• support the ability of participants to create budgets, initiate checking and savings
accounts at banks, and make informed financial decisions
• support participants in learning how to effectively manage spending, credit, and debt,
including student loans, consumer credit, and credit cards
• teach participants about the significance of credit reports and credit scores; what their
rights are regarding their credit and financial information; how to determine the accuracy
of a credit report and how to correct inaccuracies; and how to improve or maintain good
credit
• support a participant’s ability to understand, evaluate, and compare financial products,
services, and opportunities and to make informed financial decisions
• educate participants about identity theft, ways to protect themselves from identify theft,
and how to resolve cases of identity theft and in other ways understand their rights and
protections related to personal identity and financial data
• support activities that address the particular financial literacy needs of non-English
speakers, including providing the support through the development and distribution of
multilingual financial literacy and education materials
• support activities that address the particular financial literacy needs of youth with
disabilities, including connecting them to benefits planning and work incentives
counseling
• provide financial education that is age appropriate, timely, and provides opportunities to
put lessons into practice, such as by access to safe and affordable financial products that
enable money management and savings
• implement other approaches to help participants gain the knowledge, skills, and
confidence to make informed financial decisions that enable them to attain greater
financial health and stability by using high quality, age-appropriate, and relevant
strategies and channels, including, where possible, timely and customized information,
guidance, tools, and instruction.
In November of 2016, the Financial Literacy Education Commission released a guide,
“Incorporating Financial Capability into Youth Employment Programs,” aimed at financial
institutions interested in enhancing youth financial capability by partnering with youth
employment programs. It maps how and why financial institutions engage in helping young
people achieve greater financial well-being and employment success and can be found at:
Financial Literacy Guide.
Program Element 12: Entrepreneurial skills training
20 CFR § 681.560 states this program element provides the basics of starting and operating a
small business. Such training must develop the skills associated with entrepreneurship. Such
skills may include, but are not limited to, the ability to:
• take initiative;
• creatively seek out and identify business opportunities;
• develop budgets and forecast resource needs;
• understand various options for acquiring capital and the trade-offs associated with each
option; and
• communicate effectively and market oneself and one’s ideas.
Approaches to teaching youth entrepreneurial skills may include, but are not limited to:
(1) Entrepreneurship education that provides an introduction to the values and basics of
starting and running a business. Entrepreneurship education programs often guide youth
through the development of a business plan and also may include simulations of business
start-up and operation.
(2) Enterprise development which provides supports and services that incubate and help
youth develop their own businesses. Enterprise development programs go beyond
entrepreneurship education by helping youth access small loans or grants that are needed
to begin business operation and by providing more individualized attention to the
development of viable business ideas.
(3) Experiential programs that provide youth with experience in the day-to-day operation
of a business. These programs may involve the development of a youth-run business that
young people participating in the program work in and manage. Or, they may facilitate
placement in apprentice or internship positions with adult entrepreneurs in the
community.
Program Element 13: Services that provide labor market information
Under 20 CFR § 681.460 (a)(13), this element includes “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.”
This element is not further described in the Youth section of the final rule; however, the
Wagner-Peyser regulation at 20 CFR § 651.10 provides additional information about this
element under the definition of workforce and labor market information. That section
defines workforce and labor market information as “the body of knowledge that describes the
relationship between labor demand and supply.” Numerous tools and applications that are
user-friendly exist, which can be used to provide labor market and career information, as
appropriate to each youth. These labor market information (LMI) tools can be used to help
youth and young adults to make appropriate decisions about education and careers. LMI
identifies in-demand industries and occupations and employment opportunities; and, provides
knowledge of job market expectations including education and skills requirements and
potential earnings. LMI tools also can aid in facilitating youth awareness of the career fields
that are likely to provide long-term employment and earnings in local labor markets.
WIOA youth programs and providers should become familiar with state and federal LMI
data and LMI tools, which are provided for free by agencies, in order to share relevant LMI
with youth. Providing such readily available online services can be accomplished by
connecting the youth with American Job Centers and other entities that have career
exploration tools, ability and interest inventories, and provide related employment services.
DOL electronic tools particularly relevant to youth include My Next Move and Get My
Future. In addition to connecting youth to self-service LMI tools, it is important for youth
providers to share and discuss state and local LMI with youth participants.
In general, career awareness begins the process of developing knowledge of the variety of
careers and occupations available, their skill requirements, working conditions and training
prerequisites, and job opportunities across a wide range of industry sectors. The process in
which youth choose an educational path and training or a job which fits their interests, skills
and abilities can be described as career exploration. Career counseling or guidance provides
advice and support in making decisions about what career paths to take. 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 (e.g., increased earning power and career mobility).
Program Element 14: Postsecondary preparation and transition activities
In 20 CFR § 681.460 (a)(14), the final program element is activities that help youth prepare
for and transition to postsecondary education and training. This element is not further
described in the final rule. Postsecondary preparation and transition activities and services
prepare ISY and OSY for advancement to postsecondary education after attaining a high
school diploma or its recognized equivalent. These services include exploring postsecondary
education options including technical training schools, community colleges, 4-year colleges
and universities, and registered apprenticeship. Additional services include, but are not
limited to, assisting youth to prepare for SAT/ACT testing; assisting with college admission
applications; searching and applying for scholarships and grants; filling out the proper
Financial Aid applications and adhering to changing guidelines; and connecting youth to
postsecondary education programs.
Additional Notes on Documenting and Reporting Program Elements
Documenting receipt of program elements is critical to ensure that youth who are actively
participating in programs do not get unintentionally exited due to 90 days of no service. All
14 WIOA youth program elements are contained in the PIRL and local youth programs
should ensure that services received are reported in the applicable program element in the
PIRL.
In addition, note that case management is the act of connecting youth to appropriate services
and not a program element. Case managers providing case management should not be
reported as one of the 14 youth program elements in the PIRL.
8. Inquiries. All inquiries should be directed to the appropriate ETA regional office.
9. Attachments. References and Determining Whether Youth are Living in a High Poverty
Area.
Attachment (official PDF: https://www.dol.gov/sites/dolgov/files/ETA/advisories/TEGL/2017/TEGL_21-16_Attachment_1.pdf)
Attachment 1
WIOA Operating Guidance TEGL References
• The Workforce Innovation and Opportunity Act (WIOA) (Public Law (Pub. L.) 113-
128)) Titles I and IV, enacted July 22, 2014;
• WIOA Regulations at 20 CFR part 681;
• The Workforce Investment Act (WIA) of 1998 (Pub. L. 105-220), Title I;
• Training and Employment Guidance Letter (TEGL) No. 10-16, Performance
Accountability Guidance for Workforce Innovation and Opportunity Act (WIOA) Title I,
Title II, Title III and Title IV Core Programs;
• TEGL No. 8-15, Second Title I WIOA Youth Program Transition Guidance;
• TEGL No. 1-15, Operations Guidance Regarding the Impact of Workforce Innovation
and Opportunity Act Implementation on Waivers Approved Under the Workforce
Investment Act;
• TEGL No. 38-14, Operational Guidance to Support the Orderly Transition of Workforce
Investment Act Participants, Funds, and Subrecipient Contracts to the Workforce
Innovation and Opportunity Act of 2014;
• TEGL No. 23-14, Workforce Innovation and Opportunity Act Youth Program Transition;
• TEGL No. 19-14, Vision for the Workforce System and Initial Implementation of the
Workforce Innovation and Opportunity Act;
• TEGL No. 12-14, Allowable Uses and Funding Limits of Workforce Investment Act
(WIA) Program Year (PY) 2014 funds for Workforce Innovation and Opportunity Act
(WIOA) Transitional Activities.
Attachment (official PDF: https://www.dol.gov/sites/dolgov/files/ETA/advisories/TEGL/2017/TEGL_21-16_Attachment_2.pdf)
Attachment 2
Determining Whether Youth are Living in a High Poverty Area
Instructions for Using Census Data to Determine High-Poverty Geographical Areas
Introduction
The Workforce Innovation and Opportunity Act (WIOA) Title I Youth Program contains a new
provision that allows for youth living in a high poverty area to automatically meet the low-
income criterion that is one of the eligibility criteria for in-school youth, for some out-of-school
youth in the WIOA youth program, and for youth in the Indian and Native American
Supplemental Youth Program. The WIOA regulations at 20 CFR § 681.260 define high-poverty
areas as a Census tract, a set of contiguous Census tracts, an American Indian Reservation,
Oklahoma Tribal Statistical Area (as defined by the U.S. Census Bureau), Alaska Native Village
Statistical Area or Alaska Native Regional Corporation Area, Native Hawaiian Homeland Area, or
other tribal land as defined by the Secretary in guidance or county that has a poverty rate of at
least 25 percent as set every 5 years using American Community Survey 5-Year data. The
regulations at 20 CFR § 684.130 allow Indian and Native American grantees to use either the
poverty rate of the total population or the poverty rate of Indian and Native Americans in
determining whether the poverty rate of an area meets the 25 percent threshold.
All instructions will begin from the Census Bureau’s American Fact Finder homepage at
FactFinder.Census.Gov or click here.
Section 1: Determining if a County has a Poverty Rate of 25 percent. Many rural
counties in the U.S. have a poverty rate of 25 percent or above. If the American Community Survey
reports a poverty rate for the county that meets the poverty threshold you do not need to look at the
poverty rate of individual Census tracts. To determine the poverty rate for your county:
1. Go to the American Fact Finder homepage at www.FactFinder.Census.Gov.
2. In the text box under the Community Facts header, enter the name of the county and state that
you are searching for and click on Go or hit enter on your keyboard. See the example for
Cameron County, Texas below:
3. A new page will appear highlighting the county’s population total. Click on the Poverty tab from
the POPULATION column on the left.
4. The poverty1 rate for the county will appear. Again, using Cameron County, Texas as an
example, the county poverty rate is 34.8%.
1
Poverty rates are derived from 5 year Census survey data.
Section 2: Determining if an Individual Applicant lives in a Census Tract with
a Poverty Rate of 25 Percent. If the American Community Survey reports a poverty rate for
the county that does not meets the poverty threshold, you may need to look at the poverty rate of
individual Census tracts. These directions may look complicated, but after a few practice tries, it will take
about a minute and a half to determine whether an applicant lives in a high-poverty area.
1. Go to the American Fact Finder homepage at www.FactFinder.Census.Gov.
2. Find the Address Search section located on the middle right side of the page and click on the
Street Address link or click here.
3. Type in the address, city and state for the area for which you are interested.
4. A table will come up titled Geography Results with a list of geography types (Region, States,
County, Congressional Districts, etc.). Census Tract will be the seventh option on the list.
Left Click on the Census Tract hyperlink.
5. Next, on the left side of the page there are search options for Topics, Geographies, Race and
Ethnic Groups, Industry Codes, and Occupation Codes. Click on the first option Topics.
6. A Dialogue Box will come up and you will need to close it. You may need to scroll up
to close the Dialogue box.
7. After you close the Dialogue Box a list of tables will come up. Where it says Refine your
Search Results, type in S1701 and click Go.
8. A list of files will come up. Click on the file S1701 Poverty Status in the Past 12 Months for
the most recent year's ACS 5-Year Data. Be sure to use the 5-Year data rather than the 1-
Year or 3-Year data. The latest 5-Year data available currently is 2015 5-Year Data.
9. A table will come up showing the poverty rate of the Census Tract. Use the top line showing
the poverty rate of the total population of the Census Tract. For example, the poverty rate
of Census tract 17.02 in Black Hawk County, Iowa is 8.4 percent.
10. To check the poverty rate of several addresses at the same time, after you have clicked on the
first Census tract, type in the second street address and then click on Census tract again, and so
on for additional street addresses before clicking on the Topics button on the left side of the
page to get the poverty rates of all Census tracts selected.
Section 3: Using Census Data to Identify Contiguous High Poverty-
Areas in Advance.
Cities can use Census data to map out in advance entire neighborhoods or large sections of
their city that meet the 25 percent poverty rate threshold. In most cases cities will not need to
map out every Census tract within their border as local areas are already familiar with where
their high-poverty areas are located. Rural counties that do not meet the 25 percent poverty
threshold can also map out Census tracts within the county that meet the threshold. Again, the
directions below may seem complicated, but a city or county planning department, or a staff
person at the workforce board could use these directions to map out high-poverty areas even
for large cities with a few days of work. Also, the WIOA regulations specify that high-poverty
designations need only to be done once every five years.
1. Go to the American Fact Finder homepage at www.FactFinder.Census.Gov.
2. Find the section header, "What We Provide" near the bottom left of the page and click on
American Community Survey Get Data.
3. A list of tables will come up. At the top of the list next to "Refine Your Search Results" type in
S1701. Then click on "Go".
4. A list of S1701 files will come up for different years. Check the box for S1701 Poverty Status the
Last 12 Months ACS 5-Year Data for the latest year available. Be sure to check the box for 5-
Year Data rather than 1-Year or 3-Year. It currently is 2015 5-Year Data.
5. Next, on the left side of the page there are search options for Topics, Geographies, Race and
Ethnic Groups, Industry Codes, and Occupation Codes. Click on <Geographies>.
6. The “Select Geographies” box will come up with four tabs: List, Name, Address, and Map.
Double click on <Map>. A map of North America will come up.
7. In the upper left corner of the map is a text box with an arrow that says "Find address or place."
Type in the name of your city, county or town and click <Go>.
8. A list appears with the city, county, or town you wanted included in the list as well as other
places in other states with the same name. Click on your selected city, county, or town. A map
that includes your city, county, or town will come up with a blue arrow with a white circle in it
pointing to your city, county, or town.
9. Along the right side of the map is a series of icons. You will be using the first icon which looks
like an arrow pointing to a circle and a third icon which resembles three layers of tiles. First,
click on the first icon which looks like an arrow pointing to a circle, called <Select Geographies>.
The Select Geographies Dialogue Box will come up. Click on the down arrow under “Select” to
open the pull-down menu, then select the 7th option <Place> if you are mapping a city or town
or the 4th option <County> if you are mapping the entire county.
10. Next, click on the dot point which is the first of the four shape boxes under the pull-down menu.
Your cursor now becomes a pointer.
11. Move your cursor over the map and click on the blue arrow with the white circle that indicates
your city, county, or place. Your city, county, or town will now be highlighted in gray, and your
city, county, or place will now appear under the dot point in the <Select Geographies> Dialogue
Box.
Ill.
3-5
12. Next, to the right of the map click on the third icon which resembles three layers of tiles and is
called <Boundaries>. A Dialogue Box will come up giving you several options. Click on both
boxes for the 7th choice <Census Tracts>. Then be sure to click on <Update> at the bottom of
the Dialogue Box.
13. After you click on <Update>, the map of your city, county, or town will now display Census
Tracts. You may need to close the <Boundaries> box to see the entire map.
14. You will probably need to zoom in on the map by clicking on the “+” at the top left of the map to
make the Census Tract numbers legible. To pan around the map, simply use the up and down
and left and right directional keys on your keyboard.
15. Next, click on the first icon on the right, which looks like an arrow pointing to a circle, called
<Select Geographies>. Click on the down arrow under “Select” to open the pull-down menu,
then select the 6th option, <Census Tracts>.
16. Next, select the dot point which is the first of the four shape boxes under the pull-down menu,
labeled <select using a pointer>. Your cursor now becomes a pointer.
17. Move your curser over the map and single click on each desired Census Tract to be included in
the set of contiguous Census Tracts. It is better to single click because if you double click you
will also increase the zoom level of the map. Again, the Census Tracts that you select must be
contiguous. At times you may need to zoom in further to see street boundaries. You need to
keep the Select Geographies dialogue box open while you are using the cursor to add Census
tracts.
18. The selected Census Tracts will appear a darker shade on the map and be listed within the
<Select Geographies> Dialogue Box, under the four shape boxes. If the shading isn’t dark
enough for you to distinguish which Census Tracts you are selecting then zoom in a little further
which will increase the contrast of the shading. To remove a Census Tract from the list, click on
the blue <X> next to the Census Tract in the list.
19. When you are satisfied with your selections, click on <Add to Your Selections> underneath the
Census Tract listings in the <Select Geographies> Dialogue Box. Your city will now appear a light
shade of yellow on the map and the Census Tracts you selected will appear a darker shade of
yellow on the map.
20. Next, click on < Topics> located to the left of the map. There will be a Dialogue Box pop up. Just
click on the <X> to close the Dialogue Box. You may need to scroll up to close the Dialogue Box.
21. Then click on the title of the data file that you previously selected S1701 Poverty Status in the
Last 12 Months ACS 5-Year Estimates for the latest year available. Again, be sure to use 5-Year
data.
22. A table will display the poverty data for the Census Tracts that you selected. Use only the first
row of data showing overall poverty numbers and poverty rate for each Census Tract. Use the
directional arrows on the table to move from Census Tract to Census Tract.
23. If some Census tracts within the contiguous set of Census tracts that you identified have poverty
rates of less than over 25 percent you can determine the poverty rate of the contiguous set by
creating your own table with a column showing the total population of each census tract and a
column showing the number in poverty in each Census tract. Add up each column and divide
the total number in poverty in the contiguous Census Tracts by the total population of the
contiguous Census Tracts to compute the poverty rate of the contiguous Census tracts. Note
that you can have as many sets of contiguous Census tracts as there are that meet the 25
percent poverty threshold set in the WIOA regulations.
24. To save your work thus far, there is a line of Action options right above the Census table
showing the poverty rates of the Census tracts you have identified. Click on Bookmark/Save> at
the top of table. You will be given two choices—to either Create Bookmark or to Save Query.
You can do either or both. Select Save Query. A prompt will appear asking whether you want
to Open or Save the document. Don’t click on the Save button, but rather the arrow next to the
Save button, which will give you the option of either Save or Save As. Click on Save As and you
will be given the chance to browse your computer’s files to get to the file where you want to
save your work just as you would if you were saving any other document. Then hit Save. You will
be able to retrieve this query for later use. If this option is not available to you, you may
bookmark the page using your browser by clicking on the star to the right of the URL address or
through saving it to your Favorites by clicking on the star in the upper right corner of your
computer screen. Note that maps and some tables may not be bookmarkable because the table
or map is too complex to fit into a URL.
25. You can also print the table as a PDF document. This will allow you to use the zoom feature of
the map to identify the streets that serve as the boundaries of the target area. In almost all
cases streets forming the boundaries of census tracts will be shown if you zoom in close enough.
In a few cases the map will not show the name of a particular street and you will have to use a
street map or actually drive through the target area to identify the boundary street.
26. If you need to go back and add or delete Census Tracts, at the top of the page with your table,
click on Back to Advanced Search. This will take you back to the page with the Your Selections
box. Below the Your Selections box, click on <Geographies>. Then, at the top of the Geographies
page, click on <Maps>. This will take you back to the map that you have been working on.
27. When you are back to the map that you have been working on, before you can add Census
tracts you will need to (1) re-select Census Tracts under the third icon <Boundaries> to the left
of the map and hit Update; (2) re-select Census Tract under the first icon <Select Geographies>,
and (3) re-select the dot point. Then you can proceed to add Census Tracts by clicking on
additional points on the map and clicking on <Add to Your Selections> underneath the Census
Tract listings in the <Select Geographies> Dialogue Box. To delete a Census Tract simply click on
the blue X next to the Census Tract in the Your Selections box.
28. To retrieve a Query after you have saved it go to American Fact Finder homepage at
www.FactFinder.Census.Gov. Then in the bottom right hand corner of the American
FactFinder home page, click on <Load Query>, and then click on the Browse prompt to find the
work that you saved on your computer. Look for the file as you would look for any other
document that you have saved. Click on the file when you find it and then click on OK when
given the prompt.
Section 4: To determine the Poverty Rate of an Indian Reservation, Tribal
Area, Native Alaskan Village, or Hawaiian Home Land.
1. Go to the American Fact Finder homepage at www.FactFinder.Census.Gov
2. Near the bottom of the left column of American Fact Finder homepage find the section titled
"What We Provide" and click on the first bullet American Community Survey Get Data.
3. On the American Community Survey page, under "Refine Your Search Results" type in S1701.
Then click on "Go".
4. A list of S1701 files will come up for different years. Check the box for S1701 Poverty
Status the Last 12 Months ACS 5-Year Data for the latest year available. Be sure to use
the 5-Year data rather than the 1-Year or 3-Year data. It currently is 2015 5-Year Data.
5. On the left side of page click on <Geographies>. The "Select Geographies" box will come
up with four tabs: List, Name, Address and Map. It should automatically open to the List
tab, but if not click on <List>.
6. Select “Most recent Geographic Types”, and in the dropdown menu scroll down and
select American Indian Area/Alaska Native Area/Hawaiian Home Land—250.
7. The American Indian Area/Alaska Native Area/Hawaiian Home Land list first lists
federally-recognized Indian reservations, trust lands, and Rancherias alphabetically;
then lists joint use areas, then Hawaiian Home Lands; then Oklahoma Tribal Statistical
Areas, then Native Alaskan areas; then state-designated reservations and tribal areas
and Tribal-designated areas. Click on your reservation or native area and then click on
Add to Your Selections.
8. Next, click on < Topics> located to the left of the map. There will be a Dialogue Box pop
up. Just click on the <X> to close the Dialogue Box. You may need to scroll up to close
the Dialogue Box.
9. Then click on the title of the data file that you previously selected S1701 Poverty Status
in the Last 12 Months ACS 5-Year Estimates for the latest year available. Again, be sure
to use 5-Year data.
10. A table will display the poverty data for the reservation or tribal area that you selected.
The WIOA Regulations provide Indian and Native American grantees the option of using
either the overall poverty rate of the area to be served or the poverty rate of Native
Americans in the area to be served. The first row of data in the table shows the overall
poverty rate for the reservation or tribal area. Scroll Down under Race and Ethnicity in
the table to see the poverty rate of Native Americans or of Native Hawaiians in the area.
For example, the Colville Reservation and Off-Reservation Trust Lands has an overall
poverty rate of 32 percent and a poverty rate of Native Americans of 36.5 percent.
11. If your Reservation is not listed in the American Community Survey dropdown list then
use the instructions above for determining the poverty rate of a county or street
address to see if the county or Census tract in which you are located has a poverty rate
for Native Americans of over 25 percent.
12. Similarly, if your Oklahoma Tribal Statistical Area or Reservation does not meet the 25
percent poverty threshold then use the instructions above for determining the poverty
rate of a county or street address to see if the county or Census tract in which you are
located or if some counties or Census tracts that make up your tribal area have a
poverty rate for Native Americans of over 25 percent. For example, the overall Choctaw
Tribal Statistical Area does not meet the 25 percent poverty threshold, but Latimer, La
Flore, McCurtain, Pittsburg, and Pushmatah Counties and Census tracts 7956, 7962,
7964, and 7965 within Bryan County do meet the 25 percent poverty threshold.
13. Indian and Native American grantees serving multiple Native Alaskan Villages, Hawaiian
Villages, Reservations, or Rancherias will need to look at the poverty rate of each
individual site. If the Village, Reservation, or Rancheria’s poverty rate does not meet the
25 percent threshold or if data is not available in the American Community Survey for
the area, grantees can also use the directions above to check whether the county or the
Census tract in which the area is located meets the poverty threshold. Half of the
counties in California have a poverty rate of Native Americans of over 25 percent, as do
the counties of Bethel, Denali, Nome, Northwest Arctic, Valdez-Cordova, Wade
Hampton, Wrangell, and Yukon-Koyakuk in Alaska; the counties of Clark, Douglass,
Esmeralda, Eureka, Humboldt, Lincoln, Mineral, Pershing, and White Pine in Nevada;
and the counties of Duchesne, Iron, Salt Lake, San Juan, San Pete, Sevier, Uintah, and
Washington in Utah. Similarly, Hawaii County in Hawaii has a poverty rate for Native
Hawaiians of over 25 percent.
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