Back to Federal guidance

WIOA adult and dislocated worker training options and service access

Summary ETA explains the range of training and other services that WIOA Adult and Dislocated Worker programs may offer. It asks workforce boards and agencies to review local needs and enrollment data, adjust training options where appropriate, and report spending and outcomes. The letter discusses evidence on training approaches while recognizing that different approaches may fit different participants.
Document
Federal guidance
Agency
U.S. Department of Labor, Employment and Training Administration (ETA)
Document number
TEGL No. 21-22
Date issued
June 9, 2023
Status
Active
ETA lists this advisory as active. It prints an expiration date of Continuing and no rescissions.
Status last verified October 24, 2026

Apply this to your situation

This page explains the general guidance. Ask about your specific situation and see what current federal labor law says, with citations.

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
                                                        WIOA – Adult and Dislocated
  EMPLOYMENT AND TRAINING ADMINISTRATION                Worker Training
              ADVISORY SYSTEM                           CORRESPONDENCE SYMBOL
         U.S. DEPARTMENT OF LABOR                       OWI
            Washington, D.C. 20210                      DATE
                                                        June 9, 2023

ADVISORY:     TRAINING AND EMPLOYMENT GUIDANCE LETTER NO. 21-22

TO:           STATE WORKFORCE AGENCIES
              STATE WORKFORCE ADMINISTRATORS
              STATE WORKFORCE LIAISONS
              STATE AND LOCAL WORKFORCE BOARD CHAIRS AND DIRECTORS
              STATE LABOR COMMISSIONERS
              AMERICAN JOB CENTERS
              STATE APPRENTICESHIP AGENCIES
              STATE DIRECTORS OF THE OFFICE OF APPRENTICESHIP

FROM:         BRENT PARTON
              Acting Assistant Secretary

SUBJECT:      Increasing Equitable Service Access and Employment Outcomes for All
              Jobseekers in Workforce Innovation and Opportunity Act Adult and Dislocated
              Worker Programs

    1. Purpose. This guidance clarifies and compares the variety of training and other services
     available to states and local workforce areas under the Workforce Innovation and
     Opportunity Act (WIOA) with the goal of improving training outcomes across all
     populations served, particularly those with barriers to employment and underserved
     populations. The guidance also addresses operational questions related to implementing
     certain types of training.

    2. Action Requested. State and Local Workforce Development Boards (WDBs) and State
     Workforce Agencies should: 1) analyze labor market information and service enrollment
     data to assess community need for and equitable access to public workforce development
     system services and training, 2) adjust and enhance the variety of WIOA-funded training
     types and other services offered, particularly where evidence supports promising training
     approaches and strategies, and 3) provide accurate quarterly updates on expenditures for
     WIOA training programs, as well as quarterly performance reports.

  RESCISSIONS                                            EXPIRATION DATE
  None                                                   Continuing

3. Summary and Background.

a. Summary – WIOA permits funding several service and training strategies for adults and
   dislocated workers, described previously in Training and Employment Guidance Letter
   (TEGL) No. 19-16 and TEGL No. 08-19. This guidance builds on those TEGLs to share
   insights into what national WIOA data suggests regarding system implementation of
   adult and dislocated programs for all populations and expands on how different training
   and service approaches may be deployed for individual customer circumstances. This
   guidance shares where existing evidence supports the effectiveness of a particular service
   or training approach, which state and local areas should consider incorporating into the
   implementation of WIOA-funded training programs.

   The Department of Labor’s (DOL) Employment and Training Administration (ETA)
   analyzed WIOA participant and outcomes data for Program Years (PY) 2018, 2019, and
   2020, a highlight of which is available in Appendix II. The Department as well as other
   entities have also conducted evaluations of the workforce system. The Department’s
   WIOA data analysis, along with a portfolio of evidence from evaluations on training
   programs suggests that completing a training program aligned with particular strategies
   and approaches that have an empirical basis and may increase wage and employment
   outcomes for participants, when compared to outcomes of individuals who enroll in a
   training program that is not based on evidence-based practices.

   However, different approaches may not work for all groups and in all contexts.
   Deploying a variety of effective outreach, service, and training strategies permitted (or
   even required) by WIOA to meet different community and individual needs is of
   particular importance as the workforce system aims to better serve marginalized and
   historically underserved and underrepresented populations, at a time when multiple
   sectors are growing from public investment in transportation, clean energy, and
   broadband. A state and local service portfolio can include more than one service and
   training strategy available for customers, especially if resources are largely devoted to
   those that have the most evidence for improving employment.

b. Background – On January 20, 2021, President Biden issued the Executive Order On
   Advancing Racial Equity and Support for Underserved Communities Through the
   Federal Government (EO 13985), which directed agencies to allocate resources to
   advance fairness and opportunity and to promote equitable delivery of government
   benefits and equitable opportunities for underserved communities, including Black,
   Latino, and Indigenous and Native American persons, Asian Americans and Pacific
   Islanders and other persons of color; members of religious minorities; lesbian, gay,
   bisexual, transgender, and queer (LGBTQ+) persons; persons with disabilities; persons
   who live in rural areas; and persons otherwise adversely affected by persistent poverty or

          inequality.1 In support of this EO, ETA analyzed WIOA performance data to determine
          how Federal resources allocated to the states and local areas for the Adult and Dislocated
          Worker (DW) programs are used to provide access to services and lead to increased
          employment, credentials and increased earnings, and whether there are meaningful
          differences among populations in access and outcomes.

          While WIOA performance data analyzed alone cannot show causation or exclude
          intervening variables, the data suggests that workforce system participants (individuals
          who received any training or individualized services) who completed training programs
          funded through WIOA were observed to have higher rates of employment and wages
          than those who enrolled in training funded through WIOA but did not complete training.2
          This analysis was completed by aggregating data from various years of WIOA
          performance and calculating averages. Similarly, other studies have found that strategies
          designed to improve adult completion of non-degree credentials, including career
          pathways and comprehensive student supports, can have positive impacts on non-degree
          credential completion.3 Overall, in Program Years (PYs) 2018-2020, exiters from the
          Adult program who completed training earned, on average, wages of $2,125 more than
          the average for Adult program participants who enrolled in training programs but did not
          complete. Trained exiters from the DW program earned, on average, wages of $1,119
          more than the average for DW program participants who enrolled in training but did not
          complete. For both Adult and DW programs, exiters who completed training also had
          higher employment rates than those who did not complete training, both in Q2 and Q4
          after exit. These higher wages and employment rates are consistent across demographic
          groups.4 However, completion rates sometimes differ by demographic group, as reflected
          in the data analysis in Attachment II, Table 1 and Table 4; we encourage state and local
          boards to review and complete a similar analysis for their region.5

          Where program completion varies by race or ethnicity, such differences can have impacts
          on economic outcomes and exacerbate inequities. It is exceptionally important that
          quality training opportunities are available for individuals of all races, genders, and
          members of other populations protected from discrimination by WIOA Section 188,6 as
          well as from all other demographic backgrounds. Further, it is important that, regardless

1
  Executive Order 13985 Advancing Racial Equity and Support for Underserved Communities Through the Federal Government,
https://www.federalregister.gov/documents/2021/01/25/2021-01753/advancing-racial-equity-and-support-for-underserved-communities-through-the-federal-government.
2 WIOA Performance Data, PY 2018, PY 2019, PY 2020, U.S. Department of Labor,

https://www.dol.gov/agencies/eta/performance/results.
3 McKay et al. 2019, Miller et al. 2020
4 WIOA Performance Data, PY 2018, PY 2019, PY 2020, U.S. Department of Labor,

https://www.dol.gov/agencies/eta/performance/results.
5 In addition, State Governors are required as part of their annual monitoring responsibilities to conduct statistical or other

quantifiable analyses of records and demographic data by particular protected categories, and to investigate any significant
differences to determine whether they appear to have been caused by discrimination. See 29 CFR 38.51(b)(1).
6 WIOA Section 188 and its implementing regulations prohibit discrimination on the bases of race, color, religion, sex, national

origin, age, disability, or political affiliation or belief, or, for beneficiaries, applicants, and participants only, on the basis of
citizenship or participation in any WIOA Title I-financially-assisted program or activity. See 29 CFR 38.5.

         of the race, disability status, sex, or other protected status of the participants, all WIOA
         DW and Adult program participants have access to training for top growth occupations
         and occupations with higher salaries. National information about growth occupations and
         WIOA occupational training data examined by race/ethnicity and sex shows that Black,
         Hispanic, and White men in Adult and DW training programs were less likely to be
         trained in high-growth occupations, particularly in nursing and medical occupations, than
         were Black, Hispanic, and White women.7 However, men had a higher average hourly
         wage ($36.75 for DW and $31.66 for Adult) than did women ($25.52 for DW and $28.90
         for Adult), as of October 2022.8 This national-level analysis, which may mask important
         local-specific variations, indicates gaps where workforce programs have an opportunity
         to examine whether program design results in discrimination or impedes earnings equity,
         and whether workforce programs can do more to help women and other underserved
         populations overcome external forces such as pay discrimination in the larger labor
         market. More information on national wage differentials can be found in the Department
         of Labor’s Women’s Bureau Earnings and Ratios tool.9 Occupational segregation for
         different underserved populations may impact the occupations for which individuals are
         trained. Attachment III includes the data tables that show the occupations for which
         different demographic groups are generally trained.

        4. Using WIOA investments to improve access to training and entry into quality jobs.

      a. Funding Mechanisms for WIOA Training Strategies. Participants’ individual service
         needs vary, as do the employment sectors most prevalent in a local area, so it is
         important to tailor training options to meet the needs of the local community and learner.
         A successful local area can use multiple types of training approaches that address the in-
         demand competencies and skill needs identified through state and local sector initiatives.
         When determining which sectors and occupations to focus training efforts on, states and
         local areas should also focus resources on training that prepares jobseekers for higher-
         paying quality jobs in local growth industries, such as jobs with benefits, where workers
         have voice and opportunities for career advancement. More information about Job
         Quality can be found in the Department of Commerce and Department of Labor Good
         Jobs Principles10 and in TEGL 07-22, “Increasing Employer and Workforce System
         Customer Access to High Quality Jobs.”

           WIOA allows states and local areas to fund training through a variety of approaches.
           Most local areas tend to use individual training accounts (ITAs), but ETA encourages
           the use of other funding mechanisms when appropriate. Table 1 below provides a

7 Training Data (2022), U.S. Department of Labor); data included is an aggregate of several years of data.
8Training Data (2022) U.S. Department of Labor; data included is an aggregate of several years of data.
9 “Earnings and Ratios,” Women’s Bureau, U.S. Department of Labor, https://www.dol.gov/agencies/wb/data/earnings.
10 Good Jobs Principles Fact Sheet (2022), U.S. Department of Labor, https://www.dol.gov/sites/dolgov/files/goodjobs/Good-

Jobs-Summit-Principles-Factsheet.pdf.

       description of each allowable training type that the funding mechanisms described above
       can support, as well as a highlight of some of the advantages to participants and
       employers inherent in each; please note that context, curriculum, groups being served,
       and local factors will impact the success of these programs. States and local areas should
       consider these factors when standing up programs. Section 4(b) of this TEGL provides
       more detail on how states and local areas can better design and leverage training
       programs. A full description of allowable training activities can be found in TEGL Nos.
       19-16 and 08-19 (and their respective Change 1s). In addition, TEGL No. 13-16 expands
       on training that may be provided to support the primary components of Registered
       Apprenticeship Programs (RAP). Further guidance regarding non-Eligible Training
       Providers (ETP) contract training is available in Attachment I of this TEGL.

Table 1: Training Types and Advantages of Each

 Training Types   Description of Training Type               Advantages for Participants and
                                                             Employers
 Classroom or     Classroom training refers to the           Support for classroom training:
 Online           academic or technical education
 Training for     individuals receive through a              Participants may benefit from ITAs
 Individuals      structured instruction. ITAs are           for training and supportive services
                  available to cover the cost or             if they remain in a training
                  supplement other sources of funding,       program, reducing barriers to
                  such as grants for eligible participants   enrollment and completion.
                  enrolled in a training program on the      Classroom training appears to have
                  state’s ETP list. WIOA funds can also      the most significant impact on
                  pay for supportive services                employment when its completion
                  participants need to enroll in and         allows a participant to obtain an
                  complete classroom training.               industry-recognized credential,
                                                             particularly a credential associated
                                                             with an occupation that pays them
                                                             more than what they made before.
                                                             Classroom training should be of
                                                             sufficient depth and quality that it
                                                             allows participants to obtain an
                                                             industry-recognized credential that
                                                             can potentially provide them with a
                                                             notable increase in income.

                                                             Well-designed classroom training
                                                             benefits employers and participants
                                                             when such training is developed in
                                                             coordination with employers or
                                                             industry sector partners, preparing

                                                                              workers with the skills needed by
                                                                              employers.

 On-the-Job              OJT refers to training by an employer                Paid employment while in
 Training                to a participant hired by the employer               training:
 (OJT)                   that provides knowledge and skills
 for Individuals         essential to full and adequate job                   Participants build skills and
                         performance. OJT funds provide                       establish employment status while
                         reimbursements to businesses of up to                receiving a consistent paycheck.
                         50 percent of the wage rate of OJT                   OJT also provides learning
                         participants (in certain circumstances               opportunities for those who cannot
                         up to 75 percent) to help defray the                 spend time outside of work hours
                         personnel training costs of new                      for more traditional classroom
                         employees. In an OJT program, the                    training programs.11
                         business is generally the entity
                         providing the training. This training is             Employers can hire an employee
                         funded by a direct contract and could                right away, ensure the training
                         exist as a stand-alone training, or as a             program is specific to their hiring
                         portion of an integrated training type,              needs, and get help offsetting
                         such as a RAP.                                       training costs. Employers should
                                                                              ensure that all OJT programs and
                                                                              hiring are nondiscriminatory and
                                                                              equitable.
 Cohort                  Cohort training, financed through a                  Participants and employers
 Training                contract instead of an individual ITA                benefit from economies of scale:
                         or an individual OJT contract can
                         cover classroom-based occupational                   A cohort of participants benefit
                         training for a group of participants                 from paid on-the-job learning
                         and/or on-the-job training for a group               and/or paid occupational skills
                         of participants. Cohort training can                 training. They also benefit from
                         also be utilized to support both                     peers working through the program
                         primary components of a RAP, as                      with them, providing support and
                         noted below (See TEGL No. 13-16).                    opportunities for peer learning,
                                                                              which evidence shows to be
                                                                              promising for education.12

                                                                              Employers as well as Local WDBs
                                                                              benefit from cost and
                                                                              administrative efficiencies, as well
                                                                              as economies of scale.

11 What Works in Job Training: A Synthesis of the Evidence (22 July 2014), U.S. Department of Labor, U.S. Department of

Commerce, U.S. Department of Education, U.S. Department of Health and Human
Serviceshttps://www.dol.gov/sites/dolgov/files/OASP/legacy/files/jdt.pdf.
12 Drago-Severson, E., Helsing, D., Kegan, R., Popp, N., Broderick, M., Portnow, K.(2001), The Power of a Cohort and of

Collaborative Groups, Focus on Basics (5) Issue B: 15-22., https://www.ncsall.net/index.html@id=254.html.

 Registered     RAPs are an employer-driven, work-                           Paid employment while training
 Apprenticeship based training strategy that combines                        and progressively higher wages:
 Programs       On-the-Job Learning, work
                experience, or OJT with job-related                          Participants receive an income
                academic instruction, resulting in a                         while participating in training that
                Certificate of Completion. A                                 culminates in at least one industry
                Certificate of Completion is a                               recognized credential. There is a
                nationally recognized occupational                           built-in career ladder for
                credential that counts as a recognized                       apprentices who receive wage
                post-secondary credential under                              increases associated with skills
                WIOA sec. 3(52). OJT contracts can                           attainment.
                support the On-the-Job Learning
                component, and ITAs can support the                          Employers can benefit from a
                Related Instruction component.                               highly trained employee right away
                                                                             with good prospects for retention.13
 Incumbent               Under IWT, an employer selects a                    Retention and Advancement:
 Worker                  training provider to increase skills for
 Training                current employees and pays a                        Participants gain skills necessary to
 (IWT)                   significant portion of training costs,              keep their jobs or advance within
                         often as a layoff aversion strategy or              their company.
                         to facilitate skill upgrading. Direct
                         contracts can fund IWT.                             Employers can benefit from
                                                                             retaining and promoting talent
                                                                             internally, minimizing real and
                                                                             institutional knowledge costs of
                                                                             replacing employees.
 Customized              Customized training is contracted                   Customizable:
 Training                group training based on a
                         commitment by an employer or group                  Participants build skills and
                         of employers to hire participants upon              establish employment status.
                         successful completion of the training.              Customized training requires an
                         Employers pay for a significant cost                employer commitment to retain the
                         of the training, as determined by the               individual upon successful training
                         Local WDB.                                          completion.

                                                                             Employers can benefit from
                                                                             leveraging a customized training
                                                                             program to attract workers, build
                                                                             workers’ skills tailored to
                                                                             employers’ needs (including for
                                                                             hard-to-fill vacancies), and gain a
                                                                             competitive advantage with a
                                                                             skilled workforce.

13TEGL 13-16, Attachment III (12 January 2017). United States Department of Labor,

https://www.dol.gov/sites/dolgov/files/ETA/advisories/TEGL/2017/TEGL_13-16_Attachment_Iii_acc.pdf

      b. Designing effective and efficient training programs. It is important for the workforce
         system to invest in the full suite of training options available through WIOA and align
         those training options to state and local sector strategies.14 Not all potential participants
         will need the same types and length of training. For example, individuals with limited
         work history, such as some recently justice- impacted individuals, may benefit from
         transitional employment (described below) initially, while a mid-career worker may be
         better served by IWT, and both may benefit from OJT. To expand access to training for
         a variety of participants with diverse needs, state and local WDBs should:
             • Establish the foundation for participant success by investing in supportive
                 services, creating partnerships with worker or community-based organizations
                 for worker supports (such as local providers serving people with disabilities that
                 can provide information and resources) and with industry sectors for employer-
                 responsive training, hiring and training staff, and leveraging transitional jobs for
                 individuals from underserved populations. (See part i below.)
             • States and localities must ensure that training complies with legal requirements
                 for providing program materials and technology that are accessible to and in
                 appropriate formats for individuals with disabilities and translated or interpreted
                 into appropriate languages for persons with limited English proficiency.
             • Strengthen and expand the menu of available high-quality training options
                 aligned to in-demand occupations and sectors by expanding ITAs and ETPs to
                 include populations that may be proportionally underserved by these programs,
                 investing in pre-apprenticeship programs, and working with employer partners to
                 develop high-quality OJT. (See part ii below.)
             • Leverage training to create partnerships designed to help employers recruit and
                 retain workers. (See part iii below.)
         More detailed strategies can be found in the following sections. States and localities
         should consider the information below to create an intentional and sustainable plan for
         better leveraging training options and serving individuals from underserved communities,
         including those protected from discrimination by WIOA Section 188 and those
         highlighted in EO 13985, as described in the Background section of this TEGL.
         Attachment V provides a compilation of program evaluations and research studies
         regarding the training types, techniques, and supportive services outlined in this section
         that have shown evidence of effectiveness. For more studies about the effectiveness of
         various strategies, please use the Department of Labor’s Clearinghouse for Labor
         Evaluation and Research to see the most up-to-date research.15

14Hendra, et al., “Encouraging Evidence on a  Sector-Focused Advancement Strategy,” MDRC,
https://www.mdrc.org/sites/default/files/2016_Workadvance_Final_Web.pdf
15Clearinghouse for Labor Evaluation and Research, U.S. Department of Labor, https://clear.dol.gov/

    i. Establish the Foundation for Participant Success.

           Invest in supportive services as a component of increasing equitable access to
           successful training programs. Any number of barriers may prevent an individual from
           entering or completing training. These barriers include but are not limited to:
               • Training, materials, and testing costs
               • Childcare needs
               • Transportation
               • Financial literacy training
               • Access to internet and other necessary tools to complete program
               • Unstable housing

         These barriers may be more pronounced for some individuals from underserved
         populations and can interact to create multiple challenges. For example, a parent
         searching for scarce childcare may be limited in their options if they do not have access
         to a car or live in an area without easily accessible public transportation, which further
         exacerbates their childcare challenge. People with disabilities, especially those unable to
         drive, may face similar barriers and have similar needs. Successful states and local areas
         assess and address barriers to WIOA participation when designing workforce services.16

         Studies have demonstrated that providing supportive services to training participants
         leads to more successful outcomes. Use of holistic supports, including financial and
         social services, had a positive impact on the likelihood of adult learners attaining a
         credential in health pathways.17 Program participants surveyed who received supportive
         services indicated they had higher rates of meeting or being on track to meet their
         completion goals.18 Supportive services have also been shown to facilitate retention in
         RAPs.19

         ETA strongly encourages the use of Adult and DW formula funding to provide
         supportive services, such as transportation tokens or vouchers for childcare, as a method
         for increasing participation in and completion of career and training services. States have
         freedom to establish allowable funding amounts and policies to provide supportive
         services as a component of career services and training, and local areas can further refine

16 TEN 12-21, Practitioners Guide to Supportive Services(15 October 2021), U.S. Department of Labor

https://wdr.doleta.gov/directives/corr_doc.cfm?docn=9977.
17 Bragg, Debra D., Giani, Matt S.(November 2019), “The impact of holistic student supports on credential attainment for diverse

adult learners in the Health Pathways Consortium,” Impacts of Key Community Strategies on Non-Degree Credential Completion
by Adult Learners, Lumina Foundation,) pg. 7, https://www.luminafoundation.org/wp-content/uploads/2019/11/impacts-of-key-community-college-strategies-on-non-degree-credential-completion-by-adult-learners.pdf.
18 Eyster, Lauren, et al. (December 2012), Implementation Evaluation of the Community-Based Job Training Grant (CBJTG)

Program, The Urban Institute https://www.urban.org/sites/default/files/publication/23936/412890-Implementation-Evaluation-of-the-Community-Based-Job-Training-Grant-CBJTG-Program.PDF.
19 Kelly, Maura and Wilkinson, Lindsey, "2020 Evaluation of the Highway Construction Workforce Development Program"

(2020). Sociology Faculty Publications and Presentations. 151.
https://archives.pdx.edu/ds/psu/34307.

          both their local policies and menu of such services. See 20 CFR 680.900 for a list of
          allowable supportive services under WIOA. Please note this list is not exhaustive; states
          and localities may choose among these and/or identify other supportive services
          necessary to remove barriers and improve training and employment outcomes. ETA
          encourages partnerships with other programs and organizations to provide supports. It
          also is important to note that there is no cap on supportive services under WIOA or its
          programmatic and nondiscrimination regulations.

          Create partnerships with existing community groups and education providers that
          serve underserved communities. WIOA requires outreach as a key responsibility of
          state and local WDBs (20 CFR 679.130; 29 CFR 38.40). To better share information with
          and to provide services to members of the various groups protected from discrimination
          by WIOA Section 188 and its implementing regulations, state and local WDBs and other
          recipients are required by those regulations to engage with community groups and
          education providers that serve members of those groups. Similarly, local WDBs should
          engage with community groups and education providers in underserved communities,
          particularly those that are led by and devoted to communities underrepresented in WIOA
          programs. Community-based nonprofits, schools including community schools, labor
          unions, worker organizations, disability-focused and faith-based organizations that are
          well-known in underserved communities are key partners in this work as trusted conduits
          of information to local jobseekers, and they are valuable sources of feedback to the
          workforce system. High-performing state and local boards invite these organizations to
          share concerns and needs with boards to ensure services and programs are responsive to
          community needs, and budget funds to pay for such expertise if information requests are
          more than nominal. Community-based organizations are also well-placed to share
          information about American Job Centers (AJC) and training programs directly with
          community members and can follow up with those individuals to support them as they
          navigate the process. Community-based partners may also be able to help AJC programs
          recruit bilingual staff fluent in the languages used by the local community to provide
          services within WIOA and AJC programs, and identify qualified interpreters and
          translators to perform those specific tasks in the relevant languages.20 Many WDBs
          already coordinate with K-12 schools and community colleges, and such partnerships can
          help connect individuals with supportive services and job search assistance as they work
          to complete secondary or postsecondary education and move along a career pathway.
          Even WDBs with strong connections to education partners should examine which
          education institutions are part of communities underrepresented in WIOA programs, such
          as minority-serving institutions, and seek to establish and/or strengthen partnerships with
          such institutions. High school and community college career technical education
          programs also provide opportunities for developing lifelong learning opportunities for
          learners and workers and workforce pipeline development for employers. WIOA-funded
          staff may present information to, partner with, develop cohort training with, and seek

20 See definition of “qualified interpreter” at 29 CFR 38.4(xx)(2).

          feedback from sessions regarding WIOA training opportunities to local high schools, out-
          of-school-time programs, community colleges, and four-year institutions including
          minority-serving institutions. Staff hours to perform outreach to workers, community
          organizations, education partners, and employers is an allowable program cost under
          WIOA.

          WDBs should track participant success among its training programs and share the
          outcome information with partners, with a focus on wage and employment data, and
          highlight the positive impact these programs can have on local individuals and
          communities. At the same time, training programs that do not demonstrate value for
          participants should be reevaluated as an available option. Outreach and communications
          are legally required and necessary for building partnerships and for informing jobseekers
          in the community about available services. To reiterate, outreach and recruitment is an
          allowable cost of WIOA funds, per 2 CFR 200.421. More information about allowable
          outreach is available in TEGL 23-14, and in the October 2022 webinar Outreach and
          Marketing with WIOA: Exploring the Possibilities.

          Train existing staff and recruit new front-line staff and career counselors at AJCs to
          welcome individuals from all walks of life, including individuals from underserved
          communities who may be using AJC services for the first time. Career counselors help
          potential program participants identify their short- and long-term career goals; understand
          local and regional labor market information to choose a career path; help navigate testing
          or licensing; and develop individual plans to provide the best recommendations to
          customers. While states and local areas differ in levels of career counseling they deliver,
          evidence shows that, on average, individuals with more intensive career counseling at the
          onset have higher wages long-term.21 For example, case managers in jail-based AJCs
          with direct linkages to community-based AJCs were viewed by participants as the
          strongest influence on their likelihood of career success after release from jail.22 See
          Attachment IV for some resources available to career counselors.

          Core training topics should include how to comply with the nondiscrimination
          requirements of WIOA Section 188 and its implementing regulations as well as
          overcoming unconscious bias, anti-racism, anti-sexism, disability awareness and
          nondiscrimination, reasonable accommodations, cultural sensitivity, gender identity, and
          other topics relevant to the local community. For instance, workforce development
          practitioners should ensure that women are presented with all employment and training
          options, including in non-traditional sectors for women that could be higher paying and
          offer them growth opportunities. The same is true for members of other underrepresented
          communities. There are many Diversity, Equity, Inclusion, and Accessibility training

21 Perez-Johnson, Irma. Moore, Quinn. Santillano, Robert (October 2011),      Improving the Effectiveness of Individual Training
Accounts: Long-Term Findings from an Experimental Evaluation of Three Service Delivery Models, Mathematica,
https://www.mathematica.org/publications/improving-the-effectiveness-of-individual-training-accounts-longterm-findings-appendices.
22 Bellotti, Jeanne, et al. (4 September 2018), https://www.dol.gov/sites/dolgov/files/OASP/legacy/files/LEAP-Final-Report.pdf.

          programs and curricula that the workforce system can leverage to best respond to local
          needs. See Attachment IV for some available resources. Further, AJCs should recruit
          staff members who reflect the local community and have lived experiences that help them
          understand, relate to, and effectively serve AJC customers.

          For instance, the workforce system should hire front-line staff who speak the languages
          most spoken in the community and contract with interpretation and translation services to
          ensure that qualified interpreters/translators are available for a wide range of other
          languages. Per the WIOA nondiscrimination regulations at 29 CFR 38.9, AJC programs
          are responsible for providing information and resources in appropriate languages to
          individuals who are limited English proficient [LEP]. AJC programs must determine
          which languages are used by a significant number or portion of the population eligible to
          be served, or likely to be encountered, by the program, and translate all vital
          information23 into those languages. They must also collect information about the LEP
          status and preferred language of every applicant, registrant, participant, and trainee,24 and
          provide vital information to LEP participants in their preferred languages, as specified in
          29 CFR 38.9. To enable meaningful access to training for LEP individuals and other
          individuals with a preferred language other than English, local areas can take steps such
          as providing training materials in the preferred language of participants (either written
          translation or by oral interpretation or summarization) and providing oral training content
          in the preferred language through in-person translation or phone translation.

          As a general rule, AJC programs must take reasonable steps “to ensure meaningful access
          to each…LEP individual served or encountered so that LEP individuals are effectively
          informed about and/or able to participate in the program or activity.” Such steps
          minimize confusion and frustration for potential participants.

          In addition, as required by 29 CFR 38.15, it is essential to ensure that equally effective
          communication supports are provided upon request to job seekers and their companions
          who are deaf or hard-of-hearing, or who have other communication-related disabilities,
          including those who also have language access needs (such as Spanish sign language
          interpretation).

          Furthermore, AJC programs should review the documentation commonly collected at
          intake so as not to delay access to services with extensive document reviews. WIOA-
          funded programs should limit such documentation to that required for eligibility and use
          the flexibilities already available in data validation guidance to accept self-attestation
          where needed to facilitate timely access to services for individuals. See TEGL 23-19,
          Change 1. Please note, WIOA-funded programs should not turn away jobseekers who
          decline to provide an SSN. Further, there is no circumstance in which SSNs of family

23 As defined in 29 CFR 38.4(ttt).
24 As defined in 29 CFR 38.4(c), (aaa), (oo), and (nnn), respectively.   These definitions are likely to differ from the common
understanding of the terms.

         members should be collected; this is not necessary for any WIOA-funded program
         eligibility.

         Utilize transitional jobs for those with minimal job experience. Transitional jobs
         allow individuals to strengthen their work history while earning a wage in a short-term
         job. Transitional jobs are considered career services and are particularly suitable for
         participants with inconsistent work history or who are long-term unemployed. Studies
         have found that transitional jobs have a positive impact on participants' employment and
         earnings outcomes, with the gains concentrated during the period of the transitional job
         placement.25 The findings also included increased likelihood of employment and
         decreased use of public benefits after job placement. A demonstration project that tested
         transitional jobs among individuals recently released from prison and low-income parents
         that had fallen behind on child support found increased earnings among participants and
         higher total earnings compared to a control group at the point of follow-up.26 A recently
         completed synthesis of studies of 13 subsidized employment models found nearly all
         programs that provided subsidized employment or traditional transitional jobs produced
         larger impacts among those who had more barriers to employment.27 State and local
         boards using transitional jobs must adopt relevant policies, including:

              •   Provisions on employer reimbursement amounts, up to 100 percent of wages
              •   Limits on job duration;
              •   Supportive services to be offered;
              •   Methods to identify individuals who are chronically unemployed or have
                  inconsistent work history who may serve as program participants; and
              •   The decision to what degree job readiness training will be provided in
                  combination with the transitional job.
         WIOA regulations at 20 CFR 680.195 state that transitional jobs must be combined with
         relevant supportive services for participants, who are often at high-risk of incompletion
         for a variety of reasons.28 To best achieve this, states can consider working with
         Temporary Assistance for Needy Families (TANF) programs to identify individuals who
         need assistance finding a job and would benefit from work experience, but for whom
         TANF cannot fund such work experience. TANF and the Supplemental Nutrition
         Assistance Program (SNAP) already serve individuals with the highest need in
         communities; supporting transitional job training with WIOA funding for SNAP or
         TANF participants who need work experience allows individuals to get important job

25CLEAR, Rapid Evidence Review Strategies from the Great Recession to Support Employment(March 2021), Mathematica

https://clear.dol.gov/sites/default/files/documents/files/CLEAR_GreatRecessionRR_Synth_202107.pdf.
26 Barden, Bret, Juras, Randall, Redcross, Cindy, Farrell, Mary, and Bloom, Dan,(May 2018), The Enhanced Transitional Jobs

Demonstration, New Perspectives on Creating Jobs, Final Impacts of the Next Generation of Subsidized Employment Programs,
MDRChttps://www.mdrc.org/sites/default/files/ETJD_STED_Final_Impact_Report_2018_508Compliant_v2.pdf.
27 Can Subsidized Employment Programs Help Disadvantaged Job Seekers? (February 2020), U.S. Department of Health and

Human Services, https://www.mdrc.org/sites/default/files/sted_final_synthesis_report_feb_2020.pdf.
28 Supportive Services Desk Reference(August 2021), U.S. Department of Labor,

https://ion.workforcegps.org/resources/2017/07/14/09/22/Supportive_Services_Desk_Reference.

          experience while also using the strengths of both programs to support their path to
          employment.
      ii. Strengthen and Expand the Menu of Available Training Options and Strategies
          Some training programs have evidence supporting their efficacy, such as training that
          provides learning in a work context, including Registered Apprenticeship and well-
          structured on-the-job training, as well as training that prepares learners for work in a
          particular sector; evidence on their efficacy can be found in Attachment V to this TEGL.
          Leverage ITAs and create an intentional list of ETPs to help participants access
          high quality programs. Participants that would benefit from classroom training and
          want a more traditional approach to education with the flexibility to choose their
          programs may prefer using an ITA to access training from approved providers. Most
          WIOA-funded training takes place via ITAs; 84 percent of individuals enrolled in
          occupational skills training used an ITA in Program Year (PY) 2020.
          State and local WDBs should review ITA policies at the state and local level to assess
          whether per-person funding caps enable participants to truly access training that leads to
          credentials for occupations with career ladders and salary progression. Policies should not
          unintentionally cause participants to choose shorter-term training with more limited
          career prospects. State and local WDBs should also review and reconsider policies that
          prohibit individuals from receiving training more than once. Career pathway programs
          offer training in discrete, stackable credentials, so that learners and workers can continue
          to work while taking training that prepares them to move up multiple steps along a career
          pathway. Among the findings of a meta-analysis of career pathways evaluations, some
          programs that target longer-term, more advanced training from the outset, have had larger
          and more sustained impacts on earnings.29 Programs might also improve earnings results
          by using labor market information to target occupations and industries that have high
          potential for advancement. Some programs that target other industry sectors, such as
          information technology (IT) or financial services, have had large and sustained impacts
          on earnings.30
          State WDBs should continue to review and update the state list of ETPs with a focus on
          finding providers that are convenient for and available to underserved communities, and
          that serve those communities effectively. The process of reviewing and updating should
          also ensure that the providers do not discriminate on any basis prohibited by WIOA
          Section 188, and in particular that they comply with legal requirements for serving LEP
          individuals and individuals with disabilities. As remote and online training options have
          expanded in recent years, state WDBs should also assess whether the state’s ETP list
29A meta-analysis of 46 career pathways impact evaluations. (December 2021). Abt Associates. U.S. Department of Labor.

https://www.dol.gov/sites/dolgov/files/OASP/evaluation/pdf/A%20Meta-Analysis%20of%2046%20Career%20Pathways%20Impact%20Evaluations_final%20report.pdf.
30 Peck, L.R., Schwartz, D., Strawn, J., Weiss, C. C., Juras, R., de la Rosa, S. M., Greenstein, N., Morris, T., Durham, G., Lloyd,

C.Abt Associates. A Meta-Analysis Of 46 Career Pathways Impact Evaluations: Final Report. Chief Evaluation Office, U.S.
Department of Labor https://www.abtassociates.com/insights/publications/report/meta-analysis-of-46-career-pathways-impact-evaluations.

         adequately reflects such training options. More detail on program quality can be found in
         TEGL No. 08-19, which describes requirements states and local areas must implement to
         approve ETPs, including the placement of RAPs on state ETPs.
         States and local areas must regularly review those ETPs, ensuring program providers
         continue to provide quality programs that lead to an industry recognized post-secondary
         credential in an in-demand field that will lead to a quality job, while providing for
         consumer choice. States and local areas should also ensure program providers comply
         with applicable nondiscrimination requirements.
         Prepare individuals for high-value RAPs, including investing in pre-apprenticeship.
         State and Local WDBs should work with apprenticeship providers to ensure RAPs are
         accessible for all populations, including underserved and underrepresented communities.
         This includes ensuring that their application process, training materials, and worksites are
         fully compliant with applicable disability-related requirements, including any that apply
         to electronic and information technology or physical accessibility. Providers can also
         scale up pre-apprenticeship programs for individuals interested in pursuing a RAP, which
         often have high school equivalency or other skill-specific requirements to enter. Quality
         pre-apprenticeship programs help individuals learn the skills they need to be successful in
         their chosen occupation, including soft and basic academic skills.
         To be considered a quality pre-apprenticeship program, such a program must be
         connected to a RAP and designed to develop specific skills needed for a would-be
         apprentice to succeed in an established RAP, which provides high-quality training
         opportunities for participants. Quality pre-apprenticeship programs also incorporate
         strategies that increase Registered Apprenticeship opportunities from underrepresented or
         underserved populations facing significant barriers to employment in the Registered
         Apprenticeship labor force. For instance, the US Department of Labor Women’s Bureau
         awards grants yearly to many community-based organizations that work to recruit and
         retain more women into RAPs through training focused on women. The average wage for
         a RAP completer is $77,000 per year, and 93.0 percent of completers retain
         employment.31 In a study that measured net effects of apprenticeships for participants, it
         was found that over a career, the estimated earnings of RAP participants were an average
         of $300,000 more than similar nonparticipants.32
         WIOA Title I training funds can be used in the following ways to support RAPs and pre-
         apprenticeship programs:
              •    ITA Funds: Apprentices who are eligible for WIOA can use an ITA to support the
                   related technical/classroom instruction component for eligible apprentices and
                   pre-apprentices if those RAPs are on the state ETP. ITAs can be used to support

31 Explore Registered Apprenticeship (August 2022), U.S. Department of Labor,

https://www.apprenticeship.gov/sites/default/files/dol-industry-factsheet-apprenticeship101-v10.pdf.
32 Office of Apprenticeship. U.S. Department of Labor.

https://www.apprenticeship.gov/?utm_source=dol_gov_agencies_eta_apprenticeship&utm_medium=text&utm_campaign=appre
nticeship_homepage.

                   placing participants in registered apprenticeship through pre-apprenticeship
                   training and training services provided under the RAP.
              •    Contracted Classes for Related Instruction: In certain circumstances (outlined in
                   the OJT section below), a Local WDB may choose to contract with a training
                   provider to train a cohort of apprentices in an in-demand industry sector or
                   occupation. A workforce system may choose to use a contract as a vehicle for
                   training an apprenticeship cohort in the Related Instruction component, provided
                   the apprentices meet the Adult or DW eligibility requirements, per section
                   134(c)3(G)(ii)(V) of WIOA. More information about contracting can be found in
                   Attachment I.
              •    Customized Training: State and Local WDBs can create customized training
                   agreements to support RAP sponsors, per the customized training guidance below.
         More details on registered apprenticeship and pre-apprenticeship can be found in TEGL
         No. 13-16 and TEN No. 13-12, respectively.
         Partner with employers to develop and expand flexible OJT programs. Evaluations
         have found that on-the-job training has positive impacts on employment and earnings
         outcomes.33 Potential participants may prefer OJT if they need an earn-and-learn option
         and may not be able to attend a classroom program. OJT is a good option for states and
         local areas looking to expand access for individuals who need income or who are
         balancing multiple priorities. Successful OJT programs involve coordination with
         employers offering high quality jobs, training providers, and WDBs to monitor quality
         and ensure program participants are learning relevant skills for their chosen career path.34
         In successful OJT programs, employers regularly continue to employ and advance those
         that have completed an OJT program in their organization; employers that regularly end
         employment of OJT participants should no longer receive OJT funding, per 20 CFR
         680.700. Employers receiving publicly funded wage reimbursement in an OJT benefit
         from the workforce system, and local boards should consider which employers are the
         best investment. Employers offering higher wages and high-quality jobs with benefits,
         retention, and career advancement are stronger candidates for successful OJT that build
         talent pipelines and advance worker mobility.
         Local boards can set limits on training length or employer reimbursement levels based on
         job complexity. Most local boards limit the training to no fewer than 4 weeks and no
         more than 26 weeks to ensure efficiency and effectiveness of programs. The workforce
         system should also consider program participant needs when determining program
         length; some participants will need more program flexibility than others. These length
         and complexity limitations are to be included in the OJT contract. States may choose to
         submit a waiver to ETA to increase OJT reimbursement up to 90 percent for small

33 Kleinman, Liu, Mastri, Reed, Reed, Sattar, & Ziegler (2012). An Effectiveness Assessment and Cost-Benefit Analysis of

Registered Apprenticeship in 10 States. Mathematica Policy Research. Prepared for the U.S. Department of Labor, Employment
and Training Administration.
34 On-the-Job Training (OJT) Toolkit (2020). U.S. Department of Labor,

https://ion.workforcegps.org/resources/2017/12/01/11/19/On-the-Job-Training-Toolkit.

         businesses; states and localities may use this reimbursement as motivation for small
         businesses in underserved communities to start OJT programs for local residents. For
         more information on OJT program implementation, see the Department’s OJT Toolkit.35
    iii. Create Training Opportunities that are Responsive to Local Economic Needs
         Leverage Incumbent Worker Training (IWT) as an effective layoff aversion and
         retention strategy. In a period of rapid turnover, employers may need to adapt their
         operations and train employees to build a more resilient workforce. In a survey conducted
         by SHRM in 2016 with 2,048 respondents, the findings show that the reported cost to
         hire a new employee is $4,129 on average,36 and employers lose important institutional
         knowledge when employees are laid off or quit before training their replacements. For
         entry level employees, IWT is a tool to obtain training that participants may need to
         advance along a career pathway. Further, employers can use IWTs to break up any
         occupational segregation within their firm and provide employees from one occupation
         the training necessary to advance to higher-paid positions within the firm, a hallmark of
         job quality. Though evidence is still in progress for IWT, an evidence scan from
         Mathematica identified studies that suggest potential benefits for employees and
         employers. In one study, at-work training hours for incumbent workers were positively
         correlated with promotion frequency over a two-year period. Another study in California
         observed positive impacts for employers, including improved firm size, after they
         launched a state funded IWT program.37
         State and Local WDBs should align IWT eligibility requirements with local needs. The
         most effective IWTs are built in partnership with employers and workers. As part of a
         sector strategy, the development of a career pathway, or as a standalone business service,
         WDBs can engage with a major local and regional employer and workers to identify why
         they are seeing turnover, and the skills most valuable for employees to climb the ladder at
         their organization. Employers and workers can together identify ways for IWT to
         strengthen the employer’s workforce and the workers' employment.
         Develop customized training programs to respond to emerging local economic
         needs. Customized training programs give an employer the opportunity to train
         employees for jobs that are well-defined, guaranteed, and not seasonal. Business should,
         when possible, contract with external instructors who can provide participants with
         industry recognized credentials as a component of this training. It is important for the
         workforce system to prioritize training that leads to portable, industry-recognized
         credentials which allow for career advancement, rather than simply one-off training for a

35On-the-Job Training (OJT) Toolkit (2020). U.S. Department of Labor,

https://ion.workforcegps.org/resources/2017/12/01/11/19/On-the-Job-Training-Toolkit.
36 Average Cost-per-Hire for Companies is $4,129, SHRM Survey Finds (2016), SHRM, https://ima-net.org/average-cost-per-

hire-for-companies-is-4129-shrm-survey-
finds/#:~:text=42%20days%20is%20the%20average,new%20Human%20Capital%20Benchmarking%20Report.
37 Deutsch, Jonah, Allison-Clark, Katherine, Yanez, Armando (June 2021), The Workforce Innovation and Opportunity Act

(WIOA) Research Portfolio: A Research Evidence Scan of Key Strategies Related to WIOA, Mathematica,
https://www.dol.gov/sites/dolgov/files/OASP/evaluation/pdf/WIOA%20Portfolio%20Research%20Evidence%20Scan.pdf.

         particular job. Still, this training method may be helpful when an employer is trying to
         hire multiple individuals at once, such as when responding to new infrastructure
         investments. More information highlighting evidence for this method can be found in
         Attachment V.
         An employer or group of employers in a local area identify an occupation(s) for which
         they need trained employees. The employer can then work with the local WDB to
         develop a training program with a contractor that will give potential employees the skills
         they need to be successful for that particular occupation. For customized training
         programs to be effective, the employer must meet the requirements listed above in the
         IWT section. New positions must not lead to the displacement of or wage reduction for
         incumbent workers in the business. This training type benefits participants that are
         looking for training that leads to a guaranteed job with a specific employer.
         Under customized training, the employer pays a significant portion of the cost of training,
         as determined by the local board, considering the size of the employer and other factors.
         If the customized training involves an employer located in multiple local areas across the
         state, the Governor decides appropriate factors in determining how much the employer
         should pay.
         Reporting Training Expenditures. All Adult, DW, and Youth program grantees must
         report expenditures used for training on the Training Expenditures line in the ETA-9130
         reporting form. ETA’s review of training expenditures shows that numerous states are
         reporting zeros for training expenditures on the ETA-9130. In preliminary expenditure
         reporting for Program Year 2021, 23 states did not report total training expenditures for
         their Adult programs, and 26 states did not report total training expenditures for their DW
         programs. In Program Year 2020, 14 states did not report total training expenditures for
         their Adult programs, and 15 states did not report total training expenditures for their DW
         programs.38
         All types of training should be accounted for, including OJT; Skill Upgrading;
         Entrepreneurial Training; Adult Basic Education or English as a Second Language in
         conjunction with other training; Customized Training; Occupational Skills Training;
         Prerequisite Training; Registered Apprenticeship; other Non-Occupational Skills
         Training; and Job Readiness Training in Conjunction with Other Training. Please note,
         Transitional Jobs are not considered training for reporting purposes. All tuition costs,
         materials, and supportive services to enable participation in training must be included.
         For more information, see Training and Employment Notice (TEN) 19-22, Change 1,
         TEGL 16-22, and the ETA Financial Reporting website.39
         As a component of WIOA, the workforce system is required to continually evaluate the
         success of its programs, per 20 CFR 682.220. The workforce system should take this

38 Program Year 2021 preliminary expenditure data (1 September 2022).   U.S. Department of Labor.
39 Financial Reporting.(1 September 2022), U.S. Department of Labor,
https://www.dol.gov/agencies/eta/grants/management/reporting.

   opportunity to evaluate whether the strategies they employ to support underserved
   populations lead not only to providing more equitable services but also more equitable
   outcomes for participants. Likewise, the Department reviews evaluations to determine the
   effectiveness of workforce training programs and strategies. Some of the evaluations
   reviewed as a component of this TEGL are included in Attachment V. The Department
   encourages states to perform their own evaluations. Additionally, Governors are required
   to monitor WIOA Title I State programs to ensure nondiscrimination and equal
   opportunity, per 29 CFR 38.51.

5. Inquiries. For further information, please reach out to the appropriate ETA Regional
   Office. For information about nondiscrimination requirements, please contact the
   Department’s Civil Rights Center.

6. References. See Attachment VI.

7. Attachments.
   • Attachment I: Frequently asked questions regarding non-ETP contract training
   • Attachment II: Data on Participation and Performance by Demographic Group
   • Attachment III: In-Demand Occupations vs Training Programs by Race and Sex
   • Attachment IV: Resources for a Career Counseling, Credentialling, and DEIA
      Training Toolkit
   • Attachment V: Evidence of Effective Training Strategies and Approaches
   • Attachment VI: References

                                                                                    Attachment I

                Frequently asked questions regarding non-ETP contract training

    The Department fielded several questions in the past year from states and local areas that are
    working to diversify their training portfolios. This attachment seeks to answer some of the
    more common questions regarding training performance requirements and procedures.

•   Are all training providers subject to the ETP eligibility and data reporting
    requirements at WIOA Section 122(a)-(f)?

    Training providers are typically subject to the ETP eligibility and data reporting
    requirements; however, WIOA allows exceptions for certain training options based on their
    record of success and/or an inherent requirement for employers to hire participants. These
    work-based learning strategies include OJT, IWT, RAPs, and customized training.
    Additionally, WIOA allows local areas to pursue any allowable training activity through
    direct contracting with providers under certain circumstances. In these cases, providers are
    not responsible for satisfying ETP eligibility and performance requirements, although they
    must comply with nondiscrimination requirements. These training options are designed to
    meet specific employer needs and should be considered when available training programs
    and/or curricula do not meet the specific training requirements of employers.

    As established in 20 CFR 680.530 and TEGL No. 08-19, the Governor may establish
    performance criteria for OJT, IWT, customized training, and contracted training that are
    otherwise exempt from the Section 122(a) through (f) eligibility/performance requirements.
    Local workforce development boards must collect this information, if required, and
    determine whether the providers meet the Governor’s performance criteria before entering
    into contracts with training providers that meet these criteria. AJC operators must
    disseminate information identifying providers and programs that have met the Governor’s
    performance criteria, along with the relevant performance information about them, through
    the AJC delivery system.

•   May states establish performance or general criteria for non-ITA-based training, or are
    criteria only determined by the local workforce development boards?

    States may not outright prohibit or otherwise limit a local area’s ability to use non-ITA-based
    training. However, the state may establish policy that is not contradictory to statute,
    regulation, and guidance. Local WDBs therefore, may also set policies, but those policies
    must not conflict with state policy or WIOA. TEGL No. 08-19 specifically states that the
    Governor may include performance criteria that must be met and reported when contracting
    for training services.

•   Under 20 CFR 680.320, one of the acceptable reasons for local workforce development
    boards to execute contracts directly with training providers is when it determines that
    there are an insufficient number of training providers within the local area. How does
    a local workforce development board determine that there are an inadequate number
    of providers?

    WIOA and its regulations do not address the process by which the local WDB determines
    that the number of training providers in the local area is insufficient. The state and/or local
    area may develop such criteria. As a reminder, the local plan must describe how contracts for
    training services will be procured.

    One possible measure of “insufficiency” could be a situation when there is no ETP program
    available for an identified (either state or local) in-demand occupation or industry and the
    only way to procure the training would be through contracting directly with a provider.
    Another possible measure of “insufficiency” could be the lack of training providers with
    experience working with individuals with underserved populations, including individuals
    with disabilities, requiring contracting directly with a provider who provides customized
    employment services for youth and adults with disabilities who require such service in order
    to become employed in competitive, integrated employment. It is important to understand,
    however, that contracting with such providers cannot and must not replace serving
    individuals with disabilities in programs that are not disability-specific, if a particular
    individual with a disability is qualified for such a program and wishes to participate in it. See
    29 CFR 38.12(c), (d). The non-disability-specific program retains the legal obligations to
    provide physically accessible facilities (where required), equally effective communications,
    and reasonable accommodations / modifications to participants with disabilities.

•   Are the processes used in determining an insufficient number of training providers
    described in the Local Plan annually or as modification to the plan?

    Any local area that wishes to contract with providers because there are an inadequate number
    of providers in the local area must provide notice of its intention to do so for a 30-day public
    comment period. The local WDB board may elect to do this concurrently with, or as a part
    of, the public comment period required of the local plan.

    The state does not need to update the process for determining insufficiency of training
    providers unless that process changes. However, consistent with the requirements at 20 CFR
    679.530, the Governor could conceivably require local areas to review specific local policies
    on a more frequent basis. ETA encourages states and local workforce development areas to
    reexamine their policies on a regular basis for the purposes of continuous improvement.

•   Is the Local Plan comment period an additional period to the 30-day comment period
    for interested providers?

    The regulation at 20 CFR 680.320 states that one of the circumstances in which mechanisms
    other than an ITA may be used to provide training services includes when the Local WDB
    determines there are an insufficient number of ETPs in the local area. The regulation also

    states, “The determination process must include a public comment period for interested
    providers of at least 30 days and be described in the local plan.” Because the process must be
    described in the local plan, the minimum 30-day comment period under 680.320(a)(2) could
    be done either concurrently with the local plan comment period described in 20 CFR
    679.550(b) or it may be done separately, so long as the local plan describes the determination
    process. The 30-day comment period under 680.320(a)(2) would be conducted consistent
    with the process described in the local plan.

•   How does the Local WDB determine program effectiveness?

    WIOA and its programmatic regulations do not prescribe the criteria a local WDB must use
    for determining program effectiveness for contract-based training. The local WDB must have
    standard criteria in place to determine demonstrated effectiveness of a given training
    program, and may include in the criteria, the list provided in 20 CFR 680.320(a)(3).

•   Can the state select the criteria from above that must be used? Can the state require
    additional criteria outside of what is stated above?

    The WIOA programmatic regulations reserve this process for the local area, but the state may
    require or encourage the use of certain criteria, including criteria that are not listed in 20 CFR
    680.320(a)(3).
•   In terms of non-ITA training contracts and exceptions, what is the definition of a
    provider of training services? Is the term defined differently from an Eligible Training
    Provider?

    A training provider, as defined under WIOA, may be a local or national community-based
    organization or intermediary; a community college; a university; a joint-labor management
    organization; an Apprenticeship provider; a Title II provider; or another public or private
    provider of training services. These non-ITA contractors are not held to the same
    requirements as ETPs (with the exception of the requirement to comply with the WIOA
    nondiscrimination regulations at 29 CFR part 38) but should still provide quality training
    services.

                                                                                            Attachment II

                 Data on Participation and Performance by Demographic Group40

The below analysis uses ETA performance data to show outcomes for different population
groups in the Adult and Dislocated Worker programs, segmented by whether or not the
participant completed training. Across the board, exiters that completed training had higher
average median earnings and employment rate than those who did not complete training.

                        Table 1: PY 2018-2020 Average for Adult WIOA by Sex
                                                                                    Exiters
                                                                                  Enrolled in
                                                                                 Training That     Exiters
                                                                                    Did Not         That
                 Population                                                        Complete      Completed
                   Group                  Measure               All Exiters        Training       Training
                                     % of Total Exiters              100.0%               5.4%         19.5%
                                     Training Rate                    24.9%             100.0%       100.0%
                                     Employment Rate
                                                                        70.4%           71.7%         82.8%
                                     (ER) Q2
        All

                      All
                                     ER Q4                              69.6%           71.3%         81.1%
                                     Median Quarterly
                                     Earnings Q2                       $6,429           $5,640       $7,765
                                     (Median Earnings)
                                     % of Total Exiters                48.6%             2.5%          9.1%
                                     Training Rate                     23.8%           100.0%        100.0%
                     Male            ER Q2                             69.4%            69.7%         80.7%
                                     ER Q4                             68.1%            69.2%         78.5%
                                     Median Earnings                   $7,175           $6,364        $8,611
        Sex

                                     % of Total Exiters                50.9%             2.9%         10.3%
                                     Training Rate                     25.9%           100.0%        100.0%
                    Female           ER Q2                             71.4%            73.4%         84.8%
                                     ER Q4                             71.1%            73.1%         83.4%
                                     Median Earnings                   $5,820           $5,171        $7,112

40 WIOA Performance Data, PY 2018, PY 2019, PY 2020, U.S. Department of Labor,

https://www.dol.gov/agencies/eta/performance/results.

            Table 2: PY 2018-2020 Average for Adult WIOA by Ethnicity and Race
                                                                      Exiters
                                                                    Enrolled in
                                                                   Training That
                                                                      Did Not     Exiters That
              Population                                             Complete      Completed
                Group            Measure            All Exiters      Training       Training
                            % of Total Exiters           100.0%             5.4%        19.5%
                            Training Rate                 24.9%           100.0%       100.0%
All

                  All       ER Q2                         70.4%            71.7%        82.8%
                            ER Q4                         69.6%            71.3%        81.1%
                            Median Earnings               $6,429           $5,640       $7,765
                            % of Total Exiters            16.5%             0.9%          3.4%
                            Training Rate                 26.2%           100.0%       100.0%
               Hispanic     ER Q2                         71.1%            70.4%        82.2%
                            ER Q4                         70.2%            69.7%        80.4%
Ethnicity

                            Median Earnings               $6,359           $5,841       $7,759
                            % of Total Exiters            71.4%             4.1%        14.5%
                            Training Rate                 26.0%           100.0%       100.0%
             Non-Hispanic ER Q2                           71.0%            72.3%        83.3%
                            ER Q4                         70.1%            71.8%        81.5%
                            Median Earnings               $6,470           $5,536       $7,766
                            % of Total Exiters              3.1%            0.2%          0.5%
               American     Training Rate                 21.2%           100.0%       100.0%
            Indian / Alaska ER Q2                         66.9%            66.9%        79.4%
                Native      ER Q4                         65.6%            65.7%        77.2%
                            Median Earnings               $5,755           $5,056       $7,284
                            % of Total Exiters              3.7%            0.1%          0.6%
                            Training Rate                 19.6%           100.0%       100.0%
                 Asian      ER Q2                         67.7%            71.3%        78.1%
                            ER Q4                         67.7%            66.3%        77.2%
Race

                            Median Earnings               $7,628           $6,923       $8,564
                            % of Total Exiters            27.3%             2.0%          6.6%
                            Training Rate                 31.7%           100.0%       100.0%
            Black / African
                            ER Q2                         71.9%            72.8%        81.4%
               American
                            ER Q4                         70.6%            72.5%        79.4%
                            Median Earnings               $5,513           $5,110       $6,918
                            % of Total Exiters              0.9%            0.0%          0.1%
                Native      Training Rate                 18.2%           100.0%       100.0%
              Hawaiian /
                            ER Q2                         67.7%            65.6%        79.3%
             Other Pacific
               Islander     ER Q4                         67.4%            65.4%        77.8%
                            Median Earnings               $6,359           $5,605       $7,775

                                                                            Exiters
                                                                          Enrolled in
                                                                         Training That
                                                                            Did Not     Exiters That
                     Population                                            Complete      Completed
                       Group           Measure            All Exiters      Training       Training
                                  % of Total Exiters            54.0%             2.6%          9.7%
                                  Training Rate                 22.7%           100.0%       100.0%
                       White      ER Q2                         70.4%            71.3%        84.7%
                                  ER Q4                         69.6%            70.8%        83.0%
                                  Median Earnings               $6,823           $5,846       $8,287
                                  % of Total Exiters              3.1%            0.2%          0.5%
                                  Training Rate                 20.5%           100.0%       100.0%
                    More than One
                                  ER Q2                         67.1%            66.1%        79.0%
                        Race
                                  ER Q4                         66.0%            64.2%        78.1%
                                  Median Earnings               $5,467           $4,554       $7,149

                    Table 3: PY 2018-2020 Average for Adult WIOA by Disability Status
                                                                            Exiters
                                                                          Enrolled in
                                                                         Training That
                                                                            Did Not     Exiters That
                     Population                                            Complete      Completed
                       Group            Measure           All Exiters      Training       Training
                                   % of Total Exiters          100.0%             5.4%        19.5%
                                   Training Rate                24.9%           100.0%       100.0%
All

                         All       ER Q2                        70.4%            71.7%        82.8%
                                   ER Q4                        69.6%            71.3%        81.1%
                                   Median Earnings              $6,429           $5,640       $7,765
                                   % of Total Exiters             7.5%            0.3%          1.0%
                     Individuals                                17.8%           100.0%       100.0%
                                   Training Rate
                       with a
                                   ER Q2                        54.6%            55.4%        70.2%
Disability Status

                      Reported
                      Disability   ER Q4                        52.9%            54.2%        68.7%
                                   Median Earnings              $4,794           $4,760       $6,744
                                   % of Total Exiters           73.1%             4.8%        17.3%
                     Individuals   Training Rate                30.2%           100.0%       100.0%
                      without a
                                   ER Q2                        72.4%            73.2%        83.8%
                      Reported
                      Disability   ER Q4                        71.4%            72.7%        82.0%
                                   Median Earnings              $6,581           $5,702       $7,838

      Table 4: PY 2018-2020 Average for Dislocated Worker WIOA by Sex
                                                             Exiters
                                                           Enrolled in     Exiters That
                                                          Training, Did     Completed
       Population                                         Not Complete       Training
         Group            Measure           All Exiters     Training
                     % of Total Exiters         100.0%              3.0%         11.7%
                     Training Rate               14.7%           100.0%         100.0%
All

           All       ER Q2                       67.6%            74.5%          80.9%
                     ER Q4                       69.3%            75.3%          80.6%
                     Median Earnings             $7,762           $8,260         $9,379
                     % of Total Exiters          49.9%              1.6%          6.5%
                     Training Rate               16.2%           100.0%         100.0%
          Male       ER Q2                       67.6%            75.1%          81.2%
                     ER Q4                       68.9%            75.9%          80.8%
                     Median Earnings             $8,717           $9,338        $10,501
Sex

                     % of Total Exiters          49.8%              1.4%          5.1%
                     Training Rate               13.1%           100.0%         100.0%
         Female      ER Q2                       67.6%            73.9%          80.5%
                     ER Q4                       69.7%            74.6%          80.3%
                     Median Earnings             $6,944           $7,292         $8,139

Table 5: PY 2018-2020 Average for Dislocated Worker WIOA by Ethnicity and Race
                                                                    Exiters Enrolled      Exiters
                                                                    in Training, Did       That
               Population                                            Not Complete       Completed
                 Group             Measure            All Exiters       Training         Training
                              % of Total Exiters          100.0%                 3.0%         11.7%
                              Training Rate                14.7%              100.0%        100.0%
                 Hispanic     ER Q2                        67.6%               74.5%          80.9%
                              ER Q4                        69.3%               75.3%          80.6%
  Ethnicity

                              Median Earnings              $7,762              $8,260        $9,379
                              % of Total Exiters           18.5%                 0.6%          2.2%
                              Training Rate                15.1%              100.0%        100.0%
               Non-Hispanic ER Q2                          66.9%               73.0%          80.1%
                              ER Q4                        69.2%               73.9%          79.8%
                              Median Earnings              $7,236              $7,998        $8,902
                              % of Total Exiters           71.6%                 2.1%          8.3%
                 American     Training Rate                14.5%              100.0%        100.0%
              Indian / Alaska ER Q2                        68.2%               75.6%          81.7%
                  Native      ER Q4                        69.8%               76.1%          81.3%
                              Median Earnings              $7,892              $8,329        $9,519
                              % of Total Exiters            2.4%                 0.1%          0.2%
                              Training Rate                11.2%              100.0%        100.0%
                   Asian      ER Q2                        67.3%               69.1%          77.5%
                              ER Q4                        68.0%               68.0%          76.8%
                              Median Earnings              $6,608              $7,535        $8,475
                              % of Total Exiters            5.1%                 0.1%          0.6%
                              Training Rate                13.9%              100.0%        100.0%
  Race

              Black / African
                              ER Q2                        62.5%               71.2%          72.8%
                 American
                              ER Q4                        65.9%               73.5%          72.9%
                              Median Earnings             $10,340             $12,019       $12,099
                              % of Total Exiters           20.9%                 0.7%          2.6%
                  Native      Training Rate                15.7%              100.0%        100.0%
                Hawaiian /
                              ER Q2                        67.8%               75.4%          80.7%
               Other Pacific
                 Islander     ER Q4                        70.5%               75.9%          80.4%
                              Median Earnings              $6,635              $7,312        $8,471
                              % of Total Exiters            1.0%                 0.0%          0.1%
                              Training Rate                 9.3%              100.0%        100.0%
                   White      ER Q2                        66.6%               73.4%          79.2%
                              ER Q4                        68.0%               69.1%          78.4%
                              Median Earnings              $7,104              $7,591        $9,324

                                                                               Exiters Enrolled      Exiters
                                                                               in Training, Did       That
                           Population                                           Not Complete       Completed
                             Group           Measure             All Exiters       Training         Training
                                        % of Total Exiters            58.8%                 1.7%          6.8%
                                        Training Rate                 14.3%              100.0%        100.0%
                          More than One
                                        ER Q2                         68.5%               74.7%          82.3%
                              Race
                                        ER Q4                         69.5%               75.5%          81.9%
                                        Median Earnings               $8,143              $8,526        $9,664

     Table 6: PY 2018-2020 Average for Dislocated Worker WIOA by Disability Status
                                                                                     Exiters
                                                                                   Enrolled in
                                                                                  Training That
                                                                                     Did Not     Exiters That
                           Population                                               Complete      Completed
                             Group             Measure             All Exiters      Training       Training
                                          % of Total Exiters            100.0%             5.4%         19.5%
                                          Training Rate                  24.9%           100.0%       100.0%
      All

                                All       ER Q2                          70.4%            71.7%         82.8%
                                          ER Q4                          69.6%            71.3%         81.1%
                                          Median Earnings                $6,429           $5,640       $7,765
                                          % of Total Exiters               7.5%            0.3%          1.0%
                            Individuals   Training Rate                  17.8%           100.0%       100.0%
                          with a Reported ER Q2                          54.6%            55.4%         70.2%
      Disability Status

                             Disability   ER Q4                          52.9%            54.2%         68.7%
                                          Median Earnings                $4,794           $4,760       $6,744
                                          % of Total Exiters             73.1%             4.8%         17.3%
                            Individuals                                  30.2%           100.0%       100.0%
                                          Training Rate
                             without a
                                          ER Q2                          72.4%            73.2%         83.8%
                             Reported
                             Disability   ER Q4                          71.4%            72.7%         82.0%
                                          Median Earnings                $6,581           $5,702       $7,838

Training rate of all above tables indicates the percentage of the total exiters that belongs to that
demographic group.

                                                                                                        Attachment III

                  In-Demand Occupations vs Training Programs by Race and Sex

The information provided below is based on an examination of national labor market information
(LMI) from the Bureau of Labor Statistics. States and local areas should use local LMI to
complete a similar analysis to determine where increased investment in training will benefit
industry and workers.

Table 1: Top 10 Growth Occupations Requiring a Postsecondary Non-Degree Award;
Associates Degree Award; or Some College, No Degree41

 Occupation                          Employment change,              Typical                  Typical on-the-job
                                     2021-31 (In                     education                training needed to
                                     Thousands)                      needed for entry         attain competency in
                                                                                              the occupation
 Medical Assistants                  117.8                           Postsecondary            None
                                                                     nondegree award

 Heavy and Tractor-Trailer           90.9                            Postsecondary            Short-term on-the-job
 Truck Drivers                                                       nondegree award          training

 Preschool Teachers, Except          72.9                            Associate's degree       None
 Special Education

 Nursing Assistants                  62.7                            Postsecondary            None
                                                                     nondegree award

 Hairdressers, Hairstylists, and     60.8                            Postsecondary            None
 Cosmetologists                                                      nondegree award

 Paralegals and Legal                49.9                            Associate's degree       None
 Assistants

 Computer User Support               42.7                            Some college, no         Moderate-term on-the-job
 Specialists                                                         degree                   training

 Licensed Practical and              41.3                            Postsecondary            None
 Licensed Vocational Nurses                                          nondegree award

 Manicurists and Pedicurists         36.6                            Postsecondary            None
                                                                     nondegree award

 Dental Assistants                   30.1                            Postsecondary            None
                                                                     nondegree award

41 Employment by detailed occupation, 2021 and projected 2031, U.S. Bureau of Labor Statistics, (8 September 2022),

https://www.bls.gov/emp/tables/emp-by-detailed-occupation.htm.

Table 2: Top 10 Occupation Training Programs for WIOA Dislocated Worker Program
Participants by Race and Sex42

 Black Female       Hispanic Female                                                  Hispanic Male
 DW                 DW                  White Female DW          Black Male DW       DW                  White Male DW
 Heavy and                                                       Heavy and           Heavy and           Heavy and
 Tractor-Trailer    Medical                                      Tractor-Trailer     Tractor-Trailer     Tractor-Trailer
 Truck Drivers      Assistants          Medical Assistants       Truck Drivers       Truck Drivers       Truck Drivers

                    Educational                                  Computer and                            Computer and
                    Instruction and                              Information         Welders, Cutters,   Information
 Nursing            Library Workers,    Medical Records          Systems             Solderers, and      Systems
 Assistants         All Other           Specialists              Managers            Brazers             Managers
                                                                 Heating, Air        Heating, Air
                                                                 Conditioning, and   Conditioning, and
                                                                 Refrigeration       Refrigeration       Welders, Cutters,
 Medical            Medical Records                              Mechanics and       Mechanics and       Solderers, and
 Assistants         Specialists         Nursing Assistants       Installers          Installers          Brazers
                                                                                                         Heating, Air
                                                                 Network and                             Conditioning, and
 Medical                                Bookkeeping,             Computer                                Refrigeration
 Records            Nursing             Accounting, and          Systems                                 Mechanics and
 Specialists        Assistants          Auditing Clerks          Administrators      Security Guards     Installers
 Licensed
 Practical and                                                                       Network and
 Licensed                                                        Computer User       Computer            Project
 Vocational         Office Clerks,                               Support             Systems             Management
 Nurses             General             Registered Nurses        Specialists         Administrators      Specialists

 Computer and                                                                        Computer and        Network and
 Information        Bookkeeping,                                 Project             Information         Computer
 Systems            Accounting, and     Heavy and Tractor-       Management          Systems             Systems
 Managers           Auditing Clerks     Trailer Truck Drivers    Specialists         Managers            Administrators

 Project            Heavy and           Medical Secretaries
 Management         Tractor-Trailer     and Administrative       Managers, All                           Managers, All
 Specialists        Truck Drivers       Assistants               Other               Electricians        Other
                    Medical
                    Secretaries and     Licensed Practical       Welders, Cutters,   Project             Computer User
 Managers, All      Administrative      and Licensed             Solderers, and      Management          Support
 Other              Assistants          Vocational Nurses        Brazers             Specialists         Specialists

 Registered         Customer Service    Office Clerks,           Information         Managers, All
 Nurses             Representatives     General                  Security Analysts   Other               Animal Scientists
                    Licensed
 Medical            Practical and       Executive Secretaries
 Secretaries and    Licensed            and Executive                                Computer User
 Administrative     Vocational          Administrative                               Support             Procurement
 Assistants         Nurses              Assistants               Security Guards     Specialists         Clerks
*Highlighted fields indicate a growth occupation, as defined in Table 1*

42 Training Data (2022). U.S. Department of Labor.

Table 3: Top 10 Occupation Training Programs for WIOA Adult Program Participants by
Race and Sex43
 Black Female        Hispanic Female      White Female                              Hispanic Male         White Male
 Adult               Adult                Adult               Black Male Adult      Adult                 Adult
                                          Heavy and           Bookkeeping,          Bookkeeping,          Bookkeeping,
 Nursing             Nursing              Tractor-Trailer     Accounting, and       Accounting, and       Accounting, and
 Assistants          Assistants           Truck Drivers       Auditing Clerks       Auditing Clerks       Auditing Clerks
                                                                                    Computer
 Medical             Medical Records      Medical             Database              Network Support       Database
 Assistants          Specialists          Assistants          Administrators        Specialists           Administrators
                     Heavy and
 Medical Records     Tractor-Trailer      Nursing             Computer Network      Database              Skincare
 Specialists         Truck Drivers        Assistants          Support Specialists   Administrators        Specialists
 Heavy and                                                    Industrial            Industrial            Industrial
 Tractor-Trailer     Medical              Medical Records     Production            Production            Production
 Truck Drivers       Assistants           Specialists         Managers              Managers              Managers
                                                              Property, Real
                                                              Estate, and
 Bookkeeping,        Bookkeeping,         Bookkeeping,        Community                                   Heavy and
 Accounting, and     Accounting, and      Accounting, and     Association           Skincare              Tractor-Trailer
 Auditing Clerks     Auditing Clerks      Auditing Clerks     Managers              Specialists           Truck Drivers
                     Medical              Medical                                   Aircraft Structure,   Network and
 Human               Secretaries and      Secretaries and     Education             Surfaces, Rigging,    Computer
 Resources           Administrative       Administrative      Administrators, All   and Systems           Systems
 Specialists         Assistants           Assistants          Other                 Assemblers            Administrators
 Licensed                                 Licensed
 Practical and                            Practical and
 Licensed            Clinical and         Licensed            Network and           Heavy and             Assemblers and
 Vocational          Counseling           Vocational          Computer Systems      Tractor-Trailer       Fabricators, All
 Nurses              Psychologists        Nurses              Administrators        Truck Drivers         Other
 Medical
 Secretaries and     Human                Human
 Administrative      Resources            Resources           Human Resources       Physical Therapist    Manicurists and
 Assistants          Specialists          Specialists         Managers              Assistants            Pedicurists
                     Licensed
 Computer and        Practical and
 Information         Licensed             Computer User                                                   Training and
 Systems             Vocational           Support                                                         Development
 Managers            Nurses               Specialists         Registered Nurses     Nursing Assistants    Specialists
                                                              Janitors and          Property, Real
                                                              Cleaners, Except      Estate, and
 Computer            Project              Project             Maids and             Community             Loan
 Network Support     Management           Management          Housekeeping          Association           Interviewers and
 Specialists         Specialists          Specialists         Cleaners              Managers              Clerks
*Highlighted fields indicate a growth occupation, as defined in Table 1*

43 Training Data (2022), U.S. Department of Labor.

                                                                                 Attachment IV

       Resources for a Career Counseling, Credentialling, and DEIA Training Toolkit

The below resources and training modules can be used to help AJC staff to provide quality career
counseling and training equitably across all populations.

Career Guidance Resources Available on CareerOneStop.org

•   Career Advisor Portal. https://www.careeronestop.org/ResourcesFor/CareerAdvisor/career-
    advisor.aspx
•   Certification Finder. https://www.careeronestop.org/Toolkit/Training/find-certifications.aspx
•   License Finder. https://www.careeronestop.org/Toolkit/Training/find-licenses.aspx
•   Local Training Finder. https://www.careeronestop.org/Toolkit/Training/find-local-
    training.aspx

All of the above CareerOneStop.org tools are integrated into the occupational profiles in
MyNextMove (https://www.mynextmove.org/) a tool individuals can use to find career and
training opportunities. The above tools are also included in O*NET Online
(https://www.onetonline.org/), which individuals can use to explore occupational information.

Career Counseling and Equity Resources
• Clawson, Stacey. (21 April 2022). Designing with Equity in Mind: An Action Toolkit. Jobs
   for the Future. https://www.jff.org/resources/Designing-with-equity-in-mind-an-action-
   toolkit-for-cbe/.
• Employment Coaching During the COVID-19 Pandemic: Lessons Learned. (3 June 2022).
   U.S. Department of Health and Human Services.
   https://www.acf.hhs.gov/opre/report/employment-coaching-during-covid-19-pandemic-
   lessons-learned.
• Employment Coaching: What Do Participants Say? (29 October 2021). U.S. Department of
   Health and Human Services. https://www.acf.hhs.gov/opre/report/employment-coaching-
   what-do-participants-say.
• Evaluation of Employment Coaching for Temporary Assistance to Needy Families (TANF)
   and Related Populations & Long-Term Follow-Up Study. U.S. Department of Health and
   Human Services. https://www.acf.hhs.gov/opre/project/evaluation-employment-coaching-
   tanf-and-related-populations-2016-2021.
• Helping Students Select Best Bets. (December 2013). Jobs for the Future. https://jfforg-prod-
   new.s3.amazonaws.com/media/documents/CTC_onepager_COMMUNITYCOLLEGES_122
   713.pdf.
• Henry-Nickie, Makada. (June 2021). Race Equity in Workforce Development: A Survey of
   Attitudes. National Association of Workforce Boards. https://irp.cdn-
   website.com/dc0a626e/files/uploaded/NAWB_Race_Equity_Survey-
   060821%20%28002%29.pdf.
• Johnson, Melissa, et al. (13 September 2019). The Roadmap for Racial Equity. National
   Skills Coalition. https://nationalskillscoalition.org/resource/publications/the-roadmap-for-
   racial-equity/.

•   My Skills, My Future. https://www.myskillsmyfuture.org.
•   Promising Practices In Achieving Nondiscrimination and Equal Opportunity: A Section 188
    Disability Reference Guide. (February 2019). LEAD Center WIOA Policy Development.
    https://leadcenter.org/resources/new-promising-practices-in-achieving-nondiscrimination-
    and-equal-opportunity-a-section-188-disability-reference-guide/.
•   Rollins, Katie. The Potential of Motivational Interviewing. Chapin Hill and Public
    Consulting Group. https://www.chapinhall.org/project/the-potential-of-motivational-
    interviewing.
•   Skills Engine. https://builder.skillsengine.com/.
•   The YouthBuild Manual for Counseling, Case Management, and Program Culture. (20
    December 2021). Workforce GPS.
    https://www.workforcegps.org/resources/2015/04/07/09/18/The_YouthBuild_Manual_for_C
    ounseling_Case_Management_Program_Culture:
    https://strategies.workforcegps.org/announcements/2021/12/20/15/17/~/link.aspx?_id=E64E
    97E7351947D7A0ED812D871B880A&_z=z.
•   What is Motivational Interviewing? Head Start, Early Childhood Learning and Knowledge
    Center. https://eclkc.ohs.acf.hhs.gov/mental-health/article/what-motivational-interviewing.

                                                                                   Attachment V

                  Evidence of Effective Training Strategies and Approaches

Below are several evaluations, databases, reports, and other resources that provide more detail
about effectiveness of various training programs and strategies highlighted in this guidance. Not
all of these resources were directly referenced in the TEGL itself but are included as an
additional set of resources for interested parties.

   •   Andersson et al. (2013). Does federally-funded job training work? Nonexperimental
       estimates of WIA training impacts using longitudinal data on workers and firms.
       https://clear.dol.gov/Study/Does-federally-funded-job-training-work-Nonexperimental-
       estimates-WIA-training-impacts-1.
   •   Clearinghouse for Labor Evaluation and Research. U.S. Department of Labor.
       https://clear.dol.gov/.
   •   Deming et al. (2023). Navigating public job training. Harvard University Project on
       Workforce. https://www.pw.hks.harvard.edu/post/publicjobtraining.
   •   Employment coaching during the COVID-19 pandemic: lessons learned. (3 June 2022).
       U.S. Department of Health and Human Services.
       https://www.acf.hhs.gov/opre/report/employment-coaching-during-covid-19-pandemic-
       lessons-learned.
   •   Heinrich, Carolyn J. Mueser, Peter R. Troske, Kenneth R. (December 2008). Workforce
       Investment Act non-experimental net impact evaluation. Impaq International.
       https://wdr.doleta.gov/research/FullText_Documents/Workforce%20Investment%20Act
       %20Non-Experimental%20Net%20Impact%20Evaluation%20-%20Final%20Report.pdf.
   •   Hendra et al. (2016). Encouraging evidence on a sector-focused advancement strategy.
       https://clear.dol.gov/Study/Encouraging-evidence-sector-focused-advancement-strategy-
       Hendra-et-al-2016-1.
   •   Hollenbeck, Kevin. Schroeder, Daniel. King, Christopher T. Huang, Wei-Jang. (2005).
       Net Impact estimates for services provided through the Workforce Investment Act. U.S.
       Department of Labor.
       https://wdr.doleta.gov/research/FullText_Documents/Net%20Impact%20Estimates%20fo
       r%20Services%20Provided%20through%20the%20Workforce%20Investment%20Act-
       %20Final%20Report.pdf.
   •   Evidence review: Employment and training, what works. (2016). Centre for Local
       Economic Growth. https://whatworksgrowth.org/wp-content/uploads/16-06-
       15_Employment_Training_Update-1.pdf.
   •   Eyster et al. (December 2012). Implementation evaluation of the Community-Based Job
       Training Grant (CBJTG) Program. The Urban Institute.
       https://www.urban.org/sites/default/files/publication/23936/412890-Implementation-
       Evaluation-of-the-Community-Based-Job-Training-Grant-CBJTG-Program.PDF.
   •   Mack, Melissa and Dunham, Kate. (2021). The Workforce Innovation and Opportunity
       Act (WIOA) research portfolio: A scan of key trends in the labor market and workforce
       development system. Mathematica.
       https://www.dol.gov/sites/dolgov/files/OASP/evaluation/pdf/WIOA%20Portfolio%20Sca
       n%20Labor%20Force%20and%20Workforce%20Trends.pdf.

•   Maguire et al. (2010). Tuning in to local labor markets: Findings from the Sectoral
    Employment impact study. https://clear.dol.gov/Study/Tuning-local-labor-markets-
    Findings-Sectoral-Employment-impact-study-Maguire-et-al-2010-3.
•   Pathways to Work Evidence Clearinghouse, U.S. Department of Health and Human
    Services. https://www.pathwaystowork.acf.hhs.gov/
•   Peck, L.R., Schwartz, D., Strawn, J., Weiss, C. C., Juras, R., de la Rosa, S. M.,
    Greenstein, N., Morris, T., Durham, G., Lloyd, C. Abt Associates. (2021) A Meta-
    Analysis Of 46 Career Pathways Impact Evaluations: Final Report. Chief Evaluation
    Office, U.S. Department of Labor.
    https://www.abtassociates.com/insights/publications/report/meta-analysis-of-46-career-
    pathways-impact-evaluations.
•   Perez-Johnson, Irma. Moore, Quinn. Santillano, Robert. (October 2011). Improving the
    effectiveness of Individual Training Accounts: Long-term findings from an experimental
    evaluation of three service delivery models. Mathematica.
    https://www.mathematica.org/publications/improving-the-effectiveness-of-individual-
    training-accounts-longterm-findings-appendices.
•   Reed et al. (July 2012). An Effectiveness Assessment and Cost-Benefit Analysis of
    Registered Apprenticeship in 10 States. Mathematica.
    https://wdr.doleta.gov/research/FullText_Documents/ETAOP_2012_10.pdf.
•   Schaberg, Kelsey. (2020). Sector strategies for success. MDRC.
    https://www.mdrc.org/sites/default/files/I%26E_Sector_Strategies.pdf
•   What works in job training: A synthesis of the evidence. (2014). U.S. Department of
    Labor. https://www.dol.gov/sites/dolgov/files/OASP/legacy/files/jdt.pdf.
•   Ready to Work: Job-driven training and American opportunity. (2014). The White
    House. https://obamawhitehouse.archives.gov/sites/default/files/docs/skills_report.pdf.
•   Martinson, Karin. Cho, Sung-Woo. Loya, Karen. Dastrup, Samuel. (2021). Washington
    State's Integrated Basic Education and Skills Training (I-BEST) program: Three-year
    impact report. U.S. Department of Health and Human Services.
    https://www.acf.hhs.gov/opre/report/washington-states-integrated-basic-education-and-
    skills-training-i-best-program-three-0.
•   Workforce Investment Act Adult and Dislocated Worker Programs Gold Standard
    Evaluation. Mathematica. https://www.mathematica.org/projects/wia-gold-standard-
    evaluation.

                                                                                 Attachment VI

                                  References and Resources

The below resources are used in this TEGL:
•   Adult and Dislocated Worker key resources- work-based learning. (2020). Department of
    Labor. https://ion.workforcegps.org/resources/2017/07/14/09/08/Work-Based-Learning-
    Desk-Reference.
•   Anderson, T., et al. (2021). Racial and ethnic equity gaps in postsecondary career and
    technical education considerations for online learning. Urban Institute.
    https://www.urban.org/research/publication/racial-and-ethnic-equity-gaps-postsecondary-
    career-and-technical-education.
•   A meta-analysis of 46 career pathways impact evaluations. (December 2021). Abt
    Associates. U.S. Department of Labor.
    https://www.dol.gov/sites/dolgov/files/OASP/evaluation/pdf/A%20Meta-
    Analysis%20of%2046%20Career%20Pathways%20Impact%20Evaluations_final%20report.
    pdf.
•   Average cost-per-hire for companies is $4,129, SHRM survey finds. (2016). SHRM,
    https://ima-net.org/average-cost-per-hire-for-companies-is-4129-shrm-survey-
    finds/#:~:text=42%20days%20is%20the%20average,new%20Human%20Capital%20Bench
    marking%20Report.
•   Barden, Bret’. Juras, Randall. Redcross, Cindy. Farrell, Mary. Bloom, Dan. (May 2018). The
    enhanced transitional jobs demonstration, new perspectives on creating jobs, final impacts of
    the next generation of subsidized employment programs. MDRC.
    https://www.mdrc.org/publication/new-perspectives-creating-jobs/file-full.
•   Bellotti, Jeanne, et al. (4 September 2018). Developing American Job Centers in jails:
    anImplementation of the Linking to Employment Activities Pre-Release (LEAP) Grants.
    Mathematica Policy Research.
    https://www.dol.gov/sites/dolgov/files/OASP/legacy/files/LEAP-Final-Report.pdf.
•   Bragg, Debra D. Giani, Matt S. (November 2019). “The impact of holistic student supports
    on credential attainment for diverse adult learners in the Health Pathways Consortium.”
    Impacts of Key Community Strategies on Non-Degree Credential Completion by Adult
    Learners, Lumina Foundation. pg. 7. https://www.luminafoundation.org/wp-
    content/uploads/2019/11/impacts-of-key-community-college-strategies-on-non-degree-
    credential-completion-by-adult-learners.pdf.
•   Can subsidized employment programs help disadvantaged job seekers?(February 2020). U.S.
    Department of Health and Human Services.
    https://www.mdrc.org/sites/default/files/sted_final_synthesis_report_feb_2020.pdf.
•   Drago-Severson E. Helsing, D. Kegan, R. Popp, N.,Broderick, M.,Portnow, K. (2001). The
    Power of a Cohort and of Collaborative Groups. Focus on Basics (5). Issue B: 15-22.
    https://www.ncsall.net/index.html@id=254.html
•   “Earnings and Ratios.” Women’s Bureau. U.S. Department of Labor.
    https://www.dol.gov/agencies/wb/data/earnings.
•   Employment by detailed occupation, 2021 and projected 2031. (8 September 2022). U.S.
    Bureau of Labor Statistics. https://www.bls.gov/emp/tables/emp-by-detailed-occupation.htm.

•   Executive Order 13985 Advancing Racial Equity and Support for Underserved Communities
    Through the Federal Government.(20 January 2021).
    https://www.federalregister.gov/documents/2021/01/25/2021-01753/advancing-racial-equity-
    and-support-for-underserved-communities-through-the-federal-government.
•   Explore Registered Apprenticeship. (September 2020). U.S. Department of Labor.
    https://www.apprenticeship.gov/sites/default/files/dol-industry-factsheet-apprenticeship101-
    v10.pdf.
•   Eyster, Lauren, et al. (December 2012). Implementation Evaluation of the Community-Based
    Job Training Grant (CBJTG) Program. The Urban Institute.
    https://www.urban.org/sites/default/files/publication/23936/412890-Implementation-
    Evaluation-of-the-Community-Based-Job-Training-Grant-CBJTG-Program.PDF.
•   Financial Reporting. (1 September 2022). U.S. Department of Labor.
    https://www.dol.gov/agencies/eta/grants/management/reporting..
•   Glasmeier, Amy K. (2021). Living Wage Calculator. The Massachusetts Institute for
    Technology. https://livingwage.mit.edu/.
•   Good Jobs Principles Fact Sheet. (2022). U.S. Department of Labor.
    https://www.dol.gov/sites/dolgov/files/goodjobs/Good-Jobs-Summit-Principles-
    Factsheet.pdf.
•   Hoops, J. (2010). A Working Model for Student Success: The Tennessee Technology Centers.
    Complete College America. https://eric.ed.gov/?id=ED536826.
•   Impacts of Key Community College Strategies on Non-Degree Credential Completion by
    Adult Learners. (November 2021). Lumina Foundation.
    https://www.luminafoundation.org/wp-content/uploads/2019/11/impacts-of-key-community-
    college-strategies-on-non-degree-credential-completion-by-adult-learners.pdf.
•   Implementation of the Nondiscrimination and Equal Opportunity Provisions of the
    Workforce Innovation and Opportunity Act, 29 C.F.R. part 38.
•   Occupational Employment and Wage Statistics. (May 2021). U.S. Bureau of Labor
    Statistics. https://www.bls.gov/oes/tables.htm.
•   Office of Apprenticeship. (May 2023). U.S. Department of Labor.
    https://www.apprenticeship.gov/?utm_source=dol_gov_agencies_eta_apprenticeship&utm_
    medium=text&utm_campaign=apprenticeship_homepage
•   O*Net Online. (November 2022). https://www.onetonline.org/.
•   On-the-Job Training (OJT) Toolkit.(2020), U.S. Department of Labor.
    https://ion.workforcegps.org/resources/2017/12/01/11/19/On-the-Job-Training-Toolkit.
•   Perez-Johnson, Irma. Moore, Quinn. Santillano, Robert. (October 2011). Improving the
    Effectiveness of Individual Training Accounts: Long-Term Findings from an Experimental
    Evaluation of Three Service Delivery Models. Mathematica.
    https://www.mathematica.org/publications/improving-the-effectiveness-of-individual-
    training-accounts-longterm-findings-appendices.
•   Program Year 2021 preliminary expenditure data. (1 September 2022)U.S. Department of
    Labor.
•   Rapid evidence review strategies from the Great Recession to support employment. (March
    2021), Mathematica.
    https://clear.dol.gov/sites/default/files/documents/files/CLEAR_GreatRecessionRR_Synth_2
    02107.pdf.

•   Supportive Services Desk Reference. (August 2021). U.S. Department of Labor.
    https://ion.workforcegps.org/resources/2017/07/14/09/22/Supportive_Services_Desk_Refere
    nce.
•   TEN 12-21: Practitioners Guide to Supportive Services.(15 October 2021). U.S. Department
    of Labor. https://wdr.doleta.gov/directives/corr_doc.cfm?docn=9977.
•   TEN 19-22, Change 1, Reporting Training in the U.S. Department of Labor’s (DOL)
    Participant Individual Record Layout (PIRL). (27 February 2023).U.S. Department of Labor.
    https://www.dol.gov/agencies/eta/advisories/ten-19-22-change-1.
•   TEGL 08-19, Change 1.Guidance on Registered Apprenticeship Provisions and
    Opportunities in the Workforce Innovation and Opportunity Act (WIOA). (17 May 2021),
    U.S. Department of Labor. https://www.dol.gov/agencies/eta/advisories/training-and-
    employment-guidance-letter-no-08-19-change-1.
•   TEN 12-21, Practitioners Guide to Supportive Services. (15 October 2021). U.S. Department
    of Labor. https://wdr.doleta.gov/directives/corr_doc.cfm?docn=9977
•   TEN 13-12: Defining a Quality Pre-Apprenticeship Program and Related Tools and
    Resources. (30 November 2012). U.S. Department of Labor.
    https://www.dol.gov/sites/dolgov/files/ETA/advisories/TEN/2012/TEN_13-12.pdf.
•   TEGL 13-16, Guidance on Registered Apprenticeship Provisions and Opportunities in the
    Workforce Innovation and Opportunity Act (WIOA). (12 January 2017). U.S. Department of
    Labor. https://www.dol.gov/sites/dolgov/files/ETA/advisories/TEGL/2017/TEGL_13-16.pdf.
•   TEGL 19-16, Guidance on Services provided through the Adult and Dislocated Worker
    Programs under the Workforce Innovation and Opportunity Act (WIOA) and the Wagner-
    Peyser Act Employment Service (ES), as amended by title III of WIOA, and for
    Implementation of the WIOA Final Rules. (1 March 2017). U.S. Department of Labor.
    https://www.dol.gov/agencies/eta/advisories/training-and-employment-guidance-letter-no-
    19-16.
•   TEN 12-21, Practitioners Guide to Supportive Services. (15 October 2021). U.S. Department
    of Labor. https://wdr.doleta.gov/directives/corr_doc.cfm?docn=9977.
•   Training Data. (2022).U.S. Department of Labor.
•   What Works in Job Training: A Synthesis of the Evidence. (22 July 2014). U.S. Department
    of Labor. U.S. Department of Commerce. U.S. Department of Education. U.S. Department of
    Health and Human Services.
    https://www.dol.gov/sites/dolgov/files/OASP/legacy/files/jdt.pdf.
•   Work Based Learning Desk Reference.(2020). U.S. Department of Labor.
    https://ion.workforcegps.org/resources/2017/07/14/09/08/Work-Based-Learning-Desk-
    Reference.
•   WIOA Performance Data: PY 2018, PY 2019, PY 2020. U.S. Department of Labor.
    https://www.dol.gov/agencies/eta/performance/results.

What does federal law require in your situation?

Ezel checks current federal labor law against your facts and answers with citations.

Opens in Ezel Pro.

  • Checks the law as it stands today, not only this page
  • Cites every source it relies on, so you can verify it
  • Chat, drafting and research in one workspace