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WIA MOU Guidelines For VESID

Workforce Investment Act Technical Assistance for VESID District Managers and Guidelines for VESID Participation In the One-Stop Service Delivery System

One-Stop Service Delivery

The WIA establishes the One-Stop Service Delivery System as the regional/local access point for employment related and training services. All core services must be available at at least one physical location, which may be supplemented by multiple additional sites and technological networks/linkages. Core services are intended to be self-accessed and must be available to all one-stop users. Individuals requiring more support may access intensive services from the one-stop or its partners. Training services are intended for individuals who require such services before they can become employed. The focus of all services is based on a work-first services approaches.

Required Core Services (allocated among appropriate share of partners)

  • Eligibility determination (for Title I WIA)
  • Outreach, worker profiling, orientation
  • Initial assessment
  • Labor Market Information
  • Information on eligible providers, performance outcomes
  • Job search, placement assistance, career counseling
  • Follow-up services (at least 12 months)

Potential Intensive Services (VESID typically may contribute)

  • Comprehensive and specialized assessment
  • Development of Individual Employment Plan
  • Group/individual counseling and career planning
  • Case Management
  • Short-term vocational preparation (soft-skills development)

Training Services (VESID typically should contribute/purchase)

  • Occupational skills training
  • Workplace training, on-site instruction
  • Entrepreneurial training
  • Job Readiness training
  • Adult Education and literacy activities
  • Skills upgrading and retraining
  • On the Job training
  • Customized training (for individual or specific occupation)

The regional WIB will charter the One-Stop and partner agencies will participate through Memorandums of Understanding, Mandated one-stop partners include:

  • Department of Labor (WIA, Title III)
  • WIA Title I programs
  • Welfare-to-Work Block Grant
  • Adult Education and Literacy (WIA, Title II)
  • Post Secondary Vocational Education
  • Trade Adjustment Act Representation (NAFTA)
  • HUD Employment and Training
  • Community Services Block Grant agencies
  • Unemployment Insurance
  • Vocational Rehabilitation (WIA, Title IV)

Memorandum of Understanding

The local WIB, with the agreement of the chief local elected official, must develop and enter into a memorandum of understanding between the local Board and the one-stop-partners. Each MOU must contain provisions describing:

  • The services to be provided through the one-stop system;
  • How the cost of such services and the operating costs of the system will be funded;
  • Methods for referral of individuals between the one-stop operator and the one-stop partners, for appropriate services and activities; and
  • The duration of the MOU and procedures for amending.

The WIB may either develop an umbrella MOU between all one-stop partners or separate MOU’s for individual partners or specific services. The MOU template developed by DOL and State partners is attached.

Individual Training Accounts

The WIA requires local boards to establish Individual Training Accounts (ITA) on behalf of participants. These accounts (for Adults and Dislocated Workers, Title I) will be used to purchase training services from eligible providers selected by the participant and approved by the WIB. Payments from ITAs may be conducted in a variety of ways, including electronic transfer of funds, vouchers, credits or other appropriate methods. The allocation within an ITA may have limits set by the one-stop and/or their partners. The application form for service providers under WIA Title I is attached.

VESID has the ability to work with the WIB and one-stop to establish appropriate fees for employment services and may work alternative payment methods (consistent with VESID policy/practice) for ITA payments.

There are three exceptions when a contract (or alternative) may be used instead of an ITA:

  • OJT or customized training
  • Insufficient number of eligible providers for required service
  • Determination by the WIB that there is a training services program of demonstrated effectiveness offered in the region by a community-based organization or another organization to serve special participant populations.

Special participant populations includes individuals with substantial language or cultural barriers; offenders; homeless individuals; and other hard-to-serve populations as defined by the Governor.

Services to Youth and Youth Councils

The WIB will appoint a Youth Council upon approval by the chief local elected official. This is not intended to be a solely advisory function, but under the WIA, the Council must:

  • Develop portions of the local service plan that relate to the employment and training needs of eligible youth;
  • Recommend eligible providers of youth activities, including funding recommendations;
  • Conduct oversight of these providers; and
  • Coordinate youth activities in the local area.

The WIB combines the JTPA Youth Allocations and Summer Youth Employment activities. Specific funding allocations for each service no longer apply.

The VESID DO should identify where it can assist the local WIB and Youth Council in assisting youth with disabilities to achieve core indicators. As with other services, customer satisfaction will also be a measure. It should be noted that a WIB must use 30% of its funds for out-of-school youth. An out-of-school youth is defined as a school dropout, or an eligible youth who has received a secondary school diploma (or equivalent), but is basic skills deficient, unemployed, or underemployed. VESID youth consumers should meet this criteria and VESID should be in a position to assist WIBs in meeting this 30% criteria (particularly in small or rural counties).

Membership on Youth Councils will include:

  • WIB members with special interest or expertise in youth policy;
  • Representatives of youth service agencies, including juvenile justice;
  • Representative of local public housing authorities;
  • Parents of WIA Title I Youth;
  • Job Corps representatives;
  • Individuals and representatives of organization having experience relating to youth activities (including former participants) and
  • Other individuals as designated by the CLEO.

Given the breath of responsibilities for the Youth Council, it is imperative that the VESID District Office have a strong involvement, including facilitating the membership of youth with disabilities on the Council or in working subgroups. The "Plan for Youth Activities" outlining Youth Council requirements is attached. An additional reference is the "Youth Council Toolkit" developed jointly by DOL and SED, and accessible through both agency's websites.

Guidelines for VESID Participation

These Guidelines are intended to provide VESID District Offices with direction and guidance regarding programmatic and fiscal participation in the One-Stop Service delivery system as specified under the Workforce Investment Act (Public Law 105-220). These Guidelines should be applied consistently with Federal Cost Principles set forth by the Office of Management and Budget, the NYS Department of Labor's "Guidelines for Cost Allocation Plans" (attached), and the NYATEP "Toolkit on Services and Funding".

Once all the One-Stop System partners have established their service plan as to the type of services available, configuration and responsibilities, the partners will identify the cost of operating the system. When reference is made to the One-Stop System, what must be included are components of the system including the:

  • One-Stop Center
  • One-Stop Operator
  • Affiliate locations
  • Other components as agreed upon by local partners

"Workforce Investment System" costs may also include the costs of:

  • Local Workforce Investment Boards (WIB)
  • Youth Councils
  • Grant recipient/fiscal agents

VESID may fund such costs when these costs are directed at VR eligible persons and these costs would have been otherwise incurred by VESID in serving such persons. District Managers have the flexibility to commit resources to innovative efforts conducted as part of the generic workforce investment activities that will result in improved outcomes for individuals with disabilities.

VESID Financial Principles

COST ALLOCATIONS MUST BE REASONABLE, ALLOCABLE AND NECESSARY.  ALL COST ALLOCATION PLANS MUST BE SUBMITTED BY THE LOCAL WIB TO THE APPROPRIATE COGNIZANT STATE/FEDERAL AGENCY FOR APPROVAL.

Operational (System) Costs:

Shared system costs may be assigned to the following categories as incurred by system components.

  • System Administration (costs of Board, Councils, etc.)
  • Facilities (fixed assests and maintenance, i.e., rent, utilities)
  • Technology (common database, partner connectivity)
  • Performance Tracking
  • Capacity Building (Staff development for board, staff, partners)
  • Planning (continuous improvement costs)
  • Marketing
  • Operations (consumable costs, i.e., travel)
  • Other (as agreed to by local partners)

Any costs to be funded from Vocational Rehabilitation funds must be attributable only to the amount spent on eligible vocational rehabilitation (VR) consumers as determined by VESID. A reasonable allocation method must be used to distribute the costs to the VR program. The type of allocation methodology used is not critical and should not be an issue for VESID District Managers. Different allocation methods may be used for different components of the system. The following are the allocation methods that may be used:

Direct Charging – Separate, distinct costs that are directly attributable to the VR program. Examples of such costs are telephone charges for the phone on a counselor’s desk or the cost of a computer for VR personnel.

Cost Pooling – Costs are collected, or pooled, for certain activities and then charged back to the specific programs that benefited from these activities. An example of this method is taking all the costs attributable to certain operations of a one stop and charging them back to each partner based on the percentage of registered consumers served by each partner in relation to all the registered consumers served by the one-stop.

Indirect Costs

Indirect costs are costs that have been incurred for a common or joint purpose and cannot be readily identified with a particular final cost. A method of allocation must be used to distribute the indirect costs to the program services or partners. A cost may not be allocated as indirect if that cost has been assigned to a program as a direct cost. An example of this method is taking all of the administrative costs of a one-stop and charging it back to each partner as a percentage of their direct costs such as adding a percentage on to each cost of an assessment.

Direct Service Costs

Direct service costs include all core and intensive costs specifically directed to registered individuals. All services that were previously funded by another partner must continue to be funded by that partner. Allowable services are defined as any goods or services necessary to render an individual with a disability employable as agreed to under the consumer's Individualized Plan for Employment. VESID does not pay for costs for reasonable accommodations that are the responsibility of the other agencies. For example, VESID will not pay for ramps at the One-Stop Center or interpreters for program participants who are not VR eligible.

Direct service costs such as intake or assessment are allowable VR costs if related to assessing an individual's eligibility and service needs for VR, but VR funding must not be considered as the only source to fund assessments for all one-stop consumers. Intake or assessment costs may be distributed to the VR program. Such a distribution must be based on a reasonable allocation method. VESID will only pay for the value added costs of these services as they relate to disability issues. The following are allocation methods that may be used:

Direct Charging – Separate, distinct costs that are directly attributable to the VR program and VR consumers. An example of this method would be if VESID were to directly pay for intake or assessment.

Cost Pooling – Costs are collected, or pooled, for certain activities and then charged back to the specific programs that benefited from these activities. An example of this method is taking all of the assessment costs of a one stop and charging them back to each partner based on the percentage of registered consumers in the one-stop served by each partner.

Activity Based Cost Allocation Plans – This is a relatively complex method of allocating costs to specific activities based on the resources that the activities consume. This method provides detailed component cost breakdowns for services delivered. For example, if a one stop spent considerably more effort on assessments as compared to other services it provides, the proportionate costs for assessments would be higher.