Policy Chapters and Sections

Allowable Costs Towards Training Expenditure

Chapter: 8 Section: 4.1
Effective Date: 7/1/2018
Expiration Date: Continuing
Published Date: 8/18/2021 11:19:49 AM
Status: Current
Version: 3

Tags: Fiscal Reporting and Accountability, Incentive Award, Training Expenditure, Administration, Fiscal

As defined within this policy, only certain WIOA-funded services will be considered as “calculable” LWIB expenditures toward the minimum training calculation. For purposes of this policy, the calculable services include:

  1. Occupational Skills Training
    An organized program of study that provides specific vocational skills that lead to proficiency in performing actual tasks and technical functions required by certain occupational fields at entry, intermediate, or advanced levels.
    1. Occupational skills training includes training programs that lead to recognized postsecondary credentials that align with in-demand industry sectors or occupations in the local area. Occupational skills training must (29 CFR Part 681.540):
      1. Be outcome-oriented and focused on an occupational goal specified in the individual service strategy;
      2. Be of sufficient duration to impart the skills needed to meet the occupational goal; and
      3. Result in attainment of a recognized postsecondary credential.
    2. Occupational Skills Training costs that are calculable include:
      1. Occupational Skills Training Individual Training Accounts (ITAs):  Payments made to a training institution or training provider for occupational classroom training authorized pursuant to an ITA (see the Individual Training Accounts (ITAs) section of the policy manual).
      2. Occupational Skills Training – Non-ITA:  Payments made to a training institution, training provider, including community-based organizations, or other private organization of demonstrated effectiveness (see the Programs of Demonstrated Effectiveness subsection of the Individual Training Accounts (ITAs) section of the policy manual) for occupational classroom training authorized pursuant to a contract for training services, or other contractual arrangement that constitutes an exception to the use of an ITA (29 CFR Part 680.320).
      3. Class-Size Training:  Class-Size Training Contracts can occur when there is a need to place multiple WIOA-registered students in the same training program with one (1) educational institution or eligible training provider (see the Class-Size Training section of the policy manual).
      4. Pay-for-Performance Contract:  Contracted training service that provides payment structure funding only when agreed upon measures are achieved within a specific timeframe. Note:  USDOL has indicated that further guidance on this new type of training is forthcoming.
  2. Work-Based Learning
    Includes on-the-job training, customized training, incumbent worker training, work experience, and transitional jobs as outlined in WIOA and the final rule.
    1. On‐the‐Job Training (OJT):  Contract(s) with an employer(s) in the public, private non‐profit, or private sector.
      1. Training does not have to occur at the employer’s location.
      2. As part of a participant’s Individualized Services Employment and Training Plan, OJT may combine other types of training such as work experience, classroom, and remediation.
      3. Classroom training paid for using an Individual Training Account.
      4. OJT may combine with ITAs to support placing participants into Registered Apprenticeship programs.
      5. When combining OJT with other types of training such as those above, only the OJT hours are eligible for wage reimbursement.
      6. Through the OJT contract, occupational training is provided to the WIOA participant in exchange for the reimbursement of the extraordinary costs of providing training and the supervision related to the training. 
      7. OJT must comply with requirements in the OJT General Requirements subsection of the Work-Based Learning section of the policy manual.
    2. Customized Training:  Costs associated with training that meets the special requirements of an employer or group of employers, conducted with a commitment by the employer to employ all individuals upon successful completion of training, and for which the employer pays for a significant cost of the training, as determined by the Local Workforce Innovation Board (LWIB) in accordance with the factors identified in WIOA Section 3(14) and the Customized Training subsection of the Work-Based Learning section of the policy manual. 
    3. Incumbent Worker Training:  Training to workers that have an established employment history with the employer for six (6) months or more, or be part of a cohort that includes employees that have a six (6)-month employment history with the employer.
      1. The employer must commit to retain or avert the layoffs of the incumbent worker(s) trained. (The Incumbent Worker Training (IWT) subsection of the Work-Based Learning section of the policy manual)
    4. Work Experience/Internships:  Costs associated with a planned, structured, time‐limited learning experience that takes place in a workplace as a work experience or internship.
    5. Transitional Jobs:  Costs associated with a limited work experience, that is subsidized in the public, private, or non‐profit sectors for those individuals with barriers to employment who are chronically unemployed or have an inconsistent work history; these transitional jobs are designed to enable an individual to establish a work history, demonstrate work success, and develop the skills that lead to unsubsidized employment. 
    6. Apprenticeships:  Costs associated with administering an Apprenticeship Program as outlined in the On-the-Job Training (OJT) section of the policy manual.
      1. ITAs may be combined with OJT funds to support the training component of a registered apprenticeship program, just as they can be used together for a participant who is not in a registered apprenticeship.  (See the OJT Apprenticeship subsection of the Work-Based Learning section of the policy manual)
      2. Calculable expenses would include all payments made to the public, not-for-profit or private training provider, including a host employer, for the cost of the training program.
      3. Apprenticeships in Illinois have been reviewed by Illinois’ Workforce Readiness through Apprenticeships and Pathways (WRAP) Committee and an IWIB Standing Committee to create flexibility in the use of this type of training, be innovative in the types of apprenticeships utilized in Illinois and expand apprenticeships beyond traditional sectors and industries. The WRAP Committee adopted the following apprenticeship definition: “An employer-driven, ‘learn while you earn’ model that combines structured on-the-job training (OJT) with job-related instruction in curricula tied to the attainment of industry-recognized skills standards and leading to an industry credential. The OJT is provided by the employer, who hires the apprentice at the commencement of the program and pays the participant during the program.”
    7. This also includes the wages and staff costs for the development and management of work-based learning programs.
  3. Occupational Bridge Programs
    Bridge programs prepare adults with limited academic or limited English skills to enter and succeed in credit-bearing postsecondary education and training leading to career-path employment in high-demand, middle- and high-skilled occupations. The goal of bridge programs is to sequentially bridge the gap between the initial skills of individuals and what they need to enter and succeed in postsecondary education and career-path employment.
    1. This training blends workplace competencies, career exploration, and basic literacy and math skills in an occupational context. It provides accelerated advancement through short, intensive classroom components, and offers academic and personal support services to help balance work, family, and school responsibilities.
    2. The participant’s individual employment plan must document the career path and the bridge program training approach.
    3. A bridge program must target one (1) or more of the following for consideration as an allowable training expenditure:
      1. Low-skilled, low-income adults unprepared to enter postsecondary occupational programs in high growth fields;
      2. Adult education students who still do not score high enough to enter postsecondary occupational programs; or
      3. Employability and career development content, if the major focus of the program is on academic remediation and occupational skills preparation.
      4. Occupational Bridge Programs must comply with requirements in the Bridge Programs and Career Pathways section of the policy manual.
  4. Other Forms of Training-Related Services Not Otherwise Detailed Above
    For all other types of allowable training-related services not mentioned above, the local workforce innovation board or staff should request clarification from the Illinois Workforce Innovation Board prior to incurring the cost to ensure the training service is allowable and to determine if the costs for services can be calculable.
    1. This category addresses any new or innovative type of training-related service that directly prepares a participant for unsubsidized employment or which could be calculable as part of a combined strategy with another calculable training service.
    2. These may include other types of training services such as programs that combine workplace training and related instructions which may include cooperative education programs, training programs operated by the private sector, or skill upgrading and retraining.
  5. Allowable Training and Educational Services Provided in Conjunction with Occupational Skills or Work-Based Training Programs
    Certain types of training or education services may benefit a participant in reaching their education and employment goals.
    1. While typically considered a career service, they may be calculable when provided in conjunction or combination with other allowable training program types listed above.
    2. They are not calculable if provided by local workforce innovation board or area staff.
    3. This type of service might include the following:
      1. English Language Acquisition and Integrated Education and Training Programs
        1. The term “adult education and literacy activities” means programs, activities, and services that include adult education, literacy, workplace adult education and literacy activities, family literacy activities, English language acquisition activities, integrated English literacy, and civics education, workforce preparation activities, or integrated education and training.
      2. Remedial Training/Pre-Vocational Services
        1. All payments made to a training institution or training provider for classroom instruction in academic remediation or short-term pre-vocational services which is normally classified as an intensive service.
        2. These services may be no more than six (6) months in duration, unless provided in conjunction with occupational training services.
        3. This also includes costs associated with basic literacy training, including but not limited to, adult basic education, high school equivalency education, and English as a second language.
      3. Job Readiness Training
        1. Job readiness training programs prepare participants to get, keep and excel at a new job and may include basic employability skills including:
          1. effective communication, problem solving, resume building, and interviewing; and
          2. programs that help participants develop good work habits that facilitate their ongoing success.
  6. Books, Materials, and Related Materials
    These are costs paid to a training institution, training provider or individual participant for books, training materials, required uniforms and other workplace attire, tools or equipment required for training and training-related licenses, permits, or fees.  This includes assistive devices for individuals with disabilities that are necessary to ensure the individuals can participate in, and/or complete training.
  7. Participant Support
    These are supportive services paid to or on behalf of a participant enrolled in training or in the twelve (12)-month follow-up period after placement into unsubsidized employment, such as transportation, childcare, tutoring, and mentoring.  Includes support services to participants who receive training from a source other than WIOA funds, e.g., Pell Grants. This category also includes needs-related payments to WIOA participants in training.
    1. Follow-up supportive services are not allowable if the adult/DW participant has been exited and/or is not receiving career or training services.
  8. Leveraged Training Resources
    1. An LWIB may apply leveraged resources spent on training services toward meeting a portion of their minimum training expenditure requirement.
      1. These leveraged training expenditures are allowable up to ten percent (10%) of their combined adult and dislocated worker formula fund allocation.
      2. Calculable expenditures under this section include:
        1. Rapid Response;
        2. EPIC (Employment Opportunities; Personalized Services; Individualized Training; Career Planning for Supplemental Nutrition Assistance Program (SNAP) recipients);
        3. Building Futures grants;
        4. U.S. Department of Labor National Emergency Grants or Dislocated Worker Grants; and
        5. Talent Pipeline grants.
    2. An LWIB providing Title I activities, such as eligibility and case management services, as part of an allowable leveraged grant for which another entity (partner/agency) is the grant recipient and covers the training activities outlined in Occupational Skills Training and Work-Based Learning sections of this policy, may apply those training costs as leveraged resources.
      1. Participants receiving training as part of the grant must be enrolled in WIOA.
      2. Staff costs related to eligibility and case management are not calculable.
    3. Beginning with the implementation of this policy on July 1, 2018, LWIBs may collect expenditure data associated with other sources of training funds.
      1. These expenditures will be analyzed and considered for inclusion as calculable leveraged training expenditures beginning on July 1, 2019. Examples include:
        1. Other public programs authorized by the WIOA (e.g., Job Corps, Migrant Seasonal Farm Worker, WIOA Title II Adult Education and Literacy, national and state WIOA discretionary grants, WIOA youth program, etc.);
        2. Federal Pell Grants established under Title IV of the Higher Education Act of 1965;
        3. MAP grants; and
        4. Match funds from employers, industry, and industry associations.

WIOA Final Rules, Part 677, Subpart A - State indicators of performance for core programs

WIOA Final Rules, Part 677, Subpart F - Performance reporting administrative requirements

WIOA Final Rules, Part 678, Subpart C - Memorandum of understanding for the one-stop delivery system

WIOA Final Rules, Part 680, Subpart C - Individual training accounts

WIOA Final Rules, Part 680, Subpart F - Work-based training

WIOA Section 134 - Adult and Dislocated Worker Employment and Training Activities, Use of funds

WIOA Final Rules, Part 681, Subpart C - Youth program design, elements, and parameters

WIOA Final Rules, Part 680, Subpart A - Delivery of Adult and Dislocated Worker Activities

Training Provider and Training Program Eligibility

On-the-Job Training (OJT)

Regional and Local Planning Requirements

Incentives and Sanctions for Performance

2 CFR 2900 Uniform Guidance UNIFORM ADMINISTRATIVE REQUIREMENTS, COST PRINCIPLES, AND AUDIT REQUIREMENTS FOR FEDERAL AWARDS

2 CFR 200 Uniform Guidance UNIFORM ADMINISTRATIVE REQUIREMENTS, COST PRINCIPLES, AND AUDIT REQUIREMENTS FOR FEDERAL AWARDS

USDOL Training and Employment Guidance Letter (TEGL) No. 08-18, Workforce Innovation and Opportunity Act (WIOA) Title I and Wagner-Peyser Act Waiver Requirements and Request Process (December 19, 2018)

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