Center Certification Policy

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Center Certification Policy

Approved and Published: October 2019

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Purpose

To provide guidance and establish COWIB policy regarding Center Certification of the Oklahoma Works American Job Center (AJC) system in accordance with the Oklahoma Office of Workforce Development (OOWD) policy issuance OWDI #01-2019.

Authority

The authority for this policy is derived from the following:

Background

WIOA envisions high-quality American Job Center (AJC) systems that are business driven, customer-centered, integrated, and tailored to meet the needs of the local workforce development area. The law emphasizes the need for partnerships and strategies that align workforce development, education, and economic development programs with regional needs. To be eligible to receive infrastructure funding as described in WIOA Sec. 121(h), local boards must assess the local one-stop delivery system at least once every two (2) years.  Such an assessment must include the effectiveness, physical and programmatic accessibility in accordance with WIOA Sec. 188, if applicable, and the Americans with Disabilities Act of 1990 (42 U.S.C.121101 et. Seq.).  

The Oklahoma Works /AJC system must be comprehensive, flexible, innovative, employer-driven, customer-focused and performance-based. The workforce one-stop system must also respond to customer needs, and be adaptable to the rapid changes in the global economy.

In an effort to ensure that the workforce one-stop system meets minimum quality standards, including the effective integration of services, and in anticipation of meeting requirements in WIOA, the Oklahoma Office of Workforce Development has developed a minimum standard for Oklahoma Works Centers/ American Job Center (AJC) certification.

Roles and Responsibilities

WIOA Sec. 121(g)(1) requires the State workforce development board (state board), in consultation with chief local elected officials (CLEOs) and LWDBs, to establish objective criteria and procedures for use by LWDBs in assessing and certifying comprehensive and affiliate one-stop centers for effectiveness, including customer satisfaction, physical and technology accessibility, and continuous improvement. The Oklahoma Office of Workforce Development has issued OWDI 01-2019 in which they state criteria and procedures setting the standards for which local workforce boards must apply to ensure each comprehensive and affiliate one-stop center meets minimum criteria for certification. Per WIOA Sec. 121 (g)(3), LWDBs may develop additional criteria to respond to labor market, economic, demographic, or other conditions or priorities within their region or local area. If they do, they must also review and update those additional criteria and standards every two years as part of the WIOA Local Plan update process. Any additional criteria must be clearly identified in addenda to the Certification Checklist. Each local area must have at least one physical comprehensive one-stop center location that provides on-demand access to career services, training services, employment services, and all required programs and data. Utilizing OWDI 01-2019 certification criteria LWDBs must establish a certification team to certify one-stop sites at least once every two years in order for those sites to share infrastructure costs among the required partners; however, in order to ensure an aligned schedule of updating the certification criteria and conducting the certifications, the OOWD established that the certification team shall certify one-stop sites every two years. States, in conjunction with the Local WDBs, must examine lease agreements and property holdings throughout the one-stop delivery system in order to use property in an efficient and effective way. Where necessary and appropriate, States and Local WDBs must take expeditious steps to align lease expiration dates with efforts to consolidate one-stop operations into service points where Wagner-Peyser Act employment services are co-located as soon as reasonably possible. These steps must be included in the State Plan. The State’s Board must certify the one stop centers.

The core and required partners must share infrastructure cost of the certified comprehensive center regardless of State or Local funding mechanisms.

Minimum Certification Criteria

The Governor’s Council for Workforce and Economic Development (GCWED or The Council), in consultation with the CLEO and COWIB, must establish objective criteria and procedures to apply when certifying comprehensive and affiliate Oklahoma Works (One-Stop) Centers.

Categories comprising the Oklahoma Works AJC (One-Stop Center) certification criteria include:

  • Customer Focus
  • Operations and Infrastructure
  • Equal Opportunity and Accessibility
  • Personnel
  • Continuous Improvement

These categories of criteria stem from the four larger categories identified in WIOA.  These are:

  • Effectiveness Criteria

These criteria evaluate the comprehensive and affiliate Oklahoma Works AJC’s (One-Stop Center) effectiveness in meeting the workforce development needs of participants and the employment needs of businesses.  They also evaluate whether the center is operating in a cost-efficient manner, coordinating services among partner programs physically or through direct linkage on demand and in real time, and providing maximum access to partner program services at times that meet participant needs, including providing services outside of regular business hours where there is a workforce need, as identified by the COWIB.  (20 CFR 678.800(b)).  Effectiveness also means required partners focus on outcomes and have the capacity to measure attainment of goals and other outcomes.

  • Physical Accessibility Criteria

Minimum certification criteria are required by WIOA to evaluate the comprehensive and affiliate Oklahoma Works AJC’s (One-Stop Center) physical accessibility.  This includes ensuring that the center’s location and layout are inclusive of individuals regardless of their range of abilities and mobility, and that reasonable accommodations for access are provided, when appropriate.  This also requires the physical characteristics of the facility to conform to checkpoints found in the Oklahoma Works Access for All Initiative Physical Accessibility Checklist.  (https://www.okabletech.org/wp-content/uploads/2017/08/PhysicalSite_Accessibility_Checklist.docx).

  • Programmatic Accessibility Criteria

These criteria evaluate the comprehensive Oklahoma Works AJC’s (One-Stop Center) programmatic accessibility, ensuring it provides equal access to all required programs, services, and activities to eligible participants and to employers regardless of their range of abilities, mobility, age, language, learning style, intelligence, or education level.  Essentially, services must be made available without unlawful discrimination.

Programmatic Accessibility actions include, but are not limited to:

  1. Making reasonable modifications to policies, practices, and procedures where necessary to avoid discrimination against any persons, including those with disabilities;
    1. Administering programs in the most appropriate integrated setting;
    1. Communicating with persons with disabilities as effectively as with others; and
    1. Providing appropriate auxiliary aids and services, including assistive technology devices and services, where necessary to afford individuals with disabilities an equal opportunity to participate in and enjoy the benefits of the program or activity.

Technology – In addition, minimum certification criteria are required in Oklahoma to evaluate the One-Stop Center’s technology environment for accessibility.  This includes ensuring that the center’s website, social media and other software offered for use by Job Seekers is accessible.  Such technology must adhere to the Web Content Accessibility Guidelines 2.0, Level AA.  In addition, the Center must conform to the Oklahoma Works Access for All Information and Communication Technology Checkpoints.  (https://www.okabletech.org/employment-services/oklahoma-works-access-for-all/roadmap-for-accessibility-certification/information-and-communication-technology-ect-checkpoints/).  In instances where the center does not meet all of the checkpoints, the center will create an Equally Effective Alternative Access Plan.

The full Oklahoma Works Access for All certification process is located here:  (https://www.okabletech.org/employment-services/oklahoma-works-access-for-all/roadmap-for-accessibility-certification/)  This site details the requirements necessary and provides tools to receive certification under the Oklahoma Works Access for All initiative.

  • Continuous Improvement Criteria

These criteria evaluate the comprehensive and affiliate Oklahoma Works AJC’s (One-Stop Centers) continuous improvement, meaning the center has the mechanisms and processes in place and has the capacity to assess and improve upon the effectiveness, physical accessibility, and programmatic accessibility of the center.  This includes a regular process for identifying and responding to technical assistance needs, a regular system of continuing professional staff development, and having systems in place to capture and respond to specific customer feedback.  Continuous improvement also includes supporting the achievement of the negotiated levels of performance for the local indicators of performance (20 CFR 678.800(c)).

Detailed certification criteria are identified in Attachment A:  Oklahoma Works (One-Stop) Center Certification Checklist (Attachment B).  To evaluate one-stop centers on the required certification criteria, COWIB must use the Certification Checklist.  GCWED, in consultation with CLEO and COWIB, must review and update the Certification Checklist criteria every two years as part of the review and modification of the WIOA State Plan.

Under the provisions of OWDI #01-2019, the COWIB has established additional criteria, to include Center Certification Pre-Assessment and Request for affiliate centers by the One-Stop Operator.  Additional criteria established by COWIB must also be reviewed and updated every two years as part of the WIOA Local Plan update process.  Additional criteria are clearly identified in addenda to the Certification Checklist.

Definitions

Comprehensive Center

A comprehensive one-stop center is a physical location where job seeker and employer customers can access the programs, services, and activities of all required one-stop partners. A comprehensive one-stop center must have at least one title I staff person physically present.

The comprehensive one-stop center must provide:

  • Career services, described in 20 CFR 678.430 and TEGL 16-16;
  • Access to training services described in 20 CFR 680.200;
  • Access to any employment and training activities carried out under sec.134(d) of WIOA;
  • Access to programs and activities carried out by one-stop partners listed in 20 CFR 678.400 through 678.410, including the Employment Service program authorized under the Wagner-Peyser Act, as amended by WIOA title III (Wagner-Peyser Act Employment Service program); and
  • Workforce and labor market information.

Customers must have access to these programs, services, and activities during regular business days and hours at a comprehensive one-stop center. The Local Workforce Development Board (LWDB) may establish other service hours at other times to accommodate the schedules of individuals who work on regular business days.

“Access’’ to each partner program and its services means:

  • Having a program staff member physically present at the one-stop center;
  • Having a staff member from a different partner program physically present at the one-stop center appropriately trained to provide information to customers about the programs, services, and activities available through partner programs; or
  • Making available a direct linkage through technology to program staff who can provide meaningful information or services.

A ‘‘direct linkage’’ means providing direct connection at the one-stop center, within a reasonable time, by phone or through a real-time Web-based communication to a program staff member who can provide program information or services to the customer.

A ‘‘direct linkage’’ cannot exclusively be providing a phone number or computer website that can be used at an individual’s home; providing information, pamphlets, or materials; or making arrangements for the customer to receive services at a later time or on a different day. If the direct linkage is provided via telephone, access must be a phone line dedicated to serving one-stop customers in a timely manner. If the direct linkage is provided via technology, access must enable trained staff to provide remote assistance through technology such as live web chat (e.g. Skype, Facetime), video conference, or other similar technology that involves a form of one-on-one assistance. As applicable and practical, one-stop partners should make services accessible to individuals electronically in a way that improves efficiency, coordination, and quality in the delivery of one-stop partner services.

All comprehensive one-stop centers and the technology they provide to Job Seekers must be accessible to individuals with disabilities, as described in 29 CFR part 38, the implementing regulations of WIOA sec.188.  Oklahoma’s Access for All was developed as a system-wide effort and includes two parts to the Access for All Certification in Oklahoma. One considers accessibility in the physical space and the other considers accessibility in technology. Both focus on the environments that Job Seekers interact with when participating in services provided by the Oklahoma Works Workforce System Partners. In the end, Oklahoma Works Workforce System Partners and Workforce Areas work through an Access for All Accessibility Process to achieve certification.

Affiliate Center

An affiliated site, or affiliate one-stop center, is a site that makes available to job seeker and employer customers one or more of the one-stop partners’ programs, services, and activities with a physical presence of combined staff more than 50 percent of the time the center is open. An affiliated site does not need to provide access to every required one-stop partner program. The frequency of program staff’s physical presence in the affiliated site will be determined at the local level.  Affiliated sites are access points in addition to the comprehensive one-stop center(s) in each local area. If used by local areas as a part of the service delivery strategy, affiliate sites must be established in a manner that supplements and enhances customer access to services. All affiliated sites must be accessible to individuals with disabilities, as described in 29 CFR part 38, the implementing regulations of WIOA sec. 188.

If Wagner-Peyser Act employment services are provided at an affiliated site, there must be at least one or more other partners in the affiliated site with a physical presence of combined staff more than 50 percent of the time the center is open.  Additionally, the other partner must not be the partner administering local veterans’ employment representatives, disabled veterans’ outreach program specialists, or unemployment compensation programs.  If Wagner-Peyser Act employment services and any of these 3 programs are provided at an affiliated site, an additional partner or partners must have a presence of combined staff in the center more than 50 percent of the time the center is open.

Specialized Center

Any network of one-stop partners or specialized centers, as described in 20 CFR 678.300(d)(3), must be connected to the comprehensive one-stop center and any appropriate affiliate one-stop centers, for example, by having processes in place to make referrals to these centers and the partner programs located in them. Specialized Centers address specific needs, (i.e. youth, key industry sectors, etc.), and are not required be certified.

Certification Teams

Oklahoma Works (One Stop) Center certification teams will be established by LWDBs and are responsible for conducting independent and objective evaluations of the one-stop sites and making certification recommendations to LWDBs.  The LWDB has discretion in forming the review team size and membership.  Foremost, certification team members must be free of conflicts of interest in the Center. For example, those conducting the review and recommending certification must not include any program partners with staff co-located in the center, or a one-stop operator who is responsible for the delivery of career services within the center. Certification teams may include local experts who represent targeted populations, experts from the state level, a third-party evaluator, or experts from outside the local area to ensure evaluations are objective, so long as they have no conflict of interest with the comprehensive and affiliate site(s). Certification teams must not be comprised of the area’s LWDB members and staff. A representative from the team should be identified as the primary contact person.

Process for Local Certification of Comprehensive and Affiliate Oklahoma Works (One-Stop) Centers

Center Certification Pre-Assessment

COWIB requires One Stop Operator and Center Staff to administer an on-site center assessment utilizing OWDI center certification checklist.  (Attachment B & C) The assessment should be submitted prior of the application submission or on-site review. The One Stop Operator should note any outstanding practices by the one-stop system and any areas that were not met. For measures not met, the One-Stop Operator should provide the COWIB with a solution and time line for meeting the measure(s).

Request

One Stop Operator will submit an application requesting certification for each comprehensive and affiliate center utilizing attachment A (Center Certification Application) to the Board.

Center Certification Team (CCT)

COWIB will establish Oklahoma Works (One-Stop) Center certification teams who are responsible for conducting independent and objective evaluations of one-stop sites and making certification recommendations to the COWIB. The COWIB has discretion in forming the review team’s size and membership. Foremost, certification team members must be free of conflicts of interest in the Center. For example, those conducting the review and recommending certification must not include any program partner with staff co-located in the center, or a one-stop operator who is responsible for the delivery of career services within the center. Certification teams may include local experts who represent targeted populations, experts from the state level, a third-party evaluator, or experts from outside of the local area to ensure evaluations are objective, so long as they have no conflict of interest with the comprehensive and affiliate site(s). Certification teams must not be comprised of that area’s COWIB members and staff.

Documentation

The local review team must identify hard data and documentation when making their determination. The CCT identified primary contact person will coordinate the request of documentation to begin a desk and onsite review, such as memorandums of understanding, reports, performance information, procedures manuals, customer satisfaction surveys, etc. with the One Stop Operator.

Desk Review

The local review team’s primary contact person will provide the Certification Review Team with the certification request, mandated checklist and electronic materials to begin a desk review. The review team members should familiarize themselves with the materials provided, as they will be helpful during the on-site reviews. COWIB requires the desk review be completed within thirty (30) days of the request.

On-Site Review

The local review team will conduct an on-site review.  This should be scheduled and conducted within sixty (60) days of the request.

Center Evaluation

Center Certification Team (CCT), will utilize the appropriate Certification Checklist (Attachment B) provided under state guidance, OWDI #01-2019 (or subsequent guidance).  Upon completion of the evaluation there are four certification determinations that may be assigned to each Oklahoma Works AJC’s (One-Stop Center):

  • Certification
  • Provisional Certification
  • Not Certified or Decertified

Certification is determined by a combination of the percentage of each type of criteria met:

  • Full Certification:

Certification may be awarded if 100% of met/not met criteria and an average score of “2” or higher for each category is achieved

  • Provisional Certification:

Provisional certification may be awarded if 75 – 100% of met/not met criteria and an average score of “1.5” or higher for each category of certification.

  • Not Certified or Decertified:

Centers may not be considered certified and/or will be decertified if less than 75% of met/not met criteria and/or the average score for each category is less than “1.5”.

Center Evaluation Certification Frequency

Oklahoma Works (One-Stop) Center sites will be evaluated and certified no less than once every two years. COWIB may direct “for-cause” site evaluation and certification as determined appropriate and warranted, as a result of a complaint or concern.

Continuous Improvement Criteria

In support of the goal of continuous improvement, The One stop operator will provide an annual report on each certified site to the COWIB, due August 1st of each year, detailing the capacity to access and improve upon the effectiveness, physical accessibility, and programmatic accessibility of the centers. Including mechanisms and regular process for identifying and responding to technical assistance needs and continuing professional staff development, and the process to capture and respond to specific customer feedback. The progress toward reaching and exceeding standards set forth in the certification criteria. COWIB will send a copy electronically to OOWD.

Non-Certification

If an existing comprehensive and affiliate one-stop center is ultimately not certified following a standard or “for-cause” evaluation, the one-stop operator must present a plan to the COWIB to ensure continuity of service between the time a site is not certified and another has been found and certified.

Review of Certification Procedures

Both the State board and LWDBs must review and update the evaluation criteria every two years as part of the review and modification of the state and local planning process.

Exit Interview

The CCT shall hold an exit interview with the One Stop Operator, Board Staff and relevant partners within two weeks of the on-site review.  The exit interview should note any outstanding practices by the one stop system and any areas that were not met.  For measures not met the One Stop Operator should provide the review team with a solution and time line for meeting measures.

Certification Determination

Once the review has been completed, the CCT shall present within 30 days the completed Certification Checklist and a letter signed by the Local Certification Team to the COWIB recommending which of the four determinations to assign to the center: (1) certification, (2) certification with Standard for Excellence designation, (3) provisional certification with a requirement that one-stop operators provide action plans and timelines for meeting certification standards, or (4) not certified or decertified.

Provisional certifications- CCT must provide a detailed description of the issues/concerns identified so one-stop operator has sufficient information around which to develop required action plans and timelines.

Once the recommendation is approved by the COWIB, the board shall obtain the signature of the CLEO(s) for final approval. In the event the CCT recommends that a comprehensive or affiliate one-stop center not be certified, the COWIB will send a letter signed by the CCT to the One-Stop Operator with specific corrective action items that must be addressed before certification can be approved. A copy of the letter shall also be sent electronically to OOWD. Once the One-Stop Operator informs the board that all issues preventing certification have been resolved, the COWIB chair or designee can reconvene the CCT to conduct a follow-up evaluation using the same method as the initial evaluation. The board must adopt the certification decision and improvement recommendations for each center and submit its decision for certification to OOWD.

Once the COWIB and CLEO approve the certification of a comprehensive or affiliate one-stop center, the LWDB chair or designee submits electronically all executed letters and copies of the completed Certification Checklist and necessary documentation to OOWD.

Re-Certification

In order to be eligible to receive infrastructure funding under the state infrastructure funding mechanism, the one-stop center must be certified every 2 years.  If the COWIB is unable to certify all of its comprehensive and affiliate Oklahoma Works AJC’s (One-Stop Centers) by the deadline as established by OOWD, the COWIB will submit a Certification Extension Plan electronically to OOWD by the same date.

The Certification Extension Plan must include:

  • A list of centers not yet certified;
  • An explanation of why they are not yet certified;
  • A plan using the timeline below for how the uncertified centers will certify by the COWIB and a technical assistance request (if needed) to complete the certification by the timeline below.
Deadline – Deliverable
April 30, 2019 – All Centers notified of baseline requirements and certification criteria so they may prepare to meet the certification requirements.
June 30, 2019 – LWDBs unable to certify comprehensive and affiliate centers by August 31, 2019, must submit to the State Board their Certification Extension Plan.
August 31, 2019 – The LWDB completes the certification process. Any LWDB who is the One-Stop Operator, must submit a self-assessment of the criteria to the state board for review, verification, and a decision.
September 15, 2019 – For those centers that did not meet certification requirements, the board must set target dates and action plans to be completed by October 31, 2019.
September 30, 2019 – The LWDB submits to the state board the Board-approved certification decision with required continuous improvement plans.
November 30, 2019 – For any LWDB who is the One-Stop Operator, the State Board will issue a certification decision with required continuous improvement plans.

Equal Opportunity and Nondiscrimination Statement

All Recipients, and Sub-recipients / Sub-grantees must comply with WIOA’s Equal Opportunity and Nondiscrimination provisions which prohibit discrimination on the basis of race, color, religion, sex (including pregnancy, childbirth, and related medical conditions, transgender status, and gender identity), national origin (including limited English proficiency), age, disability, political affiliation or belief, or, for beneficiaries, applicants, and participants only, on the basis of citizenship status or participation in a WIOA Title-I financially assisted program or activity.

Addenda / Revisions

The COWIB Chief Executive Officer is authorized to issue additional instructions, guidance, forms, etc., to further implement these procedures.

Questions about these procedures may be directed to the COWIB’s Policy Analyst at (405) 622-2026.

Please click the download button at the top of the page to view additional attachments.