Supportive Services-Adult-Dislocated Worker-Youth

Revised and Approved: October 2022

Purpose

As indicated in 20 CFR 680.900 through 970, and 20 CFR 681.570, Local Workforce Areas have been given the authority to make policy and administrative decisions, and the flexibility to tailor the workforce system to the needs of the local community. This guidance establishes a local policy on the coordination and delivery of supportive services, subject to WIOA’s limitations.

Authority

The authority for this policy is derived from the following:

• WIOA 3(59)
• WIOA 134 (d)(2) & (3)
• 20 CFR 680.900 through .970
• 20 CFR 681.570
• Federal Register/Vol. 81, NO 161 pg. 56336
• Training and Employment Guidance Letter (TEGL) WIOA No. 19-16 Operation and Guidance for the Workforce Innovation and Opportunity Act (March 1, 2017)
• OWDI 02-2016 Change 2, Youth Program Guidance (October 16, 2017)
• OWDI 07-2020 Change 1, Adult & Dislocated Programs (January 17, 2023)

Background

Supportive Services are designed to provide a participant with the resources necessary to participate in career services and/or training services and are governed by 20 CFR 680.900 through .970, and 20 CFR 581.570. The U.S. Department of Labor provides clarification for Supportive Services and their administration in TEGL 19-16, and the Oklahoma Office of Workforce Development offers further guidance through OWDI 07-2020 Change 1. Accordingly, the Central Oklahoma Workforce Innovation Board, in consultation with its One-Stop Operator, and its service providers must develop a policy on supportive services that ensures resource and service coordination in the local area. The policy should address procedures for referral to services, including how such services will be funded when they are not otherwise available from other sources, and may establish limits on supportive services.

What are supportive services?

Supportive Services may include but are not limited to:

• Assistance with child care and dependent care;
• Linkages to community services;
• Assistance with educational testing;
• Referrals to health care;
• Assistance with uniforms or other appropriate work attire and work-related tools including such items as eye glasses and protective eye gear;
• Assistance with books, fees, school supplies, and other necessary items for students enrolled in post-secondary education classes;
• Payments and fees for employment and training-related applications, tests, and certifications.

When may supportive services be provided to Adults, Dislocated Workers, and Youth?

Supportive Services are available for WIOA Title I Adult, Dislocated Worker and Youth participants participating in title I career service (excluding follow up career service) or training services. A Youth Support Service is one of the 14 youth elements that must be made available to participants and may be provided as a follow up service if needed. Supportive Service needs are identified through the Initial/Objective Assessment process and outlined in the IEP/ISS. Supportive Service do not set participation, nor do they extend the date of exit for performance accountability purposes. WIOA Title I will only pay for expenses incurred while a participant is enrolled in a WIOA Title I program and actively participating in activities authorized under WIOA, and provided that:

• Supportive services are NOT AVAILABLE through other programs providing such services.
• The supportive service is NECESSARY to enable the individual to participate in career services or training activities.

Local Policy

Coordinating with Non-WIOA-Funded Services

It shall be the responsibility of the COWIB to assure that supportive services provided under this policy shall be properly coordinated with services, resources, and activities that are available from other sources.

The One-Stop Operator, in conjunction with the service provider are authorized to establish appropriate linkages with programs such as child support, the Earned Income Tax Credit program (EITC), SNAP, Medicaid, and the Children’s Health Insurance Program (Sooner Care), which serve as key supports for customers making the transition to self-sufficiency.

When establishing linkages with other programs and agencies in the Central Oklahoma area, the One- Stop Operator, in conjunction with the service provider, should consider entering into letters of agreement or memoranda of understanding which may describe service delivery and procedures for referrals.

Determining the Availability of Supportive Services in the Local Area

To ensure resource and service coordination in the Central Oklahoma area, the One-Stop Operator, in conjunction with the service provider, shall develop and/or maintain a database containing an up-to- date listing of available services, including: transportation, child care, dependent care, and housing. Other supportive service categories may be identified by the One-Stop Operator/service provider in consultation with the COWIB’s Staff and One-Stop Partner agencies.

Providing Accurate Information to Participants

The One-Stop Operator and service provider shall utilize the database in order to provide accurate information about the availability of supportive services in the local area. The One-Stop Operator, in conjunction with the service provider, shall develop a local One-Stop procedure describing how referrals to such activities / services will be made.

Information about appropriate supportive services will be made available to all participants:

• Through the participant orientation process; or
• By providing access to electronic or printed community resource directories and information

Determining the Need for Supportive Services on an Individual Basis

Supportive services may be provided when they are necessary to enable an individual to participate in activities authorized under WIOA sec. 134(c)(2) and (3). Supportive services may only be provided to individuals who are participating in career and training services.

Needs Determined During Initial Assessment

When an adult, dislocated worker, or youth is participating in career or training services, as defined in WIOA secs. 134(c)(2) and (3), supportive services may be provided only after an initial/objective assessment has been conducted verifying the need for such services. The COWIB, in conjunction with the One-Stop Operator and the service provider, shall implement local procedures for conducting initial assessments. The local procedures shall be developed in consultation with the One-Stop Partner agencies and shall ensure that initial assessment procedures conform to all State and federal guidance with regard to the assessment of individual needs.

The decision on which supportive services to be provided, and the timing of their delivery, shall be made at the local level on a case-by-case basis depending upon the needs of the individual. Each barrier should be reviewed and determined if it is a barrier to participation in a career or training service, then a decision needs to be made on whether it would be appropriate to provide a referral or a supportive service.

Development of Supportive Services in the Individual Employment Plan/Individual Service Strategy

When an WIOA participant is participating in career or training service as defined in WIOA, supportive services may be provided only as part of an Individual Employment Plan (IEP) / Individual Service Strategy (ISS).

Consistent with the COWIB’s established Policy on Assessment and IEP’s and ISS’s for WIOA Participant’s, the One-Stop Operator, in conjunction with the service provider shall ensure that each identified barrier to participation in a WIOA activity is adequately documented and described in the individual’s IEP/ISS. The determination regarding referrals or supportive service delivery must be documented and described in the IEP/ISS prior to provision of services.

Supportive services may be provided to address identified needs that interfere with the participant’s ability to successfully participate in a WIOA career or training activity. These services may be addressed whenever the need is identified, whether at initial IEP/ISS development or at any time during participation in the WIOA program. The participant’s IEP/ISS should always reflect a clear picture of circumstances and services provided.

Providing Supportive Services Using WIOA Funds

The local procedure must ensure that similarly situated customers are treated in a similar manner. As set forth in the regulations (29 CFR part 37) implementing Section 188 of WIOA, a WIOA Service Provider must not discriminate in a manner in which it delivers any aid, benefits, services, or training under a WIOA Title I-funded program or activity. If a need has been documented, then supportive services may be provided using WIOA resources consistent with the following guidelines:

Non-Duplication of Resources

Definition of “Not Available”. When considering whether supportive services are available through other agencies, WIOA Service Provider staff should consider whether the services offered by another agency or program are:

• Accessible – that is, capable of being reached by the participant; and
• Obtainable – that is, capable of being attained by a planned action or effort.

The Central Oklahoma Workforce Innovation Board recognizes that many supportive services are offered through non-WIOA sources; however, not all of these services may be available to a WIOA participant at the time of his/her need. For example, some services are available only after a lengthy application process (which may include a waiting period). Other services are present, but not available during the hours required by the WIOA program participant. Additionally, some services may be offered by non-WIOA providers, but they are not present in a suitable or accessible geographic location. Therefore, it is understood that the “availability” of an identified supportive service must often be determined on an individual basis, taking into consideration the needs of those participants who are enrolled in a WIOA program of services.

The primary criteria for evaluating whether a service is “available” through another program or agency shall be whether the service is “present or ready for immediate use.” (Source: Merriam-Webster Online Dictionary).

Documentation that “supportive services are not available from another program” is required. Such documentation must be in the form of:

• The use of a “No Other Service Available (NOSA – Included as Attachment 1)” form.

Limits on the Amount and Duration of Services

The COWIB staff is authorized may establish limits on the amounts and duration of funds provided for supportive services. Such limits may include a maximum amount of funding and maximum length of time for supportive services to be available to participants.

In establishing such limits, COWIB, in consultation with the One Stop Operator and the service provider are encouraged to offer necessary and reasonable supportive services (consistent with approved contract budgets and this local policy). Specific limitations on the types, amount and duration of supportive services should be reviewed frequently, taking into consideration the availability of program resources and the aggregate demand for supportive services in the area.

To the extent possible, parameters for the delivery of supportive services should be:

• Developed in collaboration with the COWIB’s Staff and One-Stop Partners; and
• Tailored to meet the evolving needs of the Central Oklahoma workforce investment area.

At this time, COWIB has chosen to pay the following supportive services to participants:

Utilities Assistance:

Program funds may be utilized to assist the participant with a one-time payment per program year of utilities (one per utility type/company) not to exceed $300.00.  The utility bill may not have a past due amount for late payments.  The participant must provide a written statement of a plan to keep the utility type in good standing.

Housing Assistance:

Program funds may be utilized to assist participants who need assistance with rent or mortgage payments.  The participant may not have rent or mortgage payments past due or have eviction notices for late payments. A one-time expenditure may be made for housing assistance not to exceed $500.00. The participant must provide a written statement of a plan to keep the rent or mortgage payment in good standing.

Documentation of Supportive Service Payments

As provided in OWDI 07-2020 Change 1,

All assistance provided to individuals for education or training purposes, including assistance from other workforce partners, educational entities, or other grant assistance, must be documented in the IEP. The Coordination of Training Funds (CoTF) form must also include all assistance provided, with the exception of loans and VA benefits for education and training. The completed CoTF (or comparable, institution approved or validated documentation of the training period covered, the cost of training attendance broken down by cost category, and coordination of training funds) must be uploaded to OKJobMatch.

If a supportive service is not a reimbursement, three (3) quotes must be obtained and uploaded in support of the purchase.

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, approvals, and/or forms to further implement the requirements of policy, without making substantive change to the policy, except in situations when a new or updated state and federal guidance is issued.

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