Workforce Innovation and Opportunity Act Policy #YC 17-031
Subject: Youth Incentives Eligibility and Definition of Youth Needing Additional Assistance
Effective Date: January 10, 2018
Policy Statement: The Workforce Innovation and Opportunity Act (WIOA) provides funding for services to youth aged 14-24. The purpose of this policy is to establish and define the perimeters of incentives for youth participants.
For the purpose of this policy an” incentive” is a payment made to an eligible WIOA youth participant for the successful participation and/or completion of a goal or objective as defined in the participant’s Individual Service Strategy (ISS). Region 2000 recognizes that incentives are a way to boost participation and/or to motivate the participant to achieve established goals and objectives.
As discussed in 20 CFR § 681.640, "incentive payments to youth participants are permitted for recognition and achievement directly tied to training activities and work experiences. All incentives awarded must be connected to recognition of achievement of milestones in the program tied to work experience, education, or training”.
Incentive payments may be awarded for the following goal accomplishments or activities:
- Attainment of a Degree or Certificate
- Work Readiness and Leadership Development Activities
- Placement & Retention in Employment or Education
- Measurable Skill Gains
Maximum Incentive Amount: Total incentives are not to exceed $500 per participant, per program year. (All incentive payments are contingent on the availability of funding to the workforce region.)
Region 2000 requires that incentive goals should be noted on the participant’s Individual Service Strategy (ISS).
Attainment of a Degree or Certificate
High School Diploma or GED Incentive: The youth participant must not possess this degree prior to enrollment. Cash incentive as noted in the chart below.
Documentation: A copy of the degree, certificate or official transcript must be must be obtained and secured in the participant’s file.
Credential Attainment Incentive: The youth participant must not possess this degree/credential prior to enrollment.
Cash incentive as noted in the chart below.
Documentation: A copy of the degree, certificate or official transcript must be must be obtained and secured in the participant’s file.
Work Readiness and Leadership Development Activities
Work Readiness Activities: Completion of an agreed upon set of workshop/activities required to prepare the youth participant for occupational skills training and/or employment. Cash incentives as noted in the chart below.
Documentation: A signed and dated document from the provider verifying the title/content of the completed workshop or activity and date of completion must be obtained and secured in the participant’s file.
Leadership Development Activities: Completion of other (excluding work readiness) activities as defined as opportunities that encourage responsibility, self-determination, and other positive social behaviors. Cash incentives as noted in the chart below.
Documentation: A signed and dated document from the provider verifying the date(s) of the individual’s participation in the agreed upon activity must be obtained and secured in the participant’s file.
Placement or Retention in Employment or Education
Entered Employment Incentive: The participant must obtain employment after enrollment in the program. Incentives will be offered at 30 days and again at 90 days of employment. Cash incentives as noted in the chart below.
Documentation: A copy of employment information which may include a check stub or letter of employment (with start date), etc. must be obtained and secured in the participant’s file.
Enrolled in Post-Secondary Education or Training: The participant must enroll in or be enrolled in education during WIOA youth program participation. Cash incentives as noted in the chart below.
Documentation: A copy of the participants training records, grades, or school transcripts should be obtained and secured in the participant’s file.
Measurable Skill Gains
TABE Post-Test: A participant who at enrollment, was determined basic skills deficient and demonstrates a measurable gain of at least one grade level on the TABE Post-Test which should be given by the end of the first program year. Post testing should only be given for those areas in which the youth was deficient. Cash incentives as noted in the chart below.
Documentation: A copy of the participant’s pre and post-test results must be obtained and secured in the participant’s file.
Progress Reports for Education/Training: A participant must be considered a full-time student in good standing and maintain a “C” or better average in all classes. Incentive awards are paid at the completion of the training or on a semester basis as per the training program design.
Documentation: A copy of the Secondary or postsecondary transcript or report card demonstrating a sufficient number of credit hours which shows a participant is meeting the State unit's academic standards must be obtained and secured in the participant’s file.
Cash Incentive Awards
Attainment of H.S. Diploma or GED / $100Attainment of Credential / $100
Work Readiness Activity / $25 (each)
Leadership Development Activity / $25 (each)
Placement in (Unsubsidized) Employment
*Payable at 30 consecutive days of employment / $50
Retention of (Unsubsidized) Employment *Payable at 90 consecutive days of employment / $50
Enrollment in Post-Secondary Education / $50
TABE Post-Test / $25 (per test)
Progress Report for Education/Training / $25
Youth program staff shall maintain required documentation in the participant’s case file detailing the distribution and management of incentive awards. Youth program staff shall document the need for the incentive and justify issuance of the incentive in the participant’s ISS and in the Virginia Workforce Connection system (VOS). Incentive award payments should be documented on the participant’s financial tracker spreadsheet and maintained in the participant’s record.
Request for incentive awards will be processed through the WDB office and checks will be mailed directly to the participant’s home address. It is the service provider’s responsibility to ensure the correct participant address is shared with the WDB office. It is the responsibility of each service provider to become aware of all applicable regulations and to monitor personnel and participant activities to ensure compliance in accordance with this policy and other cited references.
In order to receive such services, an individual must first be determined eligible.
Part I. - Eligibility requirements: All eligibility factors must be explored and documented prior to WIOA youth enrollment.
An individual who is not less than 14 and not more than 24 shall be eligible to participate in WIOA Title I Youth Program if such individual:
Meets General Eligibility which consist of providing a verification source for each applicable category:
Citizenship or Eligible to Work
Selective Service Registrant (if applicable)
AND
Out-of-School Youth (OSY)
Under WIOA section 129(a)(l)(B), an out-of-school youth (OSY) is an individual who is:
(a)Not attending any school (as defined under State law);
(b)Not younger than 16 or older than age 24 at time of enrollment. Because age eligibility is based on age at enrollment, participants may continue to receive services beyond the age of 24 once they are enrolled in the program; and
(c)One or more of the following:
(1)A school dropout;
(2)A youth who is within the age of compulsory school attendance, but has not attended school for at least the most recent complete school year calendar quarter. School year calendar quarter is based on how a local school district defines its school year quarters;
(3)A recipient of a secondary school diploma or its recognized equivalent who is a low income individual and is either basic skills deficient or an English language learner;
(4)An individual who is subject to the juvenile or adult justice system;
(5)A homeless individual, a runaway, an individual who is in foster care or has aged out of the foster care system, a child eligible for assistance under Section 477 of the Social Security Act, or an individual who is in an out-of-home placement;
(6)An individual who is pregnant or parenting;
(7)An individual with a disability;
(8)A low-income individual who requires additional assistance to enter or complete an educational program or to secure or hold employment. (WIOA Section 129(a)(l)(B).)
In-School Youth (ISY)
Under WIOA section I29 (a)(l)(C), an in-school youth (ISY) is an individual who is:
(a)Attending school (as defined by State law), including secondary and postsecondary school;
(b)Not younger than age 14 or (unless an individual with a disability who is attending school under State law) older than age 21 at time of enrollment. Because age eligibility is based on age at enrollment, participants may continue to receive services beyond the age of 21 once they are enrolled in the program;
(c)A low-income individual; and
(d)One or more of the following:
(1)Basic skills deficient;
(2)An English language learner;
(3)An offender;
(4)A homeless individual, a homeless child or youth, a runaway, in foster care or has aged out of the foster care system, a child eligible for assistance under sec. 477 of the Social Security Act, or in an out-of-home placement;
(5)An individual who is pregnant or parenting;
(6)An individual with a disability;
An individual who requires additional assistance to complete an educational program or to secure or hold employment. (WIOA Section 129(a)(l)(C).) LIMITATION – Not more than 5% of the ISY in Region 2000 may be determined eligible under the barrier – An individual who requires additional assistance to complete an educational program or to secure or hold employment as noted above.
Youth in Need of Additional Assistance
An eligible youth who requires additional assistance to complete an educational program, or to secure and hold employment, means, an individual, who is:
(a)Previous termination from employment (and currently unemployed)
These youth exhibit poor work readiness skills that have caused issues in retaining employment. In addition, the highest percentage of those unemployed in the labor force are those who have lost previous employment or temporary jobs. Documentation: Letter from previous employer, UI records if available or notes from phone conversation between employer and case manager.
(b)Youth of an incarcerated parent
A parent’s incarceration could cause youth to exhibit poor school behavior or an inability to maintain employment. Youth in this environment may lack appropriate role models as they transition from youth to adulthood. They are also more likely to be a part of a non-traditional household.
Documentation: Court or school documentation verifying parent’s incarceration AND school records or letter from previous employer as applicable.
(c)Youth with mental health or substance abuse challenges
Youth that have struggled with these challenges often have social challenges and need additional support to succeed in reaching goals. Youth with mental health challenges must be stable on mental health medications or sustained counseling for at least two months.
Documentation: Letter from counselor (psychiatrist, psychologist, or social worker). Youth with substance abuse challenges must have successfully completed a rehabilitation program or counseling and have maintained sobriety for at least two months documented by a rehabilitation program or counselor.
(d)Youth attending an alternative high school
These youth have exhibited behavior that resembles youth that are at-risk of court or gang involvement and possible basic skills deficiencies. Youth that attend an alternative school need additional support in completing their education and guidance to employment or post-secondary education.
Documentation: School records indicating poor grades, behind grade level, and/or behavioral issues.
(e)Youth behind grade level
These youth need addition academic support because they are behind grade level.
Documentation: School records supporting this determination.
(f)No previous work experience
In light of the current economic conditions and excess number of people of all ages and levels of education and experience seeking jobs, a youth or young adult who has no previous work experience will have difficulty qualifying for many positions.
Documentation: Strong case notes as collected by the case manager, based on items such as interview during intake followed by individual or parent/guardian/family member affidavit, review of VEC wage records if available, referral letter from other youth service providers.
(g)Gang involved or at-risk of gang involvement
This is a barrier because of employability (demeanor, tattoos, etc.) as well as social and developmental risk factors (drugs, crime, etc.) associated with gang involvement. These youth exhibit poor behavior in school and may be basic skills deficient.
Documentation: Referral letter from a state or local police court division, or youth service agency AND if in school, school records indicating poor behavior, poor attendance and/or poor grades. An affidavit from a parent, family member or guardian can be acceptable at case manager discretion with strong case notes.
(h)Youth in Homeless Prevention Situation
Though the youth are not homeless yet, they are working with the prevention program to keep them from becoming homeless. All the family resources will be toward keeping their home instead of educational and employment support for the youth.
Documentation: Referral letter from program, church, or other community-based organizations and/ or service providers that would have verifiable knowledge.
Part II. – Exceptions to low-income requirement
A youth with a documented disability, whose family does not meet income criteria, is considered low income if the individual’s own income, separate from the household’s meets the income eligibility guidelines.
1.Not more than 5% of participants assisted in the youth program in Region 2000 may be individuals who do not meet the low income criteria to be considered eligible youth, where applicable.
The service provider shall receive prior written approval from the WDB director when using the 5% income exception for enrollment.
Attachment 1
Definitions related to eligibility as referenced in Policy YC 17-01:
Individuals must meet General Eligibility, which consists of Citizenship or Eligible to Work, Selective Service Registration and Low-income Individual (where applicable).
Citizenship or Eligible to Work – participation in programs and activities financially assisted in whole or part under WIOA shall be open to citizens and nationals of the United States, lawfully admitted permanent resident aliens, lawfully admitted refugees and parolees, and other individuals authorized by the Attorney General to work in the United States (applies to all programs under Title I). [Act 188(a)(5)]
Selective Service Registrant – each individual participating in any program established under WIOA, or receiving any assistance or benefit under WIOA, has not violated Section 3 of the Military Selective Service Act (MSSA) (50 U.S.C. App. 453) by not presenting or submitting to registration as required pursuant to such section.
Note: Males born on or after January 1, 1960 must register with the selective service system within 30 days after their 18th birthday or at least before they reach the age of 26. [Act 189(h)] Procedures are outlined in Training and Employment Guidance Letter 11-11, change 2, dated May 16, 2012.
Where applicable:
Low-income Individual – an individual who
(i) receives, or in the past 6 months has received, or is a member of a family that is receiving or in the past 6 months has received, assistance through the supplemental nutrition assistance program established under the Food and Nutrition Act of 2008 (7 U.S.C. 2011 et seq.), the program of block grants to States for temporary assistance for needy families program under part A of title IV of the Social Security Act (42 U.S.C. 601 et seq.), or the supplemental security income program established under title XVI of the Social Security Act (42 U.S.C. 1381 et seq.), or State or local income-based public assistance;
(ii) is in a family with total family income that does not exceed the higher of— (I) the poverty line; or (II) 70 percent of the lower living standard income level;
(iii) is a homeless individual (as defined in section 41403(6) of the Violence Against Women Act of 1994 H. R. 803—12 (42 U.S.C. 14043e–2(6))), or a homeless child or youth (as defined under section 725(2) of the McKinney-Vento Homeless Assistance Act (42 U.S.C. 11434a(2)));
(iv) receives or is eligible to receive a free or reduced price lunch under the Richard B. Russell National School Lunch Act (42 U.S.C. 1751 et seq.);
(v) is a foster child on behalf of whom State or local government payments are made; or
(vi) is an individual with a disability whose own income meets the income requirement of clause (ii), but who is a member of a family whose income does not meet this requirement. [Act 3(36))]
Exception
SPECIAL RULE— the term ‘‘low-income’’, used with respect to an in and out-of- school individual youth, also includes a youth living in a high-poverty area. [Act 129(a)(2)]
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