WIOA State Plan Common Elements

Co-Enrollment and Common Intake

As outlined in, Workforce Services Directive WSD19-09, California encourages planning across multiple partner programs to ensure alignment in service delivery and leveraging of resources for maximum benefit to WIOA participants. Co-enrollment is a means to establish effective partnerships across WIOA core programs and other workforce providers, including community-based organizations to provide a mix of services to individuals to meet their employment, education, and training needs.

Through the use of strategic co-enrollment, workforce partners can maximize resources and better align services with the career pathways and sector strategies at the core of our delivery model. Career pathways allow for individuals to succeed in an environment that accounts for their current abilities and skill levels and provides them with an appropriate service structure to advance, not just within an individual job, but within an occupation or occupational cluster. In order to effectively promote and develop career pathways and sector strategies, workforce partners must work together to ensure a customer-centered approach with strategic co-enrollment as a key strategy to service delivery that best benefits the participant.

A statewide co-enrollment workgroup was established to gather various WIOA partner programs’ intake forms, which were then consolidated into one document by Hanover Research. The co-enrollment workgroup adopted this document as the starting point for a statewide workforce common intake form. To operationalize the form, an electronic common intake form that interacted with the partner programs’ independent systems was created.

California is exploring ways to electronically share common data elements and trigger referrals between CalJOBS^SM, a data exchange, and other program partners. The intent would be to assist job seekers by reducing the burden of providing the same common items to multiple agencies (if receiving services from multiple programs), streamline data collection for staff, and assist programs with identifying potentially eligible individuals.

Memorandum of Understanding Cost Sharing

As outlined in Workforce Services Directive WSD18-12, each AJCC partner that carries out a program or activities within the AJCC must use a portion of their funds to help maintain the AJCC delivery system which includes contributing a proportionate payment of the AJCC infrastructure costs. Local Boards and their AJCC partners must establish Infrastructure Funding Agreements (IFA) as a vehicle for determining the amount each partner owes. When determining each partner’s proportionate share, Local Boards are required to remain in compliance with the federal statute that authorizes each partner’s program as well as Title 2 Code of Federal Regulations (CFR) Part 200 which outline the uniform administrative requirements, cost principles, and audit requirements for federal awards.

Establishing IFAs

In order to best meet the needs of the Local Workforce Development Area (Local Area), California provides flexibility to Local Boards and their partners on whether they want to use individual IFAs, a network IFA, or a combination of individual and network IFAs. Developing a combined budget based on a network of AJCCs may make financing infrastructure costs among partners easier since it does not require each partner to contribute to each individual AJCC, so long as each partner’s total contribution is still equal to their overall proportionate share of all the AJCCs in the Local Area. However, combining budgets cannot change the distribution of costs in any way, costs must be still attributable to each partner equally, and in accordance with the agreed upon cost sharing methodology.

The Local Board and partners can start the IFA negotiations by determining the budget for every AJCC within the Local Area. This will allow all partners to see where, and what kind of money is being spent throughout the Local Area. The IFA budget includes, but is not limited to, all non-personnel costs that are necessary for the physical operation of the AJCC such as: rent, utilities and maintenance, equipment, technology, and non-marketing common identifier expenses. In addition, every AJCC infrastructure budget must also have an “Access and Accommodation” line item for ensuring physical and programmatic access to the AJCC by individuals with disabilities. The budgets must contain descriptions of the specific costs grouped under each line item. Local Boards may consolidate and/or break out line items as best fits with their individual area budgets and cost allocation methodology.

Determining Benefit Received by Partners

Local Boards must first determine whether an AJCC partner is receiving benefit from the AJCC or system. If a benefit is received, the AJCC partner’s proportionate share of infrastructure costs must be calculated in accordance with Title 2 CFR Part 200 and based on a reasonable cost allocation methodology. All costs must be allowable, reasonable, necessary, and allocable as required by WIOA Joint Final Rule Section 678.715.

Partners who are physically collocated in the AJCC(s), whether full-time or part-time, are considered to receive a direct benefit that is allocable; therefore, they must contribute their proportionate share towards the infrastructure costs. Partners who are not physically collocated in the AJCC may also be receiving benefit from the AJCC system. However, that benefit must be clearly identified and allocable by way of reliable data and a cost methodology that demonstrates the partner’s usage of and benefit from the center and its services.

Cost Allocation Methodology

After creating an IFA for each individual AJCC or for the local network of AJCCs, and determining if benefit is received by each partner, the Local Board must select a cost allocation methodology to identify the proportionate share of infrastructure costs each partner will be expected to contribute. Any cost allocation methodology selected must adhere to the following:

• Be consistent with the federal laws authorizing each partner’s program (including any local administrative cost requirements).
• Comply with federal cost principles in the Title 2 CFR Part 200.
• Include only costs that are allowable, reasonable, necessary, and allocable to each program partner.
• Be based on the proportionate use and benefit received by each partner.

Other One-Stop Delivery System Costs

In addition to jointly funding infrastructure costs, AJCC partners must use a portion of funds made available under their authorizing federal statute (or fairly evaluated in-kind contributions) to pay the additional costs relating to the operation of the One-Stop delivery system. These costs may be shared through cash, non-cash, or third-party in-kind contributions as outlined in WIOA Joint Rule Section 678.760. All comprehensive, affiliate, and specialized AJCCs must include another system costs budget as part of their MOU. The other system costs budget must include applicable career services, and may include any other shared services that are authorized for and commonly provided through the AJCC partner programs to any individual, such as initial intake, assessment of needs, appraisal of basic skills, identification of appropriate services to meet such needs, referrals to other partners, and business services. Shared operating costs may also include shared costs related to the Local Board’s functions.

Establishing Other System Costs Budgets

The other system costs budget must be a consolidated budget that includes a line item for applicable career services. The MOU requires identifying the career services that were applicable to each partner program. Accordingly, this budget must include each of the partner’s costs for the service delivery of each applicable career service and a consolidated system budget for career services applicable to more than one partner.

The budget may also include shared services, which have been agreed upon by all partners, which are authorized for and may be commonly provided through the One-Stop system. Examples of these types of services include, but are not limited to, the following:

• Initial intake, assessment of needs, appraisal of basic skills, identification of appropriate services to meet such needs, and referrals to other AJCC partners. This may include costs such as technology and tools that increase integrated service delivery through the sharing of information and service delivery processes.
• Business services. This may include costs related to a local or regional system business services team that has one or more partners on the team or has delegated a specific partner to provide business services on behalf of the system.
• AJCC partner staff cross training. This may include any staff cross training on partner programs and eligibility identified in the shared services and/or shared customers portion of the MOU.
• One-Stop operator. This may include the system role of the One-Stop operator (e.g., coordinating service providers across the One-Stop delivery system) when the role is not specific to the operation of the AJCC and/or specific partner programs, so long as the role was defined by the Local Board in the procurement process and agreed to by all AJCC partners in the MOU.
• Shared personnel (and other non-infrastructure costs) for collocated partners. This may include AJCC receptionists and/or AJCC managers.

Timeline for Updates

Every MOU must contain an assurance that they will be reviewed and updated at least every three years. It is also required that the IFAs and Other System Costs Budgets be reviewed annually and if any substantial changes have occurred, be amended. The reviews should be ensuring accurate, up-to-date information regarding funding, delivery of services, additional partners, and any changes in the signatory official of the Local Board, Chief Elected Official, or AJCC partners.