Adult, Dislocated Worker, and Youth Activities

OVERVIEW

1. This Eligible Training Provider List (ETPL) and Individual Training Account (ITA) Provider policy manual outlines the Delaware Workforce Development Board’s (DWDB) approach to managing its responsibility under the Workforce Innovational and Opportunity Act (WIOA). This manual provides specific guidance on the development, management, and enforcement of Delaware’s ITA system.

3. The DWDB will make changes to this manual as needed. The DWDB will announce changes through its website, social media accounts, and as necessary, through the Division of Employment and Training.

PREPARATION

1. Introduction. Processing Individual Training Account (ITA) provider applications is an important and fundamental part of the DWDB’s work and deserves a level of detail and process appropriate to the annual expenditure of several million dollars and the training of several hundred Delawareans. While many components are key in developing a quality provider approval process, it is impossible to overstate the importance of detailed preparation.

2. Demand Occupation List. The first preparation step is development of the Demand Occupations List. This list is the driving document for provider approval. The DWDB will annually post the high demand occupation list on its website and distribute it through social media

a. To facilitate preparation the DWDB Deputy Director will:

1. Gather relevant labor market information from Delaware’s Office of

Occupational Labor Market Information (OOLMI);

2. Request qualitative information from the Delaware Economic Development

Office (DEDO), workforce development unit;

3. Conduct an initial analysis of potential employment demand;

4. Ask DEDO and OOLMI for input based on data;

5. Develop a draft high demand occupation list for the DWDB executive director;

for presentation to Proposal Review and Certification Committee; and

6. Ensure the DWDB website is posted with the new list

b. DWDB Executive Director will:

1. Review the draft list; and

2. Present it to the Proposal Review and Certification Committee for

approval.

3. Performance Measures. The development of performance measures serves several functions including, but not limited to, giving providers a clearly defined set of performance expectations and providing DWDB committees with selection criteria for future provider approvals. The development of performance measures occurs annually. The DWDB will evaluate providers based on performance. The DWDB will eliminate providers from the provider list, which fail to meet minimum standards. The development of performance measures is a joint staff project between the Delaware Department of Labor, Division of Employment and Training (DOL-DET), the DWDB Performance Measures Committee, Proposal Review and Certification Committee, and the DWDB staff. State performance measures must ensure the DWDB and DPL-DET meet or exceed the federally mandated requirements. The results of the annual negotiation, between the DWDB Performance Measures Committee and U.S. DOL Employment and Training Administration, are the primary driver for development of provider measures.
To prepare for the negotiations DOL-DET and DWDB will:

a. Work together and develop draft performance measures that ensure the success of state programs to meet federally mandated performance;

b. Take into consideration the demand occupation list when developing employment

standards; and

c. Present the draft performance measures to the Proposal Review and Certification

Committee for review and approval.

4. Other Screening Criteria. Although the Demand Occupation List and Provider Performance Measures are the two primary sets of screening criteria, the DWDB will also consider qualitative data from other sources such as the Delaware Economic Development Office, local and/or state chambers of commerce, intelligence gathered from DET Business Services Reps (BSR’s), and websites, such as Indeed.com that give a daily snapshot of job openings.

INITIAL APPLICATIONS

1. Prospective providers can submit applications anytime. However, only the Proposal Review and Certification Committee may approve a provider and its programs. The DWDB staff will only accept complete applications from prospective providers. Complete applications include:

a. A signed Memorandum of Understanding (MOU);

b. A complete program information form for each program;

c. Provide verifiable program specific information;

d. Completed initial eligibility form;

e. An initial monitoring visit form (completed by DWDB staff);

f. Debarment disclosure;

g. Delaware Department of Education (DOE) Certification;

h. DWDB staff will make an onsite visit to the prospective providers training site. The

visit will determine and ensure the provider facilities are adequate, safe, and reflect an

atmosphere appropriate to the trade being taught.

2. When the DWDB staff receives a complete initial application, it will send the provider via “snail mail” or email in pdf a copy of “The Provider Link User Guide

3. DWDB staff will recommend to the Proposal Review and Certification Committee approval/non-approval of initial applications for providers and specific programs. The staff will develop the recommendations based on, at least, the following criteria:

a. Does the provider program meet a high demand occupation?

b. Does this provider have an established track record of success for at least one year with

the general public?

c. Does the provider have enough revenue to succeed without the DWDB ITA’s?

d. Is the training site equipped to conduct training?

e. Are the programs submitted for approval currently available and ready for public use?

4. The Proposal Reviewed and Certification Committee may accept or reject the staff’s recommendation(s) in whole or in part. The committee is free to accept all prospective programs, some programs, or no programs.

5. When the committee approves a provider and/or program, DWDB staff will notify the provider to enter data into the Delaware Job Link in accordance with the instructions in “Provider Link User Guide.” When programs are entered, the DWDB staff will notify DET, which will activate the program in its financial system.

6. The DWDB executive director will notify, in writing, non-approved providers and/or programs of the committee’s decision. As a minimum the letter will:

a. Be sent to providers within 30 working days of the committee’s decision

b. Clearly inform providers of their opportunity to appeal

c. Have the appeal process as a standalone attachment to the letter

d. Generally explain the reason for non-approval

SUBSEQUENT RENEWALS

1. Retaining quality providers and ensuring provider stability is in the DWDB’s best interest. To ensure Delawareans have access to training, which will give them a competitive edge in the labor market, it is essential the DWDB review provider performance to ensure only the best are renewed. This may result in longtime providers and/or select programs being removed from the list. Programs are removed from the list for two years. Programs may reapply on the two year anniversary of the removal.

2. The subsequent renewal process generally mirrors the initial application process, with one major exception - subsequent renewals are also judged on the provider’s success rate from the previous year. To be considered for renewal providers must:

a. Attend the provider forum;

b. Submit updated forms;

c. Submit required performance information;

d. Meet the previous year’s performance objectives;

e. Still offer training programs which support demand occupations; and

f. Submit an updated contact and email list with the renewal application.

3. When a provider submits its renewal application the DWDB staff will check the performance measures. The DWDB staff will flag any performance measure failure of a subsequent program renewal application for removal from the provider list. The Proposal Review and Certification Committee will remove the program from the list.

4. DWDB staff will recommend to the Proposal Review and Certification Committee approval/non-approval for providers and specific programs of subsequent renewal applications which have met performance measures. It is important to note, that successful programs which no longer training high demand occupations are subject to non-renewal.

5. The Proposal Reviewed and Certification Committee may only renew programs that achieve minimum standards, but is free accept or reject the all other staff’s recommendation(s) in whole or in part. The committee is free to accept all programs, some of its programs, or none of the programs.

6. When the committee approves a subsequent renewal, the DWDB will notify the provider tye can submit their changes into Delaware Job Link. When programs are entered, the DWDB staff will notify DET, which will activate the program in its financial system.

7. The DWDB executive director will notify, in writing, non-approved providers and/or programs of the committee’s decision. As a minimum the letter will:

a. Be sent to providers within 15 working days of the committee’s decision

b. Clearly inform providers of their opportunity to appeal

Provider Forum

1. The provider forum is a required step in the renewal process. At a minimum DET and DWDB staff will prepare:

a. Short term and long term employment projections;

b. DET and DWDB process changes;

c. A discussion of common challenges/solutions from the previous year;

d. A discussion of state performance measures for the past and upcoming year; and

e. Other information as appropriate.

2. The DWDB staff is responsible for developing and coordinating all aspects of the forum. The Executive Director will:

a. Develop the overall vision for the forum;

b. Determine the date, and content of the forum;

c. Identify key lessons learned ;

d. Coordinate for Executive Committee representation at the forum; and

e. Give presentations/briefing as needed at the forum

.

The Deputy Director will

a. Coordinate with OOLMI for labor market projections;

b. Develop briefing slides for LMI data ;

c. Coordinate with DOL-DET director for his/her comments at the forum;

d. Work closely with executive assistant to produce binders and other handouts; and

e. Give presentations/briefings at the forum.

The executive assistant will:

a. Contact all providers pending subsequent renewal and notify them of the date, time, and location of the provider forum;

b. Coordinate with the DWDB staff for contents of binders to be distributed to forum attendees; and

c. Develop name tags, etc for the forum.

The contract specialist will:

a. Coordinate with the forum site for all logistical support;

b. Ensure smooth operation of forum events;

c. Coordinate directly with the site staff for needed support;

d. Brief providers at the forum concerning monitoring visits; and

e. Review program information process.

MOU Reviews and Updates

1. The DWDB disciplines the process through its Memorandum of Understanding (MOU) and addendums (if needed). The DWDB staff will annually review the MOU to ensure it provides clear standards to the providers and enforcement provision to the DWDB.

Enforcement

1. Enforcement of standards throughout the ITA process is essential to ensure Delaware’s publicly funded workforce system is fair to all providers, provides the highest quality training to its citizens, and makes the best use of taxpayer dollars. To that end the DWDB, in partnership with DOL-DET and providers, will take a multi-prong approach to quality control.

2. The DWDB will use both announced and unannounced visits. The DWDB contract specialist will shoulder most of the responsibility for visits, although the entire DWDB staff is expected to conducted visits. Although each situation is different, each visit will include:

a. Meet with the owner or on site ITA manager (in the case of higher eds);

b. Interviews with students;

c. A tour of the facility; and

d. Completed monitoring checklist.

3. Each visit will conclude with an exit briefing by the DWDB representative. The DWDB rep will review the monitoring checklist with the provider to ensure to ensure both parties understand the results. The monitor will - to the greatest extent possible - have the provider initial the checklist. Initialing the checklist neither constitutes agreement nor disagreement by the provider with any DWDB finding. Initialing the checklist only means the provider has received the checklist and understands its contents.

4. Non-compliance suspension. To ensure quality and promote monetary stewardship, the DWDB will rigorously enforce MOU compliance. In the rare likelihood that suspension are necessary, the suspension will last one year.

5. Providers will ensure:

a. They have sufficient funds to run their programs without the use of WIA federal money. Calls from creditors to DOL-DET or the DWDB are a potential indication of a lack of sufficient funds to run an ITA program.

b. It has a stable location. While the DWDB understands that business world is dynamic and things change, it also understands that training facility stability is an indicator of a successful and viable organization. The DWDB will suspend any organization that moves without notification, twice in the same 12 month period as the training provider will be out of compliance with its application.

c. They have a landline communication system. Because it is easy for the unscrupulous to use mobile phone technology, The DWDB requires landline telephones for all providers. Failure to have an operating landline phone is non-compliance.

d. It has adequate staff and training materials for students. Training providers will ensure that every student has sufficient equipment, books, and other materials required for instruction. Programs with inadequate and unqualified staff are non-compliant and will be suspended.

e. Tuition charged for WIOA students is equal to or less than that charged to the general public. Vendors charging more are grievously non-compliant and are subject to immediate removal from the list.

f. Programs which withhold learning materials until state payment is issued are non-compliant and will be immediately suspended.

5. In the event a complaint is made against a provider, the DWDB will immediately suspended the provider from the ITA list pending the resolution of the complaint. The DWDB will notify a provider when a complaint is filed and will ensure - to the greatest extent possible - the confidentiality of the complainant. Complaints must be specific and detailed. The DWDB will conduct an inquiry to determine, “what was or was not done in violation of what standard.” To the greatest extent possible, the DWDB inquiry will embrace the “reasonable person” standard when evaluating complaints.

ITA PROVIDER LIST MANAGEMENT

1. Overview. The Delaware JobLink is the data exchange system used by the DWDB and DOL-DET to list providers, programs, and other employment related services. The management of the ITA Provider List is an essential DWDB function and deserves the highest attention. List development and maintenance is the joint responsibility of the provider and the DWDB. Although the executive director is ultimately responsible for the list, the DWDB contract specialist is the day-to-day lead and Point of Contact for the maintenance of the ITA Provider List.

2. Renewals. All renewals are effective 1 July every year.

a. Providers will:

1. Provide accurate information for posting to the list when submitting renewal

Information;

3. Ensure every renewed program has an update course description (electronic preferred);

Programs without descriptions are noncompliant and the DWDB will delete them; and

2. Review all renewed programs between June 15^th June 21^st every year to ensure DJL

accuracy.

b. DWDB Staff will:

1. Assist providers as needed to ensure DJL input accuracy;

2. Make corrections to provider course data; and

3. Review provider data into Delaware JobLink No Later Than (NLT) 20 JUN 10

c. The Contract Specialist will:

1. Ensure all renewal programs for approved providers are accurate and updated on

Delaware JobLink NLT 15 June every year;

2. Will ensure all corrections to programs are made NLT June 28^th every year; and

3. Develop the Return on Investment results no NLT 1 August