Waiver Request 1 -

SINGLE STATEWIDE COUNCIL SERVING STATEWIDE REGIONAL PLANNING AREA

(1) Identifies the statutory or regulatory requirements for which a waiver is requested and the goals that the State or local area, as appropriate, intends to achieve as a result of the waiver and how those goals relate to the Unified or Combined State Plan;

The State of Idaho is formally seeking a waiver to permit a state board to carry out the functions of a local board. This waiver request is for a renewal of a waiver previously applied 20 CFR 679.310(f) which states that a state board must carry out the roles of a local board when the State Plan indicates that the State will be treated as a local area under WIOA. The Workforce Innovation and Opportunity Act Sections 106(d)(2) and 107(c)(4) also direct a state board for a single state local area to carry out the functions of the local board. The Workforce Development Council has acted as both the state and local board under WIA since 2005 and the current structure is reflected in the Combined State Plan.

(2) Describes the actions that the State or local area, as appropriate, has undertaken to remove State or local statutory or regulatory barriers;

No state or local policies limit the Governor’s authority to require a regional plan or utilize the Workforce Development Council as the local workforce board for the state.

(3) Describes the goals of the waiver and the expected programmatic outcomes if the request is granted;

The primary goal to be achieved by this waiver is to reduce annual overhead and maximize the available money directed to training and services to business. The programmatic outcome is to serve a larger number of participants than would otherwise be served due to added administrative costs. To maximize resources available for service delivery, the state continued to use the Workforce Development Council as the local workforce board throughout the state. When initially implemented, this saved the WIA program in the state approximately $1.5 million dollars by removing the administrative overhead of maintaining six regions throughout the state. Since then, these former administrative funds have been utilized as program funds allowing for more participants to be served.

As evidenced since its initial implementation, the single statewide planning structure has continued to reduce annual overhead, and maximizes the available funding directed to training and services to business and job seekers.

This statewide structure enhances efforts to transform the system into a demand driven system. The 25 Idaho Department of Labor offices across the state serve as the state’s American Job Centers offering the full range of workforce development services. This recognizes the importance of sharing data and information about new and expanding businesses to build the economy across regions.

(4) Describes how the waiver will align with the Department’s policy priorities, such as:

(A) supporting employer engagement; (B) connecting education and training strategies;

(C) supporting work-based learning; (D) improving job and career results, and

(E) other guidance issued by the Department.

The Workforce Development Council structure has been in place since the Jobs Training Partnership Act. Its current membership aligns with the prescribed composition under WIOA, including a majority business representatives, along with partners from government, labor, community-based and educational entities. State education policy is thoroughly aligned with the state’s workforce development goals.

(5) Describes the individuals affected by the waiver, including how the waiver will impact services for disadvantaged populations or individuals with multiple barriers to employment;

The change to a single statewide regional planning structure, in conjunction with this waiver, has allowed for an average annual increase in training opportunities for more adults, dislocated workers and at-risk youth, and has since permitted the state to maintain service levels despite funding cuts over the years.

(6) Describes the processes used to:

(A) Monitor the progress in implementing thewaiver; B) Provide notice to any local board affected by the waiver; (C) Provide any local board affected by the waiver an opportunity to comment on the request; (D) Ensure meaningful public comment, including comment by business and organized labor, on the waiver. (E) Collect and report information about waiver outcomes in the State’s WIOA Annual Report.

As evidenced since its initial implementation, the single statewide planning structure has reduced annual overhead, maximizing the available money directed to training, including work-based learning, and services to business and job seekers. The State has emphasized spending goal program funds towards direct training and support of businesses and participants, positively impacting the achievement of performance goals. This is regularly monitored to ensure that direct participant funding does not drop below 50% of the funds.

The single statewide structure has strengthened administrative oversight and accountability processes. Prior to this change, administrative deficiencies resulted in substantial disallowed costs for Idaho’s largest Workforce Investment Area. The strengthened administrative structure, under the waiver, has assisted Idaho to avoid future disallowed costs and will continue to do so, thus further enabling the redirection of funds from service provider and administration to direct participant training and support.

Originally this waiver was announced to the general public as part of the PY05 plan review process which included a process for soliciting review and comment during a three-week period and reviewed by the state’s Workforce Development Council, which included comments from the existing Local Workforce Investment Boards and their staff.

Any comments received will be forwarded to the USDOL and included as a modification to the state's Combined Plan. The impact of this waiver on the state's performance will be addressed in the state's WIOA Annual Report.

The waiver outcomes will be collected and reported in the State’s WIOA Annual Report.

(7) The Secretary may require that States provide the most recent data available about the outcomes of the existing waiver in cases where the State seeks renewal of a previously approved waiver.

Not applicable.

Waiver Request 2 -

REQUIRED EVALUATIONS OF WORKFORCE INVESTMENT ACTIVITIES

(1) Identifies the statutory or regulatory requirements for which a waiver is requested and the goals that the State or local area, as appropriate, intends to achieve as a result of the waiver and how those goals relate to the Unified or Combined State Plan;

The state of Idaho respectfully requests a waiver of the following two sections of the Workforce Innovation and Opportunity Act concerning required activities funded by Governor’s Reserve funds: completion of evaluations on workforce investment activities for adults, dislocated workers, and youth (WIOA Section 134 (a)(2)(B)(vi)), WIOA Section 129(b)(1)(A).) This request is specific to the requirements outlined in WIOA 116(e)(2)and(3).

The Combined WIOA State Plan indicates that it will use the statutory performance measures to evaluate the effectiveness of the programs. These measures, as well as regular continuous improvement processes, should provide sufficient information to determine the effectiveness of the workforce delivery system.

The State will fully cooperate with evaluations and research projects initiated by the Departments of Labor and Education. However, the State lacks the capacity to procure or develop for itself the rigorous statistical and analytical evaluations expected in the statute. Small, dispersed populations such as Idaho’s are especially expensive to study. Disproportionately large sample sizes are required to achieve statistically significant results. The State’s resources would be better directed toward service delivery and continuous improvement, while conceding evaluation expertise to federal coordination.

(2) Describes the actions that the State or local area, as appropriate, has undertaken to remove State or local statutory or regulatory barriers;

No state statutory or regulatory barriers exist at this time.

(3) Describes the goals of the waiver and the expected programmatic outcomes if the request is granted;

Although congressional action increased the percentage of Governor’s Reserve funding for states to 15 percent in PY16, Idaho’s base funding has decreased $842 thousand from PY 2016 to PY 2017. The total amount available for the Governor’s Reserve in PY 2017 is $1,083,263, down from $1,209,695 in PY 2016. Consequently, funding has become severely limited while the costs of operating the state’s workforce development/One-Stop system and the other mandatory WIOA activities continue to rise, further restricting Idaho’s ability to effectively fund and carry-out all of the required statewide workforce investment activities. The current funding level for this program year and anticipated funding levels for future program years are insufficient to cover the costs of conducting evaluations.

With this waiver, Governor’s Reserve funding will be used to enhance those primary and basic functions of the system. The state’s reduced funds are being used for the following required activities:

· Submitting required reports

· Disseminating and making available the state’s list of WIOA Eligible Training Providers;

· Carrying out statewide Rapid Response activities;

· Providing technical assistance to workforce areas;

· Assisting in the establishment and operation of the state’s One-Stop delivery system;

· Operating fiscal and management accountability information systems; and

· Carrying out monitoring and oversight of employment and training activities

The state’s goal in seeking this waiver is to ensure that the state prioritize the use of the Governor’s Reserve funds for the required WIOA activities deemed most essential to the basic functions of the state’s workforce development system.

(4) Describes how the waiver will align with the Department’s policy priorities, such as:

(A) supporting employer engagement; (B) connecting education and training strategies;

(C) supporting work-based learning; (D) improving job and career results, and

(E) other guidance issued by the Department.

Traditionally, the State has used state funds to ensure that it conducts activities that are required within Section 134 of WIOA. Governor’s Reserve funds have also been used to support local programs and initiatives that increase the availability and quality of services provided to WIOA participants. With the reduction of the state’s overall WIOA Title 1B allocation and the subsequent reduction in the Governor’s Reserve Funds, the state has prioritized usage of these funds to: 1) ensure that the state remains compliant with required WIOA administrative functions; 2) maintain activities necessary for federal reporting through the management information systems for the programs in Idaho’s workforce development system; and 3) promote and expand the services available through the 25 American Job Centers to business and individuals throughout the state.

(5) Describes the individuals affected by the waiver, including how the waiver will impact services for disadvantaged populations or individuals with multiple barriers to employment; and

The ability to maintain, rather than reduce, the current levels of service is important and extremely valuable. This waiver will provide the state with more flexibility in directing Governor’s Reserve funds to those activities that best preserve basic functions of the statewide workforce development system and ensure current service levels are maintained.

It is not anticipated that this waiver will impact any services provided to WIOA participants. Further, the state is committed to conducting these activities should the estimates contained within this document not bear out, or in the case that coming congressional budget action increases funding to the state.

(6) Describes the processes used to:

(A) Monitor the progress in implementing thewaiver; B) Provide notice to any local board affected by the waiver; (C) Provide any local board affected by the waiver an opportunity to comment on the request; (D) Ensure meaningful public comment, including comment by business and organized labor, on the waiver. (E) Collect and report information about waiver outcomes in the State’s WIOA Annual Report.

Idaho had previously requested and were granted waivers for evaluations under the Workforce Investment Act.

The Idaho Department of Labor has and will continue to monitor the implementation and impact of the waiver and progress toward expected outcomes. State oversight and evaluation will make effective use of these means to identify obstacles and address them.

Any comments received will be forwarded to the USDOL and included as a modification to the state's Combined Plan. The impact of this waiver on the state's performance will be addressed in the state's WIOA Annual Report.

The waiver outcomes, in the form of performance goals and standards, will be reported in the State’s WIOA Annual Report.

(7) The Secretary may require that States provide the most recent data available about the outcomes of the existing waiver in cases where the State seeks renewal of a previously approved waiver.

Not applicable.

Waiver Request 3 -

ELIGIBLE TRAINING PROVIDER DATA COLLECTION AND REPORTING REQUIREMENTS

(1) Identifies the statutory or regulatory requirements for which a waiver is requested and the goals that the State or local area, as appropriate, intends to achieve as a result of the waiver and how those goals relate to the Unified or Combined State Plan;

The State of Idaho is seeking a waiver from the requirements outlined in the WIOA at Sections 116 and 122, and at 20 CFR 677.230 and 20 CFR 680.400 thru 680.530, which require the collection and reporting of performance related data on all students participating in training programs listed on the state's eligible training provider (ETP) list.

With the passage of WIOA, the State of Idaho has been painstakingly working to implement the Act's ETP provisions. Training providers interested in participating may apply for inclusion to the ETP list through IdahoWorks, the state’s comprehensive WIOA and labor exchange system which contains an ETP component.

Where possible, the state has leveraged existing data systems and data sources to meet the WIOA ETP performance reporting requirements. It has coordinated with the State Board of Education to incorporate outcomes from the state’s longitudinal database system (SLDS) for educational reporting and the Idaho Department of Labor’s wage database to report earnings and address WIOA’s provisions.

Despite its efforts, Idaho has faced several challenges while working to implement the WIOA ETP requirements, which include:

• Ensuring that local areas have sufficient numbers of, and diversity of, training providers necessary to create an effective marketplace of training programs for WIOA participants utilizing ITAs.
• Ensuring fairness in the process of determining training provider eligibility.
• Reducing the burden on training providers to submit performance information to the state which may not be readily accessible.
• Proprietary schools do not currently have the ability to report student data, and as such, there is no way to automatically match students with other data sources to calculate outcomes, which results in a reporting burden on these training providers.
• Proprietary schools must collect sensitive information such as social security numbers, etc., on all students for the state to match wage and earnings information, which may leave students open to identity theft, privacy considerations, etc.
• Requiring training providers, especially proprietary schools, to collect and provide information on all students once they leave or graduate from the program. As a result, some providers choose not to participate under WIOA Title IB, limiting consumer choice.
• Providing information on eligible training programs to WIOA participants in a way that helps them make good decisions about how to use their ITAs.

(2) Describes the actions that the State or local area, as appropriate, has undertaken to remove State or local statutory or regulatory barriers;

There are no state of local statutory or regulatory barriers to implementing the proposed waiver.

(3) Describes the goals of the waiver and the expected programmatic outcomes if the request is granted; and (4) Describes how the waiver will align with the Department’s policy priorities, such as:

(A) supporting employer engagement; (B) connecting education and training strategies;

(C) supporting work-based learning; (D) improving job and career results, and

(E) other guidance issued by the Department.

Goals and outcomes related to this waiver request include:

• More numerous and varied training offerings for WIOA participants utilizing ITAs via the public workforce system through greater consumer choice.

• More training providers can lead to lower cost options.

• Greater utilization of the ETP by WIOA participants pursuing training services in Idaho related to jobs that are in-demand by employers now and in the future.

• Better overall performance outcomes for WIOA participants pursuing training via ITAs.

• Stronger partnerships and relationships between training providers and the public workforce system.

• Enhanced ability of the state/local board to respond quickly and efficiently to immediate local job seeker and employer needs.

(5) Describes the individuals affected by the waiver, including how the waiver will impact services for disadvantaged populations or individuals with multiple barriers to employment;

Individuals who access WIOA Title IB training services in Idaho via ITAs, State of Idaho WIOA staff, AJCs, contracted service provider staff, and training providers will benefit from this waiver.

(6) Describes the processes used to:

(A) Monitor the progress in implementing thewaiver; B) Provide notice to any local board affected by the waiver; (C) Provide any local board affected by the waiver an opportunity to comment on the request; (D) Ensure meaningful public comment, including comment by business and organized labor, on the waiver. (E) Collect and report information about waiver outcomes in the State’s WIOA Annual Report.

Annual WIOA on-site programmatic reviews will include an evaluation of how waivers are impacting local programs to ensure programmatic goals and outcomes are being met.

State staff involved with the administration of the ETPL and performance reporting will periodically examine the appropriateness and the effectiveness of this waiver. This strategy ensures that the goals described above, as well as those outlined in the State's Combined Plan, are consistent with established objectives of the WIOA and federal and state regulations.

In accordance with the WIOA Regulations at 20 CFR 676.145, Idaho is submitting a modification to its Combined State Plan, which is subject to the requirements outlined in the WIOA Regulations at 20 CFR 676.143(c) for public review and comment. No local boards are affected by the waiver.

Any comments received will be forwarded to the USDOL and included as a modification to the state's Combined Plan.

The waiver outcomes, in the form of performance goals and standards, will be reported in the State’s WIOA Annual Report.

(7) The Secretary may require that States provide the most recent data available about the outcomes of the existing waiver in cases where the State seeks renewal of a previously approved waiver.

Not applicable.