Adult, Dislocated Worker, and Youth Activities

OVERVIEW OF MiTC REQUIREMENTS

A “program of training services” is one or more courses or classes, or a structured regimen that leads to:

1. A recognized post-secondary credential,
    
2. Employment, or
    
3. Measurable skill gains toward such a credential or employment.
    
   Section 680.410(d) of the WIOA regulations defines an ETP as the only type of entity that receives funding for training services as defined in Section 680.200 through an Individual Training Account (ITA).  The entity must be one of the following types:
    

• An institution of higher education that provides a program that leads to a post-secondary credential (Associate or a Baccalaureate degree),
   
• An entity that carries out programs registered under the National Apprenticeship Act
  (29 United States Code 50 et seq.), or
   
• Other public or private providers of training services which may include:

• A private non-profit provider, such as a community-based organization.
   

• A private for-profit provider, such as a proprietary school.
   
• A joint labor management organization.
   
• Eligible providers of adult education and literacy activities under Title II of the WIOA if such activities are provided in combination with career services described at 20 Code of Federal Regulations 680.350.

A “site” is defined as a place at which an instructional or training program is delivered.  A “site” is administered independently and maintains administrative records specific to enrollment in its program(s) of study.

REQUIRED MiTC INFORMATION FOR SCHOOLS PURSUING OVERVIEW OF MiTC REQUIREMENTS

Required MiTC contact and program-specific information includes the following:

• The name of the school or institution/organization to provide training services to WIOA Adult and Dislocated Worker program participants.
   
• The program contact, including the name, phone number, and address of the training provider’s main location, including city, state, and five-digit zip code.  Use the U.S. Postal Service address validation system to verify the address and zip code.

• The training program title.
   
• A short description of the training program.  The description can include other course prerequisites (e.g., driver’s license or work experience, learning outcomes, competencies gained, program accreditation, full-time/part-time, required books/technology, and related careers).
   
• The program website or the URL of the training program-specific web page for training seekers to find more information on the program.  If the program-specific page is not available, the URL of a list of programs is acceptable, or the URL for the school’s web page is acceptable.

• The program of study by potential outcome, i.e., the credentials earned upon completion.  Credentials include:

• Industry-recognized occupational certificate or certification, appropriate to qualify for entry-level or advancement in employment.
   
• Certificate of completion of an apprenticeship, and/or career and technical educational certificates.

• Occupational license recognized by the state involved or the federal government.

• An associate degree.

• A program of study leading to a baccalaureate degree.

• Community college certificate of completion.

• The specific name of the associated credential.  The associated credential is identified as the specific name of the certificate, certification, license, or degree participants can receive, i.e., Certified Welding Inspector.

• The two-digit Classification of Instructional Programs (CIP) General Category code.  

• The four-digit CIP Detailed Category Code.
   
• The six-digit CIP Program Code.
   
• O*Net-Standard Occupational Classification (SOC) code for which the program prepares students.  The choices offered will be from the National  CIP to SOC crosswalk.  Up to three SOC codes can be chosen, one is mandatory. 
   
• The total out-of-pocket costs, including the total cost of tuition and required fees, assuming normal time to completion.  Examples of fees include athletic center fees, technology fees, and lab fees.
   
• The total cost of other out-of-pocket costs of books and supplies, assuming normal time to completion.
   
• Whether or not there is a license fee for employment.
   
• If any additional sources of financial assistance, including Pell Grants or other sources of financial assistance, are accepted.

• A description of any other sources of financial assistance that are accepted.
   
• Estimated waiting period for entry into the program.
   
• Program duration (clock or contact hours).  Clock hours are the total number of actual hours per week a student spends attending class or other instructional activities that count toward completing a program of study.  A clock/contact hour is defined as a 60-minute span of time with between 50 and 60 minutes of actual class instruction, which may include class, recitation, lecture, lab, training, or internship.  No more than one (1.0) clock hour can be assigned to any discrete 60-minute period.
   
• Program duration (weeks) as completed by a full-time student.
   
• Program prerequisites.  Prerequisites may include:

• High school diploma or its equivalent.
   
• Associates degree.
   
• Bachelor’s degree.

• Courses.

• A combination of education and course(s).

• Program Format.  The format of the program may include:
   

• In-person.
   
• Online, e-learning, or distance learning.

• Hybrid or blended program.

• Whether or not an internship or externship is required.
   
• Whether or not the program is a new program.  A new program is defined as a program that cannot report historical information on outcomes for graduates because the program lacks a history.  Conditions include:

• The first day of the first class has not yet occurred, AND
   
• The program is a new offering for the institution.
   

• Required MiTC program performance data.  Schools are required to meet minimum performance standards.  These minimum standards are based on Michigan’s expected performance levels, as negotiated with the U.S. Department of Labor.

Beginning July 1, 2018, both initial and continuing eligibility is based on a Program Year (PY), operating from July 1 through June 30 each year.  Additionally, all schools are required to enter their performance data on the MiTC for each program of study at each training site.  The information must be reported for all programs of study listed on the MiTC, including programs that have not served WIOA participants during the reporting period.

As part of the Michigan Department of Labor and Economic Opportunity-WD’s (LEO-WD’s) quality assurance review, programs will be reviewed for compliance with applicable State licensing laws.  The review will occur as part of the application process and prior to the program’s submission to the Michigan Works! Agency (MWA) for review.  The review will consider all licensing laws that may apply to any given training program.  WD will remove an organization and its programs from the Michigan Training Connect in the event a license is revoked or suspended.  The MWA reviews the application and criteria (i.e. credentials are valid (associate or baccalaureate degree, occupational licensure, occupational certificate, occupational certification or licensure, or other industry-recognized certificates of industry/occupational skills completion sufficient to qualify for entry-level or advancement in employment) and confirms that the training program is in high-demand and will meet employer needs within the local area).  The MWA then grants approval as an ITA-eligible program and designates their approval on the system.  Once approved, the training provider’s program will be eligible to serve the WIOA-eligible customers across the state.

Only ITA-eligible programs will appear on the MiTC.  If WIOA ITA funds are being used to pay for training, the school must be listed on the MiTC as an eligible training provider.

Training providers must apply to become certified as a WIOA ITA-eligible training provider.  The application can be accessed under the Career Explorer tab on the MiTC website.  A training provider is required to submit program information for each program, at each site at which the program is offered.

INITIAL ELIGIBILITY

The state’s Eligible Training Provider (ETP) List is housed within the Department of Labor and Economic Opportunity (LEO), Pure Michigan Talent Connect Section and is known as Michigan Training Connect (MiTC).  Eligibility criteria for initial and subsequent eligibility, in accordance with the Workforce Innovation and Opportunity Act (WIOA) Section 122, is summarized in the Michigan Training Connect Policy Manual, located on the LEO website with the other policies and manuals.  

In order to be listed on the MiTC as an ETP, the school must accept WIOA-funded Individual Training Accounts (ITAs).  The program must be on the MiTC at the time of the student’s training start date into the training program.

The state’s requirements to become an ETP apply to all organizations providing the WIOA Title I-B funded training to adults and dislocated workers, with the specific exception of Registered Apprenticeship programs.  With the exception of Registered Apprenticeship programs, for all programs that have not been previously eligible, providers must submit required information, including performance, in order to have their programs considered for initial eligibility in accordance with the LEO procedures.  Programs that receive initial eligibility designation receive the designation for one year.

In establishing initial eligibility procedures and criteria, at minimum, the following standards and information requirements apply:

• A description of the program of training services to be offered.

• Proof of proprietary school licensure.

• Information concerning whether the provider is in partnership with business.  This could include information about the quality and quantity of employer partnerships.

• Other information in order to demonstrate high-quality training services, including whether the training program leads to a recognized post-secondary credential.

• Information that addresses the alignment of the training with in-demand industry sectors and occupations, to the extent possible.
   
• With the exception of new training programs, provide information addressing a factor related to the indicators of performance, as described in the WIOA Section 116(b)(2)(A)(i)(I)-(IV), which include unsubsidized employment during the second quarter after exit, unsubsidized employment during the fourth quarter after exit, median earnings, and credential attainment.
   
  CONTINUED ELIGIBILITY
  All ETPs are subject to continued ITA eligibility procedures and minimum program performance standards each year thereafter.  Continued eligibility requirements apply to training providers transitioning to the WIOA Title I-B who were previously eligible under the Workforce Investment Act (WIA) Title I and newly eligible training providers that were determined to be initially eligible under the WIOA Title I-B.  Continued ITA eligibility in Michigan is determined with the same requirements and information collection for initial eligibility and final approval by the Michigan Works! Agency (MWA).  However, while the WIOA states that all providers are subject to review and renewal of their eligibility every two years, due to proprietary school licensure processes and requirements, Michigan will be reviewing eligibility every year.  The renewal period for training providers is based on a Program Year (PY), operating from July 1 through June 30.  
  The WIOA requires that providers seeking continued eligibility must provide verifiable program-specific performance information.  Michigan has set minimum performance standards for unsubsidized employment during the second quarter after exit, unsubsidized employment during the fourth quarter after exit, median earnings and credential attainment. Continued eligibility criteria for performance standards may include:
• Information identifying the recognized post-secondary credentials received by all training participants.
   
• Program cost information, including tuition and fees for the WIOA participants in the program.
   
• Information on the program completion rate for the WIOA participants.

The state and local areas may also consider alternate factors, such as:

• Access to training services using technology throughout the state, including rural areas.
   
• Information reported to state agencies on federal and state training programs other than programs within the WIOA Title I-B.
   
• The degree to which training programs relate to in-demand industry sectors and occupations within the state.
   
• State licensure requirements, and the licensing status of training providers; if applicable.

• The provider’s ability to offer industry-recognized certificates and/or credentials.
• The ability of providers to offer programs that lead to post-secondary credentials.
   
• The quality of a training program, including a program that leads to a recognized
  post-secondary credential.
   
• The ability of providers to provide training services that are physically and programmatically accessible for individuals who are employed and for individuals with barriers to employment, including individuals with disabilities.
   
• The timeliness and accuracy of training providers’ performance reports.

States are also responsible for ensuring the quality and value of ETPs.  Local areas may include other factors determined to ensure quality and value, as appropriate, including, but not limited to:

• The training provider’s accountability,
   
• Training participants are given an informed choice among providers,

• The provider’s ability to partner with employers and to provide job placement services,

• The provider’s student dropout rate, and

• The provider’s student loan default rate.

Continued eligibility applications for programs failing to meet State-specified performance standards may be considered for eligibility at the discretion of the reviewing MWA, provided the training provider can provide a sufficient reason for a program to be exempt from performance standards.  Local areas must have a policy in place for approving programs failing to meet State-specified performance standards.

The MWAs have the authority to consider local economic conditions and the economic and demographic characteristics of the students a school serves when reviewing applications for continued eligibility.  Training providers seeking continued eligibility approval under these circumstances must be able to provide supportive/supplemental documentation for each training program affected.  The continued eligibility application will either demonstrate that the program performance is at or above the State standards or will include an initial justification of below-standards performance.  The MWA reviewing the application reserves the right to determine whether the criteria provided by the training provider is satisfactory for approval.  However, higher local policy standards may not keep a training program off of the State ETPL. If the initial justification of below-standards performance is not satisfactory to the MWA, the “reason for disapproval” must be provided to the applicant.  Where the health and safety of students and others may be at risk, the MWAs have the right to deny continuing eligibility, based on supplemental information received about a training provider.  Training providers that are not approved for placement on the MiTC have the right to appeal the decision within 30 working days from the date of the denial.

The State allows local areas to set higher levels of performance than the state minimum performance as criteria for training providers to be placed on, or to remain on, the MiTC.  The MWAs may also request additional information, such as the name of, the quality, and quantity of employers involved in partnership with the training institution and/or additional information about the school’s alignment with in-demand industry sectors or occupations, etc. 

Local areas must have a policy in place that indicates how performance will be measured to ensure that local performance standards are applied in a consistent and objective manner.  Local policies related to ETPs and the MiTC will be examined as part of the WIOA program review process.  Once approved by the MWA, the program is designated as ITA-eligible on the MiTC and approved to serve ITA-eligible customers across the state. 

Active outreach to all U.S. Department of Labor Registered Apprenticeship programs located within the State of Michigan for placement on the MiTC has continued a partnership with Michigan’s federal Office of Apprenticeship sponsor.  Michigan’s State Apprenticeship office is located within LEO and is currently working with MiTC on outreach strategies to contact all Registered Apprenticeship programs within the state to allow them to indicate interest. 

For placement of Registered Apprenticeship programs on the MiTC, program sponsors must indicate their interest in being an ETP.  In addition to providing contact and program-specific information, all Registered Apprenticeship programs will be required to provide the following information for placement on the MiTC:

• Occupations included within the Registered Apprenticeship program.
   
• Contact information including the name and address of the Registered Apprenticeship sponsor.
   
• The name and address of the related technical instruction provider, and the location of instruction if different from the program sponsor’s address.
   
• The method and length of instruction.

• The number of active apprentices.
   
• Registered Apprenticeship program sponsors that do not provide the related technical instruction portion of the apprenticeship program may be required to provide additional information about their education provider, including the cost of instruction.  (This is the only time that cost information should be requested).
   
  DEEMING PROVIDERS INELIGIBLE (REMOVING A TRAINING PROVIDER FROM LIST)
  The state is required to establish procedures for removing a provider from the MiTC.
   
  During the continued eligibility process, the MWAs will have access to programs on the MiTC failing program performance measures.  The ITA eligibility designation will be removed from the MiTC unless the governing MWA wishes to retain a given program on the MiTC.  The MWAs wishing to grant an exception, based on local economic conditions and the economic and demographic characteristics of the students a school serves, should notify WD.  Training providers will then be notified.
   
  Providers may be also removed under the following conditions:
   

• Inaccurate information regarding a program is intentionally supplied; a termination of eligibility will occur for a period of not less than two years.
   
• It is determined an eligible provider has substantially violated any requirements under the Act; the provider’s eligibility to receive funds for the program(s) in question will be terminated for a period of not less than two years.
   
• If a training provider does not reapply under the continued eligibility procedures; they will be removed from the MiTC.  The training provider will be required to reapply under continued eligibility procedures and have met performance prior to having their program placed back on the MiTC.
   
• A provider must deliver positive results and provide accurate information about those results.  If a provider fails to meet or exceed established performance levels; the provider’s eligibility to receive funds may be suspended for a period of not less than two years.  At the end of the two-year period, the provider would have to reapply under continued eligibility provisions.  The provider would only be placed back on the MiTC following a determination by the local area as to whether performance is now at an acceptable level.
   
• A training provider that substantially violates the terms outlined in a training agreement with an MWA or one of its sub-recipients may be considered as non-compliant as defined under Section 122 (f) of the WIOA and thereby subject to removal from the MiTC.  An example of a substantial violation may include, but is not limited to, ceasing operations prior to delivering all training services.

• Where the health and safety of students or others could be at risk, the MWAs have the right to request removal of a training provider, based on supplemental information received.  The MWA must first notify WD in writing that they are requesting that the training provider be removed from the MiTC.  Once approved by the WD, the MWA must then notify the school that they will be removed from the MiTC and of their right to appeal following the WD Grievance and Complaint Policy Issuance in effect at the time of the training provider’s removal from the MiTC.
   

Training providers determined to have intentionally supplied inaccurate information or have subsequently violated any provision of the WIOA Title I or supporting federal regulations will be removed from the MiTC.  A provider whose eligibility is terminated under these conditions will be liable to repay, from non-federal funds, all the WIOA training funds received during the period of

non-compliance.  To be reinstated on the MiTC, the training institution must reapply under continued eligibility procedures, retain their Title IV status, retain licensure, and meet all performance measures.  The state will work with the MWAs to ensure that participants enrolled in a training program where a provider’s eligibility was revoked for non-compliance will experience minimal disruption.

The training program is required to be listed on the MiTC at the time of the participant’s training start date of the training program and remain on the MiTC with subsequent semester(s) or term(s), with special attention given to August 1 and after (after Michigan’s July renewal period).

If the participant is enrolled in a training program that is removed from the MiTC prior to their completion of the training activity, the MWA must notify WD.  A determination will be made on a case-by-case basis following the WD review of the circumstances around the removal of the program from the MiTC.

The ETPs are subject to the equal opportunity and nondiscrimination requirements contained in Section 188 of the WIOA.

 APPEALS PROCESS

Providers removed from the MiTC must be afforded the opportunity to appeal the removal.  The training provider has the right to appeal their removal from the MiTC within 30 working days from the date of the revocation, following the WD Grievance and Complaint Policy in effect at the time of training provider’s removal from the MiTC. This policy is located on the LEO website