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e. Waiver Requests (optional) (e1-e6)

States wanting to request waivers as part of their title I-B Operational Plan must include a waiver plan that includes the following information for each waiver requested:

  • 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;

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

  • 3. Describes the goals of the waiver and the expected programmatic outcomes if the request is granted;

  • 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.

  • 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

  • 6. Describes the processes used to:

    • A. Monitor the progress in implementing the waiver;

    • 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.

  • 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.

Current Narrative:


Waiver of Governor's reserve and local formula youth funds on OSY

1. The statutory and/or regulatory requirements the State would like to waive:

The State of Indiana is requesting a waiver from Section 129(a)(4)(A) and 20 CFR 681.410, which require not less than 75 percent of funds allotted to states under Section 127(b)(l)(c), reserved under Section 128(a), and available for statewide activities under subsection (b), and not less than 75 percent of funds available to local areas under subsection (c), shall be used to provide youth workforce investment activities for OSY.

Indiana is requesting the following waivers to this statutory and regulatory provision:

A waiver of the requirement to expend 75 percent of funding on the OSY population. Indiana is requesting that this percentage be lowered to 50 percent.

A waiver of the requirement that local funding meet the 75 percent minimum expenditure requirement. Indiana requests that this percentage be lowered to 50 percent to align with the statewide target (see 1 above).

A waiver of the requirement to expend 75 percent of Statewide Activities funding on the OSY population. It is requested to reduce this percentage to 50 percent to allow flexibility of funding special projects that meet the vision and mission of the state.


Hoosier adults with a high school degree or less or those with some college but no credential or degree are at a competitive disadvantage to obtain middle-skill work with residents of every Midwestern state and over half of Southern states.1 Additionally, 54% of Indiana employers do not believe students are adequately prepared for the workforce, with 51% leaving jobs unfilled due to underqualified applicants.2 Employers cite critical thinking, personal qualities, communication skills, interpersonal skills, and understanding of technology as the most challenging qualities to find among job applicants and new hires.

1 Indiana Institute for Working Families, 2018. The Status of Working Families in Indiana 2018 Report.

2 Indiana Youth Institute, 2019. 2019 Indiana Kids Count Data Book.

Indiana has a student to school counselor ratio of approximately 600 students to one counselor. Counselors have a large responsibility of responding to the social-emotional needs of students that leaves a strained capacity for working with students regarding their plans for life after high school. To combat these issues and increase the state's graduation rate, the Indiana General Assembly continues to commit state funds to dropout prevention funding. The 2014 and 2016 biennium budget allowed the Indiana Department of Workforce Development to double its dropout prevention program. The 2018 budget allowed continued advancement in the dropout prevention program.

This waiver is consistent with Governor Holcomb's vision to cultivate a strong and diverse economy by sharing Indiana’s story of opportunity and developing a 21st Century skilled and ready workforce. Specific to these goals, the Governor is working to align workforce and education programs to quality career pathways, providing more opportunities for students to connect to resources.

The above waiver request will result in increased partnership and collaboration between the Governor’s Workforce Cabinet, Department of Workforce Development, the local Workforce Development Boards and economic development teams, local school districts, parents, families and communities, postsecondary institutions, public and private organizations, and local employers to support our Hoosier youth and build a readied talent pipeline.

2. Actions the State has undertaken to remove State and local barriers:

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

3. State strategic goal(s), projected programmatic outcomes, and Department of Labor priorities supported by the waiver:

Goal: Continued increase of services to at-risk youth. Approval of this waiver request will allow the state and local areas to focus funds and services on engaging at-risk, in-school youth to assist in connection to valuable experience that drive career and educational opportunity awareness.

Goal: Increased evaluation of support and funding for high-quality dropout prevention programming. Through focused funding and continual evaluation of the programming, the state can continue to adjust programs to meet the optimal needs of at-risk students, increasing successful transitions to employment or postsecondary education. One of the critical program elements for the Workforce Innovation and Opportunity Act (WIOA) youth program are follow-up services. Providing continued follow-up services and supports for at-risk youth who graduate high school as they transition to new opportunities in employment or education will increase performance metrics related to employment rate, credential attainment, and median earnings.

Goal: Improved flexibility of local and statewide activities funding to best meet the needs of our citizens and businesses. This waiver will improve the ability of the Workforce Development Boards to develop strategies to align with the workforce and economic needs of their local areas and to design these programs to meet the needs of their youth. The needs of one community may be different compared to the needs of another including when and what type of a program is offered. WIOA encourages strong partnerships to leverage resources and increase opportunities for at-risk youth. Indiana established the Governor’s Workforce Cabinet to facilitate this connectivity among state agencies, local school districts and boards, and employers in an effort to leverage resources to prevent students from dropping out of high school and decrease their likelihood of needing government benefits in the future.

4. Individuals, groups or populations benefitting from the waiver:

Indiana's at-risk young adult population, parents of the youth, school counselors, American Job Centers (AJC), agencies serving at-risk youth, subcontracted service provider staff, and employers will be positively impacted by this waiver, so that programs are structured in the most beneficial way for all involved.

5. How the State plans to monitor waiver implementation, including collection of waiver outcome information:

Annual WIOA onsite programmatic reviews will include an evaluation of how youth funding is being utilized.

Local onsite reviews will take place to discuss in-school and out-of-school youth programs and expenditure plans with each service area.

6. Assurance of State posting of the request for public comment and notification to affected local workforce development boards.

The Governor’s Workforce Cabinet’s Strategic Plan Committee, created in 2019, consisted of key agency, education, workforce, and organizational leadership. The committee discussed the waivers and had local board representation present. The draft state plan was posted on the Department of Workforce Development and Governor’s Workforce Cabinet websites and notice was sent out broadly by core partners that the plan was open for public comment.

A local meeting occurred in 11 regions beginning in August and concluding in November to discuss

objectives in the State Plan and hear feedback from local partners.

A copy of the waiver will be available for public inspection at the Indiana Department of Workforce Development offices and the Governor’s Workforce Cabinet office.