Located in:
- Program-specific Requirements for Adult, Dislocated Worker, and Youth Activities under Title I-B
The Unified or Combined State Plan must include the following with respect to activities carried out under subtitle B—
- c. With respect to youth workforce investment activities authorized in section 129 of WIOA—
With respect to youth workforce investment activities authorized in section 129 of WIOA—
- c. With respect to youth workforce investment activities authorized in section 129 of WIOA—
c. 4. Provide the language contained in the State policy for “requiring additional assistance to enter or complete an educational program, or to secure and hold employment” criterion for out-of-school youth specified in WIOA section 129(a)(1)(B)(iii)(VIII) and for “requiring additional assistance to complete an education program, or to secure and hold employment” criterion for in-school youth specified in WIOA section 129(a)(1)(C)(iv)(VII). If the state does not have a policy, describe how the state will ensure that local areas will have a policy for these criteria.
Current Narrative:
An administrative memo was issued on February 22, 2019 to provide guidance on the definition of the Needs Additional Assistance (NAA) eligibility criterion. It is the practice of the VDOL youth program to serve the most at-risk youth of Vermont through the provision of career and educational development services. The VDOL has a procedure for those individuals who do not meet the specified WIOA eligibility markers (including high school dropouts, homeless youth, youth in foster care, pregnant or parenting teens, etc.), but who Need Additional Assistance (NAA) to complete an educational program or to secure or hold employment.
In-School Youth (ISY) age 14-21, who meet the low-income marker, but do not have a specified at-risk eligibility factor as determined under WIOA § 129(a)(1)(B), may be served as an at-risk youth, provided that they are determined by NAA to complete an educational program or to secure or hold employment. Not more than 5 % of the ISY newly enrolled in a given program year may be eligible based on the NAA criterion. If the individual needs additional assistance, a request for approval must be submitted to the Grant Manager prior to enrollment and after the Regional Manager has reviewed the file and supports the enrollment. The request for approval form (5% NAA funding) can be found in the Workforce Development (WFD) forms folder.
Out-of-School Youth (OSY) age 16-24, who does not have a specified at-risk eligibility factor as determined under WIOA § 129(a)(1)(C), may be served as an at-risk youth, provided that they are determined to NAA to complete an educational program or to secure or hold employment. In order for an OSY to qualify as NAA, the OSY must also be determined to be low income. If an OSY applicant is age 18 or older, and is determined to have a low-risk NAA, a referral to the Adult WIOA program for a training services eligibility determination will be considered.
Needs Additional Assistance (NAA) Definition: An individual who needs additional assistance to overcome barriers to completing an educational program or to securing or holding employment will qualify for WIOA services if they are determined eligible and their NAA is clearly documented in both their case notes and their Objective Assessment. The following table establishes the barriers, their definitions and the acceptable documentation to be provided in support of the existence of such a barrier.
| Must meet at least one of the barriers listed below: | Definition | Acceptable Documentation |
|---|---|---|
| Incarcerated parent/legal guardian | Youth with a parent or legal guardian who is currently or has been incarcerated within the past 5 years | Letter or other documentation from Department of corrections or the court system; self-attestation |
| Youth who has experienced recent traumatic events, are victims of abuse, or reside in an abusive environment | Youth who has experience recent traumatic events, are victims of abuse, or reside in an abusive environment within the past 5 years | Letter or other form of documentation from: a social service agency, the legal system, a school official; self-attestation |
| Youth who has been referred to or is being treated by an agency for substance abuse or addiction issues. | Youth with a substance abuse problem or addiction issue, has been treated for a such a problem with the past 5 years or previously in treatment facility | Letter or other form of documentation from: a treatment facility, a school official, a court official, a doctor, or a social service agency. Signed statement from a parent or guardian; medical records or self-attestation |
| History of mental illness | Youth that has been diagnosed with cognitive, emotional, or behavioral illnesses | School documentation, medical records, letter or other documentation from mental health professional |
| Harassment, Victimization and Bullying | Youth who is/was a victim of verbal/physical harassment and/or bullying | School documentation, medical records, court documents, or self-attestation |
| Youth who is emancipated or in the process of being emancipated | Youth who is emancipated or in the process of being emancipated by the courts | Court Documents |
| A high school graduate or GED recipient who has not held a full-time regular job for more than 3 consecutive months and lacks work readiness skills necessary to obtain and retain substantial employment | Individual who has not been able to retain employment for more than three months | Documentation from past employers; self-attestation |
| Involved in gang activity | A gain is a group of three or more individuals who engage is criminal activity and identify themselves with a common name or sign | Court documentation; juvenile justice system documentation; self-attestation |
| Youth that are residing with family members with substance abuse or addiction issues | Youth that are currently residing with a family member that is enrolled in a treatment program or released within the past 12 months prior to enrollment | Letter or other documentation from the treatment facility verifying participation and/or release information |