Adult, Dislocated Worker, and Youth Activities

WAIVER REQUEST 1 STATE OF INDIANA*

*UPDATE: US DOL ETA approved this waiver request but required the addition of unique Adult Education and Vocational Rehabilitation representatives, with voting privileges, on the GWC. Announced on August 2, 2022, Governor Holcomb has appointed the following to fulfill this requirement:

Marilyn Pitzulo, Indiana DWD, Associate Chief of Strategy/Design (Adult Education)

Theresa Koleszar, Indiana FSSA, Director of the Bureau of Rehabilitation Services (VR)

Waiver of State Workforce Board Membership

Governor Holcomb's administration has made workforce development a signature pillar of his administration and is committed to ensuring that Hoosiers have the skills and training needed for success in a 21^st century economy. State leaders also continues to make significant and crucial investments in our economic climate and Indiana has positioned itself as one of the premier states in America in which to start and grow businesses.

Indiana established the Governor’s Workforce Cabinet in 2018 to spearhead these efforts, seeking to align the state’s strategies across, education, workforce, economic development, social services, and other areas. The Cabinet became the state workforce board in 2018 through USDOL waiver approval and the waiver was renewed in 2020. The waiver structure facilitated Indiana’s first Combined WIOA plan in 2020 and has helped bolster a wide variety of state strategies outlined throughout the waiver. This request seeks to renew the waiver for PY22 and PY23.

Moving from a 46-member state workforce board to a 31-member Cabinet reporting directly to the Governor has ensured and will continue to ensure collaboration across state agencies. The Cabinet has the ability to continue to drive strong collaboration among local governments, local workforce boards, various state agencies, and employers all across Indiana. The Cabinet’s structure also allows it to be nimble and actionable to challenges that arise in addressing needs brought forward by various stakeholders key to the state’s workforce and education efforts.

A core component of the State’s vision for workforce development recognizes that a true workforce strategy responsive to employer needs must align education from pre-k through postsecondary with traditional workforce programs and social services. To that end, Indiana includes as a part of the GWC representatives from all levels of education with policy-making authority in their respective organizations, to ensure that the input, concerns and needs raised by the diverse employer community represented on the Cabinet translate to development and implementation of scalable training programs responsive to those needs.

As Indiana’s economy emerges from the COVID-19 pandemic, the Cabinet will continue to be a central part of the state’s workforce strategies. This includes continuing to work across all partner programs on executing the strategies in the State Plan. Indiana is currently seeing record low unemployment, but challenges remain in getting more Hoosiers into the labor force and moving more people into meaningful training and high-wage jobs. The Cabinet will continue to strive for continuous improvement to our traditional workforce development programs and alignment of those programs with resources and strategies that assist in cross-agency communication. Collaboration with agency leadership spurred through the Cabinet is creating better connected services and innovative new ways to deliver services focused on the best experience for the people served not the system outcome.

1. Statutory and/or Regulatory Requirements the State would like to Waive:

State Workforce Development Board (SWDB) Membership and Establishment

Workforce Innovation and Opportunity Act (WIOA) requirement for SWDB membership WIOA Sec. 101(b)(1) and (c) and the corresponding regulations at 20 CFR 679.110(b)-(c): requirement to appoint specific members to the board described in this CFR section. The membership of the current Governor's Workforce Cabinet (Cabinet) and additional supplementary information about Cabinet membership may be found at the end of the waiver request in the appendix section. The appendix includes a roster with current membership, category represented, and vacancies. The State of Indiana asks that the waiver for the membership of the Cabinet be granted for a two-year period, PY 22 and PY 23.  

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

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

The Indiana General Assembly passed and Governor Holcomb signed Senate Enrolled Act 50 in 2018, Indiana Code 4-3-27. The bill created the Governor's Workforce Cabinet to comply with the federal requirements for a state workforce development board under WIOA.

3 and 4. State strategic goal(s) and Department of Labor priorities supported by the waiver:

The goal of continued waiver flexibility in the membership requirements of the SWDB under WIOA Sec. 101(b)(1) and (c) is to maintain a smaller, more nimble board in favor of efficiency and consensus-building, as well as keeping the priorly authorized membership flexibility to tap optimum policy-making authority across the entirety of Indiana’s workforce development system (birth through adulthood), especially through the appointment of state leaders’ who oversee or influence core and ancillary programs that co-enroll target populations, affect seamless program-to-program handoffs, share data, sometimes co-locate, and cross-train each other or local partners, e.g., WDBs, K-12 stakeholders, and employers.

An example of how Indiana has used its waiver flexibility to advance core state goals includes the inclusion of the Chancellor of Ivy Tech Community College, the nation’s largest individually-accredited public community college system, and the President of Vincennes University, Indiana’s multiple-campus, two-year university, to serve on the Cabinet. Their optimum-policy authority empowers state agencies, employers, stakeholders, and target populations to leverage state and federal resources to maximum effect for short-term certificates and credentials.

The vision of WIOA outlined in TEGL 19-14 highlights the importance of state workforce boards working in partnership with workforce, economic development, education, and social service organizations at the state level to ensure all jobseekers and businesses can access pathways to prosperity. Waiver flexibility has helped support Indiana in realizing this vision and ongoing flexibility will continue to assist the state in meeting several strategic goals in line with Department of Labor priorities.

State Strategic Goal #1: Setting a single vision for workforce policy.

The objective of the original and approved waiver was to enable the collaborative development, refinement, and implementation of a single state vision for workforce policy. During the first waiver period, the Cabinet shifted to the Governor's Office and became chaired by the state’s Commissioner for Higher Education, a nationally-recognized state higher education executive officer. The Commissioner led the Cabinet throughout the second waiver period but stepped down this spring from both roles. The Governor has recently named a new chair since the submission of the original waiver request at the end of March. The new chair brings with him a variety of experiences in both the public and private sector critical to the Cabinet’s ongoing mission. Continued membership flexibility is facilitating this process as well as ensuring continuity of the Cabinet’s efforts, particularly in executing the state WIOA plan.

The Cabinet’s daily objectives are led by a seasoned staff with experience in education and workforce; they liaise and collaborate with relevant state agencies and the Governor’s Office daily, in addition to outside stakeholders spanning local government, federal government, education, business, and nonprofit sectors. The Governor’s appointees are geographically diverse and represent key areas of Indiana’s economy. Due to this broad-based, expert leadership, the goal of a single vision for workforce policy was realized. That singular, common workforce policy is bolstered through concrete guiding statements that the Cabinet can follow as different recommendations are made. The Mission, Vision, Goals, and Guiding Principles adopted by the Cabinet in 2019 can be found here.

These foundational elements were key during this last waiver period where the Cabinet completed the state’s first Combined WIOA plan in 2020 and led the state’s workforce recovery efforts during the COVID-19 pandemic. Without waiver flexibility, the Cabinet would not have had the requisite representation of all applicable state agencies and external stakeholders who oversee or influence the core and ancillary programs that serve the plan’s target populations. Furthermore, implementing Indiana’s key strategies, such as co-enrollment, co-location, data sharing, and cross-training would have otherwise been hindered without the waiver enabling the participation of multiple key principals with optimum policy-making authority.

One of the goals of the original waiver was to streamline board size to allow Indiana to react efficiently to changes in economic conditions and responsively meet the needs of employees and employers. This ability to react quickly and decisively, through the streamlined board structure, became incredibly important in 2020 at the onset of the pandemic. The Cabinet structure provided for efficient collaboration with Indiana employers, education and training providers, policymakers, and state and local partners to quickly mobilize resources and implement a comprehensive workforce recovery plan to respond to the substantial impact to the state’s economy including both employers and individual citizens.

Through the leadership of the GWC, Indiana established the Rapid Recovery for a Better Future initiative providing resources and support for Hoosiers to secure education, training, as well as skills and career coaching, and increasing access to quality jobs. The GWC was able to utilize the state’s workforce vision and goals to identify priority areas of focus for the Rapid Recovery effort, which included use of CARES funding to provide workforce training and other career coaching tools to help Hoosiers and employers on the path to economic recovery.

State Strategic Goal #2:Implement and track WIOA State Workforce Plan (State Plan) initiatives.

The waiver-enabled Cabinet structure was instrumental in Indiana completing its first Combined WIOA plan in 2020 through the work of Cabinet subcommittees, collaboration of constituent agencies and stakeholders, and coordinating work of Cabinet staff. Indiana’s unique structure sustains implementation, allows for adjustments, and supports tracking progress of the State Plan. Having representation from all of the state agencies key to the development of the Plan on the Cabinet allowed for the state to develop a more comprehensive workforce plan with significant input from state agencies, employers, and other key stakeholders. The Plan includes a variety of strategies around co-enrollment, data sharing, cross-training, employer engagement, and co-location that were enhanced through the Combined WIOA plan and are being tracked as part of the Plan’s progress.

One example of data sharing has occurred through a cross-agency project led by the Cabinet and the Department of Workforce Development focused on better connecting job seekers with employment and training opportunities, particularly those who are unemployed or underemployed. A data sharing agreement has been put in place across several state agencies through the direction of the Cabinet that has facilitated this project, which seeks to use artificial intelligence and machine learning to help provide better resources to Hoosiers interacting with state programs. This project is being paired with efforts to streamline user experiences through a centralized website to serve customers in a more clear and relevant manner.

Employer engagement has also been a key focus, including through the Next Level Jobs Employer Training Grant which serviced over 1,200 employers during the pandemic. The Employer Training Grant received an additional infusion of $15 million in CARES funding (alongside investments in the Workforce Ready Grant discussed in state strategic goal #3). This resulted in employers being able to skill up 11,752 employees who were both retained and realized a wage increase. Significant increases were seen in participation of minority, women, and veteran owned businesses due to targeted strategies by the state. These results were supported by the infrastructure and relationships developed through the Cabinet that allowed the state to quickly deploy strategies to best serve Hoosier businesses.

Through these items and others, the Cabinet structure facilitated the submission of Indiana’s first Combined Plan in 2020 and continues to serve an important role in tracking the implementation and progress of the State Plan.

State Strategic Goal #3: Continue to increase Indiana’s educational attainment rate with a specific goal of having 60% of Hoosiers with a quality credential beyond high school by 2025

According to the Lumina Foundation in their Stronger Nation through Higher Education report, Indiana and the U.S. as a whole, must rapidly increase attainment rates to meet established attainment goals. Indiana’s attainment rate stands at 48.3% and the Cabinet is an integral part of the state’s efforts to reach a 60% attainment goal by 2025. We have seen consistent gains in our attainment rate in recent years, but more than 700,000 Hoosiers have begun but not completed postsecondary programs and another 400,000 lack any high school diploma or equivalency at all.

Earning postsecondary credentials, whether certificates or degrees, requires multiple state agencies and higher education entities setting and implementing plans toward this attainment goal. Without waiver flexibility, Indiana’s Cabinet would have significant difficulties in leading the efforts of Indiana’s workforce and education agencies towards the 60% goal. One of the state’s central efforts to achieving this attainment benchmark is through targeting populations facing barriers to employment and training through Indiana’s signature workforce development initiative, Next Level Jobs.

Next Level Jobs is made up of two grant programs, the Employer Training Grant and the Workforce Ready Grant. The Next Level Jobs Workforce Ready Grant (WRG) program provides free training to Hoosiers without education beyond high school in certificate programs that have been identified as part of Indiana’s high-wage, high-demand sectors. The WRG program is administered in partnership by the DWD and the Commission for Higher Education (CHE) the former administers funding for non-credit bearing training programs, while the latter funds credit-bearing certificate and credential training programs. This collaboration between the two agencies, made possible through the direction and leadership of the Cabinet, allows for a balanced approach to providing Hoosiers with the opportunity to earn a credential in a high-demand field.

During the pandemic, Governor Holcomb allotted $50 million in CARES funding towards workforce recovery efforts. Due to the Cabinet structure and relationships built during the Combined Plan process, the Cabinet was able to stand up a committee to determine how to effectively deploy the funding. The funding was primarily utilized to expand access and promote the Next Level Jobs program, with nearly half going to the Workforce Ready Grant. From the summer of 2020 through the end of 2021, 30,000 Hoosiers enrolled in a certificate program and nearly 18,000 completed a credential. Individuals who complete this training program see an average wage gain of $6,800.

The Cabinet’s role in setting the vision and providing direction on a variety of initiatives central to Indiana’s educational attainment goal is a key element in Indiana’s broad-based effort to continue making progress towards this goal. Without waiver flexibility allowing for multiple applicable state agency leaders as well as multiple higher education institutions’ leadership to sit on the Cabinet, Indiana would not have been able to realize system-wide integration to this extent, nor have been able to react as quickly to the COVID-19 pandemic. Going forward, maintaining the momentum of the Next Level Jobs program and other key initiatives will continue to be enabled through the continued flexibility provided by the Cabinet’s waiver.

State Strategic Goal #4: Launch newly developed career and technical education programs of study during the 2022-2023 school year to advance opportunities for students participating in CTE.

Following the Cabinet’s establishment as a distinct state agency in 2019, the Cabinet became the eligible agency for the Carl D. Perkins Act. Cabinet members and staff worked in concert with vast array of stakeholder types spanning the state to complete a comprehensive review of Indiana’s CTE system. That Cabinet-led collaboration resulted in the complete redesign of 66 CTE programs of study which are more rigorous, career relevant, reverse-engineered to meet employer needs, and mirror the same credential training an adult would receive through postsecondary CTE offerings at career centers and community college campuses. This initiative, named Next Level Programs of Study, was available to secondary schools and career centers on an opt-in basis this school year (2021-2022), which has seen record enrollment and state investment in CTE coursework. Beginning next school year (2022-2023), Next Level Programs of Study will be mandatory statewide.  

The waiver facilitated the ability to move CTE under the Cabinet and the Cabinet’s stature allowed for the state to pull in various partners to complete the redesign of the state’s CTE system over the past 2 years. Through the newly designed programs of study, students will experience greater quality, consistency, and intentionality in their CTE programming that would have been impossible to realize without a statewide, multistakeholder redesign. For example, Next Level Programs of Study provide students the opportunity to complete one year of postsecondary academic credit while in high school, preparing students to secure quality employment or quickly transition to an applicable postsecondary program with both confidence and competency that did not previously exist based on their experiences. 

The new programs of study are set to launch in the 2022-2023 school year. An extension of the waiver will allow the Cabinet to seamlessly begin implementing these new courses, working in concert with the state’s Department of Education and other stakeholders. The Cabinet will be specifically measuring three Measures of Program Quality outlined in the state’s Perkins Plan - dual credits earned, credential attainment, and work-based learning participation.

Without waiver flexibility, the Cabinet’s structure could not have accommodated a variety of high-level stakeholder voices critical to the success of the CTE redesign process over the last two years, such as specified appointments for the Secretary of the Indiana Department of Education, a school corporation superintendent, a high school principal, a regional career center CTE director, and the Superintendent of the Department of Correction. Alongside employers sitting on the cabinet, these individuals and their wider colleague networks and associations, such as the Indiana Association for Career and Technical Association, played a central role in gathering feedback and results upon the opt-in launch of the new CTE programs this school year (2021-2022). Statewide momentum is accelerating for high school CTE that is rigorous and career relevant. This school year, Indiana disbursed a record $168 million in state tuition support for high school CTE classes.

Furthermore, waiver flexibility will be essential to monitoring mandatory, statewide adoption during the upcoming school year (2022-2023). Overall, Indiana’s waiver flexibility is indispensable to realizing the full potential of its Perkins-funded and CTE programmatic efforts for high schoolers, adults, and incarcerated individuals.

State Strategic Goal #5: Increase access to work-based learning and apprenticeship opportunities

Indiana continues to focus on increasing access for both youth and adult populations to high-quality work based learning opportunities, including apprenticeships, as a key strategy for building the talent pipeline employers need. The diverse membership of the Cabinet, including state agencies responsible for developing a framework for WBL and employer representatives who benefit from such programs, provide critical input on how to build scalable programs responsive to employer needs.

Indiana recently submitted two complementary proposals for the U.S. Department of Labor’s Apprenticeship Building America Grant. The Cabinet’s career and technical education staff led the submission of a proposal for Section 2 of the grant, which focuses on increasing registered apprenticeship program opportunities for youth. The DWD Office of Work-Based Learning and Apprenticeship (OWBLA), in collaboration with regional Workforce Development Boards, also submitted a proposal for two of the ABA categories related to increasing opportunities for adult populations. This application seeks to build off prior iterations of US DOL apprenticeship grants that OWBLA has received to assist local boards and businesses.

Having completed the redesign of the state career and technical education programs in the last two years, one of the Cabinet’s specific focuses is on integrating more opportunities for quality work-based learning opportunities, including apprenticeships, into CTE programs. Multiple cabinet-represented agencies and entities are prioritizing WBL and are currently participating in a business-led supply-and-demand study of WBL opportunities across the state, with a specific focus on rural and urban populations.  

Outcomes identified in the DWD’s grant application to expand apprenticeship and pre-apprenticeship opportunities for adult populations includes strategies to serve 1,118 individuals through registered apprenticeship programs, with an additional 500 participants served through Indiana’s pre-apprenticeship programs known as State Earn and Learn programs (SEALs). Utilizing the experience and reach of Cabinet members to build upon existing employer connections through local workforce development boards’ employer networks will be critical to this effort.

Indiana has been successful in implementing strategies to consistently increase the use of work-based learning opportunities to create the skilled talent pipeline employers demand currently ranking 6^th nationally in number of active apprentices and 8^th for number of completions in CY 22. However, maintaining the momentum in doing so will be further enabled through the continuity provided by the Cabinet’s waiver and the continued partnerships with industry leaders, labor leaders, education leaders, equity partners, and community-based organizations that the waiver supports.

5. Quantifiable projected programmatic outcomes resulting from implementation of the waiver:

The projected programmatic outcomes supported by implementation of this waiver request include:

1. Increase Indiana’s educational attainment rate with a specific goal of having 60% of Hoosiers with a quality credential beyond high school by 2025. Consistent with its Perkins submission, Indiana will target an 8% increase in credential attainment over the waiver period.

This outcome is supported by several items outlined in the waiver, including the full implementation of Indiana’s new CTE courses, Next Level Programs of Study, and continued efforts to build on the successful results of the Next Level Jobs Workforce Ready Grant.

2. Expand work-based learning opportunities for both youth and adult populations. Indiana will target a 6% increase in work-based learning participation over the waiver period.

Strategies to achieve this outcome and recent progress are described in more detail under Strategic Goal #5. Additional specific goals around work-based learning and apprenticeship opportunities are being currently informed by a statewide study of current capacity, which includes involvement from several members of the Cabinet.

3. Increase employer engagement with a focus on engagement with minority-, women- and veteran-owned businesses. Indiana will target a 10% increase in employer engagement over the waiver period.

Recent growth towards this outcome is described in Strategic Goal #2, with a focus on Indiana’s effort with the Employer Training Grant during the Rapid Recovery initiative responding to workforce disruption brought on by the COVID-19 pandemic. DWD is currently engaged in a variety of initiatives to better measure employer satisfaction  

The Cabinet is also in the process of developing a high-level dashboard that will be used by policymakers, state leaders, and others as a resource to measure the state’s progress on a variety of top-level indicators across the education to workforce space. Examples include the postsecondary going rate, labor force participation, and median household earnings. Where specific goals do not currently exist, the Cabinet is actively working to outline goals for each of the indicators that will be included on the dashboard.

6. Individuals, groups, or populations benefiting, or otherwise impacted by the waiver:

The Cabinet drafted and submitted Indiana’s State Plan with effective strategies to reach WIOA target populations front of mind. The most recent plan modifications and updates represent lessons learned during the first waiver period. Waiver flexibility began and sustained this implementation and was especially critical amidst the challenges of the COVID-19 pandemic, which wrought disparate impacts on WIOA target populations throughout Indiana. A reauthorization of the waiver will allow for the continued execution of the state plan without interruption.

An example of a target population delineated in the state plan and better served through the flexibility provided by the waiver is ex-offenders. Indiana’s waiver flexibility provides representation to the Superintendent of the Department of Correction (DOC), a department critical to providing adult education, CTE, credential training, and job placement to very high-need target populations before reentry. In addition to in-facility Adult Education and CTE training, DOC’s Hoosier Initiative for Reentry (HIRE) program leverages state resources, SNAP/TANF assistance, and the Work Opportunity Tax Credit to train and then place offenders with employers.

Comparing this year’s progress with same period last year (January – April), DOC’s HIRE program has realized:

• 2021: Secured employment for 371 participants both before and immediately upon release involving 97 different businesses. The average hourly wages were $13.41; the majority of placements were in manufacturing.
• 2022: While the program has had fewer placements, it has realized higher average wages and greater employer engagement by securing employment for 285 individuals through 164 different businesses. The average hourly wages were $15.76; the majority of placements were again in manufacturing.

Other examples of DOC harnessing its Cabinet representation include utilizing Perkins funding for CTE equipment and machinery as well as ensuring released offenders are co-enrolled in supportive programs that remove barriers to employment and successful reentry, such as Medicaid and SNAP.

Another example are the nearly 30,000 Hoosiers without education beyond high school who completed a high-value credential through the Next Level Jobs Workforce Ready Grant program, as discussed under state strategic goal #3. The unique structure of membership on the Cabinet has allowed for the right stakeholders to be present to continuously refine and promote the Workforce Ready Grant to maximize its effectiveness in reaching Hoosiers.

The State Plan and information contained in the waiver highlight other populations that are being positively benefitted through the flexibility provided through Indiana’s waiver.

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

One of the functions of the Cabinet is to review, monitor, and recommend changes to the state's workforce system. As such, there will continually be an eye toward how Hoosiers are impacted by the policy decisions of the Cabinet and the programs implemented at both a state and local level.

The GWC membership structure enables leadership to keep a close eye on progress and act quickly to partner when needed. State Plan implementation continued to be overseen by GWC staff, in collaboration with operations staff from partner programs, such as DWD, FSSA/VR, etc.

GWC, in collaboration with partners under the Combined Plan, will track and report waiver progress and updates on an annual basis as required in the WIOA Annual Performance Narrative. DWD submits this narrative following its performance data submission each Fall.

8. Assurance of State posting of the request for public comment (including the dates that the state made the draft request available for public comment) and notification to affected local workforce development boards:

The last waiver request was included in the Cabinet’s State Plan process in 2020, which included vetting during by a Strategic Plan Review Committee and local meetings in all 12 workforce regions to discuss objectives in the State Plan and hear feedback from local partners.

This waiver request seeks to keep in place the Cabinet as the State Workforce Board for another 2 years, allowing the Cabinet to work alongside state agency partners to continue implementing the Combined WIOA plan. The request for an extension of the Waiver was discussed during the February 17, 2022, meeting of the Governor’s Workforce Cabinet. The state plan was then released for public comment from February 24 to March 25.

At the beginning of the public comment period, formal notice was provided via email to the Cabinet, local workforce boards, and other key stakeholders (CTE directors, Adult Education directors, etc.) to notify them of the 30-day public comment period. The process was also outlined on the homepage of the Governor’s Workforce Cabinet and the Department of Workforce Development with comments accepted through a publicly shared email, GWCpubliccomment@gov.IN.gov. After the closure of the period, the received public comments were carefully considered before this submission.

Upon receipt of the Waiver, formal notice will be sent to the Cabinet, local workforce boards, and other key stakeholders. A copy of the Waiver request and the Waiver will be available for review on the website of both the Governor’s Workforce Cabinet and the Department of Workforce Development. These will also be available for public inspection at the offices of the Governor’s Workforce Cabinet and the Indiana Department of Workforce Development.

 APPENDIX 1: Governor's Workforce Cabinet Membership*

The Cabinet does have several non-voting members who participate as members. These members are all state agency leaders or state legislative leaders who have optimum policy-making authority over their programs and departments. They work directly with Cabinet staff and the Governor’s Office on an ongoing basis to provide input and direction on decisions relating to their areas of oversight. All Cabinet members, whether voting or non-voting, have optimum policy-making authority, but staff is currently conducting a review under new leadership to determine if any replacements need to be made to ensure all stakeholders and interest groups are being represented with maximum effectiveness on the board.

The positions for the Governor’s Workforce Cabinet as outlined in Indiana code are shared below with current members denoted in parentheses.

1. A chairperson appointed by the Governor. (Ryan Kitchell)
2. The secretary of career connections and talent, serving as a nonvoting member. (This position is currently vacant) 
3. The commissioner of the department of workforce development. (Fred Payne, Commissioner of the Indiana Department of Workforce Development – includes Adult Education)
4. The secretary of commerce or the secretary of commerce’s designee, serving as a nonvoting member (Tony Denhart, Executive Vice President of Workforce and Talent at the Indiana Economic Development Corporation)  
5. The commissioner of the Indiana commission for higher education. (Chris Lowery, Indiana Commissioner for Higher Education)
6. The secretary of education (Dr. Katie Jenner, Indiana Secretary of Education)
7. The president of Ivy Tech Community College (Dr. Sue Ellspermann, President of Ivy Tech Community College)
8. The president of Vincennes University (Dr. Chuck Johnson, President of Vincennes University)
9. One (1) member representing a research university appointed by the governor (Anne Hazlett, Senior Director of Govt. Relations/Public Affairs at Purdue University)
10. One (1) member representing a comprehensive university or an independent college appointed by the governor. (Dr. Ronald Rochon, President of the University of Southern Indiana)
11. A member appointed by the governor who is an apprenticeship coordinator of a joint labor- management apprenticeship program approved by the United States Department of Labor, Employment and Training Administration, Office of Apprenticeship. (Mark Kara, Assistant to the Coordinator for Local 150 Operating Engineers)
12. A member representing high school career and technical education educators or directors appointed by the governor in consultation with the Indiana Association of Career and Technical Education Districts. (Dr. Steve Rogers, Director of Walker Career Center)
13. Either: (this position is currently vacant)
    1. A member representing manufacturing appointed by the governor in consultation with the Indiana Manufacturers Association; or
    2. An employee of the Indiana Manufacturers Association appointed by the Governor
14. A member representing a minority business enterprise appointed by the governor. (Maurice Coates, Jr., President of CK United)
15. A member representing a women's business enterprise appointed by the governor. (Megan Glover, CEO of 120WaterAudit)
16. A member representing a veteran owned business appointed by the governor. (Tony Vespa, Founder of Vespa Group)
17. A member representing the nonunion and construction trades appointed by the governor in consultation with the Associated Builders and Contractors, Inc., and the Indiana Builders Association. (This position is currently vacant)
18. Either:
    1. A business owner appointed by the governor in consultation with the Indiana Chamber of Commerce. (Paul Perkins, President of Amatrol, Inc.)
    2. An employee of the Indiana Chamber of Commerce appointed by the governor
19. A small business owner appointed by the governor in consultation with the National Federation of Independent Businesses. (this position is currently vacant)
20. A member of a community-based organization appointed by the governor. (Jena Bellezza, Indiana Parenting Institute)
21. Three (3) at-large business owners appointed by the governor, one (1) of whom is a business owner who employs less than fifty (50) employees. One (1) member appointed under this subsection shall be from an organization representing technology.

(Rebecca Schroeder, President of Whiteshire Hamroc)
(Megan Glover, CEO of 120WaterAudit)
(There is currently one vacancy for the 3^rd spot in this category)

22. A school principal, appointed by the governor (Jody French, Principal of Perry Central Jr./Sr. High School)
23. A school superintendent, appointed by the governor (Dr. Steve Thalheimer, Superintendent of Elkhart Community Schools)
24. The commissioner of the department of correction, serving as a nonvoting member. (Robert Carter, Indiana Department of Correction Commissioner)
25. The secretary of family and social services, serving as a nonvoting member. (Dr. Daniel Rusyniak, M.D., Secretary of Indiana Family and Social Services Administration – includes Vocational Rehabilitation)
26. A member of the house of representatives appointed by the speaker of the house of representatives who serves as a nonvoting member. (Representative Bob Behning, House Education Chair)
27. A member of the senate appointed by the president pro tempore of the senate who serves as a nonvoting member. (Senator Jeff Raatz, Senate Education and Career Development Chair)
28. Any additional members designated and appointed by the governor.

(Chris Lamothe, recently retired CEO of Elevate Ventures)
(Rebecca McCuaig, Legal Counsel for Accelerate Indiana Municipalities, a statewide non-partisan advocacy organization for Indiana municipalities)

1. The members appointed under subsection (a)(13) through (a)(21) must be geographically diverse.

WAIVER REQUEST 2 STATE OF INDIANA

Waiver of Governor's reserve and local formula youth funds on OSY for PY22 and PY23.

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

For PY22 and PY23:

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 an extension of the following waiver 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 meets 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.

Goals and expected programmatic outcomes of waiver

Because JAG Indiana serves students with significant barriers to graduation, approval of this waiver will allow Indiana to continue to invest in at-risk youth before they drop out of high school. When entering the program, approximately 40% of JAG Indiana students have low academic performance or are basic skills deficient.

JAG Indiana serves more than 3,500 in-school youth who are at risk for dropping out of high school in 125 school-based programs. JAG Indiana has proven outcomes with students graduating at a rate of over 93% (current data from December 2021), which remains higher than the 2021 state graduation rate of 86.7% for all students and 82.8% of those who receive Free/Reduced price meals. JAG Indiana and WIOA performance goals are aligned to achieve positive outcomes with a focus on attainment of a credential and placement in higher education or training, employment or military service.

School administrators and counselors refer students to the JAG Indiana programs because of the successful model and associated outcomes. This vulnerable population receives daily counseling and support by “Specialists” while delivering competency-based curriculum.  Central to the JAG model is a focus on serving the most disadvantaged youth in communities most in need across Indiana.  There is an inherent focus on diversity, equity and inclusion in our programming both in JAG and WIOA youth services, as enrollments across in-school and out-of-school youth lean into minority populations across multiple intersectionalities, including, but not limited to gender, race, sexual orientation and disability status.  Access to high quality programming, like JAG, for these students is of the utmost importance to their sense of belonging and identity which fuels their success in school, as showcased in overall programmatic outcomes on page 3.

JAG Indiana has been long supported by a multitude of funding streams, including WIA (now WIOA) and a state dropout prevention funding line item in the state’s biennium budget.  However, due to COVID-19, funding support for state programs was decreased by 15% just prior to the start of the 2020-21 school year and has continued in the 2021-22 school year.  Local Workforce Development Boards who operate JAG Indiana programs in their communities (over 90 different communities across the state) faced challenges in sustaining their long-successful programs which provide support to students most in need. 

Due to the budget constraints, nearly 600 students across the state were due to be impacted by potential program closures.  As they do, local WDB’s and the Department of Workforce Development looked for myriad ways to continue to provide services to our most at-risk youth through streamlining service delivery in partnership with other state agencies and community partners and an increase in the use of our prior WIOA waiver related to the 25% in-school limitation, with more regional partners taking advantage of the 50/50 split granted through our 2021 state plan waiver request.  At the onset of the 2020 program year and like prior program years, numerous WDB’s were on track to expend over 25% of their funds on the JAG Indiana in-school youth program, with the aid of the WIOA waiver; however, due to the impact of COVID-19 in schools these same WDB’s face continued funding challenges with increased demand for in-school related services for the 2021 program year.  As the 2020-21 school year began, Indiana, like most other states, was still in “lock-down” status with varying restrictions and re-opening plans in our school partners.  These restrictions created issues such as:

• Virtual or hybrid students having no access to high school elective courses, such as JAG, which lead to low enrollments; Indiana saw an overall 15% decrease in enrollments during the 2020-21 school year;
• Virtual and hybrid students were disengaged in classes, which can be seen in the decreased attendance in JAG classes; Indiana saw an overall decrease in student contact hours from prior average of 120 to 85 average hours during the 2020-21 school year;
   

Despite a sense of “return to normal” for the 2021-22 school year, the above metrics continue to be less than pre-COVID years.  JAG Indiana student average contact hours (as of December 2021) are projected to be 95 in May 2022 (up from 85 in prior school year).  Enrollment numbers have also continued to decrease and at this time are now trending upwards of 20% below pre-COVID enrollments; however, Indiana typically sees some enrollment growth (approximately 5%) during the 2^nd semester of January-May.

In line with the 2021 waiver request goals, specific goals of this 2022 waiver request are to:

Increase flexibility of WIOA Statewide Activities and formula funding to support:

• • The implementation of evidence-based programs and strategies;
  • Progress toward closing the economic inequity gap;
  • Placing more Hoosier youth on the path to high-wage skills; and
  • Increase college readiness.

All four of the above strategies can be met by continuing to serve and/or increase the number of high school youth served through the JAG Indiana dropout prevention program. This allows us to be proactive about addressing the out-of-school youth problem, while simultaneously increasing the number of youth who enter the workforce and/or post-secondary education with the skills to succeed in either goal.

Of the over 4,000 in-school JAG Indiana youth who were served last year, history shows that we could have expected 19% of them to drop out. Indiana’s graduation rate of 83% for low-income youth (which is 3% less than the prior school year), the number of in school youth who were saved from out-of-school status is estimated at nearly 700 youth through the implementation of the JAG Indiana program. Despite challenges due to COVID-19, which forced students to stay home and learn remotely and/or caused temporary and sometimes permanent job loss among Hoosier youth, in nearly every category students enrolled in the JAG Indiana program achieved results matching or exceeding its past outstanding outcomes for youth with barriers to success.  Outcomes include:

* For the Class of 2020, a new metric, Post-Secondary Outcomes were added, and Positive Outcomes were eliminated. 

**Data for the Class of 2021 is as of December 2021, which includes on 6 months of the follow-up period.

Although not all JAG Indiana students are co-enrolled into WIOA youth programming, nearly all in-school WIOA youth enrollments are JAG Indiana students.  Blended funding is vital to the success of co-enrolled students, opening a bevy of supportive services, training funds and more that supports the long-term success of these co-enrolled WIOA in-school youth students, which has been historically documented in Indiana’s successful attainment of WIOA performance measures, including employment, education or training placements, credential attainment, median earnings and measurable skills gains. 

As of the writing of this waiver request, quarterly youth performance ending December 31, 2021 demonstrates Indiana’s track record for success:

Alignment with U.S. Department of Labor (USDOL) Policy Priorities

This waiver request aligns with the following USDOL policy priorities, as found in the USDOL Fiscal Year 2018 – 2022 Strategic Plan and the WIOA law and federal regulations:

• • The USDOL Employment and Training Administration (ETA) has a strategic objective to create customer-focused workforce solutions for American workers, including development of a strong youth pipeline;
  • The ETA has prioritized improvement of the effectiveness and efficiency of workforce development programs, including supporting state and local flexibilities to enable these entities to effectively tailor their workforce strategies to meet their needs;
  • The ETA focuses on programs that support work-based learning, skills development, and work readiness while promoting training strategies that lead to credential attainment and closing the skills gap;
  • The ETA has prioritized implementation of evidence-based programs and strategies, including adoption of proven programs and strategies;
  • The WIOA places a strong emphasis on work experience for youth participants, requiring that 20 percent of WIOA Youth funding be expended on this element;
  • The WIOA promotes strong partnerships to leverage resources and increase opportunities for youth; and
  • The WIOA prioritizes participant success, as measured by skill gains, entry into and retention of employment
     

Quantifiable Projected Programmatic Outcomes Resulting from Implementation of the Waiver

As previously noted, Indiana’s high school graduation rate has stagnated at less than 90% for years.  While Indiana school counselors are over-burdened with increasing caseloads of students, averaging 532:1 (more than twice the recommended caseload), and growing administrative responsibilities, the State of Indiana is requesting increased flexibility of WIOA Statewide Activities funding to implement a statewide program focused on providing a comprehensive set of services designed to keep In-School Youth (ISY) attached to the education system to improve their rate of success in achieving educational and career goals.  The DWD has identified the Jobs for America’s Graduates program to be this solution in schools where it is most needed, given its previously described history of success and linkages to employers and community resources that will best benefit the students it serves. 

Following the JAG National performance outcome requirements, DWD and the JAG Indiana program, pledge to strive to meet the following requirements:

Additionally, in the classroom, the following outcomes serve as guideposts to student success while they are active in the program:

Individuals impacted by waiver

Currently, JAG Indiana utilizes a limited amount of WIOA funds to operate its in-school model. If Indiana is limited to 25% of WIOA youth funding to serve only in-school youth, DWD would be forced to close over 15 JAG Indiana programs across the state, potentially removing over 600 students from the dropout prevention program and negatively impacting local communities statewide.  As previously noted, due to COVID-19, the need for programming and services designed to assist students in graduating high school is more critical than ever, which has continued during the 2021-22 school year.  This waiver will ultimately impact Indiana’s at-risk young adult population. American Job Center and subcontracted service provider staff, workforce development partners, employers, parents, and school counselors will also benefit from the waiver.
 

Plans for Monitoring Implementation and Collecting Waiver Outcome Information

WIOA programmatic reviews will include an evaluation of how local waivers are being utilized to ensure programmatic goals and outcomes are being met. The regional Youth Directors and state staff dedicated to the administration of the WIOA Youth program will continually examine the effectiveness of waivers throughout the PY, including bi-annual desk reviews. This strategy ensures that the objectives described above, as well as those outlined in the existing state and local WIOA plans, are consistent with established objectives of the WIOA, and federal and state regulations.
 

Since 2006, the State has utilized an electronic case management system for all federal and state eligibility-based workforce investment programs. This system, Indiana Career Connect, is configured to support the full integration of programs, eligibility determination, service recording and tracking, and performance tracking for WIOA, TAA, Wagner-Peyser, Veterans Employment and Training Programs, and Reemployment Programs, as well as for local programs throughout the State, regardless of funding source. Indiana Career Connect has been designed to record service delivery information on every client service while providing transaction records necessary to document program performance. This cross-match of data allows DWD and Workforce Development Boards to effectively determine such outcomes as credential attainment, employment status and participant earnings in a more rapid timeframe than other mechanisms. DWD will monitor the progress of the waiver implementation through analysis of local performance results as well as through ongoing oversight and exchanges with local area management and staff.