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c. 1. Identify the State-developed criteria to be used by local boards in awarding grants or contracts for youth workforce investment activities and describe how the local boards will take into consideration the ability of the providers to meet performance accountability measures based on primary indicators of performance for the youth program as described in section 116(b)(2)(A)(ii) of WIOA.¹¹ Further, include a description of how the State assists local areas in determining whether to contract for services or to provide some or all of the program elements directly.

¹¹ Sec. 102(b)(2)(D)(i)(V)

Current Narrative:

The Indiana Department of Workforce Development (DWD) and local workforce development boards (LWDBs) recognize and adhere to 20 CFR § 681.400 to allow grant recipients/fiscal agents the option to directly provide some, or all, of the required youth workforce investment activities. When not directly providing services, the LWDB will award grants or contracts on a competitive basis to providers of youth workforce activities, while taking into consideration the ability of providers to meet performance accountability measures based on the primary indicators of performance for the WIOA Youth program, as described in the WIOA Section 116(b)(2)(A)(ii). The LWDB must also conduct oversight with respect to such providers. 

The State-developed criteria for local boards to consider when procuring youth providers are the following: 

  • Ability to deliver services to the targeted population in accordance with locally established guidelines; 

  • Experience in working with youth in similar programs and activities; 

  • Past and current collaboration with other service providers; 

  • Past performance record, including both programmatic and fiscal integrity; 

  • Understanding of and commitment to meeting goals and objectives; and 

  • Demonstration of understanding of and commitment to continuous improvement methods. 

As local boards make decisions about youth provider procurement and to award contracts and grants to providers, they must also: 

  • Identify youth service providers based on criteria established in the State Plan; 

  • Take into consideration the ability of the provider to meet performance accountability measures; 

  • Award such grants or contracts on a competitive basis and in accordance with the Procurement Stands found at Uniform Guidance at 2 CFR parts 200 and 2900; and 

  • If the service provider (entity) selected fulfills another role in the local area, the LWDB must comply with applicable conflict of interest, separation of duties, and firewalls requirements in relation to WIOA’s single entity/multiple role parameters. 

LWDBs must identify eligible providers of youth workforce investment activities in the local workforce development area by awarding grants or contracts on a competitive basis, based on the recommendation of the youth standing committee, if the local board chooses to establish a standing youth committee under 20 CFR Section 681.100; if no such youth committee exists, the LWDB then must assign a committee that function. Where the LWDB elects to award contracts but determines there is an insufficient number of eligible providers of youth workforce investment activities in the local area, (such as a rural area), the LWDB may award grants or contracts on a sole source basis. The LWDB committee must take into consideration the ability of providers to meet performance accountability measures based on the primary indicators of performance for the WIOA Youth program. 

Procurement of youth service providers must be in accordance with the Uniform Guidance at 2 CFR Parts 200 and 2900, in addition to applicable State and local procurement laws. Grantees and sub grantees must establish, maintain, and follow written procurement standards and procedures that are in compliance with all applicable federal, State, and local laws and regulations. 

Currently, local areas are able to set their own parameters for procurement of youth services, thus not all areas describe or request specific performance plans related to primary performance indicators in their Request for Proposal. However, some local areas list metrics of success to ensure providers meet or exceed goals, including pay for performance goals. Awards are then made to organizations possessing the demonstrated ability to perform. 

  • As determined by U.S. Department of Labor and DWD, performance goals include: 

    • Placement in employment, education, or training; 

    • Employment, education, or training retention; 

    • Median earnings; 

    • Credential rate; 

    • Attainment of degree or certificate; or 

    • Measurable skills gains 

    • Valid satisfactory record of past performance in delivering the proposed or similar services, including demonstrated quality of services and successful outcome rates from past programs (including non-WIA/WIOA programming) 

    • Ability to provide services that can lead to the achievement of competency standards for customers with identified barriers or deficiencies. 

For youth service provision, performance analysis will continue to focus on performance of required WIOA youth service performance and performance as outlined in JAG services. 

Youth service provision procurement will adhere to 20 CFR 681.400.