WIOA State Plan Common Elements

As outlined in Workforce Services Directive WSD17-01, all WIOA Title I-financially assisted programs and activities must be programmatically accessible. This includes providing reasonable accommodations for individuals with disabilities, making reasonable modifications to policies, practices, and procedures, administering programs in the most integrated setting appropriate, communicating with persons with disabilities as effectively as with others, and providing appropriate auxiliary aids or services, including assistive technology devices and services, where necessary to afford individuals with disabilities an equal opportunity to participate in, and enjoy the benefits of, the program or activity.

AJCC Certification Policy

The CWDB, in consultation with an AJCC Certification Workgroup comprised of state-level partners and Local Board representatives, developed objective criteria and procedures for Local Boards to use when certifying the AJCCs within their Local Area.

The WIOA outlines three key requirements for AJCC certification: effectiveness of the AJCC, physical and programmatic accessibility for individuals with disabilities, and continuous improvement. California’s certification process is centered on these key requirements and sets a statewide standard of service delivery that ensures all customers consistently receive a high-quality level of service.

California established two levels of AJCC certification: Baseline and Hallmarks of Excellence. In order to receive Baseline AJCC Certification an AJCC must ensure equal opportunity for individuals with disabilities in accordance with the ADA, WIOA Section 188, and all other applicable federal and state guidance. In order to receive the Hallmarks of Excellence AJCC Certification, AJCC’s must ensure universal access to services, with an emphasis on individuals with barriers to employment such as people with disabilities.

Staff Training and Capacity Building

At the local level, staff training in the Local Areas for nondiscrimination and equal opportunity is the responsibility of the Local Equal Opportunity (EO) Officers. Since the Department of Rehabilitation is a required partner at the comprehensive AJCCs, the Local Areas also can utilize their partnership as a resource. The EDD’s Equal Employment Office (EEO) also provides technical assistance for the Local Areas regarding questions of physical and programmatic accessibility.

At the state level, California utilized a portion of WIOA statewide funds to support the development of a California Training Model to build the capacity of the workforce system statewide. Local Boards within each RPU worked collaboratively to hire/designate a Regional Training Coordinator (RTC) to coordinate the implementation of the RPU’s Regional Training Plan. Each RPU participated in needs assessment for regional capacity building requirements and a comprehensive list of trainings, facilitations, and consulting services was developed as a result of the assessment.

In June 2018, California worked with each RTC to develop and begin to implement their Regional Training Plans. As part of the Regional Training Plans, the following disability related trainings were delivered throughout California:

• Disability Awareness and Sensitivity Training (e.g. disability etiquette and diversity training)
• Program Services (e.g. Americans with Disabilities Act of 1990 (ADA) basics, serving customers with disabilities)
• Employment (e.g. consumer self-disclosure of disability and related barriers, working with individuals with hidden disabilities)
• Digital/Electronic Access and Physical Access (e.g. principles of accessible documents, creating accessible forms)

Service Delivery

Local Boards, AJCCs, service providers, and local partners are actively engaged in improving and innovating their service delivery models to ensure they are improving service delivery models and outcomes for individuals with disabilities. Included below are a few examples of strategies that have been recently developed and implemented throughout the state:

• East Bay: utilizes an Employer Situational Assessment, which is a working interview led by a Job Coach, where both parties can assess the fit of the employer with the participant without making a commitment until they are satisfied with their placement. This practice has led to a strong retention rate of individuals with disabilities at the Local Board.
• Golden Sierra: conducts comprehensive assessments and provides pre-vocational training prior to placing participants in a work-based learning opportunity, which has helped reduce the drop-out rate and improve overall reemployment retention. Additionally, the Local Board facilitated in regular meeting with stakeholders to ensure a full range of employment services were available to eligible participants, and has dedicated a Business Engagement Team to help market participants to employers in high-growth industries.
• Humboldt: co-locates a WIOA Coordinator at Yuba Community College who conducts outreach to various departments at the college, and has a dedicated computer lab for the WIOA sponsored students to access. The WIOA Coordinator advocates for the student participants, and assists them in acquiring housing and transportation.
• Jewish Vocational Services (JVS) SoCal: partners with community colleges and non-profit agencies to place students and clients from other nonprofits into paid work experience, which helps to enhance the participant’s skills, confidence, and employability, and further aligns the community colleges and JVS SoCal for seamless service delivery.
• Managed Career Solutions (MCS): hosts quarterly Employability Partnership meetings, which includes sixteen disability coordinators from AJCCs in Los Angeles. At each meeting, a disability expert brings current information and training to the group. Additionally, MCS hosts an annual National Disability Employment Awareness Job and Research Fair each October, which connect potential workers with career opportunities.

The CWDB commits to continuing to work with our state partners to develop policies, trainings, tools, and other resources to assist front line AJCCs in providing high quality, individualized, and culturally competent services for people with disabilities.

Compliance Monitoring Review Process

In California, the EDD is responsible for the oversight and monitoring of all WIOA Title I financially assisted state programs, including the compliance with nondiscrimination and equal opportunity requirements. Consequently, the EDD’s EEO Office conducts annual onsite compliance monitoring reviews of all Local Areas following the process below.

The Compliance Monitoring Review Process includes the following six steps: notification, request for preliminary information, desk review, onsite compliance monitoring review, entrance conference, and exit conference.

1. Local Areas are notified approximately two to four weeks prior to EDD’s EEO Office conducting onsite compliance review. Notifications are sent to the Local Area Director/Administrator and the Local EO Officer.
2. The notification will include a request for preliminary information and include the Compliance Monitoring Guide that EDD EEO Office staff will use to conduct the compliance monitoring review.
3. Preliminary information will be reviewed prior to the onsite visit to help identify potential items to be addressed during the onsite compliance monitoring review.
4. The onsite monitoring review will determine compliance with the WIOA nondiscrimination and equal opportunity requirements.
5. EDD EEO Office staff will meet with Local Area Directors/Administrators to discuss the scope of the review, make arrangements for client and staff interviews or file reviews, and discuss preliminary findings of the data analysis.
6. Immediately following the completion of the onsite compliance monitoring review, EDD EEO Office staff will conduct exit conference with Local Area Directors/Administrators and/or the Local Area EO Officer to discuss findings and clarify areas in question.

Corrective Action Plan

If areas of non-compliance are found, a Corrective Action Plan (CAP), which consists of a list of specific steps that the Local Area will take within a specific time period in order to attain compliance, must be instituted to rectify accessibility issues. The CAP includes the following steps:

1. The EDD EEO Office will issue an initial written report within 30 days of completion of the onsite compliance monitoring review to the Local Area Director/Administrator and to the Local EO Officer, and address areas of non-compliance and outline those areas that are found to be in compliance.
2. When areas of non-compliance are found, the EDD EEO Office will make recommendation(s) for corrective action(s) in the initial written report.
3. If the Local Area Director/Administrator or Local EO Officer agree with the recommendation(s) of the EDD EEO Office, a CAP must be forwarded to the EDD EEO Office within 30 days of the date the Local Area received the recommendation(s).
4. If the Local Area Director/Administrator or Local EO Officer disagree with the EDD EEO Office recommendation(s), they may contact the EDD EEO Office to attempt an informal resolution of the issue(s).
5. When an informal resolution is reached, a CAP must be forwarded to the EDD EEO Office within 30 days of the date the Local Area accepts the recommendation(s).
6. If an informal resolution is not reached, the State EO Officer will meet with the Local EO Officer and the appropriate management official for the Local Area to develop recommendations to bring the Local Area into full compliance.
7. Six months after the recommendations are implemented, a follow-up review may be scheduled to assess the progress made by the Local Area resolving the identified areas of noncompliance.