Local Workforce Development Board Executive Directors Commission Executive Offices Integrated Service Area Managers

Transcription

1 TEXAS WORKFORCE COMMISSION LETTER ID/No: WD Date: March 14, 2017 Keyword: Vocational Rehabilitation; WIOA Effective: Immediately To: From: Subject: Local Workforce Development Board Executive Directors Commission Executive Offices Integrated Service Area Managers Reagan Miller, Deputy Director, Workforce Solutions Summer Earn and Learn for Students with Disabilities PURPOSE: To provide Local Workforce Development Boards (Boards) with information on: the Summer Earn and Learn initiative approved by the Texas Workforce Commission s (TWC) three-member Commission (Commission); and TWC s related purchase of employability skills training and paid work experience services from Boards. RESCISSIONS: None BACKGROUND: On January 31, 2017, the Commission approved TWC s use of $5.4 million in Vocational Rehabilitation (VR) funds to support the statewide implementation of Summer Earn and Learn. This was one of five strategies approved to support a VR Pathways to Careers initiative. The initiative focuses on the provision of preemployment transition services (Pre-ETS) to students with disabilities, as required under Title IV of the Workforce Investment and Opportunity Act (WIOA), also known as the Rehabilitation Act of 1973, as amended. WIOA Title IV requires TWC, as a VR agency, to reserve and expend 15 percent of its federal allotment to provide Pre-ETS to both eligible and potentially eligible students with disabilities, and places particular emphasis on the provision of work-based learning opportunities, such as paid work experience and internships. WIOA also requires VR agencies to conduct Pre-ETS coordination activities, including working with the Local Workforce Development Boards, one-stop centers, and employers to develop work opportunities for students with disabilities, including internships, summer employment, and other employment opportunities available throughout the school year.

2 Summer Earn and Learn is a statewide strategy that includes employability skills training and paid work experience for students with disabilities. It will be offered in each local workforce development area (workforce area) during the summer months, when students are out of school. Boards in Texas have an established history of providing employability skills and work experience to the populations they serve. In some workforce areas, the Texas VR program has benefited from that experience by including VR students in summer employment programs available through Boards and their workforce service providers. Expanding on that relationship, and consistent with the aforementioned WIOA requirements to work with Boards to develop work opportunities for students with disabilities, including summer employment, TWC engaged a sample of Boards through a work group to explore statewide purchase of a Summer Earn and Learn service package. TWC has further developed its initiative based on that input. This WD Letter supports implementation by describing TWC s service expectations as part of the purchase and how the contract terms will reflect those expectations. For Summer Earn and Learn, TWC VR will contract with each Board to purchase work readiness (employability skills) training, worksite identification, placement and monitoring, and payment of student wages and associated costs for Summer Earn and Learn students. Local VR staff will work in partnership with each Board to identify students, conduct outreach and recruitment, identify worksites, and provide additional services to the students as necessary for successful program completion. Under TWC s VR Summer Earn and Learn contracts, each Board will be a TWC contractor, as contractor is defined in the Office of Management and Budget Uniform Guidance, 2 CFR Contractor and Subrecipient and Contractor Determinations. TWC anticipates that Boards will engage in additional subcontracting. No subgrants will be awarded. The terms and conditions of the federal award prohibit subgranting of VR funds at any level. Summer Earn and Learn is an opportunity for Texas integrated workforce system to work collaboratively, building on partners expertise to increase the availability and effectiveness of services to Texas students with disabilities and to prepare them for a successful transition to postsecondary education and careers. PROCEDURES: No Local Flexibility (NLF): This rating indicates that Boards must comply with the federal and state laws, rules, policies, and required procedures set forth in this WD Letter and have no local flexibility in determining whether and/or how to comply. All information with an NLF rating is indicated by must or shall. Local Flexibility (LF): This rating indicates that Boards have local flexibility in determining whether and/or how to implement guidance or recommended WD Letter

3 practices set forth in this WD Letter. All information with an LF rating is indicated by may or recommend. Funding and Required Components N TWC will execute VR Pre-ETS service contracts with Boards in the amounts shown in Attachment 1, Summer Earn and Learn Contract Amounts. Successful performance under these VR service contracts will require Boards to develop work experience opportunities with employers in their workforce areas, pay for students wages during the work experience, and provide students with employability skills training as part of program participation. N Each Board must submit a description of its Summer Earn and Learn program services (program description) to TWC. (TWC will provide a template and TWC contact information for the submission.) The program description must: address how the Board will provide the TWC-purchased Summer Earn and Learn components at an average total cost per student of $2,500 to $3,000; and identify the single hourly wage that students will receive for the paid work experience component in the workforce area and include in the average total cost any other associated and necessary costs for the paid work experience component, such as worker s compensation insurance coverage. N In delivering the TWC-purchased services, Boards must be aware of the following: Paid work experience placement for each student must be for a minimum of five weeks. Work readiness training can occur before the students begin the work experience component or during the work experience component. The number of work experience hours per week for each student can vary based on employer needs and student availability. Boards may set an hourly wage rate for the paid work experience component that is consistent with or based on the hourly wage the Board uses for paid work experience under the WIOA Title I formula youth program. Boards may pay a training stipend to students for participation in the employability skills training component. N If a Board pays a stipend for the employability skills training component, it must describe the stipend and specify the total amount that will be paid to each student in the program description. Planning and Coordination N To support successful performance under the VR Pre-ETS Summer Earn and Learn service contracts, Boards must: WD Letter

4 coordinate with local VR contacts to jointly develop local processes for the referral of students, exchange of needed student documentation, handling of student needs, and other necessary procedures (Attachment 2, List of Vocational Rehabilitation Regional and Local Office Contacts by Local Workforce Development Area, lists the VR contacts for each Board); ensure that the Board s local processes support joint planning and ongoing coordination with the regional and local VR offices in each workforce area; identify one or more points of contact for Summer Earn and Learn and include that information in program descriptions; and provide the Board contact information to their designated workforce area VR contacts, as listed in Attachment 2. Boards may work with regional and local VR offices to establish a joint planning committee, team, or similar coordinating body, and to identify points of contact as needed to ensure orderly coordination and communication. Joint committees may also assist with the selection of candidates, particularly in workforce areas with more candidates than available slots. In the joint selection of candidates, Boards will describe available slots and work requirements while VR offices will consider the student s placement needs and fit with those work requirements. Boards are encouraged to consider doing the following as part of coordination efforts with local VR offices: Establish a team or planning committee; Develop outreach and recruitment materials and strategies, if necessary, to fill additional slots; Identify other partners and providers as appropriate and available in the workforce area; Determine a joint selection process, including identifying types of employment and appropriate worksite placements for students; Develop procedures for VR to refer customers to Boards and for Boards to refer customers to VR for data collection and eligibility determination; Work with VR staff to understand what information the Board must collect for VR case files and federal reporting, and develop processes for collection and submission; Identify employers who may be interested in participating; Develop processes for identification and resolution of issues that impede a student s successful participation; and Identify and provide necessary orientation and training for participating Board, contractor, and VR staff. Identification of Students, Outreach, and Recruitment N Boards must be aware that the VR Pre-ETS service contracts from TWC will support TWC VR s provision of the Summer Earn and Learn experience to approximately 2,000 students. WD Letter

5 N When developing outreach and recruitment materials and strategies, Boards must ensure that students meet the following criteria, as verified by local VR staff, before enrollment in the program: The student must be years of age and must be less than 22 years of age as of September 1, 2016; The student is eligible for and receiving special education or related services under the federal Individuals with Disabilities Education Act, or is an individual with a disability for purposes of 504 of the Rehabilitation Act; The student is in an educational program, including: secondary education; nontraditional or alternative secondary education programs, including home schooling; postsecondary education programs; and other recognized educational programs, such as those offered through the juvenile justice system. Note: Students who have completed secondary education and are under age 22 as of September 1, 2016, must be entering postsecondary education in fall 2017, or already be enrolled in postsecondary education and continuing in fall Boards are not responsible for, and must not make, eligibility determinations for VR Pre-ETS Summer Earn and Learn students. N Boards must be aware that candidates for Summer Earn and Learn may be current VR customers who have been determined eligible for VR services and who have an Individualized Plan for Employment. VR counselors in local offices will identify and refer current customers for Summer Earn and Learn as appropriate. N Boards must be aware that candidates for Summer Earn and Learn may also be potentially eligible students who have not applied for or been determined eligible for VR services. Potentially eligible students are still reportable individuals under WIOA Title IV, so local VR staff is required to gather sufficient documentation to meet requirements for federal reporting and verification of disability. N Boards must ensure that all necessary documentation as identified by local VR offices during planning and specified in local procedures is gathered and submitted to the VR counselor. N Boards must be aware that VR counselors in local VR offices will identify current VR customers who are candidates for Summer Earn and Learn; however, depending on the number of slots assigned to the workforce area, Boards must, when necessary, conduct outreach and recruitment to identify additional students to participate. WD Letter

6 While outreach and recruitment are among the services being purchased from Boards and for which Boards will be responsible, Boards are encouraged to work with the regional and local VR offices to develop the outreach materials and jointly plan and conduct outreach and recruitment of students as needed to fill the number of slots assigned to each workforce area. Boards may work with the regional and local VR offices, via planning committee or other arrangement, to develop processes to ensure effective referral of students and collection of necessary documentation. Eligibility Determinations N Boards must be aware that TWC s VR staff will conduct eligibility for VR customer participation. Boards must work closely with VR staff to ensure the collection of all necessary documentation as identified by local VR offices during planning and specified in local procedures for Summer Earn and Learn customers. VR staff will be responsible for entering the data into the VR case management system, ReHabWorks. Boards are not required to enter VR student data into TWIST. A Board may coenroll students and enter their information into TWIST if the Board decides to provide additional, non-vr services to students (any non-vr services must be funded through other sources available to the Board). Worksite Development and Recruitment N Boards must recruit employer participation and develop worksites for Summer Earn and Learn paid work experience placements. Boards, their contractor staff, and VR staff are encouraged to work together to identify employers that may be interested in participating in Summer Earn and Learn. VR staff may assist with recruiting employers in the workforce area that have hired VR customers or provided worksites for previous work experience activities. Additionally, VR staff may assist in identifying appropriate placements for each student as well as any accommodations needed by a student at a particular worksite. Boards are encouraged to develop work experience opportunities in high-growth, high-demand occupations, skilled trades, and crafts. Boards may identify employers in both the public and private sector. Monitoring and Oversight of Worksites N Boards must: place students at worksites, coordinating with local VR staff as appropriate to ensure that the worksite is an appropriate match for the student; conduct ongoing worksite monitoring to ensure that students are participating successfully in the program and that revisions are made as needed to address issues; and WD Letter

7 establish a point of contact for students to communicate any worksite placement concerns that arise. Boards may establish points of contact for students that are the same individuals as those established for planning and coordination purposes, or may identify other Board or Workforce Solutions Office staff specifically for resolution of worksite issues. Boards may coordinate with regional and local VR staff, including the student s VR counselor, to address concerns with worksite placement and make any necessary revisions to the placement at that worksite or another worksite, as appropriate. Additional Customer Supports N Boards must be aware that VR counselors will provide case management services for VR customers participating in Summer Earn and Learn. N Boards must be aware that VR counselors may purchase additional auxiliary aids and services and other supports as needed by the students to ensure their successful participation in Summer Earn and Learn, if the purchases are necessary, allowable, and appropriate uses of Pre-ETS or regular VR funds. Purchases may include, but are not limited to, the following: American Sign Language interpreters; Screen reader or screen magnification software; Assistive device and equipment; Work Experience trainers to provide on-site one-on-one or group training to ensure that the students receive needed training and meet the employer s expectations; and Transportation. These services and supports are not included in the VR Pre-ETS Summer Earn and Learn service contracts with Boards. Need for any such services and supports must be referred to VR counselors and funded by TWC VR using other VR funds. Depending on the support needed, a customer participating in Summer Earn and Learn as a potentially eligible student with a disability may be required to apply for and be determined eligible for VR services before the purchase of needed goods or services. Payments and Invoicing N Boards must request payment on a cost reimbursement basis. However, because Boards have limited or no unrestricted funds at the start of the contracts, TWC will provide a working capital advance to each Board in an amount equal to one month of expenses to ensure funds are available to support contract services. Boards must repay the working capital advance at the end of the contract, after TWC makes its final payment. WD Letter

8 N Boards must invoice TWC for each Summer Earn and Learn student, using an invoice template provided by TWC. The invoice will capture the number of hours the VR customer worked each week based on the Board s established hourly wage rate. Boards must submit student timesheets as supporting documentation for each invoice. Boards must ensure that the invoice also reflects any additional costs for Summer Earn and Learn components that were included in the Board s program description, such as costs associated with planning, coordination, outreach and recruitment, employability skills training, worksite monitoring, and allocable staff, facility, and indirect costs. N Boards must submit invoices weekly or biweekly. N Boards must be aware that TWC will provide the invoice template and additional submission instructions at a later date. INQUIRIES: Send inquiries regarding this WD Letter to wfpolicy.clarifications@twc.state.tx.us. ATTACHMENTS: Attachment 1: Summer Earn and Learn Contract Amounts Attachment 2: List of Vocational Rehabilitation Regional and Local Office Contacts by Local Workforce Development Area REFERENCES: 29 United States Code 733(d)(2) Workforce Innovation and Opportunity Act WD Letter