workforce innovation and opportunity act local service ... · the workforce innovation and...

Workforce Innovation and Opportunity Act

Local Service Delivery Guidelines

ii

Introduction

The Workforce Innovation and Opportunity Act’s primary service delivery tool is the one-

stop system. The one-stop system provides the eligible local population access to the federally

funded services of the required partners’ programs. The Act requires each Local Workforce

Development Area (LWDA) to establish, at a minimum, one comprehensive one-stop which

makes all the required partners’ programs available through either dedicated staff or direct

linkage during normal business hours.1 In addition to the comprehensive one-stop, LWDAs may

have affiliate service locations which provide access to one or more of the required partners’

programs. These affiliate sites and the comprehensive one-stop together make-up each LWDA’s

one-stop system.

In order to establish an organized and efficient local one-stop system, the Act requires

each LWDA’s leadership, composed of the Local Workforce Development Board, Chief Local

Elected Official, and required partner representatives, to enter into memorandums of

understanding (MOUs) which detail the service delivery strategy for the local one-stop system.

These local MOUs are meant to detail how the service strategy outlined in the LWDA’s Local Plan

is funded and carried out. The Act and its implementing regulations set forth minimum

requirements for these local MOUs and require the state agency administering Title I-B of the Act

to provide guidance on certain required components of the MOU. These Local Service Delivery

Guidelines are the Georgia Department of Economic Development Workforce Division’s

collaborative effort, with other required partner programs, to satisfy the federal mandate to guide

and assist local service delivery negotiations which will end in the signing of comprehensive, local

MOUs.

The Local Service Delivery Guidelines are meant to provide clear, succinct guidelines to

assist a LWDA’s leadership in developing a complete and compliant MOU which will govern its

local one-stop system. Due to the diverse governance structures existing in Georgia’s nineteen

LWDAs, the Local Service Delivery Guidelines do not include MOU templates which, due to their

generality, would lack sufficient detail to be applicable to all LWDAs.

1 See Appendix A regarding federal presence requirements for required partner programs.

iii

Table of Contents

Section I. Negotiation Procedure ..................................................................................................... 1

Section II. Infrastructure Costs ...................................................................................................... 4

Section III. Other Shared Costs .......................................................................................................7

Section IV: Memorandum of Understanding ................................................................................. 9

Section V. Timelines ...................................................................................................................... 15

Section VI. Reporting Requirements ............................................................................................. 17

Section VII. Appeals ....................................................................................................................... 18

Appendix A ..................................................................................................................................... 19

Appendix B ..................................................................................................................................... 21

Appendix C .................................................................................................................................... 25

Appendix D ................................................................................................................................... 28

Appendix E .................................................................................................................................... 29

Appendix F ..................................................................................................................................... 31

Appendix G ................................................................................................................................... 32

Appendix H ................................................................................................................................... 33

1

Section I. Negotiation Procedure

What is the Negotiation Process?

Each Local Workforce Development Area (LWDA) will be required to schedule meetings,

which must include representatives from the Local Workforce Development Board (LWDB) and

each of the required partner programs, to negotiate service delivery and funding contributions.

These parties will be responsible for reaching agreement on a functional service delivery system

which fits the strategy set forth in the LWDA’s Local Plan and which will be detailed and

memorialized in the local memorandum of understanding (MOU). When complete, the MOU will

detail all aspects of the LWDA’s service delivery system and the methods for funding the system.

The guiding principles for the local negotiation process are integrated service delivery, cost

sharing, and transparency. In order for the local meetings to be beneficial to all parties, it is

paramount that all parties dedicate time to reviewing the applicable regulatory guidance.

What are the requirements for a Negotiation Meeting Roster?

In order to ensure the correct individuals are present at the meetings, a roster must be

created by each LWDA. All individuals named on the roster must be present for all negotiations

and their attendance must be documented in the minutes taken at each meeting. Each of the

twelve required partner programs must have a representative named on the roster who is

authorized to make financial and service delivery commitments on its agency’s behalf. In some

LWDAs, a required partner program may require more than one representative if the financial

and budget authority rests with one individual and programmatic service delivery authority with

another. In addition to the required partner program representatives, LWDBs must appoint a

representative to attend the negotiations. (Please note that the LWDB representative assigned to

this group will be in addition to the LWDA director who will be the group member representing

the Workforce Innovation and Opportunity Act (WIOA) Title I-B programs.) Each LWDA’s roster

must have an individual for each of the following programs, in addition to the LWDB member:

1. Programs authorized under WIOA Title I-B;

Adult, Dislocated Worker, Youth, Job Corps., Youthbuild, Native American

Programs, and Migrant Seasonal Farmworker Programs

2. Programs authorized under the Wagner-Peyser Act (29 U.S.C. 49 et seq.);

3. Adult education and literacy activities authorized under Title II;

4. Programs authorized under Title I of the Rehabilitation Act of 1973 (29 U.S.C. 720 et

seq.) (other than section 112 or part C of Title I of such Act (29 U.S.C. 732, 741);

5. Activities authorized under Title V of the Older Americans Act of 1965 (42 U.S.C. 3056

et seq.);

Senior Community Service Employment Programs

2

6. Career and technical education programs at the postsecondary level authorized under

the Carl D. Perkins Career and Technical Education Act of 2006 (20 U.S.C. 2301 et

seq.);

7. Activities authorized under chapter 2 of Title II of the Trade Act of 1974 (19 U.S.C. 2271

et seq.);

8. Activities authorized under chapter 41 of title 38, United States Code;

Jobs for Veterans State Grants Programs

9. Employment and training activities carried out under the Community Services Block

Grant Act (42 U.S.C. 9901 et seq.);

10. Employment and training activities carried out by the Department of Housing and

Urban Development;

11. Programs authorized under State unemployment compensation laws (in accordance

with applicable Federal law); and,

12. Programs authorized under section 212 of the Second Chance Act of 2007 (42 U.S.C.

17532).

The individuals representing the twelve programs above are to be referred to as the required

partners. In the event one of the above listed programs is not provided within a LWDA, the

LWDA’s MOU must state that the program is not present.

Each LWDA must also designate a group leader on its roster who will serve as the primary

convener. LWDA group leaders should not be interested parties. Therefore, business

representatives, who sit on the LWDB, make ideal group leader candidates whereas required

partners, who are interested parties, do not. Another option could be to procure a consultant who

can perform the required group leader duties. Please note that if a consultant is procured, all

applicable procurement requirements must be complied with. To ensure a non-interested

individual is designated the group leader, each LWDA must notify WFD of its proposed group

leader in accordance with the deadlines set forth in Section V: Timelines. WFD shall either

approve the designation or request the LWDA designate another individual in a timely manner.

Generally, the group leader will need to oversee the creation of the roster, schedule the group’s

meetings in accordance with the mandated meeting dates, ensure meeting minutes are

documented, and ensure that all required documentation is disseminated to the roster’s members

in a timely manner.

The LWDB members may assist the LWDB business person if the negotiations group uses

a LWDB business person as their group leader. The LWDA, meaning the fiscal agent and/or

programmatic administrative staff, may also assist the LWDB business person in performing

administrative, clerical, and scheduling duties. If the fiscal agent and/or programmatic

administrative staff are WIOA Title-I funded and represent WIOA Title I programs as a required

partner, their assistance to the LWDB business person must be made known to the other members

of the negotiation.

3

What documents must be gathered and distributed prior to the initial meeting?

In addition to creating a roster listing all of the required partner programs’

representatives, each LWDA must gather and distribute the following critical documents to all of

the representatives prior to the initial meeting:

1. Comprehensive list identifying all affiliate and comprehensive one-stop sites within the

LWDA. If the comprehensive one-stop site is yet to be determined by the LWDB, all

market research and supporting documentation which has been undertaken by the LWDA

to determine where the comprehensive one-stop will be located should be included. Please

note that if a current Georgia Department of Labor Career Center may or will be used as

the comprehensive one-stop, the negotiations group must be notified.

2. Infrastructure Budget for operating each physical service delivery site (affiliates and

comprehensive one-stops) within the LWDA’s boundaries for the past program year (July

1, 2015-June 30, 2016).

After identifying all required partners on the roster and circulating all of the documents

listed above to each of those individuals, the group leader must schedule the meetings in

accordance with the mandated meeting dates. Utilizing the contact information provided by each

of the individuals included on the roster, the group leader must contact each representative and

schedule meeting times in accordance with the mandated meeting schedule which will enable all

representatives to attend. Due to the importance of these meetings, WFD highly recommends all

meetings be conducted in-person and discourages conference line attendance. All required

representatives must attend each of the meetings. In order to facilitate a timely conclusion to the

negotiations, a timeline with deadlines is included in Section V: Timelines. Each LWDA must

comply with the deadlines set forth in Section V: Timelines.

What specific Negotiation Guidance do the State-Administered Required Partners

have for LWDAs?

Each required partner whose program is state-administered, must provide general

negotiation guidance for LWDAs pertaining to that required partner’s specific negotiation

requirements and preferences. These guidelines are located in Appendix H. Included in the

guidelines are specific points of contact for each of the state-administered required partner

programs and a mandated meeting schedule which will facilitate the state-administered required

partner programs’ representatives attendance at the negotiations meetings.

4

Section II. Infrastructure Costs

How are required partner contributions determined and what funds may be used

for contributions?

One of the goals of the negotiations is to reach agreement between all required partners

on the funding of the local one-stop system’s infrastructure costs. WIOA requires every LWDA to

reach agreement on a local funding mechanism which will determine how infrastructure costs

associated with the local one-stop delivery system will be shared amongst the required partners.

Each LWDA must establish, at a minimum, one comprehensive one-stop facility which

must provide the services of all required partner programs present in the LWDA. The

infrastructure funding mechanism will determine the required partner programs’ financial

contributions to the comprehensive one-stop’s infrastructure. Importantly, all required partner

programs “must use a portion of the funds available for the program and activities to maintain

the one-stop delivery system, including payment of the infrastructure costs of one-stop centers,

[and] these payments must be in accordance with [WIOA regulations]; Federal cost principles,

which require that all costs must be allowable, reasonable, necessary, and allocable to the

program; and all other applicable legal requirements.”2

What costs are included as Infrastructure Costs?

Per federal regulations, “infrastructure costs of one-stop centers are nonpersonnel costs

that are necessary for the general operation of the one-stop center [and] include:

1. Rental of the facilities;

2. Utilities and maintenance;

3. Equipment (including assessment-related products and assistive technology for

individuals with disabilities); and

4. Technology to facilitate access to the one-stop center, including technology used for

the center's planning and outreach activities.”3

Additionally, LWDBs “may consider common identifier costs as costs of one-stop infrastructure.”4

In the event the LWDB includes common identifier costs (i.e. signage) as infrastructure costs, the

initial meeting minutes shall indicate that common identifier costs are to be treated as

infrastructure costs and the resulting comprehensive one-stop budget shall account for common

identifier costs.

What is an Infrastructure Funding Agreement?

The infrastructure funding agreement is a required component of the local service delivery

MOU and must be developed by the required partner program representatives and the LWDB.

Utilizing the documents listed in Section I: Negotiation Procedure, the negotiations meeting

220 C.F.R. §678.700(c) 3 20 C.F.R. §678.700(a) 420 C.F.R. §678.700(b)

5

group will be able to review each required program’s past infrastructure costs within the LWDA

and review the past or proposed infrastructure costs associated with the comprehensive one-stop

location and affiliate sites. At the conclusion of local infrastructure negotiations, each LWDA must

agree upon an infrastructure budget for the comprehensive one-stop(s) and affiliate sites or notify

WFD of its failure to reach agreement. Any notification to WFD must be made by the deadline

identified in Section V: Timelines, using the form provided in Appendix B.

MOU negotiations and the funding of “other shared costs” must meet the deadlines set

forth in Section V: Timelines. The Employment and Training Administration within the United

States Department of Labor (ETA) recently released a FAQ document which provides a six month

extension for reaching final agreement on the infrastructure funding agreement, a required

component of the MOU.5 While WFD recommends reaching final agreement on infrastructure

costs by May 12, 2017, if agreement regarding infrastructure costs cannot be finalized by that

deadline, then the parties will continue to meet to develop and implement an interim

infrastructure agreement.6

A separate timeline is provided in Section V: Timelines which sets forth the deadlines for

LWDAs who fail to reach final agreement on infrastructure funding and instead choose to

implement an interim infrastructure funding mechanism. The use of an interim infrastructure

funding formula developed at the local-level will allow LWDAs to essentially “try-out” a funding

mechanism for its comprehensive one-stop(s) for up to three months at which point the required

reconciliation will allow the LWDA to determine whether the interim infrastructure agreement or

a modified version of that agreement will be implemented as a “final” infrastructure funding

mechanism. In the event that LWDAs cannot reach agreement on a final infrastructure

agreement, the LWDA will notify WFD using the form provided in Appendix C and in accordance

with the deadlines set forth in Section V: Timelines, and WFD will apply the State Infrastructure

Funding Mechanism.

How does a LWDA conduct an infrastructure budget meeting?

In an effort to provide additional assistance to the local infrastructure budget negotiation

process, a step-by-step breakdown of how the meetings should be conducted and decisions

reached is provided below. Please note that this is only one way to conduct the negotiations and

this process may need to be adjusted due to local governance structures.

Step 1: Follow the steps set forth in Section I of the Local Service Delivery

Guidelines. Specifically, create a roster, designate a group leader (such as a

LWDB business representative) to serve as the convener, coordinate and

notify the members of the mandated meeting dates, and circulate all

required documents.

Step 2: The group leader presents the current or proposed comprehensive one-

stop infrastructure budget. Ideally, this infrastructure budget has been

reviewed prior to the meeting to ensure it only includes those items which

5 20 C.F.R. §678.715(c) 6 See Question 2 on page 2 of “Workforce Innovation and Opportunity Act (WIOA) One-Stop Infrastructure Costs – FAQs” (https://www.doleta.gov/wioa/docs/FAQs-Infrastructure-Funding-Guidance-Dec-27-2016.pdf )(Cited January 11, 2017)

6

federal regulations allow to be factored into the shared comprehensive

one-stop infrastructure budget.

Step 3: Using past infrastructure budgets of the required partner programs, the

group will begin drafting a proposed infrastructure budget for the

comprehensive one-stop for the next program year (July 1, 2017 – June 30,

2018)7. Sample methodologies for determining required partner programs’

fair and equitable contribution to the comprehensive one-stop’s

infrastructure are provided in Appendix F. It is the required partner

program representatives’ responsibilities to notify the group of any

funding restrictions its program’s enabling act, or its implementing

regulations.8

Step 4: At the conclusion of the first meeting, the proposed draft budget will be

circulated and reviewed as needed prior to the second meeting.

Step 5: Through follow-up meetings, all revisions will be reviewed and

incorporated and all comments addressed. By the deadline set forth in

Section V: Timelines, a final budget must be prepared for the LWDB’s and

Chief Local Elected Official’s (CLEO) review and approval. All revisions

made by the LWDB or CLEO should be reviewed by the required partners.

7 Note extensions announced in the December 27, 2016, “Workforce Innovation and Opportunity Act (WIOA) One-Stop Infrastructure Costs – FAQs” (Link: https://www.doleta.gov/wioa/docs/FAQs-Infrastructure-Funding-Guidance-Dec-27-2016.pdf) 8 20 C.F.R. § 678.720

7

Section III. Other Shared Costs

What are “Other Shared Costs?”

In addition to sharing infrastructure costs, WIOA also requires that the one-stop partners

share in the payment of “other shared costs.” Specifically, federal regulations provide that “one-

stop partners must use a portion of funds under their programs’ authorizing Federal law (or fairly

evaluated in-kind contributions) to pay additional costs relating to the operation of the one-stop

delivery system.”9 Unfortunately, the term “other shared cost” is not explicitly defined within

WIOA or its regulations. Rather, final regulations identify specific items which must be included

as components of “other shared costs.” Specifically, “other shared costs” “must include applicable

career services.”10 The applicable career services are the basic career services listed in 20 C.F.R.

§678.430(a). Generally, career services are split into three categories: basic career services,

individualized career services, and follow-up services. TEGL 10-16, released December 19, 2016,

includes tables in Attachment 7 that list many of the items and services which ETA consider career

services. 11 It is important to note that career services do not include training services.

Career services are the only cost that must be included in “other shared costs.” However,

federal regulations provide additional guidance on types of costs that may be included in “other

shared costs.” Shared services’ costs “may include the costs of shared services that are authorized

for and may be commonly provided through the one-stop partner programs to any individual.”12

It is important to note that these voluntary “other shared costs” may be split between some, but

not all of the one-stop partners.

How can “Other Shared Costs” be funded?

Federal regulations permit “other shared costs” to be funded through cash, non-cash, or third-

party-in-kind contributions.13 Each of these funding methods are further defined in federal

regulations.14 However, any and all cost sharing must be:

1. Allocated in accordance to the proportionate benefit received by each of the partners;

2. Consistent with the Federal law authorizing the partner’s program; and,

3. Consistent with all other applicable legal requirements, including 2 C.F.R. § 200.15

What Restrictions are on “Other Shared Costs”?

As previously mentioned, “other shared costs” must be funded in accordance with federal

uniform administrative requirements which, among other things, require the allocation to be

proportionate and relative to the benefit received.16 Furthermore, the costs must be allowable,

reasonable, necessary, and allocable to the partner program.17 Additionally, WFD recommends

that LWDAs reconcile “other shared costs” quarterly to ensure that a partner is not over or under

paying its proportionate share.

9 20 C.F.R. § 678.760 10 20 C.F.R. § 678.430; 20 C.F.R. § 678.760(a) 11 https://wdr.doleta.gov/directives/attach/TEGL/TEGL_10-16.pdf (cited 1/3/2017) 12 20 C.F.R. § 678.760(b) 13 20 C.F.R. § 678.760(c) 14 20 C.F.R. § 678.720 15 20 C.F.R. § 678.760(d) 16 2 C.F.R. § 200 17 2 C.F.R. § 200

https://wdr.doleta.gov/directives/attach/TEGL/TEGL_10-16.pdf

8

What Methodologies can be used to Proportion “other shared costs?”

WFD will not mandate a particular methodology for allocating “other shared costs.” Instead,

WFD wants to provide LWDAs with as much flexibility as possible to choose a methodology or

methodologies best suited among the partners who are required to contribute to the shared costs.

WFD understands that multiple methodologies may be required when determining how to

allocate cost. However, all methodologies must comply with the federal uniform administrative

requirements18 and other governing cost limitations. WFD provides the following examples of

methodologies that may prove helpful to LWDAs in allocating costs. Please note that other

methodologies may exist which are not identified herein.

1. Square footage: Using this methodology, costs would be allocated by determining the

percentage of square footage a particular partner occupies across the total square footage

of the one-stop center and or one-stop delivery system and then multiplying that

percentage by the total cost at issue. If this methodology is utilized, partners must ensure

that costs are allocated in accordance with relative benefit received. This methodology may

prove difficult to apply where services are being provided via direct linkage.

2. Usage: Using this methodology, costs would be allocated by determining the applicable

percentage that each partner uses a particular service. For example, if there are five

partners within the system, and each partner utilizes the service equally, then costs will be

equally allocated. Alternatively, if five partners utilize a service, with one partner using

80% of the service, then that partner’s proportionate contribution must reflect the 80%

usage and the four other partners would be responsible for the remaining 20%. This

methodology inherently ensures that each partner is paying in accordance with relative

benefit received. Unfortunately, this methodology may not work for every cost as it

assumes that it is possible to quantify the overall usage percentage of each partner. The

recommended quarterly reconciliations would resolve any disproportionate allocation.

3. Full-time Employees: Using this methodology, costs would be allocated based on the

number of full-time employees a partner dedicates to providing services through the one-

stop center (either physically or through direct linkage).

4. Hybrid Approaches: A combination of more than one methodology may prove

beneficial.

Where are “Other Shared Costs” documented?

Any agreed upon “other shared costs” must be included in the MOU. Appendix G

references an excel spreadsheet which provides a general template that LWDAs may use to

identify shared costs. If a LWDA uses the appendix, it should be incorporated into the MOU.

18 2 C.F.R. § 200

9

Section IV: Memorandum of Understanding

What is the MOU?

WIOA requires that each LWDB, with the agreement of the CLEO, develop and enter into

a MOU amongst the LWDB and all one-stop partners. The purpose of the MOU is to define the

roles and responsibilities of each partner as mutually agreed upon, relating to the operation of the

one-stop delivery system within the LWDA. In essence, the MOU is the contractual document

that memorializes how the one-stop partners will jointly fund and operate the one-stop delivery

system.

WIOA permits the LWDB and CLEO to enter into separate agreements with each one-stop

partner. Using such an approach, there could be numerous separate agreements for how costs are

shared and services are delivered for a particular one-stop delivery system. Additionally,

negotiating separate agreements for each one-stop partner may prove time consuming and would

serve to limit full and open negotiation amongst the one-stop partners. Alternatively, WIOA

permits, and WFD recommends, that LWDAs create a single “umbrella” MOU which will facilitate

a full and transparent negotiation process.

Within the “umbrella” MOU, the required partners and LWDA leadership will agree on an

area wide service delivery strategy and infrastructure funding for the comprehensive one-stop(s).

Service delivery strategies and cost sharing for additional service delivery locations (i.e. affiliate

sites) should be addressed in appendices or addendums to the MOU.19 This approach will enable

LWDAs to maintain focus on establishing and funding their comprehensive one-stop location-s)

while still addressing area-wide service delivery. This approach also allows flexibility in terms of

updating and amending cost sharing and service delivery issues that may arise at a particular

location, but do not impact the workforce delivery system as a whole.

Who are the parties to the MOU?

The MOU must contain the signatures of the LWDB chair, all one-stop partners, and the

CLEO.

How should the MOU be negotiated?

Neither WIOA nor its regulations dictate which entity writes the MOU, but emphasize that

it must be a product of local discussion and negotiation among the LWDB, CLEO, and the one-

stop partners. WFD requires that all parties to the negotiations follow the negotiation procedures

outlined in this guidance and the applicable federal regulations governing MOU negotiations.20

Importantly, all MOU negotiations must be undertaken in good-faith and required partners must

establish how they will fund infrastructure and other shared costs as both of which are required

components of the MOU (see Sections II and III of this guidance). Keep in mind that the parties

must document the negotiation process as they must comply with the reporting requirements

identified in Section VI of this guidance.

19 Affiliate sites negotiations should only be between those required partner programs that provide services at the affiliate site and are only required where more than one required partner is providing services at the location. 20 20 C.F.R. §§ 678.500

10

What is included in the MOU?

Pursuant to WIOA § 121 and applicable federal regulations,21 the MOU must, at a

minimum, contain the following required provisions. WFD has included the additional

content/considerations portion to identify additional issues that the parties should consider while

negotiating and drafting the MOU. Please note that this list only identifies required provisions.

The parties to the MOU may choose to require additional items not identified herein.

Required Provisions and Additional Content/Considerations of the Memorandum

of Understanding Required MOU Provisions Additional Content/Considerations

Descriptions of the services to be provided through the one-stop delivery system, including the manner in which the services will be coordinated and delivered. WIOA Sec. 121(c)(2)(A)(i)/ § 678.500(b)(1)

Detail the purpose/goals of the one-stop system.

Identify all partners included in the MOU.

Describe the one-stop system design.

Identify system customers.

Detail each required partner’s available services.

Describe the roles and responsibilities of each partner.

Identify the comprehensive one-stop location(s).

Expectations around operations or protocols to be used during times of emergencies or disasters that affect normal/routine operations.

Describe the role of the one-stop operator in accordance with § 678.620. Such description should at a minimum identify how the one-stop operator will coordinate service delivery of the required one-stop partners and service providers. Such description may also include additional roles, such as coordinating service delivery across the system, being the primary provider of services within the center, or coordinating service delivery in a multi-center area, which may include affiliate sites. § 678.620.

The one-stop operator may not undertake any of the functions identified in §678.620(b) unless the operator also serves a different role within the one-stop delivery system, and sufficient firewalls and conflict of interest policies exist in accordance with § 679.430.

21 20 C.F.R. § 678.500(b) and 20 C.F.R. § 678.755

11



Agreement on funding the costs of the services and the operating costs of the system. This must include a plan for funding the shared service costs of one-stop centers and the one-stop delivery system. Additionally, either a final infrastructure funding agreement or an interim infrastructure funding agreement must be included. WIOA Sec. 121(c)(2)(A)(ii)/ § 678.500(b)(2)

Include a commitment to share system operating costs.

Include an assurance that costs will be based on proportionate use and agreed upon methodology.

Describe the methods for referring individuals among partners for appropriate services and activities. WIOA Sec. 121(c)(2)(A)(iii)/ § 678.500(b)(3)

Describe the one-stop system referral process.

Describe commitment to ensuring high quality customer service and customer-centered design.

Identify how the one-stop system will provide direct access to partners.

Detail customer flow of service.

Describe methods to ensure that the needs of workers, youth, and individuals with barriers to employment, including individuals with disabilities, are addressed in providing access to services, including access to technology and materials that are available through the one-stop delivery system. WIOA Sec. 121(c)(2)(A)(iv)/ §678.500(b)(4)

Define individuals with barriers to employment and describe how the one-stop system will ensure access and priority for services to individuals with barriers to employment.

Include a commitment to WIOA veteran’s priority of service.

Include a commitment by the partners to share data and technology.

Identify measures and internal controls applied to ensure system security.

Include a commitment to comply with the confidentiality provisions of the respective statutes of the one-stop partners.

Include a commitment that the partners and locations will comply with ADA physical and programmatic access requirements.

Describe the one-stop system grievance procedures.

Describe how the one-stop system will comply with non-discrimination and equal opportunity requirements.

12



Define the duration of the MOU and the procedures for its amendments during the duration of the memorandum. WIOA Sec. 121(c)(2)(A)(v)/ §678.500(b)(5)

Identify the effective dates of the MOU.

Describe the procedures established to revise and modify the MOU.

Describe the procedures established to terminate the MOU.

The MOU should also contain language to periodically reconcile shared costs to ensure that they are being accurately proportioned. WFD requires reconciliation to occur at least quarterly.

The MOU should contain language that the parties will agree to adhere to the State Infrastructure Funding Mechanism in the event that the parties are unable to reach agreement on required cost sharing for future years.

The MOU should contain language stating that if a one-stop partner appeals any application of the State Infrastructure Funding Mechanism outcomes using the appeal process identified in Appendix E, the MOU will be updated to reflect the final one-stop system partner contributions.

Describe the assurances that such memorandum shall be reviewed not less than once every 3-year period to ensure appropriate funding and delivery of services. WIOA Sec. 121(c)(2)(A)(v)/ §678.500(b)(5)

The period of time in which this infrastructure funding agreement is effective. This may be a different time period than the duration of the MOU. § 678.755(a) Identification of an infrastructure and shared services budget that will be periodically reconciled against actual costs incurred and adjusted accordingly to ensure that it reflects a cost allocation methodology that demonstrates how infrastructure costs are charged to each partner in proportion to its use of the one-stop center and relative benefit received, and that complies with 2 C.F.R. part 200 (or any corresponding similar regulation or ruling). § 678.755(b)

It is important to note here that there may be multiple distinct infrastructure funding agreements for each comprehensive one-stop as well as any affiliate sites that contain more than one partner. Accordingly, WFD recommends that each location that requires the sharing of infrastructure or other costs be addressed in an attachment to the MOU.

13



Identification of all one-stop partners, chief elected officials, and Local WDB participating in the infrastructure funding arrangement. § 678.755(c) Steps the Local WDB, chief elected officials, and one-stop partners used to reach consensus or an assurance that the local area followed the guidance for the State funding process. § 678.755(d)

Description of the process to be used among partners to resolve issues during the MOU duration period when consensus cannot be reached. § 678.755(e)

The parties to the MOU should develop and agree upon a dispute resolution process for any disagreements that may arise during the MOU term. Such options for this process may include the submission of disputes to a neutral partner or a third-party mediator/arbiter.

Description of the periodic modification and review process to ensure equitable benefit among one-stop partners. § 678.755(f)

In LWDAs where entities perform multiple functions, internal controls preventing conflicts of interest must be detailed.

“Local organizations often function simultaneously in a variety of roles, including local fiscal agent, Local WDB staff, one-stop operator, and direct provider of services. Any organization that has been selected or otherwise designated to perform more than one of these functions must develop a written agreement with the LWDB and CLEO to clarify how the organization will carry out its responsibilities while demonstrating compliance with WIOA and corresponding regulations, relevant Office of Management and Budget circulars, and the State's conflict of interest policy.”

§679.430

As service delivery will be detailed in the MOU, WFD recommends that, in those LWDAs where one entity performs multiple functions, the LWDA sets forth its internal controls for ensuring conflicts of interest are prevented. This could be included as an attachment to the MOU or in the MOU.

14

As previously stated, WFD strongly recommends the use of an “umbrella” MOU used to

address issues that are applicable to the entire one-stop delivery system and then using individual

attachments or schedules to address issues that only exist for certain of the required locations.

Within the main body of the “MOU,” WFD recommends that the parties also address general

boilerplate contractual provisions. Such provisions may include, but are not limited to:

Recommended Provisions of the Memorandum of

Understanding Recommended MOU Provisions Additional Content/Considerations

Insurance Requirements Address any insurance requirements that may exist

Assignment Provision Explain how to handle assignment of contractual duties

Applicable record retention provision Identify applicable federal, state and local retention requirements

Compliance with law provision Include general language representing that each party to the MOU agrees to comply with all applicable laws

Force Majeure Include language excusing performance due to an act of God or other extraordinary circumstance or event

Billing & Payment Provisions Include language establishing process for how billing and payments will be handled.

Indemnification Provisions This may not be applicable as State & Local Governments are generally prohibited from entering into indemnification agreements. However, the parties may require non-governmental entities to enter into such a provision

Notice Provisions Identify primary points of contact for notices.

15

Section V. Timelines

The timeline for required activities in program year 2016 (July 1, 2016- June 30, 2017)

and each subsequent program year is summarized in the following table.

Activities For All Years In Which An MOU Is Negotiated

Annual Deadline

Notify WFD of Proposed Negotiations Group Leader and provide short description of individual’s current role within the LWDA’s workforce system

March 10

First local negotiations meeting is conducted. All required documents are to be circulated at least five (5) business days prior to the first meeting.

March 17

Final local negotiations meeting is conducted. April 28

Required Outcome Reports are provided to WFD. LWDAs unable to reach consensus must provide all required materials listed in Section II. Those LWDAs unable to reach agreement regarding local infrastructure funding mechanism must continue meeting to create an Interim Infrastructure Funding Agreement. The Interim Infrastructure Funding Agreement is governed by the deadlines set forth in the Interim Infrastructure Funding Agreement Timeline on the next page of this guidance.

May 12

For LWDAs failing to reach agreement on an MOU (excluding failure to reach agreement on a Local Infrastructure Funding Mechanism), WFD works with LWDA leadership and required partner program representatives to reach consensus.

May 15 through May 26

MOU must be executed by all required parties (Required partners, CLEO, LWDB Chair). MOU must include Interim Infrastructure Funding Mechanism if a Local Infrastructure Funding Mechanism was not agreed upon by the LWDA.

June 30

Comprehensive One-Stop becomes operational and provides access to all required partner programs present within the LWDA.

July 1

Activities For LWDAs that Do Not Reach Agreement on a Local Infrastructure

Funding Mechanism PY 16 and PY 17 Deadlines

Required Outcomes Report due to WFD in which LWDA identifies its failure to reach agreement on a Local Infrastructure Funding Mechanism.

May 12

Negotiations Group continues to meet to reach agreement on an Interim Infrastructure Funding Mechanism.

May 12 through June 15

16

Interim Infrastructure Funding Mechanism provided to CLEO and LWDB for review and approval.

June 16

Interim Infrastructure Funding Mechanism is in effect.

July 1 through September 30

Interim Infrastructure Funding Mechanism incorporated into the final MOU and goes into effect.

July 1

Required Partners meet and, through cost reconciliations, determine whether Interim Infrastructure Funding Mechanism works and will become the Final Local Infrastructure Funding Mechanism. If not, LWDAs must continue to try and reach a Final Infrastructure Funding Mechanism.

October 1 through October 30

LWDA must notify WFD, using form provided in Appendix C, whether a Final Local Infrastructure Funding Mechanism has been agreed upon.

October 31

If Required Partners cannot reach agreement on a Final Local Infrastructure Funding Mechanism, the State Infrastructure Funding Mechanism will be used to determine Required Partners infrastructure contributions.

November 17

Any Required Partner’s appeal of the apportionment determined through the application of the State Infrastructure Funding Mechanism must be provided to WFD with required supporting documentation. Appeal procedure is detailed in Section VII: Appeals.

November 30

17

Section VI. Reporting Requirements

How is Notice provided to WFD?

LWDAs have an obligation to report to the Governor (WFD) whether they are able to reach

consensus on a MOU (including the infrastructure costs and required “other shared costs”

portions).22 LWDAs must use the form in Appendix B to provide the required notice to WFD no

later than May 12, 2017. In the event that the required partners are unable to reach agreement,

then Appendix B requires the LWDA to identify those issues that the required partners are unable

to agree upon and submit documents listed in Appendix D. If the only component of the MOU

which cannot be agreed upon is the Local Infrastructure Funding Mechanism, the required

partners shall continue meeting to develop an Interim Infrastructure Funding Mechanism which

will go into effect July 1.23 Notice of the outcome of the Interim Infrastructure Funding

Mechanism must be provided to WFD by October 31, after the completion of a cost reconciliation,

using the form provided in Appendix C. If the infrastructure funding mechanism is not finalized

by the deadlines set forth in Section V: Timelines, the LWDA must notify WFD.

What Documents Must be provided to WFD if MOU Negotiations Fail?

For those LWDAs unable to reach agreement in their MOU, Appendix B requires the

LWDA to provide to WFD certain documentation, which is also listed in Appendix D, in addition

to their notification letter. Such documentation includes:

1. LWDA Local Plan;

2. Proposed Cost Allocation Methodologies;

3. Proposed Infrastructure Budget;

4. Total Required Partner Funds included in the Budget;

5. Type of Funds or Non-Cash Contributions to be Contributed by Each Required Partner;

6. Proposed One-Stop Budget;

7. MOU(s) (including any partially complete MOUs);

8. Summary of the Negotiations; and,

9. Meeting Minutes from All the Negotiation Meetings.

2220 C.F.R. § 678.725 2320 C.F.R. § 678.715(c)

18

Section VII. Appeals

Federal regulations mandate the inclusion of an appeals process for required partners to use

in certain, limited situations. In those LWDAs where local infrastructure negotiations reach an

impasse and the State Infrastructure Funding Mechanism is applied, an appeals process is

available to required partners. An Appeals Form is included in Appendix E which must be

completed and submitted by any required partner wishing to appeal an infrastructure funding

decision. The required partners may only appeal the State Infrastructure Funding Mechanism

apportionment on three grounds.24 These three grounds are if “the Governor’s determination is

inconsistent with:

1. Proportionate share requirements [set forth] in §678.735(a);

2. Cost contribution limitations [set forth] in §678.735(b); [or],

3. Cost contribution caps [set forth] in §678.738.”25

Any appeal by a required partner of the apportionment determined through the use of the

State Infrastructure Funding Mechanism must be filed with WFD by the deadline set forth in

Section V: Timeline using the Appeals Form at Appendix E. In the event a required partner files a

timely appeal, WFD shall determine the merit of the appeal. If the appeal is meritorious, WFD

will convene the State Workforce Development Board’s (SWDB) Executive Committee to review

the appeal and modify the State Infrastructure Funding Mechanism to account for the issue(s)

identified in the appeal. The SWDB Executive Committee’s review of the appeal and modification

of the State Infrastructure Funding Mechanism shall be concluded no later than sixty (60) days

from December 1, 2017.

24 20 C.F.R. §678.750 25 20 C.F.R. §678.750(b)

19

Appendix A

Comprehensive One-Stop Presence Requirement for all Required Partner

Programs

The requirements detailed below are a directly copied from Section 678.305 of Title 20 with

emphasis added.

A comprehensive one-stop center is a physical location where job seeker and employer customers

can access the programs, services, and activities of all required one-stop partners. A

comprehensive one-stop center must have at least one title I staff person physically

present.

The comprehensive one-stop center must provide:

1. Career services, described in §678.430;

2. Access to training services described in §680.200 of this chapter;

3. Access to any employment and training activities carried out under sec. 134(d) of WIOA;

4. Access to programs and activities carried out by one-stop partners listed in §§678.400

through 678.410, including the Employment Service program authorized under the

Wagner-Peyser Act, as amended by WIOA title III (Wagner-Peyser Act Employment

Service program); and,

5. Workforce and labor market information.

Customers must have access to these programs, services, and activities during

regular business days at a comprehensive one-stop center. The Local Workforce

Development Board (WDB) may establish other service hours at other times to accommodate the

schedules of individuals who work on regular business days. The State WDB will evaluate the

hours of access to service as part of the evaluation of effectiveness in the one-stop certification

process described in §678.800(b).

“Access” to each partner program and its services means:

1. Having a program staff member physically present at the one-stop center;

2. Having a staff member from a different partner program physically present at the one-

stop center appropriately trained to provide information to customers about the

programs, services, and activities available through partner programs; or,

3. Making available a direct linkage through technology to program staff who can

provide meaningful information or services.

o A “direct linkage” means providing direct connection at the one-stop center, within

a reasonable time, by phone or through a real-time Web-based communication to a

20

program staff member who can provide program information or services to the

customer.

o A “direct linkage” cannot exclusively be providing a phone number or

computer Web site or providing information, pamphlets, or materials.

All comprehensive one-stop centers must be physically and programmatically accessible to

individuals with disabilities, as described in 29 C.F.R. part 38, the implementing regulations of

WIOA Sec. 188.

21

Appendix B

Notification to Governor of Result of MOU Negotiations

Local Workforce Development Area:

In accordance with § 678.725, LWDA___ hereby notifies the Governor concerning the results of

its MOU negotiations. If the LWDA failed to reach agreement in its MOU negotiations

(notwithstanding agreement on the local infrastructure funding mechanism component of the

MOU), the LWDA shall include the documents listed in Appendix D.

Notice is hereby provided that the LWDA reached agreement as to the MOU (including the

local infrastructure funding mechanism component of the MOU) for PY ____;

OR

Notice is hereby provided that despite good-faith efforts, the LWDA failed to reach

agreement on an MOU (notwithstanding agreement on the local infrastructure funding

mechanism component of the MOU) for PY ____.

Failure to reach agreement on the MOU:

The LWDA failed to reach agreement on the MOU for the following reasons:

Disputed Issue Impacted Partner (Identify by Program)

Failure to reach agreement on required cost sharing component of the MOU:

The required partners failed to reach agreement on required cost sharing for the

following reasons:

22


Signatures:

__________________________ ____________________________

Local Workforce Development Board Chief Local Elected Official

Chair

Required Partner Signatures:

One-Stop Partner

Programs authorized under WIOA Title I-B

(Adult, Dislocated Worker, Youth, Job

Corps., Youthbuild, Native American

Programs, and Migrant Seasonal

Farmworker Programs);

One-Stop Partner

Programs authorized under the Wagner-Peyser Act (29 U.S.C. 49 et seq.);

One-Stop Partner

Adult education and literacy activities authorized under Title II;

23

One-Stop Partner

Programs authorized under title I of the Rehabilitation Act of 1973 (29 U.S.C. 720 et seq.) (other than section 112 or part C of Title I of such Act (29 U.S.C. 732, 741);

One-Stop Partner

Activities authorized under Title V of the Older Americans Act of 1965 (42 U.S.C. 3056 et seq.); (Senior Community Service Employment Programs)

One-Stop Partner

Career and technical education programs at the postsecondary level authorized under the Carl D. Perkins Career and Technical Education Act of 2006 (20 U.S.C. 2301 et seq.)

One-Stop Partner

Activities authorized under chapter 2 of Title II of the Trade Act of 1974 (19 U.S.C. 2271 et seq.)

One-Stop Partner

Activities authorized under chapter 41 of Title 38, United States Code (Jobs for Veterans State Grants Programs)

One-Stop Partner

Employment and training activities carried out under the Community Services Block Grant Act (42 U.S.C. 9901 et seq.)

One-Stop Partner

Employment and training activities carried out by the Department of Housing and Urban Development

One-Stop Partner

Programs authorized under State unemployment compensation laws (in accordance with applicable Federal law)

24

One-Stop Partner

Programs authorized under section 212 of the Second Chance Act of 2007 (42 U.S.C. 17532)

One-Stop Partner

Additional Program Included as a Required Partner, if applicable

25

Appendix C

Failure to reach agreement on infrastructure funding methodology:

Local Workforce Development Area:

LWDA___ hereby notifies the Governor concerning the results of its infrastructure funding

methodology component of its MOU negotiations. If the LWDA failed to reach agreement on the

infrastructure funding methodology component of its MOU after utilizing an interim

infrastructure funding methodology, the LWDA shall include the documents listed in Appendix

D.

The required partners failed to reach agreement on a local infrastructure funding

methodology for the following reasons:


26

Signatures:

__________________________ ____________________________

Local Workforce Development Board Chief Local Elected Official

Chair

Required Partner Signatures:

One-Stop Partner


(Adult, Dislocated Worker, Youth, Job

Corps., Youthbuild, Native American

Programs, and Migrant Seasonal

Farmworker Programs);

One-Stop Partner

Programs authorized under the Wagner-Peyser Act (29 U.S.C. 49 et seq.);

One-Stop Partner

Adult education and literacy activities authorized under Title II;

One-Stop Partner

Programs authorized under title I of the Rehabilitation Act of 1973 (29 U.S.C. 720 et seq.) (other than section 112 or part C of Title I of such Act (29 U.S.C. 732, 741);

One-Stop Partner

Activities authorized under Title V of the Older Americans Act of 1965 (42 U.S.C. 3056 et seq.); (Senior Community Service Employment Programs)

One-Stop Partner

Career and technical education programs at the postsecondary level authorized under the Carl D. Perkins Career and Technical Education Act of 2006 (20 U.S.C. 2301 et seq.)

27

One-Stop Partner

Activities authorized under chapter 2 of Title II of the Trade Act of 1974 (19 U.S.C. 2271 et seq.)

One-Stop Partner

Activities authorized under chapter 41 of Title 38, United States Code (Jobs for Veterans State Grants Programs)

One-Stop Partner

Employment and training activities carried out under the Community Services Block Grant Act (42 U.S.C. 9901 et seq.)

One-Stop Partner

Employment and training activities carried out by the Department of Housing and Urban Development

One-Stop Partner

Programs authorized under State unemployment compensation laws (in accordance with applicable Federal law)

One-Stop Partner

Programs authorized under section 212 of the Second Chance Act of 2007 (42 U.S.C. 17532)

One-Stop Partner

Additional Program Included as a Required Partner, if applicable

28

Appendix D

Required Documentation when Negotiations Fail

When submitting the above-referenced Notification, the LWDA must also supply the

Governor with the following documents if MOU negotiations fail:

1. LWDA Local Plan;

2. Proposed Cost Allocation Methodologies;

3. Proposed Infrastructure Budget;

4. Total Required Partner Funds included in the Budget;

5. Type of Funds or Non-Cash Contributions to be Contributed by Each Required Partner;

6. Proposed One-Stop Budget;

7. MOU(s) (including any partially complete MOUs);

8. Summary of the Negotiations;

9. Meeting Minutes from all the Negotiation Meetings; and,

10. All other documents the LWDA may deem relevant, and a clear explanation of why the

documents are relevant.

29

Appendix E

Required Partner Appeal Form

In the event local infrastructure negotiations fail and the State Infrastructure Mechanism

is utilized to determine the required partners’ infrastructure funding contributions, required

partners may appeal the application of the State Infrastructure Mechanism on certain limited

grounds.

By completing and submitting this Appeal Form in compliance with the filing deadlines

set forth in Section V: Timelines, the required partner must identify the required partner program

which he/she represents from the list below and the grounds upon which their appeal is based.

List of Required Partner Programs

(Please check the box beside the program you represent)


Adult, Dislocated Worker, and Youth,

If Job Corps., Youthbuild, Native American Programs, or Migrant Seasonal

Farmworker Programs, please state which one below:

_______________________________________________________

Programs authorized under the Wagner-Peyser Act (29 U.S.C. 49 et seq.)

Adult education and literacy activities authorized under Title II

Programs authorized under Title I of the Rehabilitation Act of 1973 (29 U.S.C. 720 et

seq.) (other than section 112 or part C of Title I of such Act (29 U.S.C. 732, 741)

Activities authorized under Title V of the Older Americans Act of 1965 (42 U.S.C. 3056

et seq.); Senior Community Service Employment Programs

Career and technical education programs at the postsecondary level authorized under

the Carl D. Perkins Career and Technical Education Act of 2006 (20 U.S.C. 2301 et

seq.)

Activities authorized under chapter 2 of Title II of the Trade Act of 1974 (19 U.S.C. 2271

et seq.)

Activities authorized under chapter 41 of Title 38, United States Code; Jobs for

Veterans State Grants Programs

Employment and training activities carried out under the Community Services Block

Grant Act (42 U.S.C. 9901 et seq.)

30

Employment and training activities carried out by the Department of Housing and

Urban Development

Programs authorized under State unemployment compensation laws (in accordance

with applicable Federal law)

Programs authorized under section 212 of the Second Chance Act of 2007 (42 U.S.C.

17532)

List of Grounds for Appeal

(Please check the box beside the ground your appeal is based upon)

The appeal may be made on the ground that the Governor's determination is inconsistent with

either:

Proportionate share requirements in §678.735(a);

Cost contribution limitations in §678.735(b); or,

Cost contribution caps in §678.738.

31

Appendix F

What Methodologies may be used to Allocate Costs?

WFD will not mandate a particular methodology for allocating either infrastructure or other shared costs. Instead, WFD wants to provide LWDAs with as much flexibility as possible to choose a methodology or methodologies best suited among the partners who are required to contribute to the shared costs. WFD understands that multiple methodologies may be required when determining how to allocate costs. However, all methodologies must comply with the

requirements of 2 C.F.R. § 200 and other governing cost limitations. WFD provides the following examples of methodologies that may prove helpful to LWDAs in allocating costs. Please note that other methodologies may exist which are not identified herein.

WFD cautions LWDAs to ensure that any methodology selected appropriately allocates costs based on the benefit received by each of the partners including those physically co-located as well as those who provide services via direct linkage. For example, methodologies based on a physical presence may under-value the benefit received by partners providing presence via direct linkage. Alternatively, methodologies that include the usage of an employee breakroom or other employee benefits may apply costs to the direct linkage partners when no benefit is received. The presence of both physical and direct linkage partners may require the use of multiple methodologies or multiple budgets (e.g. one methodology/budget for physically co-located partners and a separate methodology/budget that includes direct linkage partners) to ensure allocations are based on benefits received.

1. Square footage- using this methodology, costs would be allocated by determining the percentage of square footage a particular partner occupies across the total square footage of the one-stop center and or one-stop delivery system and then multiplying that percentage by the total cost at issue. If this methodology is utilized, partners must ensure

that costs are allocated in accordance with relative benefit received. This methodology may prove difficult to apply where services are being provided via direct linkage.

2. Usage-using this methodology, costs would be allocated by determining the applicable percentage that each partner uses a particular service. For example, if there are five partners within the system, and each partner utilizes the service equally, then costs will be equally allocated. Alternatively, if five partners utilize a service, with one partner using 80% of the service, then that partner’s proportionate contribution must reflect the 80% usage and the four other partners would be responsible for the remaining 20%. This methodology inherently ensures that each partner is paying in accordance with relative

benefit received. Unfortunately, this methodology may not work for every cost as it assumes that it is possible to quantify the overall usage percentage of each partner. The recommended quarterly reconciliations would resolve any disproportionate allocation.

3. Full-time Employees- using this methodology, costs would be allocated based on the number of full-time employees a partner dedicates to providing services through the one-stop center (either physically or through direct linkage).

4. Hybrid Approaches- a combination of more than one methodology may prove beneficial.

32

Appendix G

See excel spreadsheet titled, “Cost Sharing Chart”

33

Appendix H

Required Partner program-specific negotiation guidance documents

Georgia Department of Labor

State Administrator for the following Required Partner Programs:

1. Programs authorized under WIOA Title I-B;

ONLY the Migrant Seasonal Farmworker Programs

2. Programs authorized under the Wagner-Peyser Act (29 U.S.C. 49 et seq.);

3. Activities authorized under chapter 2 of Title II of the Trade Act of 1974 (19 U.S.C. 2271 et

seq.);

4. Activities authorized under chapter 41 of title 38, United States Code; and,

Jobs for Veterans State Grants Programs

5. Programs authorized under State unemployment compensation laws (in accordance with

applicable Federal law).

The points of contact for each Local Workforce Development Area are as follows:

Local

Representative GDOL Finance Representative

GDOL Service Delivery Representative

LWDA 1 Julie Turner Max Wightman Kristin Laarhoven

LWDA 2 Greg Pitts Max Wightman Kristin Laarhoven

LWDA 3 Lee Hunter Max Wightman Kristin Laarhoven

LWDA 4 Melrobin Cothran Max Wightman Kristin Laarhoven

LWDA 5 Elizabeth Scott Max Wightman Kristin Laarhoven

LWDA 6 Tabatha Burks Max Wightman Kristin Laarhoven

LWDA 7 Mark Connally Max Wightman Kristin Laarhoven

LWDA 8 William Futrell Max Wightman Kristin Laarhoven

LWDA 9 Phyllis Winfrey Max Wightman Kristin Laarhoven

LWDA 10 Tishua Green Max Wightman Kristin Laarhoven

LWDA 11 Bob Thompson Max Wightman Kristin Laarhoven

LWDA 12 Lori Chafin Max Wightman Kristin Laarhoven

LWDA 13 Kermit Sears Max Wightman Kristin Laarhoven

LWDA 14 Judy Bryson Max Wightman Kristin Laarhoven

LWDA 15 John Shaw Max Wightman Kristin Laarhoven

LWDA 16 Patsy Carr Max Wightman Kristin Laarhoven

LWDA 17 Sandra Clayton Max Wightman Kristin Laarhoven

LWDA 18 William Palmer Max Wightman Kristin Laarhoven

LWDA 20 Jennifer Bradley Max Wightman Kristin Laarhoven

34

Technical College System of Georgia


1. Adult education and literacy activities authorized under Title II; and,

2. Career and technical education programs at the postsecondary level authorized under the

Carl D. Perkins Career and Technical Education Act of 2006 (20 U.S.C. 2301 et seq.).

The points of contact for each Local Workforce Development Area for Career and technical

education programs at the postsecondary level authorized under the Carl D. Perkins Career and

Technical Education Act of 2006 are as follows:

TCSG College TCSG- Carl

Perkins Representative

Email Address

LWDA 1 Georgia Northwestern Stuart Phillips [email protected]

LWDA 2 North Georgia Dr. Kathie Ivester [email protected]

LWDA 2 Lanier Tim McDonald [email protected]

LWDA 3 Atlanta Dr. Victoria Seals [email protected]

LWDA 4 Chattahoochee Catrice Hufstetler [email protected]

LWDA 5 Georgia Piedmont Dr. Ivan Harrell [email protected]

LWDA 6 Atlanta Dr. Victoria Seals [email protected]

LWDA 7 Gwinnett David Welden [email protected]

LWDA 8 Southern Crescent Dr. Mark Andrews [email protected]

LWDA 8 West Georgia Dr. Tonya Whitlock [email protected]

LWDA 9 Athens Caroline Angelo [email protected]

LWDA 10 Central Georgia Deborah Burks [email protected]

LWDA 11 Central Georgia Deborah Burks [email protected]

LWDA 12 Augusta Dr. Lisa Palmer [email protected]

LWDA 13 Oconee Fall Line Erica Harden [email protected]

LWDA 14 Columbus Jamie Lloyd [email protected]

LWDA 15 South Georgia Karen Werling [email protected]

LWDA 16 Southeastern Dr. Barry Dotson [email protected]

LWDA 17 Southern Regional Dr. Craig Wentworth [email protected]

LWDA 18 Wiregrass Georgia Angela Hobby [email protected]

LWDA 20 Savannah Dr. Kathy Love [email protected]

LWDA 20 Ogeechee Dr. Ryan Foley [email protected]

mailto:[email protected]





















35

The points of contact for each Local Workforce Development Area for Adult education and literacy

activities authorized under Title II are as follows:

TCSG Representative Adult Ed. Local Recipient Email Address

LWDA 1 Bobby Creech TBD May 19, 2017 [email protected]



















mailto:Creech,%20Bobby%20%[email protected]%3e



















36

Georgia Vocational Rehabilitation Agency


1. Programs authorized under Title I of the Rehabilitation Act of 1973 (29 U.S.C. 720 et seq.)

(other than section 112 or part C of Title I of such Act (29 U.S.C. 732, 741)

The points of contact for each Local Workforce Development Area are as follows:

Local Representative GVRA

Representative

GVRA Legal

Representative

LWDA 1 Paul Ray Minerva Nixon Crystal Perry

LWDA 2 Mary Ellen Mendiratta Minerva Nixon Crystal Perry

LWDA 3 Theora Powell Minerva Nixon Crystal Perry

LWDA 4 Valerie Carter Minerva Nixon Crystal Perry

LWDA 5 Cheryl Gosier Minerva Nixon Crystal Perry

LWDA 6 Aimee Williams Minerva Nixon Crystal Perry

LWDA 7 Crystal Perry Minerva Nixon Crystal Perry

LWDA 8 Jason Williams Minerva Nixon Crystal Perry

LWDA 9 Dixie Morris Minerva Nixon Crystal Perry

LWDA 10 Charles Wells Minerva Nixon Crystal Perry

LWDA 11 Anita Coney Minerva Nixon Crystal Perry

LWDA 12 Carmella Jennings Minerva Nixon Crystal Perry

LWDA 13 Carmella Jennings Minerva Nixon Crystal Perry

LWDA 14 Doreene Carlisle Minerva Nixon Crystal Perry

LWDA 15 Doreene Carlisle Minerva Nixon Crystal Perry

LWDA 16 Mary Beth Falk Minerva Nixon Crystal Perry

LWDA 17 Cathy Manuel Minerva Nixon Crystal Perry

LWDA 18 Renee Giedl Minerva Nixon Crystal Perry

LWDA 20 Candace Mims Minerva Nixon Crystal Perry

37

February 2017

◄ January 2017 February 2017 March 2017 ►

Sun Mon Tue Wed Thu Fri Sat

1

2

3

4

5

6

7

8

9 State Workforce Development Board Meeting/ Infrastructure Guidance is Approved

10 Infrastructure Guidance distributed by WFD to LWDAs

11

12

13 State Partners Meeting about State Funding Formula

14

15

16

17 Round 1 Agency Prep Meetings

18

19

20

21

22

23 Round 1 Thomson (LWDA 13) & Augusta (LWDA 12)

24 Round 1 ARC (LWDA 7) & Agency Prep Meetings

25

26

27 Round 1 Macon (LWDA 10) & Middle GA (LWDA 11)

28 Round 1 Cobb (LWDA 4)

Notes: X Round 1 X Round 2 X Additional Rounds X Unavailable Day

http://www.wincalendar.com/Holiday-Calendar/January-2017

http://www.wincalendar.com/Holiday-Calendar/March-2017

38

March 2017

◄ February 2017 March 2017 April 2017 ►


1 Round 1 Columbus (LWDA 14) & Middle Flint (LWDA 15)

2 Round 1 DeKalb (LWDA 5)


4

5

6 Round 1 Northeast Georgia-Athens (LWDA 9) & Georgia Mountains-Gainesville (LWDA 2)

7 Round 1 Northwest Georgia-Rome (LWDA 1)

8 Round 1 Atlanta (LWDA 3) & Fulton (LWDA 6)

9 Round 1 Three Rivers- Griffin (LWDA 8)


11

12

13 Round 1 Heart of Georgia (LWDA 16)

14 Round 1 Coastal-Savannah (LWDA 20)

15 Round 1 Southern Georgia-Valdosta (LWDA 18)

16 Round 1 Southwest Georgia-Albany (LWDA 17)

17 Round 1 Due Date

18

19 SETA Conference

20 SETA Conference

21 SETA Conference

22 SETA Conference

23


25

26

27 Round 2 Thomson (LWDA 13) & Augusta (LWDA 12)

28 Round 2 ARC (LWDA 7)

29 Round 2 Macon (LWDA 10) & Middle GA (LWDA 11)

30 Round 2 Cobb (LWDA 4)



http://www.wincalendar.com/Holiday-Calendar/February-2017

http://www.wincalendar.com/Holiday-Calendar/April-2017

39

April 2017

◄ March 2017 April 2017 May 2017 ►


1

2

3 Round 2 Columbus (LWDA 14) & Middle Flint (LWDA 15)

4 Round 2 DeKalb (LWDA 5)

5 Additional

Round Schedule conference calls with LWDAs that need an additional round (if needed).

6 Round 2 Northeast Georgia-Athens (LWDA 9) & Georgia Mountains-Gainesville (LWDA 2)


8

9

10 Round 2 Northwest Georgia-Rome (LWDA 1)

11 Round 2 Atlanta (LWDA 3)

12 Round 2 Fulton (LWDA 6)

13 Round 2 Three Rivers-Griffin (LWDA 8)


15

16

17 Round 2 Heart of Georgia (LWDA 16)

18 Round 2 Coastal-Savannah (LWDA 20)

19 Round 2 Southern Georgia-Valdosta (LWDA 18)

20 Round 2 Southwest Georgia-Albany (LWDA 17)


22

23

24 State Holiday

25 Additional


26 Additional


27 Additional


28 Final Round Due Date

29

30


http://www.wincalendar.com/Holiday-Calendar/March-2017

http://www.wincalendar.com/Holiday-Calendar/May-2017