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Comment #71— Is the placement requirement based on WIOA enrollments only or includes general public as well? Resolution —The placement requirement for initial eligibility includes all students. For continued eligibility, the completion measures includes all students, whereas the other measures include WIOA participants only. Comment #72 — In regards to performance for public postsecondary, is there a form for the providers to fill out with the performance information? Resolution —All providers are required to report their performance data directly into CaIJOBS. Comment #73 — Local Boards are responsible for meeting WIOA performance outcomes for WIOA participants. Are training providers held to the outcomes that are the responsibility of the Local Boards or do they hold shared responsibility? If the performance metrics inclusive of both WIOA and non-WIOA participants, is it common for providers to track employment outcomes or is this specific to ETPL? Resolution — Providers are held to the performance requirements outlined in the ETPL Directive, as described in the Initial and Continued Eligibility sections. If providers and/or programs are successful with WIOA participants, the Local Board will see this success in meeting their negotiated goals. The responsibility of outcomes is shared. Comment #74— Program data being entered into CaIJOBS represents duplication of work for those who do collect such information and is not verifiable. Minimally, we believe the state should work with the CaIJOBS vendor to provide a more streamlined process. Resolution —As described in TEGL 3-18, all providers must work with the state to submit performance data required by the ETP Report in order to be eligible and listed on the ETPL. WIOA participant data will come from case management work that is already entered into WIOA applications in CaIJOBS. Providers are required to submit aggregate data on all students in CaIJOBS. Comment #75— Providers are required to report data on ALL students, not just WIOA, to the Local Board and the state. Does this data need to be reported by individual? If so, how do we avoid FERPA violations with individuals who have not signed consent for us to have their data? Resolution — Providers only need to submit aggregate all student data as outlined on the CA ETP Assurances Form (Attachment 4). Comment #76 — The data collection and reporting of all students that is required for the ETP Report is prohibitive. This is evidenced by many waivers that have been granted by DOL to states as well as our own state's request to waive this provision. The waiver to collect all student data should be extended. Resolution —The waiver to report all student data ended with PY 19. DOL has recently granted an extension to the waiver for PY 20; however, the DOL denied our request for a waiver Page 1S of 25