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Comment #90 — Vetting process for adding training providers needs to be streamlined and <br />much improved. It is currently locally driven. Can this be centralized in state this can really help <br />achieve economies of scale? Additionally, the state has expertise in financial stability, <br />accessibility, compliance, etc. <br />Resolution — With the implementation of this policy, the EDD will review all Local Board <br />nominated providers and program for initial and continued eligibility ensuring the <br />requirements outline in this directive are applied consistently. In addition, the EDD is exploring <br />other ways to streamline and improve the ETPL process. <br />Comment #91—Are Adult Education and Literacy activities not allowable/fundable under <br />WIOA unless in conjunction with an authorized training? Are such activities allowable, but not <br />considered training? Are they simply not allowable? <br />Resolution —To be listed on the ETPL, the provider must be an eligible provider of adult <br />education and literacy activities under Title II of WIOA. Adult education and/or literacy <br />activities must be offered concurrently, or in combination with, occupational skills training. <br />Comment #92 — Public education course work should automatically be accessed and allowed <br />on ETPL. Data collection has proven prohibitive. Should all public schools, such as Adult Ed, <br />Community Colleges, ROP, contract education, etc., should be automatically eligible. <br />Resolution — Not all public education programs are in -demand, so each program should be <br />looked at individually for ETPL eligibility requirements. Per federal requirements, data <br />collection is required of all providers (except registered apprenticeships). <br />Comment #93 —Are all other service types on Section B, page 2 (except on the job training <br />[OJT], Incumbent Worker Training [IWT], and customized training) required to be on ETPL? <br />Resolution —Aside from OJT, IWT, and customized training, all services listed are considered <br />"training services," and when funded through an ITA, these must be on the ETPL per TEGL 8- <br />19. <br />Comment #94— Is it required that OJT, IWT, customized training providers are listed in CaIJOBS <br />as a non-ITA provider or be listed on the local ETPL? <br />Resolution — Local Areas are encouraged to enter OJT, IWT, and customized training providers <br />into CaIJOBS as a non-ITA provider. These providers are not required to be on the ETPL; <br />however, the Local Board must inform participants of the OJT, IWT, and customized training <br />options available. In CaIJOBS, these providers would be listed as either ETPL (ITA) or Local <br />Providers (non-ITA). <br />Comment #95 — If all elements of the Draft Directive become final, it will take all the time of <br />one full-time employee to implement them. Additional funding and training would have to be <br />provided by the state. <br />Resolution —The EDD will offer training, and quarterly meetings with the ETPL Coordinators to <br />provide technical assistance. Questions and concerns regarding Local Area's allocations can be <br />directed to the Local Board's Regional Advisor. <br />Page 18 of 25 <br />