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Page 19 of 25 <br /> <br />Comment #96 – What about programs that are offered in English and Spanish? Should those <br />be listed separately, like programs that are online or in-person? BPPE does not mandate <br />combining of program data for English and Spanish courses. <br />Resolution – If the curriculum between a Spanish and an English program is the same, then the <br />program only needs to be entered once. The description of the program should indicate that <br />the program is offered in both English and Spanish. If the curriculum between the two <br />programs is different, then the programs should be listed separately, per DOL ETP reporting <br />requirements. <br /> <br />In-Demand <br />Comment #97 – Who verifies whether a program is in-demand? The ETPL coordinator of the <br />Local Board that nominated the provider? And what about priority sectors of adjacent or even <br />far-away Local Boards? <br />Resolution – The Local Board is responsible for verifying that a program be for occupations in <br />in-demand industry sectors identified by the state, region, or Local Board. In-demand or <br />priority industry sector information must be verified with the State Board and/or Local Board. <br />CA ETPL programs would then be available for other Local Boards to use. If the Local Board <br />chooses to have a local ETPL, the Local Board would determine if the program is in-demand in <br />their area. <br /> <br />Comment #98 – In-demand industry sectors are locally defined. How do you identify <br />occupations (by SOC code) that are in-demand as determined by the state? Where is this list <br />located? Would you use state in-demand to determine state eligibility, then use local in- <br />demand to determine local eligibility? <br />Resolution – California’s Unified Strategic Workforce Development Plan has language on what <br />is considered an in-demand occupation, as well as a list of occupations that Local Boards can <br />use to justify state in-demand requirements. Local Boards would then apply their own local <br />requirements for their local ETPL eligibility. You can find a link to the plan on the California <br />Workforce Development Board’s website. <br /> <br />Local Board Policy <br />Comment #99 – Does the state have a guide for the specific documents that contribute to <br />“sufficient records”? <br />Resolution – This requirement is to ensure providers are submitting accurate data to the Local <br />Board. Providers can be removed for intentionally supplying inaccurate data. What constitutes <br />as “sufficient records” needs to be addressed in the Local Board’s local policy. <br /> <br />Comment #100 – If the provider that went out of business is the only provider in a reasonable <br />distance, Local Boards may not be able to provide a comparable training alternative. Must we <br />provide travel costs if the client wishes to go? <br />Resolution – This would be something to address in the Local Board’s local policy. <br /> <br />EXHIBIT 2