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Comment#71— Is the placement requirement based on WIOA enrollments only or includes <br /> general public as well? <br /> Resolution—The placement requirement for initial eligibility includes all students. For <br /> continued eligibility, the completion measures includes all students, whereas the other <br /> measures include WIOA participants only. <br /> Comment#72—In regards to performance for public postsecondary, is there a form for the <br /> providers to fill out with the performance information? <br /> Resolution —All providers are required to report their performance data directly into Cal1OBS. <br /> Comment#73— Local Boards are responsible for meeting WIOA performance outcomes for <br /> WIOA participants. Are training providers held to the outcomes that are the responsibility of <br /> the Local Boards or do they hold shared responsibility? If the performance metrics inclusive of <br /> both WIOA and non-WIOA participants, is it common for providers to track employment <br /> outcomes or is this specific to ETPL? <br /> Resolution —Providers are held to the performance requirements outlined in the ETPL <br /> Directive, as described in the Initial and Continued Eligibility sections. If providers and/or <br /> programs are successful with WIOA participants,the Local Board will see this success in <br /> meeting their negotiated goals. The responsibility of outcomes is shared. <br /> Comment#74—Program data being entered into CaIJOBS represents duplication of work for <br /> those who do collect such information and is not verifiable. Minimally, we believe the state <br /> should work with the CaIJOBS vendor to provide a more streamlined process. <br /> Resolution—As described in TEGL 3-18, all providers must work with the state to submit <br /> performance data required by the ETP Report in order to be eligible and listed on the ETPL. <br /> WIOA participant data will come from case management work that is already entered into <br /> WIOA applications in CaIJOBS. Providers are required to submit aggregate data on all students <br /> in CaIJOBS. <br /> Comment #75— Providers are required to report data on ALL students, not just WIOA, to the <br /> Local Board and the state. Does this data need to be reported by individual? If so, how do we <br /> avoid FERPA violations with individuals who have not signed consent for us to have their data? <br /> Resolution— Providers only need to submit aggregate all student data as outlined on the CA <br /> ETP Assurances Form (Attachment 4). <br /> Comment#76—The data collection and reporting of all students that is required for the ETP <br /> Report is prohibitive. This is evidenced by many waivers that have been granted by DOL to <br /> states as well as our own state's request to waive this provision. The waiver to collect all <br /> student data should be extended. <br /> Resolution —The waiver to report all student data ended with PY 19. DOL has recently granted <br /> an extension to the waiver for PY 20; however,the DOL denied our request for a waiver <br /> Page 15 of 25 <br />