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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 />