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Comment#17— If WIOAfunds cannot be used for building construction, doesn't that restrict <br /> Local Boards from funding apprenticeship/pre-apprenticeship programs? <br /> Resolution— DOL Final Rules 683.235 clarifies that WIOA funds can't be used for construction, <br /> etc. forthe purposes of administering WIOA without prior approval from the Secretary of <br /> State. However, in the context of apprenticeships and pre-apprenticeships, WIOA funds can be <br /> used to pay for participants to be enrolled in construction programs. <br /> Consumer Choice <br /> Comment#18—Does this mean the Local Board must refer the client for training and an ITA <br /> regardless of the appropriateness of the training?Can an individual demand enrollment and <br /> training services while demonstrating poor fitness by missing appointments, failing to meet <br /> their obligations in the Individual Employment Plan (IEP), and participate in training that does <br /> not necessarily fit their employment goals as long as they possess the minimum age, basic <br /> skills, and/or prerequisites to do so? If so; we do not believe this is required by WIOA or <br /> beneficial to the participant or the system. <br /> Resolution —The America's Job Center of Californialm staff must determine training services <br /> are appropriate for an individual after conducting an interview, an evaluation or assessment, <br /> and career planning. If training is determined to be appropriate after meeting with a career <br /> planner,the Local Board must send that participant to the training they select as long as <br /> - training funds have not been exhausted. Individuals maintain the right to enroll in whatever <br /> program they choose, however it is the Local Board's responsibility to help individuals with <br /> choosing the best program that fits their needs based on the IEP. Please see the definition of <br /> Training Services in WSD19-06 for further guidance on how an individual qualifies fortraining <br /> services. <br /> Comment#19—The CA ETPL does not permit the Local Board to approve a training program <br /> that'is eligible to be paid with WIOA funding,even though the Local Board is the subject <br /> matter expert on what will lead to a self-sustainable career in the local/regional economy.The <br /> CA ETPL limits the choice of consumer and the Local Board to use Labor Market Information to <br /> determine which courses should be deemed eligible. <br /> Resolution—Local Board staff are still able to select providers to nominate that reflect the <br /> needs of their Local Workforc e Development Area (Local Area). Attachment 1, page 6 states <br /> "Once all necessary information is entered, the Local ETPL Coordinator must review and <br /> nominate the training provider and/or program for inclusion on the CA ETPL." <br /> Delegation <br /> Comment#20—Does each Local Board need to screen all ETPL schools in the Regional <br /> Planning Unit (RPU)for inclusion on its local ETPL? Currently we only go through the local <br /> process if a customer requests the school. <br /> Resolution—Yes, as well as all CA ETPL approved distance education providers and registered <br /> apprenticeships. <br /> Page 5 of 25 <br />