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Resolution —The delegation form is used to delegate ETPL responsibilities (including <br /> providers/programs) to another Local Board. Individual providers cannot be delegated to <br /> another Local Board. If a provider moves its headquarters from one Local Area to another,the <br /> responsibility for that provider changes, and both Local Board ETPL Coordinators should be <br /> made aware of the change. <br /> Eligibility <br /> General Eligibility <br /> Comment#27—Can Local Boards place the burden of proof on providers to prove that their <br /> programs meet the requirements for eligibility? <br /> Resolution —Local Board staff are required to review programs to ensure they meet eligibility <br /> requirements, including credentials. Once all necessary information is entered, the Local ETPL <br /> Coordinator must review and nominate the training provider and/or program for inclusion on <br /> the CA ETPL ensuring all information provided is complete, accurate, and current, and is in <br /> alignment with this Directive. <br /> Comment#28—What documentation is required to demonstrate a provider's partnership <br /> with local businesses? <br /> Resolution —This will vary depending on the Local Board and their local policy. The state will <br /> allow Local Boards to decide what is considered "in partnership with business. <br /> Comment#29—Will the negotiated goals be the same as WIOA title I programs or will there <br /> be different ones for training provider programs? <br /> Resolution —programs must meet the performance requirements described in the continued <br /> eligibility section of the Directive, as well as the state-level Title I Adult performance goal. <br /> Comment#30—Why are training providers that do not award degrees and solely provide <br /> educational programs for total charges of$2,500 not allowed? If a provider has a BPPE <br /> .exemption, it is unclear if a W1OA-funded ITA is considered Federal student financial aid and <br /> therefore ineligible. <br /> Resolution—This exemption prohibits anyfederal funding be used to pay forthis program, <br /> thus excluding WIOA funding from being used. Section 74110 of the CEC defines public funding <br /> as "any financial aid paid on behalf of students or directly to an institution from any public <br /> k <br /> source," which includes WIOA. <br /> Initial Eligibility <br /> Comment#31— Performance requirements for initial eligibility limit customer choice and local <br /> autonomy by removing the ability for new training providers to be added to the ETPL without <br /> performance data.The Draft Directive does not specify the source of the performance metrics. <br /> If in the past, it will come from a provider's BPPE Annual Report, this will further inhibit a Local <br /> Board's autonomy as BPPE is currently two years behind in publishing performance data and, <br /> in fact, does not even allow a provider to upload data until September for publication in <br /> Page 7 of 25 <br />