Strategic two-year state of the workforce investment plan : for Title I of the Workforce Investment Act of 1998 and the Wagner-Peyser Act

              MODIFICATION TO
STRATEGIC TWO-YEAR
WORKFORCE INVESTMENT PLAN
FOR
TITLE I OF THE WORKFORCE INVESTMENT ACT OF 1998
AND
THE WAGNER PEYSER ACT
TO INCLUDE THE
AMERICAN RECOVERY AND REINVESTMENT ACT OF 2009
STATE OF OKLAHOMA
JULY 1, 2009 THROUGH JUNE 30, 2010
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TABLE OF CONTENTS PAGE
SECTION I. CONTEXT, VISION, AND STRATEGY ................................................................................. 3
Economic and Labor Market Context .......................................................................................... 3
State Vision and Priorities ........................................................................................................... 4
Overarching State Strategies ........................................................................................................ 8
Service Delivery Strategies, Support for Training ..................................................................... 14
SECTION II. SERVICE DELIVERY ..................................................................................................... 19
State Governance and Collaboration ......................................................................................... 19
Reemployment Services and Wagner-Peyser Act Services ....................................................... 21
Adult and Dislocated Worker Services ...................................................................................... 22
Youth Services ........................................................................................................................... 25
Veterans’ Priority of Service ..................................................................................................... 27
Service Delivery to Targeted Populations ................................................................................. 27
SECTON III. OPERATION ................................................................................................................ 28
Transparency and Public Comment ........................................................................................... 28
Increasing Services for Universal Access .................................................................................. 28
Local Planning Process .............................................................................................................. 29
Procurement ............................................................................................................................... 30
Technical Assistance .................................................................................................................. 30
Monitoring and Oversight .......................................................................................................... 31
Accountability and Performance ................................................................................................ 33
WAIVERS……………………………………………………………………………………… 33
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SECTION I. CONTEXT, VISION, AND STRATEGY
Economic and Labor Market Context
Question IV in PY 2009 Stand-Alone Planning Guidance: Provide a detailed analysis of the state’s economy, the labor pool, and the labor market context. (§112(b) (4).)
Oklahoma has certainly been impacted by the national recession. Our statewide unemployment rate has increased to 5.9% from a cycle low of 3.2%. We have seen our payroll employment decline by over 27,000 jobs in just the last six months. Manufacturing alone has lost 12,600 jobs (8.3%) in the last twelve months. Our insured unemployment rate is the highest it has been in more than twenty-one years. While there is some very slight evidence to suggest that the pace of the weakening has slowed, this certainly does not mean that conditions are about to improve. It is very likely that Oklahoma’s unemployment rate will continue to rise throughout most, if not all, of 2009.
Certain groups of Oklahomans have been impacted more by the recession than others of course. We have seen relatively higher unemployment claims among males and younger workers. To a large extent, this is likely a function of the industries and job families formerly occupied by these individuals. Men are more likely to be employed in the goods-producing industries than females. These same industries tend to be more cyclical than many service-providing industries that employ greater percentages of women. Younger workers, because they tend to lack both job seniority along with skills and education, often find themselves among the first to be laid off during a contraction.
Between 2006 and 2016, the 10 industries reporting the largest number of jobs gained will account for nearly 70 percent of all jobs added. These industries, known as growth industries, cover a variety of disciplines, including health services, professional services and hospitality. The industry expected to add the most jobs is administrative and support services. This industry will expand by more than 19,000 jobs during the period. Administrative and support services includes areas such as employment services, business support services and services to buildings. Next on the list of top 10 growth industries is educational services, an industry expected to expand by more than 18,500 jobs during the period. Factors affecting this industry will be an increased number of jobs at post-secondary and professional schools, added emphasis on structured activities for children, and anticipated educational reforms. Following closely behind with an addition of 16,160 jobs will be the food services and drinking places industry. Growth is expected to result from an aging population that desires more convenient dining options. Professional, scientific and technical services is projected to expand by 14,470 jobs, and local government, excluding education and hospitals will add more than 12,500 jobs. Specialty trade contractors is the only goods-producing industry in the top 10 growth industries for the 2006 to 2016 period. 4
Of the top 10 industries to add the most jobs, three are classified as health services industries: hospitals, ambulatory health care, and nursing and residential care facilities. These industries will combine to account for 23,610 new jobs between 2006 and 2016. When combined with educational services, the other component of the educational and health services super-sector, these industries will provide nearly one-quarter of the jobs gained over the projection period.
State Vision and Priorities
Question I.C. What is the Governor’s vision for ensuring a continuum of education and training opportunities that support a skilled workforce? (§112(a) and (b) (4).)
The Governor’s vision is to utilize ARRA to achieve greater numbers of appropriately skilled and credentialed Oklahomans in order to make Oklahoma more competitive in a global economy.
To accomplish this goal, and to ensure a continuum of education and training opportunities to support a skilled workforce, we must connect the 3 parts of a comprehensive system and their various services. These 3 interdependent parts are:
o Talent/ Labor Exchange - Electronic systems, as well as physical locations, that provide direct service to clients that lead them to enter or re-enter the labor market. Also provides services to employers that provide access to talent and related business services.
o Skill Alignment and Validation – Actively engaging employers to understand their skill needs and validate career paths within their industries. Using this data to align education and training supply with industry demand.
o Skill Development – Building the pipeline thru joint efforts of various partners with employment, training and education programs to ensure that there is a labor pool of appropriately skilled and credentialed workers that meets industry sector needs
To make these linkages happen, we must first have a better understanding of our key industry sectors and the skill-needs that drive these industries. With this industry sector focus, at both the state and regional level, we can validate skill needs and then ensure that our education and training systems are aligning their programs and business services to provide these needed skills and credentials. The third leg of the system is then to provide improved employer access to those individuals with these skills and credentials through our talent/labor exchange system.
The ARRA funding will allow us move faster toward this vision and to build on the specific priorities that have been established by the Governor’s Council for Workforce and Economic Development (GCWED). Current priorities of the Council include:
1. Align education and training in order to be more responsive to employer needs
2. Expand Oklahoma’s workforce
3. Increase high school graduation rates 5
To achieve this vision, ARRA will be used as a catalyst to:
Identify linkage points across agencies to leverage resources and link the 3 interdependent parts of the larger comprehensive system Determine how data collection systems help with linkage and coordination Enhance partnership alignment across agencies to achieve “Oklahoma goals”
To achieve this vision, the Governor’s Council has identified the following funding priorities:
• Continued focus on industry sector work, including sector studies and gap analysis
• System study/review to enhance/transform system development
• Continued investments in the Career Readiness System (CRC/Key Train/Profiling) to measure skills attainment, improve skills, provide employer services, and quantify skills to better support economic development.
• Success Coaches and related intervention strategies for youth
• Career pathway mapping (to link industry sector and skills development work)
• Incumbent Worker Training
• Data gathering/analysis and reporting and related communications strategies
• Education and outreach efforts
Common Tools & Processes•Industry Sector Work/ Gap Analysis•Data gathering/ reporting/ alignment •System Review & Development•Career Readiness System/ CRC/ Profiling/ -Key Train/ Certified Work Ready Communities•Success Coaches –Increased Graduation & Retention Rates •Career Pathways mapping •Incumbent Worker Training•Growoklahoma.com/ electronic system enhancements & connections•Education and Outreach Individual Programs –Education, Training & Employment ServicesOESC, Workforce Boards, DRS, DHS, CareerTech, Higher Ed, Adult Ed, Common Ed, Others Entrepreneurships, Apprenticeships, Internships, Classroom, Virtual, Work-Based trainingSkillsDevelopmentSupply Appropriately Skilled andCredentialed Workers-Business Services AccessTalent/ LaborExchangeCommon BusinessServices Industry / Employer Employment OpportunitiesBusiness Location, Retention, Expansion Economic Development Support New Hire NeedsAccess to talentScreening / assessment &pre-employment servicesRecruitmentExisting Worker NeedsRetentionUpgrade of EmployeesTrainingSkill Alignment&Skill ValidationDemand
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Question I.E. What is the Governor’s vision for ensuring that every youth has the opportunity for developing and achieving career goals through education and workforce training, including the youth most in need of assistance, such as out-of-school youth, homeless youth, youth in foster care, youth aging out of foster care, youth offenders, children of incarcerated parents, migrant and seasonal farm worker youth, youth with disabilities, and other youth at risk? (§1 12(b) (18) (A.)
The Governor is committed to ensuring that youth in the state have every opportunity to succeed and develop to their fullest potential. It is the Governor’s intent that the majority of funds will be spent on a summer youth program for the summer of 2009. The state will have an expanded summer youth employment opportunities program and work initiative. The program focus will be to provide pre-employment skills, career exploration and pathways, linkages to academics and occupational learning, and work experience. Work experience for non-summer months will also be provided to older out of school youth. It is the Governor’s vision that the recruitment process for identifying and determining eligibility for participation has already begun, with the understanding that the first date of service for Summer Employment Program can not be prior to May 1, 2009.
It is the state’s intent to engage other community partners and programs in providing referrals for possible participants. Some examples include working with the local Department of Human Services offices in determining low income youth, contacting the Department of Rehabilitation Services to help identify youth with disabilities, and contacting Juvenile Affairs to identify youth offenders. We will also work with other community partners and programs.
Governor Henry’s vision for youth is reflected in the mission of the State Youth Council: “Create an Oklahoma workforce strategy for youth that aligns with youth initiatives and provides common solutions that coordinate with the state’s economic goals of building wealth creation for all Oklahomans.” Several initiatives are currently underway which provide a variety of services to youth most in need. These include:
Project MOVES (Manufacturing for Oklahoma’s Vital Economic Sustainability – Project MOVES gives priority to youth aging out of foster care that helps these youth learn about Oklahoma’s advanced manufacturing industry. The youth learn about careers in manufacturing and can attend Youth Career Academies where they learn advanced manufacturing skills. Upon completion of the training, youth are placed in internships with local manufacturing companies. A mentor, who is an employee of the company, is also assigned to each youth. Once the youth completes the internship, he/she is given priority for full-time employment with the company.
At-risk youth who attend high school youth who attend Oklahoma City Southeast High School may attend the Southeast Academy of Manufacturing program where they advance their manufacturing skills on state-of-the-art equipment. Senior students can be placed into internships with local manufacturers.
At-risk students at the Thunderbird Trades Academy in Pryor receive instruction in advanced manufacturing skills and are placed in internships with area manufacturers. 7
Students in this part of Project MOVES also receive six hours of college credit from the Oklahoma State University Institute of Technology.
Oklahoma’s Shared Youth Vision – Oklahoma was one of 16 states to receive funding from the U.S. Department of Labor to develop a comprehensive array of services to most-in-need youth. The project was piloted in Tulsa and focused on foster youth in group homes. Partners are developing a service strategy that encompasses the collaborative efforts of several agencies. The project has expanded into three other areas of the state.
Credentialing – Governor Henry believes that enhanced credentialing of youth is pivotal if Oklahoma is to succeed in a global economy. The state has undertaken several initiatives to increase the quantity and quality of credentials earned by youth in the state. These include:
- WorkKeys: With approximately 16,000 youth having already earned the Oklahoma Career Ready Certificate, the state is a national leader in this area. Youth are given the WorkKeys assessment and, depending on the score earned, receive a gold, silver, or bronze Oklahoma Career Ready Certificate. This CRC illustrates to employers that the youth has the skills necessary in Reading for Information, Locating Information, and Applied Math to do the job. The state will continue its efforts to increase the number of youth with CRC’s utilizing ARRA, WIA, and other funding sources.
- HS Diploma/GED: It is a state priority to increase the number of youth with high school diplomas. A bill authorizing “Success Coaches” in Oklahoma schools was recently enacted and signed into law by Governor Henry. The Success Coaches will work with school counselors, students, parents, and others to keep the student on track for graduation and help explore post-secondary opportunities.
- Technology-Driven Tutoring: The state will expand efforts to engage students in technology-driven tutoring programs. This initiative is especially critical for youth residing in foster care group homes and for incarcerated youth.
Information- The state will work to assure that all eligible most-in-need youth apply for “Oklahoma’s Promise.” This program is offered through the State Regents and will pay tuition for students at any public Oklahoma college or university. The student must have a minimum GPA and the family must meet income guidelines. Also, Information and access to programs like Tulsa Achieves will be provided. This program allows all high school graduates from Tulsa County high schools to receive free tuition at Tulsa Community College if certain criteria are met. Minimum grade point averages must be maintained and the students must participate in community service to continue to receive the assistance. A similar program is in place at Oklahoma City Community College for graduates of Oklahoma City high schools.
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Internships and mentorships – The GCWED partners will expand internships and mentorships for youth. In pilot projects, these strategies have proven to be some of the most effective instruments for keeping youth engaged in post-secondary training and employment. Specific internship goals include:
Expanding the recently developed tools within www.GrowOklahoma.com to include an internship management system; Creating an internship tool kit for businesses; Engaging students through LWIB and higher education institutions; and Engaging employers through LWIB and the State Chamber of Commerce.
The state will utilize ARRA funds to develop and fund innovative projects such as:
Expansion of the Shared Youth Vision project to develop strategy and serve more youth aging out of foster care, youth involved in the juvenile justice system, children of incarcerated parents, and runaway and homeless youth.
Implementation of Success/Graduation Coaches in Oklahoma schools
Special projects targeting Oklahoma’s most at-risk youth (aging out of foster care, juvenile offenders, runaway and homeless youth, etc.)
Expansion of internships and mentorships
Summer academies for middle and high school teachers in targeted industry sectors
Expansion of students earning a CRC
Expansion of Youth Career Academies in targeted industry sectors
Question II. Identify the Governor’s key workforce investment system priorities for the state’s workforce investment system and how each will lead to actualizing the Governor’s vision for workforce and economic development. (§§111(d) and 112(a).)
To actualize the state vision, the Governor’s Council has identified 4 specific areas of priority for the workforce system.
1. Transform Service Delivery System:
Guidelines: The system should not continue business as usual. We will focus on strengths, exploit use of existing infrastructure, re-think the model and be creative to ensure the vision as described earlier can be achieved.
Actualization of this priority area be the development of: A stronger, more comprehensive One-Stop system where adults move easily between the labor market and further education and training in order to advance in their careers and upgrade their 9
contributions to the workplace and where disconnected youth are able to reconnect through multiple pathways to education and training that enable them to enter and advance in the workforce. This is a key part of the talent/ labor exchange element of our state vision/ model.
2. Transforming Re-employment and Employer Stabilization Services: Provide a dual employer/ client focus to provide services to individuals that will quickly connect them to employment and training opportunities and provide employers access to skilled and credentialed talent and related business services.
Actualization of this priority will: Enhance our industry sector work and create value-added services to businesses that will become part of a comprehensive layoff aversion strategy. It will also serve to better engage employers in talent development and workforce development issues in order to better understand their skill needs and to assist them with services that will keep them productive and help prevent layoffs. Real- time data and skills validation from employers is a key element in this process and must include various data sources.
3. Transforming Career Pathways: Provide career pathways and service resource maps that will help career decision making and increase the numbers of credentialed Oklahomans including Career Readiness Certificates, Key Train skill development/ work readiness and post secondary credentials and degrees. The ultimate purpose is to align increased skills and credentials with industry demand.
Actualization of this priority will: Create maps of career pathways that will enable individuals to better plan and manage their careers by seeing how they can plug into the job market while taking advantage of continued education and training in order to realize their ultimate career goals. It will also better connect education and training with the skills/credentials that are in demand by industry. This is a key element of the skills development leg of the state vision/ model.
4. Transforming Data Collection, Tracking and Reporting System: For data based policy development, decision making and to ensure transparency and accountability.
Actualization of this priority will: Incorporate various data elements from all partners into a more comprehensive reporting structure that will help to ensure labor supply and demand are aligned. This is a key part of the skills validation and the skills development parts of the state vision/ model.
Over-Arching State Strategies
Question V.B. What strategies are in place to address the national strategic direction discussed in [Section 4] of this guidance, the Governor’s priorities, and the workforce development issues identified through the analysis of the State’s economy and labor market? (§1 12(b) (4) (D) and 112(a).)
The Governor’s Council for Workforce and Economic Development serves as the State 10
WIB and assists the Governor in setting strategy and priorities for system development.
The Council has developed strategies and set priorities that will help to address the ARRA goals. Specific goals as outlined in section 4 of the ARRA Guidance include:
o “Investments connected to economic growth objectives through regional sector strategies aligned with economic development, education, including community colleges, business and labor organizations, and other partners for high-growth industries such as green jobs, healthcare, and advanced manufacturing”
o “The significant investment in stimulus funds presents an extraordinary and unique opportunity for the workforce system to advance transformational efforts and demonstrate its full capacity to innovate and implement effective One-Stop service delivery strategies.”
o “A stronger, more comprehensive One-Stop system where adults move easily between the labor market and further education and training in order to advance in their careers and upgrade their contributions to the workplace and where disconnected youth are able to reconnect through multiple pathways to education and training that enable them to enter and advance in the workforce”
As a result of this guidance, the Council has identified the following as a key question that transcends ARRA planning:
The key question is, “How will we be different and better in 2012 as a result of ARRA funding?”
Oklahoma will be aligned and coordinated to produce the talent needed to support key industries and to increase per capita incomes.
What does transformation look like in Oklahoma?
Many key strategies were already in place to answer this question and to support these efforts as a result of Council work and recommendations over the past few years. These strategies include: Focusing on key industries – By meeting the needs of key industries, whether statewide or within a region Growth will occur within regions – Our actions need to encourage and support development of agile and appropriate regional partnerships and solutions State agencies will align – Knock down “silos” and work toward common goals Everyone needs to grow – Our strategies will focus on ensuring that all Oklahomans are part of our state’s future success Removing barriers – Encourage and enable workers to take advantage of continuous life long learning opportunities Being accountable for results – Cannot be mere rhetoric. We will develop metrics for our progress and use them to drive our actions 11
Specific initiatives and actions that are in place to accomplish the strategies and the ARRA goals are already in place. Current initiatives and outcomes include:
o Industry Sector Work:
o Major reports for Health Care and Aerospace have been completed – both of which have lead to increased resources devoted to talent development within these industries
o Several sector-related grants have been received as a result of our industry sector work. The most recent being a grant to support Oklahoma’s Aerospace Triangle
o Career Readiness System implementation:
o 29,000 Oklahomans have received a Career Readiness Certificate
o 100 employers have had jobs profiled
o 100 local sites are licensed to provide CRC assessments and include a vast variety of partner locations
o WorkKeys has been approved by the State Board of Education to be used as an alternative end of instruction exam
o Over 50 Oklahoma high schools are now issuing a CRC to their seniors
o Oklahoma is the first state in the nation to certify a local region/community as a “certified work ready community.” This requires coordination with education, employers, and employment programs and serves as an economic development tool in business location, expansion and retention efforts.
o Regional teams are formed and working:
o 11 regional teams, all consisting of at least 6 different funding stream partners, have formed to work on regional industry sector planning. Many have held regional Sector Summits and have developed more specific regional initiatives to support their key industry sectors.
o State agencies are aligning around issues:
o Several agencies have embraced the use of WorkKeys and have incorporated it into their internal systems
o A task force of agency Research Division directors has formed to work closely on joint data projects particularly related to workforce supply and demand
o Interagency and industry workgroups have formed around system transformation, re-employment services and career pathways
o A Workforce Solutions Staff Team (WSST) meets regularly to work on alignment issues and common goals
o Agency directors meet quarterly to ensure close working relationships and to discuss how to support the Council and over-arching state goals
o Funding has been leveraged among agencies to support specific goals, including piloting Success/Graduation Coaches, and to support Career Readiness System efforts
o Career Management/exploration:
o To help Oklahomans continue to grow, the Grow Oklahoma website was launched as a career management system. It was designed to provide tools and information for career exploration, career planning, and to provide 12
information and resources to eliminate barriers for continued education and training.
o Oklahoma’s Report Card:
o A yearly report card has been incorporated into the Council’s reporting structure to help measure results and to help us better understand where we need to focus improvement.
o A metrics “dashboard” project has been started to identify common measures across funding streams.
o Employer surveys have helped to ensure that the strategies are aligned with employer needs.
ARRA will allow us to continue and to enhance these efforts. In addition, specific initiatives within the 4 priority areas, as previously identified, are being set via the interagency and industry workgroups. Planning by these groups includes:
1 & 2. Transform Service Delivery System & Re-Employment and Employer Stabilization Services
Oklahoma will use the opportunity of ARRA to bring a tighter focus and valuable resources to provide transformational/systemic change that will create the "desired state" as noted below:
• Stronger, more comprehensive system where adults move easily between the labor market and further education and training in order to advance in their careers and upgrade their contributions to the workplace and where disconnected youth are able to reconnect through multiple pathways to education and training that enable them to enter and advance in the workforce.
"System Transformation" must begin with intentional steps that lead to a robust service workforce development/training system that is :
-- Easily used by employers
-- Easily used by job seekers/individuals
-- Delivered through well supplied, well supported and well trained field staff
that includes cross-training of staff among programs.
-- Delivered through an easily used but very well developed web presence
(i.e. growoklahoma.com) that is
-- Aggressively promoted through conventional "outreach" methods and thus becomes seen as the first choice of both targeted groups to seek out labor exchange and workforce training solutions.
-- Supported by a cross-functional state team that is simultaneously delivering on
their organization’s strengths and pulling in other related organizations to
make a seamless system that is invisible to the public user.
This “transformed system” ultimately consists of linking 3 inter-related parts:
o Talent/Labor Exchange - Electronic systems, as well as physical locations, that provide direct service to clients that lead them to enter or re-enter the labor market. Also provides services to employers to provide access to talent and related business services. 13
o Skill Alignment and Validation – Actively engaging employers to understand their skill needs and validate career paths within their industries. Using this data to align education and training supply with industry demand.
o Skill Development – Building the pipeline- Joint efforts between partners with employment, training and education programs to ensure that there is a labor pool of appropriately skilled and credentialed workers that meets industry sector needs.
DETAILS: Following are the initial steps/actions that will be initiated through ARRA to transform our system to actually deliver on our individual and corporate missions and mandates.
Buy-in to connect the parts: Work with each agency to identify their place and value within the larger system that include the 3 inter-related parts listed above. Connect and align those pieces into a homogenous framework.
Continuous Improvement: Formally survey users of the system (physical and electronic) to identify strengths and deficiencies. Develop a feedback system for partners.
Conduct usability studies of electronic tools to determine strengths and weaknesses. Integrate findings into the electronic tools. Connect and enhance electronic tools into a more comprehensive and user-friendly system. Review and refine electronic systems to create more functionality and features that serve the needs of users, both employers and job seekers.
Utilize GrowOklahoma.com as the system “front page.” Focus on fully developing the GrowOklahoma.com website in order to make certain that the information is relevant, useful and desired by the two targeted groups expand the mission and content of growoklahoma.com/Job Link create a timeframe for development and delivery of feedback/outcomes Determine what current market penetration is and develop goals for increased market penetration and use of system/virtual and physical Create common metrics that can be used by all partners as a “dashboard” to show success.
Outreach: Create and properly fund an outreach program to promote an enhanced system. This would be an effort to increase the awareness to the system including Job Link, growoklahoma.com/OKCIS, collegestart.org, etc., using Grow Oklahoma as the front page. This must, first, be of an order of magnitude that the message will be communicated statewide with great impact and second, be sustainable to create a destination that can be used to provide a “front door” to workforce/talent development tools and resources.
Sector Strategies: Simultaneous to the work listed above determine what skills business and industry are demanding now and in the foreseeable future and work to orient our organizations to meet these demands (Skills Alignment with industry sector needs). Begin with high-value industry sectors Provide resources to update and continue providing skills gap analysis by sector, similar to the health care and aerospace reports already completed. Provide information statewide and regionally. Focus on regional sector strategies, regional skills panels and skills partnerships to meet the unique needs of various areas. 14
Define what business and industry needs for the existing worker to advance in their
work and in their career (incumbent worker training) Ensure that comprehensive lists of training opportunities and tools are provided on the virtual system, as well as to all front line staff, in order for clients, no matter where they enter the system, to access information and tools to allow them to make informed career decisions. Determine value-added business services, including retention of existing workers, and incorporate into layoff aversion and re-employment plans/strategies Create a timeframe for development and delivery of outcomes
Re-employment Strategies: A comprehensive system as outlined above is critical to adequately respond as a state to the re-employment needs of our citizens. First, we must have a system that provides accurate user-friendly labor market information in real-time. This information would provide data on who/what industries and occupations are hiring in both short and long term time frames. With that information, the education, employment and training supply side can better and more efficiently help individuals to get re-skilled and get back to work more quickly.
The goal is to have a system that responds to changing economic conditions and provides the tools and processes needed to help both individuals and employers. These tools would include coordinated electronic tools, rapid response enhancements, better connections to Unemployment Insurance, and an education and training system that that functions as parts of a comprehensive framework all working together to respond to the needs of Oklahoma citizens and employers- in both good times and bad.
The initiatives and the 4 areas of transformation as described above will help get us to this goal, and ARRA will help to provide the resources to move in this direction.
Another key element of the system, including re-employment, is mapping of career pathways and creating career ladders and lattices. This is another area of transformation that is targeted for development with ARRA funds. The outline of this project is below.
3. Transforming Career Pathways
What are Career Pathways?
Career pathways includes mapping career paths and creating career ladders and lattices within industry sectors and correlating those career ladders with a system of connected education, training and employment programs and support services.
Why Career Pathways?
Career Pathways enables individuals to secure employment within a specific industry or occupational sector and to advance over time to successively higher levels of education or employment in that sector or related sectors. Each step on the career pathway is designed explicitly to prepare for the next level of employment and education.
This is critical in order to create a stronger, more comprehensive system where adults move easily between the labor market and further education and training in order to advance in 15
their careers and upgrade their contributions to the workplace and where disconnected youth are able to reconnect through multiple pathways to education and training that enable them to enter and advance in the workforce.
Career Pathways will help:
o To better understand employer skill needs
o To better support Oklahoma’s industry sector work at both state and regional levels
o To make education and training more responsive to the needs of employers
o To provide a process and tool to help individuals to plug into lifelong learning and to continue to increase skill levels in order to move up the career ladder
Intended Outcomes:
o Increased number of Oklahomans who can access postsecondary education
o Increased number of Oklahomans who persist and attain postsecondary degrees,
credentials and certifications
o Decrease need for remediation at the postsecondary level
o Increase entry into employment and lifelong learning opportunities
o Increase wage gain over time for those who obtain credentials, certificates and degrees.
Major components of the Career Pathways Project:
Write vision statement and goals of project
o To establish career pathways that will align with targeted industry sectors key occupations and skill needs
o Develop the operational framework and tools, methodology and processes that will accomplish the vision and goals
Engage key sectors to get support, information and validation related to career pathways of key occupations and skill levels within each sector (Initially map up to 5 occupations within each key sector)
o Health Care
o Advanced Manufacturing
o Aerospace
o Energy
o Construction
Map the career pathways from entry level (low wage) to top (high wage)
o Core competencies
o Industry specific skills
o Occupational specific requirements
o Include required certificates/licenses
o Mapping of levels to CRC - WorkKeys skill levels
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Map corresponding programs and services that are available to individuals that help to get them engaged in, and then to move up on the ladder/lattice toward their career goal. Programs should include, but not be limited to:
o Adult Education
o Education and training programs
 Classroom training
 Virtual/on-line training
 Work-based training
o Programs aimed at assistance to the working-poor
o Disability programs
o Apprenticeship and pre-apprenticeship programs
o Internship/mentorship programs
o Supported employment programs that provide skill development for those with limited English skills
Crosswalk/connect the industry career pathways with the available programs and services that will assist clients in achieving the higher skill levels needed to enter and move up into higher level/ higher wage employment.
o Deliverable will be written documentation and visual maps that clearly show career progression and the multiple pathways and programs that can assist customers.
o This deliverable will be used to achieve the final two components as well as determine any program gaps.
The final two elements to be completed after the initial deliverables have been accepted are:
Making pathways web-based and user-friendly
o Attach to growoklahoma.com – or otherwise make them available on the web
o Providing tutorials/training for use by individuals and by front line staff from multiple entities that will use them as part of their employment and career guidance/counseling services.
Plan for sustainability and ongoing updating of pathways
o Expansion of added industry sectors and occupations
o Continued partnership development to support and implement pathways
o Industry sector engagement/validation at State and Regional levels
4. Transforming Data Collection, Tracking and Reporting System
 Continue and enhance industry sector reports
o More effective, timely and efficient way of collecting data
 Aligning data supply of workforce, demand of industry sectors, and capacity of training providers: Real Time Data (forecasting data project)
 Enhanced analysis and reporting of data for use by policy makers, employers, individuals and service providers
 The data project being developed at present by OSRHE, CareerTech, Commerce, and OESC merging forecasted job openings with current degree/certificate production is geared toward planning for the future for all agencies involved. ARRA funding should 17
be used to provide the needed programming support to finalize this data resource and develop the web-presence for the resource.
Service Delivery Strategies, Support for Training
Question IX.G. Describe innovative service delivery strategies the state has or is planning to undertake to maximize resources, increase service levels, improve service quality, achieve better integration or meet other key state goals. (§1 12(b) (17) (A).)
Governor Henry’s goals and initiatives for the Recovery Act are to make education and training more responsive to the employer needs, ensuring there is a dual customer focus balance of skill development of the individuals with the skill needs of the employers. Specific strategies have been identified previously. To maximize resources, increase service levels, improve quality and achieve better integration Oklahoma will:
Identify high-growth, targeted industries and occupations Identify employer skills gaps and expand training to fill them Collaborate with employers to define changing workforce needs Provide KeyTrain skills assessment and skill upgrade material Provide Career Readiness Certificates and job profiles Co-enroll Wagner-Peyser with adult or dislocated worker State and regional industry sector gap analysis Build relationships with apprenticeship programs Align workforce activities with education strategies Encourage regional collaboration
Below is more detail on selected existing strategies and outcomes:
The primary issue facing Oklahoma employers and workers is one of skill development. As a result of that need and to improve our ability to meet those needs, Oklahoma has participated in the National Governor’s Association Policy Academy for Sector Strategies since September 2006. In September 2008 we became members of the Learning Network states, sharing experiences with other states new to sector strategy work.
o As a result of our experience in the NGA Sector Academy, Oklahoma has made great strides in connecting business to education. Higher education, career tech and K-12 have all sponsored events that have involved Oklahoma’s industry sectors, teachers and students, thus improving on awareness of industry needs.
o Local WIBs and their partners have embraced this industry sector strategy by forming partnerships within their regions. Our 2008 industry sector summit hosted teams from all 12 workforce regions of our state. Each team contained members from private industry, education, workforce professionals/partners, economic developers, and WIB staff. The summit focused on developing regional solutions to workforce challenges facing Oklahoma’s primary industries and the employers within them. Since the summit workforce regions have identified key industries within their areas - industries that drive their local 18
economies and provide family-living wages and have formed industry sector strategy partnerships.
o Oklahoma’s technical assistance toolkit for industry-led regional sector strategies has just recently been completed and will be made available very soon to local workforce investment boards and staff.
o Recovery Act funding will enable Oklahoma to provide technical and financial assistance to regional sector strategy teams and fund research and data projects. We have funded the healthcare and aerospace studies – both of which have resulted in increased state funding. A comprehensive study of Oklahoma’s advanced manufacturing industry is critically needed at this time to better forecast skills needed and hiring trends in the near future. Recovery funding will enable us to do so.
Another tool that Oklahoma has embraced to demonstrate the value of education and workforce skills is Career Ready Certification and WorkKeys. To ensure that job seekers possess the skills that employers have identified as critical to their hiring needs, CRC’s are now available to high school seniors – as critical to their future as the diploma that they receive at graduation. Proof in hand that the job seeker has the ability needed to successfully perform the job that he/she is applying for. Since January 2006, Oklahoma has certified over 29,000 individuals. We are looking forward to supplying CRC credentials to thousands more with financial assistance through the Recovery funds.
Oklahoma is also offering “Profiling” to employers, identifying skills that are key to the jobs within their facilities. Again, Recovery funds will allow us to increase this service to employers, assisting them better matching new hires to the skills necessary for specific jobs.
Oklahoma’s career management system, www.GrowOklahoma.com, offers unique information, navigation, and personal workforce tools to anyone looking for a first job, career information, job after military service, or even a job after a lifetime of working. Still growing and improving, this portal is a valuable tool for counselors and teachers as they guide students into careers that are not only in-demand today, but also critical to employers tomorrow. Recovery funds will allow GrowOklahoma.com to possibly add a tutoring portal to our website, as well as several other additions that our task forces have identified as crucial electronic needs.
The Governor’s Council for Workforce and Economic Development, Oklahoma’s State Workforce Investment Board, publishes and E-Blast to ensure transparency and public awareness. Workforce and economic development information is shared with public and private sector representatives. Oklahoma plans to add several other electronic mediums including Twitter and Face Book to further our public information and educational endeavors.
In 2008 Oklahoma certified the nation’s first Certified Work Ready Community. This economic development tool encourages improvement in high school graduation rates and provides a true picture of the local workforce skills to current and potential employers. 19
These communities receive work-ready certification when 3% of their total workforce and 25% of their available workforce have a CRC. In addition, the community must have a high school graduation rate of at least 82%, or 82% of the high school seniors must obtain a CRC.
In addition, added services and quality will be achieved through a Waiver Request to use up to 50% of ARRA and WIA Rapid Response funds to upgrade the skills of our existing workforce targeting the industries that drive our state’s local economies as identified through our Industry Sector Strategies Initiative. By increasing personal job skills, employers will enjoy many benefits, including targeting specific industry skills that are critical to their growth and stability. Individuals will enhance their job security by having the skills that are vital to their particular employment. And, communities will benefit from strengthening their essential employers. This is a key element in an overall layoff aversion strategy that will help increase service levels and quality to both individuals and employers.
SECTION II. SERVICE DELIVERY
State Governance and Collaboration
Question III.A.2. Describe how the agencies involved in the workforce investment system interrelate on workforce, economic development, and education issues and the respective lines of authority. (§1 12(b) (8) (A).)
Oklahoma has developed a comprehensive, integrated system that involves a variety of partners to advance the state’s workforce and economic development agenda. To foster collaboration and ensure workforce development strategies and initiatives support economic development efforts the Governor moved the Employment Security Commission to the Commerce cabinet, appointed a Deputy Secretary of Commerce for Workforce Development and reconstituted the State Workforce Board as the Governor’s Council for Workforce and Economic Development (GCWED). The Governor has appointed the representatives of the GCWED to provide strategic direction and policy. The Office of Workforce Solutions in ODOC provides staff support to the GCWED and focuses on planning, policy and partnership development. The Deputy Secretary of Commerce for Workforce Development is responsible for implementing the GCWED initiatives. The Deputy Secretary oversees two bodies that provide support to the GCWED and ensures agency relationships in carrying out its mission:
The Workforce Solutions Staff Team (WSST) - The WSST consists of a variety of representatives from state agencies that assists the GCWED in implementing its initiatives. The WSST provides for a cooperative spirit among Oklahoma’s public agencies when it comes to workforce and economic development issues. The WSST tears down barriers that too often in the past prevented agencies from working together for the common good of the state. Turf issues are addressed and overcome which provides for cohesive, streamlined policy and implementation strategies. Nine state agencies with involvement in Oklahoma’s workforce and economic development system have signed a “Commitment to a Workforce and Economic Development Partnership” 20
agreement which calls for collaboration and agreement for system-wide goals in developing the state’s workforce and economic development system.
State Youth Council - The Governor has established a State Youth Council to address youth workforce issues. The State Youth Council consists of various state agency representatives, non-profit groups specializing in youth issues, private sector representatives, and youth participants interested in developing strategies to serve the state’s youth population. The State Youth Council provides recommendations on youth policy issues to the GCWED, which has final approval.
Oklahoma Department of Commerce – ODOC is the grant recipient for all WIA state funding. Through the Office of Workforce Solutions, the agency provides staff assistance to the GCWED in developing state strategic direction and developing partnerships among state agencies, employers, local WIBs, service providers, and educational entities.
Oklahoma Employment Security Commission – OESC is the administrative entity for all WIA programs and provides technical assistance to WIBs and service providers. The agency distributes formula funds to local WIBs and is in charge of program compliance.
Question III.C.1. Describe the steps the state will take to improve operational collaboration of the workforce investment activities and other related activities and programs outlined in section 112(b)(8)(A) of WIA, at both the state and local level (e.g., joint activities, memoranda of understanding, planned mergers, coordinated policies, etc.). How will the State Board and agencies eliminate any existing state-level barriers to coordination? (§§1 11 (d) (2) and 1 12(b) (8) (A).)
As indicated above, the State has undertaken a variety of activities to improve collaboration at the state and local levels. These include the Work of the Governor’s Council, WSST, and the various interagency/industry workgroups and our Industry Sector engagement at both the state and regional levels. Open dialogue and a spirit of cooperation have increased dramatically over the years. State strategies have emerged from Council recommendations and have been embraced by various agencies.
The state vision/model that was outlined above to connect the 3 interdependent processes- skill validation, skill development and talent/labor exchange touch all partners. Further development of this model will continue to improve operational collaboration and will ensure that our education and training suppliers are meeting the needs of our industry sectors.
One of the purposes of the Council is to address any existing state-level barriers and to develop joint strategies. The State will improve operational collaboration of workforce investment activities by undertaking the following activities:
Commitment to a Workforce and Economic Development Partnership – This agreement, signed by the heads of eight state agencies, commits those agencies to a number of activities and policies to improve the workforce and economic 21
development system at the state and local levels. The agreement was signed in 2005 and will be examined and updated to reflect changing workforce and economic conditions. The agreement will specifically address strategies to be undertaken with ARRA funds.
Contracted services between state agencies and local WIBs, with ODOC as the state WIA grant recipient, will structure contracts utilizing ARRA funds to be more performance-driven with quantifiable outcomes. These outcomes will be negotiated between the parties and contain requirements regarding transparency, as directed by ARRA.
Work-Flex Authority – Oklahoma will utilize its Work-Flex authority to provide expedited services, where needed, under ARRA. The State will examine ways to refine the process in order to provide quicker turnaround times for local WIBs requesting waivers under Work-Flex.
Technical assistance to local WIBs – The State will provide technical assistance to local areas in development of strategic plans and missions. A technical assistance plan is being developed to ensure that effective and efficient TA is provided.
Waivers – The State is requesting waivers as part of this Plan in order to provide local WIBs and service providers with as few barriers as possible to implement provisions of ARRA and regular WIA programs.
Planned Mergers – The State will provide technical assistance and support to local workforce areas considering mergers.
Reemployment Services and Wagner-Peyser Act Services
Question IX.C.4.b. Describe the reemployment services the state provides to Unemployment Insurance claimants and the worker profiling services provided to claimants identified as most likely to exhaust their Unemployment Insurance benefits in accordance with section 3(c)(3) of the Wagner-Peyser Act. (§1 12(b) (17) (A) (iv).)
The Governor’s vision for Reemployment Services (RES) is to supplement our current Wagner-Peyser core service with a three-tiered claimant service track, which will provide a more efficient and effective method of identifying the claimant’s characteristics and needed service strategy.
Claimant’s characteristics will be identified Claimants will be integrated with the regular flow of traffic in office Claimants will be identified through the UI Profiling system Reemployment services to be provided are skill assessment, career guidance, basic employment plans, enhanced employment plans, labor market information, job skill workshops, job developments, job skills upgrades and referrals. Claimants will be provided state-generated labor market information.
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Question IX.C.1.b. Describe how the State will ensure the three-tiered service delivery strategy for labor exchange services for job seekers and employers authorized by the Wagner-Peyser Act includes: (1) self-service, (2) facilitated self-help service, and (3) staff-assisted service, and is accessible and available to all customers at the local level. (§1 12(b) (17) (a) (i).)
The state will facilitate the listing of Recovery Act jobs on Oklahoma Job Link, the state’s job bank, ensuring the accessibility and availability to all customers by: Creating an Executive Order signed by the Governor that directs all entities creating jobs using Recovery Act funds to list them on Oklahoma Job Link Assist the workforce system, including Workforce Centers, with outreach efforts to fully inform job seekers and employers about Recovery Act jobs Expand linkages among partner electronic systems and Oklahoma Job Link, whose customers will benefit from learning about available Recovery Act jobs
Adult and Dislocated Worker Services
Question IX.C.1.a. Describe state strategies and policies to ensure adults and dislocated workers have universal access to the minimum required core services as described in §134(d) (2).
The state has functioning units in our workforce centers. Every individual will be seen by the Welcoming Unit for an Initial assessment, career guidance, and labor market information. Once every person has received these core services it can be determined which unit is appropriate for them to move in order to gain employment. The state also has Oklahoma Job Link which will help to identify the targeted population and help to assist those most in need. The individuals can either receive a self-service or a staff assisted service in our integrated center. The state plans to substantially increase the number of adults and dislocated workers served under the ARRA and WIA adult and dislocated worker programs. It is the state plan to offer core services that will support entry or re-entry into the job market.
Core services are available to anyone using the local workforce system and include:
Employment information, including job vacancy listings, skills necessary to obtain employment in specific jobs, and earnings and skill requirements for occupations in the local, regional and national labor markets.
Information regarding filing claims for unemployment compensation.
Eligibility determination for services requiring criteria-tested eligibility.
Outreach and orientation to Workforce Center services.
Performance and cost information on eligible providers of training services.
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Information and referrals to supportive services including transportation and childcare.
Information on financial aid for training and education not funded under WIA.
Job search and placement assistance and, where appropriate, career counseling.
Initial assessment of skill levels, aptitudes, abilities and supportive service needs.
Follow-up services.
Oklahoma’s policy is to provide universal access for all core services available in Workforce Centers. System monitors examine physical locations to ensure that universal access is standard at all Centers.
In addition to physical access, the State encourages local Workforce Centers to promote to customers the availability of Internet-based core services. This includes core services available through Oklahoma Job Link and www.growoklahoma.com.
Question IX.C.1.c. Describe how the state will integrate resources provided under the Wagner-Peyser Act and WIA Title I for adults and dislocated workers, as well as resources provided by required One-Stop partner programs, to deliver core services.
(§1 12(b) (17) (a) (i).)
The state provides a comprehensive service delivery system to ensure that services are not duplicated. Wagner-Peyser and WIA work together in our local centers to ensure resources are used in unison. Eligible individuals are co-enrolled in all programs. With the addition of ARRA funds, the state will substantially increase the number of adults and dislocated workers served under these programs. Again, we will use our state system to help identify those in targeted populations. The state will use supportive services and needs-related payments to enable participants to successfully complete programs and enter the workforce.
The State’s Integration Policy provides guidance to local areas on constructing a streamlined, seamless process to provide services to adults and dislocated workers. An approved integration policy is required from all local WIBs as part of their strategic plan. The GCWED, through its committee structure, reviews local WIB integration strategies and examines this component as part of its WIB certification process. The State monitors local areas on integration policies and the actual practice of achieving integration in the Workforce Centers.
Question IX.C.3.a. Describe the Governor’s vision for increasing training access and opportunities for individuals including the investment of WIA Title I funds and the leveraging of other funds and resources. (§112(b) (17) (a) (i).)
The Governor believes that access must be expanded for customers seeking training in high- 24
growth, high-demand occupations in targeted industry sectors in the local area. No WIA/ARRA training funds will be invested in individuals who desire training outside of high-growth, high-demand occupations in the locally-determined targeted industry sectors. Among other things, the State will: Request a waiver to reduce the 50% employer match for customized training Request a waiver to reduce to 50% employer match for On-the-Job Training Request a waiver to allow the use of ITAs for older out-of-school youth Request a waiver to allow local areas to use up to 25% of adult and dislocated worker formula allocations for local activity funds – it is anticipated that local areas will use these funds for incumbent worker training Provide more Career Readiness Certificates as a way to demonstrate skill attainment at multiple levels and with multiple populations
Customers desiring training must complete Federal Financial Aid applications (if applicable) and those funds must be leveraged with WIA Title I and Recovery Act funds just as they must be leveraged against TAA and TRA benefits. Also, OESC is currently coordinating with the Oklahoma Department of Rehabilitation to better leverage services to assist customers with disabilities. This will allow WIA Title I and Recovery Act funds to be expanded and allow more individuals to be enrolled in training programs.
Local Workforce Investment Boards are currently exploring a variety of Green Job training activities including a new Wind Turbine Technology program. WIBs are currently working with local training providers to design and implement training opportunities.
Oklahoma recently sponsored a “Growing in Green” summit. Individuals representing both state and local level partners attended from local WIBs, local CAP agencies, educational institutions, state agencies, private business and other local organizations.
WIA board staff and Community Action Agencies are coordinating information regarding weatherization, energy efficiency, and other projects to provide maximum return for training dollars. Local WIBs are also working with training providers on innovative healthcare projects that will address Oklahoma’s critical healthcare worker shortage available through the Recovery Act. These programs may require the use of contracts as outlined in the Recovery Act.
Question IX.A.5. What models/templates/approaches does the state recommend and/or mandate for service delivery in the One-Stop Career Centers? For example, do all One-Stop Career Centers have a uniform method of organizing their service delivery to business customers? Is there a common individual assessment process utilized in every One-Stop Career Center? Are all One-Stop Career Centers required to have a resource center that is open to anyone? (§§112(b) (2) and 111(d) (2).)
Comprehensive Workforce Centers in Oklahoma are required to have a Resource Center available with universal customer access. These centers have computer access to Oklahoma Job Link for job search and initial and continuous claim filing capabilities for Unemployment Insurance. They also provide access to the Internet, printers, fax, copiers and telephone for job seekers to utilize in their job search.
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Local areas have developed a plan to serve the business community within their area utilizing a Business Service Team concept. All partners within the center will participate in the development and delivery of this service resulting in no duplication of effort and services are provided in a uniform manner.
KeyTrain Pre-Assessment is the individual skill assessment utilized in the Workforce Centers to identify the individual’s skill level or skill gaps. WorkKeys is also available to individuals who wish to have a Career Readiness Certificate.
Utilize Oklahoma Job Link/Service Link, the state’s web based system, to identify the individual’s need and barriers. This portion of the system identifies the individuals who are most in need and provides information specific to targeted groups (low income, disabled, etc.).
Each individual visiting a Workforce Center will experience the Welcoming Function of a three-function process. This function provides KeyTrain Pre Assessment, career guidance, labor market information and the development of a Basic Employment Plan (BEP). This BEP will facilitate the individual’s access to the different levels of service within the center.
Youth Services
Question IX.E.1. Describe the state's strategy for providing comprehensive, integrated services to eligible youth, including those most in need. (§1 12(b) (18).)
Oklahoma’s program design will be to provide a robust summer jobs program for unemployed youth. The program focus for the younger in-school and older out-of-school youth will be to provide pre-employment skills, career exploration/pathways, linkages to academics and occupational learning, and work experience. Work experience will also be provided to unemployed out of school older youth during the non-summer months.
Oklahoma plans to utilize a majority of the Recovery Act funds to fund the 2009 Summer Youth Program and provide work experience during the non-summer months. Oklahoma Employment Security Commission (OESC) will monthly analyze the spending ratio of the Recovery Act Youth funds in order to determine if the funds are being expended according to the Local Workforce Investment Board’s projected spending ratios. OESC will submit this monthly analysis to Oklahoma Department of Commerce Director of Operations by the 15th of each month. OESC will also conduct a review of spending ratios at the quarter ending March 31, 2010. If sub-grantee has not expended at least eighty percent (80%) of their Youth allocation, the difference between the percentage of funds expended and eighty percent (80%) may be recaptured by OESC and relocated to another local area. For example, if on March 31, 2010, Sub-grantee has only spent sixty percent (60%) of their available Youth funds, twenty percent (20%) will be recaptured and reallocated to other local areas for immediate use. Youth service during the summer of 2010 will be provided but could be limited depending on the amount of remaining funds.
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The State will allocate the Recovery Act funds to the 12 Local Workforce Investment Boards. Each Local Workforce Investment Board will develop a summer program design for the WIA Youth funds provided under the Recovery Act. Their programs will approve the appropriate services and employment that will meet the needs of both younger in-school, and older or out-of-school youth in their local areas.
Oklahoma has allocated the Recovery Act Funds to each of the 12 LWIBs. Each LWIB will be working with a variety of worksites which will include a mix of public and private sector work experiences. The state will conduct monitoring visits with each of the LWIBs to ensure that meaningful work experiences are being developed and provided to the youth participants.
All Out of School youth who do not have a high school diploma or GED will be required by the State to participate in an academic activity. Of the out of school youth that are required to participate in an academic activity, the State recommends that at least 20% of their time will be spent in a academic activity, whether it is GED training or occupational-relevant curriculum designed to teach relevant theory and skills. Academic activity may include soft skills instruction, work readiness, occupational skills, or academic curriculum. The training should, where possible, include occupational information on the region’s targeted industry sectors and a component on green technologies.
The state anticipates serving approximately 1,500 youth with the Recovery Act funds, and most of these will be participating in the summer employment opportunities created with the Recovery Act funds. Local areas will be encouraged to provide stipends for academic achievement and supportive services including day care assistance, transportation assistance, and other traditional supportive services as the WIB deems necessary. The State will monitor supportive services payments to assure they are in compliance with local, state, and federal guidelines.
Describe any policies or strategies that the state is implementing to ensure that local areas implement activities that support out-of-school youth during summer and/or non-summer months, such as supportive services, needs-based payments, or day-care.
The state of Oklahoma has ensured that the Local Workforce Investment Boards are aware of Training and Employment Guidance Letter (TEGL) issued on March 18, 2009 (guidance for Implementation of the Workforce Investment Act and Wagner-Peyser Act Funding in the American Recovery and Reinvestment Act of 2009 and State Planning Requirements for Program Year 2009). The state provided a two-day strategic planning session to the Local Workforce Investment Areas. The purpose of the session was to work on strategic planning for the summer youth employment program, which included discussing strategies to support out-of-school youth during summer and/or non-summer months. This training session will be followed by a two day training session with all of the front-line youth case workers. The state has not developed a state policy that addresses supportive services for youth; the Local Workforce Investment Boards have been given the flexibility to develop their own policy for providing supportive to youth. By giving the Local Workforce Investment Board the flexibility to develop the policy, each area will be able to ensure that they are providing the services that fit the needs of their youth. Through technical assistance and meetings the state has strongly encouraged the LWIBs to implement activities that support out-of-school youth during summer and/or non-27
summer months. The state has also required that the LWIBs address this in their Local Summer Youth Strategic Plan.
Veterans’ Priority of Service
Question IX.C.5.b. What policies and strategies does the state have in place to ensure that, pursuant to the Jobs for Veterans Act (P.L.107-288) (38 USC 4215), priority of service is provided to veterans (and certain spouses) who otherwise meet the eligibility requirements for all employment and training programs funded by the Department of Labor?
Oklahoma’s policy for priority of service to veterans applies to every qualified job training program funded, in whole or in part, by the Department of Labor. A veteran or eligible spouse shall be given priority over a non-veteran for the receipt of employment, training, and placement services as long as the veteran or eligible spouse meets all eligibility requirements. Each Local Workforce Investment Board must include a copy of their Veterans’ Priority of Service Policy in the Local Plan.
Veteran or eligible person will be:
Identified at point of entry to the One Stop System Made aware of priority of service concerning the full array of programs and services available to them Made aware of any eligibility requirement for the programs or services
Service Delivery to Targeted Populations
Question IX.C.4.a. Describe the state’s strategies to ensure that the full range of employment and training programs and services delivered through the state’s One-Stop delivery system are accessible to and will meet the needs of dislocated workers, displaced homemakers, low-income individuals, migrant and seasonal farm workers, women, minorities, individuals training for nontraditional employment, veterans, public assistance recipients and individuals with multiple barriers to employment (including older individuals, limited English proficiency individuals, and people with disabilities). (§1 12(b) (17) (A) (iv).)
OESC has included the language on “Targeted Use of Funds” from TEGL #14-08 in its Statement of Work in the contracts between OESC and the Local Workforce Investment Boards to ensure the targeted use of WIA Adult formula funds for recipients of public assistance and other low-income individuals as described in WIA §134(d)(4)(E). Also, the State is in the process of issuing new policy guidance on needs-related payments to enable this group to remain in successfully complete training.
In order to support the goals outlined in Wagner-Peyser Act section 8(b), OESC staff are currently in discussions with the Oklahoma Department of Rehabilitation Services (DRS) to foster integration and cooperation at the local level in order to accomplish the following:
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Placement of DRS Benefit Planners into four or six local One-Stop Career Centers. Benefit Planners would office out of these One-Stop Career Centers and serve multiple local workforce investment areas; Coordination of services to shared customers; Assistance to individuals with disabilities in navigating the workforce system to address their needs; and, Referral of persons with disabilities to Job Placement.
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Section III. Operations
Transparency and Public Comment
Instruction from Section II of State Planning Guidance Plan Development Process: Include a description of the process the state used to make the Plan available to the public and the outcome of the state’s review of the resulting public comments. (§§1 11(g) and 1 12(b) (9).)
ARRA was discussed in depth at the Governor’s Council meeting on April 3, 2009. The strategic priorities and funding priorities were determined at that meeting. From that meeting workforce workgroups were formed to look at more in-depth recommendations and will continue to provide guidance.
These workgroups included Governor’s Council members, WSST members and other partners. The state will send the plan to local stakeholders for comment as well as make the Plan available on the OESC and ODOC web sites for public comment for a two-week period. These public comments will be analyzed, and, where feasible, changes will be made in the Plan to reflect public comment.
The modified plan was sent to Council members, WSST members and local Workforce Boards and posted on the Department of Commerce website 10 days prior to the Council’s June meeting. It will be approved by the Governor’s Council at its June 5 meeting. Once approved, copies of the final approved Plan will be emailed to local WIBs, WIB Chairpersons, GCWED and State Youth Council members and other interested parties.
Increasing Services for Universal Access
Question VI.C. What state policies are in place to promote universal access and consistency of service statewide? (§1 12(b) (2).)
Currently, OESC has eight vacancies that have been posted for recruitment. These positions are assigned responsibilities involving the management of career assessment/counseling, interviewing applicants to determine needs for job skills, placement, training, unemployment insurance eligibility, and other social services under a case management system. This includes providing services to public and private employers to refer qualified and trained applicants and providing unemployment compensation services. Specialized and critical tasks will be assigned 29
to qualified veteran staff for the provision of priority employment services to eligible veterans and disabled veterans as defined by the U.S. Department of Labor.
The current State Plan has provided policy and guidance since its adoption in January 2000. Many components of that leading edge Plan are still quite useful. It has guided Oklahoma into position to take the next steps in a comprehensive workforce and economic development system.
The Governor’s Council for Workforce and Economic Development (GCWED) developed an internet-based workforce and economic development information system. This economic modeling system allows an integrated display of current information through overlays of employment, education, and economic development in a map format. The GIS is Phase One of the system while the workforce and economic development information system is Phase Two. Both phases have been implemented and are available for local workforce areas. These two systems provide a powerful tool for workforce and economic development professionals throughout Oklahoma.
Other strategies for the GCWED include “coordinating partner agency communication within guidance and counseling services.” This will be accomplished by enhancing and expanding the work of the Advice and Placement Project currently being done through the WSST, including the JOIN project. The purpose of the Advice and Placement Project is to create common processes and data bases that can be used by employees of all partners who have responsibility to provide guidance and counseling services to clients. A Career Counselor Certification process and other system capacity building initiatives will also be undertaken in this area.
Local Planning Process
Question VIII.D. Describe the state-mandated requirements for local areas’ strategic planning, and the assistance the state provides to local areas to facilitate this process. ((§112(b) (2) and 20 CFR 661.350(a) (13).)
Local planning guidance has been provided in several forms. These have included meetings with local WIB staff, local WIB chairs, conference calls and written guidance. Some planning guidance was also provided in the actual grant agreements that were signed by the local areas in order to receive their funds.
Oklahoma Employment and Training Issuance (OETI) 07-2009, “Local Recovery Plan Guidance,” requires LWIBs to submit a Local Recovery Plan to the Director of the Workforce Integrated Program Division by June 1, 2009. This OETI requires Local Recovery Plans to include, but is not limited to: An Amended Monitoring Plan A Revised Demand Occupation List Supportive Services/Needs Related Payments (NRP) Individual Training Accounts Summer Youth Strategic Plan
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OETI 07-2009 offers specific guidance for each of the above areas to assist LWIBs in completing their Local Recovery Plan
Procurement
Question VIII.F.5. Describe the competitive and non-competitive processes that will be used at the state level to award grants and contracts for activities under title I of WIA, including how potential bidders are being made aware of the availability of grants and contracts. (§1 12(b) (16).) (Note: All procurements must comply with OMB requirements codified in 29 CFR Parts 95.40-95.48 and 97.36.)
On March 5, 2009 – The Oklahoma Employment Security Commission (OESC) issued guidance to the Local Workforce Investment Boards (LWIBs) on the subject of procuring service providers to operate the youth activities under the Recovery Act funding in accordance with our State Procurement and Contract Policy. This policy requires all contracts to contain the method and circumstances required for contract modifications and states that the minimum that is acceptable is to provide a way to change the contract in the event of federal amendments. This clause may also provide for a way to increase funds if additional funds become available to the area, such as NEG funds, reallocation of funds or any other increase of funds becoming available from USDOL. We also stated that since OESC believes the American Recovery and Reinvestment Act of 2009 qualifies as a Federal Amendment - existing service provider contracts that are in compliance with the above requirement and may be modified to provide the youth activities due to the recovery funds Oklahoma has received.
In order to implement summer employment during the summer of 2009, Oklahoma has submitted a waiver to be utilized for youth activities under Recovery Act funding to conduct an expedited, limited competition to select service providers, if needed. Direct contracts with institutions of higher education and eligible training providers will also allow LWIBs to quickly design training to fit the needs of the job seekers and employers.
Technical Assistance
Question VIII.G.2. Describe how the state helps local areas identify areas needing improvement and how technical assistance will be provided. (§112(b) (14).)
We will have a frequently asked questions (FAQ) section on the OESC website that will help identify areas needing improvement. OESC will conduct webinars and teleconferences periodically to address these areas that need improvement. The state will have onsite monitoring of the programs in any areas that need technical assistance. In addition to the monitoring, the state will also go onsite to the local areas and provide technical assistance. In addition to the webinars and teleconferences, the state will have quarterly meetings with local board staff. OESC had a consultant come in to provide training on the American Recovery and Reinvestment Act of 2009 and to provide support for creation of local strategic plans. State staff also attends DOL regional training in Texas so that they may better provide technical assistance to our locals. 31
Recovery Act funds will be utilized to provide technical assistance and training to local areas. New staff may receive training at a variety of locations and through electronic resources. State staff is currently assisting local areas with summer employment program implementation and guidance.
Monitoring and Oversight
Question VIII.H. Describe the monitoring and oversight criteria and procedures the state utilizes to move the system toward the state’s vision and achieve the goals identified above, such as the use of mystery shoppers, performance agreements. (§1 12(b) (1 4) .)
OESC’s Workforce Investment Act (WIA) monitoring process is guided by the Act itself; Chapter 21 of the Rules for the Administration of the Oklahoma Employment Security Act; OETI #08-2006, Change 1 (the Governor’s Oversight and Monitoring Plan), and direction received from Region IV of the Department of Labor.
Early each program year, Workforce Quality Division publishes to all Oklahoma workforce investment areas a monitoring schedule which provides dates for on-site monitoring visits to each area. Monitors correspond with all local areas, and this calendar serves as a “living document” which, by mutual agreement, occasionally changes to accommodate requests from local areas as well as unanticipated situations affecting our monitoring staff. At 45 days prior to the scheduled on-site visit to a local area monitors request certain documents from Board staff and Fiscal Agent personnel to enable a “desk review” which, along with results of previous years’ monitoring, assists in focusing monitoring efforts. Two weeks prior to each on-site visit monitors remind local area personnel of the impending monitoring.
On-site monitoring visits are usually conducted over a 5-day period, although for larger areas with more extensive programs the visits may include an additional 5 or more days. Monitors employ a “monitoring instrument,” a detailed listing of questions organized in 5 categories: Design and Governance, Program and Grant Management Systems, Financial Management, Service Delivery, and Senior Community Service Employment Program. This instrument is based upon guidance received from the Department of Labor, and is also provided to local areas to assist in their own oversight and monitoring responsibilities. Using the instrument to guide their work, monitors review samplings of program and financial records to determine compliance with federal and state laws, rules, policies and other requirements as well as locally-adopted policies and procedures. Technical assistance is provided throughout the on-site visit when issues are identified and when requested by workforce area staff personnel.
The “desk review” and on-site monitoring visit commonly result in several “issues” which are shared with Board and Fiscal Agent staff representatives during an “exit conference,” conducted either on-site or through telephonic conferencing means. Usually “issues” have already been identified to - and discussed to some degree with - appropriate staff personnel during the course of the on-site visit. Monitors emphasize that these issues may or may not result in findings, depending upon results of additional research, review of documents and, frequently, further correspondence with Board and/or Fiscal Agent staff personnel.
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Monitors draft the monitoring report, including findings and any associated questioned costs, upon completion of that post-visit research. Findings and questioned costs result from issues which can’t be cleared through additional information and/or documentation. Local areas have 30 days from the date of our monitoring report to submit a response which may include additional information and documentation to assist monitors in thoroughly understanding the findings and possibly resolving questioned costs. Local area representatives may request in writing an additional 30 day time period. During this period, the Director of Workforce Quality or the CLEO, Fiscal Agent, Local Board or grant recipient may also request an informal resolution conference in order to discuss the findings in the monitoring report.
After receipt of the LWIB’s response to the monitoring report, monitors have 60 days to issue an initial monitoring determination; and the CLEO, Fiscal Agent, Local Board or grant recipient has 30 days from the date of our initial determination to submit its response. An informal resolution conference may also be requested during the period between receipt of the response to the initial monitoring determination and issuance of the final monitoring determination. If an informal resolution conference is requested, an additional 30 days may be extended for completion of the final monitoring determination. The final monitoring determination will be issued within 30 days from the date the response to the initial determination is received unless an informal resolution conference is requested.
If the CLEO, local area, fiscal agent, Local Board or grant recipient is not satisfied with the findings issued in the final determination, it has 15 days from the date of the final determination to file an appeal with the Director of Workforce Quality. The Director forwards the appeal to the Assessment Board within 5 days of its receipt. The Director and monitoring staff, assisted as needed by OESC’s General Counsel, engage local areas to determine if appealed findings may be resolved prior to a hearing being conducted. If such resolution is unsuccessful, the Director and monitoring staff work with General Counsel to prepare exhibits and testify in support of the Agency’s position on the appealed determination(s).
Monitors employ a “risk management” approach in order to maximize our on-site time and avoid unnecessary duplication of required local area monitoring responsibilities, thus minimizing disruption of ongoing local area activities. On-site efforts focus on aspects unique to each area (e.g., individual service strategies (ISS), individual employment plans (IEP), on-the-job training (OJT) contracts, travel, etc.) which, based on evaluation of previous monitoring reviews, will likely present the area with greater vulnerabilities to program performance and/or misuse of grant funds. This process also includes innumerable opportunities for interaction between our monitors and local workforce investment area personnel to include the sharing and discussion of documents related to findings and questioned costs.
Monitors provide technical assistance to Boards and Fiscal Agents on system, program and financial management compliance during on-site monitoring visits and at all other times upon request, to include support of procurement and contracting activities. Monitors also participate throughout each year in various working groups, forums and conferences focused on improving local workforce investment areas’ efficiency and performance.
The Department of Commerce is included as a copy addressee on all monitoring reports, initial and final monitoring determinations, and results of appeals.
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A new avenue for resolution of issues prior to becoming findings has been introduced during Program Year 2008. Following the “exit conference,” local areas have 15 days to submit additional information and/or documents for monitor’s consideration. Submitted documentation or additional information may thus preclude issues discussed in the exit conference becoming findings formalized in the monitoring reports.
Accountability and Performance
Question X.C.1. Describe the state’s performance accountability system, including any state-system measures and the state’s performance goals established with local areas. Identify the performance indicators and goals the state has established to track its progress toward meeting its strategic goals and implementing its vision for the workforce investment system. (§§112(b) (3) and 136(b) (3).)
The state utilizes Oklahoma Service Link to evaluate performance and track progress of all programs provided by Wagner-Peyser, WIA and ARRA identified funds. Measurability of work readiness skills, credentials, numbers and demographics of populations served will be accounted for through data provided by Oklahoma Service Link reporting systems. Through these reports, plans may be developed to address the State’s Vision and Priorities, with identification of successful programs, gaps identified by LMI, Oklahoma Service Link and other report data, and the sharing of this information with other agencies and partners.
The various workgroups have begun to identify specific deliverables and outcomes of specific initiatives which will also be measured. The primary goal set by the Council for ARRA funds was to increase credentials. This will measured by using service link, Career Readiness Certificate database, as well as cross walking information with our education and training partners.
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Waiver Requests
Oklahoma submits the following waiver requests for approval for the remainder of Program Year 2009:
1. Request waiver for use of the eligible training provider system for older and out-of-school youth.
2. Request for waiver of performance measures for Workforce Investment Act Title I and the Wagner-Peyser Act and will use common measures instead.
3. Request to waive procurement requirements for youth activities under the Recovery Act.
4. Request to waive Youth Common Measures under the Recovery Act.
5. A waiver to request allowance of up to 50% of the statewide WIA/ARRA Rapid Response funds for the purpose of providing an Incumbent Worker Training fund and program in Oklahoma.
6. A waiver to modify subsequent eligibility determination and the reinstatement of initial eligibility for all training providers on the statewide eligible training provider list.
7. Work-Flex: Oklahoma makes this request under the authority of §189(i) and §192 of Public Law 105-220, the Workforce Investment Act of 1998.
8. Customized Training/OJT Waiver: The State will follow the guidance in TEGL 13-06. The proposed employer match sliding scale will range from 10 to 50 percent, based on guidance in the TEGL.
9. Local Activities Funds: Allows use of up to 25% of local formula funds to be used as flexible local activity funds.
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(1.) Waiver for use of the eligible training provider system for older and out-of-school youth and waiver of the prohibition on the use of Individual Training Accounts for youth under WIA/ARRA.
Submitted in abbreviated waiver request to DOL on April 13, 2009.
(2.) Request for waiver of performance measures for Workforce Investment Act Title I and the Wagner-Peyser Act and will use common measures instead.
Submitted in abbreviated waiver request to DOL on April 13, 2009
(3.) Request to waive procurement requirements for youth activities under ARRA
This request was submitted as a separate waiver request in May 2009.
(4.) Request to waive youth common measures under ARRA
This request was submitted as a separate waiver request in May 2009.
(5.) A waiver to request allowance of up to 50 percent of statewide WIA/ARRA Rapid Response funds to be used to support Incumbent Worker Training
The Oklahoma Department of Commerce (ODOC), the state’s WIA/ARRA Fiscal Agent, requests a waiver to allow 50 percent of WIA and ARRA Rapid Response funds to be used to support Oklahoma Incumbent Worker Training (IWT) activities as needed. A waiver would provide Oklahoma with the needed flexibility to meet the growing demand for innovative and effective incumbent worker training.
Waiver Duration: July 1, 2009 through June 30, 2010
This waiver request is written in the format identified in WIA Section 189(i)(4)(B) and in WIA Regulations 20 CFR 661.420 (c) of the Regulations.
A. Statutory Regulations to be Waived:
Oklahoma requests the waiver of WIA Section 134(a)(2)(A) and WIA Regulations 20 CFR 665.310 through 20 CFR 665.330 that establish allowable statewide Rapid Response activities and uses for set-aside Rapid Response funds.
B. Goals to be Achieved by the Waiver:
1) Broadly speaking, this waiver will enhance the state’s efforts job retention and rapid re-employment as well as providing new job prospects for presently employed individuals. The state and national economy will benefit from the increased productivity and upward mobility of workers. 36
2) The State of Oklahoma knows from experience that there is a deep reservoir of demand for incumbent worker training. This waiver will provide additional resources for a key state initiative to boost creativity and innovation in incumbent worker training and to supply the skills that challenge Oklahoma employers.
3) The state believes its partners and local workforce investment boards are ready to embrace incumbent worker training as an activity integrated into our industry sector / layoff aversion strategies. Creating more flexibility within WIA regulations through this waiver is critical to this effort.
4) The state expects incumbent worker training funds to benefit key industries and local economies by providing a means to upgrade the skills so critical to employers. The intention is to seek proposals for Incumbent Worker Training projects that will most assist in layoff aversion and that are incorporated into regional industry sector strategies. By building business partnerships within regions and within industry sectors, we expect that there will also be substantial savings in training expenses. Local boards will be required partners at the regional level. The partnerships of Sector Strategies Initiatives across Oklahoma’s Workforce Investment Regions will ensure that critical skills within key industries will be upgraded.
5) With the availability of this funding, the State of Oklahoma will continue to make WorkKeys and Career Ready Certificates available to the existing workforce, thus providing a tool to identify the skills levels of these workers and the opportunity to increase their levels of proficiency. We will also have the capacity to provide Job Profiling to Oklahoma businesses, thus establishing the valid skill levels of specific company occupations.
C. State or Local Statutory or Regulatory Barriers
There are no state or local barriers to implementing the requested waiver.
D. Description of Waiver Goal and Programmatic Outcomes
This waiver will give state and local employment and training staff the resources to respond expeditiously to the needs of businesses and workers for upgraded skills. Businesses that need highly skilled workers within their present labor force will have the opportunity to acquire them. One of the major costs of businesses is turnover. This waiver will allow businesses to retain workers, thus recognizing a cost savings to businesses and to the Unemployment Insurance (UI) system. This is particularly important to small businesses, given their greater difficulty in hiring and retaining qualified workers and the impact a high UI experience rating can have on their bottom line.
By upgrading the skills of our incumbent workers, they will quickly move into more specialized jobs within their industries, creating new job possibilities for our lower skilled workforce to enter.
The average incumbent worker will gain a great deal from this waiver. The worker will retain employment thus avoiding the mental, physical, and financial stress that comes from 37
unemployment. The worker will gain upgraded skills that will allow him/her to better work within an expanding and more complicated economy. And in the event that a worker does get laid off after receiving incumbent worker training, they will need fewer (if any) dislocated worker program dollars to get them back on their feet and in a new career.
The state will establish performance measures and standards that will assess the effectiveness and efficiency of the activities allowed under this waiver. It is expected that the measures and standards will include, but not be limited to demonstration of one or more of the following categories:
• Demonstrate business was able to avoid/ reduce layoffs
• Demonstrate increases in productivity through measurements
• Demonstrate that funds used to train incumbent workers resulted in lowering turnover rates
• Demonstrate increased pay to employees who complete the training program
• Increase retention of their existing workforce and retaining workers
• Demonstrate the skills received are those that will transfer to another employer
The use of rapid response funds for Oklahoma’s Incumbent Worker Training will not diminish the ability of Oklahoma to provide dislocated worker services as needed.
E. Description of the Individuals Impacted by the Waiver
Employers and incumbent workers will be impacted by the waiver. Employers will have the human resources to remain competitive, and perhaps expand. Workers will keep good jobs, improve their skills, and increase their confidence that they can compete in a more technologically sophisticated, knowledge based global economy. Many workers will receive pay increases.
F. Description of the Monitoring Process
This waiver will be incorporated into the administrative entity’s monitoring procedures including a periodic review of how well the measures/standards are being met.
G. Opportunity for Local Boards to Comment on the Waiver Request
The Governor’s Council (State WIB) has included incumbent worker training as a high priority within its strategic plan. This waiver request is a result of implementation of that plan that was approved in December of 2008.
Local Workforce Investment Boards have been sent a copy of this waiver request and have been asked for their comments.
H. Public Comment on the Waiver Request
In addition to sending this request directly to local boards, it has also been sent to state partners 38
thru the Workforce Solutions Staff Team. It has also been placed on the Workforce page of the Oklahoma Department of Commerce web site, www.okcommerce.gov, for public review and comment. All comments received will be reviewed and included where appropriate.
Eight comments received have been from Oklahoma employers who are participating in the Registered Apprenticeship Program. Each asked that we consider allowing Incumbent Worker Training funds be used to upgrade the skills of currently employed Registered Apprentices.
One comment of support was received from an administrator of a local workforce board.
(6.)Waiver to modify subsequent eligibility determination and the reinstatement of initial eligibility for all training providers on the statewide eligible training provider list
The Oklahoma Employment Security Commission, the administrative entity for the Workforce Investment Act, is requesting a waiver of Section 122(c) and (d) and CFR 661.530, concerning the eligibility of training providers until June 30, 2010. Additionally, the State wishes to revert back to the initial eligibility requirements for inclusion on the Eligible Training Provider List (ETPL), as provided for under WIA Section 122(b) and Title 20 CFR Section 663.530, related to eligible training provider provisions.
This waiver request is being written in the format identified in WIA Section 189(i)(4)(B) and WIA Regulations 661.420(c).
A. Statutory Regulations to be Waived: WIA Section 122(c) and (d) and WIA Regulations at Section 661.530 address the time limit for initial eligibility that would be waived with an extension of the initial eligibility period to June 30, 2011. WIA Section 122(b) and Title 20 CFR Section 663.530, related to eligible training provider provisions.
B. Goals to be achieved by the waiver: The goals to be achieved by the waiver include:
Retain current approved eligible providers and continue to increase their numbers thereby providing quality customer choice for Oklahoma job seekers Alleviate providers’ concerns with the types and amount of required information Have sufficient time to develop an effective and efficient method of collecting data from training providers Increase the amount and accuracy of WIA performance information from training providers Provide increased training opportunities for Oklahoma WIA participants residing close to border areas (Arkansas, Texas, Kansas, Missouri) where attending training would be more convenient and practical. These states currently have similar waivers and refuse to report to Oklahoma WIBs the performance data. This severely limits customer choice.
C. State or Local Statutory or Regulatory Barriers: There are no state or local statutory or regulatory barriers to implementing the requested waiver.
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D. Description of the Waiver Goal and Programmatic Outcomes: The waiver will allow Oklahoma the time necessary to thoroughly assess the eligible training provider process and determine best practices for data collection and dissemination. The reversion back to initial eligibility will afford Oklahoma job seekers an opportunity to take advantage of the wide array of programs provided by the State’s training providers.
OESC has worked in conjunction with the 12 local WIBs to market the concept of the ETPL to training providers throughout the state. For the most part, efforts have been successful. Once the period of initial eligibility began, the State worked with local WIBs to further educate training providers on the data collection and performance requirements of the subsequent eligibility process. Several concerns have been identified by training providers:
Creating and maintaining a system that would collect the data required around the WIA regulations would be costly and burdensome For many of the providers, the relatively small number of WIA-eligible participants accessing their training services through Individual Training Accounts did not justify the resources that would have to be committed to collecting the data required. The occurrence of potential violations of data privacy – especially related to the Family Educational Rights Privacy Act. WIA data requirements would present an additional burden to the amount of data already being collected from students at a time when most businesses, schools, and colleges are trying to streamline processes and be more customer friendly
These concerns have led several potential training providers to forego completing the training provider application and many current providers to state that they would be unable to comply with the requirements for subsequent eligibility certification. The loss of a number of training providers, especially in the state’s community college and comprehensive university systems, will have a negative impact in rural areas, where the number of eligible training providers is already very limited. The lack of eligible training options would virtually shut down the ITA effort in many of the state’s rural One Stop Centers. This waiver would allow current providers to stay on the ETPL, and provide participants with the training option choices mandated by the Act.
E. Individuals affected by the Waiver: This waiver will positively impact Oklahoma’s public and private training providers. As indicated earlier, these mandated reporting requirements are so burdensome and costly that some providers have found it necessary for them to end WIA participation. The waiver would alleviate this problem by allowing the State to retain providers that are currently participating and also allow for the reinstatement of past providers.
The waiver would also have a positive impact on WIA training participants. It gives greater choice, not only among in-state providers, but also with providers located in border states where an Oklahoma WIA participant may find it more convenient to attend training.
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F. Discussions with local WIBs: Local WIBs and service providers urged the State to seek this waiver. The submission of this waiver has been discussed with local Oklahoma WIB staff and service providers. They are supportive of this request.
G. Description of the Process to Monitor Progress: The Director of OESC’s Workforce Integrated Programs Division and staff will monitor the progress of the above-mentioned actions and related activities.
H. Public Comment on the Waiver Request: This waiver will be posted on the Oklahoma Department of Commerce web site (www.okcommerce.gov) for a period no less than 15 days to solicit public comment. In addition, copies of the waiver request will be sent to local WIBs, service providers, members of the Governor’s Council for Workforce and Economic Development, and other individuals and entities as appropriate for comment.
(7.) Work-Flex
The State of Oklahoma is requesting an extension as a designated Work-Flex State by the U.S. Department of Labor until June 30, 2010. Oklahoma makes this request under the authority of §189(i) and §192 of Public Law 105-220, the Workforce Investment Act of 1998.
The process by which local areas in the State may submit and obtain approval by the State of applications for waivers of requirements applicable under Title I of WIA, including provisions for public review and comment on local area waiver applications.
Local areas will submit requests for waivers to ODOC, Legal Division & the Deputy Secretary of Commerce for Workforce Development. ODOC will begin consultations with officials from the Workforce Integrated Programs Division of the Oklahoma Employment Security Commission to obtain recommendations relating to program policy. The local area submitting the request for waiver must also publish the request on its website and/or in the legal notices of one local newspaper with a primary circulation in the local workforce area. If the request is posted to the local area’s website, it must remain on the website for at least two weeks and interested parties must be informed on how to comment on the proposed waiver, either by e-mail or regular mail. If the waiver is published in a local newspaper, it must run in two consecutive editions. Expense to publish the waiver request will be borne by the requesting local area.
All public comments received from the local area will be forwarded to ODOC with the waiver request. A review of the waiver and related comments and recommendations from OESC will be conducted by ODOC workforce and legal staff. A recommendation for approval or denial will be forwarded to the Deputy Secretary of Commerce for Workforce Development. Once a decision on the waiver has been made, a letter will be forwarded to WIB staff and the WIB chairperson regarding that decision and next steps.
It is the goal of ODOC to have waiver requests granted or denied within 45 days of receipt.
Below are examples of statutory and regulatory requirements of Title I that are likely to be 41
waived by the State under the plan.
Statutory and Regulatory Provisions to be Waived
(8.) Customized Training and On the Job Training Waiver
The State submits this request for a waiver to change the required 50% employer contribution for customized training or On-the-Job training at WIA 101 (8)(C) & (31)(B) to a contribution based on a sliding scale, ranging from 10 to 50 percent, based on guidance in TEGL 13-06.
Goals to be achieved by this waiver
Increase flexibility at the local level to serve business and industry through a demand-driven approach to their specific needs Equip workers with relevant job training with relevant skills that lead to targeted industry sectors Improve the ability of WIBs to work with the private sector and respond quickly to changes in their areas Increase local flexibility for design and control of training programs
Programmatic Outcomes
Increase the percentage of employers using customized training as a means to hire and retain skilled workers Increase the percentage of workers trained and hired through customized training and OJT programs
Individuals Impacted by this Waiver
Employers will benefit from the waiver due to the reduced match requirement. This will make customized training a more attractive option for acquiring workers trained to their specifications.
The waiver will impact the provision of training services through customized and OJT Training to Adults, Older Youth, and Dislocated Workers eligible for services under WIA. In particular, ARRA/WIA eligible individuals with multiple barriers to employment, low basic skills, and English language proficiency stand to benefit the most from customized training.
Process to Monitor Progress in Implementing the Waiver
The State will monitor customized and OJT training programs. Technical assistance during the implementation phase of the waiver will cover areas such as procurement, contracting, and program design. The State will monitor performance reports and compare actual performance with contract benchmarks. The State will continue to make adjustments to monitoring performance requirements to ensure that performance goals and objectives are met for all ARRA/WIA customized training programs. The State will monitor progress on this, and all waivers under Work-Flex. Provisions in contracts for customized training/OJT programs will 42
address specific performance measures for each project.
(9.) Request for waiver for local activity funds
The State of Oklahoma requests a waiver under the authority of the Secretary of Labor to waive certain requirements of the Workforce Investment Act, Title I, subtitles B and E and sections 8-10 of the Wagner-Peyser Act and ARRA. This authority is granted to the Secretary of Labor under Section 189 of WIA and in the implementing regulations at 20 CFR 661.420 until June 30, 2010.
Oklahoma is seeking a waiver from the provisions of Sections 129 (regarding use of funds for youth activities) and 134 (regarding use of funds for employment and training activities) of WIA, as well as a waiver from the provisions of 20 CFR 663.145. This waiver would allow local workforce investment boards in Oklahoma to use up to 25% of the funds allocated to them under Sections 127, 128, 132, and 133 of WIA and ARRA in the same manner and fashion as Statewide Activity Funds are used under Sections 129 and 134 of WIA and 20 CFR 665.200, 665.210, and 665.220(including incumbent worker training).
Purpose
The purpose of the waiver is to gain additional flexibility for WIBs in the use of WIA/ARRA formula funds to meet demands of local workforce development area employers, incumbent workers, job seekers, and youth.
Waiver Request
To meet the demands of employers, incumbent workers, job seekers, and youth, this waiver seeks additional flexibility needed by the local WIBs by expanding the allowable uses of formula funds. This expanded use encompasses activities allowed under the uses of Statewide Activity Funds authorized in WIA/ARRA Oklahoma is seeking a waiver that allows local WIBs, upon request, to use up to 25% of their formula funds for these expanded purposes. For clarity, these expanded use funds will be referred to as Local Activity Funds.
The State of Oklahoma expects the following sequence to take place upon implementation of the
1. Local WIBs would analyze changing economic conditions in their areas and the demands of employers in order to identify a need for additional flexibility.
2. WIBs would submit a request, as a local plan amendment to the Governor, for a portion of the area’s formula funds to be designated as Local Activity Funds to be used consistent with the activities allowable under Statewide Activity funding.
3. The individual WIB’s plan amendment would specify a dollar amount or a certain percentage of the formula funds and the type of fund (Youth, Adult, or Dislocated Worker) to be designated as Local Activity Funds.
4. The plan amendment will also describe the anticipated services to be provided.
5. The plan amendment will include an assurance from the WIB that all services required by WIA/ARRA will be provided. 43
6. The plan amendment will include an acknowledgement from the WIB that all performance targets and expenditure benchmarks will be met.
7. The Governor would notify WIBs of approved plan amendments and contract amendments would be initiated to reflect the additional performance expectations.
Description of the individuals affected by the waiver
The waiver will benefit employers, incumbent workers, job seekers, youth, WIBs, service providers, and One Stop center staff. The flexibility of these funds authorized under this waiver would encourage WIBs to increase their services and become more responsive and innovative to meet existing and new customers’ needs.
State or local statutory and regulatory barriers to implementation
There are no state or local statutory or regulatory barriers to implementing the proposed waiver. Upon notification of approval of the waiver request, state policy will be amended to comply with the terms of the waiver, and applicable policies and procedures will be developed and issued to local WIBs.
Goals to be achieved by the Waiver
This waiver is instrumental as a component in Oklahoma’s workforce strategy, which is consistent with national policy direction, to develop a more integrated, efficient, and effective workforce system.
Local responsiveness for program effectiveness
Improve the ability of local WIBs to respond to changes within their local areas Provide greater flexibility to local WIBs in designing and implementing WIA/ARRA programs Increase local control for program delivery
Statewide program effectiveness
Increase employer/board collaboration to address industry needs and worker training Enhance employment, re-employment, and job retention for job seekers and workers by providing education, training, and other services necessary to assist individuals in moving along the wage and skill continuum Enhance effective access of individuals and businesses to training and employment services that meet a local area’s workforce needs Contribute to maintaining and increasing the availability of a quality mix of jobs in all Oklahoma communities.
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Outcomes/Benefits
The most immediate outcome of the waiver will be to increase the numbers of incumbent workers who would not otherwise be trained. That impact will be felt widely across the state. This waiver will benefit local WIBs, employers, job seekers, service providers, and Oklahoma communities. The following are specific impacts of the proposed waiver:
Program participants will benefit because local WIBs will have added flexibility to design programs based on local needs and priorities More customers will have access to essential services Local WIBs will be able to target more resources to layoff aversion activities involving incumbent worker training The State will be able to more effectively target resources where most needed to provide incumbent worker and other activities. Oklahoma will benefit from results of this waiver through an improved economy. By increasing the skill base of employees in local business and industry, Oklahoma’s employer community would strengthen their standing in competitive markets, leading to more robust local economies.
Monitoring/Evaluation Process
The Oklahoma Employment Security Commission (OESC) is the State administrative entity for the Workforce Investment Act and American Recovery and Reinvestment Act and will monitor service delivery and outcomes under the waiver as required by an annual on-site review and issue a report to the Oklahoma Department of Commerce.