TAA Policy Manual
Ch. 7) Program Benefits

7.6 Training Services & Supplemental Assistance

Table of Contents 

7.6.2 Training Approval Criteria

Effective August 1, 2021

Revised December 11, 2024

For TAA participants who are interested in pursuing training services the TAA Career Planner must complete an in-depth analysis of the following six criteria¹ to determine whether training is appropriate and allowable:

1. There is no suitable employment available for the TAA participant.
2. The TAA participant would benefit from appropriate training.
3. There is a reasonable expectation of employment following completion of the training program.
4. Training is reasonably available to the TAA participant.
5. The TAA participant is qualified to undertake and complete the selected training program.
6. The selected training program is suitable for the TAA participant and available at a reasonable cost.

Each criterion must be analyzed by the TAA Career Planner based on the results of assessment(s) completed with the TAA participant, available labor market information, and an evaluation of available training programs. The results of this training eligibility analysis must be documented on form TRA-16679-E and in the participant's Individualized Employment Plan (IEP).

7.6.2.1 Criterion 1: No Suitable Employment is Available

By definition, suitable employment varies from participant to participant, so it must be evaluated on an individual basis for each participant requesting a training service. Career planners must consider a number of factors when determining whether suitable employment exists for a TAA participant. The TAA Initial Assessment Form (TAA-19885-E) guides career planners through the information that must be gathered to complete this determination.

This analysis will require knowing and understanding the participant's pre-layoff job title and duties, wage/salary, and the employment requirements for that job including education and experience level. Several resources are available to help career planners assess this information including Job Center of Wisconsin and other aggregate job searching websites, WisConomy, Career OneStop, and O*Net Online.

If the Career Planner determines that the participant is not eligible for training because suitable employment is available within the commuting area or within a chosen area for relocation, then the availability of suitable employment must be documented in the participant's file.²

7.6.2.2 Criterion 2: Participant Would Benefit from Training

The Career Planner must determine that appropriate training will increase the participant's likelihood of obtaining employment in their goal job.³ This can be documented by finding the training typically required for the goal job in O*Net, or by analyzing job ad requirements.

Training should improve the worker's chances of obtaining employment at higher wages than they could obtain without training or place them on a path to do so.⁴ Although it is preferred for training to lead to suitable employment, it is not required. Training should allow participants to compete for the highest paying employment achievable given their preexisting skills, abilities, and education and the current and projected job market.⁶

7.6.2.3 Criterion 3: There is a Reasonable Expectation of Employment After Training Completion

The Career Planner must review labor market projections to determine whether there is a reasonable expectation that the participant will gain employment in the chosen occupation, and within the participant's normal commuting distance, after completion of the training program.⁷ In cases where the participant has indicated a desire to relocate, this analysis must be conducted for the selected area of relocation.⁸

Several resources are available to help career planners assess the current and future availability of employment including:

• Job Center of Wisconsin and other aggregate job searching websites;
• WisConomy;
• Career OneStop;
• O*Net Online

The Career Planner may also:

• Review the local Workforce Development Board's WIOA Regional or Local Plan;
• Connect with local business services teams or other organizations representing businesses (e.g. Chambers of Commerce, economic development entities, etc.); or
• Connect directly with local employers to gauge current and future labor market needs for the selected occupation.⁹

The Career Planner must document the labor market information used to conduct this analysis in the participant's file.¹⁰

Career Planners may approve training for limited demand occupations if there is evidence, based on local employer feedback, that there is a need for such trained worker in the local area.¹¹ At minimum, such evidence must be documented in ASSET case notes and reference the employer(s) contacted to make this determination.

Career Planners may also approve training that leads to self-employment. Training plans leading to self-employment may include entrepreneurial training in conjunction with occupational training, but may not be solely comprised of entrepreneurial training.¹² There also must be evidence that the self-employment will provide wages or earnings at or near (80% or more) the worker's pre-layoff wage.¹³ The Career Planner may connect with similar small businesses or local small business resources (e.g. UW Extension, small business associations, etc.) to determine marketability and earnings potential in the selected occupation or industry. At minimum, the information collected must be documented in ASSET case notes and reference the resource(s) contacted to make this determination.

In the case of a training plan for On-the-Job Training (OJT) this criterion is only satisfied if the OJT is expected to lead to suitable employment with the OJT employer.¹⁴

7.6.2.4 Criterion 4: Training is Reasonably Available

The Career Planner must determine whether training is reasonably available to the TAA participant. To make this determination Career Planners should consider the following:

1. Is there training available for the selected occupation within the participant's normal commuting area? If so, the training program(s) available within the normal commuting area must be given first consideration.
2. If there is no training available within the normal commuting area, is there training available outside of the normal commuting area?
3. Whether located within or outside the normal commuting area, is the training available at a reasonable cost?

Career Planners may also consider the timeliness of training availability in making this determination.¹⁵ For example, if the earliest start date for training within the normal commuting area is six months in the future, but training outside the normal commuting area is available at a reasonable cost and begins within 30 days, the Career Planner may opt to approve the training program outside the commuting area. In cases such as this the Career Planner must consult TAA Central Office to ensure allowability of the training plan. The results of such consultation must be documented in the participant file or in ASSET case notes.

7.6.2.5 Criterion 5: Participant is Qualified to Undertake and Complete Training

The Career Planner must determine, based on the results of assessments completed with the participant,¹⁶ whether the participant is reasonably able to undertake and successfully complete the selected training program.¹⁷ The following must be considered:

1. Do the participant's current knowledge, skills, abilities, educational background, and work experience demonstrate the participant's ability to be successful in the training program? Similar analysis completed for Criterion 2 may be used to make this determination. This determination may be based on the participant's current education level, credentials, work experience, mental/emotional/physical capabilities,¹⁸ career inventory results, etc. as collected through the assessment process. Information from a training institution such as placement tests, physical exams, and/or staff attestations may also be considered. At their discretion the Career Planner may engage the services of the local Job Service Career Counselor to complete additional comprehensive and specialized assessment(s) with the participant to assist with this determination.
2. If the participant will not have UI or TRA payments available for the entire length of their training program, the State must determine whether the participant has adequate financial resources to support themselves and their family while completing the training program. Financial resources to consider include, but are not limited to:
   1. Personal financial resources including, but not limited to, severance pay or wages from part-time employment;
   2. Family financial resources; and
   3. Federal student financial aid, state-funded student financial aid, and/or private scholarships, awards, or grants.¹⁹
   NOTE: This determination requires an analysis of the participant's personal budget, including fixed expenses such as housing rent/mortgage costs, utility payments, child support payments, etc. TAA Central Office strongly recommends the use of the CEPT Budget tool to capture and analyze the participant's expenses vs. income when making this determination.

If the remaining weeks of UI and TRA payments are not sufficient to last the entirety of the training program, and the participant does not have other adequate financial resources available to them, then the training must not be approved.²⁰ In this case, the Career Planner must work with the participant to identify other available training opportunities, including short-term training programs and/or work-based learning opportunities, that would allow for approval based on the available financial resources.

7.6.2.6 Criterion 6: Training is Suitable for Participant and Available at a Reasonable Cost

The Career Planner must also ensure that the selected training program is available at a reasonable cost as compared to similar training programs.²¹ The cost of a training program includes:

• Tuition, books, tools, computers and other electronic devices, internet access, uniforms and other training-related clothing, goggles, work boots, laboratory fees, and other academic fees that are required by the training institution for successful completion of the training program;²⁰
• Allowable transportation and subsistence (food and lodging) costs; and
• Costs of initial licensing and certification tests and fees if applicable.²²

The Career Planner must consider the following in comparing training programs and costs:

1. Are there one or more training programs available within the normal commuting area?
   If there is only one training program available within the normal commuting area for the selected field, then that program must be given first consideration.
   If there are multiple training programs available within the normal commuting area for the selected field, the career planner must work with the participant to evaluate the quality, content, results, timeline and cost of those programs before selecting and approving a program. First consideration must be given to the lowest cost training available within the normal commuting area.
2. If there is no suitable training program available within the normal commuting area, are there reasonable training options outside the normal commuting area?
   When evaluating training programs outside the normal commuting area the cost of transportation assistance and subsistence payments must be factored into the cost comparison analysis. Training may not be approved if the cost of training is unreasonably high as compared with the average costs of training participants in similar programs at other providers.

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• ¹ 20 CFR 618.610(a)-(f)
• ² 20 CFR 618.610(a)(2)
• ³ 20 CFR 316.620(b)(1)
• ⁴ 20 CFR 316.620(b)(1)
• ⁵ 85 FR 51904, 51929
• ⁶ 20 CFR 618.610(c)
• ⁷ 20 CFR 618.610(c)(3)
• ⁸ 20 CFR 618.610(c)(2)
• ⁹ 20 CFR 618.610(c)(2)
• ¹⁰ 20 CFR 618.610(c)(4)
• ¹¹ 85 FR 51931
• ¹² 20 CFR 618.610(c)(5)
• ¹³ 20 CFR 618.610(c)(6)
• ¹⁴ 20 CFR 618.610(f)(2)(ii)
• ¹⁵ 20 CFR 618.610(e)(2)
• ¹⁶ 20 CFR 618.610(e)
• ¹⁷ NOTE: The Career Planner must not deny training on the basis of disability status; but must work with the participant and any relevant partner agencies/programs to develop an appropriate training plan based on the participant's abilities and provide any reasonable accommodations necessary for the participant to be successful in the training program.
• ¹⁸ 20 CFR 618.61(e)(3)
• ¹⁹ 20 CFR 618.61(e)(5)
• ²⁰ 20 CFR 618.610(f)(2)(A)
• ²¹ 20 CFR 618.610(f)(2)(B)
• ²² 20 CFR 618.610(f)(2)