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Previous Policy - 4.16

4.16 - 35 Percent Expenditure Training Goal for Program Year Formula Allocations

Effective date: August 25, 2018 - October 14, 2019


This policy will provide guidance on the 35 percent expenditure goal for training related to Adult and Dislocated Worker Program Formula Allocation Grants.

The Workforce Innovation and Opportunity Act (WIOA) is designed to help job seekers and workers, particularly those with barriers to employment, access needed education, training, and supportive services so they can succeed in the labor market. It is also meant to match employers with the skilled workers they need to compete in the global economy.

The purpose of the expenditure goal is to increase the numbers of interested and eligible participants receiving training to help them learn the skills needed to qualify for better paying jobs and meet the workforce needs of employers.


To ensure that resources are focused on preparing more people for higher wage jobs, and recognizing the strong connection of training to a "ready" workforce, DWD-DET is maintaining the expenditure goal of 35 percent for WIOA Adult and Dislocated Worker Program funds for training and training-related supportive services. Funds dedicated to administration are not to be included as part of the calculation. The 35 percent expenditure goal applies to the Workforce Development Boards' (WDB) Adult and Dislocated Worker Program formula allocations. The 35 percent goal does not apply to the WIOA Youth Program.

Placement of participants into training is to be guided by the goal of continuing to increase participants' earning potential. Training costs that may count towards the 35 percent expenditure goal include:1

  1. Occupational skills training, including training for nontraditional employment;
  2. On-the-Job Training (OJT);2
  3. Incumbent Worker Training;3
  4. Programs that combine workplace training with related instruction, which may include cooperative education programs;
  5. Training programs operated by the private sector;
  6. Skills upgrading and retraining;
  7. Entrepreneurial training;
  8. Job readiness training provided in combination with services listed in paragraphs (a) through (g) of this section;
  9. Adult education and literacy activities, including activities of English language acquisition and integrated education and training programs, provided concurrently or in combination with training services listed in paragraphs (a) through (h) of this section; and
  10. Customized training conducted with a commitment by an employer or group of employers to employ an individual upon successful completion of the training.4

To help ensure successful participation in and completion of training, the WDBs and their service providers are strongly encouraged to provide participants in training with any necessary supportive assistance that cannot be accessed through non-WIOA resources. Therefore, costs for supportive services provided to training participants may also count towards the 35 percent goal if provided during the period that the training service is open. Supportive services include:5

  1. Linkages to community services;
  2. Assistance with transportation;
  3. Assistance with child care and dependent care;
  4. Assistance with housing;
  5. Needs-related payments6
  6. Assistance with educational testing;
  7. Reasonable accommodations for individuals with disabilities;
  8. Legal aid services;
  9. Referrals to health care;
  10. Assistance with uniforms or other appropriate work attire and work-related tools, including such items as eyeglasses and protective eye gear;
  11. Assistance with books, fees, school supplies, and other necessary items for students enrolled in postsecondary education classes; and
  12. Payments and fees for employment and training-related applications, tests, and certifications.


WDBs shall maintain accounting records to accurately identify and account for the 35 percent training and support expenditures. WDBs must report the costs they count toward the 35 percent expenditure goal monthly in the Contract Management and Expenditure Tracking (COMET) System as memo activities. A participant does not have to complete his or her training in order for the training and associated costs to count towards the goal. These costs should be reported in COMET at the time they are incurred.

To evaluate achievement of the goal, the amounts reported in COMET will be compared to total program expenditures over the life of each grant (i.e., the PY17 Adult and Dislocated Worker formula allocations). In the event that funds are transferred between programs, the 35 percent goal will be evaluated against the modified grant amounts.

Sanctions will not be applied if a WDB does not attain the 35 percent expenditure goal. However, WDBs that do not meet the goal at the end of the grant period must explain why they were unable to attain the 35 percent expenditure level. Any WDB not meeting the goal must provide a written explanation to the WDB's assigned Local Program Liaison (LPL) within 60 days of the close of the grant (between the contract end date and the final report date in COMET).

Note:Transitional jobs were intentionally left off the list of training costs that may be counted towards the 35 percent goal. In the preamble to the final rule, it is stated, "The citation to transitional jobs at § 380.190 has been moved from § 680.380 to reflect the Department's position that transitional jobs are a type of work experience, and thus a career service."7