7.1 Individual Training Accounts

7.1.2 Use in the Adult Program and Dislocated Worker Program

Effective date: March 13, 2023

Individual Training Accounts (ITAs) are the primary method to be used for funding training services for Adult Program and Dislocated Worker Program participants.¹ An ITA must be used to fund participant training, unless the training is funded through a contract for services under one of the five "contract exceptions"² or the local WDB has a waiver from the Governor to provide the training.³

Since ITAs can only be used to fund training programs on the state's Eligible Training Programs List (ETPL), the local WDB must make the ETPL available to Adult Program and Dislocated Worker Program participants to maximize informed consumer choice when selecting a training program.⁴ DWD-DET requires Title I career planners to share the location of the ETPL website with participants interested in occupational skills (i.e., classroom) training. Participants must select their training program from the ETPL in consultation with their career planner.⁵

Local WDBs must fund a participant's training program of choice through an ITA when:

1. the participant is found eligible for training;
2. the participant selects a training program from the ETPL in consultation with their career planner;⁷
3. the training program is fundable considering local ITA limitations;⁸
4. consistent with federal cost principles, the local WDB determines that the cost of the program is considered reasonable;¹⁰
   AND
5. the local WDB has not exhausted training funds for the program year.⁹

If the five conditions outlined above are not met for a given participant, an ITA cannot be used to fund the participant's training program, and the local WDB must ensure the reason(s) for denying the ITA are documented. When the denial is based on the unreasonableness of the cost of the program, the local WDB's documentation must demonstrate that other comparable training options were available at a lower cost.

• ¹ TEGL 19-16, p. 7
• ² 20 CFR § 680.320; TEGL 19-16, p. 7
• ³ 20 CFR § 680.300
• ⁴ 20 CFR § 680.340(a) & (b)
• ⁵ 20 CFR §§ 680.300 & 680.340(c)
• ⁶ Participants must be found eligible for training under 20 CFR § 680.210.
• ⁷ 20 CFR § 680.340(c)
• ⁸ 20 CFR § 680.310
• ⁹ 20 CFR § 680.340(c)
• ¹⁰ 2 CFR § 200.404 states that "[a] cost is reasonable if, in its nature and amount, it does not exceed that which would be incurred by a prudent person under the circumstances prevailing at the time the decision was made to incur the cost." One of the factors in determining reasonableness of a given cost is the market price for comparable goods or services for the geographic area (see 2 CFR § 200.404 (c)).

7.1.3 Use in the Youth Program

Effective date: October 1, 2024

If appropriate, Individual Training Accounts (ITAs) may be used to fund training services for Youth Program participants who met the out-of-school youth (OSY) criteria at the time of the eligibility determination.¹ ITAs may also be used to fund training services for Youth Program participants aged 16 or older who met the in-school youth (ISY) criteria at the time of eligibility determination.

Youth Program participants who are 18 years of age or older may co-enroll in the Adult Program in order to receive training services funded through an ITA funded by the Adult Program.² Additional information about co-enrollment of Youth Program participants ages 18 and older is available in section 10.4.2.

Special Waiver Note: DOL has approved a waiver for Wisconsin that allows ITAs to fund training services for Youth Program participants aged 16 or older who are ISY at the time of eligibility determination. This waiver is effective for Program Years 24 and 25, ending June 30, 2026.

• ¹ 20 CFR § 681.550; Note that 20 CFR § 681.550 states that ITAs are allowed "for OSY, ages 16 to 24 using WIOA youth funds . . . ." This language suggests that ITAs can only be used for OSY participants who are 16 to 24 years of age at the time of establishing the ITA. DWD-DET disagrees with this interpretation since 20 CFR § 681.210(b) specifically states that OSY participants may continue to be served as OSY beyond the age of the 24.
• ² TEGL 21-16, p. 17

7.1.4 Use with Registered Apprenticeship

Effective date: July 1, 2020

Local WDBs may use Individual Training Accounts (ITAs) to support Title I participants (except Youth Program in-school youth (ISY) participants) in registered apprenticeships.¹ If a registered apprenticeship (RA) program is on Wisconsin's ETPL, an ITA may be used to fund the occupational skills (i.e., classroom) training component a participant must complete as part of the RA program.² If a pre-apprenticeship program is on Wisconsin's ETPL, an ITA may be used to fund a participant's training in that pre-apprenticeship program.³

• ¹ 20 CFR § 680.330(a)
• ² 20 CFR § 680.330(a)(2)
• ³ 20 CFR § 680.330(a)(1)

7.1.5 Limitations

Effective date: July 1, 2020

The state and local WDBs have the ability to establish general limitations for all Individual Training Accounts (ITAs) through policy, including limits on:

• duration;
• dollar amount (e.g., a range of amounts based on level/type of training or occupational field, or a maximum amount for all ITAs);¹
• occupational area;² and
• level of education/training that will be funded (e.g., certificate programs, bachelor's or master's degrees).³

Any general limitations on ITAs cannot be devised or implemented in a manner that undermines WIOA's requirement that training services be provided in a manner that maximizes customer choice in the selection of a training program from the ETPL.⁴ Therefore, DWD-DET prohibits local WDBs from:

• prohibiting the use of ITAs for particular institutions included on Wisconsin's ETPL;
  OR
• requiring participants to select programs on the ETPL that lead to a WIOA-recognized credential.⁵

Any general limitations established by the State WDB or a local WDB through policy must also be described in the State or Local Plan, respectively.⁶ These limitations are not effective until they are included in the State or Local Plan.⁷

Note: Wisconsin's State WDB, The Governor's Council on Workforce Investment, has not established any general limitations on ITAs.

To the extent the State WDB or a local WDB establishes general limitations on ITAs, they may also address situations when exceptions may be made for individual cases.⁸ If the State WDB or a local WDB allows exceptions to the limitations, those exceptions must be described in state or local policy, respectively.⁹ When a local WDB allows for exceptions, DWD-DET requires the local WDB to describe in its local policy the criteria it will use for granting an exception and the procedure it will follow to approve or deny an exception.

If a local WDB includes general limitations in its Local Plan, DWD-DET requires the local WDB to complete the "ITA Limitations" form and send the completed form to its assigned Local Program Liaison within five business days from the effective date of the Local Plan. DWD-DET will publish the local WDB's "ITA Limitations" form on Wisconsin's ETPL website to notify participants and training institutions of the limitations. If the local WDB changes the general limitations through a modification to its existing Local Plan or by issuing a new Plan, it must complete and send a new "ITA Limitations" form to its assigned Local Program Liaison within five business days from the effective date of the modified or new Plan.

• ¹ 20 CFR § 680.310(d). Participants may select training programs that exceed local WDB amount limits. See 7.1.7 Funding Coordination for more information.
• ² 20 CFR § 680.210(b) states that programs of training services must be directly linked to the employment opportunities in the local area or the planning region, or in another area to which the individuals are willing to commute or relocate.
• ³ 20 CFR § 680.310
• ⁴ 20 CFR § 680.310(c)
• ⁵ 20 CFR § 680.420 specifically allows training that leads to employment or measurable skill gains.
• ⁶ 20 CFR § 680.310(c)
• ⁷ 20 CFR § 679.550 states that policies, procedures, and local activities carried out in the local area must be included in the local plan and that the local WDB must provide an opportunity for public comment.
• ⁸ 20 CFR § 680.310(c)
• ⁹ 20 CFR § 680.310(c)

7.1.6 Training Program Removal

Effective date: July 1, 2020

If a training program is removed from the Eligible Training Programs List (ETPL), but the institution has not committed a substantial violation, DWD-DET allows local WDBs and their service providers to use Individual Training Accounts (ITAs) to continue to fund participants who enrolled in the program prior to the program's removal from the ETPL.¹ However, local WDBs cannot establish new ITAs for programs that have been removed from the ETPL.²

If a program is removed from the ETPL due to the institution committing a substantial violation , local WDBs and their service providers are prohibited from making any further payments to the institution through ITAs. DWD-DET will take action to reclaim all ITA funds paid to the institution during the period of noncompliance.³ Additionally, DWD-DET will identify any current participants with an open training service in that program and promptly notify the participant's career planner and the local WDB director about the substantial violation. The career planner must offer the participant both of the following choices:

1. to continue the program without WIOA Title I training funds; or
2. use the ETPL to identify and select a comparable program at a different institution and continue training in the comparable program.

Local WDBs may wish to address in their ITA policies how they will handle situations where participants must select a comparable program at a different institution. For example, they may allow exceptions to any ITA-related funding and duration limitations.

Note: Since fund reclamation would leave some or all of a participant's tuition/fees unpaid, participants may be liable to pay the institution the unpaid amount.

• ¹ This applies to situations where an institution on the ETPL becomes federally debarred. Pursuant to 2 CFR § 180.310, recipients of a federal award may continue transactions with federally debarred organizations if the transaction was in existence at the time the organization became debarred. DWD-DET interprets this provision to allow use of ITAs to fund training programs at federally debarred institutions, so long as the participant was enrolled in the program before the institution was debarred. DWD-DET agrees with DOL's statement in TEGL 41-14, p. 12, that ETPL program removal should result in minimal disruption to enrolled participants.
• ² 2 CFR § 180.320; 20 CFR § § 680.480(b), 683.200(d), & 683.250(a)(4). DWD-DET allows local WDBs that use an ITA to make incremental payments for a training program to make all of the payments so that the participant can complete the program.
• ³ 20 CFR § 680.480(b)

7.1.7 Funding Coordination

Effective date: July 1, 2020

A participant may select a training program from the ETPL that exceeds the maximum amount available for an ITA (as established by state or local policy) when other fund sources can supplement the ITA.¹ Other sources include, but are not limited to: Pell Grants, scholarships, and household income.²

• ¹ 20 CFR § 680.310(d)
• ² 20 CFR § 680.310(d)

7.1.8 Funding a Segment of a Program

Effective Date: January 24, 2022

Training programs published on Wisconsin's Eligible Training Programs List (ETPL) may be comprised of multiple courses/classes.¹ DWD-DET allows an ITA to be used to fund one or more courses/classes that are part of an approved program on Wisconsin's ETPL, even if the participant does not intend to complete all of the courses/classes that combine to form the approved training program. DWD-DET refers to this scenario as using an ITA to fund a "segment" of a training program on Wisconsin's ETPL.

If an ITA is used to fund a segment of a training program, the career planner must do the following:

1. Open an "occupational classroom" or "occupational skills training" service in ASSET and associate that service with the ITA Program ID for the training program that contains the segment of interest.
2. In that service, add a note in the comments box indicating that the participant is taking a smaller segment of the training program. Indicate which course(s)/class(es) of the program will be covered by the ITA. Also include the ITA amount, specifying the cost(s) associated with the smaller segment. The career planner may need to contact the training institution to obtain the cost information associated with the smaller segment.
3. When the participant exits the smaller segment, the ASSET service must be marked as "Completed a Segment"² since the participant did not complete the full training program.
4. Report in ASSET any Measurable Skill Gain and any credential the participant earned while or upon completing the segment.

• ¹ 20 CFR § 680.420; TEGL 08-19 Attachment I, p. I-3
• ² Email from DOL to DWD-DET, 06/05/2020