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7.4.2 Background for Wisconsin's Eligibility Procedures
Effective date: September 2, 2019
After consulting with the Governor's Council on Workforce Investment and the directors from the local WDBs, DWD-DET, as Wisconsin's State Workforce Agency, established the State's ETPL eligibility procedures. The parties agreed that, as part of these procedures:
information requirements and eligibility criteria for initial and continued eligibility will be the same1 and will align with federal ETP performance reporting requirements;2
some information requirements and eligibility criteria will depend on the institution's status as a Standard or Alternate institution;
ETPL eligibility criteria will not include minimum levels of program performance;3
the local WDBs will refrain from requiring additional information requirements and eligibility criteria;4
DWD-DET will be responsible for receiving and reviewing institution and program applications and making initial and continued eligibility determinations;
and
continued eligibility will occur annually, at the same time each year.
120 CFR § 680.450 addresses the procedure for initial eligibility and 20 CFR § 680.460 addresses the procedure for continued eligibility. A state may choose to have different information requirements and eligibility criteria for each procedure; however, Wisconsin opts to keep the information requirements and eligibility criteria consistent across both procedures.
2DOL requires several data elements as part of annual ETP reporting. See DOL's ETA 9171
320 CFR §§ 680.450(f) and 680.460(f)(1)(iv) allow states to establish minimum performance standards as part of initial and continued eligibility. DWD-DET, with the support of the State WDB and the local WDBs, chooses not to exercise this authority. All parties agree that publishing each program's aggregated student performance data on the ETPL will help to effectively promote informed choice; whereas, the process of choosing minimum performance standards would be arbitrary and could therefore unnecessarily limit consumer choice.
4Local WDB-level information requirements and eligibility criteria are difficult to administer and could be perceived as confusing to training institutions and program participants accessing Wisconsin's ETPL website.
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