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  4. WIOA Title I-A & I-B
  5. Policy & Procedure Manual
  6. 7.4 ETPL Eligibility

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7.4 ETPL Eligibility

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7.4.1 WIOA Overview

Effective date: January 20, 2020

The State Workforce Agency, on behalf of the Governor and in consultation with the State WDB, establishes the initial eligibility application and continued eligibility procedures as well as the state's and the local WDBs' roles in carrying them out.1 As part of this process, the State Workforce Agency must:

  • solicit and consider recommendations and comments from the local WDBs and training institutions within the state;
  • and
  • designate a specific period of time for interested members of the public, including representatives of business and labor organizations, to submit comments.2

Program eligibility is determined on a program-by-program basis for each training institution.3 A training program is added to the state's ETPL through the initial eligibility application procedure. An institution applying to have a training program added to the ETPL must, at minimum, provide the state with a description of the training program, verifiable information that addresses a factor related to the WIOA indicators of performance, and information detailing whether the institution is in a partnership with business.4 Once a training program is published on the state's ETPL, it is considered eligible for local WDBs to fund through an Individual Training Account (ITA), even if the program is located outside of a WDB's local area or the state.5

The state uses the continued eligibility procedure to periodically review eligibility of institutions and their training programs and determine if a training program's eligibility should be renewed.6 Eligibility for newly added programs must be reviewed after the first year7 and at least every two years thereafter.8 WIOA requires that the continued eligibility procedure be implemented in a manner that ensures continuity of eligibility for those programs that will be renewed.9

For both the initial eligibility application and continued eligibility procedures, the institutions must comply with:

  1. the state's information requirements, eligibility criteria and any established minimum levels of program performance10
    AND
  2. local WDB information requirements, eligibility criteria and any additional minimum levels of program performance beyond those established by the state, for the training institution's program to be eligible for ITAs within that local WDB.11

The state's eligibility procedures must be outlined in the State Plan, including the state's and the local WDBs' roles and responsibilities in receiving and reviewing institution and program applications and making eligibility determinations.12

Neither the state nor the local WDB has the authority to waive initial or continued eligibility requirements for an institution or program.13 For example, institutions of higher education cannot be granted automatic approval.

Note: Registered apprenticeship programs are generally exempt from ETPL eligibility requirements because of the extensive process they undergo to become registered.14

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.

7.4.3 State and Local WDB Roles & Responsibilities

Effective date: September 2, 2019

DWD-DET is entirely responsible for oversight and implementation of the initial eligibility application and continued eligibility procedures as well as maintenance of the ETPL website. Under this model, the local WDBs agree to refrain from applying additional information requirements and eligibility criteria. However, the local WDB may still impose certain limits on ITAs for dollar amount, duration, and/or occupational field.1

7.4.4 Wisconsin's Initial Eligibility Procedure

Effective date: March 16, 2022

The following is DWD-DET's initial eligibility process:

  1. A representative from a training institution submits an Institution Application through the ETPL Provider Portal. An Institution Application may be submitted at any time.
  2. DWD-DET reviews the Institution Application to determine whether the institution meets the Institution Minimum Requirements. If the training institution does not meet the Institution Minimum Requirements, it is ineligible for Wisconsin's ETPL.
  3. If the institution meets the Institution Minimum Requirements, DWD-DET classifies the institution as either "Standard" or "Alternate."
    1. A Standard institution can add one or more training programs to the ETPL website through the ETPL Provider Portal if it supplies all required program-level information for each program in the ETPL Provider Portal, which includes individual-level information for all students enrolled in the training program for the three most recently completed program years (if applicable).
    2. An Alternate institution must submit a program application to DWD-DET through the ETPL Provider Portal for each training program it would like added to the ETPL website. DWD-DET will determine if the training program meets the alternate eligibility criteria. If the training program does, the institution may publish the program to the ETPL website once it supplies all the required program-level information, including the individual-level student information referenced above, in the ETPL Provider Portal.

  4. Note: Institutions that are part of Wisconsin's Technical College System (WTCS) are not required to submit the file of individual-level information for all students if the training program is recognized by the WTCS Office (i.e., the WTCS Office has assigned the program a unique identification number). The WTCS Office submits the required performance information for these programs to DWD-DET directly. Institution staff must, however, submit the individual-level student information for any program not recognized by the WTCS Office (also referred to as a "local program").

Registered apprenticeship sponsors are not subject to the same eligibility requirements as other training institutions.1 See Section 7.8 Registered Apprenticeships for more information.

7.4.5 Wisconsin's Continued Eligibility Procedure

Effective date: March 16, 2022

DWD-DET will perform its continued eligibility procedure for all institutions and their programs between July 1 and August 31 each year, regardless of when the institution's program eligibility began. Institutions and their programs that pass continued eligibility requirements maintain their listing on Wisconsin's ETPL website. Wisconsin's continued eligibility procedure consists of the following steps:

  1. DWD-DET verifies that the institution still meets DWD-DET's Institution Minimum Requirements;
  2. DWD-DET verifies that the institution still meets at least one of DWD-DET's standard eligibility criteria or, if the institution is classified as an Alternate, the program meets DWD-DET's alternate eligibility criteria;
    AND
  3. The institution uses the ETPL Provider Portal to submit a file in the required format that contains individual-level information for all students who were enrolled in the training program for the most recently completed program year (i.e., July 1 through June 30). See 7.7 ETPL Performance Reports.

    Note: Institutions that are part of Wisconsin's Technical College System (WTCS) are not required to submit the individual-level information for all students if the training program is recognized by the WTCS Office (i.e., the WTCS Office has assigned the program a unique identification number). The WTCS Office submits the required performance information for these programs to DWD-DET directly by September 7 of each year. Institution staff must, however, submit the individual-level information for any program not recognized by the WTCS Office (also referred to as a "local program").

7.4.6 Institution Minimum Requirements

Effective date: July 25, 2022

The following are DWD-DET's Institution Minimum Requirements:

  1. the institution is one of the types outlined in 7.3.1;
  2. the institution is a direct1 provider of training services that have a vocational objective;2
  3. the institution has a current, verifiable Federal Employer Identification Number (FEIN);3
  4. the institution has a current, verifiable Federal Unique Entity Identifier;4
  5. the institution has an active registration on SAM.gov and is not federally debarred, suspended or otherwise excluded from or ineligible for participation in federal programs or activities;5
  6. the institution is not a "delinquent taxpayer" with the Wisconsin Department of Revenue;6
  7. the institution has an "Officer" that DWD-DET can identify through sources other than the Institution Application and applicant;
    AND
  8. the Officer agrees to and electronically signs Wisconsin's ETPL Agreement within 60 days of the date the institution submitted its application to join the ETPL.
  • 1 Email from DOL to DWD-DET, 08/19/2020. The guidance was that institutions that serve as a "conduit" connecting participants to training programs offered by other entities are not eligible for the ETPL. The ETPL is only for direct providers of training services.
  • 2 20 CFR § 680.410(c). DWD-DET considers "vocational objective" to mean leading to proficiency in performing tasks and technical functions related to or required by a specific occupational field. This definition aligns with the definition for "occupational skills training" at 20 CFR § 681.540.
  • 3 DWD-DET uses several methods to verify an institution's FEIN, including: IRS.gov, Wisconsin's Unemployment Insurance database, and official Internal Revenue Service (IRS) forms, such as a FEIN designation letter.
  • 4 An entity can apply for a Federal Unique Entity Identifier (ID) free of charge on SAM.gov.
  • 5 2 CFR § 180.320; 20 CFR §§ 683.200(d) & 683.250(a)(4). DWD-DET uses SAM.gov to verify this information. DWD-DET reserves the right to investigate whether any owner or principal associated with an institution is federally debarred, suspended or otherwise excluded from or ineligible for participation in federal programs or activities. If it is the case that the owner or principal is debarred, suspended or otherwise excluded, the institution, by extension may be determined ineligible for the ETPL website.
  • 6 DWD-DET uses the Wisconsin Department of Revenue's Delinquent Taxpayer Search to verify this information.

7.4.7 Standard vs. Alternate Eligibility Criteria

Effective date: July 25, 2022

If an institution meets the Minimum Institution Requirements, DWD-DET classifies the institution as either "Standard" or "Alternate;" different program eligibility criteria apply depending on the institution's classification.

DWD-DET classifies an institution as "Standard" if it determines that the institution meets at least one of the following standard eligibility criteria:

  • it is part of the University of Wisconsin System, the Wisconsin Technical College System, or the Wisconsin Association of Independent Colleges and Universities;
  • it is a public out-of-state university, technical college, or community college;1
  • it is a fully accredited tribal college or university;
    OR
  • it is an out-of-state institution providing distance education that is approved by the National Council for State Authorization Reciprocity Agreement (NC-SARA) and it will include only distance education programs on Wisconsin's ETPL.

If an institution is not a Standard institution, DWD-DET classifies the institution as an "Alternate." An Alternate institution must demonstrate, when applicable, that it has approval or licensure by the appropriate Wisconsin state-level regulatory authority to provide the training program at issue. This means that an institution subject to Wisconsin's Educational Approval (EAP) regulatory authority must demonstrate it has secured approval from the EAP before its program can be determined eligible for Wisconsin's ETPL. This also means that an institution that is required to obtain approval or licensure by another Wisconsin state agency(ies) or board(s) – in addition to, or in lieu of, the EAP – must demonstrate it has secured such approval or licensure before its program can be determined eligible for Wisconsin's ETPL. When applicable, DWD-DET follows internal procedures in an attempt to ensure training institutions are compliant with state approval or licensing requirements.

For purposes of Wisconsin's ETPL, any program that uses the term "pre-apprenticeship" in its program application must be certified by Wisconsin's Bureau of Apprenticeship Standards, and, any WIOA Title II program must be approved as an "Integrated Education and Training" program by the Wisconsin Technical College System Office.

With some exceptions, if an Alternate institution and/or the training program it would like included on Wisconsin's ETPL are not regulated by the EAP or another Wisconsin state agency or board, the institution must attest to this and meet all of the following before a program can be determined eligible for Wisconsin's ETPL:

  • the institution meets all requirements in Wis. Stats. Ch. 180. DWD-DET will verify on the Wisconsin Department of Financial Institutions' (DFI) website that the institution is registered and current with its organizational filings. If the institution is exempt from the requirement of obtaining a Certificate of Authority from DFI, the institution must supply documentation showing that it qualifies for the exemption. DWD-DET reserves the right to request additional documentation showing that the institution is registered and current with its organizational filings in its state of organization.
  • the institution is current on all Wisconsin unemployment insurance tax obligations.
  • the institution is compliant with worker's compensation insurance coverage requirements as outlined in Wis. Stats. Ch. 102.
  • the institution submits one letter of support from an employer that is on the employer's official letterhead and contains the following:
    • the name and address of the employer,
    • a date, including the year,
    • identification of the Alternate institution and the specific training program(s) offered by that institution that the employer supports,
    • a statement from the employer that demonstrates its history of or experience with hiring students who complete the training program and/or the employer's desire to hire students who complete the training program,
    • a signature – physical or digital – from an employer representative who is in a leadership position with the employer (e.g., owner, president, vice president, director, or other executive), and
    • the job title of the signatory.

    Note: The institution may submit two additional letters of support to be published on the ETPL website; however, all letters must comply with the above criteria for them to be published. DWD-DET reserves the right to substantiate or verify any of the letter of support criteria.

  • the institution must be "presently responsible." DWD-DET reserves the right to request information or other documentation to demonstrate this. Providers that have engaged in criminal or other improper conduct of such a compelling and serious nature that it would lead one to question their honesty, ethics, or competence will not be considered presently responsible.

DWD-DET will determine, on a case-by-case basis, whether these additional eligibility criteria apply. For example, some types of training institutions and/or programs are regulated by federal agencies or authorities and, as a result, may be determined to be excepted from these additional eligibility requirements.

  • 1 DWD-DET may require institutions to provide documentation to determine if they meet this criterion.

7.4.8 Information Requirements

Effective date: January 9, 2020

PLEASE NOTE – The information in this section reflects the current fields in the ETPL Provider Portal. This information will be updated in the Spring of 2022 to align with the policy and process updates addressed in section 7.0.2 of this manual.

In an effort to streamline and standardize data collection from institutions, DWD-DET requires institutions to submit information consistent with federal ETP performance reporting requirements. Furthermore, DWD-DET requires and requests some additional information that the local WDBs consider helpful when participants and career planners evaluate training programs.

Institution-Level Information

DWD-DET requires institutions, other than registered apprenticeships, to complete and submit an Institution Application through the ETPL Provider Portal. The online application contains fields for the following information:

Field Required DOL1 or DWD-DET Requirement
Name of Institution Y DOL
Institution's Federal Employer Identification Number (FEIN)2 Y DWD-DET
Institution's address for its main location (city, state, and 5-digit zip code) Y DOL
Institution's phone number Y DWD-DET
Institution's website N DWD-DET
Institution's date of establishment Y DWD-DET
Type of Institution3 Y DOL
Institution's description Y DOL
Institution's accreditation information4 Y DWD-DET
National Council for State Authorization Reciprocity Agreement (NC-SARA) membership5 Y DWD-DET
Wisconsin Education Approval Program (EAP) status6 Y DWD-DET
Contact information for the individual submitting the Institution Application Y DWD-DET

Program-Level Information

DWD-DET requires institutions, other than registered apprenticeships, to submit program-level information through the ETPL Provider Portal. The institution will be asked to supply the following information for each program it would like on the ETPL:

Field Required DOL7 or DWD-DET Requirement
General Program Information
Name of training program Y DOL
Wisconsin Technical College System (WTCS) Program ID (if applicable) Y DWD-DET
URL for information about the training program N DOL
Training program description Y DOL
Classification of Instructional Programs (CIP) code8 Y DOL
O*NET-SOC code(s) associated with the training program9 Y DOL
Training program format (in-person, online, or combination) Y DOL
Minimum education required for entry Y DOL
Additional prerequisites (if applicable) Y DWD-DET
How often the training program is offered N DWD-DET
Whether the training program is competency-based Y DOL
Length of the training program (in weeks) Y DOL
Hours per week a student spends attending class or other instructional activities Y DOL
Whether the training program is full-time, part-time, or both N DWD-DET
Whether classes are offered during days, evenings, and/or weekends N DWD-DET
Whether the training program is part of a career pathway10 N DWD-DET
Whether the training program is in partnership with a business11 Y DOL
Whether the training program offers job placement services N DWD-DET
Whether the training program offers tutoring N DWD-DET
Application deadline(s) for the training program N DWD-DET
Any program credit hours N DWD-DET
Training program's date of establishment N DWD-DET
Site name and address for the training program (city, state, and 5-digit zip code)12 Y DWD-DET
Point of contact for the training program and the individual's contact information Y DWD-DET
Point of contact for disability and language accommodation services N DWD-DET
Potential outcome of the training program13 Y DOL
Name of credential received for completion of the training program14 Y DOL
Cost of tuition and required fees Y DOL
Cost of books Y DOL
Cost of supplies / materials Y DOL
Cost of other program fees and description of fees N DWD-DET
Whether financial aid is available for the training program Y DWD-DET
The refund policy Y DWD-DET
Individual-Level Information for All Students15
Student's first name Y DWD-DET
Student's middle initial N DWD-DET
Student's last name Y DWD-DET
Student's suffix N DWD-DET
Student's SSN16 N DWD-DET
Student's sex17 Y DWD-DET
Student's date of birth18 Y DWD-DET
Student's actual program start date Y DWD-DET
Student's actual program end date N* DOL
Whether the student completed the program N* DOL
Whether the student withdrew from the program N* DOL
Whether the student transferred from the program N* DOL
Whether student attained a credential during the program19 N* DOL
Whether the student attained a secondary school diploma or its recognized equivalent during the program20 N* DOL
Program Information for Alternate Institutions (only one is required)
Program accreditation information21 N DWD-DET
Whether the training program relates to barbering, cosmetology, real estate, substance abuse counselor, aesthetics, electrology, manicuring, medication aide, certified nursing assistant, or lead and/or asbestos removal training N DWD-DET
Whether the training program relates to Community Based Residential Facilities (CBRFs) and, if so, the name(s) and instructor ID(s) for all the instructor(s) N DWD-DET
Whether the training program is a pre-apprenticeship N DWD-DET
Whether the training program is on another state's ETPL and the name of the state22 N DWD-DET
Letter of support from a trade association N DWD-DET
Letters of support from three employers N DWD-DET

* This field is required if the student has an actual program end date because the student completed, withdrew or transferred from the program.

  • 1 DOL requires several data elements as part of annual ETP reporting. See DOL's ETA-9171.
  • 2 DWD-DET uses IRS.gov and Wisconsin's Unemployment Insurance database to verify FEINs. If DWD-DET cannot verify the institution's FEIN, the institution will be asked for its Dun & Bradstreet D-U-N-S Number via email.
  • 3 DOL requires that an institution select whether it is: (1) an institution of higher education that only awards or primarily awards associate's degrees, (2) an institution of higher education that that only awards or primarily awards bachelor or higher degrees, (3) an institution of higher education where the majority of credentials awarded are community college certificates of completion or technical diplomas, (4) an institution that is a Registered Apprenticeship provider, (5) an institution that is a private non-profit provider, (6) an institution that is a private for-profit provider, (7) an institution that is a public provider, or (8) an institution that is a type not already listed.
  • 4 DWD-DET requires that the institution indicate if it is accredited by an accrediting organization approved by the Council for Higher Education Accrediting (CHEA). CHEA is considered the largest national advocate for promoting academic quality through accreditation. It is an association with approximately 3,000 degree-granting colleges and universities and recognizes 60 institutional and programmatic accrediting organizations, including the Higher Learning Commission.
  • 5 NC-SARA is a voluntary agreement among its member states and U.S. territories that establishes comparable national standards for interstate offering of postsecondary distance-education courses and programs.
  • 6 The Wisconsin EAP is a postsecondary education regulatory agency that evaluates and approves private trade, technical, career, distance learning, and degree-granting schools.
  • 7 DOL requires several data elements as part of annual ETP reporting. See DOL's ETA-9171.
  • 8 DOL requires one CIP code for a program. CIP codes may be accessed online; a lookup table is also available in the ETPL Provider Portal.
  • 9 DOL requires at least one O*NET-SOC code but allows institutions to report up to three for a program. O*NET-SOC codes may be accessed online; a lookup table is also available in the ETPL Provider Portal.
  • 10 DWD-DET determined that the term "career pathway" used for purposes of the ETPL does not have to meet the definition used at WIOA sec. 3(7).
  • 11 20 CFR § 680.450(e)(3)
  • 12 DWD-DET does not require online-only programs to provide site information.
  • 13 DOL requires the institution to select at least one potential outcome for the training program from the following list: (1) an industry-recognized certificate or certification, (2) Certificate of Completion for a registered apprenticeship, (3) a license recognized by the state involved or the federal government, (4) an associate's degree, (5) a bachelor's degree, (6) a community college certificate of completion or technical diploma, (7) a secondary school diploma or its equivalent, (8) employment, (9) a measurable skill gain leading to a credential, or (10) a measurable skill gain leading to employment. Institution staff should make the selection(s) to the best of their knowledge. DWD-DET, however, reserves the right to modify the type of program outcome(s) published on the ETPL website based on DOL's guidance on WIOA-recognized credentials. If changes are made, DWD-DET will notify the institution. DWD's Performance Advisory Committee (PAC) periodically reviews programs' selected outcomes and makes the ultimate determination on whether the selections meet WIOA's definition.
  • 14 DOL requires this information if a credential is listed as a potential outcome.
  • 15 DWD-DET requires the institution to submit a .csv file of individual-level information for all students, by program year, to fulfill its DOL annual ETP performance reporting requirements. Institutions that are part of Wisconsin's Technical College System (WTCS) are not required to submit the .csv file for programs that are assigned a unique WTCS identification number because the WTCS Office supplies DWD-DET with the information needed for annual ETP performance reporting. WTCS institutions must, however, submit the .csv file for any program that is not assigned a unique WTCS identification number.
  • 16 Students' SSNs are needed to perform employment and wage matching to the State's Unemployment Insurance data. This is done as part of DOL-required performance reporting. If institution staff do not submit student SSNs for a program, DWD reports a "0" for that program's employment and wage outcomes on the published ETPL. If staff submit an incomplete list of student SSNs, DWD-DET reports the average of verified outcomes and publishes the average, along with the percent of students that were verified for that program.
  • 17 This field is required to help ensure accuracy of employment and wage matching to the State's Unemployment Insurance data.
  • 18 This field is required to help ensure accuracy of employment and wage matching to the State's Unemployment Insurance data.
  • 19 This field is required for students who are indicated as having an actual program end date.
  • 20 This field is required for students who are indicated as having an actual program end date.
  • 21 The institution may indicate if the training program is accredited by an accrediting organization approved by the Council for Higher Education Accrediting (CHEA).
  • 22 If the institution indicates the training program is on another state's ETPL, DWD-DET requires that it provide the name of the state (only one state is required, even if the training program is on multiple states' ETPL).

7.4.9 "Incomplete" Application Status

Effective date: March 16, 2022

Institution and program applications submitted to DWD-DET for review are considered incomplete when DWD-DET does not have all the information needed to make an eligibility determination. If DWD-DET notifies the institution of an action that needs to be taken (e.g., electronically sign the ETPL Agreement or supply certain information), the institution must complete that action within 90 days. If the institution fails to complete the action within 90 days from DWD-DET's notification, DWD-DET will deny the application and notify the institution of the same. The institution may submit a new institution or program application for consideration at any point following a denial for this reason.



Individual Training Account

Effective date: September 2, 2019

An Individual Training Account (ITA) is the payment the local WDB or its service provider makes, on behalf of a participant, to a training institution for training services, when the institution and the program of interest are included on the State's Eligible Training Programs List (ETPL).

20 CFR § 680.300



Officer

Effective date: September 2, 2019

The training institution's Officer is typically an owner, president, vice president, other executive-level representative of the institution, board director, provost, chancellor, or dean.

The Officer is an individual who, acting on behalf of the institution, is authorized to (1) sign the ETPL Agreement and (2) designate individuals who manage ETPL Provider Portal user access for the institution.



Competency-based Training

Effective date: December 1, 2019

DWD-DET defines "competency-based training" as a program that requires its students to demonstrate they have successfully acquired a set of skills or knowledge base prior to completing the program. Compare to a "time-based" training program that results in successful completion if the students participate in a certain number of instructional hours.

DWD-DET uses 29 CFR § 29.5 on registered apprenticeships to help define the term "competency-based training."

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