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Effective date: July 1, 2024 - September 30, 2024
Incumbent worker training (IWT) activities are carried out by the local WDB for the purpose of increasing the competitiveness of the employee or employer.1
Incumbent worker training is intended for workers with an established work history with the current employer and who have the knowledge, skills, and abilities needed by their current employer but now need additional training because of changes in the necessary skills to:
Incumbent worker training is the most appropriate training service for retraining existing employees as a layoff aversion strategy.3
An individual receiving incumbent worker training does not need to meet the eligibility requirements for the WIOA Adult Program or the WIOA Dislocated Worker Program in order to receive the IWT service.5 However, in order to receive career services or training services beyond the IWT service, that individual must meet WIOA Title I eligibility criteria for the WIOA Title I Adult or Dislocated Worker Program.6
To qualify as an incumbent worker, an individual must:
An exception to the employment history requirement exists only in the event that the incumbent worker training is being provided to a cohort of employees. In this case, it is not required that every employee in the cohort has worked for the employer for six months or more, as long as the majority of employees in the cohort meet this requirement.8 However, incumbent worker training is not permitted for providing the occupational training that new hires need; OJT or customized training would be more appropriate in this circumstance.9
Incumbent worker training is carried out by the local WDB in conjunction with an employer or a group of employers of incumbent workers, which may include employers in partnership with other entities for the purposes of delivering training.10
An employer must be determined eligible to receive incumbent worker training funds based on an evaluation of whether training would increase the competitiveness of the employees or both the employees and the employer. The WDB must consider the following criteria when determining the employer's eligibility for participating in IWT:
DWD-DET does not permit local WDBs or their WIOA Title I-B service providers to be employers in WIOA-funded IWT contracts.
Local WDBs may develop incumbent worker training strategies that best fit the needs of the local Workforce Development Area. Acceptable uses of IWT funds include:
Local WDBs may set aside up to 20 percent of their total allocation of Title I Adult and Dislocated Worker funds (including administrative funds) for covering the federal share of the cost of providing incumbent worker training.15 For example, if a local WDB receives $1.5 million in Adult funds and $1.0 million in Dislocated Worker funds, it may use up to $500,000 (20 percent of the total) for incumbent worker training. This 20 percent can be used for incumbent worker training activities that are programmatic in nature, as administrative activities must be paid out of the local WDB's administrative funds.16
Employers are required to pay the non-federal share of the cost of providing the training to their incumbent workers.17 The amount of this share will be no less than:
The non-federal share provided by the employer participating in the program may include the wages paid by the employer to the worker while the worker is attending training. The employer may provide the non-federal share in cash or fairly evaluated in-kind contributions, or both.19 Employers have flexibility in how they arrange to pay for these costs; however, payments must not come from any other federal funds.20 Employer share must be reported on the quarterly ETA-9130 financial report.
Local WDBs that choose to utilize Incumbent Worker Training as a workforce strategy must have a clear local policy that governs the use of funds for such services.21 Incumbent worker training policies must be aligned with State and Local Plans, as well as with career pathway and sector strategy approaches for in-demand occupations.22 The policy must define which workers, or groups of workers, are eligible for incumbent worker services.23 The policy may establish a local definition of the phrase "increase the competitiveness of the employee or employer."24
DOL requires that states develop a process to document the six month work-history requirement for IWT recipients with the employer and also requires that the IWT contract between the local WDB and the employer include the required work-history as a term of the contract.25 DWD-DET requires that local WDBs document the trainee's work history with the IWT employer by maintaining the trainee's ASSET record as outlined in section 11.22. Local WDBs may establish additional procedures for documenting the employment history, but, at a minimum, the state's process must be followed.
If workers receiving incumbent worker training are not participants in the WIOA Title I Adult Program or Dislocated Worker Program, they are not WIOA "participants," and thus are not included in calculations for the state's Primary Indicators of Performance.26
Local WDBs must report on individuals who receive incumbent worker training, including employment status after training and credential attainment, as detailed in section 11.22.27