10.5.2 Options for Administering Program Elements
Effective date: February 18, 2020
There are three ways for local WDBs to provide the 14 required program elements. A local WDB may use a combination of these options:
(1) Partnerships. Local WDBs are not required to use WIOA Youth Program funds for each of the program elements; they may partner with existing local, state, or national entities that can provide program element(s) at no cost to the local Youth Program.1 However, if a program element (or services within a program element) is not funded with WIOA Title I Youth funds, the local WDB must have a signed Youth Services Memorandum of Understanding (MOU) in place with a partner organization to ensure the partner organization will reliably offer the program element and it aligns with the goals and objectives of the local program.2 Additionally, the local WDB's contract with its youth service provider must include the requirement that the service provider refer participants who need a specific service to the appropriate partner organization with which the local WDB has a Youth Services MOU in place and, that the referral be handled in a manner consistent with the MOU. The local WDB is also responsible for letting the partner organization know the names of the current youth service providers, since it is often the service providers who directly contact the partner organization. This is accomplished by completing the MOU's Youth Service Provider Addendum and updating the Addendum if there are any changes. DWD-DET requires local WDBs to have signed Youth Services MOUs in place by July 1, 2020, for any program elements provided through partnerships.
Note: While WIOA's intent is that local WDBs establish networks of partners to provide program elements, DWD-DET recognizes that there may be circumstances in which a participant with unique needs would benefit from services from a provider outside the local WDB's network of partners. In such a circumstance, DWD-DET does not require the local WDB to establish a formal agreement in order to refer the participant for services. For example, a local WDB has a formal agreement in place with a provider for services that fall under Comprehensive Guidance and Counseling, but a participant with a unique mental health issue would benefit from another provider with specialized expertise. The local WDB could provide this referral without having to establish a Memorandum of Understanding with the specialized provider.
(2) Grants or Contracts. If a local WDB chooses to award grants or contracts to service providers, they must generally do so using a full and open competitive process.3 This competitive process must identify youth service providers based on any criteria outlined in the WIOA State Plan and take into consideration the ability of the provider to meet performance accountability measures based on the primary indicators of performance for the WIOA Youth Program.4 Furthermore, the local WDB must follow all procurement requirements in the Uniform Guidance at 2 CFR parts 200 and 2900, applicable state laws, and county-level requirements.5 If the local WDB has a standing youth committee, it may assign the committee the responsibility for selecting service providers.6
The only exception to the requirement for a competitive process occurs when the local WDB can demonstrate that there is an insufficient number of eligible service providers in the local workforce development area.7 To meet this exception, the local WDB must have a policy that defines what constitutes an insufficient number of eligible youth service providers.8 In this scenario, the local WDB may award grants or contracts on a sole source basis.9
For more information on contracting strategies to serve youth most in need, see TEGL 13-09.
(3) Direct Provision. Local WDB staff may directly provide some or all of the program elements.10 This allows local WDBs the flexibility to provide program elements when it is most efficient and cost-effective to do so; however, DOL encourages the local WDBs to use competitive procurement to award contracts when local areas have access to experienced and effective youth service providers.11 If the local WDB decides to have its staff directly provide youth services and the staff perform other functions within the local area, the local WDB and Chief Elected Official must have a written agreement in place that clarifies how the staff will carry out their responsibilities for providing direct services along with their other responsibilities and comply with any state-level conflict of interest policy.12 The agreement must provide clarity on the expectations for staff when performing their different functions and clear methods for tracking effective execution and accountability for the distinct functions.13
Note: DWD-DET, as the entity with ultimate accountability to DOL for program performance, has the authority to set policy requiring local WDBs to provide some or all of the program elements through competitive procurement.14 DWD-DET currently opts not to exercise this authority.
10.5.3 Descriptions of the 14 Youth Program Elements
Effective date: October 1, 2024
Program Element 1: Tutoring, study skills training, instruction, and dropout prevention and dropout recovery services1
The services under this program element help lead the participant towards the completion of a high school diploma, its recognized equivalent2 or a recognized postsecondary credential.3 Services are intended to keep youth in school and engaged in a formal learning or training setting. Examples include:
- academic support such as tutoring;
- helping youth identify areas of academic concern;
- assisting with overcoming learning obstacles;
- providing tools and resources to develop learning strategies;
- literacy development;
- active learning experiences;
- after-school opportunities; and
- individualized instruction.4
Depending on the service involved, local WDBs may find it appropriate to provide these services one-on-one, in a group setting, by referring participants to resources in the community, and/or through workshops.5
For ASSET reporting purposes, dropout recovery services aimed at youth who withdrew from postsecondary training/education prior to successful completion are documented under this element.6 Career planners must use element 2, "alternative secondary school services or high school dropout recovery services," to document any dropout recovery services aimed at getting a youth who has dropped out of high school back into high school or an alternative secondary school/equivalency program.7
Program Element 2: Alternative secondary school services or high school dropout recovery services
The services under this program element are intended to help youth who (a) have dropped out of high school OR (b) are currently struggling with traditional high school and would benefit from an alternative secondary school program.8 Services are aimed at reengaging youth so they pursue education that leads to the completion of high school diploma or its recognized equivalent.9 Examples of services include:
- basic education skills training;
- individualized academic instruction;
- English language learning;
- counseling related to re-engaging youth in secondary education;
- educational plan development;
- preparation for high school equivalency attainment (for high school dropouts only); and
- educating youth about alternative secondary school programs within the school district and helping them through the process of connecting to an appropriate program. 10
Program Element 3: Paid and unpaid work experience
The services under this program element provide planned, structured learning experiences that take place in a workplace for a limited period of time.11 Services are focused on providing participants with opportunities for career exploration and skill development.12 A participant's paid or unpaid work experience must be tied to the goals identified in his/her individual service strategy.13
Work experience may take place in the private for-profit sector, the non-profit sector, or the public sector and can be paid or unpaid, as appropriate.14 Virtual work experience are allowable under the WIOA youth program, so long as they are overseen by a physical representative of an employer/work site.69 DWD-DET does not permit work experience within the local WDB or service provider's workplace. The local WDB or service providers may, however, directly provide structured work experience opportunities relating to community service projects that are outside of the organization's day-to-day operations.
The following services may constitute work experience:
- employment opportunities;
- pre-apprenticeship programs;
- internships;15
- job shadowing; and
- on-the-job training (OJT) opportunities;16
- registered apprenticeship programs.70
Note: DWD-DET requires pre-apprenticeship programs to be approved by Wisconsin's Bureau of Apprenticeship Standards or funded through YouthBuild.68
This program element also includes any activities that help the youth prepare for the specific work experience17 and supportive services that enable WIOA participants to participate in work experience can count toward the work experience expenditure requirement.71
Special Waiver Note: DOL has approved a waiver for Wisconsin that allows local WDBs to increase the reimbursement rate for OJT contracts up to 90 percent for employers that have 50 or fewer employees. In order to provide the 90 percent reimbursement rate for eligible employers, the local WDB must consider the factors that apply when increasing the reimbursement rate up to 75 percent, as outlined in section 8.5.4. This waiver is effective for Program Years 24 through 27, ending June 30, 2028.
Labor standards apply in any work experience where an employee/employer relationship exists, as defined by the Fair Labor Standards Act or applicable state law.18 Additionally, Title I Youth Program funds may not be used to directly or indirectly aid in filling a job opening that is vacant because the former occupant is on strike or is being locked out in the course of a labor dispute, or the filling of which is otherwise an issue in a labor dispute involving a work stoppage.19
A work experience must include both academic and occupational education components.20 Academic and occupational education must be designed to provide participants with contextual learning that may occur concurrently or sequentially with the work experience and may occur inside or outside the work site.21 DWD-DET requires that both the academic and occupational education components of a participant's work experience relate to the same specific job or occupational area. While WIOA does not explicitly state this requirement, examples DOL provides in TEGL 21-16 (p. 16) show clear intent that the two work experience components will relate to the same specific job or occupational area.
Example: A work experience is at a hospital. The occupational education could be learning about the duties of a phlebotomist. The academic education could be learning about the different blood types and why it matters for blood transfusions. The participant might complete the academic component by reviewing an online module about blood types at home before hearing firsthand from a phlebotomist at the work site about his/her work responsibilities.
The work experience employer can provide the academic and occupational education, or it can be provided separately in the classroom or through other means.22 Local WDBs and/or their service providers have the flexibility to decide the appropriate type of academic and occupational education necessary for a specific work experience and who provides the education.23
Local WDBs must spend at least 20 percent of their WIOA Youth funding on services that fall under the work experience program element.24 DOL encourages local WDBs to coordinate work experiences, particularly local summer jobs programs, with other youth serving organizations and agencies, including Temporary Assistance for Needy Families, Community Services Block Grant, and Community Development Block Grant programs.25
Program Element 4: Occupational skills training
The services under this program element involve engaging youth in occupational skills training program. Occupational skills training is an organized program of study that provides specific vocational skills that lead to proficiency in performing actual tasks and technical functions required by certain occupational fields at entry, intermediate, or advanced levels.26
Such training must meet all three of the following criteria:
- be outcome-oriented and focused on an occupational goal specified in the individual service strategy;
- be of sufficient duration to impart the skills needed to meet the occupational goal;
AND
- lead to the attainment of a recognized postsecondary credential.27
Examples: Registered Apprenticeships, a Certified Nursing Assistant (CNA) certification; a commercial driver's license (CDL); a one-year Accounting Assistant technical diploma from a technical college; or a two-year Machine Tooling technical diploma from a technical college.
Local WDBs may provide occupational skills training through any of the options discussed in section 10.5.2 as well as through Individual Training Accounts (ITAs) for OSY28 or ISY who are 16 or older.
Youth Program participants who are 18 years of age or older may co-enroll in the WIOA Adult Program in order to receive training services funded through an ITA funded by the Adult Program.29 Additional information about co-enrollment of Youth Program participants ages 18 and older is available in section 10.4.2.
- Note: The state's Eligible Training Provider List must be used to select ITA-funded training programs.30 If the training is funded through the WIOA Adult Program, the program's priority of service and training eligibility provisions apply.
Special Waiver Note: DOL has approved a waiver for Wisconsin that allows ITAs to fund training services for Youth Program participants ages 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.
Local areas must give priority consideration to training programs that lead to recognized postsecondary credentials that align with in-demand industry sectors or occupations in the local area.31 Career planners are responsible for helping youth make informed training choices.32
Program Element 5: Education offered concurrently with and in the same context as workforce preparation and training
Services within this program element reflect an integrated education and training model in which workforce preparation activities, basic academic skills education, and hands-on occupational skills training are taught within the same time frame and connected to a specific occupation, occupational cluster, or career pathway.33
Example: A youth learns how to apply basic measuring concepts using a tape measure while ensuring lumber is the correct length to meet blueprint specifications for a new building.
While a local WDB may offer basic academic skills education as part of alternative secondary school services and dropout recovery services (program element 2), workforce preparation activities as part of a work experience (program element 3), and occupational skills training (program element 4) separately and at different times, this program element refers only to the concurrent delivery of these services within an integrated education and training model.34 Common examples of services that follow an integrated education and training model are YouthBuild and Career Pathways GED/HSED programs offered by some technical colleges.
Program Element 6: Leadership development opportunities
The services under this program element are focused on encouraging responsibility, confidence, employability, self-determination, and other positive social and civic behaviors.35 Services include:
- exposure to postsecondary educational possibilities;
- community and service learning projects;
- peer-centered activities, including peer mentoring and tutoring;
- organizational and teamwork training, including team leadership training;
- training in decision-making, including determining priorities and problem solving;
- citizenship training, including life skills training such as parenting and work behavior training;
- civic engagement activities which promote the quality of life in a community; and
- other activities that place youth in a leadership role, such as serving on youth leadership committees (e.g., a Youth Standing Committee).36
Program Element 7: Supportive services
The purpose of the services under this program element is to enable individuals to participate in WIOA activities.37 Consistent with DOL's requirements for the Adult and Dislocated Worker Programs, DWD-DET requires local WDBs to have a supportive services policy for their Youth Program.38 Supportive services include, but are not limited to:
- referrals to community programs/services and to state and federal public assistance programs;
- transportation assistance;
- child care and dependent care assistance;
- housing assistance;
- needs-related payments;
- assistance with educational testing;
- reasonable accommodations for youth with disabilities;
- services provided by legal aid organizations;
- health care referrals;
- uniforms, work attire, and work-related equipment/tools (e.g., eyeglasses and protective eye gear);
- books, fees, school supplies for postsecondary education; and
- payments/fees for employment and training-related applications, tests, certifications and licenses.39
- digital literacy access services, including devices and broadband internet service.72
- food at a reasonable cost when the participant’s situation poses an immediate need for food assistance73
Note on needs-related payments: WIOA regulations (20 CFR §§ 680.930-680.950) provide specific eligibility requirements for Adult and Dislocated Worker Program participants to receive needs-related payments (e.g., adults must be unemployed, not qualified for or receiving unemployment compensation, and enrolled in training services). However, as WIOA provides no similar direction on eligibility requirements for Youth Program participants, DWD-DET's interpretation is that local WDBs may set their own policies related to Youth Program participants' eligibility for needs-related payments; however, a local WDB must have appropriate policies and procedures in place before issuing any needs-related payments.
See the Supportive Services - Examples and Resource Guide for more information.
Program Element 8: Adult mentoring
This program element involves a formal relationship between a youth participant and an adult mentor that includes structured activities where the mentor offers guidance, support, and encouragement to help develop the youth's competence and character.40 While group mentoring activities and mentoring through electronic means are allowable services under this element, the youth must be matched with an individual mentor who provides some face-to-face interaction.41 This element may include workplace mentoring where the youth is matched with an employer or employee of a company.42
The mentoring services must last at least 12 months and may occur both during participation and as a follow-up service after program exit.43 To document mentoring services provided after a participant exits the program, the career planner must close the mentoring services in the ASSET Manage Services screen and add mentoring services in the Manage Follow-ups screen.
Local WDBs are responsible for having appropriate processes in place to adequately screen and select mentors.44
While DOL strongly prefers that career planners not serve as mentors, they may in areas where adult mentors are scarce.45
Program Element 9: Comprehensive guidance and counseling
Services under this program element are focused on individualized counseling for participants and include:
- drug and alcohol abuse counseling; and
- mental health counseling.
Services may be provided by partner programs when the resources needed do not exist within the local program.46 If the local program refers participants to outside counseling services, it must coordinate with the referral organization to ensure continuity of service.47
Program Element 10: Financial literacy education
Services under this program element are intended to help youth acquire the knowledge, skills, and confidence to make informed and effective decisions with their financial resources.48 The goal is to help youth attain greater financial health and stability by providing high quality, age-appropriate, relevant, and where possible, customized services.49 Services include:
- helping participants create budgets and open checking and savings accounts;
- helping participants learn how to effectively manage spending, credit, and debt, including student loans and consumer credit;
- teaching participants the significance of credit reports and scores, their rights regarding credit and financial information, how to assure accuracy of a credit report and correct inaccuracies, and how to improve or maintain good credit;
- helping participants understand, evaluate, and compare financial products, services, and opportunities;
- educating participants about identity theft, ways they can protect themselves from identity theft and resolve cases of it, and their rights and protections related to personal and financial data;
- benefits planning and work incentives benefits counseling for youth with disabilities; and
- providing age appropriate and timely financial education that presents opportunities to put lessons into practice, such as by access to safe and affordable financial products that enable money management and savings.50
Note: Career planners may find the Budget Planner and Self-sufficiency Calculator in CEPT useful when working with Youth Program participants. Because the Self-sufficiency Calculator requires at least one adult per household, participants under age 18 without an adult in their household will need to be entered as adults in the Household Composition section of the calculator using the "Ages 18+" field. These tools are also available for registered users as a widget in My JCW.
DOL provides a link to "Incorporating Financial Capability into Youth Employment Programs," a resource guide in TEGL 21-16 for ideas about how local WDBs can partner with local financial institutions to support the financial literacy of Youth Program participants.
Program Element 11: Entrepreneurial skills training
Services under this program element provide the basics of starting and operating a small business to develop the skills associated with entrepreneurship.51 Services include developing the ability to:
- take initiative;
- creatively seek out and identify business opportunities;
- develop budgets and forecast resource needs;
- understand various options for acquiring capital and the trade-offs associated with each option; and
- communicate effectively and market oneself and one's ideas.52
Approaches to teaching youth entrepreneurial skills include, but are not limited to:
- entrepreneurship education that introduces the youth to the values and basics of starting and running a business. Entrepreneurship education programs often guide youth through the development of a business plan and may include simulations of business start-up and operation.
- enterprise development to help youth develop their own businesses by developing viable business ideas and accessing small loans or grants that are needed to begin business operation.
- experiential programs that provide youth with experience in the day-to-day operation of a business. These programs may involve the development of a youth-run business that program participants work in and manage.53
Entrepreneurial skills training, like all other program elements, is available to participants regardless of age but must align with their individual service strategy goals.54
Program Element 12: Career Awareness, Career Exploration, and Career Counseling
Services under this program element (Career Awareness, Exploration, and Counseling) help youth make appropriate decisions about education/training and careers by providing them with information, advice, and support. Examples of services include, but are not limited to:
- providing labor market information (LMI) and employment information about in-demand industry sectors or occupations in the local area;
- helping participants use different tools and applications to gather LMI and career information;
- providing access to skill, ability, and/or interest inventories;
- discussing state and local LMI with participants;
- providing information about résumé preparation and/or assisting youth with résumé preparation;
- assisting with interview skills;
- discussing opportunities for work experience; and
- discussing the long-term benefits of postsecondary education, such as increased earning power and career mobility.55
Note: Career planners may find the Employment Plan tool in CEPT and the Career Exploration and Employment Plan widgets in MyJCW useful when working with Youth Program participants.
Program Element 13: Postsecondary preparation and transition activities
Services under this program element prepare ISY and OSY for advancement to postsecondary education and training after attaining a high school diploma or its recognized equivalent.56 Examples of services include helping youth:
- explore postsecondary education options including technical training schools, technical colleges, 4-year colleges and universities, and registered apprenticeship;
- prepare for SAT/ACT testing;
- connect to postsecondary education programs;
- navigate admissions processes;
- search and apply for scholarships and grants; and
- accurately complete the proper financial aid applications.57
Program Element 14: Follow-up services
Services under this program element are provided after program exit to help ensure the youth is successful in employment and/or postsecondary education and training.58 Some follow-up services may include other program elements; to count as follow-up services, they must occur after the participant's exit date.59 Follow-up services include:
- supportive services;
- adult mentoring;
- financial literacy education;
- career awareness, exploration, and counseling services;
- postsecondary education preparation and transition activities; and
- contact with the participant's employer, including assistance in addressing work-related problems that arise.60
Follow-up services may begin immediately following the last expected date of service in the Youth Program (and any other program in which the participant is co-enrolled) when no future services are scheduled.61 Follow-up services do not cause a participant's exit date to change or trigger re-enrollment in the WIOA Youth Program.62
Local WDBs must report follow-up services in a manner that clearly differentiates them from those services provided prior to exit.63 To accomplish this, follow-up services must be reported in the "Manage Follow-ups" screen in ASSET.
Local WDBs must offer all youth participants the opportunity to receive follow-up services that align with their individual service strategy.64 Local WDBs must provide follow-up services for a minimum of 12 months, unless participants decline to receive follow-up services or cannot be located or contacted.65 Local programs must have policies in place to establish when a participant cannot be located or contacted.66
Follow-up services may be provided beyond 12 months at the discretion of the local WDB. The types of services provided, and the duration of services must be determined based on the needs of the individual and therefore, the type and intensity of follow-up services may differ for each participant. Unsuccessful attempts to contact a participant or contacts made simply to secure documentation for program performance indicators do not count as follow-up services.67
- 1 While DOL regulations state that dropout prevention and recovery services provided under Element 1 must be "evidence-based," DOL has not defined what constitutes an "evidence-based" service. Therefore, DWD-DET will not require local WDBs to meet this requirement.
- 2 This includes a certificate of attendance or similar for individuals with disabilities. 20 CFR § 681.460(a)(1)
- 3 20 CFR § 681.460(a)(1)
- 4 TEGL 21-16, p. 14
- 5 TEGL 21-16, p. 14
- 6 TEGL 21-16, p. 14
- 7 TEGL 21-16, p. 14
- 8 TEGL 21-16, pp. 14-15
- 9 TEGL 21-16, p. 15
- 10 TEGL 21-16, p. 14
- 11 20 CFR § 681.600(a); TEGL 21-16, p. 15
- 12 TEGL 21-16, p. 15
- 13 DOL states, "the Department does require the program elements provided to a youth to align with the goals the youth set forth in the ISS." 81 FR 56177
- 14 20 CFR § 681.600(a); TEGL 21-16, p. 15
- 15 As WIOA regulations do not include a definition of "internship," DWD-DET is using a definition from other DOL guidance.
- 16 20 CFR § 681.600(c)
- 17 TEGL 21-16, p. 15
- 18 20 CFR § 681.600(a)
- 19 20 CFR §§ 680.840 & 681.600
- 20 20 CFR § 681.600(b); TEGL 21-16, p. 15
- 21 20 CFR § 681.600(b); TEGL 21-16, p. 16
- 22 TEGL 21-16, p. 16
- 23 TEGL 21-16, p. 16
- 24 20 CFR § 681.590
- 25 TEGL 23-14, p. 8
- 26 20 CFR § 681.540
- 27 20 CFR § 681.540
- 28 20 CFR § 681.550
- 29 TEGL 21-16, p. 17
- 30 TEGL 21-16, p. 17
- 31 TEGL 21-16, p. 17
- 32 81 FR 56124
- 33 20 CFR § 681.630
- 34 TEGL 21-16, pp. 17-18
- 35 20 CFR § 681.520
- 36 20 CFR § 681.520
- 37 20 CFR § 681.570
- 38 20 CFR § 680.900
- 39 20 CFR § 681.570
- 40 20 CFR § 681.490
- 41 20 CFR § 681.490
- 42 20 CFR § 681.490
- 43 20 CFR § 681.490
- 44 TEGL 21-16, p. 18
- 45 TEGL 21-16, p. 18
- 46 TEGL 21-16, p. 20
- 47 20 CFR § 681.510
- 48 20 CFR § 681.500(i)
- 49 20 CFR § 681.500(i)
- 50 20 CFR § 681.500
- 51 20 CFR § 681.560
- 52 20 CFR § 681.560
- 53 20 CFR § 681.560
- 54 81 FR 56182
- 55 TEGL 21-16, pp. 21-22
- 56 TEGL 21-16, p. 22
- 57 TEGL 21-16, p. 22
- 58 20 CFR § 681.580
- 59 TEGL 21-16, p. 19
- 60 20 CFR § 681.580
- 61 TEGL 21-16, p. 19
- 62 81 FR 56183; TEGL 21-16, p. 19
- 63 TEGL 21-16, p. 19
- 64 TEGL 21-16, p. 19
- 65 TEGL 21-16, p. 19
- 66 81 FR 56183
- 67 TEGL 21-16, p. 19
- 68 Under 20 CFR § 688.120 ("Pre-apprenticeship"), YouthBuild programs that receive funding under Part 688 of WIOA (i.e., Provisions Governing the YouthBuild Program) are considered pre-apprenticeship programs as defined in 20 CFR § 681.480.
- 69 TEGL 9-22, p. 4 while WIOA section 681.600 states that work experiences must take place in a workplace, this includes a virtual workplace when remote work experiences are possible and practical. For technical assistance resources, visit: https://youth.workforcegps.org/resources/2020/06/18/13/10/Resources-on-Virtual-Engagement.
- 70 TEGL 9-22, p. 6; TEGL 13-16. pp. 2-3
- 71 TEGL 9-22, p. 5, ETA recently determined that supportive services that enable WIOA participants to participate in training can count toward training expenditures.
- 72 TEGL 9-22, p. 5
- 73 TEGL 9-22(f)(ii), pp. 5-6,states that grant funds for food should be limited to reasonable and necessary purchases coordinated, when possible, with other community, state, or federal services that provide food for low-income individuals. Local policies and procedures regarding food as a supportive service must align with 2 CFR 200.403 and 2 CFR 200.438.