10.6 Incentive Payments

10.6.2 Local Policy/Procedure Requirements

Effective date: September 4, 2018

If a local WDB chooses to use incentive payments, it must have written policies and procedures in place that:¹

1. clearly identify the types of program milestones that qualify for incentive payments and award amount(s);
2. specify any limitations (e.g., maximum amount in incentives a participant may receive during the period of participation);
3. align with the local WDB's organizational policies;²

AND, DWD-DET requires that policies and procedures ensure that the incentive payments are:

4. administered in a manner so that all participants receive equal rewards for equal achievements;
5. outlined in the participant's individual service strategy (ISS) before the start of the program element for which the incentive payment is available; and
6. processed through a voucher or similar method.

Note: The local WDB's policies and procedures must be outlined in writing before it can start awarding incentive payments.³ If a local WDB adds new opportunities for incentive payments, those must be covered by the local WDB's written policies and procedures before they can be extended to participants.

Note: Incentives for entertainment costs are prohibited.⁴ Examples include tickets for movies or sporting events, or gift cards to movie theaters or other venues whose sole purpose is entertainment.⁵ Additionally, local WDBs must follow 2 CFR part 200 requirements related to internal controls to safeguard cash and gift cards, which are essentially cash.⁶ The procurement of non-cash incentives must follow standard procurement procedures as stipulated in the Uniform Administrative Requirements, 2 CFR §200.318-320.

• ¹20 CFR §681.640
• ²20 CFR §681.640(c)
• ³20 CFR §681.640(b)
• ⁴2 CFR §200.420-475
• ⁵2 CFR §200.420-475
• ⁶81 FR 56186 and TEGL 21-19, p. 10

10.6.3 Activities that Local WDBs Cannot Incentivize

Effective date: August 26, 2021

Local WDBs cannot use WIOA funds for incentives to motivate activities that are not directly tied to work experience, education, or training-related program milestones. Prohibited activities include those related to recruitment, submitting eligibility documentation, and participating in the program.¹ Specific examples of activities for which local WDBs cannot use WIOA funds to provide incentive payments include:

• Enrolling in WIOA Youth Program services
• Referring a friend to the WIOA Youth Program
• Providing documentation/information for program eligibility
• Attending career counseling sessions or career awareness activities
• Choosing a career pathway
• Communicating/keeping in touch with Youth Program staff
• Participating in services
• Researching Labor Market Information (LMI) data
• Completing financial literacy education activities, including completion of a budget
• Completing a wellness plan
• Completing driver's education for a regular (non-commercial) driver's license or earning a regular (non-commercial) driver's license²

Local WDBs may leverage non-WIOA funds for incentives that WIOA cannot fund.

• ¹TEGL 21-16, p.10
• ² Guidance received during US DOL Youth-State Liaisons Call on 07/20/21. DOL Federal Project Officer advised that WIOA funds may not be used to incentivize obtaining a driver's license; the license itself is the incentive.

10.6.4 Documentation Requirements

Effective date: September 4, 2018

• The participant's ISS must identify the work experience, education or training that s/he plans to undertake and the corresponding incentive award(s) to be provided.
• The participant's file must include documentation of the achievement of each milestone for which s/he received an incentive.
• The incentive payment(s) must be recorded in ASSET.
• The payments must be documented and processed through a voucher or similar method.