12.7 CEPT Employment Plan Documentation

12.7.1 General Overview

Effective date: TBD

The Comprehensive Employment Planning Toolkit (CEPT) housed in ASSET serves as tool to assist career planners with performing individual employment plans (IEPs) and individual service strategies (ISSs) tasks. CEPT helps support active participation with IEPs and ISSs for participants through the collaboration with career planners. This active collaboration between career planner and participants enables participants to become more involved towards their goal of education and employment.

An employment plan (EP) identifies a participant's employment goals, sets appropriate achievement objectives, and identifies an appropriate set of services to help the participant achieve their employment goals.¹ It is developed jointly² by the participant and career planner.³ The EP serves as a continuous strategy to help the participant reach their employment and/or educational goals. Therefore, the career planner must update the EP to reflect participant needs.⁴

This policy and guidance are specific to documenting the creation and updates of IEPs and ISSs. DWD-DET requires career planners to use CEPT while a participant is enrolled in Title 1 Adult, Title 1 Dislocated Worker, and Title 1 Youth Programs.

• ¹ WIOA Sec. 134(c)(2)(A)(xii)(II); 20 CFR § 678.430(b)(2)
• ² DWD-DET substitutes the term "acknowledge" for the 20 CFR § 680.170 requirements that the IEP is developed jointly by the participant and career planner.
• ³ 20 CFR § 680.170
• ⁴ 20 CFR § 680.170

12.7.2 CEPT Transition Expectation

Effective date: TBD

For existing participants, DWD-DET requires career planners to transition from the participant's current employment plan to the CEPT Employment Plan Tool during the plan's next review.

Note: This includes reviews and/or updates that do not require an acknowledgment as described in Section: Employment Plan Reviews and/or Updates for an IEP and ISS.

12.7.3 Title I Adult Program and the Dislocated Worker Program: Individual Employment Plan

Effective date: TBD

It is developed jointly¹ by the participant and career planner.² The IEP serves as a continuous strategy to help the participant reach their employment and/or educational goals. DWD-DET requires the IEP to be guided by the results of the initial, comprehensive, specialized assessments,³ which means the need for all planned services to be identified.

An acknowledged IEP is required for Adult Program and Dislocated Worker Program participants before a participant receives any participation-causing service (other than assessments) funded through Title I-B, as outlined in 8.3.1 Order of Services. CEPT is able to better assist with electronic communication between career planners and participants in obtaining these acknowledgements for IEPs.

Note: If a participant needs a service(s) before an IEP REVIEW can become active, the career planner can deliver those services if the services were first identified as planned services on a previous or updated assessment and acknowledged IEP.

Employment plan review requirements for CEPT Employment Plans are listed below in the IEP Reviews and/or Updates That Require A Participants Acknowledgment Section and ISS Reviews and/or Updates That Do Not Require Participants Acknowledgment Section

• ¹ DWD-DET substitutes the term "acknowledge" for the 20 CFR § 680.170 requirements that the IEP is developed jointly by the participant and career planner.
• ² 20 CFR § 680.170
• ³ In ASSET, the applicable services are "Initial Assessment of Interests, Skill Level & Supportive Service Needs" and "Comprehensive Individualized or Specialized Assessment." This DWD-DET requirement for Adult Program and Dislocated Worker Program IEPs is consistent with WIOA's Youth Program requirement that individual service strategies and IEPs be based on assessment results. This requirement also helps provide seamless transitions from Dislocated Worker services as required by TEGL 19-16, p. 35.

12.7.4 WIOA Title I Youth Program: Individual Service Strategy

Effective date: TBD

An ISS identifies a participant's education and employment goals, appropriate achievement objectives, and the services that will help lead to goal attainment.¹ Program elements added to the ISS must align with the goals identified on an ISS. Career planners must review the ISS with the participant on an ongoing basis that is in accordance with local policy. Further ISS details are located in Chapter 10.2.4 Individual Service Strategy.

Employment plan review requirements for CEPT Employment Plans are listed below in the ISS Reviews and/or Updates That Require A Participants Acknowledgment Section and IEP Reviews and/or Updates That Do Not Require Participants Acknowledgment Section.

• ¹ WIOA Sec. 129(c)(1)(B)

12.7.5 Employment Plan Required Contents

Effective date: TBD

Goals for Title I Adult Program and Dislocated Worker Program

DWD-DET requires an IEP to have an employment goal. The employment goal must be an occupation or career exploration.¹ For the long-term Career Goal, enter a specific career area or occupation. The employment goal of the plan may be different from the long-term goal and self-sufficiency goal associated with the plan. If these goals are the same for an individual, then only a single goal may need to be completed. See example below showing a participant with multiple goals for a single plan:

• For the Employment goal of the plan the participant is seeking to become a Certified Nursing Assistant (CNA)
• The participant has chosen for a long-term goal to become a Nurse Practitioner (NP)
• For the participant to become self-sufficient the participant needs to become a Registered Nurse (RN)

Each goal has a different occupation the participant wants to obtain. Another example below showing a participant with two different goals for a single plan:

• The participant's Employment goal of the plan is to become a RN
• The participant's long-term goal of the plan is to end with becoming a NP
• The self-sufficient goal set for the plan is RN

The participant has two goals, Employment goal and self-sufficient goal, with the same associated occupation. The final example below will show a participant with a single goal for a plan:

• The participant's Employment goal of the plan is to become an Electrical Power-Line Installer
• The participant's long-term goal of the plan is to become an Electrical Power-Line Installer
• The participant's self-sufficiency goal of the is an Electrical Power-Line Installer

Goals for The Title I Youth Program

DWD-DET requires an ISS to have either an employment goal or an education goal. If your youth participant is not in career exploration, you must input information in both the Short-term Goals and Long-term Goals sections. Youth participants in career exploration, career planners can enter short-term goals to assist the career exploration. For the short-term goals, you must indicate both a short-term employment goal and short-term education/training goal. For the long-term Career/Employment Goal, select a specific occupational category (1st dropdown), then select a subcategory (2nd dropdown)and occupation (3rd dropdown).

Career Exploration for WIOA Title I

During the time that career exploration is the goal of an IEP or ISS, DWD-DET only allows career planners to provide services for two reasons:

1. to allow participants to take part in activities related to career exploration, or
2. to help the participant gain employment to provide an income while s/he decides on a career goal.
   Note: DWD-DET considers work experience as an allowable service during "Career Exploration," while on-the-job training, incumbent worker training, and apprenticeships are not allowable.

Select supportive services such as Transportation Assistance and Childcare are allowable when these are needed to help the participant participate. No other services or program elements, including training services, may be provided while career exploration is the goal of a participant's IEP or ISS.

An initial Employment Plan with career exploration as a goal must include necessary supportive services, and the participant and the career planner must acknowledge this plan.

Job Fit Review

When is the Job Fit Review Required?

Only participants in "Career Exploration" are required to complete a Job Fit Review when creating a new IEP or updating an IEP. DWD-DET recommends the participant to complete a job fit review for the occupational goal identified in the new plan whenever a job fit review is available for that occupation.²

Note: DWD-DET does not require Job Fit Review completion for youth participants with an ISS.

The Job Fit Review is completed after selecting the occupation, but before the participant acknowledges the IEP. Participants can complete the Job Fit Review using In the MyJCW Employment Plan tool, or career planners can record participants' Job Fit Review responses in CEPT's Employment Plan tool. Once the Job Fit Review is complete, the participant can acknowledge the IEP.

If a Job Fit review is unavailable for the participant's selected occupation, DWD-DET requires the career planner to use an assessment outside of CEPT. If an outside assessment is used, the career planner must follow the documentation steps below:

1. In the Job Fit Review section of the CEPT Employment Plan, select the box "Job Fit Review was completed outside of CEPT"
2. Go into ASSET Documents
   1. Select "Title 1" from Category drop-down
   2. Select "Assessments" from Document Type drop-down
   3. Select "Title 1 Adult or Title 1 Dislocated Worker" from Program drop-down
   4. Select "Assessment" from the Select Purpose drop-down
   5. Upload the Job Fit Review Assessment
3. Record in ASSET via a case note

Potential Barriers

DWD-DET requires career planners to identify and describe a participant's potential barriers to attaining and retaining the specified employment and/or education goals by adding the category. If additional needs not available in the list, you must enter them in the comments box of the Potential Barriers section. If the participant has no potential barriers, DWD-DET requires career planners to enter a note to that effect in the comments box.

Note: By identifying and describing a participant's potential barriers in the IEP or ISS, the career planner documents the need for supportive services provided to the participant.

Services and Planned Services

DWD-DET requires all participation-causing services or program elements be documented on the participant's IEP or ISS.³ Career planners may not provide these service(s) or program element(s) until it has been added to the participant's IEP or ISS and is acknowledged by both the career planner and the participant. Services or program elements do not need to be added to the IEP or ISS if they were created only to change the funding source or contract ID.

DWD-DET requires that all planned services be documented on the participant's IEP or ISS.⁴ If a participant's planned service is never provided, career planners should document the reason why the planned service was never provided in either an ASSET Case Note or within the planned service's "Comments Box," career planners must document this within 10 calendar days of its "Planned Service Start Date." Some examples of possible reasons that a planned service would never be provided include but are not limited to:

• the participant indicated they no longer wish to receive the service;
• a participants assessment results changed when the previous assessment results initiated the planning of the service;
• the participants IEP or ISS goal changed;
• the participant no longer required the service due to reaching their IEP or ISS goal;
• the service or funding for the service became unavailable;
• the participant exited participation from the Title I program before the service could otherwise be provided; or
• the participant did not attend the service as planned.

Action Steps

DWD-DET requires adding action steps to the Employment Plan. The action steps must relate to the goal(s) of the Employment Plan for the participant. Once the employment plan is in draft form, determine what action steps are needed to achieve the identified goals.

Note: The career planner must review the action steps added by the participant in MyJCW and add applicable action steps to the plan.

• ¹ Some participants may require a period of career exploration before choosing a goal occupation.
• ² The job fit review portion of the IEP is based on data from O*NET. It involves participants assessing their comfort with the tasks, skills, and knowledge needed to succeed in the goal occupation identified in the plan. A job fit review is not available for all occupations because the required O*NET data is not available for all occupations.
• ³ 20 CFR § 618.350(c)(3) requires that TAA staff document each service on the IEPs before it can be provided to the participant. DWD-DET is modeling this TAA requirement for use in the CEPT Employment Plan Title I Programs.
• ⁴ 20 CFR § 618.350(c)(3) requires that TAA staff document "any services that will be needed" on the IEPs before the service can be provided to the participant. DWD-DET has changed this language to "planned services." DWD-DET is modeling this TAA requirement for use in the CEPT Employment Plan Title I Programs.

12.7.6 Participant Acknowledgment of Initial Employment Plan

Effective date: TBD

Acknowledgment of the Initial Employment Plan is required to consider the plan active. To demonstrate that the Employment Plan was developed jointly by career planners and participants, DWD-DET requires that participants acknowledge this initial Employment Plan.¹ Career planners can document participant acknowledgment in one of the following ways:

1. the CEPT / MyJCW applications' electronic acknowledgment functionality. In CEPT, an acknowledged plan automatically displays the participant's name alongside the time and date of acknowledgment (see example);
   
   
   
   Note: For participants co-enrolled in one or more programs, CEPT only allows one career planner to instigate participant acknowledgment.


2. uploading an electronic copy of a printed-and-signed Employment Plan to ASSET's Documents Upload > Category (Title I) > Purpose (Employment Plan) field.
   
   Local WDBs may determine how career planners convert a signed, paper copy of the Employment Plan into an electronic copy (photograph, scan, electronic fax, etc.); OR


3. an email from the participant stating that they have reviewed, acknowledged, or otherwise accepted the initial Employment Plan. DWD-DET requires the e-mail chain to contain an electronic copy of the Employment Plan (image, .pdf file, etc.).
   
   A copy of the email must be uploaded into ASSET's Document Upload > Category (Title I) > Purpose (Employment Plan) field.

Note: For items 2 and 3, career planners must upload the appropriate Employment Plan acknowledgment documentation into ASSET before the participant exits. Career planners must upload the documentation within 30 calendar days of the actual date of acknowledgment. DWD-DET notes a participant may exit before documentation is received.

DWD-DET requires the Employment Plan created date in CEPT to match the Open Actual Service Date for the ASSET IEP Development service. The Approval date in CEPT must match with the Close Actual Service Date for the ASSET IEP Development or Review service.

Note: For an Initial Employment Plan to be considered active the plan must be acknowledged by the participant and associated fields in the plan must be completed.

• ¹ 20 CFR § 680.170 requires that Title I IEPs are developed jointly by career planner and participants.

12.7.7 Deleted and Incomplete Employment Plans

Effective date: TBD

Employment Plans a career planner and a participant begin and do not become active can be either deleted or marked as incomplete.

When to delete a plan: Delete an Employment Plan with inaccuracies or never makes it to the participant acknowledgment step. To delete the plan, the career planners must select the "delete" button in CEPT to complete the process.

Note: Career planners may recover a deleted Employment Plan by submitting a Staff Request.

When to mark a plan Not Complete: Career planners select the not complete function when the participant does not want to acknowledge the plan. Once the career planner has confirmed the participant will not acknowledge the plan, they must update the "IEP Development or Review" service Completion Code in ASSET as "Did Not Complete This Service." Confirmation of the contact with the participant must be recorded in ASSET via a case note. Next, career planners must select the "Not Complete" button in CEPT. The Employment Plan will become inactive, and the career planner can create a new one.

For plans intended to be reviewed/updated that do not require a participant's acknowledgement and the Career Planner does not make changes. The Career Planner selects "This plan does not require participant acknowledgement" box. Enter the date, then select save. The plan will become active and can be reviewed/updated according to the next review date.

12.7.8 Employment Plan Reviews and/or Updates for an IEP and ISS

Effective date: TBD

This section includes documentation requirements for EP reviews and updates. See the IEP and ISS policies for requirements.

Reviews and updates to Employment Plans are separated into two categories, reviews and updates that require the participant's acknowledgment and reviews and updates that do not require a participant's acknowledgment.

Note: Employment Plan reviews and updates are only considered active when the plan is acknowledged.

The review timeline restarts each time the career planner and the participant review the employment plan, regardless of the need for the participant's acknowledgment. Below are examples based on a 90-day review format:

• A career planner updates a participant's Employment Plan by removing an action step or a supportive service. This update occurred 60 days from the previous active plan date. The new required review date is now 90 days from this updated active plan date.
• A career planner reviews and updates a training service in a participant's Employment Plan, which the participant acknowledges. The reviewed and updated plan occurred 20 days from the previous active plan date. The new review date is 90 days from the new active date.
• A non-participating causing service is added to the Employment Plan 80 days from the previous active plan date. The new review date is 90 days for the updated active plan date.

DWD-DET requires career planners to collaborate with participants for IEP review service or ISS program element.

Note: ASSET case notes should reflect the actual dates and details of the service, action step, or barrier identified, and the next scheduled IEP or ISS review date.

Career planners are allowed to change the employment goal of the Employment Plan. A change to the employment goal will require closing the existing IEP and opening a new IEP. Career Planners are able to follow the below steps when changing the employment goal of the Employment Plan:

1. Select "Not Completed" from the Select Plan Outcome dropdown menu.
2. Click the "Close Plan" button.
3. A pop up box will populate asking, "Once you have closed this plan there is no way to reopen it. Are you sure you want to close your plan?" select ok.
4. The existing IEP with the old employment goal is now closed. The career planner can select the Employment Plan tool from the CEPT dropdown in the ASSET menu.
5. Select the "add" button from the Employment Plan tool main page.
6. Select the "Programs Other Than Youth Program (IEP)" box.
7. Go to My Goals field of the Employment Plan.
8. Select the green circle with a white plus sign and continue to search for the new occupation.
9. Career planners add/update necessary information in the Job Fit Review, Potential Barriers, Services, Action Steps fields.
10. Send IEP to participant for acknowledgement.

Note: Career planners that need to change a short-terms and/or long-term goals for an ISS do not need to follow the above steps. The goals for an ISS can be updated without completing the steps above.

IEP Reviews and/or Updates That Require A Participants Acknowledgment

DWD-DET requires a participant to acknowledge a reviewed and/or updated Employment Plans when any of the following changes occur for the plan to be considered an active Employment Plan:

1. Non-participation causing service of Referral is added to the participants plan;
2. Participation causing career service(s) is added to the participants plan;
3. Training service(s) is added to or removed from the participants plan;
4. Barrier(s) added from the participants plan;
5. Barrier(s) is removed, if not completed from the participants plan;
6. A supportive service(s) is added or removed from the participants plan;
7. Action step(s) is added to the participants plan; or
8. The employment goal is changed.

Career planners must create a new version of the IEP in CEPT (all content from the previous version is automatically carried forward to the new version). After the review and/or changes have been made to the new version, the participant must acknowledge the document. Acknowledgment from the participant will show the review/update was performed jointly. DWD-DET requires the same review documentation as is listed in the Employment Plan Required Contents section.

Participants may not receive the new services or engage in steps that were added and not previously identified on the comprehensive assessment during the review and/or update (i.e., services or action steps not identified on the previous active version of their plan) until the new Employment Plan is acknowledged by the participant and career planner thus making the plan active.

DWD-DET requires the applicable Employment Plan versions' created date in CEPT to match the open date for the ASSET "IEP Development or Review" service. The approval date in CEPT is to match the close date for the ASSET "IEP Development or Review" service.

IEP Reviews and/or Updates That Do Not Require Participants Acknowledgment

DWD-DET does not require reviews and/or updates of Employment Plans outlined below to be acknowledged by participants:

1. Non-participation causing career service(s), excluding Referral, is added or removed from the participants plan;
2. Participation causing career service(s), if completed, is removed from the participant's plan;
3. Barrier(s) is removed, is no longer impacting participant, from the participants plan;
4. Action step(s) is removed from the participants plan; or
5. The Employment Plan has no changes
   Note: If a barrier is removed from the participant's plan, the career planner is required to enter a case note to explain why the barrier is no longer impacting the participant.

Career Planners must follow the below procedure to document the Employment Plan review:¹

1. Career planners must record the contact in ASSET (via a case note or service, in accordance with state and local policy);
2. Career planners record an IEP Review service in ASSET, using actual service dates matching the contact;
3. Career planners log into CEPT, and visit the participant's Employment Plan;
4. Career planners click the "Update/Review" button;
5. Career planners navigate to the newly created version of the Employment Plan;
6. In the "Acknowledgment" section, career planners:
   1. Click the "Plan Does Not Require Participant Acknowledgement" checkbox;
   2. Enter text describing an acknowledgement was not needed for review or update;
   3. Enter the Actual Service date of the IEP Review service in ASSET;
   4. Enter ASSET case note describing acknowledgement was not needed for review or update; and
   5. Click "Acknowledge";²
7. Enter ASSET case note describing acknowledgement was not needed for review or update.
   Note: A review and/or update that does not require a participants acknowledgment occurs most frequently from participants in long-term training, who give training-related updates, but require no new or updated training services, removal of supportive services, or new or updated Employment Plan goal(s).

ISS Reviews and/or Updates That Require Participants Acknowledgment

DWD-DET requires a participant to acknowledge a reviewed and/or updated ISS when any of the following occur for the plan to be considered active:

1. Program Element(s) is added or removed from the participants plan;
2. Partner Program Participation service(s) is added to the participants plan;
3. Barrier is added to the participants plan;
4. Barrier(s) is removed, if not completed from the participants plan
5. New action step(s) is added to the participants plan; or
6. A change to short-term or long-term goals.

Career planners must create a new version of the ISS in CEPT (all content from the previous version is automatically carried forward to the new version). After the review and/or changes have been made to the new version, the participant must acknowledge the document. Acknowledgment from the participant will show the review/update was performed jointly. DWD-DET requires the same review documentation as is listed in the Employment Plan Required Contents section.

Participants may not receive any newly added service(s) during the review or update (i.e., services not identified on the previous active version of their plan) until the new Employment Plan is acknowledged by the participant and career planner, thus making the plan active.

DWD-DET requires the applicable Employment Plan versions' created date in CEPT to match the open date for the ASSET "IEP Development or Review" service. The approval date in CEPT is to match the close date for the ASSET IEP Development or Review service. The dates in CEPT are related to the active applicable Employment Plan.

ISS Reviews and/or Updates That Do Not Require Participants Acknowledgment

DWD-DET does not require a participant's acknowledgement for ISS reviews and/or updates when any of the following occur for the plan to be considered active:

1. Pre-Enrollment service(s) is added or removed from the participants plan;
2. Partner Program Participation service(s), if completed, is removed from the participant's plan
3. Barrier(s) is removed, is no longer impacting participant, from the participants plan;
4. Action step(s) is removed from the participants plan; OR
5. The Employment Plan has no changes
   Note: If a barrier is removed from the participant's plan, the career planner is required to enter a case note to explain why the barrier is no longer impacting the participant.

If a participant's ISS does not require any changes, and the career planners have contacted the participant within 90 days or timeline that is in accordance with local policy of the last completed Employment Plan, career planners may follow the below procedure to document the Employment Plan review:³

1. Career planners must record the contact in ASSET (via a case note or service, in accordance with state and local policy);
2. Career planners record an IEP Review service in ASSET, using actual service dates matching the contact;
3. Career planners log into CEPT, and visit the participant's Employment Plan;
4. Career planners click the "Update/Review" button;
5. Career planners navigate to the newly created version of the Employment Plan;
6. In the "Acknowledgment" section, career planners:
   1. Click the "Plan Does Not Require Participant Acknowledgement" checkbox;
   2. Enter text describing an acknowledgement was not needed for review or update;
   3. Enter the Actual Service date of the IEP Review service in ASSSET; and
   4. Click "Acknowledge";⁴
7. Enter ASSET case note describing acknowledgement was not needed for review or update.
   Note: An ISS review and/or update that does not require a participants acknowledgment occurs most frequently from participants in long-term training, who give training-related updates, but require no new or updated training services, removal of supportive services, or new or updated Employment Plan goal(s).

• ¹ DWD-DET considers an Employment Plan with a review and/or update that does not require a participants acknowledgement "developed jointly" as required in 20 CFR § 618.110, 618.350(f)(2) and 680.170 because the career planner and participant have previously documented their "joint [development]" through a previous acknowledgement. DWD-DET intends to align this policy with local policies requiring career planners to contact participants within 30 or 60 days; requiring an additional 90-day communication and acknowledgment could create barriers to the participant accessing program services.
• ² DWD-DET is including documentation of IEP Reviews in CEPT in part to gather detailed information in its CEPT Dashboards and BI Data Warehouse for program improvement purposes.
• ³ DWD-DET consider an Employment Plan with no change to be "developed jointly" as required in 20 CFR § 618.110, 618.350(f)(2) and 680.170 because the career planner and participant have previously documented their "joint [development]" through a previous acknowledgement. DWD-DET intends to align this policy with local policies requiring career planners to contact participants within 30 or 60 days; requiring an additional 90-day communication and acknowledgment could create barriers to the participant accessing program services.
• ⁴ DWD-DET is including documentation of IEP Reviews in CEPT in part to gather detailed information in its CEPT Dashboards and BI Data Warehouse for program improvement purposes.

12.7.9 Employment Plans for Co-enrolled Participants

Effective date: TBD

When a participant is co-enrolled in two or more programs that use the CEPT Employment Plan tool, career planners from those programs must coordinate efforts and use a shared plan. DWD-DET requires collaboration if a goal needs changed, or services removed and encourages career planners to consult with career planners from other programs before making changes to a shared plan. Career planners must not remove services not associated with their program, add services not associated with their program, close a plan, or create a new plan without the consultation and approval of the co-enrolled programs career planner(s).

Note: Only a single Employment plan is required to be opened. CEPT does not allow for multiple Employment plans to be opened for participants enrolled in two or more programs.

For co-enrolled participants, DWD-DET will only look for one "IEP Development or Review" service in ASSET, as well as one Active Employment Plan in CEPT. DWD-DET requires the same documentation showing review as is listed in Employment Plan Required Contents and Employment Plan Reviews and/or Updates for an IEP and ISS.