WIOA Title I-A & I-B Policy & Procedure Manual

Work Authorization Verification Requirements

Effective Date: October 1, 2024

Career planners may deliver many WIOA Title I services to participants without verifying a participant is eligible to work in the United States (i.e., having "work authorization").¹ Based on Title 1 of the Personal Responsibility and Work Opportunity Reconciliation Act (PRWORA), there are specific services that cannot be provided to participants without verifying work authorization documentation. The following chart lists the ASSET services and, for each service, identifies if work authorization verification using I-9 acceptable documents is required before the participant receives that service.

*Note: Once a participant has self-attested to be eligible to work in the United States, supportive services may be used to help obtain certain documents, such as a driver's license and/or a social security card, that are used to verify work authorization. See Form I-9 for acceptable documents used to validate whether a participant has work authorization. Costs for supportive services must align with all the requirements of WIOA Policy Manual 8.6.

Note: Career planners must keep expiration dates of work authorization documents in mind when scheduling services. If a participant's authorization to work in the U.S. will expire before the planned close date for a service, the participant should renew their work authorization before beginning the service. If that is not possible, services must be scheduled so that they can be completed before the work authorization expires.²

WIOA funds can support a participant renewing their un-expired Employment Authorization Documents (EAD) through the category "Services provided by legal aid organizations".³ Costs for supportive services must align with all the requirements of WIOA Policy Manual 8.6.

ASSET Service Name-Title I Adult and Dislocated Worker	Work Authorization Verification Required⁴
BASIC CAREER SERVICES – SELF/INFORMATIONAL
Financial Aid Information	No
Information about Eligible Training Program (ETPs)	No
Information on Local Area Performance	No
Intake and Orientation	No
Job Requirements Information	No
Labor Market Information (includes the following subcategories): Info on in-demand occupations/sectors Info on non-traditional occupations Other LMI	No
Referral	No
BASIC CAREER SERVICES – STAFF ASSISTED
Eligibility Determination	No
Initial Assessment of Interests, Skill Levels & Supportive Service Needs	No
Provision of referrals and associated coordination of activities	No
Job Referral/Placement Assistance	Yes
Job Search Assistance (includes the following subcategories): Information about a specific job vacancy appropriate for the participant Development of a job search plan Job search workshop Job finding club Other job search assistance	No
Resume Development	No
INDIVIDUALIZED CAREER SERVICES
Unemployment Insurance (UI) Claim Assistance	No
Career Planning	No
Comprehensive Individualized or Specialized Assessment	No
Disaster-Relief Employment	Yes
English Language Learning	No
Financial Literacy Services	No
Group Employment Counseling	No
IEP Development or Review (includes the following subcategories): IEP Development IEP Review	No
Individual Employment Counseling	No
Integrated Education and Training Programs	Yes
Job Development	Yes
Out of Area Job Search Assistance	Yes
Out of Area Relocation Assistance	Yes
Short-term Pre-vocational Services	No
Work Experience (includes the following subcategories): Internship Job Shadowing Transitional Job Other Work Experience	Yes
Workforce Preparation	No
NEEDS RELATED PAYMENTS
Needs Related Payment	Yes
PARTNER PROGRAM PARTICIPATION
All Partner Program Participation	No
SUPPORTIVE SERVICES
Supportive Services (That represent a direct financial benefit such as a voucher or reimbursement, relocation expense, or need-related payments)⁵ (See *Note)	Yes
Supportive Services (Information and referral)	No
TRAINING SERVICES
Adult Education and Literacy	No
Apprenticeship Training	Yes
Combined Workplace Skills Training & Related Instruction	No
Customized Training	Yes
English Language Instruction	No
Entrepreneurial Training	Yes
Job Readiness Training	Yes
Occupational Classroom	Yes
On-The-Job Training	Yes

ASSET Service Name-Title I Youth	Work Authorization Verification Required⁶
PARTNER PROGRAM PARTICIPATION
All Partner Program Participation	No
YOUTH PROGRAM PRE-ENROLLMENT SERVICES
Eligibility Determination	No
Individual Service Strategy (ISS) Development	No
Objective Assessment	No
YOUTH PROGRAM ELEMENTS
Adult Mentoring	No
Alternative Secondary School or Dropout Recovery Services	No
Career Awareness, Exploration, and Counseling	No
Comprehensive Guidance and Counseling	No
Education Offered Concurrently with Workforce Preparation Activities for a Specific Occupation	No
Entrepreneurial Skills Training	Yes
Financial Literacy Education	No
Incentives	Yes
Individual Service Strategy (ISS) Review	No
Leadership Development	No
Occupational Skills Training	Yes
Postsecondary preparation and transition activities	No
Supportive Services (That represent a direct financial benefit such as a voucher or reimbursement, relocation expense, or needs-related payments) (See *Note)	Yes
Supportive Services (Information and referral and fees)	No
Tutoring, Study Skills Training, Dropout Prevention	No
Work Experience: Employment Opportunity	Yes
Work Experience: Internship	Yes
Work Experience: Job Shadowing	Yes
Work Experience: On-the-Job Training	Yes
Work Experience: Pre-apprenticeship Programs	Yes

¹ TEGL 10-23, pp. 5-8 DWD-DET interprets "not yet authorized to work" as individuals who self-attested to be eligible to work in the United States but still need to obtain documentation. This does not include those who want to become work authorized.
² WIOA Sec. 188(a)(5); 20 CFR § 683.285(a)(5); TEGL 02-14, p. 2.
³ 81 FR 56158 states "legal aid can uniquely address certain barriers to employment." There are 16 organizations in Wisconsin listed in the National Immigrant Legal Services Directory provided by the Immigration Advocates Network. All but one of these list "filings with USCIS" as a service that they provide.
⁴ TEGL 10-23, p. 6-7
⁵ TEGL 10-23 p.8
⁶ TEGL 10-23, p. 6-7