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

Work Authorization Verification Requirements

Effective Date: TBD

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. 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 being eligible to work in the United States, program funded 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 program-funded supportive services must be reasonable.

ASSET Service Name-Title I Adult and Dislocated Worker Work Authorization
Verification Required2
Financial Aid InformationNo
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
Referral No
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
Resume Development No
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
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
Workforce Preparation No
Needs Related Payment Yes
All Partner Program Participation No
Supportive Services (Program funded) (See *Note) Yes
Supportive Services (Information and referral) No
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 Required3
All Partner Program Participation No
Eligibility Determination No
Individual Service Strategy (ISS) Development No
Objective Assessment No
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 (Program funded, including needs-related payments) Yes
Supportive Services (Information and referral) 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

Reasonable Cost

Effective date: October 10, 2018

Costs are considered reasonable if they are of a nature and amount that would be incurred by a prudent person under the circumstances prevailing at the time the decision was made to incur the costs. The question of reasonableness is particularly important when the non-federal entity is predominantly federally-funded. In determining reasonableness of a given cost, consideration must be given to:

  1. Whether the cost is of a type generally recognized as ordinary and necessary for the operation of the non-federal entity or the proper and efficient performance of the federal award.
  2. The restraints or requirements imposed by such factors as: sound business practices; arm's-length bargaining; federal, state, local, tribal, and other laws and regulations; and terms and conditions of the federal award.
  3. Market prices for comparable goods or services for the geographic area.
  4. Whether the individuals concerned acted with prudence in the circumstances considering their responsibilities to the non-federal entity, its employees, where applicable its students or membership, the public at large, and the federal government.
  5. Whether the non-federal entity significantly deviates from its established practices and policies regarding the incurrence of costs, which may unjustifiably increase the federal award's cost. (2 CFR § 200.404)