Purpose
The purpose of this policy is to clearly articulate the Passaic County Workforce Development Board Incumbent Worker Training (IWT) framework in alignment with both federal and state guidelines. This document provides essential information regarding IWT as it pertains to local policy and guidance. The primary objectives of the Incumbent Worker Training funded through the Workforce Innovation and Opportunity Act (WIOA) are to prevent potential layoffs of employees and to enhance the skill sets of the workforce, thereby facilitating opportunities for promotion and creating backfill positions within the organization.
Employer Eligibility
As outlined in WD-PY21-4 (pp. 3-4), to qualify for Incumbent Worker Training funding, individuals must meet the following criteria:
- Be currently employed.
- Comply with the Fair Labor Standards Act (FLSA) requirements regarding the employer-employee relationship.
- Have a documented employment history with the employer for a minimum of six months. This period may include time as a temporary or contract worker who has performed work for the employer that is receiving IWT funds.
PCWDBs must take into account specific criteria when assessing eligibility for IWT, including:
- The connection to in-demand occupations.
- The standing and reputation of the employer.
- The potential benefits to employees.
- Characteristics of the trainees.
- The quality of the training provided.
While IWT is primarily intended for private sector employers, there may be exceptions allowing non-profit and local government entities to receive these funds. However, support for IWT in local government entities should not surpass 10% of the combined Title I Adult and Dislocated Worker allocations (p. 3).
Documentation and Reporting
WD-PY21-4 (pp. 2) mandates that specific outcomes data must be collected and reported in the AOSOS system for all individuals participating in IWTs. This includes information regarding employment retention and wage levels. Participants in IWTs who are not enrolled as Title I participants will be reported as WIOA Reportable to USDOL and will not be included in WIOA performance measures.
Priority of Eligibility
As stated in WD-PY21-4 (pp. 5-6), PCWDB prioritizes workings for incumbent work services by providing an assessment of participant characteristics, particularly focusing on those with barriers to employment, as priority should be given to incumbent workers facing such challenges.
When assessing potential participants for incumbent worker training, it is essential to evaluate whether they face specific barriers to employment. Priority should be given to incumbent workers who encounter such challenges, as addressing these barriers can enhance workforce participation and retention.
It is crucial to consider how the proposed training initiative will enhance the competitiveness of the employer. Training efforts that provide clear advantages to the employer’s market position should be prioritized, as they contribute to overall organizational growth and sustainability.
The training opportunity should offer unique professional development or training experiences that do not duplicate existing programs within the organization. It should complement and enhance current professional development strategies, thereby providing additional value to both the employees and the employer.
PCWDB will document the six-month work history of participating employees, ensuring compliance and accountability via email and/or phone monthly.
To verify an employee’s employment history of at least six months, the following steps are followed:
- Collection of Employment Records: Obtain official documentation such as pay stubs that clearly indicate the employee’s start date and ongoing employment status.
- If necessary, request the employee to provide an employment verification letter on company letterhead, detailing the start date, current employment status, and position held.
Employer Contributions
As specified in TEGL 19-16 (pp. 17-18), employers are responsible for covering the non-Federal share of the costs associated with incumbent worker training. WIOA Sec. 134(d)(4)(D) mandates that Local WDBs establish policies regarding this non-Federal share, which can include both cash payments and appropriately evaluated in-kind contributions.
The minimum employer contribution is determined by the size of the organization, as follows:
- 10% of the training cost for employers with 50 or fewer employees.
- 25% of the training cost for employers with 51 to 100 employees.
- 50% of the training cost for employers with more than 100 employees.
