WIOA waiver request to allow the use of unobligated balances from the Governor’s Reserve for supplementary allocations to local areas experiencing significant cuts:
1. The statutory and/or regulatory requirements the state would like to waive:
The state requests a waiver of WIOA Section 128(a), which governs the use of Governor’s Reserve funds for statewide activities. Specifically, the state seeks permission to utilize any unobligated balance remaining after funding required activities under 20 CFR § 682.200 to supplement the sub-state allocations for local areas that experience significant year-to-year cuts in their WIOA Title I Adult, Youth, and Dislocated Worker program allocations. This waiver would allow the state to ensure that no local area experiences a reduction greater than 15% of the prior year’s allocation, provided sufficient funds are available.
2. Actions the state has undertaken to remove state or local barriers:
The state has engaged with local workforce development boards and the Governor’s Workforce Council to develop a policy that mitigates the volatility of WIOA funding. By leveraging the Governor’s Reserve unobligated balances, the state has sought to protect local areas from drastic funding cuts, allowing for more stable and consistent delivery of services. Additionally, the state has conducted a review of local workforce plans to ensure alignment with the new funding policy and to identify any administrative or regulatory obstacles to implementation.
3. A description of the state’s strategic goal(s):
The strategic goals of the state are:
- Stabilize Funding: Ensure that local workforce areas receive predictable and stable funding, allowing them to deliver uninterrupted services and maintain strong partnerships with employers and service providers.
- Enhance Workforce Outcomes: Support local areas in providing consistent career services, training, and youth programs, resulting in better employment outcomes and higher credential attainment rates for job seekers.
- Strengthen Employer Engagement: By ensuring continuous funding, the state aims to maintain long-term partnerships with employers, allowing for the delivery of tailored workforce solutions that meet regional labor market needs.
- Promote Equity: Prevent disproportionate cuts to funding that could negatively impact disadvantaged and underserved populations, ensuring equitable access to workforce development programs.
4. A discussion of how the waiver complements Department of Labor priorities:
This waiver aligns with several U.S. Department of Labor priorities, including:
- Improved Employer Engagement: Consistent funding allows local areas to maintain strong relationships with employers, establishing apprenticeships, on the job trainings, and other work-based learning activities to meet employer and labor market needs.
- Support for Vulnerable Populations: By mitigating drastic cuts, the waiver ensures uninterrupted services for vulnerable populations, including disadvantaged youth, displaced workers, and underserved communities, aligning with the priority of increasing access to services for all job seekers. A primary value of this funding stabilization will be the increased ability to avoid staff layoffs, ensuring the consistency in case managers for the individuals served as well, which we anticipate will have a positive effect on performance.
5. Quantifiable projected programmatic outcomes resulting from implementation of the waiver:
Projected Outcomes based on consistency in service delivery, avoiding interruptions with stabilized funding:
- Increased Q2 Employment: With supplementary funding, the state expects fewer service disruptions, resulting in a projected 3% increase in second quarter after exit employment rates over the next program year.
- Improved Training Outcomes: Local areas are expected to maintain stable partnerships with training providers, leading to a projected 5% increase in individuals completing occupational skills training compared to the previous year.
These projections were based on the performance of the Eastern, Northwest, and Southwest regions, which face the largest funding cuts for PY24 based on the formula funding allocations to the state of Connecticut. Specifically, in terms of Employment Second Quarter After Exit for the Northwest and Eastern regions (and Dislocated Worker funding for the Southwest), the negotiated goals are on average 9.3% lower than their actual PY23 preliminary, not adjusted, rates. This reduction reflects concerns that with fewer resources, regions may struggle to match prior performance levels, although efforts will be made to meet these targets.
Similarly, the Credential Rates in these regions were also negotiated for PY24 9.3% lower than their PY23 preliminary, not adjusted, rates. While credential outcomes can vary, the state believes that stable funding will support better training completion rates due to the consistency of case managers supporting participants.
The projected 3% and 5% increases are compared to the PY23 preliminary, not adjusted, rates, allowing for a consistent comparison between PY23 and PY24 outcomes.
6. Individuals, groups, or populations benefitting, or otherwise impacted by the waiver:
- Dislocated Workers: These individuals will benefit from uninterrupted access to training and career services, improving their chances of reemployment.
- Youth (In-School and Out-of-School): Youth populations will benefit from stable access to leadership development, internships, and work experience programs, enhancing their career pathways.
- Low-income and Disadvantaged Populations: Consistent supportive services, such as transportation and childcare, will allow these groups to continue participating in workforce programs without disruption.
- Employers: Employers will benefit from continuous partnerships with workforce boards, enabling them to fill critical skill gaps through training, apprenticeship, and on-the-job training programs.
7. How the state plans to monitor waiver implementation, including collection of measurable waiver outcome information:
The state will monitor waiver implementation through regular budget and performance reviews conducted by the state workforce agency. Specific measures include:
- Monthly Expenditure Reports: Tracking the use of Governor’s Reserve funds for supplementary allocations and ensuring compliance with state and federal requirements.
- Performance Metrics: Monitoring programmatic outcomes such as job placement rates, credential attainment, and measurable skill gains among WIOA participants in affected local areas.
- Quarterly Stakeholder Feedback: Local workforce boards will provide feedback on the effectiveness of the supplementary funding and report any challenges to ensure continuous improvement.
The state will also conduct annual evaluations of the waiver’s impact, measuring progress toward meeting the quantifiable targets outlined in the waiver request.
8. Assurance of state posting of the request for public comment:
The state assures that this waiver request will be posted for public comment for a minimum of 30 days on the state workforce agency’s website. Notification of the public comment period will also be sent to all local workforce development boards. Comments will be collected, reviewed, and incorporated into the final waiver request, with a summary of the comments and responses included in the submission to the U.S. Department of Labor. The draft waiver was made available for public comment on 11/4/24, with the comment period closing on 11/22/24.
NOTE: Please share any comments to CTDOL.workforceadmin@ct.gov and erica.tew@ct.gov.