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Comment #17 — If WIOA funds cannot be used for building construction, doesn't that restrict <br />Local Boards from funding apprenticeship/pre-apprenticeship programs? <br />Resolution — DOL Final Rules 683.235 clarifies that WIOA funds can't be used for construction, <br />etc. for the purposes of administering WIOA without prior approval from the Secretary of <br />State. However, in the context of apprenticeships and pre -apprenticeships, WIOA funds can be <br />used to pay for participants to be enrolled in construction programs. <br />Consumer Choice <br />Comment #18 — Does this mean the Local Board must refer the client for training and an ITA <br />regardless of the appropriateness of the training? Can an individual demand enrollment and <br />training services while demonstrating poor fitness by missing appointments, failing to meet <br />their obligations in the Individual Employment Plan (IEP), and participate in training that does <br />not necessarily fit their employment goals as long as they possess the minimum age, basic <br />skills, and/or prerequisites to do so? If so, we do not believe this is required by WIOA or <br />beneficial to the participant or the system. <br />Resolution —The America's Job Center of Californias'staff must determine training services <br />are appropriate for an individual after conducting an interview, an evaluation or assessment, <br />and career planning. If training is determined to be appropriate after meeting with a career <br />planner, the Local Board must send that participant to the training they select as long as <br />training funds have not been exhausted. Individuals maintain the right to enroll in whatever <br />program they choose, however it is the Local Board's responsibility to help individuals with <br />choosing the best program that fits their needs based on the IEP. Please see the definition of <br />Training Services in WSD19-06 for further guidance on how an individual qualifies for training <br />services. <br />Comment #19 —The CA ETPL does not permit the Local Board to approve a training program <br />that Is eligible to be paid with WIOA funding, even though the Local Board is the subject <br />matter expert on what will lead to a self -sustainable career in the local/regional economy. The <br />CA ETPL limits the choice of consumer and the Local Board to use Labor Market Information to <br />determine which courses should be deemed eligible. <br />Resolution — Local Board staff are still able to select providers to nominate that reflect the <br />needs of their Local Workforc a Development Area (Local Area). Attachment 1, page 6 states <br />"Once all necessary information is entered, the Local ETPL Coordinator must review and <br />nominate the training provider and/or program for inclusion on the CA ETPL." <br />Delegation <br />Comment #20 — Does each Local Board need to screen all ETPL schools in the Regional <br />Planning Unit (RPU) for inclusion on its local ETPL? Currently we only go through the local <br />process if a customer requests the school. <br />Resolution —Yes, as well as all CA ETPL approved distance education providers and registered <br />apprenticeships. <br />Page 5 of 25 <br />