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Resolution —The delegation form is used to delegate ETPL responsibilities (including <br />providers/programs) to another Local Board. Individual providers cannot be delegated to <br />another Local Board. If a provider moves its headquarters from one Local Area to another, the. <br />responsibility for that provider changes, and both Local Board ETPL Coordinators should be <br />made aware of the change. <br />Eligibility <br />General Eligibility <br />Comment #27— Can Local Boards place the burden of proof on providers to prove that their <br />programs meet the requirements for eligibility? <br />Resolution — Local Board staff are required to review programs to ensure they meet eligibility <br />requirements, including credentials. Once all necessary information is entered, the Local ETPL <br />Coordinator must review and nominate the training provider and/or program for inclusion on <br />the CA ETPL ensuring all information provided is complete, accurate, and current, and is in <br />alignment with this Directive. <br />Comment #28— What documentation is required to demonstrate a provider's partnership <br />with local businesses? <br />Resolution —This will vary depending on the Local Board and their local policy. The state will <br />allow Local Boards to decide what is considered "in partnership with business. <br />Comment #29— Will the negotiated goals be the same as WIOA title I programs or will there <br />be different ones for training provider programs? <br />Resolution — Programs must meet the performance requirements described in the continued <br />eligibility section of the Directive, as well as the state -level Title I Adult performance goal. <br />Comment #30— Why are training providers that do not award degrees and solely provide <br />educational programs for total charges of $2,500 not allowed? If a provider has a BPPE <br />exemption, it is unclear if a WIOA-funded ITA is considered Federal student financial aid and <br />therefore ineligible. <br />Resolution —This exemption prohibits any federal funding be used to pay for this program, <br />thus excluding WIOA funding from being used. Section 74110 of the CEC defines public funding <br />as "any financial aid paid on behalf of students or directly to an institution from any public <br />source," which includes WIOA. <br />initial Eligibility <br />Comment #31— Performance requirements for initial eligibility limit customer choice and local <br />autonomy by removing the ability for new training providers to be added to the ETPL without <br />performance data. The Draft Directive does not specify the source of the performance metrics. <br />If in the past, it will come from a provider's BPPE Annual Report, this will further inhibit a Local <br />Board's autonomy as BPPE is currently two years behind in publishing performance data and, <br />in fact, does not even allow a provider to upload data until September for publication in <br />Page 7 of 25 <br />