COORDINATING LOCAL WORKFORCE DEVELOPMENT

Connecting the Carl D. Perkins Vocational and Technical Education Act
to the Workforce Investment Act

In anticipation of the State Workforce Investment Board approving Local Workforce Investment Boards (LWIB) in early 2000, this memorandum is intended to give guidance to Perkins III postsecondary formula fund recipients with respect to their responsibilities under the Workforce Investment Act (WIA), particularly in reference to initiating a Memorandum of Understanding (MOU) with the LWIB, regarding the coordination and funding of a local One-Stop system.

General Responsibilities:

In addition to fulfilling requirements under Perkins III, all recipients of Perkins III postsecondary funds are mandatory One-Stop partners under WIA and must fulfill the responsibilities set out in Title I of WIA. These responsibilities include:

• Representation on the LWIB. Remember that all recipients of Perkins III postsecondary funds are mandatory One-Stop partners. As such, recipients are automatically entitled to membership on the LWIB. However, in order to keep Board membership manageable, localities may need to select a representative to serve on behalf of all recipients;
• Entering into an MOU with the LWIB relating to the operation of the One-Stop system. This MOU will include a description of services, how the cost of the identified services and operating costs of the system will be funded, and methods for referral;
• Making available applicable core services through the One-Stop delivery system, either in lieu of or in addition to making these services available at the program site; and
• Using a portion of Perkins III funds to "create and maintain" the One-Stop system.

Core services are defined as the following:

• Information concerning the performance and cost of career programs;
• Initial assessment of skill levels, aptitudes, abilities, and supportive service needs of individuals prior to their entry into a career program; and
• Information relating to the availability of supportive services, including child care and transportation, available in the local area and referral to such services as appropriate.

Responsibilities for Supporting One-Stop Activities and Services

It is noted that, regardless of how they choose to use Perkins III funds, each recipient must provide information to the One-Stop system regarding the performance of the recipient’s entire career program (as required in Perkins III) as well as the cost to individuals of enrolling in these programs. The Perkins III postsecondary provider should strongly consider negotiating MOU language that allows for the use of the annual performance report which is issued by the State Education Department for each provider to satisfy the WIA performance requirements.

Generally, the information about support services provided at the comprehensive One-Stop Center should be comparable to the information made available to an individual at the Perkins III program site.

One-Stop partners and the LWIB have been provided the flexibility to determine the most appropriate means of providing core services. Applicable core services may be made available by the provision of appropriate technology at the One-Stop, by co-locating personnel at the Center, cross-training of staff or through cost reimbursement or other agreements between service providers at the Center. The manner in which these core services are made available must be described in the MOU.

Core services must be made available at the comprehensive One-Stop Center. Services may also be provided at the Perkins III program site.

Perkins III postsecondary grantees must also provide access at the One-Stop to other services and activities provided through Perkins III.

The responsibility for providing applicable core services must be proportionate to the use of the services at the One-Stop by the individuals attributable to the Perkins III funded program activity. This means that the use of Perkins III funds to support One-Stop services is restricted to those individuals who are enrolled in a career and technical education program.

Responsibilities for Supporting One-Stop Administrative Operations

Decision-making regarding the contribution of Perkins III funds to the operating cost of the One-Stop is negotiated with the LWIB as part of the MOU. Contributions may be cash or in-kind. Factors that must be taken into account during this negotiation include:

• Proportionality. How individuals who can be attributed to Perkins program activities use the One-Stop system . The level or intensity of services provided may also be considered in applying this principle;
• Limitations on administrative cost under Perkins III. While contributions to the One-Stop may be in-kind or cash, cash contributions to the One-Stop are presumptively administrative and are part of the 5% maximum indirect cost;
• Allowable cost. Grantees may only contribute towards costs that are allowable under Perkins III; and
• Supplanting. The Perkins III prohibition applies to WIA.

Additional Information

The requirement for Perkins III postsecondary fund recipients to enter into an MOU, which includes the above responsibilities, does not take effect until the State Workforce Investment Board approves an LWIB. Recipients who have already entered into formal agreements to support existing local One-Stop efforts should review these agreements, consider the above requirements, and anticipate any necessary amendments.

Be aware that postsecondary providers may use funding sources other than Perkins III to support One-Stop services and operations. Also, keep in mind that covering costs for One-Stop services should be a shared responsibility. Some of these services, such as assessment and counseling, may target enrolled career students. It may be appropriate for the Perkins III postsecondary provider to negotiate that these services be supported by WIA Title I funds.

While not required, it may suit the interests of a recipient to enter into MOUs with multiple LWIBs.