Action Required
Programs affected include but are not limited to:
• Workforce Innovation and Opportunity Act (WIOA) Title 1-B Adult
• WIOA Dislocated Worker and Minnesota Dislocated Worker programs
• Trade Adjustment Assistance (TAA)
• Pathways to Prosperity
• Adult Workforce Development Program
• Minnesota Adult Workforce Development Program
• Women in High Earning Non-Traditional Jobs (WESA)
• And other state appropriations under the WDD
The completion and implementation of an IEP is an integral part of the delivery of employment and training services. Organizations receiving funds to administer programs for adult job seekers must create an IEP for each enrolled participant. The IEP outlines the responsibilities of both the participant and the service provider as the participant prepares to achieve the program goal of full-time, long-term, unsubsidized employment at the most realistic and highest possible wage (see “Required Components” section in this policy).
Service providers must keep IEPs current to ensure all parties involved are accountable for their responsibilities. Training, support services, and intensive services cannot be incurred, obligated, or distributed until after the participant is enrolled AND the participant and employment counselor have signed and dated the IEP.
Definition
Individual Employment Plan: A record of an individual’s work plan and goals. This document is an ongoing strategy to identify employment goals, achievement objectives, and an appropriate combination of services including support services.
Objective Assessment: An examination of the capabilities, needs, and vocational potential of a participant.
Required Components of a Complete IEP
I. Participant’s full, legal name (including middle name(s)) must be recorded on the IEP. If, while enrolled, the participant’s name changes, service provider must update the IEP and participant’s file must contain legal documentation of the name change. Acceptable documentation includes any one of the following:
A. legal certificate of name change,
B. driver’s license, or
C. social security card.
II. Eligibility documentation
A program-specific eligibility document must be completed at intake. This document must be in participant’s file. The program-specific eligibility document must include justification for the participant’s enrollment as per program-specific eligibility criteria.
Dislocated Worker (DW) and National Dislocated Worker Grants (NDWG) Only: If determining eligibility for DW (including NDWG), must include documentation attached to IEP, to support “Unlikely to Return” (see DW Eligibility Policy). The service provider must make this determination prior to enrollment into the DW program, using regional labor market information which provides justification that the individual will not return to their previous occupation.
III. Objective Assessment
A. All participants must receive an objective assessment. The assessment should include consideration of the participant’s:
• work history,
• education and basic skills,
• occupational skills,
• interests,
• aptitudes (including interests and aptitudes for non-traditional occupations),
• obsolete skills or skill gaps,
• family or other caregiving needs,
• need for any accommodations,
• support service needs (including transportation or housing needs), and
• legal assistance to reduce job search barriers.
B. Method of Objective Assessment: The service provider will choose the most appropriate way to conduct the Objective Assessment of the participant. Methods will include at least one of the following:
• structured interviews,
• performance tests (e.g. skill and/or work samples),
• observational assessment,
• interests and/or attitude inventories,
• career guidance instruments,
• aptitude tests, and/or
• basic skill assessments (math and reading skills test).
Objective assessment is an on-going process. The service provider must review any additional information about a participant as it becomes available and adjust the IEP as appropriate.
C. Skills Assessments: Every participant in pursuit of training (see Credentials and Training Policy) who has attained less than a bachelor's degree?must take a basic skills assessment (math and reading).?The results of their standardized skills assessment must be documented in the participant’s case file or IEP prior to beginning the training.
IV. Employment Goal
All participants must have:
A. a written employment goal, which considers non-traditional employment; and
B. documented justification for the employment goal; this justification will include action steps and required services; the justification must be on and/or attached to the IEP; and
C. appropriate intermediate objectives, including training objectives; and
D. documentation to support training (e.g. LMI data, etc.) and support services planned.
Note: Individual instances of support services are not required on the IEP.
The service provider must include projected completion dates for each objective and goal on the IEP. IEPs must be updated when a goal is reached or the completion date passes (see “Updating the IEP” below).
The service provider must develop the IEP jointly with the participant and remain consistent with nondiscrimination and equal opportunity laws and policies. When developing the IEP, the service provider must inform the participant whether enrollment in an education program will require the participant to pay a portion of the cost.
Procedure
An IEP is a living document. It must be updated on an on-going basis as a participant’s needs or information changes. Service providers may house the IEP electronically in WF1 or on paper in the participant’s file and reflect in WF1 that the paper IEP exists. If using a WF1 IEP, service provider must attach a printed copy of the IEP with signatures and date of signatures from the participant and service provider.
I. Updating the IEP
A. Original Signatures: DEED requires signature and date on the original IEP from the participant and service provider. The IEP is not complete without these dated signatures.
B. The service provider should re-evaluate the appropriateness of the participant’s training plan, where applicable. This includes an evaluation of the participant's progress in acquiring basic skills and occupational skills as appropriate, and the adequacy of the supportive services provided. The service provider must include the results of each monthly live contact in case notes. (Policy Pending)
C. Annual IEP review: If the participant is or will be enrolled for longer than 365 days, DEED requires the service provider to review the IEP formally with the participant on an annual basis (TAA participants exempt).
1. Annual review must occur between 335 – 395 days, which is 30 days before or after the year mark of 365 days after the original signatures were obtained on the IEP.
2. Annual review must include a re-evaluation of the participant’s plan. The service provider must update the IEP as appropriate.
3. The service provider must obtain new dated signatures from the service provider and the participant.
4. The service provider must file documentation of the annual IEP review in the participant’s file. Acceptable documentation of the annual IEP review can either be on the original IEP or on a separate updated IEP. If changes to the IEP are not necessary, a notation on the IEP explaining why changes are not required along with the signatures of both participant and counselor. Additionally, counselors will note the participant’s current status.
II. Co-Enrollment across other WDD programs
When co-enrolling within one service provider, one completed IEP for a WDD program will be accepted by other WDD program. Enrollment in one program does not necessarily guarantee enrollment in any or all other programs. Eligibility and available resources in each of these programs governs co-enrollments. Service providers should ensure the employment goal, action steps, and appropriate services are kept current on the IEP, and a copy of the participant’s IEP is accessible to all programs in which that participant is enrolled or made available upon request by DEED staff. The IEP must be updated to denote co-enrollment status of participant in other programs.
When co-enrollment occurs within one service provider, coordination of services is strongly encouraged to streamline services and prevent unnecessary duplication of staff time and effort.
DEED reserves the right to disallow costs due to failure to comply with any component of this policy.
Q: Do we have to list each support service we provide the participant on the IEP?
A: No, you do not need to list each separate support service you provide but your assessment of support service needs as a whole should be documented and up-to-date on the IEP.
Q: Is it necessary to have the math and reading scores on the IEP?
A: No, you do not need to record the actual score on the IEP, but please have a copy of the scored assessment in the participant’s file.
Q: Is it necessary for us to print the WF1 IEP and obtain signatures/dates?
A: Until we have the ability to obtain electronic signatures, printing the WF1 copy of the IEP to obtain signatures is required.
Q: Will RTAA/ATAA participants who are co-enrolled be required to have an annual IEP review?
A: No, those who are co-enrolled in TAA and receiving RTAA/ATAA benefits are exempt from the annual IEP review.
Q: Do we need to update name changes in WF1 and does the “full name” include their middle name?
A: Please update WF1 and make a note on the IEP if the participant’s name has legally changed; obtain a copy of one of the acceptable forms to document this name change, then file in participant’s file. Yes, please include the participant’s middle name. It is possible that names are similar or identical, for this reason, a middle name is required on the IEP if the participant has one.
Q: Is gathering additional information on the name change necessary since we already change the name in WF1 and document in the case notes?
A: Yes, it is important for DEED to be able to document the path of the funds. If a participant is put through training and later, their name changes, DEED needs to be able to document funds originally used to put that participant through training especially if their certificate of completion is awarded under a different name.
Q: The policy states that the IEP must be updated when the completion of a goal is accomplished or the completion date has passed, does this need to be documented on the IEP or in case notes?
A: It must be documented on the IEP. Case notes should support the IEP.