Based on the Information Collection Request (ICR) for the Workforce Innovation and Opportunity Act (WIOA) State Unified and Combined Plans, plan strategies must prioritize high-vulnerability populations including public assistance recipients, other low-income individuals, or individuals who are basic-skills deficient.
The Alliance recognizes this requirement as an opportunity to incorporate language that will prioritize collaboration between workforce boards and Continuums of Care (CoCs) to serve people who are experiencing or are at risk for homelessness into state plans.
States have already begun to release draft versions of their WIOA plans for public comment and the Alliance strongly encourages communities and homeless service providers to review and comment on these plans, or to contribute to unfinished drafts when possibl in order to ensure that resources are tapped to achieve an end to homelessness.
WIOA State Planning
- States must submit, at a minimum, a Unified State Plan with a four-year strategy for core programs of the State’s workforce development system. States may elect to submit a Combined State Plan that outlines this strategy in collaboration with one or more partner programs (e.g., Temporary Assistance for Needy Families (TANF), the Supplemental Nutrition Assistance Program (SNAP), the Department of Housing and Urban Development (HUD), and the Community Services Blog Grant (CSBG) through the Department of Health and Human Services (HHS)).
- Given the joint provisions within WIOA guidance, which require partnership with HUD-administered employment programs including Jobs Plus and the Community Development Block Grant program, combined state planning with HUD and/or other agencies can and should improve the quality and depth of service provided by all systems system. Combined State planning has the potential to identify the gaps in HUD-funded employment services and workforce development services and enhance both systems.
- Regardless of the Unified or Combined nature of a State Plan, it must include strategic and operational planning elements. Strategic elements include economic, workforce, and workforce development activities analysis; state strategic vision and goals; and a state strategy. The operational elements include state strategy implementation and state operating systems and policies.
- A State Plan must detail coordination of employment and training activities and relevant supportive services through state and local workforce development systems. States may also include proposals for innovative programs and strategies that will target high-need or vulnerable populations to combat poverty.
The following are items or concepts that homelessness services stakeholders should advocate to include in State Plans through public comment or other direct engagement in the state planning process:
- Ensure that persons experiencing homelessness are included in your State Plan as a priority population.
Under Title 1-B of the Federal Requirements, each state must provide assurances within the State Plan that priority will be given to the delivery of services to “individuals who are low-income, public assistance recipients, or basic skills deficient” in accordance with WIOA sec. 134[c][E].
The Alliance recommends that your state plan include details for how to specifically address the employment needs of homeless individuals.
The Alliance also recommends that policies and procedures for providing services to youth specifically include and identify homeless youth as a unique priority population.
- Detail how priority in the delivery of services is actualized.
The Alliance recommends that a State plan include a specific and actionable definition for providing services to priority populations, including outreach. The Alliance also suggests the establishment of a benchmark, like that of The Center for Law and Social Policy (CLASP), which recommends having at least 70 percent of those served meet the definition of priority population.
- Insist on appropriate and stringent performance measures and responsive technical assistance.
The Alliance recommends that, in accordance with sec. 106 of WIOA, criteria for determining that a local area “performed successfully” should include outcomes that reflect providing opportunity and training to homeless job seekers.
Performance measures should indicate at what points states will provide technical assistance (TA) when local areas are not achieving desired outcomes.