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									                  TO:          MCTA Staff
               FROM:           Bert R. Cene, Director
               DATE:           May 1, 2009
      POLICY NUMBER:           PM3 – ARRA Revision
             SUBJECT:          Individual Training Account (ITA) Training


To establish a procedure for administering Individual Training Account (ITA) Training in
accordance with the Workforce Investment Act (WIA) of 1998.


ITA Training services are administered by the MCTA under the authorization of the Workforce
Investment Act of 1998 and the Rules and Regulations governing Training Services for Adults
and Dislocated Workers that are defined in Sections 663.300 through 663.410 of 20 CFR.
Training Services may be made available to employed and unemployed adults and dislocated
workers who are eligible for intensive services, receive at least one intensive service and are
determined to be unable to obtain or retain employment through such services. The customer
must demonstrate a need for training through the assessment, vocational exploration and
counseling phases of core and intensive services, and be unable to obtain/retain self-sufficient
employment. The following guidelines apply to managing ITA Training services.


I. ITA Training (Occupational Skills Training) Customer Requirements:

         A. A customer must have met the eligibility requirements for intensive services (i.e., be a
            registered, eligible applicant and received at least one core service) and be unable to
            obtain or retain employment through such services.

         B. Comprehensive Assessment (Sec. 663.240) by a Career Consultant documents the
            customer’s need for training services through one or more of the following criteria: no
            marketable skill through a credential or work experience; need of enhancement to
            credential or work experience skills to be marketable; need of additional training to
            offset existing barriers* to employment (* for example: offender, substance abuse,
            disability, ...). Comprehensive Assessment also documents the customer’s
            qualifications to successfully participate in the selected program of training services.
            Prior to training, an Individual Employment Plan (IEP) which identifies the
            participant’s employment goals, appropriate achievement objectives, and the
            appropriate combination of services for the participant to achieve the employment
            goals (Sec. 663.245) shall be developed by the customer and Career Consultant.

Rev. 5-01/09 (ARRA)
       C. A program of training services is selected that is directly linked to the employment
          opportunities either in the local area, the State of Ohio, or in another area to which the
          individual is willing to re-locate. Employment opportunities are those occupations
          on the current Occupational Employment Projections Report, or other local available
          data, reflecting an increase in openings. When inspecting ‘increase in openings’ data,
          review both the percent change and the total annual openings information.

       D. A program of training services shall be selected from training locations within
          reasonable commuting distance for the customer. Limited funds preclude room and
          board as viable supportive services.

       E. Training Services shall be limited to customers who are unable to obtain other grant
          assistance for such services, including Welfare-to-Work, TAA, and PELL; or
          individuals who require WIA assistance in addition to other sources of grant
          assistance. However, customers unable to access publically supported grants and/or
          loans due to default status will not be funded with WIA monies.

       F. An Adult funding stream customer must be determined to be eligible in accordance
          with the priority system (See Priority Selection Policy- Adult), if in effect.

II. ITA Parameters
       The ITA is established to finance training services (Sec. 663.400) selected by customers
       in consultation with a Career Consultant from a list of WIA approved training providers
       (Sec. 663.410, Sec. 663.500). Note: Customers, aged 18-21, who are receiving Youth
       services shall utilize the Training Agreement to finance training services.

       A. Program of Training Services
          A program of training services in one or more courses or classes, or a structured
          regimen, that upon successful completion, leads to:

           1. A certificate, an associate degree, baccalaureate degree, or
           2. The skills or competencies needed for a specific job or jobs, an occupation,
              occupational group, or generally, for many types of jobs or occupations, as
              recognized by employers and determined prior to training (Sec. 663.508).

       B. An ITA is established for the duration of the training program (Sec. 663.420). ITA
          entries for training costs will reflect tuition, books, and fees. No costs incurred prior
          to the issuance of the ITA will be honored by MCTA.

Rev. 5-01/09 (ARRA)
       C. Each ITA is limited to a maximum of $9500 per 12 month period * (Sec. 663.420).
          An individual may select training that costs more than the maximum amount available
          for MCTA ITA’s when other sources of funds are available to supplement the ITA.
          These other sources may include: PELL Grants, scholarships, severance pay, and
          other sources (Sec. 663. 420). When the yearly training cost exceeds $9500, the
          customer must explain and document how the difference can and will be paid.
          Exceptions may be made but must be documented thoroughly in the participant files
          (IEP). Some of the reasons for exceptions to this policy could be the availability of
          training, individual customer needs, and administrative considerations such as
          performance attainment.

           *Out of area residents may be offered ITA’s capped at the amount which would have
           been available to them in the local area of residence and not to exceed $9500 per 12
           month period.

III. Training Services Parameters

       A. Only full time occupational skills training will be recognized by MCTA.

          Full time ITA Training course work at a training institution must meet the following
          1. The instruction should be no less than twelve (12) hours per week for university
              course work.

           2. The schedule of full time instruction is defined by the training provider and
              reflected on the Eligible Training Provider application.

       Exceptions may be made depending upon individual circumstances and with the approval
       of the director.

       B. ITA Training should only be provided to those customers who lack a marketable skill
          through a credential or work experience, or those customers who need skill
          enhancements to make them more employable. Customers with two (2) year degrees
          or with four (4) year degrees or more may be provided with skill enhancement courses
          to make them more employable but no other degree program should be provided by
          MCTA. Exceptions may be made depending upon marketable value of degree held
          and approval of the Director. Director approval is not required in cases where the
          degree is 10 or more years old and there is less than 2 years training-related
          work experience or Labor Market data indicates negative growth in that

       C. ITA training should only be provided for occupations that require two (2) years of
          training or less.
          1. Four (4) year degree programs may be funded when the customer can document
Rev. 5/01/09 (ARRA)
              that he/she is in the last two (2) years of the program (i.e., remaining hours are
              equal to or less than 50 percent of the total hours required for the degree).
           2. Associate Degree programs with substantial pre-requisites for admission to the
              program shall be considered by MCTA only when admission to the program has
              been achieved and all pre-requisites* completed.
           3. Customers requesting degree programs at university (typically YSU or KSU) must
              complete placement tests and satisfactorily complete any deficiency courses prior
              to MCTA approval for degree program.
           4. Online courses that are a requirement of a full-time curriculum may be
              considered if a classroom setting is unavailable.

       * For those programs which require satisfactory completion of pre-requisite courses prior
       to application to the program, MCTA may fund such pre-requisite courses at the intensive
       level of services for no more than two semesters.

       Exceptions may be made with the approval of the director.

       Section D is effective with Spring 2005 semester for current and new students:
       D. Since university costs have risen and since university students select courses each
          term, the following criteria are established to structure the customer's financial
          contribution and to promote program completion within 24 months.

         1. Customers approved for an ITA for a university degree program:
            a. must satisfactorily complete 50 % of degree credits in the first 12 months
            following enrollment in occupational skills training
            b. must satisfactorily complete 50% of degree credits in the second 12 month

           2. Implementation:
               a. MCTA will fund a maximum of 16 hours per semester (YSU) and 18 hours per
                    semester (KSU).
               b. The customer's contribution beyond grants will likely occur in semester 3
                  and/or semester 6.
               c. Customers who do not complete 50 % of degree credits in 12 months will be
                 permitted to enroll for a fourth semester at their own expense but remain under
                   case management with an adjustment to the IEP. Fourth semester extensions
                  are for special circumstances and not intended to be routinely available.

               Thus, $9500 is available for 12 successive months. The customer must use it or
lose it. The remaining $9500 is available only if the first 12 months [or through the fourth
semester extension] reflect satisfactory completion of 50% of degree credits.

              d. MCTA will consider payment for used books only, unless course work requires
                 a newly published edition or a used book is not available.

Rev. 5/01/09 (ARRA)
Exceptions may be made with approval of the director.

       E. Standardized Testing
          1. A customer scoring below a 9.0 grade equivalent in the reading, mathematics, or
              language section of the assessment may be required to successfully upgrade those
                deficiencies prior to consideration for entry into training.
          2. Customers requesting degree programs may be considered for this level of training
              if: Aptitude scores in Verbal Reasoning and Numerical Reasoning fall at an
               average level (Stanines 4,5, or 6) and one (VR or NR) is at Stanine 5 or higher.
          3. Customers requesting degree programs which also focus on Abstract Reasoning,
              Spatial Relations, and/or Mechanical Reasoning may be considered for this level
                of training if: Aptitude scores in areas relevant to training fall at an average level
                 (Stanines 4,5 or 6) or higher.

       F. Performance
          Training providers or specific programs that fail to meet local performance measures
          shall not be offered or will be suspended from the inventory of acceptable providers
          or programs. These providers or programs may be reinstated once acceptable levels
          have been attained. A customer who obtains a specific letter of intent to hire based on
          completion of a restricted program may be considered for training; however, this
          consideration is solely at the discretion of MCTA.

       G. Room and board are not considered training service costs.

       H. ITA training will only be provided for government service occupations in cases where
          a letter of commitment to hire from the governmental unit has been received. The
          letter must state that there is sufficient funding to hire the customer on a permanent ,
          full time basis at the completion of training.

IV. Procedures for Implementation of Training Services

       A. All participants must provide documentation to MCTA:

          1. Of acceptance to training provider and program identified on IEP.
          2. That they have applied for all available grants to reduce the costs of training (Cost
             of Attendance).
          3. Of validated curriculum to be targeted on ITA.
          4. Of schedule of classes for current term.
             A. Prior to the start of each quarter/semester at a university, grades for the
                 previous period and a complete schedule of classes for the new period must be
                 submitted to and approved by MCTA.

       B. Career Consultants:

          1. are responsible for compliance of scheduled classes with the program/curriculum
Rev. 5/01/09 (ARRA)
              identified on the IEP.
           2. are required to submit the following for customer registration into Training
              a. Letter of Intent to Training Provider
              b. ITA
              c. Cost of Attendance *
                  * No payments to training providers shall be made prior to submission of Cost
                  of Attendance by the training provider.
              d. Requisition(s) for training costs
           3. shall refer the customer to consumer credit counseling in order to assist the
              customer with budgeting concepts and resources available and also to document
              the need for supportive services through MCTA.

V. Monitoring Procedures

To ensure that the performance of the Occupational Skills Training program is in compliance
with the WIA of 1998, its rules and regulations, and the policies of the MCTA, and to ensure that
any discrepancies that require corrective action are handled in a complete and timely manner.

The Career Consultant will conduct/collect the following reports, review the information
provided, and pursue any corrective action necessary.

       A. Customer Five Week Monitoring Report             Attachment 1

       Perform a desk top audit of the customer’s file.
       Review IEP, ITA, WIA Complaint Procedure, and Consumer Credit Counseling

       Conduct a participant monitoring review within each five (5) weeks the customer is in
       training. Note any comments and any corrective action that may be needed.

       B. Customer Evaluation By Training Instructor            Attachment 2
          Collect the training instructor’s evaluation of the customer within each five (5) weeks
          the customer is in training. The training instructor will evaluate university students
          once each term.

       C. Discrepancies

Rev. 5/01/09 (ARRA)
           1. Report any and all discrepancies to your immediate supervisor no later than 5:00
              p.m. the work day following the monitoring review.

           2. Construct a corrective action plan, if needed, including dates of completion and
              review. This action must be completed within five (5) working days.

           3. The Director effects the final action as determined from information derived from
              follow-up reports.

Action Required
       All staff must explain and use the content of this policy when determining and delivering
ITA Training services.

       Any clarification needed by MCTA staff should be directed to their immediate

Effective Date: Immediately


Rev. 5/01/09 (ARRA)
Attachment 1
                           Mahoning and Columbiana Training Association
                              Customer Five-Week Monitoring Report

Customer_____________________________________ Monitoring Date___________________

Training Facility_____________________________ Program____________________________

1 - Review* of Customer File: IEP, COA, ITA, WIA Complaint Procedure, Consumer Credit Counseling Report
* To be completed during the first five (5) weeks of training and kept in customer’s working file. _______ C.C. Init.

2 - Are you experiencing any circumstances that are interfering with your training at this time:

 Transportation                                                 Illness

 Housing                                                        Death in family

 Pregnancy                                             Employment

 Childcare                                                      Other

Comments: ___________________________________________________________________________________



3 - Are you employed: _____ Yes       _____ No           _____ Hours per week?

4 - How would you evaluate the training and instruction you received for _____ quarter / semester / trimester?

         Excellent _____                      Good _____            Fair _____              Poor _____

         Class                                                  Instructor
         ______________________________________                 ______________________________________

         ______________________________________                 ______________________________________

         ______________________________________                 ______________________________________

5 - How is the customer progressing in relation to the training curricula?

         Excellent _____                      Good _____            Fair _____              Poor _____


1 - Do you have an updated resume:                              Yes _____           No _____
2 - Have you developed job interviewing skills?                 Yes _____           No _____
3 - Do you have appropriate clothing for interviews?            Yes _____           No _____
4 - Describe appropriate clothes for an interview.

Do you feel that you would benefit from working with MCTA to improve your job search skills?
Yes _____ No _____

_________________________________________________                                   ________________________
MCTA Customer                                                                Date

_________________________________________________                                   ________________________
MCTA Career Consultant                                                              Date

Rev. 5/01/09 (ARRA)
                                                                                       Revised 10-25-01
Attachment 2
                                Mahoning And Columbiana Training Association
                        Customer Evaluation by Training Instructor - Five Week Evaluation

____________________________________________                                   ________________________
Customer Name                                                                  Training Facility
_____________________________________________                                  ________________________
Class                                                                          Instructor

1.      Student’s current grade for class?______________________

Student’s attendance for

Is student turning in
Is student participating in classroom
Did you have a conference with the

6.      Does student have knowledge of equipment and


        Rev. 5/01/09 (ARRA)

______________________________                       _______________
Instructor                                             Date

________________________________                     _______________
MCTA Customer                                 Date

____________________________                         _______________
MCTA Career Consultant                                 Date

                                                                       Revised 10-25-01

Rev. 5/01/09 (ARRA)

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