Individual Training Account (ITA) 50% Expenditure Requirement FAQ

Individual Training Account (ITA) 50% Expenditure Requirement

• Does the 50% ITA reserve requirement apply to the individual funds or the combined Adult & Dislocated Worker funds?

  The restriction applies to the combined funds. So, a region could expend more than 50% for the Adults and less than 50% for the Dislocated Workers, as long as at least 50% of the combined funds are expended for allowable ITA expenditures.

• Should regions completely contained in RACEC Designated Regions be treated differently?

  No, although being located in a RACEC could be a factor when determining if a waiver of the ITA requirement is warranted.

• Does the 50% reserve requirement, and the now-reduced authorized expenditures, apply to funds appropriated to the boards before the effective date of ch. 2012-29. L.O.F.?

  Yes, as unexpended appropriations from previous years are “re-appropriated” every year in the state budget.

• Can required uniforms or tools, licensing exams and preparatory courses that are required for training and/or licensure count toward the 50% ITA reserve?

  No. The guidance limits qualified ITA expenditures to “tuition, books, and fees” of training providers. Florida law does not allow participation requirements, such as uniforms or tools, or licensing examinations not charged by the training provider as a “fee” to be included in those costs that count toward the 50% ITA expenditure requirement.

  The law goes on to state that “other training services prescribed and authorized by the Workforce Investment Act of 1998 qualify as an Individual Training Account expenditure.” The inclusion of this language allows the direct costs associated with other training services such as OJT and Employed Worker Training Programs to count toward the 50% ITA requirement and the guidance reflects that. It does not, however, mean that all costs associated with those “other training services” count. Florida law limits costs associated with traditional classroom training programs to tuition, books, and fees, so the guidance applies that same principle to other training services and excludes costs such as licensure, tools, etc. that may be required for an individual to participate in the training program or complete certification for that training program unless those costs are either included in the tuition or charged as a fee by that provider.

• Can ITA reserved funds be used to fund Core, Intensive and Supportive Services?

  No.  ITA reserved funds may only be expended for authorized training services, as approved by the WFI Board of Directors and described in the draft Guidance. 

• Are these new requirements in conflict with federal law?

  No.  Federal law provides the state the authority to: 
  
  “Establish policies, interpretations, guidelines and definitions to implement provisions of title I of WIA to the extent that such policies, interpretations, guidelines and definitions are not inconsistent with the Act and the regulations issued under the Act.” [20 CFR s. 661.120 (b)]

• How does the “Pell Grants First” policy affect training services to One-Stop clients?

  Neither federal nor state guidance requires that Pell Grants be used first. WIA s. 134(d)(4)(B) stipulates that training is limited to individuals who are unable to obtain other grant assistance (including Pell Grants) or require assistance beyond the grants. Federal rules require program operators to “coordinate” training costs, which would allow the application of WIA funds to “tuition books and fees” and Pell Grants to any remaining costs of attendance. [20 CFR s. 663.320] The Department of Economic Opportunity has published a presentation on this topic, Funding WIA Training: Coordination of ITAs with Other Financial Resources.

• Does the policy require that there be a physical classroom component or group activity for approval of on-line courses for ITAs?

  The policy does not require that there be a physical classroom component.  Approved online classes should include other characteristics of traditional for-credit classes: qualified instructors, organized curriculum and instructional methods, evaluation mechanisms, and the ability to obtain individual feedback and guidance from the instructors.

• Can other sources of training funds be counted toward the ITA reserve?

  No. The law specifically applies to WIA funds for Adult and Dislocated Workers: it is from these specific funds that the reserve requirement applies.