Operations Issuance: 2020-14
Issuance Number: 2020-14
Date: April 29, 2020
To: Workforce Partnership WIOA Subrecipients
From: Andrew Picard, Chief Program Officer
Subject: Youth Work Experience & Work-Based Learning Activities during COVID-19
This operations issuance is to notify Workforce Partnership (SDWP) subrecipients of temporary guidance regarding policy and procedure, including payments, for youth work experience and work-based learning activities during COVID-19.
Program services are impacted by COVID-19 and the Stay Home Order issued by the State of California on March 19th. SDWP and its subrecipients remain operational under the Essential Critical Infrastructure Workers (Essential) within the COMMUNITY-BASED GOVERNMENT OPERATIONS AND ESSENTIAL FUNCTIONS part of the order. This guidance will reflect the local commitment of continuing to provide services to enrolled and eligible individuals while respecting the stay home order. For updated CalJOBS guidance, please continue to review the “COVID-19 CalJOBS Updates” under references below.
Federal and State Guidance:
The Department of Labor (DOL) released guidance on the status of providing work experience and work-based learning through a COVID-19 Frequently Asked Questions (FAQ). This guidance also included information on payment of wages or stipends related to work experiences and work-based learning. EDD required SDWP to develop local policy regarding the FAQ. The local policy is as follows:
Due to COVID-19 impacts on employers, subrecipients can use maximum flexibility to provide individuals with work experience or work-based learning activities that are either telework-related or with essential service employers. Subrecipients may pay wages for virtual or essential service work experience activities and must continue to develop a Worksite Agreement & Training Plan, per the SDWP Operations Manual, Chapter 4, Part 2, page 24. Stipends can be paid to a participant for virtual work-based learning activities. Stipends must be approved through the subrecipient’s stipend policy.
All work-experiences and work-based learning that began after March 19th must follow the temporary guidance on program activities above, and included in *Operations Issuance 2020-10.
Work Exprience & Stipends Prior to March 19, 2020
If the participant’s work experience or work-based learning terms, including the duration, wage or stipend, and other training or work requirements, were established prior to the National Emergency Declaration on March 13, 2020, then the subrecipient can continue to pay the participant for the remainder of the term of the activity. Modifications or adjustments to the terms to extend the duration of the activity or increase the wage or stipend are not allowable. For work experience or work-based learning activities that began between March 13th and March 19th, subrecipient must obtain written approval from their Program Specialist.
Policy and Procedure
- The CalJOBS activity code must have been opened prior to March 13, 2020 (or March 19, 2020 with written approval by the Program Specialist).
- The Worksite Agreement & Training Plan and/or approved stipend policies must have been previously established.
- The participant may receive wages/stipends for the remainder of the work experience/work-based learning activity, based off the original Worksite Agreement & Training Plan or established schedule, as applicable by policy either through the Operations Manual or the subrecipients approved stipend policy.
- The participant may receive wages/stipends for previous hours from the date on which the activity was stopped (back pay).
- If the activity will continue after the date the participant receives the back pay, the subrecipient must follow the payment schedule per the worksite agreement/stipend policy until the activity is complete.
- Right to Work must be established prior to receiving payments.
- All applicable documentation prior to the stoppage date must be kept in the participants file or noted in CalJOBS.
- Subrecipient must document each payment under the original activity code with the following attached case note:
- Subject: “COVID-19 [WEX/WBL] Payment”
[Work experience/work-based learning] [wage/stipend] payment by [method of payment] for [dates] approved per Operations Issuance 2020-14. The activity stopped due to COVID-19 on [date].
- Provide details on the hours, pay rate, and calculation of payment amount.
- Note if the payments will continue or ended.
- Subrecipient must include a copy of the check and proof of payment in the participant’s case file.
- COVID-19 payments will be tracked/monitored by case note subject and details. Missing, incorrect, or incomplete case notes will result in disallowed costs.
- Close the activity as successful completion.
Effective April 29, 2020 all training providers may use this guidance as necessary to continue to provide services until the stay home order has been lifted.
*Please note: Guidance in this operations issuance supersedes previous guidance in Operations Issuance 2020-10, if conflicting. Subrecipient should use both issuances to continue to provide program services to youth participants.
If you have any feedback or questions regarding this issuance contact your Program Specialist.
References and Related Material: