TEGL 09-22.pdf

ETA Advisory File Text

EMPLOYMENT AND TRAINING ADMINISTRATION ADVISORY SYSTEM U.S. DEPARTMENT OF LABOR Washington D.C. 20210 CLASSIFICATION WIOA Youth CORRESPONDENCE SYMBOL OW I DYS DATE March 2 2023 RESCISSIONS None EXPIRATION DATE Continuing ADVISORY TRAINING AND EMPLOYMENT GUIDANCE LE TTE R NO. 09 -22 T O STATE WORKFORCE AGENCIES STATE WORKFORCE ADMINISTRATORS STATE WORKFORCE LIAISONS STATE AND LOCAL WORKFORCE BOARD CHAIRS AND DIRECTORS FROM BRENT PARTON Acting Assistant Secretary SUBJECT Workforce Innovation and Opportunity Act Title I Youth Formula Program Guidance 1.Purpose. To provide guidance and planning information to states local workforce areas and other recipients of Workforce Innovation and Opportunity Act WIOA Title I youth formula funds on the activities associated with the implementation of WIOA. 2.Action Requested. Share with all staff who administer the WIOA Youth program. States and local areas should review their youth program policies and procedures to comply with this guidance. 3. Summary and Background.a.Summary This guidance addresses the Employment and Training Administration ETA s priorities for youth programs and further clarifies WIOA Youth program policies. It also provides information to help states and local areas improve services supports and outcomes for youth particularly opportunity youth out-of-school and out- of-work youth by integrating equity and job quality principles into program design and service delivery as well as elevating youth voice and addressing mental health. b. Background This is the first WIOA Youth program guidance since the COVID-19 pandemic required states and local areas to shift service delivery strategies and develop innovative approaches to serving youth. Since then ETA has set priorities for programs serving youth as well as a vision for coordination and impact many based on lessons learned from the pandemic and best practices used in states and local areas. This guidance highlights different ways to meet the evolving needs of youth participants. Section 4 includes important policy clarifications that States and local areas need to be aware of when developing and implementing the WIOA Youth program. 2 4. Priorities and Policy Clarifications ETA has set a vision and several priorities for youth workforce development including priorities of advancing equity ensuring job quality addressing mental health and elevating youth voice. The overarching vision is to achieve a no-wrong-door workforce system with critical partners committed to quality career pathways and paid work experiences. States and local workforce boards are encouraged to incorporate this vision and priorities in their planning and implementation of programs. For additional information about these priorities see Attachment I. Included in the attachment are several ways states and local workforce boards can integrate these including through the provision of quality work experiences that are a part of a broader career pathway strategy. We encourage states and local boards to provide direction and support to assist local youth programs in integrating these priorities. Additionally local programs should work to incorporate youth voice into decisions about programming that ultimately impact the young people they serve. Youth as partners and co-designers of programs can provide critical insights and recommend strategies to improve outreach recruitment and other service delivery strategies. Attachment I provides additional detail on the benefits of engaging youth and resources for how to effectively incorporate youth voice. Additionally over the last two years ETA has identified program areas that warrant further clarification and direction. This section addresses their related requirements around programming and reporting. a. Documenting WIOA Youth Eligibility. ETA recognizes that documenting WIOA Youth participant eligibility can appear and sometimes be burdensome. It is important that local programs are aware of flexibilities within WIOA statute regulations and guidance that may help reduce barriers for WIOA Youth programs to document eligibility. First WIOA eliminated the need to document low-income status for eligibility determination for the majority of out-of-school youth. There are only three instances where low-income status must be documented for OSY. Only those out-of-school youth who are determined eligible by virtue of using 1 the basic skill deficient 2 English Language Learner or 3 an individual who requires additional assistance to enter or complete and educational program or to secure or hold employment barriers to document the WIOA Section 129 a 1 B iii portion of out-of-school youth eligibility must be low income. Other out-of-school youth do not need to be low-income or document their income. Secondly WIOA permits individuals who receive or are eligible to receive free or reduced lunch foster youth homeless youth and youth living in a high-poverty area to automatically be considered low income. Lastly self-attestation is an acceptable source of documenting almost all program elements related to WIOA Youth eligibility. As stated in TEGL 23-19 Change 1 the following youth eligibility data elements allow self- attestation as an acceptable source of documentation school status at program entry date of birth individual with a disability pregnant or parenting youth who needs additional assistance foster youth homeless youth offender low income and English Language Learner. The only data element related to WIOA Youth eligibility that does not permit the use of self-attestation for documentation is basic skills deficient. Please note that as stated in TEGL 23-19 Change 1 self-attestation means a written or electronic digital declaration of information for a particular data element signed and 3 dated by the participant. ETA broadly interprets what is an electronic digital signature. Electronic signatures or a submission from the participant such as an email text or unique online survey response is considered an electronic signature or verification it must be participant generated and traceable to the participant. Grantees must retain documentation of the self-attestation. As stated in TEGL 23-19 Change 1 ETA encourages grant recipients to consider the impacts on equity and accessibility when developing their source documentation policies and procedures. For example grantees considering restrictions on the use of self- attestation should consider that while other documentation sources are preferred when practical self-attestation is an important option for populations with barriers to obtaining eligibility and reporting documents such as disconnected youth American Indian and Alaska Native populations individuals experiencing homelessness justice involved individuals refugees disaster impacted individuals and others and help ensure such populations are able to equitably access services. As a best practice once enrolled programs should assist the participant in obtaining the required documents through the use of supportive service funds as these documents are likely needed for employment and training related activities. b. Mental Health Assessment Referrals and Training for Staff. The youth workforce system plays a critical role in supporting the mental health of participants through assessments comprehensive guidance and counseling including referrals to partner organizations as well as providing sufficient supportive services to help alleviate additional barriers to education and work. Understanding the challenges and building new or strengthening existing partnerships with local mental health agencies and organizations can help ensure that youth are receiving the support and treatment they need. Comprehensive guidance and counseling is one of the WIOA Youth program s 14 program elements. As defined in 20 CFR 681.510 of the WIOA final rule comprehensive guidance and counseling provides individualized counseling to participants. This includes drug and alcohol abuse counseling mental health counseling and referral to partner programs as appropriate. When referring participants to necessary counseling that cannot be provided by the local youth program or its service providers the providers must coordinate with the organization to which it refers in order to ensure continuity of service in the WIOA Youth program. In its August 2022 survey the National Youth Employment Coalition found that most youth employment programs indicated that their youth cannot access mental health services when they need them. Sixty percent of respondents estimated that fewer than half the youth could access mental health support in their community when needed. Two other major findings from the survey include 64 of respondents did not have a process for screening and or monitoring young people for mental health needs. Moreover 60 of these respondents estimated that more than half of their youth need mental health support. 4 89 of respondents indicated they did not have sufficient resources to deliver quality mental health training to staff. 72 of respondents do not track if youth receive needed mental services. It is important to note that while youth workforce development practitioners are not expected to be experts in mental health there are many ways to assess mental health needs at program enrollment and throughout their participation in the program and that mental health assessments are an allowable cost under WIOA. ETA strongly encourages integrating mental health assessments into the objective assessment process to identify potential mental health needs that must be addressed through mental health services or through referrals to mental health professionals for youth to be successful in the program. Additionally professional development for youth workforce development practitioners is essential for ensuring staff have the appropriate skills knowledge and abilities to effectively serve the young adults in the WIOA Youth program. Professional development is an allowable cost under WIOA. ETA strongly encourages local workforce development boards to offer professional development training to all staff that work with youth and quality mental health training along with training related to trauma- informed care principles should be included. c. Virtual Work Experiences. Virtual work experiences are allowable under the WIOA youth program. With COVID-19 pandemic virtual services such as virtual work experiences became necessary. Virtual work experiences can offer more flexibility and broaden work experience opportunities particularly in rural areas. They can also promote equity and access for youth that might not otherwise have the opportunity for certain types of work experiences. Therefore local WIOA Youth programs are permitted to continue to provide virtual work experiences beyond the COVID-19 pandemic. And while WIOA section 681.600 states that work experiences must take place in a workplace this includes a virtual workplace when remote work experiences are possible and practical. For technical assistance resources visit https youth.workforcegps.org resources 2020 06 18 13 10 Resources-on-Virtual- Engagement. d. Digital Literacy and Access. Section 101 of WIOA authorizes state workforce development boards to use WIOA funding to support digital literacy efforts. Additionally Section 107 states that local boards shall identify strategies for better meeting the needs of individuals with barriers to employment including strategies that augment traditional service delivery and increase access to services and programs of the one-stop delivery system such as improving digital literacy skills. Jobs in almost every industry are increasingly requiring workers to have digital literacy skills. While many youth are considered digital natives or people who have grown up with technology and the internet it is still important to ensure that young people have the digital skills needed to successfully enter and remain in the workforce. 5 It is important to note that WIOA funds can also be used to pay for devices and broadband internet service that will allow a participant to create or maintain a wireless connection for distance learning search for jobs and engage in other employment and training services where such services are already allowable. A local area must have written policies and procedures in place that outlines the steps factors it will consider to approve a cost and ensure that costs are reasonable necessary allowable and allocable to the WIOA grant. In addition ETA encourages local WIOA Youth programs to inform participants about the Affordable Connectivity Program that helps families access affordable broadband. For more information visit Emergency Broadband Benefit Federal Communications Commission fcc.gov . e. Assessment. WIOA requires an objective assessment of academic levels skill levels and service needs of each participant which includes a review of basic skills occupational skills prior work experience employability interests aptitudes supportive service needs and developmental needs. TEGL 21-16 stated that local programs may use previous basic skills assessment results if such previous assessments have been conducted within the past six months. While this continues to be true state and or local programs may use previous assessments older than six months if they deem appropriate and if there is a state local policy in place that allows the use of such assessments. It is important that assessments do not serve as a deterrent to program enrollment. In addition it is critical that local programs incorporate the results of the objective assessment into a participant s Individual Service Strategy and the services such as career counseling that participants receive. f. Supportive Services. Supportive services allow participants to persist in and complete program activities and are vital ingredients in youth success. i. Supportive services as an allowable work experience expenditure TEGL 21- 16 stated that supportive services are a separate program element and cannot be counted toward the work experience expenditure requirement even if supportive services assist the youth in participating in the work experience. However ETA s policy on this issue has evolved. ETA recently determined that supportive services that enable WIOA participants to participate in training can count toward training expenditures. Therefore to be consistent with this policy supportive services that enable WIOA participants to participate in work experience can now count toward the work experience expenditure requirement. ii. Food. A frequently asked question is whether food is an allowable cost for youth participants in WIOA. ETA s policy continues to be that on a limited basis and in certain situations food at a reasonable cost may be provided to youth-serving program participants as a supportive service. Food may be provided to eligible youth when it will assist or enable the participant to participate in allowable youth program activities and to reach his her employment and training goals thereby achieving the program s overall performance goals. The use of grant funds for food should be limited to 6 reasonable and necessary purchases that are coordinated when possible with other community state or federal services that provide food for low-income individuals. Local areas should have written policies and procedures in place for purchasing and distributing food to ensure consistent treatment of these types of expenses. When developing written policies and procedures please review the Uniform Guidance at 2 CFR 200.403. g. Reporting and Expenditures for Pre-Apprenticeship and Apprenticeship. WIOA and 20 CFR 681.590 a require that a minimum of 20 percent of local area funds for the Title I Youth program be spent on work experience. TEGL Nos. 8-15 and 21-16 provide further discussion of allowable expenditures that may be counted toward the work experience expenditure requirement and articulate that program expenditures on the work experience program element can be more than just wages paid to youth in work experience. An important reminder is that expenditures for pre-apprenticeships count toward the work experience expenditure requirement. In addition if the pre-apprenticeship program includes an occupational skills training component separate from the work experience WIOA Youth programs may report pre-apprenticeship under both the work experience program element and the occupational skills training program element. Also while not explicitly listed in WIOA as a type of work experience WIOA Youth expenditures related to Registered Apprenticeship programs count toward the minimum work experience expenditure requirement. h. Comprehensive Guidance and Counseling Reporting. As noted elsewhere in this guidance local area staff should prioritize delivering services over administrative functions. However accurate reporting provides enough administrative data to assess what strategies are working and can also contribute to building evidence on effective services for youth. Therefore ETA also notes where program elements may not be accurately reported. Where feasible states should review their policies systems and training so that services can be accurately recorded. In reviewing reporting data ETA observed that many states may not be accurately reporting the comprehensive guidance and counseling program element. For example in the most recent data reported five states report 100 percent of participants receive this program element two additional states report over 90 percent of participants receive this program element and three more report over 70 percent as receiving comprehensive guidance and counseling. It appears some states report certain program services as comprehensive guidance and counseling that should be categorized in other program elements or they are reporting general case management as comprehensive guidance and counseling. As stated in TEGL 21-16 case management is the act of connecting youth to appropriate services and is not considered a program element. Another program element that often is misreported as comprehensive guidance and counseling is the program element entitled services that provide labor market and employment information about in-demand industry sectors or occupations available in the local area such as career awareness career counseling and career exploration services. As discussed in TEGL 21-16 career counseling services may include providing 7 information about resume preparation interview skills potential opportunities for job shadowing and the long-term benefits of postsecondary education and training. This type of career counseling often provided by a case manager should be reported as the services that provide labor market information program element and should not be reported as the comprehensive guidance and counseling program element. As mentioned above youth are experiencing significant mental health and substance abuse issues and it is important to have a clear understanding of when WIOA Youth providers deliver services within the comprehensive guidance and counseling program element to youth participants. Technical assistance resources related to comprehensive guidance and counseling can be found at https youth.workforcegps.org resources 2017 03 22 09 55 link.aspx id E98DB3B 477814B1DAD1754299248AE86 z z i. Follow-up Services and Mentoring Reporting. In reviewing reporting data ETA observed fewer participants than expected receiving the program elements of mentoring and follow-up services. Only 10 percent of youth nationally are reported as receiving mentoring in the current program year and nine states report zero participants receiving mentoring services. In addition to those nine states 17 more states report fewer than three percent of participants as receiving mentoring services. Likewise only 18 percent of youth nationally are reported as receiving follow-up services despite follow-up services being a required program element for all participants. Five states reported zero youth as receiving follow-up services an additional nine states reported less than five percent of participants receiving follow-up services and 13 more states reported less than 10 percent of participants receiving follow-up services. Both mentoring and follow-up services provide critical support to youth that help youth succeed in their career pathway progression. One potential explanation for the low numbers in these two program elements is that perhaps these services are being provided just not for the full twelve months specified in WIOA. While both program elements require their provision for a minimum of 12 months it is not necessary to wait until a participant receives these services for the full 12 months prior to reporting them. For example if a participant receives mentoring services such services can be reported in the first quarter in which mentoring is received. Likewise follow-up services can be reported in the first quarter in which it is received. As a reminder as stated in WIOA section 681.580 mentoring is one of the types of services that is permitted during follow- up. Technical assistance resources related to Mentoring can be found at https youth.workforcegps.org resources 2017 03 22 09 55 link.aspx id 1D201FB 7BEAA404EA16918E772D45F68 z z. Technical assistance resources related to Follow-up can be found at https youth.workforcegps.org resources 2017 03 22 09 55 link.aspx id C8899A8 18F794561941389237DF746CC z z. 8 j. Reporting Barriers Including In-School Youth Who Require Additional Assistance. In order to ensure the program is serving a diverse mix of youth and that it is accessible to all youth reporting youth demographic information including eligibility barriers is very important. In addition programs should make sure to report all eligibility barriers for youth when youth have multiple barriers so that program staff states and ETA and have an accurate representation of the youth we serve. There is one exception to the reporting of all youth eligibility barriers -- in-school youth who require additional assistance to complete an education program or secure or hold employment. For this particular barrier it is important that local programs report it only when it is a participant s sole eligibility barrier. WIOA includes a limitation where in each local area only five percent of in-school youth in a given program year can be determined eligible using the youth who require additional assistance to complete an education program or secure or hold employment barrier. Based on the most recent data 24.3 percent of in-school youth nationally are reported as having the youth who require additional assistance barrier. In order to more accurately track this five percent limitation WIOA Youth programs should only report youth as having this barrier if it is their only barrier and therefore the barrier used for eligibility determination. In the most recent report 43 states had more than five percent of their youth with this barrier meaning that at least one local area in each of those states report more than five percent of their youth as having this barrier. While this does not necessarily indicate that all such reported youth have the youth who require additional assistance as their only barrier for tracking purposes of the five percent limitation in-school youth with multiple barriers should not be reported as having the youth who require additional assistance barrier. States must ensure that each local area in their state has less than five percent of their in-school youth per program year that report this barrier for eligibility determination. 5. Inquiries. Please direct inquiries to the appropriate Regional Office. 6. References. Workforce Innovation and Opportunity Act Pub. L. 113-128 Training and Employment Guidance Letter TEGL No. 21-16 Third Workforce Innovation and Opportunity Act WIOA Title I Youth Formula Program Guidance Training and Employment Guidance Letter TEGL No. 8-15 Second Title 1 WIOA Youth Program Transition Guidance Training and Employment Guidance Letter TEGL No. 23-19 Change 1 Guidance for Validating Required Performance Data Submitted by Grant Recipients of U.S. Department of Labor DOL Workforce Programs 7. Attachment Attachment I Departmental Vision and Priorities for Youth I-1 Attachment I ETA Priorities for Youth Workforce Development Equity Job Quality Mental Health and Youth Voice. Vision The Department envisions a no-wrong-door youth workforce system that offers seamless access to resources programs and wrap around services offers guaranteed paid work experiences for young people and coordinates with critical partners including but not limited to employers sector-based industry coalitions workforce intermediaries labor unions and philanthropy committed to high quality career pathways for young workers. Priorities Equity On January 21 2021 his first day in office President Biden issued Executive Order 13985 On Advancing Racial Equity and Support for Underserved Communities Through the Federal Government. The Executive Order defines equity as the consistent and systemic fair just and impartial treatment of all individuals including individuals who belong to underserved communities that have been denied such treatment. Advancing equity to ensure youth have equal access to and outcomes in high quality education and training is a key priority for the Department. Equity must be integrated into everything programs do from outreach and recruitment to service delivery strategies to partnership development and to using data to inform decision making. Equity in the WIOA Youth program means that not only do youth have equitable access to services and supports but also that youth are achieving equitable outcomes. On January 20 2022 ETA hosted a webinar Technical Assistance to Meet Equity Goals in WIOA Youth Programs which reviewed resources and provided audience members an opportunity to share their technical assistance needs as it relates to how WIOA youth providers can improve youth outcomes through more equitable and inclusive programming. Presenters and audience members on this webinar engaged in a rich discussion of what integrating equity principles into WIOA youth programming can look like. ETA encourages those who were unable to attend the webinar to view the recording of the webinar at https www.workforcegps.org events 2021 10 25 19 36 Technical-Assistance-to-Meet- Equity-Goals-in-WIOA-Youth-Programs. For additional resources on equity visit https youth.workforcegps.org resources 2022 08 08 19 05 Resources-on-Advancing- Workforce-Equity-for-Youth. Additional information on integrating equity into workforce development programming can be found at https youth.workforcegps.org resources 2022 08 08 19 05 Resources-on- Advancing-Workforce-Equity-for-Youth Job Quality Ensuring equity in WIOA Youth programs means that programs must not only connect youth to a job but ensure youth have access to quality jobs by creating opportunities for on-ramps to quality career pathways. The Department leads the Good Jobs Initiative focused on job quality by providing critical information to workers employers and I-2 government as they work to improve job quality and create access to good jobs free from discrimination and harassment. The Department in partnership with the U.S. Department of Commerce created eight principles framework known as the Good Jobs Principles for a shared vision of job quality. These principles focus on hiring and recruitment family- sustaining benefits for full- and part-time workers diversity equity inclusion and accessibility DEIA in the workplace empowerment and representation job security and working conditions that include a safe and healthy workplace pay that is stable and a living wage and skills and career advancement opportunities to progress to good jobs. TEGL 07-22 Increasing Employer and Workforce System Customer Access to Good Jobs defines a good job explains why job quality is important and outlines how the workforce system integrates good job strategies into its employer relationships and workforce training. It also clarifies the workforce system s role as supporter and developer of good jobs in an effort to make the workforce system more equitable and responsive to worker and business needs. Strong State and Local Workforce Development Boards and State Workforce Agencies use the information in that guidance to develop a strategy for identifying and creating long-term partnerships with employers offering good jobs helping other employers to provide good jobs and creating strategic flexible career pathways to good jobs that respond to local labor market needs. Quality Work Experiences Integrating equity and job quality principles into the WIOA Youth program is achieved by ensuring youth have access to quality work experiences in particular paid work experience whenever possible that have on-ramps to career pathways. The decade between ages 14 and 24 is marked by critical transitions as youth begin to enter adulthood and make decisions about how to continue their education or enter the workforce. The opportunities and support available to young people during this time influences their long-term trajectories into adulthood. 1 Early employment represents one experience that is generally associated with better labor and wage outcomes in the future potentially because it helps youth to develop soft skills a job history and connections to employer networks. 2 1 Abdul Latif Jameel Poverty Action Lab J-PAL https www.povertyactionlab.org sites default files publication SYEP EvidenceReview-5.25.22.pdf 2 1 Kahn Lisa B. 2010. The Long-Term Labor Market Consequences of Graduating from College in a Bad Economy. Labour Economics 17 no. 2 April 303 316. doi https doi.org 10.1016 j.labeco.2009.09.002 Neumark David. 2002. Youth Labor Markets in the United States Shopping around vs. Staying Put. The Review of Economics and Statistics 84 no. 3 462 482. https doi.org 10.1162 003465302320259475. Ea rly employment is also an experience that youth and young adults from low-income households have greater difficulty accessing than higher-income peers. 3 Black and Hispanic teenagers from low-income households experience even greater challenges in the labor market due to structural barriers to opportunities faced by people of color in the American job market. 4 This inherent inequity makes it critical that the WIOA Youth program provide quality work experience opportunities to youth participants. 3 2 Sum Andrew Ishwar Khatiwada Mykhaylo Trubskyy Martha Ross Walter McHugh and Sheila Palma. 2014. The Plummeting Labor Market Fortunes of Teens and Young Adults. Brookings Institution. https www.brookings.edu wp-content uploads 2014 03 Youth Workforce Report FINAL-1.pdf. 4 Spievack. 2019. For People of Color Employment Disparities Start Early. Urban Institute. https www.urban.org urban-wire people-color-employment-disparities-start-early. I-3 According to MDRC s meta-analysis on career pathway programs systematic biases especially against people of color and women social networks that limit which jobs and employers workers can connect to and employers strong preference to hire those who already have relevant work experience can all combine to make it difficult for people to get access to employers and careers that offer family-supporting wages. Work-based learning can help offset those disadvantages by using a college or training program s relationships and credibility to open doors. Apprenticeships offer another potential avenue by which work- based learning could increase college completion rates earnings and equity if they were expanded to include more diverse participants. Apprenticeships are already often connected to colleges that deliver classroom training components leading to college credentials. In addition to ensuring youth have access to paid work experience opportunities it is critical that such work experiences be in industries and occupations that put youth on a career pathway to high quality jobs. As discussed in CLASP s research brief entitled Toward a Vision of Quality Summer Employment for All Youth recent interviews with Summer Youth Employment Program funders providers advocates and participants in six U.S. cities explored what it would take to guarantee a high-quality summer job to all youth. Among the insights that emerged one theme became clear Young people want more than a summer job they want career-focused work experience that is worth their time and responsive to their day-to-day realities. 5 Creating targeted job opportunities with deliberate focus on equity and exposing youth to careers and connecting them to social networks in fields where they are underrepresented will help youth enter career pathways that will lead to family-sustaining wages. 5 CLASP https www.clasp.org wp-content uploads 2022 05 2022 TowardAVision.pdf Appr enticeships and Pre-Apprenticeships One way to connect youth to work experiences that will lead to career pathways is through pre-apprenticeship and Registered Apprenticeship opportunities. Registered Apprenticeship programs RAP offer learn while you earn opportunities and are appropriate for many youth participants. The average wage for a RAP completer is 70 000 and 94 percent of completers retain employment. 6 Furthermore RAP participants earn an average of 98 718 more than nonparticipants over their career. 7 6 Career Seeker Fact Sheet September 2020 Department of Labor 7 Reed Debbie et al. An Effectiveness Assessment and Cost-Benefit Analysis of Registered Apprenticeship in 10 States July 2012 Mathematica. Hi storically many individuals including youth have faced significant barriers to accessing RAPs. Quality pre-apprenticeship programs however can play a key role in removing these barriers and creating accessible pathways to RAPs and to rewarding careers. While a quality pre-apprenticeship program can play a valuable role in providing work-based learning for all Americans as identified in recent evaluations of the American Apprenticeship Initiative AAI grant program pre-apprenticeship programs may also serve as an effective tool for promoting DEIA by helping individuals facing barriers to employment acquire the practical and foundational skills needed to successfully participate in the workforce and to gain entry into RAPs. Pre-apprenticeship programs use varied program strategies which place an I-4individual on the potential career pathway to employability through a RAP. They utilize a wide range of program designs and approaches and often vary in duration to meet the needs of diverse populations and employers. The Department has invested significant funding in recent years on building pre- apprenticeship and RAPs for youth and encourages states and local areas to work with their apprenticeship partners to leverage and align WIOA Youth program resources and further expand these quality work and learning opportunities. The Department encourages states and local areas to develop or strengthen existing relationships with their State Apprenticeship Agency in those states that have them or with an ETA Apprenticeship and Training Representative in states that don t have a State Apprenticeship Agency. Mental Health The workforce system must play a key role in addressing the youth mental health crisis. Even before the pandemic demand for mental health services was increasing especially for our nation s young people. The COVID-19 pandemic intensified the situation subjecting many young Americans to social isolation loss of routines and traumatic grief8 . These challenges are documented in the White House s Fact Sheet Improving Access and Care for Youth Mental Health and Substance Use Conditions found at https www.whitehouse.gov briefing-room statements-releases 2021 10 19 fact-sheet- improving-access-and-care-for-youth-mental-health-and-substance-use-conditions . Additionally in December 2021 the Office of the Surgeon General released an advisory report Protecting Young People s Mental Health found at https www.hhs.gov sites default files surgeon-general-youth-mental-health-advisory.pdf in which the devastating impacts of the pandemic and the alarming increases in mental health needs of young people are outlined. In August 2022 the Department hosted a webinar entitled Supporting Youth Mental Health in the Workforce System where the Office of the Surgeon General presented on its Advisory mentioned above National Youth Employment Coalition provided an overview of the findings from their report summarizing findings from their national survey entitled Identifying Gaps in Youth Employment Programs Capacity to Address Youth Mental Health Needs and offered policy and practice solutions and Substance Abuse and Mental Health Services Administration showcased a number of resources that may be useful to program practitioners when helping youth access mental health services and supports. The webinar recording is available at https www.workforcegps.org events 2022 07 01 18 50 Supporting-Youth-Mental-Health- in-the-Workforce-System. During the webinar ETA showcased the Youth Mental Health Resource Guide which was designed to help youth workforce practitioners deliver on the WIOA youth program element of providing youth with comprehensive guidance and counseling. The Resource guide can be found at https youth.workforcegps.org resources 2022 08 16 15 26 Youth-Mental- Health-Resource-Guide. 8 The White House FACT SHEET Improving Access and Care for Youth Mental Health and Substance Use Conditions https www.whitehouse.gov briefing-room statements-releases 2021 10 19 fact-sheet-improving- access-and-care-for-youth-mental-health-and-substance-use-conditions . I-5 Trauma-Informed Care. Trauma is a major contributor of poor mental health. When working with youth it is important to understand the effects trauma may have. Trauma affects the way a person learns plans and interacts with others a young person may be combative non-responsive at times or misuse substances to cope with these past traumas. Youth programs have increasingly adopted different types of trauma-informed care approaches which seek to support individuals who have experienced trauma or distressing events in their lives. Several local programs have adopted trauma-informed care into their program offering. ETA encourages all WIOA Youth program providers to fully incorporate trauma-informed care principles and practices into program planning staffing training and implementation. Resources on Trauma and Trauma-Informed Care can be found at https youth.workforcegps.org resources 2020 03 24 11 13 Resources-on-Trauma-and- Trauma-Informed-Care. These resources can help workforce system providers better understand the impacts of trauma on the young people they serve and that professional development and training in trauma-informed care is critical to achieving positive outcomes. ETA will continue to share up-to-date resources and research and encourages the system to fully integrate trauma-informed practices into service delivery to help youth feel safe supported and engaged while participating in education training and employment. Youth Voice Youth play an important role in strengthening programs and improving youth outcomes. Empowering youth to identify and respond to community needs helps them become leaders and assist them in civic engagement. Finding ways to incorporate youth in program development recruitment strategies and execution of activities is pivotal. The Interagency Working Group on Youth Programs composed of representatives from 22 federal agencies that support programs and services focusing on youth created a tool Assessing Youth Involvement and Engagement to assist organizations and community partnerships in determining how they involve youth in programs whether youth are becoming more engaged in the community and if certain strategies are helping to retain youth. ETA created a tip sheet entitled Civic Engagement for Leadership Development which notes that by supporting youth in finding the issues they are passionate about increases their investment. Involving youth as partners in making decisions that affect them increases the likelihood the decisions will be accepted and adopted. Further providing participants a safe platform to express their ideas opinions and advice to others is pivotal in developing leadership skills which is a requirement of the WIOA Youth program. Youth involvement can benefit organizations and their programs as well as the youth themselves. Youth voices assist programs with assessing the resources required to meet the needs of current and future participants. Learning from best practices shared from the IWGYP programs developed in partnership with youth are more likely to be effective at engaging the population and therefore to have a greater impact. States and local programs are encouraged to engage youth in leadership development opportunities to enhance their confidence employability self-determination and other positive social behaviors. I-6 For more resources on how programs can engage youth and incorporate youth voices into their programs visit https youth.workforcegps.org resources 2022 08 08 17 41 Resources- on-Engaging-Youth-Voice.