Workforce Connections
General Policies
Customized Training (CT) / ADW-030-09
Policy Approved By: WC Executive Director
Policy Adopted on: August 01, 2013


To establish Workforce Connections’(WC) Policy regarding the Adult and Dislocated Worker Program: Customized Training


As indicated in the Workforce Investment Act (WIA) Section 101(8) Customized Training means training that: A) is designated to meet the special requirements of an employer (including a group of employers); B) that is conducted with a commitment by the employer to employ an individual upon successful completion of the training; and C) for which the employer pays for not less than 50 percent of the cost of training.Service Providers currently under contract with Workforce Connections and receiving WIA Title I formula funds shall follow this policy and must establish written procedures that meet the requirements of this policy.


Workforce Connections has established that all adult and dislocated workers who have been first determinedeligible for WIA Title I services may be approved for customized training when: A) training program is designed to meet the unique requirements of an employer or a group of employers; B) the training is conducted with a commitment by the employer(s) to employ, or in the event of those who are currently employed, to continue to employ program participants after successful completion of the training program.

This policy applies to all Workforce Connections’Service Providers providing WIA Title I services to adult and dislocated workers.


PL 105-220 - WIA [Section 101.(8)(A)(B)(C)]

[20 CFR §663.715; §663.720; §663.730]

[WIA State Compliance Policy 1.14]

A.Customized Training for Employed Individuals

Training for an individual who is currently employed may be provided when: A) the individual is not earning a self-sufficient wage, as determined by Workforce Connections; B) the training relates to the introduction of new technologies, introduction of new production or service procedures, upgrade to new jobs that require additional skills, workplace literacy, or other appropriate training approved by Workforce Connections.

B. Customized Training Agreement

All customized training agreements must be approved by Workforce Connections prior to the commencement of the customized training activity.


  1. General Provisions for Customized Training

Customized Training -Definitions

  1. The training is designed to meet the special requirements of an employer (or group of employers).
  1. The training is conducted with a commitment by the employer to employ, or in the case of incumbent workers continue to employ, trainees upon successful completion of the training program.
  1. The employer pays no less than 50 percent of the cost of training program.
  1. The training program takes place at the job site or off site; is conducted by either the employer, or by trainers that have been retained by the employer.
  1. Customized Training-Service Requirements
  1. Training services may be provided through community colleges, local area vocational/technical centers, State universities, or licensed and certified private institutions.
  1. Customized training may be conducted at the business facility, the training provider’s facility, or at a combination of sites.
  1. Instructors can be either full or part-time educators, or professionals from the local business community.
  1. Reimbursable training expenses:
  1. Delivery of training
  2. Textbooks and instructional manuals
  1. Non-reimbursable training expenses include:
  1. Instructors/trainers salaries for the actual time of instruction/training
  2. Curriculum development costs
  3. Training equipment
  4. Travel expenses for instructors/trainers
  5. Purchase of capital equipment (production equipment)
  1. Successful completion of the customized training must be documented, trough an employer certificate of completion. Workforce Connections may require from the employer an additionalindustry acceptedcredential.
  1. The employer must, at a minimum, provide a fifty percent (50 %) match for the expenses of the training project. Otherwise a waiver is in place. DOL approved waivers can be found at below link:



  1. Customized Training General Guidelines

Customized training (CT) will be available to Workforce Investment Act (WIA) eligible adult and dislocated worker participants. The same level of service (Core A, Core B/Intensive and Training) required for individual training accounts and On-the-Job training programs shall be completed prior to enrollment in customized training activities.

  1. Customized training programs shall only be approved for participants who have been properly assessed, who have at least received core and intensive services, and where an individual employment plan has been developed with a case manager to identify and document participant skills, interests, need for training, and employment goals.
  1. The case file must contain a determination of need for training services under [20 CFR §663.310], as identified in the individual employment plan (IEP)where the participant and case manager will identify employment goals, appropriate achievement objectives, and the appropriate combination of services for the participant to achieve the employment goals, WC - Policy ADW-030-03.
  1. In determining the appropriateness of the need for customized training, consideration should be given to the skill requirements of the occupation, employer requirements, the academic and occupational skill level of the program participant, prior work experience, and the IEP. A skills gap analysis is required at this time [Attachment B].
  1. A comprehensive training plan must be developed prior to CT program start.The description of training must indicate the occupational areas or skills the participant will be trained to perform, specific measurable objectives (along with number of hours of training required to obtain those skills), and the criteria for measuring and monitoring the attainment of those skills. Once skills have been identified and a method for measuring them has been established, trainee progress can be determined [Attachment C].
  1. Workforce Connections’Service Providers must not contract with an employer who has previously exhibited a pattern of failing to provide CT program participants with continued long-term employment wages, benefits, and working conditions that are equal to those provided to regular employees who have worked a similar length of time and are doing the same type of work WIA [Section 195 (4)].
  1. All information required by Federal, State and local reporting requirements must be collected for each individual receiving services other that core self-service or informational services, including documentation of each eligibility requirement for the type of service that the individual has received. The appropriateness of any service provided to an eligible program participant should be documented in the Individual Employment Plan (IEP) and should show a clear linkage between the provided service and potential improvement in the participant’s employability or career/objective goals.



  1. Customized Training – The Employer

The CT must be provided under an agreement with an employer in the public, private non-profit, or private sector. Prior to entering into a CT agreement with the employer, a pre-screening and/or pre-award assessment must be conducted to ensure that the employer meets the minimum standards and can provide both training and long-term employment to CT participants.

The pre-screening and/or pre-award assessment must include, at a minimum:

  1. Compliance
  1. Federal, State and local regulations
  2. Fair Labor Standards Act of 1938
  3. Non-discrimination and equal opportunity provisions of WIA and its regulations
  4. Americans With Disabilities Act
  5. Health and safety standards
  6. State worker compensation law requirements
  1. Assurances:
  1. The company has not exhibited a pattern of failing to provide CT participants

with continued long-term employment.

  1. The company verifies that WIA funds will not be used to relocate operations in whole or part.
  2. The company has operated at current location for at least 120 days, or has planned a new or expanded operation within the local area.
  3. The company commits to providing employment for successful CT trainees
  4. WIA customized training funds will not be used to directly or indirectly assist, promote or deter union organizing.
  5. The company must furnish information, including the company’s IRS identification number, State unemployment insurance account number, and proof that all CT trainees will be covered under workers’ compensation.
  6. The company must certify that neither the employing company nor its principals are presently debarred, suspended, proposed for debarment, declare ineligible, or excluded from participation by and/orfederal department or agency.
  7. CT trainees shall not displace (including partial displacement, such as a reduction of hours of non-overtime work, wages, or employment benefits) any current employee, as of the date of the training agreement or contract.
  8. CT funding will not be approved for any company that has relocated until 120 days after the relocation, if that relocation resulted in the loss of employment for any employee at the previous location and the previous location was within the United States.



  1. To verify that an establishment which is new or expanding is not relocating employment from another area, the pre-award review must include names under which the establishment does business, including predecessor and successors in interest; the name, title, and address of the company’s official certifying the information, and whether WIA assistance is sought in connection with past or impeding job losses at other facilities, including a review of whether WARN notices relating to the employer have been filed [WIA sec. 181(d)].

Note:1.Pre-Award Assessment Form – [Attachment A]

As indicated in [20 CFR §667.270]: What safeguards are there to ensure that participants in WIA employment and training activities do not displace other employees?

  1. A participant in a program activity authorized under Title I of WIA must not displace (including partial displacement, such as a reduction in the hours of non-overtime work, wages, or employment benefits) any currently employed individual (as of the date of the participation).
  1. A program or activity authorized under Title I of WIA must not impair existing contracts for services or collective bargaining agreements. When a program activity authorized under Title I of WIA would be inconsistent with a collective bargaining agreement, the appropriate labor organization and employer must provide written concurrence before the program or activity begins.
  1. A participant in a program or activity under Title I of WIA may not be employed in or assigned to a job if: (1) any other individual is on layoff from the same or any substantially equivalent job; (2) the employer has terminated the employment of any regular, unsubsidized employee or otherwise caused an involuntary reduction in its workforce with the intention of filling the vacancy so created with the WIA participant; (3) the job is created in a promotional line that infringes in any way on the promotional opportunities of currently employed workers.
  1. Regular employees and program participants alleging displacement may file a complaint under the applicable grievance procedures found at [20 CFR §667.600]; [WIA sec. 181].
  1. Customized Training – The Agreement

Must be fully executed, and will not be considered validunless it is properly signed and dated by both the employer and the Service Providers representative. A copy of the fully executed CT agreement must be part of the program participant’s file.



  1. Required Support Documentation:
  1. Properly completed CT pre-award assessment.
  2. Copy of company’s certificate of liability insurance – both commercial/industrial and workers’ compensation.
  3. CT agreement.
  4. Skill gap analysis.
  5. Training plan – progress evaluation report.
  6. Copy of job description.
  7. Copy of employer commitment to hire CT participant.
  8. Copy of attendance records – signed by employer and CT trainee (legible copies).
  9. Copy of employer’s invoices (legible copies).
  10. Copy of payment to employer.
  1. Customized Training Agreement Guidelines

The following information must be provided to Workforce Connections for customized training funding consideration under WIA Title I funds.

  1. Name and address of requesting organization, business, or agency.
  1. Contact information, title, and telephone number, fax number and e-mail address.
  1. Cost of the proposed training program:
  1. Total cost of the training program
  2. Total WIA funds requested
  3. Total employer contribution (describe in detail)
  1. Description of proposed training program:
  1. Need for training
  2. Occupational demand for trained individuals
  3. Type of training to be provided
  4. Length of proposed training
  5. Location of training site
  6. Target group for training
  7. Number of individuals to receive training
  1. Training plan:
  1. Objectives of the training program
  2. Specific skills to be learned
  3. Method of instruction
  4. Measurement of objectives and skill attainment for trainees
  1. Employer involvement and commitment:
  1. Curriculum design meeting needs of the employer



  1. Written commitment of the employer to employ WIA participants who successfully complete the training program
  1. Employer requirements for customized training for incumbent workers
  1. Item A (page 1) of this policy must be met
  1. Budget:
  1. Provide a narrative explaining how the funds will be utilized
  2. Provided an itemized budget
  1. Occupational Eligibility

Customized training is allowable for occupations which are consistent with the participant’s capabilities, are in-demand occupations which will lead to local employment opportunities enabling the participant to become economically self-sufficient and which will contribute to the occupational development and upward mobility of the participant on a career pathway.

  1. Occupations selected for customized training shall meet, at the time of completion or per company policy, the following:
  1. Full time permanent positions (minimum of 32 hours per week);
  2. All participants shall be provided benefits and working conditions at the same level and to the same extent as other working employees working a similar length of time and doing the same type of work. This will include unemployment compensation where the employer is normally required to provide such coverage to its employees; and
  3. The position provides the participant benefits per company policy, which have a monetary value (e.g., insurance, paid leave) other than those required by law.
  1. Occupations under which individuals may not participate in customized training include, but are not limited to the following:
  1. Occupations depending on commission as the primary income source;
  2. Professional occupations for which the trainee already possesses a license (e.g., real estate agent, insurance agent);
  3. Occupations dependent on tips or gratuities as the primary income source;
  4. Occupations which provide for only temporary or intermittent employment;
  5. Occupations with high labor turnover;
  6. Occupations in lower wage industries where prior skill or training is not prerequisite for hiring;
  7. Occupations which lead to relocation of establishment from one area to another;
  8. Seasonal occupations; and
  9. Occupations with a substantial number of experienced and able workers who are presently unemployed.

WIA Adult and Dislocated Worker Program

Customized -Training (CT Pre-Award Checklist)

Attachment A

Section 1: Employer Information

Complete the following Employer information.

Employer Legal Business Name:
Contact Person: / Title:
City: / State: / Zip:
Phone#: / Fax #: / E-Mail:
Type of Organization:
Individual Partnership Limited Liability Corporation For Profit
Company NAICS Code: / # of Current
Employees: / Years in Existence:
Is the Business being sold or merging with another company? / Yes / No

Section 2: Company Review

1)WARN notices have previously been filed?

Yes No

2)The company has not exhibited a pattern of failing to provide CT Trainees with continued long-term employment

Yes No

Section 3: Meeting WIA Criteria

1)Company verifies WIA funds will not be used to relocate operations in whole or in part

Yes No

2)Company has operated at current location for at least 120 days

Yes No

3)If less than 120 days and the business relocated from another area in the U.S., were employees laid off at the previous location as a result of the relocation?

Yes No

4)Company commits to providing long-term employment for successful CT trainees?

Yes No

5)CT funds will not be used to directly or indirectly assist, promote or deter union organizing?

Agree Disagree

6)The CT will not result in the full or partial displacement of employed workers?

Yes No

7)Trainee wages to be paid are at least equal to:

  1. The Federal, State or local minimum wage (Fair Labor Standards Act)

Yes No

  1. Other employees in the same occupation with similar experience

Yes No

8)Trainees will be provided the same workers’ compensation, health insurance, unemployment insurance, retirement benefits, etc. as regularemployees

Yes No

  1. Worker’ compensation company:
  2. Account #:
  3. Effective dates: to

9)The employer will comply with the non-discrimination and equal opportunity provisions of WIA and its regulations.

Yes No

Section 4: Signatures

Authorized Signatures

I hereby certify that the above information is, to the best of my knowledge, true and correct.

Employer: / Date:
Type/Print Name: / Date:
Signature: / Title:

The outcome of this pre-award interview:

Employer meets all requirements of the CT pre-award. Yes No

CT Provider: / Date:
Type/Print Name: / Date:
Signature and title: / Title:

WIA Adult and Dislocated Worker Program

Skill Gap Analysis (SGA)

Attachment B(use additional sheet if needed)

City: / State: / Zip:
Contact person: / Title:
CT Participant Name:
CT Contract #: / Position:
Incumbent Skills / Required Skills / Skills Gap [Yes or No]
please explain:
CT recommended time: / CT reimbursement recommended
% rate:
Service Provider:
Type/Print Name / Date:

WIA Adult and Dislocated Worker Program

Training Plan Development and Implementation

Attachment C

Section 1: Contact and CT information (complete the contact information for the employer and trainee)

Employer: / Contact Name: / Phone:
Trainee: / E-mail: / Phone:
CT start date: / CT end date: / Total training hours:
Hourly wage rate: / Reimbursement rate:
% / Maximum reimbursement:

Section 2: Occupational Information (complete the occupational information for the trainee’s skills level)

Job Title: / O*NET: / Hours/Week:
Required Job Skills for occupation: / Measured:
Job skill needed: / Skills attained? Yes No
Job skill needed: / Skills attained? Yes No
Job skill needed: / Skills attained? Yes No

Section 3: Trainee’s ending capabilities (to be completed by the employer)