Operations Guide for

WorkSource Montgomery, Inc. American Job Centers

Policies and Procedures Manual for the Common

Systems and Processes Across Partners

Procedures Manual American Job Center For Use by All Staff Conducting Business in any WorkSource Montgomery American Job Centers

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VISION

The vision of WorkSource Montgomery American Job Center is to be the provider of choice and the first stop resource for citizens and businesses to develop the skills and practices necessary for the creation of a world class workforce.

MISSION

The mission of WorkSource Montgomery is to help businesses and job seekers succeed with workforce services by:

• Meeting the talent attraction, development, and retention needs of strategic industries.

• Meeting the needs of the underemployed and unemployed. • Developing career pathways that lead to sustainable wage jobs.

VALUES STATEMENT

The key operating principal for WorkSource Montgomery American Job Centers is that individuals we serve deserve to be treated with respect and be afforded the opportunity to move forward in their career paths whatever they may be. The Center staff is committed to effectively utilizing and leveraging the available resources to assist job seekers and employers.

PURPOSE

The purpose of this document is to provide the policies and procedures that define customer flow and other work operations that are applicable to all staff when working in any Montgomery County Maryland Job Center.

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TABLE OF CONTENTS

Page # SECTION 1: Introduction 6

SECTION 2: Staff Related Policies and Procedures 8 • Center Management 8 • Customer Flow 9 • Front Desk Operations 9 • Scheduling Space 10 • Hours of Operation and Inclement Weather 10 • Use of Center Building for Other Purposes 12 • Media Policy 12 • Incident and Accident Reporting 13 • Emergency Plan and Business Continuity 15 • Hiring – Equal Opportunity Employer 18 • Procurement for Vendors 20 • Conflict of Interest 22

SECTION 3: Customer Related Policies 25

• Resource Room Computer Usage 25 • Paper Usage 26 • Children in the Center 26 • Customer Expulsion 26 • Customer Complaints / Grievances 27 • Accessibililty 31 • Equal Opportunity Statement 40 • Confidentiality and Protection of Personal Identifiable Information 40 • Record Retention 46

SECTION 4: Staff Guidance 49

• Conflict Resolution 49 • De-escalating Customers 50 • Time and Attendance 51 • Telephone Answering 52

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• Name Badges 52 SECTION 5: Career Services 53

• AJC Services 53 • Assessment Services 54 • WIOA Title I Programs and Eligibility Guidelines for Career / Training 54

Services • WIOA Enrollment 60 • Priority of Service 61 • WIOA Intensive Support Services 65 • Case Management and Case Notes 66 • Training Services 69 • Exemption Termination 70 • Individual Employment Plan 70 • Follow-up Services 73 • Individual Training Accounts (ITAs) 74 • On-the-Job Training (OJT) 77 • Apprenticeships 90

Supportive Services APPENDICES Customer Flow Incident and Accident Report Form Resource Area Checklist Conflict Resolution Flow Chart Confidentiality / Release of Information Conflict of Interest Statement Staff Confidentiality Agreement Participant Confidentiality Agreement Grievance Report Emergency Action Plan WIOA Eligibility Checklist Suitability Checklist WIOA Participation Agreement & Code of Conduct High Demand Occupations Locations

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Family Size & Income Worksheet Directions to Wheaton AJC Floor Maps Individual Employment Plan Template Case File Checklist ITA Plan Template ITA Checklist ITA Agreement Letter OJT Contract OJT Timesheet OJT Training Plan OJT Invoice Eligible Training Provider Link AJC Fact Sheet Adult Customer Flow Youth Customer Flow Employer Flow Employer MWE Cheat Sheet Code of Conduct Resource Area Checklist

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SECTION 1: INTRODUCTION

Welcome to the WorkSource Montgomery American Job Center (AJC). It is our goal to provide high quality customer focused services to businesses and job seekers. We are committed to creating a comprehensive service experience for our customers that exceeds their expectations.

Many partners are co-located within the Wheaton, MD AJC. Our aim is to present a job center that is integrated in its service delivery which emphasizes an employer customer approach and affirms the measurement of success in job placement which are family-sustaining. The policies, procedures and tools outlined in this manual are designed to facilitate integration across agencies, functions, and programs. They are also designed to ensure that customers have a consistent service experience in any interaction within the Center.

The Partners may request changes or clarifications to this guide at any time. Any changes must be submitted to the Workforce Development Board for inclusion into this combined document.

All WorkSource Montgomery Partners’ staff is required to be knowledgeable of the legislative and programmatic directives that impact daily operations. These directives come from a variety of sources including but not limited to: Workforce Development Board of Montgomery County, MD WorkSource Montgomery’s Consortium Partners WorkSource Montgomery Inc. Leadership The state of Maryland Department of Labor, Licensing & Regulation The United States Department of Labor and Industry’s Training and

Employment Guidance Letters (TEGLs) and Training and Employment Notices (TENs), www.doleta.gov

Benefits of a Comprehensive American Job Center

• Ease of access to all services for the customer. • Technology driven approach to efficient and effective service delivery. • A place where job seekers get what they need all in one place.

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• A place where businesses can find easy access to services they need to grow their business.

• A place where the multiple organizations who may serve the customer is transparent.

Vision of an Integrated and Comprehensive American Job Center To ensure that customers receive efficient and effective services of high quality in a seamless and respectful manner.

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SECTION 2: STAFF RELATED POLICIES AND PROCEDURES Center Management The Center is managed through the partnership of both co-located and non-co-located partners. At an operational level, WorkSource Montgomery, Inc. and the Maryland Department of Labor, Licensing and Regulation (DLLR) is responsible for the day-to-day operational issues that arise within the Center. The staff of all co-located Partners will integrate service functions as required to deliver universal services as envisioned by the existing Memorandum of Understanding (MOU) and the Workforce Innovation and Opportunity Act. This service integration will be defined over time through the work of the American Job Center Management Team, the Consortium Partners, and the Workforce Development Board (WDB). Role of the AJC Manager The Center Manager’s role is to provide operational oversight and support to the Center.

While the following is not the complete job description, it is a listing of the essential functions of the position:

1. Provides daily functional supervision of staff. 2. Organizes and directs operations for business, community and job seeker

customers. 3. Establishes and communicates performance standards and measurable

objectives. 4. Enforces policies and procedures. 5. Responds to requests for information from internal and external customers,

the media, and the general public. 6. Implements a performance-driven and outcomes-based service delivery

system. 7. Implements and executes a continuous staff development process. 8. Ensures effective operational processes for seamless delivery of services

across multiple Partner organizations, partnerships, and funding streams.

The Manager for the site is responsible for operational management, scheduling, ensuring that services are being delivered in accordance with the Partnership’s

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products and processes measuring/monitoring customer satisfaction. The Manager provides work direction to all partner staff with regard to day-to-day operational needs. The Manager, through functional supervision, will ensure all staff operate within the agreed upon policies and procedures to manage staff with the agreed upon protocols for operations, and operate in accordance with the WDB quality standards. Per the Human Resource Guidance for the Development and Implementation of Comprehensive American Job Centers issued on January 30, 2009, the Center Manager may provide work direction to employees for whom they are not a direct supervisor. This onsite work direction and guidance may be related to work schedules, breaks, and leave to ensure interagency coordination and to ensure customer satisfaction. The Center Manager and other partner staff may also be asked, at the discretion of the specific agency supervisor, to provide performance feedback if solicited by the supervisor. Customer Flow To ensure the most customer friendly and welcoming environment for our job seeker customers and to ensure that their experience at the Center is efficient, a customer flow process map has been developed for each service area (Adult & Dislocated Workers, Youth and Employers (see Appendices). Front Desk Operations When staffing the front desk, staff will be responsible for:

1. Ensuring appropriate sign-in and sign-out of customers and partners. Front desk staff signs the customers in electronically using the sign-in system on the front desk computer. Partners sign-in using the sign-in sheets on the front desk located in the partner sign-in book. Staff leaving the Center must sign out.

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2. Maintaining the Resource Area. Ensuring that the area is clean and neat with no obstructions in the walkways, resource information organized on display, books in shelves, no wires causing a hazard, paper in the printers/fax, etc.

3. Checking and using the reference material behind the Front Desk. The

references provide the Front Desk staff with schedules of appointments for the day; partner schedules; calendars of events and other resources that will help to answer customers’ questions and to direct them appropriately. The Center Manager and Partners will keep these references current. It is the responsibility of any staff stationed at the front desk to check them and be familiar with the contents.

Scheduling Space To secure a room(s) to conduct a meeting, workshop, job fair, recruiting event or any other type of activity for the AJC or satellite location, contact the AJC Manager by email stating:

• the nature of the event • number of expected attendees • desired date and time • if you have a room preference • any equipment or accommodations needs

The AJC Manager will coordinate room allocation. Hours of Operation and Inclement Weather The Wheaton (located at 11002 Veirs Mill Road, Wheaton, MD 20902) and the Germantown (located at 12900 Middlebrook Road, Germantown, MD 20874) American Job Centers are open to the public from 8:30 a.m. to 5:00 p.m. Monday through Thursday and from 8:30 a.m. to 3:00 p.m. on Fridays. Hours do

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not vary unless a weather-related incident or other incident involving a delayed opening or closing occurs (See Policy #2012-05 Inclement Weather and Business Continuity Policy). The Centers are closed for most major holidays and will follow, as a general guideline, the County holiday closings. The Centers will be closed on the following holidays:

o Martin Luther King’s Birthday

o Presidents’ Day o Memorial Day o Independence Day o Labor Day o Veterans Day o Thanksgiving Day o Christmas Day

If a known closure is to occur, within five (5) business days, staff at the Centers will post signs to that effect at all major entrances and customer areas. A notice will also be posted on the WorkSource Montgomery website and sent to other relevant media outlets. The Center will also occasionally be open some evenings and weekends as deemed necessary by the American Job Center Consortium Partners to increase access and to provide services to customers. As nightly and weekend hours are formalized they will be posted in all customer areas.

The Center will follow County closures for inclement weather. If the County in which the Center resides is closed, the Center will be, as well. All partner staff located in the Center will abide by the closure policies of their respective agencies. Thus, if the Center is open but the partner agency is closed, the agency closure supersedes the Center’s opening. It is the responsibility of staff located at the Center to inform the Manager if they are not coming to work due to weather.

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Use of Center Building for Other Purposes The Wheaton American Job Center is located in the Westfields’ South building on the Westfield’s Wheaton property. For approval on the use of the Center for any after-hours activities, please contact the Center Manager well in advance. The Germantown AJC is located within one of the Montgomery County Regional Service Centers. For approval on the use of this location for any after-hours activities, please coordinate with the Job Center Manager.

Media Policy To ensure consistent handling of general media requests and a consistent message about the Center, when relating to the media, please respond as follows:

1. Media Queries Inquiries from the media should be handled by the senior level staff in your organization most familiar with the topic. If you are unsure to whom to direct the inquiry, it is better to say nothing at all and take a message than to convey misinformation.

Activities should be discussed in a concise, factual and balanced fashion. Our collective message around the Comprehensive American Job Center is as follows:

WorkSource Montgomery Inc. and the Montgomery County Workforce Development Board are committed to helping regional businesses with their talent needs and matching livable wage jobs to the residents in the county. The Job Centers strive to ensure that customers receive high quality, efficient and effective workforce related services in a seamless manner.

Be sure to document the media inquiry by emailing the Center Manager with the details. Include the caller’s identity, contact information, affiliated

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organization, where and when the media mention will appear and the nature of the inquiry.

2. Press Releases Whenever you issue a press release about your organization and its involvement with the Job Center, be sure to send a copy to the Center Manager. To further communicate the collaborative relationship between Consortium Partners and the co-branding effort, be sure to mention that the program is supported by WorkSource Montgomery Inc. and the Montgomery County Workforce Development Board.

3. Fact Sheets

When taking contact information from the media, mention our fact sheet that describes the Center and offer to forward it. Please use it in all interactions with the media. The fact sheet will reinforce our joint messaging. This will allow us some semblance of control over a consistent voice.

Incident and Accident Reporting A report must be filled out by program staff as soon as possible after an incident occurs while memory is fresh, both non-emergency and emergency. An incident may include any of the following:

• Injuries • Disruptive behavior of customers or accompanying children/other adults • Inappropriate behavior by the customer toward staff, such as the use of

profanity, threats, or assault

• Property theft or damage • Any suspected incident of abuse.

Incident and accident report are required because:

• They capture complaints, accidents and incidents before they become claims. • They help establish a defense for claims. • They serve as the basis for analyzing the causes of incidents and accidents and

for risk mitigation exploration to prevent similar events in the future.

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• They help identify weaknesses in the current risk management policies and help to identify areas for improvement.

Risk Management: Incidents 1. Attend to those involved to assess for injuries. 2. Complete an Incident Report (see Appendices). 3. Keep the report on file by submitting the Incident Report to the AJC Manager

within 24 hours of the event. Risk Management: Accidents 1. Attend to any persons involved and provide comfort to extent possible. 2. If necessary, move yourself and injured person(s) out of any areas of

immediate danger such as fire or traffic. 3. Administer first aid, if necessary. Only administer the level of first aid that you

are qualified to perform. 4. Do not admit liability or promise to pay for expenses incurred by injured

persons. 5. Call or ask a bystander to call 9-1-1 or the emergency number for police,

ambulance and/or fire department, if necessary. Provide as much helpful information as possible: location, victim’s name, observations, and description of injury. Do not leave the scene of the accident unless it is to call one of those services.

7. Complete an Incident Report (see Appendices). 8. Keep the report on file.

• Submit Incident Reports to the AJC Manager within 24 hours of the event and copy the Regional Labor Exchange Administrator.

• Should the authorities (police, EMT, etc.) be involved, notify AJC Manager immediately.

If immediate threat to life of injured employee is imminent, render first aid. If the victim can be moved they should be loaded into a vehicle and transported to the nearest medical facility. Victims who are not in a life-threatening situation may elect to be transported to a facility of their choice.

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Emergency Plan and Business Continuity In the event of a disaster, staff and volunteers will be responsible for following each individual partner agency’s procedures for ensuring the continuity of business. The WorkSource Montgomery AJC staff and subrecipient staff will be held to the WDB’s continuity policy which will apply to the Center operations. Emergency procedures for evacuating the building are to be posted in the Center. All personnel are to sign-off that they have read and understood the safety measures outlined in this manual (see Appendices).

IMPORTANT CODES TO REMEMBER

Code Definition EMY Contact Police

Lights Out Contact Security 459 Evacuate the Building

IMPORTANT PHONE NUMBERS

Germantown Wheaton Crisis Center 240-777-4000 240-777-4000 Security Officer 240-777-6161 301-946-3203 Sheriff’s Office 240-777-7000 Police Station 4th District: 240-773-

5500 5th District: 240-773-6200

Fire Non-Emergency 240-683-6520 240-683-6520 Police Non-Emergency 301-279-8000 301-279-8000 General Information & Service Request

311 311

Emergency Fire/Police 911 911

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PREFERRED MEANS OF REPORTING FIRES AND OTHER EMERGENCIES Fire 911 Explosion 911 Tornado/Severe Weather 911 Bomb Threat 911 Chemical Spill/Leak 911 Violence 911 Medical 911 Other 911 or see above list

Building Evacuation All office personnel are to be instructed on the procedure to exit the building in the event there is an emergency that would require the facility to be evacuated. Regularly occurring unannounced practice sessions are to be held to ensure a smooth exit should an emergency occur. Documentation of all training will be filed by the Center Manager. The emergency exits are to be kept clear of all obstructions at all times and will be checked on a regular basis. If an evacuation of the building is required, all employees will report to the place of safe refuge. All staff not engaged in controlling the emergency will report to the Safe Refuge Point and wait for instructions. Each supervisor is responsible for accounting for all assigned employees, personally or through a designee. Each assigned employee must be accounted for by name. All supervisors are required to report their head count (by name) to the AJC Manager, or designee. The Job Center Manager, or designated replacement, has been identified to direct operations in the event of an emergency. They duties include the following:

• Evacuation of the AJC (the space used on the 1st, 2nd, 4th and 5th floors) • Accounting for all partnering agencies. Each Agency will have a

designated person to account for individual staff members. • Insuring that all new employees are trained on procedures and any

specifically assigned emergency duties.

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Wheaton Primary Safe Refuge is located along the side of the Sears Building. Everyone will walk out of the building, cross the street and proceed to the northwest corner (facing Dick’s Sporting Goods). Germantown Primary Safe Refuge is located along the side of the DSW Building. Everyone will walk out of the building, cross the parking lot, cross the street and proceed to the wall along the side of the store. Critical Staff Certain personnel are tasked with remaining at the site to perform critical functions before they evacuate. These include floor monitors, impaired mobility assistants, those trained on how to assist customers / staff to evacuate, those trained to use a fire extinguisher, those trained on CPR / First Aid / ADE or any other applicable training. If you have not been trained on a specific task, you are to evacuate the building according to procedure. Each floor is to have a monitor appointed to thoroughly check their assigned floor and give the “all clear” signal to the AJC Manager and any authorities / emergency personnel. Staff with mobility concerns need to disclose this information to the AJC Manager so a team can be assigned to assist with evacuation. Similarly, Resource Room staff and any other staff serving customers with disabilities during an emergency evacuation, need to alert management that assistance is needed along with providing the location. Fire Only trained employees are instructed to respond to incipient fires (fires that have just started). At this stage, sometimes these fires can be extinguished with the proper extinguishing agent and knowledge of how to use a fire extinguisher. Remember - ALWAYS SEND THE ALARM FIRST.

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Selected employees have been trained how to use fire extinguishers. Those individuals that have not been trained on the use of fire extinguishers will evacuate the building according to procedure. Fire Extinguisher Location Wheaton – in the first and fifth floor kitchens, and in the second floor training room. Germantown – next to back entrance off the staff office space to the side parking lot Alarm - Wheaton There is a mechanical alarm in the building located in the 1st floor lobby for the staff on the 1st floor. Each upper floor has at least two alarms (one at each end of main corridor). The first person that identifies the emergency will give the alarm and respond as directed in this manual. Alarm - Germantown There is a mechanical alarm in the building. A verbal alarm will be given in the AJC (one floor). The first person that identifies the emergency will give the alarm and respond as directed in this manual.

Hiring - Equal Opportunity Employer WSM is an equal opportunity employer and seeks to employ individuals based upon their qualifications, experience, and ability to perform the position responsibilities. All applicants can expect a fair and completed evaluation of their application. Hiring Process 1. Posting a Vacant Position

a. All regular vacant positions will be posted on the job bulletin board and be held open for at least ten (10) working days. For emergency or extenuating circumstances, a position may be posted for less than ten days with the approval of the Board Chair.

b. All postings and advertisements shall identify WSM as an equal

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opportunity and affirmative action employer. c. With prior approval of the Board Chair, a vacant position may be

designated as an internal posting only. Such positions will be distributed internally and distributed to selected partners only.

2. Eligibility of Transfer Employees are eligible to apply for other job openings within WSM provided they have completed six (6) months continuous service in their present position. No more than one (1) transfer per employee will be granted in a 12-month period.

3. Recruitment for Positions

The CEO or their designee is responsible for coordinating outreach recruitment efforts. The CEO is also responsible for the development and implementation of a plan to recruit and select qualified minorities, women, and disabled individuals.

4. Application, Interview, and Selection Process

a. Any individual interested in employment with WSM must submit a resume, complete an employment application, and provide a list of three (3) professional references.

b. An employee interested in promotion or transfer opportunities must submit an application to the CEO.

c. No applicants may be considered for any position until a formal application has been submitted.

d. The CEO or their designee, which may include a consultant or a search firm, is responsible for processing and screening all applications and resumes of qualified applicants.

e. The CEO or their designee has the responsibility to select the applicants to be interviewed and schedule the interviews. The interviewer shall ensure: (1) all candidates are asked the same questions; (2) all questions are objective, job-related, measurable and consistently applied; (3) answers to questions are documented; and (4) all applicable EEO laws are followed.

f. Background reference checks shall be made by the CEO or their designee before an offer of employment is extended.

g. Once a hiring decision has been made, all applications, notes, reference reports, and other materials pertaining to the applicants and/or interviews must be maintained in an Interview and Selection Process file. The offer of employment is extended after the CEO has signed the Offering Letter/

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Memorandum of Employment. The employee must complete all new hire paperwork on the first day of employment.

h. Applicants who are not selected for a position will be notified by the CEO or their designee.

i. An applicant can be disqualified from employment with WSM if he or she does not meet the minimum requirements of the position, makes a false statement on the application form or during the interview process, has committed fraud during the application or selection process, or is not legally permitted to hold the position.

5. Employment of Non - Regular Part-Time and Temporary Personnel

a. To employ temporary personnel, individuals may be recruited in a less formal fashion than outlined in number 3 above.

b. Each individual will complete an application. c. An Offering Letter/Memorandum of Employment will specify the length of

time of employment and the conditions under which an extension may be offered, if needed.

Procurement for Vendors Procurement transactions, regardless of method or dollar value, will maximize open and free competition consistent with the standards of 2 CFR 200.317 to 326. Contractors to WorkSource Montgomery, Inc. (WSM)shall not engage in procurement practices which may be considered arbitrary or restrictive. General Procurement Standards(2 CFR 200.318) WSM and its contractors will use documented procurement procedures that reflect state and local laws and regulations, provided that the procurements conform to applicable Federal law and standards identified in 2 CFR Parts 200.317 through 200.326. WSM will maintain oversight to ensure that contractors perform in accordance with the terms, conditions, and specifications of their contracts or purchase orders. WSM’s Code of Conduct and Conflict of Interest Policy provides standards of conduct covering conflicts of interest and governing the actions of its employees engaged in the selection, award and administration of contracts. No employee, officer, or agent may participate in the selection, award, or administration of a contract supported by a Federal award if he or she has a

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real, perceived or potential conflict of interest. Conflicts of interest must be disclosed in writing when known in advance or announced to the voting body. The party must excuse themselves from any further discussion and/or vote on the matter in question. Further information can be found WSM’s Code of Conduct and Conflict of Interest Policy. WSM’s procurement procedures will avoid acquisition of unnecessary or duplicative items and promote cost - effective use of shared services by entering into state and local intergovernmental agreements for procurement or use of common or shared goods and services where appropriate. WSM will use Federal excess and surplus property in lieu of purchasing new equipment and property whenever such use is feasible and reduces project costs. Competition (2 CFR 200.319) All procurement transactions must be conducted in a manner providing full and open competition consistent with the standards provided in section 200.319 of 2 CFR 200. In order to ensure objective contractor performance and eliminate unfair competitive advantage, contractors that develop or draft specifications, requirements, statements of work or invitations for bids or requests for proposals must be excluded from competing for such procurements. Methods of Procurement WSM contractor procurements shall be made using one of the following methods: (a) small purchase procedures, (b) competitive sealed bids, (c) competitive negotiations, (d) non-competitive negotiation and shall be made in accordance with procedures set forth by OMB (2 CFR 200.320) at a minimum: Small Purchases Under $10,000

1. Micro-purchases (purchases of $1 -$5,000): Procurement by micro-purchase is the acquisition of supplies or services, the aggregate dollar amount of which does not exceed the micro-purchase threshold (currently $5,000). Micro-purchases may be awarded without soliciting competitive quotations if WSM’s contractor considers the price to be reasonable.

2. Small Purchases (purchases of $5001 -$10,000): Small purchase procedures

are those relatively simple and informal procurement methods for securing services, supplies, or other property. For purchases which cost less than $10,000 efforts will be made to get the lowest and best price. If small purchase procedures are used, price or rate quotations must be obtained

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from at least three qualified sources. Any purchases within this threshold must be approved by WSM CEO or designee before purchase is made.

Purchases over $10,000 WSM’s contractors are not permitted to engage in purchases over $10,000. If services or products are required for program operation that exceeds $10,000, WSM will work with the contractor to procure needed services or products. Conflict of Interest Conflict of interest, real or perceived, will not be tolerated. Any duality of interest or real or perceived conflict of interest on the part of any Workforce Investment Board (WDB) members, staff and vendors shall be disclosed to the Chair of the WBD or the CEO and made a matter of record, when the interest becomes a matter of Board action. A member must publicly declare that a possible conflict of interest exists before the agenda item in question is introduced. A member must disclose the nature of the conflict. The person chairing the meeting will then acknowledge the declaration. Members involved in an acknowledged conflict of interest must refrain from all discussion and abstain from all voting relative to the affected agenda item. The minutes of the meeting shall reflect that a disclosure was made and the abstention from voting and the discussion. The conflict of interest policy shall be reviewed annually at a meeting of the Board to provide information and guidance to the members. Any new members of the Board shall be advised of the policy upon entering the duties of his/her office and shall sign the Conflict of Interest Statement annually. Requirements

1. No individual in a decision-making capacity shall engage in any activity, including participation in the selection, award, or administration of a subgrant or contract supported by WIOA funds, if a conflict of interest (real, implied, or apparent) would be involved.

2. A WDB member or committee member must neither cast a vote on, nor participate in, any decision-making capacity on the provision of services by such member (or any organization which that member directly represents), nor on any matter which would provide any direct financial benefit to that member or a member of his immediate family. The U.S. Department of Labor’s Final Rule defines to “participate in a decision-making capacity” includes to discuss an issue and to influence, or try to

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influence, other WDB or committee members or staff to take a position for or against an issue.

3. A conflict of interest under paragraph 1 and 2 would arise when: • An individual; i.e., employee, officer, or agent, • Any member of the individual’s immediate family (partners, spouse,

children, or siblings), • The individual’s partner, or • An organization which employs, or is about to employ an individual

(individual has received a job offer from the organization) who has financial or other interest, either through ownership or employment, and participates in the selection or award of funding for that organization or firm.

4. Members of the WDB and committees will neither solicit nor accept gratuities, favors, or anything of monetary value from contractors, potential contractors, or parties to sub-agreements. The WDB may set minimum rules where the gift is an unsolicited item of nominal intrinsic value.

5. Neither membership on the WDB nor the receipt of WIOA funds to provide training or other services shall be construed, by itself, to violate these conflict of interest provisions of the Act or Regulations.

6. Members shall not be financially interested in any contract made by them in their official capacity or in any contract made by the WDB. If a member has a remote interest in a contract that member shall disclose such interest to the WDB so that the interest can be noted in the official records; shall not influence or try to influence another member to enter into the contract or not enter into the contract; and shall not vote concerning whether the WDB should enter into the contract.

7. When the CEO determines that h/he should not make a governmental decision because s/he has a disqualifying interest in that decision, the CEO shall disclose his/her determination and disqualifying interest in writing to the Chairperson of the WDB.

8. When an employee (other than the CEO) or a consultant determines that s/he should not make a governmental decision because s/he has a disqualifying interest in that decision, that person shall disclose his/her determination and disqualifying interest in writing to the CEO.

9. If an employee is notified or becomes aware that a potential conflict of interests exists with respect to a member, employee, or vendor the employee will so inform the CEO. If the potential conflict involves an employee, the CEO will dismiss the employee from all matters related to the potential conflict. If the potential conflict involves a member, the CEO will consult with the Chairperson of the WDB.

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10. Any member who believes a conflict of interest exists with respect to another member can declare so during the appropriate meeting. If the issue is challenged or disputed by the affected member, the Chairperson of the meeting will refer the matter to the Executive Committee for final determination, and the agenda item will be tabled pending final opinion from the committee.

11. All instances of nonparticipation due to declared conflicts of interest shall be duly recorded in the minutes of the appropriate board or committee meeting and shall serve as documentation of compliance with this policy. Instances in which a member has chosen not to be present at a meeting where a conflict of interest might arise shall likewise be recorded in the minutes.

12. A WDB member must not engage in any activity determined to constitute a conflict of interest by the State of Maryland’s Ethics Law.

13. All WDB members, committee members, and staff must participate in an annual Ethics and Conflict of Interest training conducted by the WDB.

14. All WDB members, committee members, WSM staff and vendor staff must have a Conflict of Interest Form, signed annually, on file.

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SECTION 3: CUSTOMER RELATED POLICIES

Resource Room Computer Usage The Resource Room computers are tools that provide an integral service to the public for job search use. The computers are a direct link to a customer’s ability to get reconnected to employment more quickly. It is important to safeguard the computers from any act that will cause harm.

Please have customers adhere to the following:

• Customers may not bring food or drinks near the computers. Staff working in the Resource Room should be good role models of this practice.

• Customers may not hit, bang or move the computers as this may cause damage to the unit.

• Customers may not unplug or detach any physical wires from the computers to the wall and vice versa.

• Customers are encouraged to ask for assistance if the computers are not working.

• Customers may not download/upload any foreign programs to the computers or alter settings to the computers set by the staff.

• Customers may only use the computers for job search purposes.

Staff will explain to customers at the time of arrival about the time limits set for computer usage. Due to the nature of customer flow within the Centers and the desire to provide equitable customer service to all visitors, customers are assigned a personal identification number (PIN) to use each time they visit. This PIN will be entered into the Resource Room computer to gain access. Once a customer receives their computer assignment, they have 90 minutes to conduct their business. If no one is waiting for a computer, the customer’s time will be automatically extended by 15 minutes. Once the time is completed, the customer will be automatically logged off. Prior to log off time, the customer will receive several pop-up messages announcing the remaining time available.

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Paper Usage Customers may print or copy only job search related material and are limited to using a maximum of 20 pages each day. Individuals staffing the front desk will be responsible for providing customers with 20 sheets (approximately) upon request to either place in the printer or the copy machine.

Children in the Center Customers are not encouraged to bring their children to the center. It is important to recognize that the Resource Area is an area designed for customers to work on their job search with minimal distraction. Therefore, staff may politely ask a parent to leave the Center with their child if the child is being disruptive or exhibits signs of being ill.

Customer Expulsion Staff has the right to curtail AJC access to anyone for specified reasons and customers have the right to ask to be reinstated. Customers shall receive three (3) warnings for behavior deemed inappropriate. Upon receipt of the third warning and the fourth incident, customers shall be asked to leave the Center permanently.

The customer will also receive the following reinstatement procedure. If you have been asked to leave the Center and not return at all, you may ask to be reinstated. You must follow these steps: 1. Write a letter or an email to the Center Manager specifying the behavior that

caused your permanent removal from the Center, describing the impact it may have had on witnesses, and stating that you will never engage in that behavior again while at the Center.

2. Participate in a face-to-face interview with the Center Manager, if requested.

3. Agree that the Center Manager has the right to make the final determination of reinstatement.

Behaviors that warrant permanent expulsion are:

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• verbal abuse of staff or other customers • inappropriate physical behavior • inappropriate use of Center resources • use of pornography on the Internet

Staff must fill out an incident/accident report upon each warning and final expulsion. The purpose is to keep a record and to notify all Centers that the customer has been expelled along with the reason for expulsion (see Appendices). Customer Complaints / Grievances

Individuals, specific classes of individuals, or authorized representatives may file complaints/allegations of discrimination regarding WorkSource Montgomery under the following policy guidelines.

General Complaint

A general complaint is an expression of dissatisfaction when a customer believes that the administration of a policy, procedure, rule or condition of service has resulted in unfair treatment.

Discrimination Complaint

A discrimination complaint is based on race, color, religion, sex, sexual orientation, gender identity, national origin, age, disability, political affiliation, or belief.

It is the policy of the WSM, Inc. to:

1. Establish and maintain local procedures and a process for managing complaints.

2. Appoint a single individual as the WSM AJC Complaints Officer for each type of complaint — discrimination (WSM EOC Officer) and programmatic (Manager, American Job Center (AJC)).

3. Provide information about the content of the complaint and concern procedures to WIOA participants and other interested parties affected by the local workforce system, including AJC partners and service providers.

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4. Require that every entity (such as service providers), receiving WIOA Title I funds, provide complaint and concern information to participants receiving WIOA Title I funded services.

5. Make reasonable efforts to make sure that the complaint and concern information is understood by the participants and other individuals. This includes youth and those who speak limited English. These efforts must be in compliance with the language requirements.

6. WSM and subrecipients must provide initial and continuing notice to each WIOA participant, members of the public, and any interested parties of the local complaint and concern procedures and instructions on how to file a complaint or concern.

A copy of a written description of the local complaint and concern

procedure includes: • Notification that the participant has the right to file a complaint or

concern at any time of the alleged violation; • Instructions and timeline for filing a complaint or concern; and • Notification that the participant has the right to receive technical

assistance.

7. Allow an opportunity for informal resolution at the local level. 8. Allow an opportunity for a local hearing. The local hearing must be

completed within 60 days of the filing of the complaint or concern. 9. Allow an individual alleging a labor standards violation to submit a

grievance to a binding arbitration procedure. Binding arbitration must be provided for in the collective bargaining agreement covering the parties to the grievance.

10. Allow an opportunity for a local level appeal to the State when: a) no decision is reached within 60 days; or b) either party is dissatisfied with the local hearing decision.

Any WIOA participant or other interested party believing they have been adversely affected by a decision or action by the local workforce system, including decisions by subrecipients, has the right to file a complaint with WSM. Complaints must be submitted in writing and be signed by the complainant.

At a minimum, complaints must contain the following information:

• Complainant's name; • Mailing address, or other means by which the complainant may be

contacted; • Identification of individual’s or organization responsible for alleged issue;

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• A description of the complainant's allegations, which must include enough details to determine the jurisdiction of the complaint and the date(s) the alleged incident(s) took place, and

• The Complaint’s signature and signature date or the signature of his/her authorized representative.

WSM, its subrecipients and service providers have the responsibility to provide assistance to complainants, including those complaints or concerns against WSM. Such technical assistance includes providing instructions on how to file a complaint or concern, providing relevant copies of documents such as WIOA law, regulations, local rules, contracts requirements, and providing clarifications and interpretations of relevant provisions.

To the extent possible, complaints and subsequent investigations will be handled in confidence. However, total confidentiality is usually not possible if a complaint is to be resolved. This assistance requirement does not allow WSM or subrecipients to violate rules of confidentiality unless complainant has signed a release. Without this, a proper investigation including involvement of WSM staff or others may not be conducted.

At all levels of the complaint or concern process, complainants have the right to be represented, at their own expense, by a person(s) of their choosing.

All complaints or concerns, amendments, and withdrawals that are not solved informally must be in writing. All persons filing complaints or concerns shall be free from restraint, coercion, reprisal, or discrimination. Guidelines Due Process Due process is the established series of actions designed to protect the legal rights of an individual. All persons affected by WIOA should be made aware of their rights and have access to appropriate remedies. Local complaint procedures contain full due process protections. Accurate and Complete Fact Finding Fact-finding is the discovery or determination of facts and is the first step in the process for complaint management. WIOA requires complaint procedures that ensure accurate fact-finding in preparation for a local hearing.

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Fact finding will assist in identifying the type of complaint. The WSM Complaint Officer and DLLR’s Regional Labor Exchange Administrator must be notified immediately if there are criminal complaints involving fraud or abuse. An Incident Report must be provided after immediate notification. Generally, fact-finding includes:

• Establishing the official record. • Determining the exact laws, regulations, or policies that have been

violated. Participants may have language limitations or other barriers. The individual conducting the fact-finding should establish what they heard, what the issue is, and what exact laws, regulations, or policies have been violated.

• Creating an accurate and complete record about the complaint. Detailed note taking is needed. Notes should be typed into a report format with complete details about the complaint.

• Listening to the complainant. Understanding an individual's complaint or concern is important; there is a reason they came to your office or contacted you.

• Taking a complaint in person or by the telephone. This is an important part of the process. The complainant may need assistance with the complaint.

• Determining what is causing this individual to contact you. Determine what the problem is, who is causing the problem, and how the problem should be addressed.

• Determining the facts from the complainant's point of view. Ensure that all the necessary information is gathered. This may be the first indication of the type of complaint and determining next steps in the process to follow to resolve the complaint or concern.

• Obtaining copies of documents from the complainant for the complaint file.

• Organizing and processing. The complaint needs to be processed and compared to the requirements in the law, regulations, and policies. Complaints inform the system that the WIOA program may not be working correctly.

Accurate and complete fact-finding should enable the system to determine whether the complaint is a violation of a law, regulation, fraud or abuse, an EO issue, or a program violation.

All complaints must be forwarded to the appropriate WSM AJC Manager. WSM will retain a singular log to document and track to closure all complaints.

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Note: Complaints/allegations do not have to be submitted on a prescribed complaint form in order for them to be considered valid complaints or allegations.

WSM General Complaint Officer Name: Camille McKenzie Address: 11002 Veirs Mill Rd, Wheaton, MD 20902 Phone/email: cmckenzie@worksourcemontgomery.com WSM EOC Officer Name: Annette Gantt Address: 1801 Rockville Pike, Suite 320, Rockville, MD 20852 Phone/email: 240-641-6735 / agantt@worksourcemontgomery.com DLLR Contact Name: Barbara Ebel Address: 11002 Veirs Mill Rd., Wheaton, MD 20902 Phone/email: 301-929-4390 / barbara.ebel@maryland.gov Accessibility WorkSource Montgomery considers individuals with disabilities an important element of diversity and ability within the AJCs. Individuals with disabilities must be treated with respect and give customer-centric services within both the universal AJC offerings, as well as within WIOA and other WorkSource Montgomery programmatic offerings.

No individual is to be excluded from participation in, denied the benefits of, subjected to discrimination under, or denied employment in any program or activity, funded in whole or in part under WIOA, due to race, color, religion, sex, gender identity, national origin, age, disability, or political affiliation or belief.

Program operators must use the same processes for all customers, including individuals with disabilities. The program operator will also make reasonable modifications in practices and procedures when the modifications are

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necessary to avoid discrimination on the basis of disability, unless making the modifications would fundamentally alter the nature of the service, program, or activity. The need for an accommodation/modification shall not adversely affect the consideration of a qualified individual with a disability for aid, benefits, services, and training.

Ensuring Nondiscrimination The following actions should be taken to ensure nondiscrimination of individuals with disabilities: • Ensure WSM AJCs are American with Disabilities Act (ADA) compliant and

equipped with auxiliary aids and accommodations. This should include a list of currently available assistive technology devices and services within the centers available for individuals.

• Ensure individuals are aware of compliance through use of signs or other means of visibility. "Equal Opportunity is the Law" must be prominently displayed within the AJCs and made available in other formats as requested.

• Ensure individuals are aware of the ability to receive reasonable accommodations. Notice of the availability and right to receive reasonable accommodations must be posted.

• Rejection of all job orders from any employer that specifies it will not accept applications from individuals with disabilities or from applicants with a certain disability. Under the law, individuals with disabilities must be referred for the same range of positions as any other qualified customer.

• Maintain confidentiality and not disclose disability-related or other medical information about an individual to an employer or partnering organization unless the job seeker has requested the disclosure on their behalf.

• Incorporate information on accommodations and rights of all individuals, including individuals with disabilities, in orientations.

• Refrain from stereotyping individuals with disabilities when evaluating their skills, abilities, interests and needs.

• Periodically review eligibility criteria for services or training to eliminate elements that may screen out individuals with disabilities (unless criteria is directly related to specific training or services and is essential), such as • Literacy/Numeracy level requirements to access services that may

unnecessarily prevent individuals with intellectual, cognitive or development disabilities from accessing services.

Program operators are subject to the following provisions of law: • Section 188 of the Workforce Innovation and Opportunity Act, which

prohibits discrimination on the grounds of race, color, religion, sex, national

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origin, age, disability, political affiliation or belief and requires that reasonable accommodations be provided to qualified individuals with disabilities in certain circumstances.

• Section 504 of the Rehabilitation Act, which prohibits discrimination against individuals with disabilities by recipients of Federal financial assistance.

• Title I of the Americans with Disabilities Act, which prohibits discrimination in employment based on disability.

• Title Il of the Americans with Disabilities Act, which prohibits State and local governments from discriminating on the basis of disability.

• Section 427 of the General Education Provisions Act, which requires recipients to ensure equitable access to, and participation in, certain programs run by the U.S. Department of Education.

• Maryland's Anti-Discrimination Laws, which prohibits discrimination on the basis of marital status, sexual orientation, gender identity, or genetic information in addition to those covered by Section 188 above.

Disclosing Disabilities Individuals may or may not choose to disclose that they have a disability. The individual does not have to document a disability to register at the AJC or to receive universal services.

Staff should only ask individuals if they have a disability if this question is asked of all customers using the AJC or program and for data collection purposes, or for customer service and satisfaction improvements. Staff may ask individuals whether they are able to perform the essential functions of a job, training, or activity, but should not directly ask if an individual has a disability.

If it appears that an individual with a disability may need an accommodation, staff may ask the individual if he or she can participate in a specific aid, benefit, service, or training with or without an accommodation. If the individual indicates that an accommodation is not needed, no further inquiries about the disability may be made. The individual's response must determine the Job Center's/program's actions. If the individual discloses a disability, staff must inform the individual that: • Providing information about one's disability is voluntary; • The information will be kept confidential as provided by law; • Refusal to provide the information will not subject the individual to adverse

treatment; and • The information will only be used in accordance with the law.

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For WIOA Title I services, individuals with disabilities do not need to verify a disability to be served; however, it would benefit the individual to provide documentation of the disability to receive priority of service and to receive connections to additional resources. If individuals with disabilities request accommodations on any testing for service delivery purposes, documentation of the disability will be required. Additionally, some discretionary grants may require individuals with disabilities to show documentation of their disability for eligibility purposes.

Specific information on disabilities gathered for program eligibility purposes, including medical information gathered, must be kept confidential and maintained in a separate, secure file that is only available to authorized individuals. Medical information given to staff verbally by a person with a disability is also regarded as confidential and should not be released without written consent of the person with a disability.

Reasonable Accommodations Reasonable accommodations, modification, providing effective communication, and auxiliary aids and services will hereinafter be referred to as "reasonable accommodations." A reasonable accommodation is a change in the way the program is administered that enables an individual with a disability to receive benefits, services and training equal to those provided to individuals without disabilities.

Program operators providing services will provide reasonable accommodations to qualified individuals with disabilities who utilize WIOA career and training services and WIOA youth program services to ensure equal access and opportunity.

The policies pertaining to reasonable accommodations apply to qualified individuals with disabilities in regard to: • Registration and orientation, • Initial screening, assessments, and testing, • Service delivery, including career services, training services, and support

services, and • Continuous improvement.

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Program operators must not place a surcharge on an individual with a disability, or any group of individuals with disabilities, to cover the costs of measures associated with providing auxiliary aids, services, or assistive technology, that are required to provide that individual or group with the nondiscriminatory treatment required by WIOA Title I. Types of Accommodations There are many forms of reasonable accommodations. Staff and the individual with a disability should work together to identify the most effective reasonable accommodation for that individual. Determining the most reasonable accommodation should be done as quickly as possible to avoid delaying access to services.

Auxiliary Aids Services and Assistive Technology To afford individuals with disabilities an equal opportunity to participate in and enjoy the benefits of the WIOA Title I or Title Ill program or activity, the program operator must furnish appropriate auxiliary aids or services, including effective means of communication, where necessary. In determining what type of auxiliary aid or service is appropriate and necessary, program operators must give primary consideration to the requests of the individual with a disability. Primary consideration means honoring the choice unless the agency can demonstrate that another equally effective accommodation is available, or that using the means chosen would result in a fundamental alteration in the service, program, activity, or undue financial and administrative burdens.

A non-exhaustive list of auxiliary aids and services can be found in 29 CFR S 38.4, and includes: • Qualified interpreters, note-takers, transcription services, written materials,

telephone handset amplifiers, assistive listening systems, telephones compatible with hearing aids, closed caption decoders, open and closed captioning, telecommunications devices for deaf persons (TDDs/1TYs, video telephones, or video remote interpreting devices), videotext displays, or other effective means of making aurally delivered materials available to individuals with hearing impairments;

• Qualified readers, taped texts, audio recordings, brailed materials, large print materials, or other effective means of making visually delivered materials available to individuals with visual impairments;

• Acquisition or modification of equipment or devices; and • Other similar services and actions.

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This obligation does not require the program operator to provide personal devices, such as wheelchairs; prescribed devices, such as prescription eyeglasses or hearing aids; or readers for personal use or study.

Facility Accessibility Montgomery County AJCs must be ready and welcoming for when persons with disabilities seek services, and as such, advance preparatory actions must be taken. Specific information on ADA accessibility guidelines for buildings and facilities is provided at https://www.access-board.gov/guidelines-and-standards/buildings-and-sites/about-the-ada-standards/ada-standards. Facility accessibility pertains to AJCs and any location where AJC staff provide service delivery. Some areas to particularly note include:

• Signage • Accessible Counters • Automatic and Power-Assisted Doors • Accessible Restrooms • Accessible Workstations • Obstacle Free Entrance • Space in Waiting Room for People Using Wheelchairs • 32-inch Clear Opening on Door • 36-inch Clear Path of Travel

The above is only a sampling of considerations.

Requests for Accommodations The Workforce Development Board (WDB) requires that all service providers ensure that requests for accommodations are taken seriously and that receipt of accommodations is easy, user-friendly, and treated in a respectful and timely manner.

The individual does not need to use the term "reasonable accommodation" when seeking assistance. A request can be made before services are received or after a customer has already begun to receive the services for which the accommodation is requested. The request for accommodations may be made by a family member, friend, or other representative on their behalf. However, staff should directly verify agreement with the customer concerning the request.

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When a person with a disability makes a request for a reasonable accommodation to any of the program operators' representatives, the program operator is required to respond to that request. Request for accommodations, modifications, and/or effective communication are requests that include the following two elements:

• A request for an adjustment or assistance; and • An indication that the request might be related to a medical condition

or disability. Requesting Documentation for Accommodations Requesting documentation for a disability can be an impediment to expedient and customer friendly service and, therefore, should usually be avoided. Documentation of a disability underlying a request for an accommodation should not be requested when:

• The request for accommodation falls within the range of adjustments that staff would normally make in providing good customer service for any customer, or

• The disability is apparent. Documentation for Testing Accommodations Assessment and testing accommodations (detailed in State Policy 2017-01: "Basic Education Skills and English Language Assessments") will be based upon the nature of the disability or special need and can include, but are not limited to:

• Braille Test Edition • Large Print Edition • Repeated Directions • Assistive Technology • Answers Recorded • Extended Time/Adjusted Time • Communication Assistance

For testing accommodations, documentation of disability must provide a comprehensive evaluation, a specific diagnosis, and objective evidence of a substantial functional limitation. The diagnostic report must include specific recommendations for accommodation(s), as well as a detailed explanation of why each accommodation is recommended. The evaluator(s) must describe the impact the diagnosed disability has on a specific major life activity as well as the degree of recommendations with specific test results or clinical

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observations. This evaluation must be made by a qualified professional whose credentials are appropriate to the disability. The name, title, and professional credentials (e.g., degrees, areas of specification, license or certification, employment) should be clearly stated in the documentation.

A written record must be made of any requests for reasonable accommodations that would require significant resources or preparation. Records must include the name of the individual, the nature of the reasonable accommodation, and the reason for the accommodation.

In keeping records pertaining to requests for reasonable accommodations in the AJCs, all staff should ensure that the documentation process does not delay or impede the provision of accommodations. Any documentation collected for reasonable accommodation considerations in the AJC should be kept with the Labor Exchange Administrator (LEA). Any documentation collected for reasonable accommodation considerations through WIOA Title I services should be kept with the appropriate Program Director or in the individual's participant file.

Responding to Requests for Accommodations All staff members should be able to provide or arrange basic accommodations on their own initiative in the most expedient and customer friendly way possible. The AJCs are encouraged to appoint a staff member the Disabilities Coordinator; someone familiar with the ADA law and can provide consultation to staff on reasonable accommodations and effective means of communication for individuals with disabilities.

Denying a Request for a Reasonable Accommodation The program operator may deny a request for a reasonable accommodation based on the following criteria: • The program operator has determined the customer does not have a

disability. The program operator has determined that the absence of the requested reasonable accommodation would not limit the customer's ability to have genuine, meaningful participation in and derive an equal benefit from the AJC’s aids, benefits, services and training, OR

• The program operator has determined that there is no accommodation that would be effective in improving the customer's ability to have genuine, meaningful participation in and derive an equal benefit from our aids, benefits, services and training.

The denial of an accommodation requires review and decision-making at the administrative level. If a staff person believes that it may be appropriate to seek

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documentation of a disability underlying a request for accommodation, that staff person should present the recommendation to the designated Equal Opportunity (EO) Officer or administrative level designee. The EO Officer will consider the recommendation, and if appropriate, conduct the inquiry.

Requests that cannot be provided or which are believed to pose an undue burden must be reviewed by the EO Officer. In situations where the program operator believes that the proposed accommodation would cause undue hardship, the program operator has the burden of proving that the accommodation would result in such undue hardship. The EO officer is the only person with authority to determine undue hardship on behalf of the program operators.

The EO Officer is Annette Gantt, Director of Operations, and can be reached at agantt@worksourcemontaomery.com or at 240.641-6735.

Written Notification of Accommodation Denial A written statement of the reasons for reaching these conclusions will accompany the decision of an accommodation denial. The program operator will provide a copy of the statement of reasons to the individual who requested the accommodation, modification, auxiliary aid or service, and in alternate format or with other auxiliary aids for effective communication, as appropriate.

The written notice of denial must: • Explain the reasons for the denial; • Inform the customer of his or her rights to file a complaint with the Department

of Labor Civil Rights Center and Department of Justice, Office of Civil Rights; • Provide instructions for initiating such complaints.

A copy of this notice of denial must be provided to the State Equal Opportunity Officer.

Additionally, if the denial is based on a determination of undue burden, the written notice of denial must also document that all the required factors that must be considered in determining undue burden were considered and be reviewed by an attorney versed in ADA.

Continued Responsibility of Program Operator After a determination of undue hardship, the program operator must still take any other action which would not result in such burden, but which would improve, to the maximum extent possible, the customer's ability to participate in and benefit from the AJCs aids, benefits, services, and training. If an

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accommodation would result in undue hardship, the program operator will give the individual with a disability the option of providing the accommodation. The program operator must also offer to cover the costs of the reasonable accommodation up to the limit of undue burden and to allow the customer to cover any costs above that threshold.

Notice of Right to File a Grievance / Complaint

• Individuals who believe that they have been discriminated against in failure to provide accommodations, may file a complaint with the EO Officer. Information on how to file a complaint is addressed in Section 3, Customer Complaints / Grievances.

DEI Coordinator Name: Kyeshia Barlow Address: 11002 Veirs Mill Rd, Wheaton, MD 20902 Phone/email: kbarlow@worksourcemontgomery.com

Equal Opportunity Statement Materials made available to the public, including newspaper advertisements, must contain the following: Auxiliary aids and services are available upon request to individuals with disabilities. Equal Opportunity Employer/Program. Whenever the WorkSource Montgomery address/phone number is listed, the TTY number must also be listed. Confidentiality and Protection of Personal Identifiable Information (PII) Respecting the privacy of our clients and protecting their confidential information is a basic value of WSM. Employees, contractors, consultants, volunteers and board members of WSM (herein “staff and representatives”) may be exposed to information which is confidential and/or privileged and proprietary in nature. As part of grant activities, staff and representatives may have access to large quantities of personally identifiable information (PII) relating to staff and individual

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program participants. This information could be found in personnel files, participant data sets, performance reports, program evaluations, grant and contract files, and other sources. All staff and representatives are required to take aggressive measures to mitigate the risks associated with the collection, storage, and dissemination of sensitive data including PII. It is the policy of WSM that such information must be kept confidential both during and after employment or volunteer service. “Confidential” means that an individual is free to talk about WSM, and about the programs, but an individual is not permitted to disclose clients’ names or talk about them in ways that will make their identity known. No information may be released without appropriate authorization. WSM expects all its agents to respect the privacy of clients and to maintain their personal and financial information as confidential. Access to any PII must be restricted to only those staff and representatives who need it in their official capacity to perform duties pertaining to the scope of work in the grant or contract agreement. Procedures Individuals must be informed in writing via the Confidentiality Agreement (see Appendices) that their information will be protected and that their personal and confidential information: • May be shared among federal and state agencies, partner staff and

contractors; • Is used only for delivering services and that further disclosure of their

confidential information is prohibited; and that • PII will be used for grant and eligibility purposes only. Every individual receiving WIOA or other WSM services must read, sign and date a Release of Information form (see Appendices) to share their information with partner agencies. Individuals must be informed that they can request their information not be shared among partner agencies and that this does not affect their eligibility for services. Staff and representatives should engage in practical ways to reduce potential security breaches and protect sensitive information and PII by: • Reducing the volume of collected and retained information to the minimum

necessary; • Limiting access to only those individuals who must have such access; and

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• Using encryption, strong authentication procedures, and other security controls to make information unusable by unauthorized individuals.

Medical and Disability Records Medical and disability records are additionally protected as confidential information. To ensure the information is protected, any medical or disability records must be kept separately from working participant files and kept in a secured physical and/or electronic location. Only the portion of the participant’s information that reveals the presence of a disability or other data element should be included in the participant’s file to minimize staff and representative access to medical files. Once collected, access to the medical file should be limited and only accessed: • With the approval of program management and only when necessary for WIOA

service delivery, • By first aid and safety personnel in the event of an emergency, or • By local, state, or federal monitors. When all WIOA or other WSM services are complete and the participant file is ready to be archived, participant medical and disability-related information must be placed in a sealed envelope and marked “Medical and Disability Information.” Social Security Numbers Social security numbers are additionally protected as high-risk information. Use of Social Security Numbers (SSN) for customers is critical to meeting performance outcomes (Common Measures) for the Wagner-Peyser, Workforce Innovation & Opportunity Act, and Industry Partnership funded training programs. Most Department of Labor performance measures are based on outcome information accessed through employer wage records. When requesting a participant’s social security number, staff and representatives should explain how the social security number will be used (for federal reporting purposes) and the safeguards in place to ensure confidentiality and the participant’s privacy. Staff should address any customer concerns about releasing such personal information.

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An individual is not required to provide their social security number to receive WIOA services, and services cannot be denied to an individual due to their refusal to disclose their social security number (5 U.S.C. Section 552a Note). Whenever possible, staff and representatives should use unique identifiers such as state ID numbers for participant tracking instead of social security numbers. While social security numbers may be needed for initial eligibility or performance purposes, a unique identifier should be linked to each individual record and used thereafter. This includes such records as training or contract documents. If social security numbers are to be used for specific tracking purposes, they must be stored or used in such a way that it is not attributable to the individual. For example, a training document should not include the participant name and social security number, rather the participant name and a truncated social security number. Physical Data Security Requirements When a staff or representative’s desk is unattended, it is the staff or representative’s responsibility to ensure that personal and confidential information, including PII, is properly filed and stored. This means that all documents containing personal and confidential information must not be left on desks, fax machines, printers, or photocopiers unattended. In addition, any electronic files that are open on the desktop with PII should be closed and computers logged off when unattended to reduce inadvertent security risks. All staff should secure mobile equipment, such as laptop computers and other devices that may have PII stored on them. Devices should be password protected and safeguarded when not in use. When not directly working with these documents, documents must be properly filed or stored to prevent inadvertent disclosure of information. Information must be stored in a secure location when not in use or shredded if no longer necessary. Accessing and storing data containing PII on personally owned equipment is discouraged. Any participant files stored for performance or archiving purposes must be clearly marked as containing personal and confidential information. Staff and representatives should retain participant PII only for the period required for

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assessment or performance purposes. Thereafter, all data must be destroyed by a qualified company to minimize risk of breach. Transmission of Confidential Information Staff and representatives should avoid communicating sensitive information or PII about an applicant or participant to partner agencies or other staff via email. If it is necessary, staff and representatives must ensure that the intended recipient is the only individual that has access to the information and that the recipient understands they must also protect the information. Staff and representatives must only communicate sensitive information or PII through WorkSource Montgomery emails and not through third party or personal email addresses. PII and other sensitive data transmitted via email or stored on mobile data storage (such as thumb drives) must be encrypted. Staff and representatives must not e-mail unencrypted sensitive PII to any entity, including the Department of Labor, WDB staff, or contractors. Staff and representatives should discourage participants from emailing personal and confidential information to their career specialist. If a participant sends a staff or representative PII via email, the staff or representative should immediately delete the email and subsequently delete the email from the “Deleted Items” folder in their email. Any information posted to social media sites is considered public record and is subject to public disclosure. No sensitive information or PII should be posted to social media sites. Care shall also be taken to ensure that unauthorized individuals do not overhear any discussion of confidential information. Security Breaches Any staff or representative who becomes aware of any security breach resulting from the inadvertent or intentional leak of release of confidential information, including PII, shall immediately inform their direct supervisor. Supervisors should assess the likely risk of harm caused by the breach and then assess the level of breach. Supervisors should bear in mind that notification when there is little or no risk of harm might create unnecessary concern and confusion. Four factors should be considered to assess the likely risk of harm: • Nature of the Data Elements Breached • Number of Individuals Affected • Likelihood the Information is Accessible and Usable • Likelihood the Breach May Lead to Harm Notification of the security breach should be provided to WSM and the Workforce

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Development Board if the breach is believed to cause harm. WSM will inform the Maryland Department of Labor, Licensing and Regulation (DLLR)of breaches believed to cause harm. Breaches subject to notification requirements include both electronic systems, as well as paper documents. The notification should be provided in writing within 3 business days and should be concise. The notice should include the following elements: • A brief description of what happened, including the date(s) of the breach and

of its discovery; • To the extent possible, a description of the types of personal information involved

in the breach (e.g., full name, Social Security number, date of birth, home address, account number, disability code, etc.);

• What the agency is doing, if anything, to investigate the breach, to mitigate losses, and to protect against any further breaches.

Staff Compliance All staff and representatives shall sign the Staff Confidentiality Agreement (see Appendices) to acknowledge that they have read the policy, understand the confidential nature of participant and staff data and the potential sanctions for improper disclosure, and agree to abide by all other requirements and terms contained therein. Unauthorized disclosure of confidential or privileged information is a serious violation of this policy. Any failure to comply with confidentiality requirements identified in this policy may result in termination of suspension of contractor employment, or the imposition of special conditions or restrictions to protect the privacy of participants or the integrity of PII data. Misuse or noncompliance with PII data safeguards could lead to civil and criminal sanctions per federal and state laws. It is recommended that all AJC Staff take the PII training offered by its own agency and read the following PII references: Law • Workforce Innovation and Opportunity Act of 2014 (WIOA) • Privacy Act, Section 7 – 5 U.S.C. Section 552a Note (Disclosure of Social

Security Number) Federal Guidance • Training and Employment Guidance Letter (TEGL) 05-08 –Policy for collection

and Use of Workforce System Participants’ Social Security Numbers

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• TEGL 39-11 – Guidance on the Handling and Protection of Personally Identifiable Information (PII)

• OMB Memorandum M-07-16 –Safeguarding Against and Responding to the Breach of Personally Identifiable Information

Record Retention Grantees, subrecipients, fiscal agents, and contractors are required to maintain and retain records of all fiscal and program activities funded under WIOA. With some exceptions, such records must be available to the public. Program operators must retain records in a way that protects the confidentiality and personal information of participants. Records must be secured in locked file cabinets, locked file areas or desks that do not permit unauthorized users access. Types of records that must be maintained:

• Records pertinent to grants, grant agreements, interagency agreements, contracts or any other awards, including financial, statistical, property, and supporting documentation.

• Records of non-expendable property. • Program and data validation records pertinent to applicants, registrants,

eligible applicants/registrants, participants, employees, and applicants for employment.

• Records regarding complaints and actions taken on complaints. • Copies of records made by microfilming, photocopying, or similar methods

may be substituted for original records if they are preserved with integrity and are admissible as evidence. All records must be maintained in a format compatible with current technology.

In the event of the termination of the relationship between WSM and the subrecipient, the subrecipient is responsible for maintaining and retaining their own records for the required retention timeframe. WSM will take responsibility for maintaining and retaining the records of the subrecipient if and/or when the subrecipient provides written notice of its inability to maintain and retain the records. Limitation of Public Access to Records Personal records of WIOA registrants are private and confidential and will not be

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disclosed to the public. Personal information will be made available to the WDB, WSM staff, and WSM partners or service providers upon request for the purpose of program and/or financial monitoring and audits. In addition, this information may be made available to persons or entities having responsibilities under WIOA, including representatives of:

• The U.S. Department of Labor • The Governor • WIOA Grant Recipients and Public

Agencies • Governor’s Workforce Development Board • Local Subrecipients • WSM Consultants • WSM Consortium Members/Contractors • WSM Designated Auditors/Evaluators

The conditions under which information may be released or withheld are shown below:

a. WIOA registrants will have access to all information concerning themselves as individuals unless the records or information are exempt from disclosure.

b. The names of WSM, the WDB and subrecipient staff in positions funded by WIOA, in part or in whole, will be a matter of public record. Other information pertaining to the recipient or subrecipient employees will be made available to the public in the same manner and to the same extent as such information is made available on staff in positions not funded by WIOA.

Retention Timeframes All records using WIOA funds must be maintained for a minimum of three (3) years beyond the length of time in use. Additionally, WSM may require the holding of records for a longer period if specified during contract negotiations or in the contract terms. Additional requirements related to record retention timeframes:

• Grant agreements must be maintained for a period of at least three (3) years after submittal of the final expenditure report (closeout) for that funding period to the awarding agency.

• Records of property must be maintained for three years beyond the final disposition of the property.

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• Performance-related data must be kept at least three (3) years from the point that the record is no longer included in reportable outcomes, as opposed to the close of the applicant's program year. For instance: A participant exits in January 2017 and is still reported in the PY 2017 performance report for the period ending June 30, 2017. The record retention period is July 1, 2017 through June 30, 2020. • Retain all records beyond the required three (3) years if any litigation or

audit is under way or a claim is instituted involving the grant or agreement covered by the records. The records must be retained for at least three (3) years after the litigation, audit, or claim has been resolved.

All records retained beyond the mandatory retention period are subject to audit and/or review. Destruction of Records Any documents or data collected in error or that must be destroyed, must be shredded, and not placed in a public or accessible trash receptacle. After files have been retained for at least three (3) years, refer to the Annotated Code of Maryland State Government Article 10, sections 608-611 and COMAR 14.18.02 which states “The willful, unauthorized destruction or alienation of any public record is a misdemeanor subject to criminal penalties set forth in the Annotated Code of Maryland (Criminal Law Article 8, section 606). A public record may not be disposed of without authorization from the State Archivist. This authorization must be obtained by means of filing a records retention and disposition schedule with the State of Maryland.”

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SECTION 4: STAFF GUIDANCE Conflict Resolution It is expected that any conflicts between staff of partner agencies will be resolved at the lowest levels. The procedure for handling conflicts between staff and partners will be handled as follows: If a disagreement occurs between staff of different agencies while on site at the American Job Center: Step 1: Involved staff should go to their supervisors in their respective

agencies and follow their policies/procedures. Step 2: Supervisors of the respective agencies should meet to resolve,

following each agency’s procedure for documentation. Step 3: If the issue is resolved to the satisfaction of all parties, the AJC

Manager should be informed of the issue to assess whether an existing policy contributed to the disagreement/conflict and determine how best to address/modify.

Step 4: If the issue cannot be resolved to the satisfaction of all parties, then each supervisor either separately or collectively can contact the AJC Manager by email. The email should contain the following information:

• A description of the issue • Steps taken to try to resolve the issue • The date the issue occurred and the date the email contact

to the AJC Manager is being made • The names and contact information of the supervisors

involved Step 5: Upon receipt of the written notice that a conflict exists, the AJC

Manager will discuss the issue and inform the parties of either a resolution or the steps required to resolve the issue within 10 days.

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Step 6: If the issue is still not resolved to the satisfaction of the parties, the supervisors may contact the chair of the WDB’s Quality Assurance (QA) Committee in writing with the information outlined in Step 4.

Step 7: The QA Committee will address the issue and contact the parties within 30 days of receipt of the written complaint. The QA Committees resolution is considered final. Bringing Forth Management Issues to the Job Center As stated above, the Center expects issues that create conflict or disagreement to be resolved at the lowest level, either between staff or One role of the Job Center Manager is to identify opportunities for improvement at the following operations levels.

• Facility Issues • Customer Service Issues • Staff Issues.

The AJC Manager will report to the Job Center Director on a regular basis. Any staff member may bring issues in any of the categories above to the attention of the AJC Manager. If it is something that could impact other staff, s/he may choose to include the topic in a staff meeting.

De-escalating Customers If a customer is demanding to see a staff person, kindly ask them to sit down while they wait for you to find someone to help them. Inform the other front/resource area staff that you are leaving for a moment and inform them of the demanding customer. Excuse yourself to locate the Center Manager. DO NOT take them to the staff person. There is a difference between a difficult customer who does not feel we have met their expectations or gotten what they needed, and an irate/hostile

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customer. If a customer becomes difficult, to the degree you feel uncomfortable, follow these steps:

1. Assume that the customer has a right to be angry

2. Listen to emotion without emotion

3. Be patient

4. Speak in a mild tone

5. Reiterate

6. Own the problem

7. Place the customer first, problem second

8. Triage

9. Correct the issue or find someone who can

10. Follow up For irate or hostile customers, the Center has a de-escalation team. Try to balance not wanting to deal with a difficult customer and really feeling threatened before calling the de-escalation team. Use common sense, do not try to handle anything you do not feel comfortable handling AND do not hand off customers to the team that you were perfectly capable of handling. Time and Attendance When conducting joint functions of the Center (e.g., conducting a workshop, staffing the resource room, and other ‘universal’ functions) staff is responsible for informing the Center Manager directly if they are going to be late or absent, either for scheduled or unscheduled absences. It is the responsibility of the staff person to find appropriate back-up for a scheduled absence.

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When conducting functions within the building that may not be considered ‘joint’ (e.g. an agency specific meeting, or appointments with customers enrolled in your specific program) staff are required to inform the AJC Manger directly of these activities and of any cancellations so that the front desk personnel can provide informed responses to any inquiries. Staff is expected to be informed of and to follow procedures for providing this information as the procedures are further developed by WSM and the AJC Manager. Telephone Answering Front Desk: The phone should be answered consistently using the following script: Good Morning/Afternoon. This is the WorkSource Montgomery American Job Center. How may I help you? Staff Voice Mail: All messages should be consistent with the following script: Hello, you have reached the desk of [NAME]. I cannot come to the phone right now so please leave a message and I will get back to you within the next business day. If you need to talk to someone immediately, please call [NAME AND CONTACT NUMBER]. Staff personal mobile numbers should be kept confidential. On Leave Out of Office Message: Hello, you have reached the desk of [NAME]. I am away until [insert date]. If you can wait until I return, please leave a message and I will get back to you then. If you need to talk to someone immediately, please call [NAME] at [number]. Name Badges Name badges will be provided to staff members and are required to be worn while working in the AJC and while attending events representing the AJC. Should you lose your name badge, report the loss to the AJC Manager as soon as possible to expedite its replacement.

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SECTION 5: CAREER SERVICES Career services include information and resources available at no cost to any/all employer and job seeker customers. The services provided at the AJC assist Job Seeker customers in finding a job through a variety of mediums. Career services are divided into two categories: 1) self-service and information and 2) career service that require registration. There are two factors to consider when determining which career services are classified as self-service and which require registration: 1) level of staff involvement with the customer, and 2) purpose of the services. Career services, designed to generally inform and educate customers about the local/regional labor market, would not require registration. Staff assisted services that are designed to impact job seeking and/or occupational skill will likely require registration. All customers must be offered an invitation to participate in the AJC Orientation and to register on the Maryland Workforce Exchange website. AJC Services 1. Determination of individual eligibility for services; 2. Outreach, intake (including worker profiling) and orientation to the information

and other services available; 3. Referral to Consortium Partner services, as well as other agencies in the County

as needed; 4. Initial assessment of skill levels, aptitudes, abilities, and supportive service

needs; 5. Labor exchange services; job search and placement assistance, including

access to Internet, and career counseling where appropriate; 6. Provision of employment statistics information and labor market information

such as job vacancy listings, job skills necessary to obtain jobs, local high demand occupations, earnings, and skill requirements;

7. Provision of performance information and program cost information on eligible providers of training services;

8. Provision of information regarding local area performance on the local performance measures;

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9. Provision of accurate information relating to the availability of supportive services available in the local area;

10. Provision of information regarding filing claims for unemployment compensation;

11. Assistance in establishing programs of financial aid assistance for training and education programs;

12. Other service as determined by a Partner agency’s governing legislation. Assessment Services CASAS Comprehensive Adult Student Assessment System (CASAS) – assists in determining the need of skills for success in the workforce, helps place clients into appropriate education and employment training programs and can monitor progress and certify attainment of employment related competencies. Career Exploration sites include: • www.MyNextMove.org O*NET Interest Profiler The O*NET Interest Profiler (IP) is a free, online self-assessment career exploration tool that can help clients discover the type of work activities and occupations that they would like and find exciting. Clients identify and learn about broad interest areas most relevant to them. They can use their interest results to explore the world of work. The O*NET Interest Profiler measures six types of occupational interests: Realistic, Social, Investigative, Enterprising, Artistic and Conventional. Customers can access the O*NET Interest Profiler at: https://www.mynextmove.org/explore/ip WIOA Title I Programs and Eligibility Guidelines for Career / Training Services By Act of Congress in 2014, the Workforce Innovation & Opportunity Act authorized Workforce Development Boards to invest in and strengthen the economy through its workforce. There are three categories of “eligibility” for

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Workforce Innovation & Opportunity Act fund allocation: Adult, Dislocated Worker, and Youth participants. The Adult and Dislocated Worker Programs funded through the Workforce Innovation & Opportunity Act are designed to provide quality employment and training programs to assist eligible Job Seekers in securing gainful employment and in assisting local businesses in acquiring the skilled workforce necessary to remain viable and competitive in today’s global economy. The objectives of the Adult and Dislocated Worker WIOA programs include:

1. To increase employment, as measured by entry of Job Seekers into unsubsidized employment,

2. To increase job retention in unsubsidized employment at least six months following the start of employment,

3. To increase the earnings received in unsubsidized employment as a result of the assistance/training provided by the WIOA program,

4. To ensure customer satisfaction with the public workforce system by both users: the Job Seeker and the Employer,

5. To increase enrollment in training programs that lead to recognized post-secondary credentials or employment and achieving measurable skill gains.

The Workforce Innovation & Opportunity Act legislation created an opportunity for local workforce development boards to deliver comprehensive services focusing on low-income young professionals, ages 16 to 24, with one or more barrier to employment. WIOA Youth funds assist participants in securing meaningful employment, preparing for post-secondary education, and attaining skills/training credentials. WIOA Youth program elements include: tutoring, summer employment opportunities linked to occupational learning experiences, higher educational opportunities, skills training, leadership development, supportive services, comprehensive assessment and counseling, paid work experiences, mentoring programs, internships and intensive follow-up services.

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The objectives of the Youth WIOA programs include: 1. Increasing the number of Youth in the workforce with meaningful

employment and earned wages, 2. Increase retention of participants in education, training activities or

unsubsidized employment, 3. Increasing the number of Youth who earn a high school degree equivalent

or skills certification to increase opportunities for long-term success, 4. Increasing individual participants’ literacy and numeracy skills and

capabilities as measured by standardized tests, 5. To ensure customer satisfaction with the public workforce system by both

users: the Job Seeker and the Employer.

All funds are dependent on the WDB continued receipt of funds. In the event of Federal, State or local funding rescissions or budget amendments, changes may occur to availability of services. Customers will be deemed eligible for as many programs as possible (Adult, Dislocated Worker & Youth) during the enrollment process to increase service and funding options.

Staff must be familiar with the eligibility requirements and use sound judgment; if it is apparent that an individual’s circumstances prevent enrollment in both Adult and Dislocated Worker, the individual should only be enrolled in the appropriate program. Prior Participant Eligibility All participants should be asked if they have previously received training services (ITA or OJT) under the WIA/WIOA Program. If they have, the MWE “View History” should be reviewed to verify when and with which local area the training was received. Participants who were previously enrolled in WIA/WIOA activities and are re-applying fall into one of the following scenarios:

• A participant who did not receive WIA/WIOA funded Skilled Training or On-the-Job Training within the last two (2) years, is able to enter the WIOA program and will be eligible for all services.

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• A participant, who received WIA/WIOA funded Skilled Training or On-the-Job Training within the last two (2) years, will be required to write a letter to the WIOA Director explaining the circumstances that led him/her back to the AJC, and what services s/he is requesting. If the participant is no longer able to perform the duties inherent in the previous occupation, s/he must provide documentation to verify this inability.

Upon review of the letter, one of the following outcomes will be determined by the WIOA Director:

• A participant, who received training in a High Demand Occupation and is able to perform the duties within that occupation, will be notified by the appropriate Career Specialist that s/he is eligible for services, excluding WIOA funded Skill Training or On-the-Job Training.

• A participant who was enrolled in WIA/WIOA-funded training and is no longer able to perform the duties inherent in such occupation will be notified by the Career Specialist that services are available and, if necessary, training may be considered.

The original documentation must be retained in the participant’s file. Adult Eligibility An individual (18 years or older) shall be eligible to participate in the Title I WIOA Adult services if such individual meets the following:

General Eligibility – consists of providing the appropriate documentation of:

• Social Security Number • Citizenship/Eligibility to Work • Age • Montgomery County Residency • Selective Service Registration (if applicable) • Meets the Income guidelines as established under Federal Poverty

Income Guidelines

Dislocated Worker Eligibility An individual (18 years or older) shall be eligible to participate in the Title I WIOA Dislocated Worker services if such individual meets the following:

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General Eligibility – consists of providing the appropriate documentation of:

• Social Security Number • Citizenship/Eligibility to Work • Age • Montgomery County • Selective Service Registration (if applicable)

AND Meets the definition and provides documentation for one of the following categories: • Terminated/Laid off; Eligible for unemployment compensation and

unlikely to return to previous industry or occupation • Permanent closure/substantial layoff • General announcement of closure • Formerly self-employed/currently unemployed • Displaced homemaker

Youth Eligibility In accordance with the Workforce Innovation & Opportunity Act, an eligible Youth participant must meet the following criteria (and provide documentation to verify):

General Eligibility – consists of providing the appropriate documentation of:

• Social Security Number • Citizenship/Eligibility to Work • Age (between 16 and 24 years of age) • Montgomery County Residency • Selective Service Registration (if applicable). A male who has reached

his eighteenth birthday, is registered for Selective Service. Please note: If a male is enrolled in the program prior to his 18th birthday, he must register for Selective Service within 30 days of his birthday. If he does not register within 30 days of his birthday, the contractor must exit him from the program.

AND Meets the definition and provides documentation for one of the six elements of the Low Income Individual Act: • Cash public assistance

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• Family income at or below the poverty level or 70% of the Lower Living Standard

• Has received or was eligible to receive food stamps in the last six months • Homeless and own income at or below the poverty level or 70% of the

Lower Living Standard • Publicly supported foster child and own income at or below the poverty

level or 70% of the Lower Living Standard • Individual with a disability and own income at or below poverty level or

70% of the Lower Living Standard AND

Is within one or more of the following categories: • Basic Skills Deficient (English reading or computing skills at or below the

8th grade level) • School dropout (for Out of School programs) • Homeless, runaway, or foster child • Pregnant or parenting • Offender • Is an individual (including Youth with a disability) who requires additional

assistance to complete an educational program or to secure and hold employment.

The Local definition on requiring “additional assistance to complete an educational program or to secure and hold employment” is an individual with a disability or an individual with a school authorized Individualized Education Plan (IEP) dated not more than 24 months prior to enrollment. Youth (age 18 or older) made eligible as an Adult or Dislocated Worker may qualify for services listed under ‘Adult/Dislocated Worker Eligibility’.

5% Exception (Must have prior approval from WDB before being considered for 5% Exception)

The WIOA Act includes an exception to the above requirements. Not more than 5% of Young Professional participants assisted in Montgomery County through WIOA funds may be individuals who do not meet the minimum income criteria if such individuals are within one or more of the following categories:

• School dropout

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• Basic Skills Deficient • Behind grade level • Pregnant or parenting • Individual with disabilities including learning disabilities • Homeless or runaway youth • Offender • Serious barrier to employment, including the need for additional

assistance WIOA Enrollment Once the customer has provided the proper documentation to verify general and program eligibility, the staff member will enroll the customer (see Appendices). Hard copy documentation is required for eligibility. Therefore, once the application has been completed, the participant is required to sign and date the application. A staff member is required to verify eligibility and document their review by signing and dating the original application. The original application, all documentation used to determine eligibility and the original forms signed by the participant become part of the participant’s permanent file. The contents of WIOA participant files must be assembled in a consistent file structure to allow a staff member and/or State monitor to locate a specific document quickly without having to search the entire file. WIOA participant files are to be assembled in the following order:

1. Printout of MWE WIOA history screen at the time of termination. 2. Printout of Common Measure screen for Positive Terminations (90 days

after termination) or at time of termination for Other and Non-Positive terminations.

3. rintout of MWE View Service Record screen at the time of enrollment to showing career services were provided.

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4. Original WIOA application from MWE signed and dated by the participant, the counselor and the supervisor. The supervisor’s signature indicates the participant’s eligibility has been verified.

5. Priority of Service form (for Adults only; see attached Priority of Service form)

6. Previous Employment Information form. 7. All documentation to support general and program eligibility. 8. All original Administrative documents, signed and dated by the

Participant (and Counselor if appropriate) including: a. Statement of Receipt of Complaint Procedure

Policy/Discrimination Complaint b. Participant Responsibility Form c. Authorization to Release Information d. Emergency Information Form e. Follow-Up Agreement f. ITA and/or OJT documents if/as appropriate g. Support Service Information / Requests if/as appropriate

9. Print out of each activity entered in MWE, including all supportive documentation (related to employment and/or training) in chronological order from start to finish.

10. Employment Development Plan. 11. Case Notes. 12. Incentive Program Tracking Sheet.

Priority Service Priority of service means that individuals in the targeted groups (veteran, public assistance recipients, other low-income individuals, individuals who are basic skills deficient, and underemployed who are also low-income) are given priority over other individuals for receipt of individualized career services and training services funded by the WIOA Title I Adult program. Veterans within these groups receive priority over non-veterans. Adult priority is determined for the targeted groups during eligibility and enrollment. Priority of service cannot be waived. (20 CFR 1010.250) Priority of service does not guarantee that by virtue of his/her status an individual will always receive service. The individual must be eligible and able to benefit from the services and application of priority of service is also subject to additional criteria as the WorkSource Montgomery, Inc Board has

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determined to be appropriate as listed below under Residency Requirement. (20 CFR 680.600(b))

Interaction of the Veteran’s and Adult Priority of Service

The priority of service for veterans and eligible spouses applies across all qualified employment and training programs. The priority of service for public assistance recipients, other low-income individuals, and individuals who are basic skills deficient is a statutory priority that applies only to the receipt of individualized career services and training services in the WIOA Title I Adult program. With regard to the priority of service for veterans and eligible spouses, and in accordance with the Jobs for Veterans Act of 2008 (JVA); priority of service for the WIOA Title I Adult program must be applied in the following order:

1. Veterans and eligible spouses who meet the statutory priority (public assistance recipient, other low-income individuals including the underemployed, or basic skills deficient) and Adult program eligibility will receive the highest level of priority for services;

2. Other individuals (not veterans or eligible spouses) who meet the statutory

priority (public assistance recipient, other low-income individuals including underemployed, or basic skills deficient) and Adult program eligibility then receive the second level of priority for services;

3. All other veterans and eligible spouses who meet Adult program eligibility,

then receive the third level of priority for services;

4. Other individuals (not veterans or eligible spouses) who do not meet the statutory priority (public assistance recipient, other low-income individuals including underemployed, or basic skills deficient) then receive the fourth level of priority for services.

5. Other individuals (not veterans or eligible spouses) who do not meet the statutory priority (public assistance recipient, other low-income individuals including underemployed, or basic skills deficient), but do meet Adult program eligibility, then receive the fifth level of priority for services.

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Target Populations Identified to Receive Priority of Service There are five (5) groups of individuals targeted for priority when providing individualized career services and training services in the WIOA Title I Adult program: public assistance recipients; other low-income individuals; individuals who are basic skills deficient; and individuals who are both underemployed and low-income.

1. Veterans and eligible spouses, including widows and widowers as defined in the statute and regulations, are eligible for priority of service. For the purposes of implementing priority of service, program operators use the broad definition of veteran found in 38 U.S.C. 101(2).

Veterans and eligible spouses will always have priority of service on a “first come, first served” basis in the following ways: • Veterans and eligible spouses will have first access to information and

registration of workshops provided at WorkSource Montgomery, Inc. • Veterans and eligible spouses will be referred by the Veterans

representatives to the Intensive Services Unit (ISU) and be assigned an ISU counselor promptly.

• Veterans and eligible spouses will have priority of service on a “first come, first served” basis for all ITAs in Montgomery County until ITA funding is expended in any program year.

• Veterans and eligible spouses cannot be required to exhaust their benefits prior to gaining access to WIA training.

2. Recipients of public assistance includes individuals who receive, or in the past six (6) months have received, or are a member of a family that is receiving or in the past six (6) months has received, assistance through one (1) or more of the following:

• Supplemental Nutrition Assistance Program (SNAP); • Temporary Assistance for Needy Families (TANF); • Supplemental Security Income (SSI); or

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• State or local income-based public assistance.

Low-income includes: • Individuals in a family with total income below the poverty line or 70%

of the lower living standard income level; • Homeless; • Foster youth; and • Individuals with disabilities with individual income below the poverty line

or 70% of the lower living standard income level. • Youth in-school up to age 21; or parents of such a youth who are

eligible to receive a free or reduced-price lunch.

A youth 18 or older, who was determined low-income for the WIOA Title I Youth Program, may be co-enrolled in the WIOA Title I Adult Program without an eligibility re- determination, and be counted as an individual who meets Adult priority of service, if the original determination was made no more than six (6) months prior to the date of co- enrollment.

3. Basic skills deficient is defined as an adult who is unable to compute or

solve problems, or read, write, or speak English, at a level necessary to function on the job, in the participant’s family, or in society.

In assessing basic skills, WSM will only use assessment instruments that are valid and appropriate for this target population, and will provide reasonable accommodation in the assessment process, if necessary, for individuals with disabilities. Standardized assessments will be administered following published guidelines and locators/appraisals will be used to determine the appropriate level of use of such assessments.

An adult may be assessed as basic skills deficient through case manager observations and documented in case notes. A case manager may document basic skills deficient using any one (1) of the following: • Basic skills assessment questions or test results • School records • Referral or records from a Title II Adult Basic Education program • Referral or records from an English Language Learner program

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4. Underemployed individuals are employed full-time or part-time and must also meet the definition of a low-income individual in order to be eligible for the Adult priority of service.

WIOA Intensive Support Services

If determined to be appropriate in order for an individual to obtain or retain employment:

1. Comprehensive and specialized assessments of the skill levels and service needs of adults, dislocated workers and youth, which may include—diagnostic testing and use of other assessment tools; and in-depth interviewing and evaluation to identify employment barriers and appropriate employment goals;

2. Development of an individual employment plan, to identify the employment goals, appropriate achievement objectives, and appropriate combination of services for the participant to achieve the employment goals, including providing information on eligible providers of training services and career pathways to attain career objectives;

3. Group and/or individualized career counseling and planning; 4. Short-term prevocational services, including development of learning skills,

communication skills, interviewing skills, punctuality, personal maintenance skills, and professional conduct, to prepare individuals for unsubsidized employment or training;

5. Internships and work experiences that are linked to careers; 6. Workforce preparation activities, programs, or services designed to help an

individual acquire a combination of basic academic skills, critical thinking skills, digital literacy skills, and self-management skills, including competencies in utilizing resources, using information, working with others, understanding systems, and obtaining skills necessary for successful transition into and completion of postsecondary education or training, or employment;

7. Financial literacy services; 8. English language acquisition and integrated education and training

programs; 9. Follow-up services, including counseling regarding the workplace, for

participants in workforce activities authorized under this subtitle who are placed in unsubsidized employment, for not less than 12 months after the first day of the employment.

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Case Management and Case Notes The Workforce Innovation and Opportunity Act (WIOA) adheres to a case management approach to service delivery. Integral to this approach is the maintenance of comprehensive services for each program participant. Case notes are one of the tools that document the participants' journey throughout the duration of the program. Case Notes help service providers organize and analyze the information gathered on participants and to plan case management strategies. Effective case management, involves skilled case workers and supportive policies, practices and systems, characterized by the following: • Services tailored to individual participants’ needs, abilities, skills, and interests, as well as to opportunities and supports available in the community where

customers are located (or to which they might relocate); • Supportive relationships with participants, via a person-centered approach, in

which case managers assist participants in making key decisions and in meeting requirements and milestones, by using such techniques as active listening and celebrating customer successes;

• High-quality, specialized knowledge and guidance relating to occupations, job openings, training and educational programs;

• Easy coordination of services with partner agencies, through knowledge of local agencies and the ability to communicate and share information about participants;

• Seamless transitions for participants between programs and services, when needed, without lengthy, involved, or duplicative processes and information requests; and

• Improved management and information systems (including electronic data systems and related forms, checklists, and procedures) that efficiently facilitate documentation, tracking, and reporting.

Staff must only record services that have truly been provided to assist participants in obtaining employment or attaining other outcomes as outlined in their IEP.

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Exemplary case notes lead to effective case management. Good case management requires that direct communication be made with the customer on a regular basis. Case notes should document a chronological history of contact with the customer, tracking what has occurred in the case. Using content from case notes will facilitate better communications and a more effective outcome when working alongside other service providers to serve a particular client. It is important to record concisely and accurately the information conveyed by the customer, requests made by the customer, information given by the case manager, and the plans mutually agreed upon. This helps to prevent any misunderstandings and eases the resolution of any misunderstandings that may occur. • To document activity between case manager and client for addressing and

taking progressive steps toward fulfilling that individual's vocational needs and goals within the constraints of the Job Center.

• To serve as a record of accountability on the part of the case manager and organization.

• To provide continuity of service in the instance of a change in case manager. • To record the details of services and advice provided to the client. • To document the client's participation in activities (training, networking, other

resources sought out) and progress. • To capture nuances regarding factors effecting eligibility and other information

of note. • To provide justification for services recommended and potentially provided. • To provide focal point for monitoring the progression and effectiveness of

service delivery. • To protect the case manager and organization from potential legal issues. Minimum Case Note Requirements • Date • Method of contact (phone, email, face-to-face) • Your name and anyone else relevant • Location (agency site or other) • Reason for meeting including a description of discussion points • Substance of interaction: description of desired / intended outcome / any

obstacles or resolutions / action plans / goals or next steps / completion dates / impact toward meeting IEP objectives.

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Case Notes Should Not Include 1. Personal comments/assessments 2. Transcriptions of entire e-mail or other correspondence that can be summarized

or referenced 3. Other participants’ identifying information unless specifically relevant to the

individual Participants enrolled in the WIOA Program must have AJC services entered into the Maryland Workforce Exchange Database (MWE). It is critical that each service activity is entered, at the time of delivery, into MWE. Services must be entered in MWE in order to count towards Common Measures. They should clearly demonstrate the amount of contact a professional has with his or her clients and show the level of service being provided to a customer. The frequency of these contacts should be at least once every 30 days. The IEP should be updated when monthly contacts reveal that customers are involved in new and/or expanded program activities. Quality Case Notes • Timeliness - Capture any action items, observations, thoughts, and duration as

soon as possible following a meeting or call with client to ensure accuracy. For example, new test scores, job interview, period of absence, workshop attendance, etc.). Entries should be sequential.

• Concise and Clear - Write for the benefit of others as if you will not be available for consultation: factual, concise, thorough, relevant, logical, useful, well organized, and well written using clear language (no slang or jargon, opinions or judgments, generalizations) and good grammar/spelling. Do not leave anything to interpretation.

• Consistency - There should not be gaps in either time or information. Case notes should reflect the participant's work and progress throughout their participation in the program. The case notes and the rest of the file should match and reflect the same information as the test scores, start date, revisions, supportive services, etc.

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• Legality and Analysis-Based - Case notes can be used as evidence in court. Adhere to anti-discrimination, conflict of interest, confidentiality re information possibly conveyed that does not directly apply to the individual's IEP, reasonable and customary actions, and the like. Write with the knowledge that it is likely to be audited or reviewed by a supervisor. Notes should reflect allowable activity and explain how it relates to individual's needs based on facts and impression and connecting them to the client's strengths and challenges.

Training Services One of the eligibility criteria for adults and dislocated workers to receive training services, is that after an interview, evaluation or assessment, and case management, the participant has been determined to be in need of training services and to have the skills and qualifications to successfully participate in the selected program or training services. The career specialist provides quality guidance and continuing case management. Career planners should encourage individuals to fully-utilize the information available on the Eligible Training Provider List, provide additional information beyond the assessment test and other reports, assist individuals with doing their own research on programs or providers, and help individuals identify specific options and systematically compare them. Career planners should monitor the individual’s progress through the various levels of program services.

1. Occupational skills training, including training for nontraditional employment;

2. On-the-job training; 3. Incumbent worker training; 4. Programs that combine workplace training with related instruction, which

may include cooperative education programs; 5. Training programs operated by the private sector; 6. Skill upgrading and retraining; 7. Entrepreneurial training; 8. Transitional jobs; 9. Job readiness training;

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10. Adult education and literacy activities, including activities of English language acquisition and integrated education and training programs;

11. Customized training conducted with a commitment by an employer or group of employers;

12. Other service as determined by a Partner agency’s governing legislation. Exemption Terminations An “Exemption Termination” is a termination in MWE which should be utilized in WIOA when a participant can no longer continue in the program due to one of the following circumstances:

• The participant is institutionalized – this can include a prison or hospital stay that is expected to continue for more than 90 days.

• The health /medical condition of the participant or family care – this must preclude entry into unsubsidized employment or continued participation in the program. This does not include temporary conditions or situations expected to last for less than 90 days.

• The death of the participant. • The participant is a member of the Reserve Forces and has been called to

active duty – this must be for more than 90 days. • The participant has been relocated to a mandated Residential Program –

this is for youth participants only and does not include relocation to a Job Corps center.

When a participant can no longer participate due to one of the above reasons, the exemption termination should be entered in MWE along with case note and documentation. Individual Employment Plan (IEP) IEPs are to be developed for each participant at the time of enrollment to identify the employment goals, appropriate achievement objectives, and appropriate combination of services for the participant to achieve the employment goals. A copy of the plan is to be given to the participant at the

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time of development and each time the plan is updated the participant must initial and date the IEP to acknowledge the IEP was updated. Plans are to be reviewed by the Counselor after each service element is completed Goals are to be written using the SMART model:

• Specific – If a goal is stated specifically, it will clarify who is to do what, when, how, where, and why. Example: A general goal would be: Have a positive attitude: Specific goals might be: smile more often, ask a co-worker if they need help, praise someone’s work, etc.

• Measurable – A goal should be written in such a way as to help you measure whether you have reached your goals or not. Criteria should be explicit. If you want to know if your goal is measurable, ask questions such as, how much? How many?

• Attainable – Goals should be reachable. If you break down the goal into smaller sub-goals that you can see step-by-step procedures, you have a better chance of determining if your larger goal is achievable.

• Realistic, Relevant – Realistic goals are goals you are willing and capable of achieving. Be sure to aim higher rather than lower. You must also believe that you can accomplish the goal. Refer to past experiences to help determine if your goal is realistic. Have you accomplished a similar goal in the past? The goals should be relevant as well. What will have the greatest impact for the individual that is meaningful to him or her? Relevant means focused, valued.

• Timely – A goal should be time-bound. There should be a target date for progress and completion. A goal without a commitment to a schedule of target dates tends to be forgotten or neglected in day-to-day obligations and distraction.

Identifying Potential Barriers (Staff should ask questions such as):

Language • What is your native language? • What other languages do you speak?

Transportation

• What type of transportation will you most likely use to get to work and/or training? Bus, train, drive, car pool, walk, bike?

• Do you have a valid driver’s license?

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o If no, is there a reason why not? • If license was suspended, when will suspension period end?

Child/Elder Care

• Do you have children that require child care? o If so, do they require special accommodations?

• Do you have an alternate child care plan? o If no, assist in the development of an alternate child care plan.

Special Needs

• Did you attend Special Education classes while in school? • Do you feel that you may have a special learning challenge? • Are you a primary caregiver for someone living in your home that has

special needs? • Do you have any conditions that ever prevented you from taking a job,

remaining on a job or attending an education or training program? • Do you regularly take medication that may interfere with your work or

training? • Are you pregnant? If so, are you receiving prenatal care?

Housing

• What is your current housing situation? • Are you receiving housing assistance? • Do you expect to remain in your current residence? • Are you facing any type of housing/financial crisis at this time?

Criminal History

• Have you ever been convicted with a criminal charge? o If yes, is this a barrier to employment

Employment Portfolio Documents

• Do you need assistance in obtaining any of the following documents that may be necessary to reach your employment goals? o Birth Certificate o Social Security Card o MD Learner’s Permit o MD Driver’s License

o State Non-Driver’s License ID Card o Credit Report o Criminal Background Check

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o Child Abuse Clearance o FBI Fingerprint Background Check

Follow-up Services Adult and Dislocated Workers: Participants served with WIOA funds are required to receive twelve (12) months of follow-up services following the first day of employment. When it is discovered that a participant has obtained employment, the participant must be exited from the program and documented in MWE. The exit date should always equal the last day a service was provided regardless of the employment date. Follow-up services may include, but are not limited to, telephone, e-mail, postal mail, social media and/or face-to-face contact. Services may be offered during the follow-up period. Follow-up services are to be documented in both MWE and the participant’s Case Notes. If the participant was a non-positive exit, follow-up services are not required. Youth All youth participants must receive some form of follow-up services for a minimum of twelve (12) months following the date of termination. The types of services provided and the duration of the services must be determined based on the needs of the individual. The scope of these follow-up services may be less intensive for youth who have only participated in summer youth employment opportunities. Follow-up for Youth may include:

• Leadership development and supportive service activities; • Regular contact with a youth participant’s employer, including assistance

in addressing work- related problems that arise; • Assistance in securing better paying jobs, career development and further

education; • Work-related peer support groups;

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• Adult mentoring; and • Tracking the progress of youth in employment after training.

To ensure compliance, the appropriate Counselor is required to enter the dates in MWE and the participant’s Case Notes that follow-up was completed for each participant that exited the program at the intervals indicated below:

• 1st month after termination • 3rd month after termination • 5th month after termination • 8th month after termination • 12th month after termination

Follow-up services may include, but are not limited to, telephone, e-mail, postal mail, social media and/or face-to-face contact. Services may be offered during the follow-up period. Follow-up services are to be documented in both MWE and the participant’s Case Notes. Individual Training Account (ITA) ITAs are the mechanism for providing Title I and EARN (when dual-enrolled in Title I) customers with the means to finance and obtain training to become employed full-time without additional subsidies. The Workforce Development System established under WIOA legislation emphasizes informed customer choice, system performance and continuous improvement. After receiving services and in consultation with case managers, eligible participants who may benefit from training use the list of MD Eligible Training Service Providers to make an informed choice. Training services may be made available to employed and unemployed adults, dislocated workers, and youth who:

• Have met the eligibility requirements of receiving career services and have been determined to be unable to obtain or retain employment through such services;

• After an interview and case management has determined the need of training services;

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• Have researched and selected a program of training that is directly linked to employment opportunities either in the local area or in another area to which the participant is willing to relocate;

• Are unable to obtain grant assistance from other sources to pay the total cost of such training, including State funded training, Trade, Pell Grants or require WIOA assistance in addition to other sources of grant assistance.

ITAs will only be approved for positions on the High Demand Industry List, defined as jobs (1) in demand by employers, (2) have higher skill needs and will therefore likely provide family sustaining wages, and (3) are targeted to locally have 75 or more openings each year for the next five years. Funding is based on appropriateness and funds availability. The funding for ITAs contract is $3,500. AJC customers should never be guaranteed funds or training. No payments are made directly to an individual. WorkSource Montgomery Staff should notify participants that any financial aid received may reduce the funding provided by WorkSource Montgomery, Inc. Each participant is required to conduct research and prepare a training plan prior to submitting a written request for training funds. The following must be documented in the request:

• The occupations for which the training will prepare the participant; • The local employment projections for the specific occupation(s); • The entry level salaries of these positions; • A comparison of two (2) training providers from the State Approved Eligible

Training Provider List that offer the specific training requested (if available); • Evidence that the position is on the High Priority Occupation list; • A statement regarding how the remaining tuition balance will be satisfied if

the course amount exceeds the allowable WorkSource Montgomery, Inc. funding.

Customers seeking an ITA must first successfully complete assessments. The scores on the assessments must be equal to or higher for the particular profession the customer is interested in pursuing. Results must show aptitude in the field of training. If the scores do not meet such threshold, remediation would be required.

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The appropriate Career Specialist will confirm with WorkSource Montgomery’s Director that the training providers being considered have an existing contract. If a contract has not been established, the Title l provider will prepare a contract within 48 hours and will forward it to the Training Provider. WorkSource Montgomery Center staff should not refer clients to any school or course until the contract has been signed.

Once the participant has completed the necessary research and appropriate assessments, the Career Specialist will meet with him/her to review the findings of the research and determine if the proposed training is an effective career and training option/opportunity. The ITA Check List must also be reviewed with the participant and attached to the request. The case file must contain a determination of need for training services as identified in the participant’s Individual Employment Plan (IEP). Once the Eligible Trainee has submitted their training plan the following must occur:

• The Career Specialist will sign and date the ITA Check List verifying all data is complete and correct.

• The Career Specialist will complete a Training Referral and give it to the Eligible Trainee who will take the Training Referral to the Training Provider to complete the Provider’s section. The Eligible Trainee will return the completed form to the Career Specialist.

• The Career Specialist will submit the following to the Director for review: o ITA Check List o Training Referral o Print out of courses from MD Eligible Training Providers list o Case Notes evidence of participant’s research in Training Providers and

courses o The Title I Director will review all of the material and approves the request o Should the Director deny the request, the entire packet will be returned to

the Career Specialist with the reason(s) for denial o The Career Specialist will then meet with the participant and review the

reason for denial.

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Note of Importance - Inform Participants of this Process • The Title l provider will complete the Individual Training Account (ITA)

agreement letter and mail the original to the Training Provider; a copy will be forwarded to the Career Specialist.

• The Career Specialist must verify the client is attending training and will be in communication with the training provider.

• The Career Specialist is to remain in continuous communication with customers enrolled in ITAs, as the goal is to place ITA completers into occupations for which training funds were invested.

On-the-Job Training An On-the-Job Training contract allows an Employer to hire a WSM who would not be qualified for that particular job without additional and specific skill training. The Employer receives the referral from the pool of eligible customers and then trains for the skills needed to perform the job at entry level. The WSM AJC WIOA Service Provider provides the Employer with a partial wage reimbursement, to compensate for the employer’s costs, for an agreed-upon training time period in exchange for the provision of training by the Employer and a commitment to retain the individual when the training is successfully completed. OJT funding may be allocated for an eligible Montgomery County job seeker customer residing in Montgomery County or to an Employer whose primary business and OJT training location is located within Montgomery County. Funding is based upon appropriateness and funds availability. AJC customers should never be guaranteed funds or training. WSM defines full-time employee as that equal to and no less than 37 hours per week. During the course of the OJT, the Trainee must be treated as a full-time employee and should receive wages and benefits at the same level as similar employees.

OJT is not a subsidized employment program.

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Need for Training The assessment process is used to substantiate that each Trainee has a need for the training that is to be provided and has the capability to benefit from this training. The decision to assign a participant to OJT should be based on consideration of the individual's employability skills, skill deficiencies, and interests. WSM AJC Career Specialist will utilize assessment tools to determine appropriateness of the training. If job seeker has a bachelor’s degree, this will not be required. The initiation of an OJT for an unemployed participant is only considered at which time the Trainee:

• Has identified interests and aptitudes that match the prospective training; • Has expressed an occupational preference based upon sound and

current labor market information; • Understands and/or exhibits the attitudes and behaviors that Employers

require; • Has basic work readiness and occupational skills to learn the job for

which the Trainee is being hired; • Has an updated resume, cover letter and/or portfolio and references • Has basic skills • Has reliable transportation • May have an established work history • Possesses sufficient skills to meet the minimum industry standards for the

OJT Employer. Appropriateness of OJT The emphasis on training automatically eliminates all jobs that require no more than a brief initial orientation period. Similarly, because reimbursements are intended to compensate the employer for decreased productivity, jobs that pay by commission or piecework are generally considered inappropriate. Additionally, seasonal, temporary and part-time jobs should likewise be avoided because the desired outcome of OJT is long-term retention into full-time employment that leads to self-sufficiency.

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OJT can also be inappropriate for a variety of other reasons. As with consideration of any participant for a training service, the potential Trainee should generally possess at least the threshold level of basic work readiness skill proficiency to ensure the possibility of success. Placement into OJT before a Trainee is ready can negate earlier achievements and undermine motivation and self-confidence. Additionally, the placement of Trainees who fail to meet basic employer expectations will diminish the credibility of the WSM AJC within the business community. Eligibility Trainees who are eligible for OJT must meet program eligibility requirements for each funding source, i.e. WIOA Adult, Dislocated Worker, Youth, state set-aside, National Emergency Grants (NEG), or Trade Act eligible. WSM’s AJC Career Specialists will counsel participants about the importance of training in a field in which they have potential for achieving full and adequate employment and self-sufficiency. Career Specialists will coach participants who choose OJT that it should not be considered a “stop gap” employment solution. OJT must be developed from the objectives for occupational skills outlined in the IEP and, whenever possible, aim at starting a career with pathways that will lead to potentially higher skills and higher wages.

OJTs should be approved for positions included in WSM’s High Demand Occupations (see Appendices). If a potential occupation is not on the local demand list, WSM’s AJC Business Service Representatives (BSRs) may ask the prospective employer for industry information that may assist in determining the future-prospects of the occupation and career ladders. The WSM Career Specialists may approve training if the worker may be well served through OJT, despite lack of an official listing as a demand occupation based upon wage and career pathways, upon approval of WSM WDB.

Training services may be made available to employed and unemployed adults, dislocated workers, and youth who:

• Have met the eligibility requirements of receiving career training services and have been determined to be unable to obtain or retain employment through services;

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The WSM's criteria for determining whether employment leads to self-sufficiency (note: there are separate definitions of self-sufficiency for older youth (18-24), adults and dislocated workers): Adult Self-Sufficiency — 2017 Poverty Income Guidelines or the 2017 70% lower living standard income level -which is ever is higher (based on family size) and availability of family health insurance benefits and not receiving public assistance, to include housing, transportation, childcare, or food stamps. Dislocated Worker Self-Sufficiency — 80% of previous compensation level and availability of family health insurance or Adult Self-Sufficiency definition, whichever is higher.

• After an interview and assessment, a case management team must determine the following for appropriateness of an OJT:

o Does the participant need to learn skills for the desired position, or

have those skills already been acquired? o Does the participant have a need for training? o What is the best way for the individual to obtain the skills needed?

(i.e., OJT or occupational skills training)? o Can the position be obtained at this company without the OJT

Training? If a need for OJT cannot be documented, a direct placement or referral to other services should be considered. If a need for OJT has been determined and recorded on the IEP, a referral may be made to appropriate employers.

o Is this participant likely to succeed in training?

Additionally, OJT candidates must:

• Have identified interests and aptitudes that match the prospective training

• Have expressed an occupational preference based upon sound and current labor market information

• Have sufficient basic work readiness and occupational skills to learn the job for which the Trainee is being hired

• Has an updated resume, cover letter and/or portfolio and references • Has basic skills

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• Has resolved or has plans to resolve such employment barriers as transportation, child care, housing, health, or other barriers that can prevent successful OJT participation

• May have an established work history • Possesses sufficient skills to meet the minimum industry standards • May have obtained relevant training and certifications.

Trainee Assessment Timely assessment of the applicant's interests, attitude, skills, and abilities will work to the benefit of the business. Similarly, the applicant's best interest is also served by avoiding the failure that will inevitably result from a hasty and inappropriate placement. Documenting Need- Individual Employment Plan (IEP) The decision to place a participant into an OJT must be based upon a documented assessment of the participant’s skills, knowledge, attitudes, and behaviors. An individual may be placed into an OJT only when assessment, testing, and/or individual counseling indicate a need for and ability to benefit from the training specified in the OJT agreement. The IEP documentation of a participant’s appropriateness for OJT is required prior to referral to an Employer for OJT placement. Identification of an OJT as an appropriate service must be clearly documented on the participant’s Individual Employment Plan. The IEP must also identify potential supportive services the participant may need to successfully participate in the OJT. This is no different than the processes used to determine any participant’s ability to benefit from training services – an OJT is simply another training vehicle. The information on the IEP should have back-up documentation. Career Specialists must regularly review each participant’s progress in meeting program and service strategy objectives every 30 days, including the participant’s acquisition of basic/occupational skills and the adequacy of supportive services provided as related to OJT. Currently Employed Workers: Upgrades

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A currently employed worker may be placed into an OJT with the same Employer only when the following criteria are met:

• The employed worker meets WIOA eligibility, and • The employee is not earning a self-sufficient wage, and • The OJT relates to the introduction of new technologies, introduction to

new production or service procedures; or • The OJT supports the acquisition of new skills necessary for upgrading to a

new job that require the additional skills, or • The OJT provides training in the required workplace literacy, or • The Employer continues meets OJT Employer requirements.

Providing OJT’s to employed workers is different than “Incumbent Worker” training through WIOA. An incumbent worker is an individual who is employed, but an incumbent worker does not necessarily have to meet the eligibility requirements for intensive and training services for unemployed adults and dislocated workers. An OJT candidate must meet these eligibility requirements. In the circumstance where the Employer proposes to upgrade the employee by training for a job that requires substantially different or higher-level skills, the current employee must also, as a result of successfully completing the OJT:

• Expect a wage gain by the end of the training period commensurate with incumbent positions; or

• Expect an upgrade to a new position.

The Employer will be encouraged to “backfill” with a new hire for the employee’s previous position through the WSM AJC Provider or when training is complete. Employer Referrals / Recruitment

An Employer may sometimes refer an applicant for a vacant position in order to determine whether the applicant is eligible for WIOA and appropriate for training through an OJT Training Plan. This practice is allowed under WIOA. WSM BSRs should assess the circumstances to determine whether an OJT is appropriate in the same way they would assess an individual participant.

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All OJT Job Orders must be entered into the MWE database and the participating employer must also be registered. Upon completing this assessment, an applicant who is referred to WSM by an employer can be registered into an OJT only after eligibility for WIOA has been verified and after the assessment process has documented a need for and ability to benefit from the training offered by the employer. Documentation of discussions with the referring Employer can best provide this information. Unfilled demand for skilled workers by an Employer or among a group of Employers may result in a targeted effort by WSM BSRs to recruit appropriate OJT Trainees. Candidates may be identified through a multitude of systems to include Employer relationships, from a pool of applicants who have not yet enrolled into the program, or among participants who are receiving services beyond self-service. Qualifying the Business Employers who qualify for OJT must not have a pattern of failing to provide OJT participants with continued long-term employment with 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. Employers within Montgomery County will have priority, but this does not exclude employers outside the Montgomery County limits. The Contracting process begins with a systematic exchange of information between the prospective Employer and the WSM BSR. The BSR must make an on-site visit to the interested Employer to:

• Explain the program; • Learn about the business; • Identify and describe the job(s) to be filled; • Observe the work setting and environment; and • Review the administrative systems and the business' capacity to insure

fiscal integrity.

If the initial discussion indicates that the business may be appropriate for an OJT, it is necessary to gather and record detailed information that insures that

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the business can comply with the required administrative standards, in effect to "qualify" the business for OJT services. The Process The Business Services Representative will work with the employer to develop the training plan, the work schedule (hours and days/nights) and pay rate. The pay rate for an OJT client should be comparable to what an employee hired directly by the company, with about the same experience level, would receive. It is incumbent on the Business Services Representative to have an understanding on what the area industry average wage would pay someone with the level of experience of the client. The information that is gathered is summarized, recorded and maintained in the Employer’s OJT file. The purpose of this process is to determine whether:

• The business is legitimate and furnishes its Federal Employer Identification Number (FEIN);

• The OJT Employer is registered with the Internal Revenue Service and has an account for Unemployment Insurance and carries Workman's Compensation Insurance;

• The business is financially solvent;

• The OJT Employer has adequate payroll record keeping systems that track hours worked, gross pay, deductions, and net pay. (The OJT Employer is precluded from paying OJT participants in cash);

• The OJT site has necessary equipment, materials, and supervision to

provide adequate training;

• Successful training will provide a long-term job; the OJT Employer forecasts sufficient work to provide long-term regular employment for the OJT participant;

• The business's turnover rate is reasonable;

• The OJT site has safe and healthy working conditions, without previously reported health and safety violations that have been reported but have

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not been corrected. (Note that WSM BSRs should be attentive to this issue during the initial visit - and subsequent visits - to the training site and should inquire about safety records and inspections. The BSR is not an OSHA inspector, however, and is only expected to question reasonably apparent potential hazards.)

• To the extent that the State Workers’ Compensation law applies, Workers’ Compensation must be provided to OJT employees on the same basis as the compensation provide to other individuals in similar employment;

• The rate of pay, fringe benefits, periodic pay increases, and working conditions offered to the Trainee are the same as similarly situated employees in similar positions by the same Employer and who have similar training, experience and skills. Such rates must be in accordance with applicable law, but may not be less than the higher of the rate specified in section 6(a)(1) of the Fair Labor Standards Act of 1938 or the applicable State or local minimum wage law;

• OJT employees are provided benefits and working conditions at the same level and to the same extent as other Trainees or employees working a similar length of time and doing the same type of work.

• The OJT Employer does not illegally discriminate in training or hiring practices because of race, color, sex, national origin, religion, physical or mental handicap, political beliefs or affiliations, or age;

• An OJT Agreement must not impair existing contracts for services or collective bargaining agreements. When an OJT Agreement would be inconsistent with a collective bargaining agreement, the appropriate labor organization and Employer must provide written concurrence before the OJT can begin;

• The OJT Agreement would not assist, promote or deter union organizing;

• The business is not involved in a labor dispute, has employees in layoff status, or is in violation of Davis-Bacon Act labor practices that govern prevailing wage rates for government construction contracts;

• The OJT Agreement would not displace any currently employed worker (including partial displacement such as reduction in non-overtime hours,

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wages, or benefits) or infringe upon the promotional opportunities of any current employee. Regular employees and program participants alleging displacement may file a complaint through WSM’s Customer Complaint and Grievance policy;

• No individual is on layoff from the same or any substantially equivalent job; the Employer has not terminated the employment of any regular employee or otherwise reduced the workforce of the Employer with the intention of filling the vacancy so created with an OJT participant; or the job is not created in a promotional line that will infringe in any way upon the promotional opportunities of currently employed individuals (as of the date of the participation);

• The OJT does not encourage or induce the relocation of a business or part of a business if such relocation would result in a loss of employment for any employee of such business at the original location and such original location is within the United States unless 120 days have lapsed since the date on which such business commences operations at the new location;

The OJT Service Provider must determine if a relocation results in any employee losing his or her job at the original location, since WIOA funds may not encourage or induce a business, or part of a business, to relocate from any location in the United States. If an employee has lost his or her job at the original location, no OJT or Customized Training funds can be used at the new location until the business has operated at the new location for 120 days.

To verify that an establishment which is new or expanding is not, in fact, relocating employment from another area, standardized pre-award review criteria must be completed and documented as a prerequisite to WIOA assistance.

1. The review must include the names under which the establishment does business, including predecessors and successors in interest; the name, title, and address of the company official certifying the information, and whether WIOA assistance is sought regarding past or impending job losses at other facilities, including a review of whether WARN notices relating to the Employer have been filed.

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2. The review may include consultations with labor organizations and others in the affected local area(s);

• The OJT training does not involve the construction, operation, or maintenance of any part of any facility that is used or to be used for sectarian instruction or as a place for religious worship;

• The OJT Employer is not a Casino or other gambling establishment, zoo, swimming pool, aquarium or golf course (see high demand occupation clarification referenced in the Local Plan).

• The OJT placement may only occur in a private, for-profit or non-profit sector, i.e. no public sector placements.

• The prospective OJT Employer meets the existing “pattern of failure” requirements; and

• No fee has been charged to the participant to be referred or placed into the OJT training position.

In the event that any of the above circumstances exist, further discussion with the Employer and appropriate documentation of issue resolution is needed to determine if the business can be qualified as an OJT Employer. Documentation must be placed in the Employer’s file. The BSR will submit the OJT Request Form and all necessary attachments to the WIOA Director. The Director will submit all paperwork to the WDB within one business day of receipt of the referral and three business days prior to the start date of the OJT. The WDB will prepare the contract and forward the contract to the Employer OJT Supervisor within three business days for employer signature. The assigned Business Services Representative will have the contract signed by the employer and returned to the WDB prior to the start of the contract. The BSR or Career Specialist will provide the participant with correspondence documenting his/her start date, when, where and to whom they should report on their first day, a copy of their training plan and a copy of the job description. Confirmation of receipt of correspondence will be noted in the case file. The Career Specialist will enter the activity into MWE and remain in contact with the participant during their training period. When the OJT training period has

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been completed, the Business Service Representative is responsible for contacting the employer to determine if the participant was retained. Conflict of Interest No grantee, Contractor, sub-grantee, or sub-contractor will engage in any conflict of interest, real, implied or apparent, in the selection, award or administration of a WIOA funded Contract or grant. OJT Contracting must be conducted by training professionals and Employers in a manner that is objective and independent of personal interests. A business or organization represented on the WSM’s WDB may employ OJT workers if the same standards for selecting OJT Employers who are not members of the WDB are applied, and the WDB member does not participate in the process to select OJT Employers. Funding Limits WSM has established a “Life-time” individual training funding cap of $5,000.

• Reimbursement up to 90% for a business with 50 or fewer employees • Reimbursement up to 75% for a business with 51-200 employees; or • Reimbursement up to 50% for a business with more than 200 employees

Time Limit

The period of reimbursement should be an adequate length of time based upon the individual’s IEP and has acquired the technical skills needed for employment (no longer than six months unless prior approval from the WDB). The ideal time is 3-4 months in duration.

Contract OJTs can be either BSR negotiated with business or participant-initiated. In either case, the BSR develops the contract with the business. An OJT contract completed by a BSR must include the following elements:

1. Training Plan – Provides rationale for training, period covered, an overview and monthly details of the expected training.

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2. Employer Contract – Provides a summary of the training program and executes the agreement between the WSM program and the business partner. Contracts are signed by the WIOA Program Director.

3. Employer W-9 – in order to process the reimbursement.

4. The BSR will give the fully executed contract to the WIOA Program Director, add the data into OJT google doc, add the data into the Individual Cost Google Doc and email a copy of the executed contract to the Career Specialist.

5. The Career Specialist will place a copy of the executed contract in the customer’s case file and correctly update MWE with this service within 48 hours of receipt of the email.

Payment Process Payments will follow the process described below:

1. BSR submits timesheet and/or invoice via email to the Administrative Coordinator after reviewing those documents against the contract to be sure all is as authorized. In the email include: a. Exactly how the name of the business should be written on the check

and the address for that recipient for mailing. b. A statement in the email from the BSR that the attached invoice is

approved to pay.

2. For the first timesheet, the email (which is copied to the WIOA Program Director) must include a copy of the fully executed contract.

3. Records of all payments, including date of check/payment, amount of

payment, to whom the payment was issued, and check or voucher number will be recorded by the Administrative Coordinator into the Individual Cost Google Doc.

4. The Administrative Coordinator completes payment packet and scans to Corporate Finance.

5. Corporate Finance will process the request and mail the check to the Employer. Corporate Finance will keep the only copy of the check.

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Apprenticeships The Workforce Innovation and Opportunity Act (WIOA) provides an extraordinary opportunity for the public workforce system to transform and improve the quality of life for job seekers and workers through an integrated, job-driven system that links diverse talent to our nation’s businesses. Registered Apprenticeship is a proven workforce strategy that can help state and local workforce systems transform how they meet the needs of businesses and workers and fully achieve the vision for the workforce system under WIOA. The critical strategies that are called for in WIOA, such as sector strategies and career pathways, are at the heart of the apprenticeship model. The foundation of apprenticeship is deep industry engagement that can further the workforce system’s efforts to support regional economies. Apprenticeship is an effective work-based learning approach that builds worker skills and establishes pathways to higher levels of employment and wages. Registered Apprenticeship is an industry-driven model that combines on-the-job learning with job related instruction. As an “earn and learn” model, apprentices are employed and earn wages from the first day on the job. Apprenticeship is a flexible training strategy that can be customized to meet the needs of any business. There are currently more than 1,000 occupations – including careers in health care, information technology, transportation, and energy – in which apprenticeship is used to meet business needs for qualified workers. Using apprenticeship as a workforce strategy will also contribute to higher performance outcomes in employment, retention, earnings, and credential attainment. All Registered Apprenticeship programs, by virtue of their registration, can be on a state’s Eligible Training Provider List and thereby eligible to receive federal workforce funding as pre-approved training providers. OJT can be used to support apprenticeship programs, and this change promotes the greater use of apprenticeship as a strategy to address the needs of both employers and job seekers. WIOA supports apprenticeship as a workforce strategy for youth. The law cites pre-apprenticeship activities and work-based learning among the youth program elements. WIOA also recognizes apprenticeship as a career pathway

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for Job Corps students and supports coordination of the Youth Build program with pre-apprenticeship and apprenticeship programs. Supportive Services Supportive services should only be provided when they are necessary to enable the participant to continue in Title I activities. Supportive Services are not guaranteed; if available, they are cost reimbursable only. Customers seeking Supportive Services, assessed during either an Intake or WIOA suitability process, should be referred to a partnering agency. Services may include: - Transportation - Exam Fees / Certification - Clothing allowance for training courses - Medical Testing needed for entry into - Dependent care training or employment - Housing Customers with substantial need are not deemed “job ready” but after referral and resolution, are welcome to continue with their job strategy.

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Appendix A: CUSTOMER FLOW

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Appendix B Emergency Action Plan American Job Center

I _____________________________________________ have read the Emergency Action Plan and understand my responsibilities in regard to this plan. _______________________________________________ _____________________ Print Name - Last First MI Date _____________________________________________ _____________________ Employee Signature Date _______________________________________________ _____________________ Supervisor Signature Date

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Appendix C Incident and Accident Reporting American Job Center

This report must be filled out within 24 hours of the event and turned into the Center Manager; immediate notification is required if the incident requires the involvement of the police or paramedics. Date of Incident: ____________________ Date Reported: __________________ Time of Incident: ____________________ Time Reported: __________________ Incident specific location within the Center (e.g. resource area, training room, office, etc.): _______________________________________________________________ Reporter Name: ______________________________________________________ Phone Number(s):_______________________________________________________ Position:______________________________ Agency:__________________________ Witness Name: ________________________________________________________ Witness Phone Number(s):_____________________________________________ Incident Description (Reporter): ___________________________________________________ ____________________________________________________________________________ ____________________________________________________________________________ ____________________________________________________________________________ ____________________________________________________________________________ ____________________________________________________________________________ Incident Description (Witness, if available): __________________________________________ ____________________________________________________________________________ ____________________________________________________________________________ ____________________________________________________________________________ ____________________________________________________________________________ Preventable (circle one): Yes No

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Suggested Corrective Action: ____________________________________________________________________________ ____________________________________________________________________________ ____________________________________________________________________________ ____________________________________________________________________________ ____________________________________________________________________________ Signature of Reporter: _______________________________________ Signature of Witness: ________________________________________

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Appendix D Grievance Reporting – Customer Copy American Job Center

I have received a copy of the Grievance Procedure. I understand that as a participant in a Montgomery County WorkSource Montgomery program, I must first attempt to resolve any complaints through procedures established by the agency to which I have been assigned. If I am unable to resolve the complaint at this level, or if I am not satisfied with the decision resulting from the complaint, I understand that I may file a complaint with the Montgomery County Division of Workforce Services following the steps outlined in the Grievance Procedures. Signed ____________________________________________Date__________ Witness____________________________________________Date___________

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Appendix E Staff Confidentiality Agreement American Job Center

I, _________________________________ [print name], understand that, by virtue of my position within the Montgomery County Workforce Development System (through the Workforce Development Board, WorkSource Montgomery, or as vendors to WorkSource Montgomery), I may have access to customer and employer confidential records. I have read and understand the Workforce Development Board’s Policy on Confidentiality and Protecting Personal Information. I understand that it is my responsibility as part of the workforce development system in Montgomery County to protect the confidentiality of all Workforce Investment and Opportunity Act (WIOA) applicants and participants, as well as customers utilizing the Montgomery County American Job Centers and any affiliated sites and programs. I understand that in the workforce system’s collection, usage, storage and transmission of customer information, the tenets of confidentiality are to be strictly enforced. I understand that violation of this policy could result in disciplinary action, which could include verbal counseling, written warning or termination of my employment or position. I also understand that violations of confidentiality may be subject to civil and criminal liability under state and/or federal law. By signing below, I acknowledge that I have read and understand this policy and agree to be bound by those terms and conditions throughout my participation in the workforce system. WorkSource Montgomery staff or their designee have answered any questions I may have had regarding this policy. _________________________________________________________________ Print Name __________________________________________________________________ Employee/Volunteer Signature Date

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Appendix F Participant Confidentiality Agreement American Job Center

It is the policy of the Montgomery County Workforce Development Board to protect the confidentiality of all customer information. Access to Data Program operators must collect data in order to document eligibility and provide services per federal regulation under the Workforce Innovation and Opportunity Act. The Workforce Development Board, WorkSource Montgomery and subcontractors will make every effort to collect and store data in a secure manner. Access to any personal customer information is restricted to only those staff and representatives who need it in their official capacity to perform duties pertaining to service delivery. For auditing and monitoring purposes, individual’s personal and confidential information may be shared among federal and state agencies, partner staff and contractors under the WorkSource Montgomery umbrella. Access is for the purpose of determining compliance with, and ensuring enforcement of the provisions of the Workforce Innovation and Opportunity Act. Use and Release Data Data will only be used for the purposes of verifying eligibility, delivering services, and verifying performance measures. Any other use of individual data will require written consent from the customer or customer’s parent/legal guardian. Upon request, data can be released to the subject of the information. All sensitive individual data is stored in an area that is physically safe from access by unauthorized persons at all times and data transmitted electronically is encrypted. Medical and disability records are additionally protected as confidential information. Any medical or disability records are kept separately in a secured physical and/or electronic location. Social security numbers are also protected as high-risk information. Whenever possible, staff and representatives will use unique identifiers to track individual data.

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By signing below, I acknowledge that I have explained this agreement to the WorkSource Montgomery-affiliated customer. Staff Signature: ___________________________________Date ________________ By signing below, I acknowledge that I have read and understand this agreement. WorkSource Montgomery staff have explained this agreement and answered any questions I may have had. Individual Signature: _______________________________Date _______________

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Appendix G Annual Conflict of Interest Statement

American Job Center Name: ____________________________________________________ Position: ___________________________________________________ Are you a voting Director? ☐Yes ☐No Are you an Officer of the WDB or WSM? ☐Yes ☐No

If yes, list your position: ______________________________________. Are you an employee of ☐WSM ☐Contractor receiving WIOA funds I affirm the following by initiating:

_____ I have received a copy of the WDB Conflict of Interest Policy. _____ I have read and understand the policy. _____ I agree to comply with the policy.

Do you have any relationships that might reasonably be regarded as creating a possible conflict of interest? ☐Yes ☐No If YES, please describe: I certify that I have read, understand and will comply with the WDB policy on Conflict of Interest. Signature _____________________________________________________ Date____________________

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Appendix H RESOURCE AREA CHECKLIST The following checklist is to be used to assist anyone who is staffing the front desk and resource area to ensure the area is maintained, neat, and clean.

□ Ensure that the internal walk ways are clear of chairs and any other obstructions to ensure easy access by persons who may be using a wheelchair.

□ Wipe down the computers and the computer tables with sanitizer at the

end of every day, if not more often.

□ Ensure all trash is in the trash cans.

□ Ensure all the shelves are straight and signage is in place and straight.

□ Make sure all chairs are pushed under the tables and that the entire area is straightened up and ready for customers in the morning.

□ Check each computer to make sure that there are no resumes or other personal items on the desk top. Delete if there are.

□ Check each computer to make sure that all the standing icons are on the desk top. If not, let the AJC Manager know what is missing and on which computer.

□ Make sure that the customer comment card signage is next to each computer.

□ Make sure that the partner sign-in log is on a clean page for the start of the

next day.

□ Make sure the bulletin boards and announcements are up to date and take off those that are no longer relevant.

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□ Make sure there are copies of all the forms and other handouts for customers at the front desk for the start of the next day.

□ Make sure that all the equipment is turned off if you are checking at the end of the day.

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Appendix I: CONFLICT RESOULTION FLOW CHART

An issue needs resolution between staff/partner agencies

Involved staff contacts their respective supervisors ( if resolution has not been reached by the staff among themselves)

Supervisors (and staff if appropriate) meet following respective agency procedures

Resolved? If yes, document issue as required by respective agency policies and inform the center manager.

No

Each supervisor either separately or collectively email the leader of the OSC with info described in the procedu re

OSC provides resolution or steps to resolution and follow - up to supervisors.

Documented in correspondence and meeting notes.

Resolved?

No

Supervisors co ntact the chair of the QA C ommittee in writing.

QA Committee provides resolution or steps to resolution and follow - up to supervisors.

Documented in correspondence and meeting notes.

If yes, document issue as required by respective agency policies .

Issue resolved.