Appendix j definitions and terms administrative Costs

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Appendix J

Administrative Costs - Administrative costs shall consist of all direct and indirect costs

associated with the supervision and management of the program. These costs shall include the administrative costs, both direct and indirect, of sub-recipients and contractors.

Adult Basic Education - Education for adults whose inability to speak, read, or write the English language or to effectively reason mathematically, constitutes a substantial impairment of their ability to get or retain employment commensurate with their real ability, which is designed to help eliminate such inability and raise the level, of education of such individuals with a view to making them less likely to become dependent on others, to improve their ability to benefit from occupational training and otherwise increase their opportunities for more productive and profitable employment, and to make them better able to meet their adult responsibilities.
Ancillary Services – Employment and training related activities other than core training that may enhance a participant’s employability.
Apprenticeship Training – A formal occupational training program that combines on-the-job training and related instruction and in which workers learn the practical and conceptual skills required for a skilled occupation, craft, or trade. It may be registered or unregistered.
Assessment/Intake - A process for screening individual applicants for program eligibility making the level of need determinations; making an initial determination what services or programs can best benefit the applicants; providing information about services, program eligibility, and the availability of those services, and the routing or selecting individual applicants for particular service delivery or program participation.
Assisted Placements Into Unsubsidized Employment - Assisted placements into unsubsidized employment should be recorded where the definition for placement with unsubsidized employment above is met, but the placement was arranged by an agency to which the homeless veteran was referred to.
Average Hourly Wage At Placement - The average hourly wage at placement is the average hourly wage rates at placement of all assisted placements plus direct placements.
Assurance and Certifications - The act of signifying intent to comply with applicable federal and State laws and regulations as a condition for receiving and expanding USDOL grant funds.
Barriers to Employment - Characteristics that may hinder an individual’s hiring promotion or participation in the labor force. Identification of these barriers will vary by location and labor market. Some examples of individuals who may face barriers to employment include: single parents, women, displaced homemakers, youth, public assistance recipients, older workers, substance abusers, teenage parents, certain veterans, ethnic minorities, and those with limited English speaking ability or a criminal record or with a lack of education, work experience, credential, child care arrangements, transportation or alternative working parents.
Campaign Badge veteran - A veteran who served on active duty during the war (e.g., WWII),

action (e.g., Korea, Vietnam), in a campaign, or an expedition for which a campaign badge of an

expeditionary medal has been authorized (e.g. Bosnia, Grenada, Haiti, Panama,

Southeast Asia, and Somalia).

Case Management - A client centered approach in the delivery of intensive services, designed to prepare and coordinate comprehensive employment plans for participants, to assure access to the necessary training and supportive services, and to provide support during program participation and after job placement.
Case Manager - One who coordinates, facilitates or provides direct services to a client or trainee from application through placement, post placement follow-up, or other case closing, exclusively, through periodic contact and the provision of appropriate assistance.
Chronically Homeless – is defined as an unaccompanied homeless individual with a disabling condition who has either been continuously homeless for a year or more, or who has had at least four (4) episodes of homelessness in the past three (3) years. A disabling condition is defined as a diagnosable substance abuse disorder, serious mental illness, developmental disability, or chronic physical illness or disability including the co-occurrence of two or more of these conditions. A disabling condition limits an individual's ability to work or perform one or more activities of daily living.
Classroom Training – Any training of the type normally conducted in an institutional setting, including vocational education, which is designed to provide individuals with the technical skills and information required to perform a specific job or group of jobs. It may also include training designed to enhance the employability of individuals by upgrading basic skills, throughout the provision of courses such as remedial education, training in the primary language of persons with limited English language proficiency, or English as a second language training.
Close Out – Grant close out is the process by which the Federal grantor agency (in the case of VETS grants, Department of Labor) determines that all applicable administrative actions and all required work of the grant have been completed by the grantee and the grantor.
Cognizant Federal Agency - The federal agency that is assigned audit or indirect cost rate approval responsibility for a particular recipient organization by the Office of Management and Budget (OMB Circular A-87 and A-102 [20 CFR, Part 97]).

Community Based Organization – means a private non-profit organization that is representative of a community or a significant segment of a community and that has demonstrated expertise and effectiveness in the field of workforce investment.
Core Training – Core Training activities are employment-focused interventions which address basic vocational skills deficiencies that prevent the participant from accessing appropriate jobs and/or occupations.
Cost Per Placement - The cost per placement into unsubsidized employment is obtained by dividing the total funds expended by the total of direct placements plus assisted placements.
Counseling - A form of assistance which provides guidance in the development of a participant’s vocational goals and the means to achieve those goals; and/or assist a participant with the solution to one or more individual problems which may pose a barrier (s) to sustained employment.
Counselor - (Employment/Vocational): A trained and qualified professional authorized to provide direct assistance (beyond advising and informing) through planning, testing, training and otherwise readying an individual for sustained employment.
Customized Training – A training program designed to meet the special requirements of an employer who has entered into an agreement with a Service Delivery Area to hire individuals who are trained to the employer’s specifications. The training may occur at the employer’s site or may be provided by a training vendor able to meet the employer’s requirements. Such training usually requires a commitment from the employer to hire a specified number of trainees who satisfactorily complete the training.
Direct Placements Into Unsubsidized Employment - A direct placement into unsubsidized employment must be a placement made directly by staff with an established employer who covers all employment costs for 20 or more hours per week at or above the minimum wage. Day labor and other very short-term placements should not be recorded as placements into unsubsidized employment.
Disabled Veteran - A veteran who is entitled to compensation under laws administered by the Veterans Administration; or an individual who was medically discharged or otherwise released from active duty, due to service-connected disability.
Disallowed Costs – Disallowed costs are those charges to a grant that the grantor agency (or its representative) determines to be unallowable in accordance with the applicable Federal Cost Principles or other conditions in the grant.
Disabled Veterans’ Outreach Program (DVOP) - A program of Federal assistance through grants to States to staff and support in accordance with 38 U.S.C. 4103A, appointed to perform a number of duties chief among which are direct employer contact, particularly with Federal contractors, Federal employers using individualized job development techniques, and with veterans (particularly with disabled veterans) using a case management approach to client- centered services.
Economically Disadvantaged – An individual who (a) receives, or is a member of a family which receives, cash welfare payments under a Federal, state, or local welfare program; (b) has, or is a member of a family which has, received a total family income for the six-month period prior to application for the program involved (exclusive of unemployment compensation, child support payments, and welfare payments) which, in relation to family size, was not in excess of the higher of (i) the official poverty line (as defined by the Office of Management and Budget, and revised annually in accordance with section 673 (2) of the Omnibus Budget Reconciliation Act of 1981 (42 U.S.C. 9902(2)), or (ii) 70 percent of the lower living standard income level; (c) is receiving (or has been determined within the 6-month period prior to the application for program involved to be eligible to receive) food stamps pursuant to the Food Stamp At of 1977; (d) qualifies as a homeless individual under section 103 of the Stewart B. McKinney Homeless Assistance Acct; (e) is a foster child on behalf of whom state or local government payments are made or (f) in cases permitted by regulations of the Secretary, is an individual with a disability whose income meets the requirements of clause (a) or (b), but who is a member of a family whose income does not meet such requirements.
Eligible - Meeting the minimum requisite qualifications to be considered for the provision of services or entry into a position under a funded program or as required by law.
Employability Development Services (EDS) - This includes services and activities that will develop or increase the employability of the participant. Generally, this includes vocational counseling, classroom and on-the-job training, pre-employment services (such as job seeking skills and job search workshops), temporary or trial employment, sheltered work environments and other related services and activities. Planned services should assist the participant in addressing specific barriers to employment and finding a job. These activities may be provided by the applicant or by a Sub-grantee, contractor or another source such as the local Workforce Investment Act program or the DVOP personnel or LVERs. Such services are not mandatory but entries should reflect the services described in the application and the expected number of participants receiving or enrolled in such services during each quarter. Participants may be recorded more than once if they receive more than one service.
Employment Development Plan (EDP) – An individualized written plan or intervention strategy for serving an individual which, as a result of an assessment of the veteran’s economic needs, vocational interests, aptitudes, work history, etc., defines a reasonable vocational or employment goal and the developmental services or steps required to reach the goal and which documents the accomplishments made by the individual.
Employment Service – the state level organization or public labor exchange system affiliated with the Department of Labor’s United States Employment Service.
Enlistments - Individuals who have expressed an interest, signed up for a workshop or enrollment in the program.
Entered Employment - participants who were placed in jobs or otherwise obtained employment as a result of services used or received and who retained that employment one quarter after their initial placement. While a grantee may have placements in the first quarter, by definition they should not have any “enter employments” in the first quarter.
Entered Employment Rate (EER) – is a Common Measure based term determined by dividing the number of participants who obtained and retained employment one quarter after their initial placement or when they “exited” the program by the total number of participants who have exited the program. In order to determine the entered employment rate, the program must track the employment status of their enrollees after they leave the program by re-contacting them in some way.
Enrolled Veteran – Shall be synonymous with the term participant. A veteran who has been determined eligible for services at intake and who is receiving or scheduled to receive core training.
Follow-up - The tracking of clients for a period of time up to three quarters after initial placement, last referral date for services or completion of training programs to determine current status, outcome or whether to offer additional services (such as additional referral, job retention advisement, etc.).
Full-Time Equivalent (FTE) – a personnel charge to the grant equal to 2,080 hours per year.
FY - Fiscal Year. For federal government purposes, any twelve month period beginning on October 1 and ending on September 30.
General Equivalency Diploma (GED) – A high school equivalency diploma that is obtained by passing the General Educational Diploma Equivalency Test that measures the application of skills and knowledge generally associated with four (4) years of traditional high school instruction.
Grant Officer’s Technical Representative (GOTR) - An individual (usually the DVET) serving on behalf of the Grant Officer who maintains and ensures the integrity of the approved grant agreement by reviewing and making recommendations regarding technical matters not involving a change in scope, cost, or conditions.
Homeless or homeless individual

The “Homeless Emergency Assistance and Rapid Transition to Housing (HEARTH) Act of 2009” (Public Law 111-22, Division B, Section 1003(a)(2) amended the definition of homeless in Section 103(a) of the McKinney-Vento Act.

38 U.S.C. 2002(1), the definition in Section 103(a) (42 U.S.C. 11302(a)) of the McKinney-Vento Act applies to grants issued under 38 U.S.C. 2021 (HVRP).

a) IN GENERAL.—For purposes of this Act, the terms ‘homeless’, ‘homeless individual’, and ‘homeless person’ means—

            (1) an individual or family who lacks a fixed, regular, and adequate nighttime residence;

(2) an individual or family with a primary nighttime residence that is a public or private place not designed for or ordinarily used as a regular sleeping accommodation for human beings, including a car, park, abandoned building, bus or train station, airport, or camping ground;

(3) an individual or family living in a supervised publicly or privately operated shelter designated to provide temporary living arrangements (including hotels and motels paid for by Federal, State, or local government programs for low-income individuals or by charitable organizations, congregate shelters, and transitional housing);

(4) an individual who resided in a shelter or place not meant for human habitation and who is exiting an institution where he or she temporarily resided;

(5) an individual or family who—

(A) will imminently lose their housing, including housing they own, rent, or live in without paying rent, are sharing with others, and rooms in hotels or motels not paid for by Federal, State, or local government programs for low-income individuals or by charitable organizations, as evidenced by—

(i) a court order resulting from an eviction action that notifies the individual or family that they must leave within 14 days;

(ii) the individual or family having a primary nighttime residence that is a room in a hotel or motel and where they lack the resources necessary to reside there for more than 14 days; or

(iii) credible evidence indicating that the owner or renter of the housing will not allow the individual or family to stay for more than 14 days, and any oral statement from an individual or family seeking homeless assistance that is found to be credible shall be considered credible evidence for purposes of this clause;

(B) has no subsequent residence identified; and

(C) lacks the resources or support networks needed to obtain other permanent housing; and

(6) unaccompanied youth and homeless families with children and youth defined

as homeless under other Federal Statutes who--

(A) have experienced a long term period without living independently in permanent housing,

(B) have experienced persistent instability as measured by frequent moves

over such period, and

(C) can be expected to continue in such status for an extended period of time because of chronic disabilities, chronic physical health or mental health conditions, substance addiction, histories of domestic violence or childhood abuse, the presence of a child or youth with a disability, or multiple barriers to employment.

Indirect cost - A cost that is incurred for a common or joint purpose benefiting more than one cost objective and that is not readily assignable to the cost objective specifically benefited.
In-kind Services – Property or services which benefit federally assisted project or program and which are contributed without charge to the grantee.
Institutional Skills Training – training conducted in an institutional setting and designed to ensure that individuals acquire the skills, knowledge, and abilities necessary to perform a job or group of jobs in an occupation for which there is a demand.
Intake – A process for screening individual applicants for eligibility; making an initial determination whether the program can benefit the applicants; providing information about the program, its services and the availability of those services; and selecting individual applicants for participation in the program.
Intensive Services - The provision of concentrated staff services to clients who indicate the need for facilitation or interventions to secure lasting employment. The case management approach to service delivery is a viable model for successfully providing such services and obtaining the clients goals.
Job Club Activities – A form of job search assistance provided in a group setting. Usually job clubs provide instruction and assistance in completing job applications and developing resumes and focus on maximizing employment opportunities in the labor market and developing job leads. Many job clubs use telephone banks and provide group support to participants before and after they interview for job openings.
Job Development - The process of marketing a program participant to employers, including informing employers about what the participant can do and soliciting a job interview for that individual with the employer (targeted job development); and the development of one or more job openings or training opportunities with one or more employers using a variety of techniques and means of contact.
Job Placement Services – Job placement services are geared towards placing participants in jobs and may involve activities such as job search assistance, training, or job development. These services are initiated to enhance and expedite participants’ transition from training to employment.
Job Search Assistance - An activity, which focuses on building practical skills and knowledge to identify and initiate employer contact and conduct successful interview with employers. Various approaches may be used to include participation in a job club, receive instruction in identifying personal strengths and goals, resume application preparation, learn interview techniques, and receive labor market information. Job search assistance is often self-service activity in which individuals obtain information about specific job openings or general jobs or occupational information.
Labor Exchange - Refers to the services provided to job seekers and employers by the State Employment Services Agencies, or other designated entities. Preparatory services to job seekers may include assessment, testing, counseling, provision of labor market information, targeted job development, resulting in job referral and follow-up with former applicants and prospective employers. Employer-oriented services may include accepting job orders, screening applicants, referring qualified applicants and providing follow-up to foster job retention and develop additional job openings or training opportunities.
Labor Exchange Delivery System (LEDS) - Describes the system of matching jobs and training opportunities with applicants operating with Federal employment and job training funds.
Labor Force - The sum of all civilians classified as employed and unemployed and members of the Armed Forces stationed in the United States. [Bureau of Labor Statistics Bulletin 2175].
Labor Market Area – an economically integrated geographic area within which individuals can reside and find employment within a reasonable distance or can readily change employment without changing their place of residence.
Literacy and Bilingual Training – See Adult Basic Education.
Local Veterans’ Employment Representative (LVER) Program - A program of Federal assistance through grants to States to staff in accordance with 38 U.S.C.4104 to perform a number of duties, chief among which are the provision of intensive (case management) services to targeted eligible veterans with emphasis on VA, VR&E, and to functionally supervise without necessarily exercising line supervisor authority over the provision of services to veterans by SDP staff.
Minimum Economic Need – the level of wages paid to a program participant that will enable that participant to become economically self-sufficient.
Minority Veterans – for the purposes of the HVRP and VWIP programs, veterans who are Workforce Investment Act (WIA) eligible and are members of the following ethnic categories: African American, Hispanic, American Indian or Alaskan Native, Asian or Pacific Islander.
National Veterans’ Training Institute (NVTI) - An agency contracted with USDOL/VETS to develop and provide skills development and enhancement training to individuals who are determined by the Assistant Secretary for Veterans’ Employment and Training and who deliver or monitor the provision of employment and training services to veterans (38 U.S.C. 4109).
Occupational Skills Training – Includes both (1) vocational education which is designed to provide individuals with the technical skills and information required to perform a specific job or group of jobs, and (2) on-the-job training.
Offender – Any adult or juvenile who has been subject to any stage of the criminal justice process for whom services under this program may be beneficial or who requires assistance in overcoming artificial barriers to employment resulting from a record of arrest or conviction.
On-the-Job Training (OJT) – means training by an employer that is provided to a paid participant while engaged in productive work in a job that: (a) provides knowledge or skill essential to the full and adequate performance of the job; (b) provides reimbursement to the employer of up to 50 percent of the wage rate of the participant, for the extraordinary costs of providing the training and additional supervision related to the participant is being trained, taking into account the content of the training, the prior work experience of the participant, and the service strategy of the participant, as appropriate. Usually in the OJT agreement, there is a promise on the part of the employer to hire the trainee upon successful completion of the training.
On-Site Industry-Specific Training – This is training which is specifically tailored to the needs of a particular employer and/or industry. Participants may be trained according to specifications developed by an employer for an occupation or group of occupations at a job site. Such training is usually presented to a group of participants in an environment or job site representative of the actual job/occupation, and there is often an obligation on the part of the employer to hire a certain number of participants who successfully complete the training.
Outreach - An active effort by program staff to encourage individuals in the designated service delivery area to avail themselves of program services.
Outside Funds – Resources pledged to the grant program that have a quantified dollar value. Such resources may include training funds from programs such as WIA Title I that are put aside for the exclusive use by participants enrolled in a program. Outside funds do not include in-kind services.
Participant – means an individual who has been determined to be eligible to participate in and who is receiving services (except follow-up services) under the program. Participation shall be deemed to commence on the first day, following determination of eligibility, on which the individual began receiving subsidized employment, training, or other services provided under the program. An individual who receives only outreach and/or intake assessment services does not meet this definition.
Participants Enrolled - A client should be recorded as having been enrolled when an intake form has been completed, and services, referral, and/or employment has been received through the program. This should be an unduplicated count over the year, i.e., each participant is recorded only once, regardless of the number of times she or he receives assistance.
Participants Services - This cost includes supportive, training, or social rehabilitation services, which will assist in stabilizing the participant. This category should reflect all costs other than administrative.
Placed Into Transitional Or Permanent Housing - A placement into transitional or permanent housing should be recorded when a veteran served by the program upgrades his/her housing situation during the reporting period from shelter/streets to transitional housing or permanent housing or from transitional housing to permanent housing. Placements resulting from referrals by staff shall be counted. This item is however an unduplicated count over the year, except that a participant may be counted once upon entering transitional housing and again upon obtaining permanent housing.
Placement – the act of securing unsubsidized employment for or by a participant.
Placement Rate - This is a method used to determine the percentage of participants who become employed. The figure is calculated by dividing the number of total participants who were registered for services or enrolled in the program by the number of applicants or program participants who were placed or otherwise entered employment.
Pre-apprenticeship Training – Any training designed to increase or upgrade specific academic, or cognitive, or physical skills required as a prerequisite for entry into a specific trade or occupation.
Pre-enrollment Assessment – The process of determining the employability and training needs of individuals before enrolling them into the program. Individual factors usually addressed during pre-enrollment assessment include: an evaluation and/or measurement of vocational interests and aptitudes, present abilities, previous education and work experience, income requirements, and personal circumstances.
Preference - The application of priorities in the consideration and selection through appointment or assignment of staff to funded positions, or in the provision of direct services and order of referral to listed openings in the order designated by statute regulation, and grant agreement.
Program Resources – Includes the total of both program or grant and outside funds.
Program Year (PY) - The 12-month period beginning July 1 in the fiscal year for which the appropriation is made, and ending on the following June 30.
Rate of Placement Into Unsubsidized Employment - The rate of placement into unsubsidized employment is obtained by dividing the number placed into unsubsidized employment, plus the number of assisted placements into unsubsidized employment by the number of clients enrolled.
Recently Separated Veteran - Refers to an individual who applies for program participation or assistance within 48 months of separation from active U.S. military service [29 U.S.C. 1503 (27) (c)].
Remedial Education – Education instruction, particularly in basic skills, to raise an individual’s general competency level in order to succeed in vocational education or skill training programs, or employment.
Retention Rate - is a Common Measure based term determined by dividing the number of participants who entered employment (or those exiters who earned wages in the quarter after their placement) by those exiters who also earned wages in all three quarters after their placement. Grantees will not have a reported retention rate in the first, second, or third quarters because it requires three quarters after placement to determine employment retention.
Service Connected Disabled - Refers to (1) a veteran who is entitled to compensation under laws administered by the Department of Veterans’ Affairs, or (2) an individual who was discharged or released from active duty because of a service-connected disability (38 U.S.C. 4211 (3); 29 U.S.C., Chapter 19, section 1503 (27) (C)
Service Delivery Point (SDP) - Includes offices of the public employment delivery system operated directly or by contract with the State Workforce Agency as grantee within a State and may include One –Stop Career Centers, local employment service offices, and any satellite or itinerant offices at which labor exchange services are available.
Solicitation for Grant Applications (SGA) - A document which provides the requirements and instructions for the submission by eligible applicants identified in the document’s text of requests for Federal domestic assistance (funds) for one or more programs or grants-in-aid.
State Workforce Agency (SWA) - The State level organization, as affiliated with the former United States Employment Service.
Subgrant – An award of financial assistance in the form of money, or property in lieu of money, made under a grant by a grantee to an eligible subgrantee.
Subgrantee – The government or other legal entity to which a subgrant is awarded and which is accountable to the grantee for the use of the funds provided.
Substance Abuser – An individual dependent on alcohol or drugs, especially narcotics, whose dependency constitutes or results in a substantial barrier to employment.
Supportive Services – means services which are necessary to enable an individual eligible for training, but who cannot afford to pay for such services, to participate in a training program funded under the grant. Such supportive services may include transportation, health care, financial assistance (except as a post-termination service), drug and alcohol abuse counseling and referral, individual and family counseling, special services and materials for individuals with disabilities, job coaches, child care and dependent care, temporary shelter, financial counseling, and other reasonable expenses required for participation in the training program and may be provided in-kind or through cash assistance.
Targeted Job Development - The identification and marketing of a group of qualified applicants with similar occupations or employment barriers requiring personal visitation/phone contact with those employers likely to employ these individuals.
Total Planned Expenditures - Identified forecasted financial needs to accomplish programmatic objectives broken down into fiscal quarters.
Unsubsidized Employment – Employment not financed from funds provided under the grant. In the grant program the term “adequate” or “suitable” employment is also used to mean placement in unsubsidized employment which pays an income adequate to accommodate the participants’ minimum economic needs.
Upgrading or Retraining – Training given to an individual who needs such training to advance above an entry level or dead-end position. This training shall include assisting veterans in acquiring needed state certification to be employed in the same field as they were trained in the military (i.e., Commercial Truck Driving License (CDL), Emergency Medical Technician (EMT), Airframe & Power Plant (A&P), Teaching Certificate, etc.)
Veteran - An individual who served in the United States active military, naval, or air service, and who was discharged or released there from under conditions other than dishonorable (29 U.S.C. Chapter 19, section 1503 (27) (A) [for WIA, Section 168 (VWIP) and WIA, Title I training/services]).
Veterans’ Workforce Investment Program (VWIP) – Competitively awarded employment and training grants to meet the needs of veterans with significant barriers to employment; with service-connected disabilities; who served on active duty in the armed forces during a campaign or expedition for which a campaign badge has been authorized; and recently separated veterans. The U.S. Department of Labor, Veterans’ Employment and Training Service awards VWIP grants as authorized under the Workforce Investment Act (WIA), Section 168.
Vocational Exploration Training – Through assessments such as interest inventories and/or counseling, a process of identifying occupations or occupational areas in which a person may find satisfaction and potential, and for which his or her aptitudes and other qualifications may be appropriate.
Vocational Guidance - The provision of information, suggestions, and advice through discussion with individuals who are considering a geographical or vocational choice or change, relating to their career decision.
Wartime Veteran - See “campaign veteran above.”
Welfare and/or Public Assistance recipient – An individual who, during the course of the program year, receives or is a member of a family who receives cash welfare or public assistance payments under a Federal, state, or local welfare program.
Workforce Investment Act (WIA) – The purpose of this Act is to establish programs to prepare youth and unskilled adults for entry into the labor force and to afford job training to those economically disadvantaged individuals and other individuals, including veterans, who face serious barriers to employment and who are in need of such training to obtain prospective employment. The Act requires the Assistant Secretary for Veterans’ Employment and Training to consult with the Secretary of the Department of Veterans Affairs to ensure that programs funded under VWIP of this Act meet the employment and training needs of service-connected disabled, Campaign, and recently separated veterans and are coordinated, to the maximum extent feasible, with related programs and activities.
Work Experience – A temporary activity (six months or less) which provides an individual with the opportunity to acquire the skills and knowledge necessary to perform a job, including appropriate work habits and behaviors, and which may be combined with classroom or other training. When wages are paid to a participant on work experience and when such wage are wholly paid for under WIA, the participant may not receive this training under a private, for profit employer.
Youth – An individual between 20 and 24 years of age.

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