WIOA Title I-A & I-B Policy & Procedure Manual
Ch.2) The One-Stop (Job Center) Delivery System

2.7.4 OSOs Serving Multiple Roles

Effective date: October 1, 2020

Any entity serving as an OSO that also serves a different role within the one-stop delivery system may perform some or all of these functions when it is acting in its other role if it has established sufficient firewalls and conflict of interest policies and procedures in accordance with 20 CFR § 679.430.1 Any organization that has been selected to perform more than one of these functions must develop a written agreement with the local WDB and CEO to clarify how the organization will carry out its responsibilities while demonstrating compliance with WIOA regulations and corresponding guidance, Uniform Guidance and relevant Office of Management and Budget circulars, and the state's conflict of interest policy.

An OSO can be a service provider, but there must be appropriate firewalls in place regarding the competition and subsequent oversight, monitoring, and evaluation of performance of the service provider.

The OSO cannot develop, manage, or conduct the competition of a service provider in which it intends to compete.

There must also be firewalls and internal controls within the operator-service provider entity.

In cases where the local WDB is selected as the OSO, appropriate firewalls must be established to distinguish between its role as the local WDB and its role as the OSO. These firewalls should be clearly defined in the written request for authorization described in Section 2.7.2.1.