7.1.5 Limitations

Effective date: July 1, 2020

The state and local WDBs have the ability to establish general limitations for all Individual Training Accounts (ITAs) through policy, including limits on:

• duration;
• dollar amount (e.g., a range of amounts based on level/type of training or occupational field, or a maximum amount for all ITAs);¹
• occupational area;² and
• level of education/training that will be funded (e.g., certificate programs, bachelor's or master's degrees).³

Any general limitations on ITAs cannot be devised or implemented in a manner that undermines WIOA's requirement that training services be provided in a manner that maximizes customer choice in the selection of a training program from the ETPL.⁴ Therefore, DWD-DET prohibits local WDBs from:

• prohibiting the use of ITAs for particular institutions included on Wisconsin's ETPL;
  OR
• requiring participants to select programs on the ETPL that lead to a WIOA-recognized credential.⁵

Any general limitations established by the State WDB or a local WDB through policy must also be described in the State or Local Plan, respectively.⁶ These limitations are not effective until they are included in the State or Local Plan.⁷

Note: Wisconsin's State WDB, The Governor's Council on Workforce Investment, has not established any general limitations on ITAs.

To the extent the State WDB or a local WDB establishes general limitations on ITAs, they may also address situations when exceptions may be made for individual cases.⁸ If the State WDB or a local WDB allows exceptions to the limitations, those exceptions must be described in state or local policy, respectively.⁹ When a local WDB allows for exceptions, DWD-DET requires the local WDB to describe in its local policy the criteria it will use for granting an exception and the procedure it will follow to approve or deny an exception.

If a local WDB includes general limitations in its Local Plan, DWD-DET requires the local WDB to complete the "ITA Limitations" form and send the completed form to its assigned Local Program Liaison within five business days from the effective date of the Local Plan. DWD-DET will publish the local WDB's "ITA Limitations" form on Wisconsin's ETPL website to notify participants and training institutions of the limitations. If the local WDB changes the general limitations through a modification to its existing Local Plan or by issuing a new Plan, it must complete and send a new "ITA Limitations" form to its assigned Local Program Liaison within five business days from the effective date of the modified or new Plan.

• ¹ 20 CFR § 680.310(d). Participants may select training programs that exceed local WDB amount limits. See 7.1.7 Funding Coordination for more information.
• ² 20 CFR § 680.210(b) states that programs of training services must be directly linked to the employment opportunities in the local area or the planning region, or in another area to which the individuals are willing to commute or relocate.
• ³ 20 CFR § 680.310
• ⁴ 20 CFR § 680.310(c)
• ⁵ 20 CFR § 680.420 specifically allows training that leads to employment or measurable skill gains.
• ⁶ 20 CFR § 680.310(c)
• ⁷ 20 CFR § 679.550 states that policies, procedures, and local activities carried out in the local area must be included in the local plan and that the local WDB must provide an opportunity for public comment.
• ⁸ 20 CFR § 680.310(c)
• ⁹ 20 CFR § 680.310(c)