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Farmworker BULLETIN 00-04 Effective: August 30, 2000 - (n/a)

Directive: Farmworker Bulletin 00-04

Subject: OJT GUIDANCE POINTS

Purpose: To provide a resource for Case Managers and other grantee staff of the National Farmworker Jobs Program (NFJP) and MSFW Youth Program when considering On-the-Job Training opportunities for participants.

To:
All NFJP Grantees
All MSFW Youth Program Grantees

From:

ALICIA G.FERNANDEZ-MOTT
Chief
Division of Seasonal Farmworker Programs
Date:
James De Luca
Acting Director
Office of National Programs
Expiration Date:
TO: All NFJP Grantees All MSFW Youth Grantees DATE: August 30, 2000
ONP Bulletin No. 2000-04
Subject: OJT GUIDANCE POINTS

Purpose. To provide a resource for Case Managers and other grantee staff of the National Farmworker Jobs Program (NFJP) and MSFW Youth Program when considering On-the-Job Training opportunities for participants.

References. Workforce Investment Act of 1998, Final WIA Rule, and DSFP Memorandum No. 98-4 for All Section 402 Grantees.

Background. Use of On-the-Job Training (OJT) to obtain stable, unsubsidized employment for participants enrolled in workforce investment programs, has been widely applied for many years, usually with great success. The effectiveness of OJT as a training approach that secures employment at reasonable cost, is widely recognized.

OJT Activity Requirements.

Definition of OJT:The Workforce Investment Act (WIA) defines OJT in Section 101.
The definition states:

    The term "on-the-job training" 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 training; and

    (C) is limited in duration as appropriate to the occupation for which the participant is being training, taking into account the content of the training, the prior work experience of the participant, and the service strategy of the participant, as appropriate.

Enrollment Requirements: OJT is an authorized Training Services activity under WIA. In order to enter a Training Service activity such as OJT, a participant must first have received one Intensive Service (See 20 CFR 669.330.).

An action placing a participant in an OJT activity must be supported by the service strategy decisions developed under the case management for the participant. Whenever a grantee uses case management to determine and monitor the services provided to a participant, the grantee is providing an Intensive Service. When a participant is hired by an employer under an OJT contract as the outcome of his/her case management process, the grantee will have satisfied the requirement for providing an Intensive Service before providing Training Services. Keeping with the WIA promise of customer choice, Case Management requires the full involvement of the participant in the employability development process that leads to the decision that training is needed. When the decision making process leads to development of a particular OJT position with an employer, the on-going nature of case management requires the case managers to continue to work with the OJT participant in ways that promote the successful completion of the training and retention of the participant by the OJT employer.

OJT Contract Requirements: The OJT contract requirements are found in the WIA final regulations at 20 CFR 669.420. The provision provides that OJT contracts must include:

    (a) The occupation(s) for which training is to be provided,
    (b) The duration of training,
    (c) The wage rate to be paid to the trainee,
    (d) The rate of reimbursement,
    (e) The maximum amount of reimbursement,
    (f) A training outline that reflects the work skills required for the position,
    (g) An outline of any other separate classroom training that may be provided by the employer,
    (h) Application of the general program requirements of WIA section 195(4) and section 101(31), and
    (i) The employer's agreement to maintain and make available time and attendance, payroll and other records to support amounts claimed by the employer for reimbursement under the OJT contract.

Who Are the Non-performing OJT Contractors?Grantees must evaluate OJT contractor performance and refrain from contracting with non-performing OJT employers. WIA §195(4) prohibits OJT contracts with

     "employers who have received payments under previous contracts and have exhibited a pattern of failing to provide on-the-job training participants with continued long-term employment as regular employees with wages and employment benefits (including health benefits) and working conditions at the same level and to the same extent as other employees working a similar length of time and doing the same type of work."

Summary: OJT has proven to be an effective training component that achieves successful job placements under a range of conditions, but the same experience has also shown that there are risks associated with OJT that must be understood and appreciated. Grantees must be guided by the requirements for OJT under WIA that are included in this Bulletin and should seek guidance from the attached "Basic Guidance Points for OJT."

ALICIA FERNANDEZ-MOTT JAMES C. DELUCA
Chief Acting Director
Division of Seasonal Farmworker Programs Office of National Programs
ATTACHMENTS: BASIC GUIDANCE POINTS FOR OJT
EXPIRATION DATE: NONE (subject to modification)

cc:Fernandez-Mott, Shearer, Fed. Reps., Official File, Grant Office

TDNF:ROSS SHEARER:bjt 08/30/2000 Rm. N-4644 FPB 219-8216, ext. 102

Doc. Name:ONPBulletin00-04(OJT).wpd (S:\ONP\ONPR\DSFP\BULLETIN)

BASIC GUIDANCE POINTS FOR OJT

IDANCE POINTS FOR OJT

OJT is a time-tested, successful means of placing participants into jobs where they are earning wages and are treated as permanent employees. An OJT program is likely to be a success for the participants, and bring praise to the grantee and the employer, when it:

    is an available option within a grantee's overall NFJP service delivery strategy.

    provides flexibility by offering a variety of OJT jobs available through a range of participating employers.

    is operated by Case Management staff who are entrusted to offer appropriate choices to participants under the Individual Service Strategy (ISS) process. is participant focused when the participant is involved in the decision making process and it is the logical culmination of the participant's Individual Service Strategy (ISS) under the grantee's case management system.

    is used only where it is determined through the case management plan that the participant needs job training and that the OJT methodology is appropriate for the participant.

    is an optional training strategy for those participants who are in need of skills training, but are currently unable to take advantage of classroom training.

    is a primary training strategy for participants whose skills training requirements are best served through learning by doing on the job.

    is one where the employers agree to hire, train and retain the participants as one of their own employees.

    is used only where there is a reasonable expectation that the job skills acquisition will lead to permanent employment for the participant.

    includes an individual Training Outline in every OJT contract that describes the skills to be taught by the employer and specifies a reasonable amount of time for teaching these skills under the OJT setting to the WIA participant.

    is based on agreements between the grantee's and the employer's representatives who negotiate contracted terms for training and reimbursement.

    acquires job training by paying employers for the extraordinary costs associated with training WIA participants, as determined through negotiations.

    relies on a standardized or systematic methodology upon which to base or negotiate the length of the reimbursable training period. (The Specific Vocational Preparation (SVP) levels provide generic guidance in establishing the maximum numbers of training hours.)

    includes high visibility oversight aimed at quality and financial integrity.

    Quality is enhanced through frequent contact, for example, by telephonic questionnaires to employers and participants for evaluating training progress, answering questions and initiating an opportunity for informational exchanges between the employer, the participant and the NFJP grantee.

    Financial integrity is enhanced by invoicing records that are signed by the participants and that tie directly to employers' wage records.

Potential OJT "PITFALLS":

Use of the same employer for multiple and continuing OJT contracts. Conditions occasionally develop where a significant share of an employer's new entry level employees are hired under OJT contracts and this continues over the course of several years or more. Grantee staff should be alert for the development of such conditions. Staff should critically examine the OJT program with the employers it works with to ensure the training is for additional jobs, such as ones created by business expansion, and is not for jobs that result from turnover associated with the nature of the occupation or the employer's business practices.

Pro forma use of OJT agreements where there is little or no evidence of negotiations on occupational skills to be taught by the employers or on the length of the training and reimbursement period.

Pro forma use of the Case Management process where the Individual Service Strategy (ISS) documentation of referrals to OJT is superficial or illogical and does not follow logically from the other client information contained in the ISS.

OJT contracts under which the employer does not commit to retain the employee upon completion of the training.

Inadequate provision for supervision and training by the employer.

No standardized method for determining appropriate length of training with the result that contracts are routinely written for the same time period irrespective of differing needs of participants.

Enrolling referrals or nominees from the OJT employer.

Inappropriate uses of OJT occur when it:

Purchases training in skills the WIA participant already possesses or training for "learning" simple job tasks.

Reimburses employers for OJT placements in high turn-over or low skill jobs--which include many farm labor and food processing jobs.

Subsidizes an employer's payroll or high turn-over job situation.

Pays for training of persons the employer would likely have hired in any event.

Enrolls relatives of the OJT employer.

Date: August 10, 2000