22-444-80-2752 ARPA Illinois Youth Investment Program Appendix O

Wages, Stipends and Incentives

Wages/Stipends

Category I

Wages may be subsidized by the grant for work experience only. This will include employment, work experience, internships, on-the-job training, transitional jobs, apprenticeships, and supervised school-based and youth-led enterprise. Youth may not receive subsidized wages for participation in non-workplace activities such as employment readiness activities, assessments, case management activities, Career Exploration activities, and non-workplace training and skill development activities.

Wage subsidies/stipends in this category will include compensation for services rendered limited to youth wages and benefits to include FICA and workers' compensation. Youth must be paid at least the applicable minimum wage for the jurisdiction in which the youth is employed, and the grant may not provide a wage subsidy or stipend in excess of $15.00 per hour. Full and Part-time wages may be subsidized in whole or in part with grant funding up to 3 months (13 weeks) per enrolled youth. The calculation of the 3-month limitation only includes periods during which the youth is earning a full or partial subsidized wage/stipend. The 3-month limitation is a limitation per participant, not per placement and considers length of time subsidies/stipends are paid. For example, if a youth's subsidized job placement ends after 9 weeks, and the youth receives a new subsidized job placement, the new job placement may only be subsidized for 4 weeks. Programs that are able to off-set the wage subsidies with other funds or have the capacity to provide unsubsidized opportunities, step down, or partial subsidies will be able to stretch funding to allow for additional youth to be served in the program. Incentives paid for achievement of certain identified milestones etc. will NOT count toward the 13-week subsidy maximum.

Category II

Wages may be fully or partially subsidized by the grant for the hours worked for both long-term employment and the required minimum 450 on-the-job training hours worked for the Youth Apprenticeship Program. Further, stipends may be paid for up to 2 semesters of related instruction that lead toward an industry credential as part of the Youth Apprenticeship program. Ideally these 2 semesters of instruction count toward a high-school diploma and/or postsecondary credential. Should a youth participate in a Career Development Experience, the grant may be used to fully or partially subsidize a wage provided the Experience meets the minimal definition criteria above. In total, the wage subsidies/stipends in Category II may not exceed a period of 9 months (39 weeks) per youth.

As a rule, the employer pays the wage for an Apprenticeship program. In this case, grant funds could not be used to pay a wage or stipend for work hours. Grant funds could be used to pay stipends for required training as described above only if the youth is not otherwise being compensated for training participation/completion. In situations where an established training program already pays a wage or stipend for participation in or completion of the training program, the grant may NOT be used to offset or replace this subsidy. Further, stipends may not be paid for the same hour for which a youth is earning a wage, regardless of payee. However, if the employer rate is less than the maximum allowed, the stipend may be paid in addition to but not in lieu of, provided that it at no time exceeds the maximum allowed under the grant ($15.00). If the Apprenticeship / Credentialing program only pays for work hours and not for required training, stipends may be paid for those required and verified training hours.

Except as noted above, youth may not receive subsidized wages or stipends for participation in non-workplace activities such as employment readiness activities, assessments, case management activities, Career Exploration activities, and non-workplace training and skill development activities.

Wage subsidies and stipends in this category will include compensation for services rendered limited to youth wages and benefits to include FICA and workers' compensation. Youth must be paid at least the applicable minimum wage for the jurisdiction in which the youth is employed, and the grant may not provide a wage subsidy or stipend in excess of $15.00 per hour. Full and Part-time wages may be subsidized in whole or in part with grant funding up to 9 months (39 weeks) per enrolled youth. The calculation of the 9-month limitation only includes periods during which the youth is earning a full or partial subsidized wage and/or a stipend. The 9-month limitation is a limitation per participant, not per placement and considers all subsidies/stipends paid. For example, if a youth's subsidized job placement ends after 10 weeks, and the youth receives a new subsidized job placement, the new job placement may only be subsidized for 29 weeks. Programs that are able to off-set the wage subsidies with other funds or have the capacity to provide unsubsidized opportunities, step down, or partial subsidies will be able to stretch funding to allow for additional youth to be served in the program. Incentives paid for achievement of certain identified milestones etc. will NOT count toward the 39-week subsidy maximum.

Category III

During participation in the Apprenticeship and the Recognized Postsecondary Credential training programs, youth may receive a subsidized wage for hours worked. Youth may also receive a weekly stipend for associated and required training. Stipends may only be paid for those training hours required by the Apprenticeship / Credentialing program that are completed, verified and not otherwise compensated for regardless of payee. Training stipends and wage subsidizes may not exceed $15.00 per hour or a combined total period of 12 months (52 weeks).

Wage subsidies and stipends in this category will include compensation for services rendered limited to youth wages and benefits to include FICA and workers' compensation. Training stipends will also include FICA and workers compensation as necessary. As a rule, the employer pays the wage for an Apprenticeship program. In this case, grant funds could not be used to pay a wage or stipend for work hours. Grant funds could be used to pay stipends for required training as described above only if the youth is not otherwise being compensated for training participation/completion. In situations where an established training program already pays a wage or stipend for participation in or completion of the training program, the grant may NOT be used to offset or replace this subsidy. Further, stipends may not be paid for the same hour for which a youth is earning a wage, regardless of payee. However, if the employer rate is less than the maximum allowed, the stipend may be paid in addition to but not in lieu of, provided that it at no time exceeds the maximum allowed under the grant ($15.00). If the Apprenticeship / Credentialing program only pays for work hours and not for required training, stipends may be paid for those required and verified training hours.

Except as noted above, youth may not receive subsidized wages or stipends for participation in non-workplace activities such as employment readiness activities, assessments, case management activities, Career Exploration activities, and non-workplace training and skill development activities.

Additional Provisions (all Categories)

1. Youth will not be eligible to receive a wage subsidy and/or stipend for a combined period in excess of the maximum length allowed by the category for which they are currently enrolled, inclusive of previously paid wage subsidizes/stipends under other categories.
2. No youth, under any circumstance, may receive a combined wage subsidy and/or stipend, for a period in excess of 12 months (52 weeks).
3. When the youth's wage is being subsidized by the grant, the provider may assume the role of employer of record for the employed youth and process a payroll request every two weeks during this subsidized period if this is formally agreed to in writing by both the employer and provider and the job meets all of the following criteria:
4. The Grantee must submit payroll documentation, including wages, wage subsidies, stipends, incentives and the corresponding incentive policy to the Department using Illinois workNet, or other data system as directed by the Department, including hourly wage and the employer's FICA and workers' compensation that is attributed to the participant.
5. All subsidized wages and stipends paid will be disallowed if the youth was not fully enrolled in Illinois workNet on or before the date the subsidy and stipend was earned.

Incentives (All Categories)

Incentives can be effective tools to encourage participation in activities which lead to improved skills and to the achievement of specific program elements. ?An incentive can be in the form of payment, gift cards, or a material item, etc. issued to eligible program participants for the successful participation and achievement of expected outcomes as defined by the specific program and included the individual' s case plan and/or career plan.

While incentive payments are allowable, the incentives must be in compliance with the Cost Principles in 2 CFR part 200. For example, Federal funds must not be spent on entertainment costs. Therefore, incentives must not include entertainment, such as movie or sporting event tickets or gift cards to movie theaters or other venues whose sole purpose is entertainment. Additionally, there are requirements related to internal controls to safeguard cash, which also apply to safeguarding of gift cards, which are essentially cash. The US Department of Labor (USDOL) has also clarified that incentives are not allowed for activities such as recruitment, submitting eligibility documentation, or just simply showing up for the program.

Additional Provisions

1. The incentive must be linked to an achievement and must be tied to training and education, Work Readiness skills, an occupational skills attainment goal or other goal as identified in the individual's case plan and/or career plan. ?
2. Achievements must be documented in Illinois workNet or other system as directed by IDHS and in the participant's file as the basis for an incentive payment.
3. All subsidized incentives paid will be disallowed if the youth was not fully enrolled in Illinois workNet on or before the date the incentive was earned.
4. Incentive award amounts must be reasonable and necessary. Incentives must not be more than the equivalent of $15.00 per hour.
5. Incentives may NOT be used for achievements related to activities for which the youth is receiving a wage or stipend.

Policy
If incentives are planned, a policy must be in place that governs the terms and conditions associated with the provision of the incentives. At minimum, the policy must demonstrate: