Illinois Youth Investment Program - Summer Appendix O - Wages and Incentives

Appendix O - Wages and Incentives

Wages

Summer Employment

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 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 in excess of $16.00 per hour. While a youth may be enrolled in IYIP-S for more than 13 weeks, full and part-time wages may only be subsidized in whole or in part with grant funding for a period of up to 3 months (13 weeks). The calculation of the 3-month limitation only includes periods during which the youth is earning a full or partial subsidized wage. The 3-month limitation is a limitation per participant, not per placement and considers length of time subsidies 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.

Additional Provisions

  1. No youth, under any circumstance, may receive a combined wage subsidy for a period in excess of 13 weeks.
  2. 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 the following criteria:
    1. The Grantee must submit payroll documentation, including wages, wage subsidies, and 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.
    2. All subsidized wages paid will be disallowed if the youth was not fully enrolled in Illinois workNet on or before the date the subsidy was earned.

Incentives

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.

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:

  1. The cost of the incentive program has been written into the Youth Provider's budget.
  2. The incentives are reasonable and necessary.
  3. The incentives must equate to an achievement, for achievement of certain goals, milestones and training and skill development activities connected to individual case plan goals.