At NN4Y’s annual Federal Agency Roundtable Discussion, the U.S. Department of Labor (DOL) announced new guidance that addresses one of the longstanding recommendations we have been making to DOL regarding waiving parental signature requirements. Training and Employment guidance letter no. 09-22 published March 2, 2023 is Workforce Innovation and Opportunity Act Title I Youth Formula Program Guidance.
NN4Y has been advocating for youth rights for many years. Specifically, we have been recommending that all DOL programs allow youth to enroll themselves without requiring parental signature/permission. This new guidance under the title of “Documenting WIOA Youth Eligibility” is:
…self-attestation is an acceptable source of documenting almost all program elements related to WIOA Youth eligibility. As stated in TEGL 23-19, Change 1, the following youth eligibility data elements allow self-attestation as an acceptable source of documentation: school status at program entry, date of birth, individual with a disability, pregnant or parenting, youth who needs additional assistance, foster youth, homeless youth, offender, low income, and English Language Learner. The only data element related to WIOA Youth eligibility that does not permit the use of self-attestation for documentation is “basic skills deficient.”
Please note that as stated in TEGL 23-19, Change 1, self-attestation means a written, or electronic/digital declaration of information for a particular data element, signed and dated by the participant. ETA broadly interprets what is an electronic/digital signature. Electronic signatures or a submission from the participant such as an email, text, or unique online survey response is considered an electronic signature or verification; it must be participant generated and traceable to the participant. Grantees must retain documentation of the self-attestation….
NN4Y strongly encourages local Workforce Development Boards to not add any parental signature or other requirements on top of this guidance. Low barrier access to DOL programs is vital for many youth, including youth experiencing homelessness. These programs enable youth to earn a living wage and help put youth on a pathway to upward socioeconomic mobility.