Source + trust record
Source checked as of September 18, 2026. Primary authority: EDD WSD13-13, USDOL TEGL 19-16, and active federal ETPL guidance.
Check result: EDD still lists WSD13-13 as active, but its original authority was a WIA-era, time-limited flexibility for PY 2012-13 through PY 2014-15 funds. It should not be used as the current legal basis for training contracts. Under WIOA, ITAs remain the primary training mechanism, while contracts may be used in the specific circumstances allowed by WIOA Section 134(c)(3)(G), 20 CFR 680.320, and current DOL guidance, including certain cohort training through institutions of higher education without limiting consumer choice. This AI-assisted brief does not receive human legal or compliance review. Official sources control.
WDB decision strip
| STATUS | ACTION | PRIMARY OWNER | CURRENT TIMING | IMPACT |
|---|---|---|---|---|
| ACTIVE LEGACY GUIDANCE | USE CONTRACT EXCEPTIONS CAREFULLY | Program + Procurement Leadership | When considering contracts instead of ITAs | Training contracts · Higher education · ETPs · Procurement |
The bottom line
ITAs are the normal WIOA training mechanism, while contracts with higher education or training providers are exceptions that require a documented statutory basis and sound procurement. Boards should identify the exception first, then show why the contract expands access or meets the program need better than ordinary individual training accounts.
Official source: EDD WSD13-13 — Contracts with Higher Education or Eligible Training Providers
Active legacy guidance: contracting with colleges or training providers can be an alternative to ITAs in limited circumstances, but current WIOA procurement and ETPL rules still control
WSD13-13 documented a WIA-era, time-limited flexibility allowing certain contracts with institutions of higher education or eligible training providers for PY 2012-13 through PY 2014-15 funds. It is useful as historical policy context, but current WIOA contract authority comes from WIOA, 20 CFR 680.320, and current federal/state guidance. EDD continues to list the directive as active, but some cited dates, thresholds, and predecessor-policy references are historical.
Active legacy guidance
Issued
May 20, 2014
Subject
Training contracts
Alternative to
ITAs in allowed cases
Current companion
WSD25-02 ETPL
Executive takeaway
Under current WIOA rules, ITAs remain the primary training mechanism, while contracts are permitted in specified circumstances, including certain OJT, customized, incumbent-worker, transitional-job, demonstrated-effectiveness, insufficient-provider, higher-education cohort, and pay-for-performance situations. The Local Area should document why a contract is legally permitted and programmatically appropriate before procurement.
What remains relevant
- Training contracts are an exception or alternative authorized by specific WIOA provisions, not a way to avoid ETPL or procurement rules.
- The Local Board should document the legal basis and business case for the contracting method.
- Competition, price reasonableness, performance, and contract monitoring still apply.
- Provider/program eligibility must be evaluated under current rules where applicable.
Use current rules for implementation. WSD25-02 is California’s current ETPL directive, and current Uniform Guidance and local procurement rules supersede older thresholds or procedural details in this legacy directive.
Source basis
Primary source: EDD WSD13-13 — Contracts with Higher Education or Eligible Training Providers