Source + trust record
Source checked as of September 18, 2026. Primary authority: EDD WSD15-09 and California’s current WIOA waiver directives.
Check result: EDD still lists WSD15-09 as active, but it is WIA-to-WIOA transition guidance explaining that former WIA waivers did not automatically carry into WIOA. It is not a source of new present-day waiver authority. Current operations must rely on current federal waiver approvals and California implementing directives, including WSD25-03 and WSD25-04 where applicable. 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 TRANSITION GUIDANCE | USE CURRENT WAIVER AUTHORITY | Program + Policy Leadership | Use current WIOA waiver directives for present operations | WIA-to-WIOA transition · Waivers · Historical compliance |
The bottom line
This directive explains how WIA-era waivers were treated during the transition to WIOA; it is not a source of new current waiver authority. For present operations, Local Boards should use California’s current WIOA waiver directives and applicable federal approvals.
Official source: EDD WSD15-09 — Impact of WIOA Implementation on Waivers Approved Under WIA
Active legacy guidance: WIA-era waivers did not automatically survive the transition to WIOA; current waivers must rest on WIOA authority and current approval
WSD15-09 addressed what happened to waivers approved under the former Workforce Investment Act as California transitioned to WIOA. EDD still lists the directive as active, but its practical value today is largely historical and interpretive: old WIA waivers should not be treated as continuing authority for current WIOA operations.
Active legacy guidance
Issued
November 20, 2015
Transition
WIA → WIOA
Issue
Legacy waivers
Use today
Historical authority check
Executive takeaway
Waiver authority is time- and statute-specific. A Local Board should rely on the current WIOA waiver approval and current California implementation guidance—not a pre-WIOA waiver or an assumption that a previous exception carried forward indefinitely.
What is still useful
- Understanding why certain WIA-era flexibilities ended during implementation.
- Tracing historical program decisions in monitoring or audit records.
- Reinforcing that current waivers need current statutory and DOL authority.
- Distinguishing baseline WIOA rules from temporary waiver flexibilities.
Use current waiver guidance for operations. For example, WSD25-03 and WSD25-04 govern current California WIOA waiver implementation for covered PY 2026-27 activities.
Source basis
Primary source: EDD WSD15-09 — Impact of WIOA Implementation on Waivers Approved Under WIA