State vs. Local Policy Comparator

See which layer of authority controls a decision before a local practice accidentally becomes a State rule.

Core rule: California ETPL eligibility, any separate local ETPL decision, and participant ITA/training policy are different layers. The comparator labels those layers instead of blending them.

Authority legend

FEDERAL WIOA / 20 CFR / TEGL CALIFORNIA EDD directive / notice LOCAL adopted Local Board policy where permitted PRACTICE recommended workflow, not a rule

Decision	Primary authority	Local role	Watch out
Who may be an ETP / what is an eligible program?	FEDERAL + CALIFORNIA	Apply the State eligibility process assigned to Local Boards.	Do not invent a State eligibility criterion because it seems sensible locally.
Initial provider/program eligibility	CALIFORNIA within federal framework	Review assigned provider/program facts and make the Local Board California ETPL determination.	Provider and program review can belong to different Local Boards.
Continued eligibility / State performance rules	CALIFORNIA	Review current submission and performance under the State rules.	Do not substitute a local performance formula for the State decision.
Registered Apprenticeship ETPL eligibility	FEDERAL + CALIFORNIA	Support routing/listing; do not add ordinary local eligibility gates.	RAP listing, recruiting, and available apprenticeship capacity are separate questions.
Reciprocity	CALIFORNIA through approved agreements	Verify the exact agreement/provider/program and apply participant/local funding policy separately.	Another state’s ETP list is not blanket California permission.
Separate local ETPL standards	LOCAL only where lawful and adopted	Apply after, and separately from, the California ETPL eligibility determination.	Label the decision clearly so local criteria never contaminate State eligibility.
ITA amount/duration / local participant training policy	LOCAL within federal/State limits	Career-planning/fiscal/program decision, not the ETPL provider eligibility decision.	A program may be ETPL-eligible but not fundable for a particular participant.
Internal checklist / provider office hours / review sequence	PRACTICE	Design a reliable operating process.	Do not present a recommended workflow as a legal requirement.

Local policy review worksheet

1 · Identify

What local document controls?

Policy number/title, adoption date, revision date, board approval evidence, and current effective version.

2 · Classify

Which layer does each rule belong to?

State ETPL eligibility, separate local ETPL, participant ITA/training, monitoring, or merely internal procedure.

3 · Compare

Does local language conflict?

Flag local language that changes a State denominator, State appeal route, RAP rule, reporting requirement, or State reviewer assignment.

4 · Publish carefully

Show only verified local profiles

Workforce Wonkery should not display a local policy as authoritative until the current adopted version and approval status are verified.

Verified local-area profiles

v1 launch rule: California baseline is live first. Local-area profiles are added only after the current adopted local policy and approval evidence are verified. “No profile” means “not yet verified by Wonkery,” not “no local policy exists.”

Choose local layer

This prevents an outdated draft, agenda attachment, or superseded policy from being presented as current local authority.

Source basis

WSD25-02 State/local decision separation; TEGL 08-19 roles/responsibilities; WSD22-08 reciprocity; 20 CFR Part 680 training/ETP framework. Local profiles require separately verified adopted policies.