Since the Uniform Guidance is applicable to all contracts with federal funds, the TEGL suggests the advice relating to the one-stop operator competitive process may be useful to consider when procuring other program activities or services, including selection of a fiscal agent, or procuring elements of the youth program, career services, and/or training services.

1. LWIBs are encouraged to select providers of career services through a competitive procurement process, though WIOA law and proposed rules do not require this.
   1. LWIBs can provide basic and individualized career services by agreement of the local Chief Elected Official and Governor which can be obtained by submitting a Request for Approval – LWIB to Provide WIOA Career Services.
2. WIOA further stipulates that LWIBs cannot provide training services unless the LWIB submits a written waiver request based on satisfactory and demonstrable evidence to the Governor to waive the limitation in Section 107(g)(1). 
   1. The waiver request shall be made through submission of the Request for Approval – LWIB to Provide WIOA Adult and/or Dislocated Worker Training Services.
3. WIOA specified that one-stop operators must be in place by July 1, 2017, but there is no similar deadline requirement for other roles such as staff to the LWIB.
   1. The U.S. Department of Labor Regional Office for our state has suggested the LWIBs should first define the roles of the one-stop operator and issue the RFP. 
   2. RFPs should not be tailored based on the current or future functions of an applicant.
   3. This has the appearance of potentially influencing prospective bidders and setting up an unfair advantage to other potential entities wishing to apply.
   4. The LWIB or outside entity would need to ensure that appropriate firewalls and conflict of interest agreements are in place during the negotiation and selection phase of procurement.
   5. Since the one-stop operator should be procured and in place prior to determining staff to the LWIB, DOL has instructed the state to not address LWIB staffing questions during the procurement process time period. 
   6. LWIB staffing policy will be issued at a later date.