6.4 Records Management


R1. Safeguarding Personally Identifiable Information (PII) by Admissions Counselors (ACs)

a. Providers of enrollment services must ensure that PII gathered during the admissions process is protected at all times.  ACs must adhere to the following guidelines:

1. ACs must not use personally owned or public computers to download or store protected PII.

2. ACs must only access and store student protected PII using the CDSS Suite of Applications.

3. E-mail containing any PII is not allowed outside the jobcorps.org domain.

4. Approved encryption must be used to encrypt data that is moved to a portable device like a thumb drive, or Compact Disk (CD).

5. Any missing documents or equipment that contains Protected PII must be immediately reported to the Information Technology (IT) Point of Contact (POC) and the Job Corps Technical Assistance Center.

6. When not in use, documents containing PII must be stored in locked file drawers or a secured room.

7. All documents containing PII must be immediately retrieved from printers, copiers and fax machines as soon as they are printed or received, including the originals.

8. Sensitive documents must be properly disposed of by shredding or placing them in a locked recycling bin, and never placed intact in a trashcan or open recycling bin.

9. Any kind of PII that may have been left by others, or any PII incidents that staff observe should be reported immediately.

b. Should circumstances necessitate that PII is taken outside of the Outreach and Admissions (OA) office, ACs must adhere to the following guidelines:

1. ACs must not take any personally identifiable information belonging to Job Corps applicants, students or graduates off-site unless explicit approval is received from the OA manager. This applies to all forms of PII, whether in paper form such as student documents and files, or electronic form such as CDs, thumb drives, portable hard-drives or laptops.

2. ACs must keep PII in his or her possession at all times during transit.

3. PII must not be left unattended in a vehicle; this includes any papers, document holders, briefcase, and/or any information on a CD, hard-drive or laptop.

4. PII must not be stored off-site (for example, at home) unless it can be stored securely such as in a locked filing cabinet or safe.

R2. Collection and Handling of Education-Related Information and Documents by ACs

ACs must:

a. Collect, maintain, and transmit education-related information and documents as follows:

1.​ Include copies of one or more of the records in the list below, if available, in the applicant’s file:

(a) An official school transcript with the school’s seal affixed. If the applicant states that he or she has a High School Equivalency (HSE) credential, a copy of the HSE certificate or official HSE test scores.

(b) A copy of an acceptable High School Diploma (HSD) or official high school transcripts indicating graduation, if the applicant states that he or she completed the 12th grade and obtained a diploma. An acceptable diploma is one described in Criterion 6, Educational and Training Needs, in Exhibit 1-1, Eligibility Requirements.

(c) ​​May indicate in an applicant’s records that the applicant has a HSD only after receiving a copy of one or more of the following documents:

(1) A regular/standard HSD

(2) An honors diploma

(3) An Individual Education Plan (IEP)/special education diploma

(4) Official transcripts indicating graduation from a school that meets the guidelines set in Appendix 302, Guidelines for the Accreditation of Job Corps High School Programs

(5) A foreign diploma

2.​ When filing, storing, and transmitting IEP, Section 504 plans, IEP/special education diplomas, similar documents, or any documents indicating that a particular applicant has such documents, strictly comply with the following legal requirements related to medical and disability-related information, as explained in Appendix 202, Transmission, Storage, and Confidentiality of Medical, Health, and Disability-Related Information​:

(a) Place these records in separate “health records” files that are kept and stored separately from all other information about the individual applicant until the records are sent to the center.

(b) Carefully limit access to these documents. Appendix 202, Transmission, Storage, and Confidentiality of Medical, Health, and Disability-Related Information, explains what categories of persons are legally authorized to have access to the documents.

(c) Transmit hard copies of the documents in sealed envelopes in accordance with Appendix 202, Transmission, Storage, and Confidentiality of Medical, Health, and Disability-Related Information. Make the best effort to ensure that the copies are delivered only to persons who are authorized to have access to those specific types of documents.

b. If the applicant has not provided copies of the required official records, contact the appropriate state HSE Administrator (see Exhibit 1-1, Eligibility Requirements, Criterion 6. Educational and Training Needs), or the last high school the applicant attended; send the administrator or school a Records Release Authorization (Form 1-02), signed by the applicant or his or her parent or guardian, requesting that the required official records be delivered to the OA office or Job Corps center.

c. Before an applicant departs for his or her center of assignment, ensure that the center has received either the official records listed above, or documentation of the official request. This documentation must include contact information for the HSE Administrator or school from which the records have been requested.

R3. Collection and Handling of Health-Related Information and Documents by ACs

ACs must:

a. Use the Job Corps Health Questionnaire (ETA 6-53) to collect health information about the applicant offered enrollment, along with any medically connected documentation, as described in the instructions for the Job Corps Health Questionnaire (ETA 6-53).

b. Forward the originals of the Job Corps Health Questionnaire (ETA 6-53) of the applicant offered enrollment, and all documentation that has been collected, to the center of assignment. These documents must be forwarded in envelopes or files that are sealed and kept separate from any other information about the applicant offered enrollment.

c. For applicants who are not offered enrollment, retain copies of the Job Corps Health Questionnaire (ETA 6-53), and all related documentation that has been collected, in a file that is stored separately from any other information about the applicant. The Job Corps Health Questionnaire (ETA 6-53), the related documentation, and all other medical or disability-related information about the applicant must be kept confidential, and access to this information must be strictly limited to persons with a need to know, as described in Appendix 202, Transmission, Storage and Confidentiality of Medical, Health and Disability-Related Information.

OA agencies may retain copies of the ETA 652, Job Corps Reasonable Accommodation Request Form-Admissions (Form 1-06)​, applicant folder cover sheet, folder inventory, alternate contact sheet and a copy of documentation showing proof of low income eligibility. With the exception of Form 1-06, Job Corps Reasonable Accommodation Request Form-Admissions, copies of these documents may be filed electronically.

R4. Documentation by ACs

ACs must:

a. Enter all information involving applicant eligibility criteria in the Outreach and Admissions Student Input System (OASIS) in accordance with the procedures specified in the OASIS documentation and Regional Office procedures.

b. Use the procedures described in Exhibit 1-1, Eligibility Requirements, to verify, assess, and document information relating to applicant eligibility criteria.

c. Use the procedures described in Exhibit 1-1, Criterion 12, to provide documentation to Job Corps centers for their use in assessing applicants’ health needs.

R5. Applicant Files

OA contractors must ensure that OASIS files are available to the center of assignment and that hard copy documents are available to the center at least 7 working days prior to each applicant’s scheduled arrival at the center, or departure to the center, if using government-furnished transportation.

R6. Withdrawal of Application

If an applicant withdraws his or her application, or an applicant offered enrollment chooses not to enroll, all supporting documentation should be maintained with the central file, and returned to the OA agency if the application is not in regional review. If the application is in regional review, then the applicant file and all supporting documentation must be returned to the Regional Office who will review the documentation of the withdrawal before returning the file to OA. Files must be maintained for a minimum of 3 years from the end of the applicable program year. Health and disability-related documentation must be maintained in a separate file to which access is strictly limited, as described in Appendix 202, Transmission, Storage and Confidentiality of Medical, Health and Disability-Related Information.

R7. Electronic Training Achievement Record (e-TAR) Recordkeeping

Centers must:

a. Ensure Career Technical Training (CTT) instructors record skill proficiency by rating the appropriate skills area on the e-TAR. This action (i.e., recording a rating level) represents verification to the student of skill attainment. The date entered does not necessarily indicate when the student completed the task. The date indicates the instructor’s assertion of skill proficiency, documenting that the student is able to perform the task to industry standards with little or no supervision. The student does not need to be present for duty in order for the instructor to perform the data entry process.

b. Centers must ensure that all students’ test results and progress are documented on approved e-TARs including credential attainment results.

c. Provide a copy of one or more of the following: credential attainment certificate, and/or e-mail/electronic notification of pass/fail results from credential issuing party.  This can be a hard copy in a student’s permanent records file or uploaded into the e-TAR system.

R8. e-TAR Student Portal Access

Students will use the Student Portal to access their e-TAR and check off the student acknowledgement box. This allows the student to stay informed of his/her progress. This is for information only. This does not impact the completion status or closing out of the e-TAR.

R9. Student Testing System Reporting/Documentation/Recordkeeping 

Centers must:

a. Ensure all students’ reading and mathematics test results and progress are documented and recorded using the automated Student Testing System (STS) of the Center Information System (CIS). 

b. Document student academic progress as described in the center’s CDSS Plan that is referred to in Chapter 5, Section 5.1, R8.

R10. High School Equivalency (HSE) and High School Diploma (HSD) Reporting/Documentation/Recordkeeping

Centers must record information on students’ HSE and high school diploma achievement while on center in the Center Information System (CIS), and maintain the appropriate supporting documentation in the students’ permanent Job Corps files.

a. HSD/HSE Completion Reporting

1. The HSE completion date recorded in CIS will be the date on the student’s HSE certificate, if available.  If the HSE certificate cannot be obtained prior to a student’s separation, the center can enter the date of the student’s last HSE test on the official notification from the HSE testing center indicating the student has passed the HSE assessment.

2. The official high school diploma completion date recorded in CIS will be the date on a student’s diploma. If the high school diploma is not available at the time of a student’s separation, the center can enter either: the date of the official letter from the diploma-granting institution indicating the student has met all the requirements for graduation and will be issued a diploma at a later date; or the date on the student’s official high school transcripts indicating graduation.

b. HSD/HSE Final Documentation

1. Copies of the HSE certificates or official HSE scores must be included in students’ permanent files.

2. Copies of high school diplomas students earned while on center, final high school transcripts, and supporting documentation on special education services, as applicable for students with documented disabilities, must be included in students’ permanent files.

c. HSD/HSE Progress Reporting and Documentation

1. Copies of students’ HSE practice test results (paper answer sheets, or reports generated by official practice test software, or Testing Management System (TMS) reports) will be maintained by centers required by the states in which they are located to show documentation of official practice test results prior to students taking HSE exams.

2. Centers must record students’ test scores in each HSE content area in CIS, as written confirmation is received from the testing center. Scores recorded in CIS must be updated to record higher test scores that students may obtain in retests, as needed, in each content area.

3. Students’ progress in their HSD and HSE must be documented in the students’ Pathway Achievement Record (PAR).

R11. General Reporting/Documentation/Recordkeeping in CIS

Centers must document and record in CIS, all student:

a. Concurrent Training progress (Approved alternate and additional forms of documentation must be included in the student’s permanent records upon separation.)

b. Work-Based Learning (WBL) assignment and progress (WBL Module)

c. Leadership training/student government participation

d. Driver’s education progress and test results

e. Provision for water safety instruction and swimming proficiency

f. Wellness training progress and accomplishments

g. English Language Learner (ELL)/Limited English Proficiency (LEP) test results and progress in the student’s Personal Career Development Plan and other applicable modules of CIS

R12. Counseling Reporting/Documentation/Recordkeeping

Centers must:

a. Ensure that counselors maintain a record of individual counseling sessions to include, at a minimum, the following information:

1. The reason for such session

2. An assessment

3. A plan of action with appropriate follow-up

b. Implement safeguards to assure that personal information about individual students, subject to the Privacy Act, is shared among staff only to the extent necessary to ensure the safety and effective provision of services to students, and no further, in accordance with Chapter 6, Appendix 601 (Student Rights to Privacy and Disclosure of Information). Personal counseling records must be treated as confidential documents.

c. Advise students regarding counselors’ responsibilities for safeguarding confidentiality and for disclosing information that is legally required or that may represent a threat to the student or others.

d. Monitor, on a monthly basis, the accuracy of records and data that students enter in their MyPACE Career Plans and PAR. Document changes and updates to these plans and record in Case Notes​.

R13. Fact-Finding Board Reporting/Documentation/Recordkeeping

a. Regardless of the outcome of the Fact-Finding Board, centers must ensure that documentation is retained on center and is available for auditing for at least three years, consistent with other recordkeeping responsibilities.

b. Centers must ensure that all student incentives, infractions, and sanctions are documented and recorded using CIS.  This includes documenting the date of the Fact-Finding Board, the disposition, and in the case of Level II Fact-Finding Board, a rationale if the Board’s recommendation is not upheld.

R14. Clothing Documentation

Centers must maintain records and receipts in each student’s personnel file for each clothing purchase. Such records must include a signed receipt for all clothing allowances issued to the student.

R15. Community Living (Residential) Reporting/Documentation/Recordkeeping

Center operators must:

a. Develop procedures to record important information about student-related events as the events occur and to transmit the information from each shift to the next. 

b. Maintain individual records for each student that contain, at a minimum, basic identifying information, including emergency contacts, and written parental consent (minors) for weekend passes to approved destinations. Such records must be readily accessible to dormitory staff.

R16. Records System

Centers must develop and maintain a uniform records system to accurately document and regularly update the following types of information, services, and accomplishments for each student during enrollment, as specified in the designated chapter:

Administrative Records (enrollment data, allowances and allotments, leaves and absences, and case notes) Chapter 6

Career Preparation Period and Career Development Period Records - Chapter 6

Health History and Services - Chapter 2

Personal and Social Development Records (including Fact-Finding Board documentation) - Chapter 2, Chapter 6

Career Transition Services Information - Chapter 4

R17. Student Personnel File

Centers must maintain for each student throughout enrollment a personnel file, which must include the following documents:

a. Folder Inventory Form

b. Student Job Corps Data Sheet (ETA 6-52)  and required enrollment forms (Note: Form generated through OASIS (Outreach and Admissions Student Input System).  For forms requiring signature, a signed copy shall be maintained in the student personnel file.)

c. Record of Issue/Spent Clothing Allowance

d. Designation of Beneficiary (SF 1152)

e. Zero Tolerance for Violence and Drugs Certification

f. All hard-copy verification documentation supporting pay and leave status, including parental pass consent for minors (Leave/Documentation and Case Notes). Leave requests must be maintained electronically in Center Information System (CIS).

g. Informed Consent to Receive Mental Health and Wellness Treatment

h. Equal Opportunity Notice (Form 1-09)

i. A hard copy of the My Pathway to Achieving Career Excellence (MyPACE) Career Plan (initial and all versions), justification statement if student changed career pathways during enrollment and a final Pathway Achievement Record (PAR). MyPACE Career Plan and PARs must also be stored electronically and uploaded in the CIS ​e-Folder.

R18. Separation

a. At the time of a student’s separation from Job Corps, centers must combine all necessary records pertaining to that student into a single record and store it in a central location on center.  Records of separated students must contain documents as specified below:

1. All records indicated in R17 above

2. Final Student Profile (ETA 6-40)

3. Health Record

4. Accommodation Record

5. Copy of official High School Equivalency (HSE) certificate or, if not applicable, passing scores, or high school diploma earned while in Job Corps including final high school transcript(s) (if the student earned their diplomas from a center accredited as a degree-conferring high school). Supporting documentation will also include special education services, as applicable for students with documented disabilities.

6. Notice of separation from CIS  

7. Training Achievement Record (TAR)

(a) For students who complete their program while using a paper TAR, the completed original TAR is required for the students’ permanent file.

(b) For students assigned to an e-TAR, e-TARs will be stored electronically and will be available through the Center Information System (CIS/CIS3G).

(c) The full e-TAR will be permanently stored in the data warehouse. In addition, as a contingency measure, centers will keep a hard copy of the e-TAR summary page in the student permanent record file and credential attainment results (refer to Chapter 6, Section 6.4, R.7.b. and c.).

8. Tests of Adult Basic Education (TABE) – Answer Sheets (when the TABE is not administered online) or the Student Testing System (STS) Tickets  

9. Fact-Finding Board documentation (whether result was termination or retention)

10. Unauthorized Absence CIS Case Notes

b. Provide a copy of the student’s Job Corps Consent for Release of Information as part of ETA Form 6-52 to the Career Transition Services Contractor within five working days of separation. Information from confidential files must not be released to Career Transition Services Contractors.

c. Maintain the permanent student record on center for at least three years, at which time it will be archived to the Federal Records Center, as directed by the Regional Office.

R19. Student Death

In the event of a student’s death, the center must follow Significant Incident Report (SIR) reporting requirements (see Chapter 5, Section 5.4) and send the entire student personnel record (including sealed health record) to the Office of Job Corps by signature-required mail or delivery within 10 days. The sealed health record must include Office of Worker’s Compensation Programs (OWCP) forms and written notification of death, plus the death certificate and autopsy and toxicology reports if available.

R20. Confidentiality of Student Records

Centers and Outreach and Admissions/Career Transition Services (OA/CTS) contractors must safeguard and ensure the confidentiality of student personal information contained in records, as well as verbal and written communications, in accordance with federal, state, and local law, and as specified in Appendix 601 (Student Rights to Privacy and Disclosure of Information) and Appendix 202 (Transmission, Storage, and Confidentiality of Medical, Health, and Disability-Related Information).

R21. Access to Student Records

Centers and OA/CTS contractors must provide students and parents/guardians of minors with access to their records on request. Access to medical records can be denied in accordance with the Notice of Medical Information Use, Disclosure, and Access (Form 2-01)​ and Authorization for Use and Disclosure of Your Health Information (Form 6-02​)​.

R22. Release of Information

Centers and OA/CTS providers must respond to requests from former students or third parties for information concerning their enrollments, upon receipt of a written, signed release of information, and in accordance with provisions of Chapter 5, Section 5.1, R31.c​ and Appendix 601. This shall apply as long as the center has custody of the record.

R23. Freedom of Information Act Requirements

Centers and OA/CTS contractors must respond to requests for disclosure of personal information about students in accordance with the Freedom of Information Act as specified in Appendix 601.

R24. Subpoenas for Student Records

Centers and OA/CTS contractors must forward all subpoenas to produce a student record, or to testify regarding a student record to the Regional Office.

R25. Records and Reports Maintenance

Center operators, agencies, and OA/CTS contractors must maintain records and reports for three years. Records of disclosures of protected health information shall be kept for three years. Exceptions to this retention period shall be communicated by the National Office of Job Corps on a case-by-case basis.

Form 1-02 Records Release Authorization
Form 1-06 Job Corps Reasonable Accommodation Request Form - Admissions
Form 1-09 Equal Opportunity Notice
Form 2-01 Notice of Medical Information Use Disclosure and Access
Form 5-08 Right to Use Photographic Likeness or Moving Images-Release Form for Adult Students
Form 5-09 Right to Use Photographic Likeness or Moving Images Release-Form for Minors
Form 6-02 Authorization for Use and Disclosure of Your Health Information
Exhibit 1-1 Job Corps Eligibility Requirements
Appendix 202 Transmission Storage and Confidentiality of Medical Health and Disability-Related Information
Appendix 302 Guidelines for the Accreditation of Job Corps High School Programs
Appendix 601 Student Rights to Privacy and Disclosure of Information