Policy Issuances Questions and Answers
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Q & A Policy Issuance 05-74
Title I Eligibility Requirements (Revised)
Issuance
Q Currently, we have a customer who has provided a Naturalization document and has requested services through WIA Title I. We ran his name, social security number and date of birth through “sss.gov.” (Selective Service System), and it indicated that he has not registered for the draft. Policy 05-74 reads as follows:

“(B) Males not born in the United States, whose birth date is on or after
January 1, 1960 and who entered the U.S. before their 26th birthday must have registered with the Selective Service System (must be able to document their date of entry and date of birth). Since a foreign born male who enters the U.S. as a student attending school on a full-time basis is not required to register with Selective Service, verification of the individual’s F1 Student Visa status when he was between the ages of 18-26 would be sufficient.

For non-U.S. born customers presentation of either a Certificate of Naturalization form or a valid United States Passport will indicate that an individual has met all Selective Service requirements, as Selective Service compliance is also a requirement of the naturalization process.”

• Does the policy intend to state that we are not compelled to check draft registration and simply document possession of a U.S. Passport or Naturalization form?
• Does the fact that the Selective Service System cannot verify compliance indicate a discrepancy?
• Is it possible that the registration for the draft is documented differently for non-citizens who are
  naturalized and does not get recorded through the Selective Service System?
A WIA Communication 05-74 provides guidance with regard to acceptable documentation for determining a customer’s eligibility for One-top Career Center services under Title I of the Workforce Investment Act. Nothing in the Communication either limits or waives the requirement that males of certain ages must provide proof that they are in compliance with, or are not subject to the requirement to register with the Selective Service System in order to access Title I services. In order to make such a determination for non-U.S. born males, One-Stop Career Center staff should first check with the Selective Service System, directly. If the search with the Selective Service System does not provide the necessary confirmation of compliance, other acceptable methods of documenting the individual’s compliance would be to determine if the individual possesses a valid Certificate of Naturalization form or a valid United States Passport. As the process of obtaining U.S. citizenship for all males of certain ages requires proof of compliance with all Selective Service requirements, possession of either document by a non-U.S. born male is sufficient evidence of said compliance.

It is beyond the scope of the policy as iterated in WIA Communication 05-74 whether or not the inability to confirm an individual’s compliance with the Selective Service registration requirements through a Selective Service System (sss.gov.) search indicates a discrepancy or that compliance is recorded through an alternate means. The policy sufficiently describes the forms of documentation that are acceptable in order to determine an individual’s compliance with the Selective Service registration requirements.