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«National Skills Coalition — a broad-based coalition of business leaders, union affiliates, education and training providers, community-based ...»

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National Skills Coalition Comments on

Workforce Innovation and Opportunity Act (WIOA)

Notices of Proposed Rulemaking (NPRMs)

May 2015

National Skills Coalition — a broad-based coalition of business leaders, union affiliates,

education and training providers, community-based organizations, and public workforce

agencies advocating for policies that invest in the skills of U.S. workers — is pleased to submit

the following comments regarding the Workforce Innovation and Opportunity Act (WIOA) Notice of Proposed Rulemaking (NPRM) RIN 1205-AB73 (Docket No. ETA-2015-0001), implementing Title I and Title III of WIOA; NPRM RIN 1205-AB74 (Docket No. ETA-2015-0002), “Joint Rule for Unified and Combined State Plans, Performance Accountability, and the OneStop System Joint Provisions,” and NPRM RIN 1830-AA22 (Docket No. ED-2015-OCTAE-0003), implementing programs and activities authorized under Title II of WIOA.

WIOA replaces the Workforce Investment Act of 1998 (WIA), and reflects the growing recognition that in order to adequately address the skills needs of workers, jobseekers, and employers, we must do a better job of coordinating across multiple education, training, and supportive services programs. WIOA calls for states to develop and implement state workforce plans that incorporate a broad range of federal and state investments, and establishes common performance measures across programs to facilitate greater alignment across systems.

WIOA reflects a workforce system that is constantly evolving and innovating to keep up with the demands of today’s labor market, incorporating proven best practices such as industry or sector partnerships to ensure that training investments are connected to the needs of local and regional industries, and career pathways models that help to ensure that individuals at all skill levels have meaningful opportunities to advance with those target industries. WIOA also updates and expands the allowable activities across the WIOA core programs to strengthen the emphasis on job-driven training strategies and other successful models.

National Skills Coalition strongly supports the vision and goals of WIOA, and we look forward to working with the Departments of Labor and Education — as well as other federal agencies responsible for administration of partner programs — to support the successful implementation of the law. The NPRMs released by the Departments in April 2015 are a critical step towards achieving that vision, and throughout our comments we note areas where we believe the draft rules are consistent with the statutory intent, as well as areas where we believe additional regulatory clarification or guidance may be needed.

Our comments are provided in three sections:

In the section on NPRM 1205-AB74, we provide comments on the proposed rules • relating to state unified and combined plans under new 20 CFR part 676 (and corresponding section under 34 CFR part 361 and part 463), and the performance accountability provisions at 20 CFR part 677 and corresponding sections under 34 CFR.

In our comments on NPRM RIN 1205-AB73, National Skills Coalition focuses on five key • issues under WIOA Title I: 1) the development and implementation of industry or sector partnerships; 2) the development and implementation of career pathways; 3) provisions implementing youth services under Title I-B; 4) the priority of service requirements set forth in WIOA section 134; and 5) the updated Eligible Training Provider List (ETPL) requirements Finally, in our comments for NPRM RIN 1830-AA22, we address the draft rules relating • to the Adult Education and Family Literacy Act under 34 CFR, with a particular focus on provisions relating to local workforce development board review of Title II applications, integrated education and training programs, and the definition of career pathways as part of English language acquisition programs.

1. National Skills Coalition Comments on NPRM RIN 1205-AB74 A. Unified and Combined Plans While WIOA largely retains the governance structure and program activities established under WIA, it makes a number of key changes intended to support greater alignment across federal workforce and education programs. One of the major changes under WIOA to support these alignment efforts is a requirement that states develop and submit “unified state plans” covering all core programs authorized under the law, rather than submitting separate plans for each program. The law also authorizes states to submit “combined” plans that could incorporate other federal workforce programs, including programs funded through the Temporary Assistance to Needy Families (TANF) block grant, and career and technical education programs funded under the Carl D. Perkins Act.

The new planning options under WIOA present a unique opportunity for states to strengthen integration between employment, training, and supportive services programs that have traditionally operated in silos. The increased coordination between core programs and other systems could have significant benefits for low-income and other hard-to-serve populations, who are often caught in the gaps when eligibility, performance, or funding requirements are not adequately aligned.

National Skills Coalition believes that the Departments’ proposed rules at 20 CFR 676 (and corresponding sections under 34 CFR) governing unified and combined state plans are largely consistent with these goals. We support the Departments’ inclusion of a “purposes” section at 20 CFR 676.100 that emphasizes the need for greater collaboration and coordination across systems, and in particular referencing the need to ensure that workforce and education investments support the needs of individuals with barriers to employment.





We offer two recommendations that we believe will support the legislative intent of WIOA:

The draft regulations at 20 CFR 676.105(d)(2), which implement the statutory language • at WIOA 102(b)(1)(E), specifically require that unified state plans include strategies for aligning the core programs with optional programs and other resources to support the state’s vision and goals. The term “optional programs” is not used in sec. 102(b)(1)(E), but from the context it is apparent that the Departments intended to refer to the programs described at sec. 103(a)(2) and proposed 20 CFR 676.140(d). National Skills Coalition strongly supports this language, which would help ensure that states engage in cross-program planning and alignment activities even in instances where the states do not choose to submit a formal combined plan. We would encourage the Departments to explicitly clarify this intent by amending proposed 676.105(d)(2) to include “as described in §676.140” after the words “optional programs.” The draft regulations at 20 CFR 676.140(e)(4) reiterate the statutory requirement that all • of the entities responsible for planning or administering a program described in a combined plan have a meaningful opportunity to review and comment on all portions of the plan. We believe this language could be strengthened to require assurances that all such entities have approved the inclusion of the program in a combined plan, especially where such programs do not fall under the direct control of a governor.

In addition to the specific recommendations above, National Skills Coalition notes that the NPRMs also make multiple references to “joint planning guidance” that will be issued by the Departments at an unspecified date, and which will provide additional instructions relating to the planning process and plan elements, particularly with respect to combined plans. We are concerned that some states may be waiting for definitive guidance from the agencies before beginning their planning processes in earnest, and that this may cause some states to bypass key opportunities for stakeholder engagement in an effort to meet the statutory deadlines for plan submission. This would undermine the alignment goals emphasized under the statute while also reducing access to services for jobseekers and businesses alike.

We encourage the Departments to issue the joint planning guidance as expeditiously as

possible, and to ensure that the guidance emphasizes the following:

Establishing an inclusive planning process. WIOA requires that states provide • opportunities for state agencies and other stakeholders to provide input and comments on the development of either unified or combined state plans. The joint planning guidance should clarify that all potential partner programs should be engaged in the development of the state’s strategic vision, regardless of whether the state opts to submit a unified plan or combined plan, and the Departments should consider emphasizing the opportunity to submit unified or combined plan modifications following submission of the initial plan to ensure that non-core programs continue to be engaged in the planning and implementation process. The joint planning guidance should provide recommendations for how states can develop appropriate outreach and engagement strategies for stakeholders, and documentation of input and comments provided by those stakeholders.

Cross-program alignment to support key strategies. Sector partnerships and career • pathways are proven strategies that align workforce, education, and other programs to create multiple entry points and advancement opportunities for job seekers, including low-income individuals. WIOA requires state and local workforce development boards to implement these proven strategies, but provides limited guidance around how noncore programs and services can be engaged to ensure that they are meeting the needs of target populations and industries. The joint planning guidance could highlight opportunities for alignment at both the state and local levels.

Encouraging common performance measures. WIOA establishes a set of primary • indicators of performance that apply across the core programs, including indicators relating to employment, median earnings, credential attainment, skills gains, and effectiveness in serving employers. States are required to submit proposed levels of performance for each indicator across the core programs as part of the state plan. WIOA does not establish indicators of performance for non-core programs, nor are states required to establish performance levels for such programs. States should be encouraged to apply the WIOA common measures to additional programs. Using consistent measures across additional programs will facilitate coordination across programs. In addition, in setting performance targets for additional programs, states should be encouraged to use statistical adjustments that take into account economic conditions and participant characteristics, such as the statistical adjustments for WIOA, when permissible under the statutes of other programs.

B. Data and Performance Accountability

WIOA contains a number of changes from WIA that will improve cross-program data and performance measurement that will help create a system of shared accountability across the core programs and perhaps beyond. These changes include establishing common performance indicators for the core programs and for training providers, common methods for establishing adjusted levels of performance, common requirements for performance reports, and steps to facilitate common data collection and data linking. Shared accountability recognizes that multiple programs often contribute to outcomes for participants and employers and that multiple programs should be given credit and held responsible for the outcomes. A focus on shared accountability not only reflects this reality, it incentivizes programs to work together to improve their mutual outcomes. The following comments on the NPRMs for performance accountability are offered in this context.

Definitions of “exit” and “participant.” Proposed § 677.150(c) defines the term ‘‘exit’’ • for “the purposes of performance accountability.” The definition of “exit” for the primary indicators of performance should be for a “shared” or “common” exit across WIOA — when a participant no longer receives a service from any of the 6 core programs except for follow-up and informational-only services. This definition of exit would support career pathways and other cross-program participation that can benefit participants. In order to properly implement such a definition, it is crucial for states to have performance management systems that can accurately track co-enrollment.



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