Invitation to Comment on Implementation of Title II of WIOA

(Updated Below)

The U.S. Department of Education’s Office of Career, Technical, and Adult Education (OCTAE) is providing the public with an opportunity to kvetch and complain —I mean, submit comments and recommendations—regarding the implementation of the new Workforce Innovation and Opportunity Act (WIOA), signed by President Obama in July. Specifically, the new version of the Adult Education and Family Literacy Act (AEFLA) in Title II.

According to OCTAE, “your input can help us identify issues and concerns that we need to address in order to fulfill the expectations of WIOA, particularly as we develop draft regulations for public comment.” They’ve listed a few specific issues they are interested in hearing about, but you can comment on anything you like. In fact, I usually think it’s best not to necessarily let OCTAE be the one to frame the discussion about their activities.

It is a pretty good list, though:

  1. In issuing definitions of performance indicators under Section 116, what should be considered in regulation or guidance when applying these indicators to adult education participants? How can the use of “measurable skill gain” best support services to low-skilled and limited English proficient individuals?
  2. WIOA emphasizes the importance of connecting job seekers and workers with the needs of employers and the regional economy. States will be required to report on their effectiveness in serving employers. What factors should OCTAE consider when defining how adult education and literacy programs may effectively serve employers?
  3. WIOA requires states to implement adult education content standards that are aligned to their standards under Title I of the Elementary and Secondary Education Act of 1965. What are the timeline and implementation issues that should be considered in supporting this requirement?
  4. AEFLA adds new activities to adult education and literacy services, including integrated education and training and workforce preparation. What should be considered in regulation or guidance on these new activities?

Someone representing local programs asked me earlier today if I thought it was worth their while to submit comments now, or to wait to respond to the draft regulations. I think it’s definitely worth submitting comments now. Comments on the draft regulations will also be important, but just like with legislation, it’s best to let drafters know what your biggest questions/concerns are *before* anything is drafted. It’s been my experience that the further you are along a bureaucratic process, the harder it is to change things. Once drafted, whatever is in those regulations will likely set the parameters of the discussion/debate more narrowly—it may be harder, for example, to add something that’s missing at that stage.

Another way to think of it is this: if folks at the local level don’t submit comments, then we are all relying on the comments submitted by the big national policy shops—who surely will be weighing in heavily on this. While I’m not suggesting that they won’t necessarily submit good recommendations, those groups typically don’t have to worry about actually implementing any of their proposals. It’s the folks on the ground who are going to have to live with the policies and regulations that are produced. So I’d strongly encourage local folks to get into the discussion early and often.

Not a ton of time though: comments are due by Friday, August 29th – roughly between the time almost everyone is on vacation and when they come back.

Again, here is the link to the invitation:

Invitation to Comment on Implementation of Title II and Title IV of the Workforce Innovation and Opportunity Act | Office of Career, Technical, and Adult Education.

UPDATE 8/13/14 2:30pm: Added the due date. Made title shorter.