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.

WIA/WIOA Update

I generally don’t have the time or inclination to post updates on legislative action with any kind of consistency—choosing instead to pick and choose, looking for spots where I think I might have a unique and/or possibly even interesting take on something. Presumably, loyal readers of this site have other, more reliable sources for regular legislative updates. But since I’ve written a lot about the reauthorization of the Workforce Investment Act (now retitled, with more modern-sounding buzzwords, as the Workforce Innovation and Opportunity Act, or WIOA)—most recently here—I thought I should mention that the WIOA bill which passed the Senate last month is scheduled for a vote in the House on Wednesday or Thursday of this week. The House is considering WIOA under a fast-track process known as suspension of the rules: no more than 40 minutes of debate, and no amendments will be offered. However, two-thirds of members will have to vote for the bill for it to pass.

This is not that unusual a move—it usually means that the House leadership is confident that the bill has the votes and time for lengthy debate/opportunity for amendment is not needed.

In talking with people in the adult education field, I’ve found that the level of interest/knowledge/excitement over WIOA tends to be lower than it is among policy people in Washington, D.C. I’d be interested to hear what folks on the ground in adult education (teachers, program directors, students) think the new bill will do for them.

Diversion of the Day: 1980s Ad Council PSA on Adult Literacy

A Dailymotion user has posted one of the old 1980s Ad Council adult literacy PSAs.

http://www.dailymotion.com/embed/video/x1vo5co?autoplay=1&logo=0&hideInfos=0&start=0&syndication=125600&foreground=&highlight=&background

 

For those interested, here is a little bit of the history behind this campaign:

The [Coalition for Literacy]’s media campaign was officially launched in a press conference held on 12 December 1984 in the Trustees Room of the New York Public Library. The Advertising Council (sponsors of “Smokey the Bear,” “Take a Bite Out of Crime,” and “A Mind Is A Terrible ThingToWaste”) coordinated the media campaign. They recruited the advertising agency of D’Arcy, Masius, Benton & Bowles/Worldwide as volunteers to develop the print and nonprint ads. Two advertising campaign strategies were developed—one to inform and appeal to the general public and the other to raise the awareness of the corporate sector. The theme that was chosen for the general public ads was “Volunteer Against Adult Literacy: The Only Degree You Need is a Degree of Caring.” The audience was identified as those who wanted to become volunteers to help another person learn to read. The advertising theme developed to appeal to the corporate sector [was]: “Volunteer Against Illiteracy: A Literate America is a Good Investment.” This audience is encouraged to bring corporate/private sector resources to assist national and local literacy activities.

The Advertising Council conducted studies to measure the awareness of communities about adult illiteracy before and after releasing the television and print ads. The campaign is now among the top five social awareness campaigns that the council coordinates. Within the first year of the coalition’s advertising campaign, the Ad Council indicators cite that awareness of adult illiteracy has jumped from 21 to 30 percent. The print, radio, and television media have contributed an estimated value of $20 million in advertising space and time to the coalition’s campaign.

—Jean Ellen Coleman, “ALA’s Role in Adult and Literacy Education, “Library Trends (Fall 1986) 207-17.

It’s interesting to read about the corporate messaging strategy—pretty much the same messaging we use today.

College Attainment and Skills

This article on the literacy skills of Canadian college graduates is another reminder that unless the PIAAC literacy assessment was fundamentally flawed, educational attainment isn’t a particularly reliable proxy for skills these days.