WIOA

Going After the Scammers

/ The Old Crank

(Updated Below)

The New York Times story yesterday on the Workforce Investment Act is related to the post I published yesterday. I realize there are political and strategic challenges associated with calling out public officials when they make possibly disingenuous calls for more job training. But calling out scammers like those described in the Times should be much easier. They should not only be called out for what they are, but workforce development advocates should consider aggressive, proactive initiatives aimed at taking them down. It’s the best way to distance the good stuff from the scammers. Defensive responses—sure-these-guys-are-bad-but-look-at-all-the-good-things-that-WIA-does-and-it’s-not-my job-anyway-its’-the-states-and-being accountable-is-hard etc.—is probably not going to be good enough to stem the erosion in confidence that the presence of these outfits have on the whole system.

UPDATE 8/19/14 11:15 AM: By the way, I largely agree with my colleague Mary Alice McCarthy’s criticism of the Times article, (and would be foolish not too, as her knowledge of this subject is about as good as there is), and recommend anyone interested in the subject go read it. In particular, I think she’s right that the Times does not do nearly enough to make it clear that the student indebtedness problem has to do with problems in our higher education system, rather than WIA. And since that is the entire point of the article suggested in the headline and subheading—that WIA is leaving people in debt—that’s a pretty glaring mistake.

But I don’t think that this takes anything away from my point above. I don’t think the people scammed by Daymar College and their ilk really distinguish between our higher education system and our workforce development system, and I imagine that they would find debates about who is at fault to be something between irrelevant and irritating. They were out of work and needed help, and got screwed. In such cases the WIA system may not be at fault, but the entry point for these folks may have been WIA. I think workforce development advocates can do more than just say, ‘this is a higher education problem, not ours.’

Under both the old WIA and the new WIOA, one of the success measures for a program includes transitioning participants to postsecondary education and training. Clearly for the people profiled in the Times, that transition to postsecondary hasn’t worked out too well. So OK, not WIA’s fault. My point is that it might be a helpful for workforce proponents in general to do more to identify and do something about these terrible programs, whatever legislative authority it falls under. Of course, how to do so, I have no idea. (McCarthy suggests higher ed reformers look to the recently passed WIOA legislation as a model for higher education reform.) What do others think?

UPDATE 8/25/14: Bob Lanter, Executive Director of the California Workforce Association raises similar objections to the Times piece in this press release.

Invitation to Comment on Implementation of Title II of WIOA

/ The Old Crank

(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.

Funding Still an Issue

/ The Old Crank

Lauren Eyster, writing for the Urban Institute’s MetroTrends Blog, makes an important point about the WIOA bill that was passed by the House last night:

What WIOA does not do is return overall workforce development funding to pre-sequestration levels immediately. Funding would be increased annually until 2020, but states and local areas will continue to be asked to do more with less.

Gloomy as that sounds, this assessment is actually a bit on the optimistic side. The problem is not that the bill won’t restore workforce funding to pre-sequestration levels immediately, it’s that the WIOA bill itself will not restore funding to pre-sequestration levels at all (let alone increase funding significantly), despite those increases authorized in the bill, unless Congressional appropriators actually appropriate funding at those authorized amounts. And unless Congress raises the existing budget caps and eliminates the mandatory cuts under sequestration (which otherwise, don’t forget, will return in 2016) there isn’t much chance they will. If you’re a glutton for punishment, I wrote an excruciatingly long and tedious post about this a month ago.

I do think WIOA better positions advocates to make the case for increased federal funding, but prospects for increased funding for the programs covered under this bill will continue to be at the mercy of a Republican-dominated Congress for the foreseeable future—a Congress that, if anything, will press for further cuts to non-defense discretionary programs next year. (And remember also that there is a significant possibility that Republicans will control both chambers next year.)

The reason I’m being such a party pooper is because I think it’s important that folks on the ground who depend on the programs covered under WIOA are clear on this point. While the bill includes what many people feel are welcome policy changes to the federal workforce investment system, WIOA’s passage last night isn’t going to solve their biggest problem, which is the lack of adequate funding. I can’t speak for every program in WIOA, but for those of us in adult education, in particular, that remains our biggest challenge.