Performance Accountability. in the World of WIOA. Introduction. Why Are We Talking about WIOA? implementation Where We Are: WIOA Regulations

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1 Performance Accountability in the World of WIOA Why Are We Talking about WIOA? WIOA Signed into law July 2014 WIOA Replaces Workforce Investment Act & Includes 6 Programs Title I Adult, Dislocated Worker, Youth Title II Adult Education & Family Literacy Title III Wagner Peyser Title IV Vocational Rehabilitation JVSG has historically largely followed Wagner Peyser Used Common Measures Included in Labor Exchange Reporting System DOL indicated this would be the case again DOL is including other workforce programs under its purview in this performance related streamlining effort, included the JVSG... 3 Introduction WIOA brings Massive Changes Even for Jobs for Veterans State Grants (JVSG) Changes in Key Accountability Concepts Participant Exit Exclusions Replaces Existing Common Measures Creates Significant new Reporting Requirements Will likely impact target setting & negotiations Still include Unknowns, particularly regarding implementation Where We Are: WIOA Regulations WIOA Required Draft Regulations by April 2015 DOL & ED timely published pages of proposed regulations for 60 Day Comment Period Nearly 2900 sets of comments submitted Final Regulations Issued Required January 2016, but not issued until June 2016 Final Package 4100 pages in length Preamble Estimated Impact/Cost Comments & Responses Regulations Complete/Final? Numerous instances of promises to Issue Further Guidance 2 4

2 Where We Are: Reporting WIOA Required Joint Reporting Specifications by July 2015 July 2015 draft published for 60 Day Comment Period, receiving 112 Sets of Comments April nd draft published for 30 Day Comment Period, receiving unknown # of comments June 2016 Final Joint Specifications published DOL specific Reporting Specifications had no due date September 2015 draft published for 60 Day Comment Period, receiving 68 sets of comments April 2016 published April 2016 for 30 Day Comment Period receiving unknown sets of comments June 2016 Final DOL Specifications Published Both Sets indicate more Guidance to Come There are also some mistakes to be Corrected 5 Take a Look at the Data Page 1 New WIOA Definition of Participant Reduces Numbers In PY14, System Served 626K Veterans Under WIOA, no more than 388K count as Participants Range from 20 99% 62% Nationwide DOL solves this by creating Reportable Individual concept Keeps Numbers Served High, but Reduces Accountability Loss of Lack of SSN Exclusion an Issue for Some Nationwide.78% of Veteran Participants & 1.36% DVOP Served Some states considerably higher Lack of SSN means outcomes can only be reported using follow up 7 Key WIOA Accountability Changes Definition of Who Is Participant Those Receiving Self Service Only are Excluded Those Receiving Information Only are Excluded Readily available information that does not require an assessment by a staff member of the individual s skills, education, or career objectives Probably doesn t impact JVSG When Exit Occurs Self & Information Service does not Extend Participation This could/should affect JVSG Exclusions Lack of a Valid SSN No Longer Excludes Participants Other Exclusions Unchanged Institutionalization Health/Medical Treatment Death Recall to Active Duty 6 New Common Measures WIOA brought 2 sets of new Common Measures One for Title I Youth One for Everything Else Wagner Peyser (& thus JVSG) use Employed 2 nd Quarter (Quarter) Post Exit Median Earnings 2 nd Quarter Post Exit Employed 4 th Quarter Post Exit Effectiveness of Service To Employers (Not clear how this would work for JVSG) This was a Missed Opportunity Difference between Youth & NonYouth Measures is counting of Enrollment in Education Why is going back to school Good for a 22 or 24 year old, but not a 25 or 30 year old? 8

3 Origin of New Common Measures Integrated Performance Initiative (IPI) DOL funded grant from 2004 Led by Washington State Included a number of states & National Governors Association Goal to Develop Measures Acceptable to WF, K 12, & Post Secondary Education Championed by NGA in all WIA Reauthorization drafts Ultimately adopted with few changes 9 Employment Rate Quarter 4 (Q4) Employed 4 th Quarter Post Exit Uses state UI Wage Records & Other Records of Employment Includes ALL Participants Not a Subset of those Employed Q2 Not a Retention measure Nothing other than it s easy to track Adds 1 Quarter of Lag to the Measurement Period Meaningless Measure Counts those not employed Q1 3 Post Exit if Employed Q4 You may want to track Retention of those Employed Q2 who are still employed Q3&4 as more meaningful 11 Employment Rate Quarter 2 (Q2) Employed 2 nd Quarter Post Exit Uses state UI Wage Records & Other Records of Employment Essentially Replaces Entered Employment Includes ALL Participants, not just Unemployed Picks up instances where we help an employed person get a 2 nd Job Counts employed people looking for new/2 nd jobs even if they stay employed at old job Adds 1 Quarter of Lag to the Measurement Period Minimize Affect of Added Lag by Running Data on Employed Q1 ~90% of those Employed Q1 are also Employed Q2 (Data Page 1) Take a Look at the Data Page 2 National Veterans Entered Employment 56.89% 307K in Numerator & 540K in Denominator National Veterans Employed Q % 287K in Numerator & 472K in Denominator National DVOP Entered Employment 58.07% 69K in Numerator & 119K in Denominator National DVOP Employed Q % 93.7K in Numerator & 154.6K in Denominator Texas Veterans Retention 86.82% 74.9K in Numerator & 86.2K in Denominator Texas Veterans Employed Q % 64.3K in Numerator & 95.9K in Denominator 10 12

4 Median Wages 2 nd Quarter Post Exit (All) Essentially Replaces Average Earnings Shorter Lag than old Average Earnings (2 nd Quarter vs. 2 nd & 3 rd ) Median reduces influence of outliers Better for smaller populations such as individual offices or staff Harder to Statistically Model Smaller Numbers are less meaningful to Stakeholders Median Earnings in Q2 generally about half Average Earnings in Q2 & Q3 Potentially Problematic Will use state UI Wages Records AND Other Records of Employment This is a big change 13 Effectiveness Serving Employers (ESE) Undefined in Statute Secretaries required to consult with States, Locals, Employers, Stakeholders to develop Secretaries couldn t settle on anything Proposed 3 measures and directed states to select 2 to pilot Having National Measures of Effectiveness Serving Employers Applying measures across programs rather than separately DOL & ED also referring to this as Employer Satisfaction Problems with all 3 proposed measures Not clear how they can be applied for LVER 15 Look at the Data Page 3 National Veterans Average Earnings $17,503 Includes 447K Veterans National Veterans Median Earnings $6,086 Includes 404K Veterans National DVOP Average Earnings $16,424 Includes 94.6K DVOP served National DVOP Median Earnings $6,074 Includes 117.6K DVOP served Why are the numbers so different???? Difference is not Just 2 Quarters vs. 1 Difference is 3 Quarters of Employment vs. 1 ESE #1 Market Penetration % of Employers Served Denominator Total # of Establishments Numerator # of Establishments that received service Employer Information & Support Services Workforce Recruitment Assistance Strategic Planning/Economic Development Activities Untapped Labor Pool Activities Training Services (including Incumbent Worker Training) Rapid Response/Business Downsizing Assistance Problems Which Services are Most Meaningful? Which are Easiest to Get Credit For? 14 16

5 ESE #2 Repeat Business % of Employers Served that are Repeat Customers Denominator Total # of Establishments Receiving Service at any time in last 3 years Numerator # of Establishments that received service this year AND at any time in the last 3 years Same Services as Market Penetration Problems Creates a Disincentive to Serve Smaller Employers >93% of Employer Served with 100+ Employees were repeat customers >75% of Employers Served with Employees were repeat customers <60% of Employers Served with <10 Employees were repeat customers Creates a Disincentive to Serve New Employers Denominator includes anyone served this year, even if for 1 st time Numerator does not include those served twice in the current year 17 Participant Individual Record Layout PIRL (ETA 9070) replaces LERS & WISRD files YOU NEED TO REVIEW IT LERS Required 91 Elements Max for Wagner Peyser/JVSG PIRL Requires 135 LERS had 12 LVER Elements PIRL Has None DOL s LVER FAQ states that LVERs may Assess suitability for Referral Help connect Veteran & Employer Determine Need for Additional Services (requiring referral to other staff) Lack of LVER Elements prevents use of Retention with Same Employer from being used as a national LVER measure 19 ESE#3 Retention with Same Employer Looks at Employers in Q2 and Q4 to confirm match Denominator Those Employed Q2 Numerator Those Employed Q4 at Same Employer as Q2 What if multiple Employers in Q2 and Q4? Assumedly any match counts Primarily be based on state UI Wage Records Will likely consider Other Records of Employment Could have been an amazing measure Would have allowed system to compare retention of our job seekers with all employees at an employer or industry Counts people who don t get new jobs Exit based instead of based on quarter of new hire Effectively anywhere from 3 Quarters to 5 Quarters of Retention 18 Barriers to Employment WIOA requires reporting detailed information on Barriers to Employment on ALL Participants Displaced Homemakers Low income individuals Indians, Alaska Natives, and Native Hawaiians Individuals with disabilities Older individuals Ex offenders Homeless individuals Youth who are in or have aged out of the foster care system Individuals who are English language learners, individuals who have low levels of literacy, and individuals facing substantial cultural barriers Eligible migrant and seasonal farmworkers Individuals within 2 years of exhausting lifetime eligibility under part A of title IV of the Social Security Act Single parents (including single pregnant women) Long term unemployed individuals Other groups identified by the Governor 20

6 How will the Transition Occur? DOL ETA just concluded negotiations on Title I & Title III Targets for Program Year (PY) 16 PY16 Will include those who Exited Prior to PY16 JUST LIKE TRANSITION TO ORIGINAL COMMON MEASURES 10 YEARS AGO Employed Q2 includes July 2015 June 2016 Exiters Median Earnings Q2 includes July 2015 June 2016 Exiters Employed Q4 includes Jan 2015 Dec 2015 Exiters DOL Developed & Used Statistical Models in their Negotiations Those Models depend on the Participant level data submitted by States Serving High % with Barriers to Employment will Reduce Targets Fail to Document Barrier? Likely Have Higher Targets DOL VETS has not published their Accountability Plans 21 So When Does Accountability Kick In? Can t be Sure DOL ETA Negotiated for PY16 & PY17 but then said Accountability only applies to those Exiting on/after 7/1/16 If DOL VETS takes similar Approach, PY17 would be the 1 st year with 7/1/16+ exiters: PY17 Employed Q2 includes July 2016 June 2017 Exiters PY17 Median Earnings Q2 includes July 2016 June 2017 Exiters PY17 Employed Q4 includes Jan 2016 Dec 2016 Exiters Accountable for half? This would mean we might be serving the 1 st People included in WIOA based measures NOW 23 Absent DOL Guidance... Let s Guess Pre WIOA, DOL VETS used a variety of measures Most recently primarily applied Common Measures to all Veterans, Disabled Veterans & DVOP Served Veterans Reasonable to Assume they will do so again Pre WIOA, DOL VETS trying to develop LVER measures Reasonable to Assume they will continue to try to do so Pre WIOA, DOL expected 90% of DVOP served Veterans to receive Intensive Services Reasonable to Assume they will continue to do so Didn t Intensive Services go away? Only by Name. Old Intensive Services Still Listed under WIOA 134(c)(2)(A)(xii) Now Called Individualized Career Services Uniform National Threshold Entered Employment Rate? Probably not going away for a while since defined by Regulation, not Guidance 22 Conclusion WIOA brings Massive Changes Even for JVSG Changes in Key Accountability Concepts Participant Exit Exclusions Replaces Existing Common Measures Creates Significant new Reporting Requirements Will likely impact target setting & negotiations Still include Unknowns, particularly regarding implementation Additional Resources: regs joint final rule.pdf 24