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As a coalition of
workforce development organizations, our comments will focus on how to
improve the use of AEFLA / WIA Title II funds within the context of
occupational training programs geared toward helping adults enter and
succeed in skilled occupations. However, we do also recognize that there are
other valuable uses of AEFLA / WIA Title II resources that advance adult
literacy independent of any specific employment outcome. We hope a
reauthorized AEFLA / WIA Title II will allow a better pursuit of both goals.
The Disconnect Between Adult Education and
Occupational Skills Training
Our network of workforce development stakeholders
feels there is an avoidable disconnect between federal support for
occupational training under programs like WIA Title I, and basic skills
education services provided under AEFLA / WIA Title II . Our members are
often serving job-seekers who not only lack the latest occupational skills
to enter newly available jobs, but also lack the literacy, language or
computation skills that are now minimum requirements often just to make it
through these training programs, let alone succeed in these "new economy"
positions.
Recent research confirms our members' real-world
experience: that when basic skills education is offered within the context
of occupational training, it yields significant labor market success for
trainees. For example, a recent study that was part of the National
Evaluation of Welfare-to-Work Strategies found that over three years, high
school non-graduates who participated in basic education followed by
post-secondary training or education earned an impressive 47% more than high
school non-graduates who participated in basic education alone. Yet current
federal policies do not facilitate or encourage the effective integration of
these two types of education and training. Many community colleges and
community-based organizations cite concerns about local workforce
development systems in which basic education and occupational skills
training services operate independently of each other. As a result, many
occupational training providers who serve adults with additional basic
skills needs have no way of accessing AEFLA / WIA Title II funds-or even
Title II-funded providers of adult literacy services-to support their
trainees' success. In some cases, community-based training providers find
they must cobble together leftover funds from other sources to support basic
skills services for their trainees, albeit not at the level or intensity
that such training providers would prefer. In other cases, some community
colleges find that the nature of Title II funding discourages their
institutions from integrating Title II services with the institution's
workforce development programs. There are a number of practical issues that
a reauthorized AEFLA / WIA Title II should take into account to ease
coordination between occupational and basic skills services:
·
Title I and Title II continue to function as separate
systems, even though they are mandated partners within WIA.
Individual job-seekers who are referred to a Title I "eligible training
provider" to receive occupational training services rarely receive a
simultaneous referral for adult education services. If the occupational
training provider does not receive Title II funding, then it typically has
no other federal resource to support basic skills services for that
job-seeker.
·
Title I and Title II of WIA are subject to different
performance measurement systems. Even at institutions like
community colleges, which receive both Title I and Title II funding, the
difference in performance indicators for the two sources makes their
integration within a single workforce development program difficult.
Performance indicators under WIA Title I primarily measure labor market
gains (e.g., placement, retention, earnings gains), whereas WIA Title II
indicators include other measures of equal weight, including improvements in
literacy levels and receipt of a secondary diploma or its
equivalent-important goals on their own, but not essential to measuring the
success of a graduate from an employment-focused workforce development
program. Given the need to track two different sets of goals for each
student, some colleges just opt to keep the basic skills services separate
from the occupational training services, thereby reducing integration.
·
In some states, adult education and adult occupational
skills training are often the responsibility of completely separate
institutions. In many states, the K-12 system operates AEFLA
programs, thereby placing Title II services within a completely different
set of institutions than those in which most occupational training is being
delivered to local adults under Title I (i.e., community colleges,
community-based organization, and unions).
Recommendations for Better Coordination Between Adult Education and
Occupational Skills Training
The Department of Education should continue to allow
AEFLA / WIA Title II programming that raises literacy and basic skills
levels for some individuals independent of any employment outcome. However,
for those local areas and training institutions that are providing
occupational training and want to integrate those services with basic
education services, the Department of Education should be working with
Congress and the U.S. Department of Labor to ease integration between WIA
Title I and AEFLA / WIA Title II. That can be done by:
·
Making it easier for training providers to access both
Title I and Title II funds for individual clients or programs.
·
Streamlining performance measurements for Title I and
Title II funds when used in the context of single workforce development
program. Allow the employment-focused measures used for training
services under WIA Title I (e.g., job placement, job retention, earnings
gains) to suffice for measuring performance for Title II funds used within
the context of an occupational skills training program. If there are
separate education measurements required, focus on workplace-related
competencies as opposed to only on grade-level improvements.
·
Encouraging co-location of adult education and
occupational skills training programs within individual institutions.
States should continue to have the flexibility to choose which
institutions (K-12, post-secondary, community-based, etc.) are eligible to
deliver AEFLA / WIA Title II services. However, the Department and Congress
should consider creating incentives or new demonstration programs for the
use of some of those funds by institutions / providers delivering
occupational training, in order to assess their success in integrating basic
skills and occupational skills services.
We are gratified to see that the Alliance supports the
broad purposes of the Title II program but are concerned about their
perception that consistent definitions and control of title II dollars by
employment and training agencies are their preferred means of fostering
better integration of Title I and Title II activity. We need to have them
understand that consistent employment–related definitions are needed – but
only for those individuals in Title II programs who choose employment or
training as their goal. They also seem to be unaware that the direct and
equitable provisions of Title II already allow them to apply for funding.
State and local adult education agencies need to demonstrate that the best
path to better integration is to promote partnerships between agencies that
are experienced in delivering adult education services and employment and
training agencies.
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