New Maryland policy will encourage better coordination between WIOA Title I and Title II

By Amanda Bergson-Shilcock, June 16, 2017

Policy guidance recently issued by the Maryland Department of Labor, Licensing, and Regulation (DLLR) is spurring local adult education and workforce providers to spell out how they are working together to assess program participants. The most recent guidance was issued in April 2017. It is aimed at local workforce development areas and adult education providers funded by Maryland under the Workforce Innovation and Opportunity Act (WIOA).

The policy will help to address a problem that is widespread nationally: Adult education and workforce program participants are often subjected to repeated, sometimes redundant tests to meet program reporting requirements. Better coordination across WIOA Title I workforce and Title II adult education programs can help identify instances where a single assessment result can be used to satisfy more than one reporting requirement, thus reducing the time and expense required to administer multiple tests to a single participant.

NSC recently sat down for a conversation with Erin Roth, Director of Policy in the Division of Workforce Development and Adult Learning at Maryland’s DLLR (pictured above). Edited excerpts of that conversation are below.

Q. Maryland is one of a minority of states in which oversight of WIOA Title II adult education services is housed within the same agency that oversees workforce development. Did having the state stakeholders under one umbrella help you to formulate this policy?

I’m glad you mentioned that. We worked really hard to make sure that all of the relevant State and local stakeholders were engaged in the process of developing this policy. Everybody brings different expertise and perspectives to the table, and we didn’t want to overlook any considerations as we were drafting the policy. If you want people to not just comply with a policy but really embrace the spirit of it, you have to incorporate their input from the beginning.

Q. Who were those stakeholders? Can you help us get a sense of the different types of organizations that were at the table?

We pulled together a diverse group of experts, including representatives from community colleges and local workforce areas, to work alongside State leadership from labor, education and human services. To ensure we had a good balance of perspectives, it was important to include a mix of local staff who oversee operations in addition to the individuals who administer assessments as a part of their everyday job duties.

Q. Maryland, like every state, has to report on participants’ Educational Functioning Level (EFL) gains for WIOA Title II participants, and on Measurable Skill Gains for both WIOA Title I and Title II participants. Did you develop this policy in response to those federal requirements?

We obviously want to comply with federal requirements, but actually, we started this alignment work back in 2015, realizing it was the right thing to do for our customers. Maryland is really leveraging WIOA by using it as an opportunity to evaluate existing processes and improve the customer experience within the workforce system.

Measuring EFLs isn’t a new concept for our system, but aligning the activities in this way is mostly new, and it has required hard work and honest conversations between our local partners. I do believe that strengthened coordination between our Title I workforce and Title II adult education providers will contribute to EFL gains and positive outcomes with Measurable Skill Gains performance reporting.

But more importantly, I hope that our alignment efforts will increase the likelihood that customers will succeed. We know that a lot of Marylanders could benefit from adult education services to help them access job training and make progress along career pathways. We want to make sure these individuals stay engaged, and we think that limiting the number of standardized tests they’re required to take — through increasing coordination and trust between partners — will help.

Q. Let’s talk about that. One of the big stumbling blocks for joint assessment is that different parts of the workforce and adult education systems may not trust each other’s assessment processes – and thus, may administer their own tests “just to be sure.”

Any time you have people who don’t work directly with each other, it’s possible for there to be misunderstandings or mistrust about how processes work. We wanted to address that by providing plenty of joint training opportunities for staff and by laying out some clear guidelines for what good assessment standards should include. We asked our local areas to articulate how they’re approaching assessments in their WIOA Local Plans. That way people aren’t guessing about how their colleagues in other parts of the system are carrying out the assessment functions.

Q. Let’s get into the nitty-gritty. How exactly does your policy move the system toward better coordination of assessments?

We used the Local WIOA Plan process as the driving mechanism. Under our policy, local areas were required to spell out these five items, at a minimum, in their Local Plans:

  • Outline the agreed-upon steps that will be taken to align basic education skills and English language assessments within the local area, including, but not limited to, any Memoranda of Understanding entered into by the workforce development and adult learning partners;
  • Identify how assessment scores will be shared among WIOA Title I areas and Title II providers (Consideration must be given to the Family Educational Rights and Privacy Act (FERPA));
  • Identify who will conduct which of the approved assessments and when such assessments will be conducted, consistent with the Department’s policy;
  • Specify how the local area will coordinate testing between workforce development and adult education providers; and
  • Outline how the local area will ensure that test administrators will be trained in accordance with this policy and applicable testing guidelines set forth by the applicable test publisher.

To answer these questions, local workforce and adult education providers needed to have conversations on how best to work together to align and serve mutual customers.

Q. So just to clarify, you required coordination, but you didn’t tell local areas how to coordinate?

That’s correct. We thought it was more appropriate for local areas to determine the most efficient approach given their particular considerations and context.

Q. When does the policy take effect?

We’re requiring full implementation to be effective July 1, 2017.

Q. The adult education landscape looks quite different across the various states, but federal WIOA requirements are the same across the country. Are there any lessons you learned in developing this policy in Maryland that might be applicable for other advocates who are tackling this issue?

Resist the temptation to oversimplify. Aligning assessments is important and doable, but it is more complex than it may seem. At first, it was tempting for us to create a blanket requirement for the whole state where every provider would just use the same assessment. Sure, that would have made sharing scores easier, but it would have been a miss in bigger ways and likely would have resulted in a disservice to our customers.

By including local experts in the State’s planning process from the beginning, we were able to better understand the complexities and nuances at play. It also helped us to recognize that we needed to consider the budget and planning implications this policy shift would require. And that meant building in plenty of time for local conversations and planning to occur before moving into full implementation mode.