NSC submits comments on required elements of WIOA unified or combined state plans

By Katie Spiker, September 15, 2015

National Skills Coalition today submitted comments on the Departments of Labor, Education, Health and Human Services, Agriculture, and Housing and Urban Development’s (The Departments’) recent information collection request (ICR) on the required elements of Workforce Innovation and Opportunity Act (WIOA) Unified or Combined State Plans.

The ICR is organized into strategic elements and operational elements that cover all core and partner programs included in a state’s plan, as well as program-specific requirements outlined in WIOA and other authorizing statutes. Strategic elements include a state’s vision for their workforce development priorities, analysis of current workforce conditions and future opportunities, and strategies to implement priorities given the current conditions. Operational elements cover how the programs interact and steps necessary to implement and carry out the goals of the WIOA and partner programs. The ICR also includes requirements for states to describe coordination between WIOA core programs and optional partners (TANF, Perkins, etc.) included in Combined Plans, where appropriate.

Overall, NSC believes that the ICR provides a reasonable synthesis of the required elements across both unified and combined state plan, and provides states with useful guidance on how to carry out the joint planning required under the law. NSC’s comments include recommendations on specific areas or elements that could be strengthened to better support alignment, including:

  • Defining the concept of “skill gaps.” The ICR would require states, as part of their broader analysis of the state’s workforce and economic needs, to provide an analysis of “apparent skill gaps.” Since the term “skill gaps” is not defined under WIOA, NSC recommends that this requirement be amended to require an analysis of current and projected gaps between employer skill needs and the current and projected education and skills of the state’s workforce.
  • Ensuring that state plans reflect statutory requirements relating to industry or sector partnerships. The ICR calls for states to provide descriptions of key strategies to be carried out under section 101(d)(3) of WIOA, including career pathways and sector strategies. While NSC supports the focus on career pathways, we note that the statute specifically requires that states provide information about “industry or sector partnerships,” rather than the broader concept of sector strategies, and we recommend that the ICR be amended to reflect the statutory language.
  • Clarifying the role of partner programs in state planning process. The ICR requires states to describe alignment between core programs and other programs, including combined plan programs and mandatory and optional one-stop partner programs. NSC supports this requirement but urges the Departments to provide additional guidance on the extent to which non-core programs should be engaged in the development and implementation of state strategies.
  • Engaging the full range of training providers. The ICR expands on statutory requirements relating to engagement of community and area career and technical education schools, asking states to describe strategies with respect to “education and training providers.” NSC supports the proposed language, but encourages the Departments to clarify that this language includes any training providers that could be included on the state’s eligible training provider list
  • Encouraging alignment and integration of program data. NSC urges the Departments to modify proposed language in the ICR that would require states to describe how they are planning to achieve interoperability and integration of data systems, to take into account the potential challenges states may experience in moving to full interoperability and to encourage the use of existing resources that may be used to support such efforts.
  • Supporting integrated education and training under Title II. WIOA specifically requires that state plans include a description of how the state will support integrated education and training under Title II, but the ICR does not appear to reflect this element. NSC recommends that the ICR be amended to reflect these key strategies.

To access NSC's submitted comments, click here.