NSC submits public comments on WIOA regulations

May 21, 2015

National Skills Coalition recently submitted comments to the Departments of Labor (DOL) and Education (ED) regarding the five Notices of Proposed Rulemaking (NPRMs) governing implementation and administration of the Workforce Innovation and Opportunity Act (WIOA) issued by the agencies in April 2015. Click here to read the comments.

NSC strongly supports the vision and goals of WIOA, and we look forward to working with the Departments of Labor and Education — as well as other federal agencies responsible for administration of partner programs — to support the successful implementation of the law. The NPRMs are a critical step towards achieving that vision, and throughout our comments we note areas where we believe the draft rules are consistent with the statutory intent, as well as areas where we believe additional regulatory clarification or guidance may be needed. NSC’s comments address the NPRMs covering Unified and Combined Plans, Performance Accountability and the One-Stop System; DOL-Administered Activities; and Title II Adult Education and Family Literacy Activities. Specifically:

  • In the section on NPRM 1205-AB74 we provide comments on the proposed rules relating to state unified and combined plans under new 20 CFR part 676 (and corresponding section under 34 CFR part 361 and part 463), and the performance accountability provisions at 20 CFR part 677 and corresponding sections under 34 CFR.
  • In our comments on NPRM RIN 1205-AB73, National Skills Coalition focuses on five key issues under WIOA Title I: 1) the development and implementation of industry or sector partnerships; 2) the development and implementation of career pathways; 3) provisions implementing youth services under Title I-B; 4) the priority of service requirements set forth in WIOA section 134; and 5) the updated Eligible Training Provider List (ETPL) requirements.
  • Finally, in our comments for NPRM RIN 1830-AA22, we address the draft rules relating to the Adult Education and Family Literacy Act under 34 CFR, with a particular focus on provisions relating to local workforce development board review of Title II applications, integrated education and training programs, and the definition of career pathways as part of English language acquisition programs.

Public comments must be submitted to the agencies on by June 15, 2015. We encourage you to formally submit comments, and ask that you please share your submissions with us so that we can continue to stay abreast of NPRM concerns and kudos from the perspective of the field.

On April 22, National Skills Coalition hosted a webinar covering key provisions in the NPRMs and what they mean for the workforce and industry. Watch Unpacking Proposed WIOA Regulations and read the Frequently Asked Questions released by NSC in response to questions submitted during the webinar.