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WIA Performance Related
Frequently Asked Questions (FAQ)

ARRA REPORTING LITERACY/NUMERACY
APPRENTICESHIP REPORTING
COMMON MEASURES VETERANS
CREDENTIALS/CERTIFICATION WAGE DATA
DATA VALIDATION WRIS
H-1B PARTICIPANTS YOUTH PARTICIPANTS

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American Recovery and Reinvestment Act of 2009 (ARRA) Reporting

What are the ARRA monthly reporting requirements after June 30, 2011?

As stated in TEGL 27-10, the last required submission of ARRA monthly reports were associated with the month of June, 2011. These reports were to be submitted to ETA by August 15, 2011. After these reports have been submitted, the ARRA monthly reporting process is complete. However, there are two exceptions to this: 1) the first has to do with the reporting of ARRA funded National Emergency Grants (NEGs) that have unexpired ARRA funds and 2) the second relates to the reporting of TANF-funded summer employment participants for states with waivers to report only the work readiness indicator for youth in summer employment who are co-enrolled in TANF.

What are the requirements for reporting ARRA funded National Emergency Grants (NEGs)?

The Department of Labor announced the one-time availability of up to $75 million in funding for On-the-Job Training (OJT) OJT NEGs funded through ARRA in TEN 38-09. Additional details, as well as, the reporting requirements were provided in TEGL 04-10. In addition, approximately 40 existing NEGs have active ARRA funds that did not expire June 30, 2011.

Per these guidance documents, and in order to satisfy statutory and regulatory recordkeeping and reporting requirements in ARRA, states must report characteristics, services received, and outcomes of participants served with WIA funds, including active NEGs and the OJT NEGs described in TEN 38-09. Such information is critical to determine the success of these investments. The following performance and fiscal reports, including the monthly ARRA reports, were required for ARRA funded NEGs (including the OJT NEGs) through June 30, 2012:

  • ETA 9090 - WIA Quarterly Report (OMB Control No. 1205-0420);
  • Workforce Investment Act Standardized Record Data (WIASRD) Quarterly Submission (OMB Control No. 1205-0420);
  • ETA 9148 - WIA Adults, Dislocated Workers, and National Emergency Grants ARRA Monthly Report (OMB Control No. 1205-0474). This report was required to be submitted to ETA by the 15th of each month (for the previous month reporting period) by each state that received an OJT NEG grant or had an active existing ARRA funded NEG.

    Note: As stated above, this report will only be required for states and grantees that received OJT NEG grants or that have active existing ARRA funded NEGs. Furthermore, the requirements associated with ETA form 9148 are different than they were under the previous ARRA reporting periods. Beginning with the July 2011 monthly ARRA report, states and grantees must report only the NEG portion of ETA form 9148. States must leave the Adult and Dislocated Worker sections as they are pre-populated (filled with zeros). The first two reports (July 2011 and August 2011) will be due on the same date as the September report (October 15, 2011).

  • ETA 9130 - U.S. DOL ETA Quarterly Financial Status Report (OMB 1205-0461);
  • ETA 9104 - NEG Quarterly Performance Report (QPR) (OMB 1205-0439);
  • ARRA Section 1512 - Quarterly Recipient Report.

    Please note, the ARRA recipient report is submitted by direct recipients or designated sub-recipients of ARRA funds to OMB through an electronic reporting system at www.FederalReporting.gov, no later than the 10th day after the end of each calendar quarter. This Recipient Report contains cumulative data on the projects and activities funded by ARRA from the inception of the grant award (jobs created/retained data is quarterly). For additional reporting guidance and references, see TEGL 1-09, Change 1 and 2, Reporting Requirements under Section 1512 of the American Recovery and Reinvestment Act of 2009 as well as OMB guidance found at www.recovery.gov.

  • Workforce Investment Act Standardized Record Data (WIASRD) Quarterly Submission (OMB Control No. 1205-0420)

    In addition, the WIASRD must be submitted quarterly on all participants and exiters from ARRA NEGs. In order to evaluate the success of these NEGs, it is imperative that states make every effort to submit the required reports on a timely basis, and that they be accurate and complete.

    There are a few important WIASRD elements pertaining specifically to OJT and NEG funding sources that must be completed for OJT NEG participants:

    • WIASRD data items 340 and 341 (Type of Training Service #1 and Type of Training Service #2) are the sources for determining which individuals received OJT. A lack of complete data on these WIASRD elements will result in an undercounting and underreporting of the number of individuals who received OJT;
    • WIASRD data item 342 (Occupational Skills Training Code) is important because it contains information on the occupation in which the individual was trained. This information facilitates the identification of occupations where OJT most often occurs or where it is the most successful in obtaining better employment outcomes for workforce system customers;
    • WIASRD data items 313a, 313b and 313c (1st, 2nd, and 3rd NEG Project IDs) in conjunction with WIASRD data item 326 (Other WIA or Non-WIA Programs) make possible the isolation of individuals who were provided OJT through ARRA-funded NEGs.

What are the reporting requirements for TANF-funded summer employment?

To ease the reporting burden on states, the modified monthly youth participant form (ETA 9149) used in the Summer of PY 2010 is the most convenient method for capturing the required performance data associated with the TANF source of funding in PY 2011.

The columns titled “TANF Waiver Reporting” are to be used by those states that have a waiver to report only the work readiness indicator for youth in summer employment who are co-enrolled in TANF. These states must fill out and submit (via an email to ETAperforms@dol.gov) only the Program-to-Date Column (column d) of the appended modified ETA form 9149 by October 15, 2011. States without the TANF waiver no longer have to report using the Youth ARRA monthly reporting form (ETA 9149).

Youth participants served with regular WIA formula and TANF funds and are covered by the TANF waiver will only be reported in the TANF columns of the supplemental youth report.
Youth participants served only with TANF funds will not be reported in any of the WIA reports.

Apprenticeship

Can apprenticeship be counted as advanced training?

When a person enters a bona fide apprenticeship program, he/she is counted as entering employment. Apprenticeship should be recorded as unsubsidized employment.

Common Measures

Are exclusions still in place for the original measures?

Yes.

In TEGL 17-05, can on-the-job training count as advanced training in the WIA youth program?

No.

In Attachment D, Scenario 2 of TEGL 17-05, how has the customer been “determined” eligible for WIA services in this scenario so that she is counted in the Participant count? How do we know that she is legal to work or, if it is a male, registered with the selective service?

The WIA adult program has a universal access component that allows the system to serve a universal population with core services.

How can two programs share the same date of participation when TEGL 17-05 refers to the date of participation as “represents the first day, following a determination of eligibility funded by the program?” If an individual is served in January by Wagner-Peyser funds and begins a WIA funded program in March the date of participation for WIA can not be in January?

DOL encourages states that are able to track participant services across DOL-funded programs to utilize a single date of program participation and exit. Using the example cited in the question, the date of participation is January. The individual entered the system in January and received their first service in January. Thus, the participation date is January.

What do we do in the case of wage "anomalies"?

Attachment D of TEGL 17-05 discusses wages that can be excluded. A copy of the TEGL can be found at www.doleta.gov/performance.

Credentials/Certificates

Please clarify the credential/certificate changes and requirements effective July 1, 2006 and how they apply to current participants and those after July 1st?

The change in definition from “credential” to “certificate” will apply to all WIA participants who enroll in training services on or after July 1, 2006. Any participants that are “carried over” into PY 2006 (i.e., continuing to receive training services that began before July 1, 2006) would still operate under the old “credential” definition.

Now that the WIA Adult, Dislocated Worker, and Older Youth Credential measure use the certificate definition, do GEDs, high school diplomas, and college degrees still count under the credential measure?

Yes. ETA erred in the guidance when stating the certificate definition will replace the credential definition for those participants who enroll on or after July 1, 2006. ETA should have stated that the diploma and certificate definitions replace the credential definition for those participants who enroll on or after July 1, 2006. Therefore diplomas as defined by TEGL 17-05 would also count toward the Adult, Dislocated Worker, and Older Youth credential measure in addition to certificates as defined by TEGL 17-05.

ETA has recently been asked to clarify whether or not there has been a change in policy related to work readiness certificates counting under the credential measure. For reporting purposes, how should the workforce system account for work readiness certifications?

ETA considers work readiness training and assessment to be intensive services, similar to other skill assessment and educational remediation services offered through the public workforce system. According to TEGL 17-05, and more recently in TEGL 15-10, ETA has clearly stated that work readiness certificates do not count for the purposes of the credential attainment rate measure. ETA recognizes that work readiness skills are valued by employers and can help job seekers secure and retain employment and we encourage public workforce agencies to ensure that job seekers are work ready. However, the focus of our credential definition is on attainment of measurable technical or occupational skills. The type of skills documented in work readiness certificates are foundational for many careers, rather than being technical preparation for any specific career. For these reasons, a work readiness certificate, while valuable, is not equivalent to an occupation-specific certificate or degree or to a personnel certification.

Will ETA entertain requests for waivers on the work readiness certificates?

No. ETA will not consider waivers to count work readiness certificates as acceptable under the certificate common measure.

Does a Cardiopulmonary Resuscitation (CPR) certificate or an Occupational Safety and Health Administration (OSHA) certificate count towards the Attainment of a Degree or Certificate WIA Performance measure?

ETA has received requests to provide specific guidance related to whether or not a CPR or an OSHA certificate counts for the Attainment of a Degree or Certificate WIA Performance measure. While ETA does not typically specify which credentials count and which credentials do not count toward this measure, it is providing clarification for these two specific credentials given the high volume of questions. The CPR certificate and the OSHA certificate do not count for the degree/certificate measure as they do not meet ETA's intent of its credential definition. By definition (found in Training and Employment Guidance Letter (TEGL) 17-05, Attachment B and further clarified in TEGL 15-10), a credential must be awarded in "recognition of an individual's attainment of measurable technical or occupational skills necessary to gain employment or advance within an occupation." While a CPR or an OSHA training may provide benefit to participants as they begin to gain general knowledge about occupations and occupational standards, participants are unlikely to gain employment or advance within an occupation based solely upon receiving a CPR or an OSHA certificate.

It is important to note that the goal of the Attainment of a Degree or Certificate WIA Performance measure is not simply to increase the number of credentials attained by participants; the credential should ultimately help participants gain employment or advance within an occupation as a result of attaining occupational credentials. Additionally, while they do not count towards the credential measure, WIA funds can pay for CPR and OSHA training if such training is relevant to the design of the individual's service plan.

Data Validation

Who is responsible for submitting the data validation results for each program?

The states decide who will submit the results for WIA, ES and TAA. Some states assign one person for all three programs and other states have one person for each program. The states should inform their regional representative of the contact person(s) for each state. It is the state's responsibility to communicate any changes to the contact list to the regions as soon as possible.

What happens if a state cannot find a record that has been sampled for validation?

It depends upon the cause of the problem. If an office has been hit by a disaster (flooding, fire) that destroyed the records for that office (which the state should know prior to drawing the sample for validation), the state should inform the regional office of the issue. With the region's approval, the state should create a new extract file that excludes the records for that office. This new file should be imported into a different database from the one in which the state performed report validation. The software will then provide the state with a sample of records that excludes the records from the office that was destroyed. If individual files are missing from an office, then the validator should check the Missing Records box on the validation worksheet.

When are the WIA data element validation results due for Program Year 2004?

Results for data element validation are due February 1, 2006. States should use version 3.0MR to complete validation for PY 2004. Instructions on how to e-submit your summary and analytical reports can be found in Appendix C of the user guide, which provides detailed instructions on the e-submit capability in the Data Validation Version 3.0MR software. A copy of the guide is available for each program on ETA's Web site at http://www.doleta.gov/performance/. Click on the link for Reporting Guidance and Data Evaluation and go to the third bullet point, Data Validation and more. States are required to electronically submit data element validation (DEV) and/or Report Validation (RV) data electronically via the Internet to the Department. Passwords were assigned to state staff to e-submit results through the validation for each of the three programs. Any questions should be forwarded to Traci DiMartini at Dimartini.Traci@dol.gov, or by phone at 202-693-3698.

Will states be sanctioned based on the results of PY2004 validation?

States are required to complete and submit validation results by the deadlines established in TEGL 3-03, Change 3. There are no sanctions based on validation results but states will be held accountable for conducting a thorough and complete validation of their files and electronically submitting results to ETA by the February 1, 2006 deadline.

Our state may not be able to complete data element validation by the February 1, 2006 deadline. Can we request an extension?

If a state believes it cannot meet the February 1, 2006 deadline to complete data element validation it must contact its regional representative no later than January 15, 2006. States are required to provide an explanation detailing why the deadline imposes a hardship. The regions will work with the National Office to determine whether an extension can be granted.

There are several elements that allow the state to use a Management Information System (MIS) to validate their results. Can you please provide specific examples of acceptable MIS systems? Can a state use its own WIA system to validate elements?

The data element validation instructions in the WIA Validation Handbook dated November 2004 allow states to use their MIS as a source if the MIS has specific, detailed information that is stored in the state's information system that supports the date on the validation worksheet. An indicator alone, such as a checkmark on a computer screen, is not acceptable source documentation. For example, state MIS is acceptable source documentation for date of first training service. To be an acceptable source to validate date of first training service, in addition to the date of first training, the state MIS should have detailed information about the type of training and the organization that provided the training.

Explain the validation process for the Labor Exchange.

States build two validation files, one for job seekers and one for job openings, according to the record layout specifications in the software user guide.

The job seeker file is imported into the software, and the software generates validation values for the 9002 A, B, C and D and VETS 200 A, B and C reports. If the state uses a system other than DART or the ETA provided reporting/validation software version 1.9, then the state must also import its reported counts for the 9002 A, B, C and D and VETS 200 A, B and C reports. The software then generates a report validation summary, which compares the reported and validation values and calculates a percent difference. The software also generates a 25 record data element validation sample of job seeker records that the state must compare to source document to ensure that the state constructed its validation file correctly, that is, that it included the correct data elements in building the validation file.

The job opening file is imported into the software, and the software generates validation values for the 9002 E report. If the states uses a system other than DART or the ETA provided reporting/validation software version 1.9, then the state must also import its reported counts for the 9002 E. The software then generates a report validation summary, which compares the reported and validation values and calculates a percent difference. There is no data element validation of the job opening records.

Will states be able to electronically submit their validation results directly to the Department of Labor?

Yes. States are required to electronically submit data element validation (DEV) and, if applicable, report validation (RV) data electronically via the Internet to the Department. Instructions on how to e-submit your summary and analytical reports can be found in the user guide, which provides detailed instructions on the e-submit capability in version 1.9 of the ES reporting/validation software.

What source documents are required for ES data element validation?

States should compare the data on the validation worksheets to data in the state's MIS.

Is Trade required to perform report validation?

Since states do not calculate and submit performance reports to ETA, states are not required to perform report validation. The validation software, however, provides states with the capability to analyze their performance. (November 2004)

When is data element validation for the FY 2005 TAPR due?

States should submit their data element validation results for the FY 2005 TAPR by February 1, 2006.

What are National Farmworker Jobs program grantees required to validate?

The NFJP grantees are not required to submit an annual report but are required to submit individual participant records. Therefore, there is no report validation required for NFJP grantees. The final NFJP participant data for PY 2004 is due February 15, 2006. Data element validation for PY 2004 must be completed and submitted by June 15, 2006.

H1-B Participants

Are H1-B participants and participants in “pathways to construction” captured on the WIASRD when they exit services?

The WIASRD report is used to report on individuals who exit from WIA Title I-B programs; outcomes of H1-B participants would not be reported on the WIASRD unless the participants were co-enrolled in a WIA title 1B program. We are unsure what “Pathways to Construction” is and, therefore, do not know the funding source for the project/program. The WIASRD would be used if the funding source is WIA title 1B formula funding.

Literacy/Numeracy

Are there certain tests (used to assess literacy and numeracy gains in the WIA Youth Program) determined suitable for use in the National Reporting System that are expiring?

ETA would like states and local areas to be aware of the Federal Register notice (FRN), Tests Determined to Be Suitable for Use in the National Reporting System for Adult Education, published on Monday, August 6, 2012, by the Office of Vocational and Adult Education at the U.S. Department of Education (ED). The FRN can be found at http://www.gpo.gov/fdsys/pkg/FR-2012-08-06/pdf/2012-19143.pdf. The FRN reminds people that a number of tests approved by the National Reporting System (NRS) may expire on February 2, 2013. It explains that the Secretary of Education will allow States a period of time to sunset an expiring test and transition to other tests suitable for use in the NRS. States may use the transition period to select new tests, purchase appropriate inventories of assessment materials, and provide training to staff. Specifically, tests with three-year NRS approvals expiring on February 2, 2013, may continue to be used during a transition period ending on June 30, 2014.

It is possible for tests that were granted the initial three year authorization to provide additional information to ED in order to extend their approval. This NRS assessment review process begins each year on October 1. Which tests will be submitted or whether they will be determined suitable for use in the NRS is unknown. States and local areas should review this FRN and if states and/or local areas are concerned about tests expiring, they can contact the test publisher for more information.

Ther beee hasn much discussion regarding partnering with our sister agency - Adult Basic Education - to help implement the measure successfully. However, they may feel slighted if we request an assessment of a participant who just recently acquired their GED through ABE’s program. It would seem as if programs are questioning the validity of the GED if they were to follow this exercise. Cannot the GED be recognized as an assessment by proxy, especially in light of the fact that it is currently recognized and accepted by USDOL as an obtained credential?

No. The GED is an established training program, not an approved assessment instrument on the list of NRS. Only those assessments included in the NRS are acceptable assessments for this measure.

How much success have rural, isolated areas, especially those where timely assessment may not be so readily available, had with implementation of the literacy/numeracy measure? If an assessment can be administered, how can a WIA program help the participant achieve a gain from one educational functioning level to another without a local ABE office or other educational resource in the area?

Local programs should partner with educational entities such as community and technical colleges and alternative schools in order to achieve success in this measure. These are new measures and we will focus on implementation and continuous improvement over the next few program years. We encourage all areas, both rural and urban, to provide feedback to the Departments of Labor and Education so we are aware of successes and barriers.

If a participant refuses to undergo the assessment process, either pre-test or post-test, should services then be denied to a participant based on his/her unwillingness to comply with a program’s attempts to meet the measure? This is likely to occur with older out of school youth. Those who may already have a GED or High School diploma will see the effort as duplicative and may wonder why we are testing these areas?

Services should not be denied to such participants. Local WIA programs are responsible for communicating why these assessments are important and explaining why they will help the youth achieve greater access in employment and higher education.

If we have a youth who is tested as basic skills deficient in math and speaking and they increase an educational functioning level in speaking, is that a positive hit for Literacy/Numeracy?

Gains in oral and speaking areas can count towards literacy/numeracy measure for ESL participants only.

NEG Participants

Are NEG participants included in the WIASRD? If the answer is “yes,” then why does the data validation software kick them out?

NEG participants are captured on the WIASRD, and the validation software properly imports these records. States that have trouble importing records into the DRVS software should contact the appropriate technical assistance e-mail address for support and cc their regional performance specialist and/or etaperforms@dol.gov. For WIA issues, please e-mail WIATA@mathematica-mpr.com. For Wagner-Peyser funded programs please contact ESTA@mathematica-mpr.com.

Reporting

If a participant doesn’t have a SSN but you have supplemental data, can you take a positive hit for Entered Employment?

States may use supplemental sources of data to document a participant’s entry and retention in employment for participants not covered by UI wage records.

States that use DART don’t have to use the ETA DRVS software to perform Wagner-Peyser Act report and data element validation. Does this apply only to the ETA 9002 and VETS 200 reports?

Yes. States can run their reports through the DART software in lieu of using the ETA DV software. However, states still must electronically submit the results to ETA through EBSS and indicate that they use DART to calculate their reports. DART is the only acceptable alternative software and can only be used for the ETA 9002/VETS 200 reports. All states must use the ETA software to perform WIA report and element validation.

What is the meaning of intensive services for veterans reported on the VETS 200 reports? What part of WIA intensive services is included in the VETS meaning of the term?

The meaning is limited to “staff-assisted” intensive services provided by Disabled Veterans Outreach Program (DVOP)/ Local Veterans Employment Representatives (LVER) staff, as described in WIA section 134(d)(3). Intensive services that do not involve DVOP/LVER staff assistance, such as provision of adult basic education and literacy activities, are not included in this definition.

The WIASRD report is based on exiters but are there circumstances where a WIASRD is submitted for someone who has NOT exited?

States should refer to the WIASRD general instructions, which are found at www.doleta.gov/performance, and provide the information necessary to determine who is included in the report.

If an individual is taken out of performance calculations under one of the “global exclusions” conditions, is that person still included in participant counts?

If an individual is removed from performance calculations, the person does not “disappear.” If the individual is a WIA participant, for instance, the individual is excluded from performance calculations; however, a WIASRD is still submitted by the state on this individual. ETA will not require states to go back to previous reports.

The data in FRED mysteriously changes from the outcomes reported to the outcomes contained on the graphs. What is causing this?

There was a bug in the program that produced the graphs that displayed the outcomes summarized across all years regardless if a particular program or reporting year was selected. That bug is now fixed and the outcomes are being correctly displayed on the graphs.

What would happen if a youth received Wagner-Peyser core services, went to WIA three months later, but information on school status was not collected at initial participation?

That’s fine. The school status information should be collected at the time of participation in the youth program, because it is required. Wagner-Peyser Act participants may or may not disclose this information. Even so, it is fine to update this field at the time of participation in the youth program, because it is impacts the youth measure calculations. For the Wagner-Peyser Act, the information is used for reporting breakouts on the 9002A and C reports.

An issue came up about planned gaps from an MIS perspective and how to do a gap when there has been 60 days of no service, for instance, and then the person gets sick. Would you back-date the gap to the last day of service?

There is flexibility here for the states. Customer circumstances will vary substantially, and even in this scenario, we have to make certain assumptions in order to provide an answer. If the customer completed training, went 60 days with no service, and then walked in or called the One-Stop staff and said “I now have to take care of my mom for the next 60 days,” the One-Stop staff should initiate a gap in service (we suggest making it for 180 days) based on the date on which the individual completed training. This provides a lot of room for the gap in service to occur and it is based on a real data point: the date training was completed.

Let’s say that after 60 days of taking care of the family member, the customer says “Gee, my mom is going to need me for another 60 days, but I really do want to finish services with the One-Stop.” In this instance, the One-Stop staff does not have to make any change or take any actions in the MIS, because there is enough room in the initial 180 day gap to accommodate this extra time.

If after that second 60-day window, which is now the end of the initial 180 day gap, the customer says “OK, my mom is going to need me and I am unable to complete services,” the One-Stop staff should close out the gap in service, exit the customer based on the “Date Training Was Completed,” and then record a global exclusion for “Family Care.”

Veterans

How does citizenship affect eligibility requirements? What about “right to work” and selective service?

ETA is aware of the confusion around these two issues, particularly as they pertain to serving customers in a self-service environment. ETA’s Office of Workforce Investment will develop guidance to address states’ concerns.

Is it acceptable for LVER and DVOP specialists to serve non-veterans and, if so, what are the parameters?

Only half-time DVOP specialists or LVER staff can serve non-veterans. The shared funding of these positions is most effective when the DVOP specialists and LVER staff members collaborate with other workforce professionals in identifying service delivery approaches that meet the needs of all those participating in One-Stop employment services and that observe the priority of service to which veteran participants are entitled.

The key parameter to be observed by half-time DVOP specialists and LVER staff is to see to it that they allocate their effort to veteran and non-veteran participants on the 50-50 basis that matches the funding for their positions. VETS recognizes that professional judgment is required to determine that the split in various measures of activity reflects the “fair-share” allocation to which both funding sources are entitled.

When the funding of DVOP specialist and LVER staff positions is to be shared, VETS encourages state and local program operators to use WIA funds in conjunction with VETS funds. The rationale for that preference is that this arrangement tends to strengthen the involvement of DVOP specialists and LVER staff members in decisions regarding training and positions them to play a constructive role in facilitating priority of service.

I seem to recall some kind of percentage or threshold of non-veterans that could be served by LVERs and DVOPs who are NOT part-time or half-time workers. Can you clarify this?

VETS has not published an official policy on any acceptable “threshold” of non-veterans that can be served by LVER staff or DVOP specialists. The questioner may be referring to the “3% difference” between services to veterans and non-veterans, which was an internally published document previous to the passage of the Jobs for Veterans Act.

Veteran status requires 180 days of active duty service. Does the 180 days have to be consecutive?

The required number of days of active duty service actually is 181 and those days do not need to be consecutive. As indicated in the ET Handbook No. 406, an individual may qualify as an “eligible veteran” in any of three ways.

VETS has programs that involve LVERs and DVOPs physically going into prisons and serving veterans (they can provide services up to 18 months prior to their potential release date). Since these people are incarcerated at participation, do they even count toward performance?

The Incarcerated Veteran Transition Program (IVTP) Demonstration projects provide funding to serve incarcerated veterans up to 18 months prior to separation. There are seven IVTP Demonstration Grants at this time. However, any DVOP specialist or LVER staff can provide service to incarcerated veterans. Incarcerated veteran participants are excluded from performance calculations under the common measures when they remain incarcerated at the time of exit or are found to be reincarcerated three quarters post exit.

Concerning source documentation for veteran status, although a DD-214 is required, why can't grantees use a letter received from the Veterans Administration (VA) that clearly states date of entry, exit and type of discharge? It could substitute for a DD-214 until one was secured.

This question is confusing reporting requirements with data validation requirements. PROTECH will work with VETS to determine if there are other possible documents that would be acceptable to document veteran status.

Wage Data

States create their extract files for validation in October, using the wage record files available. Sometimes, when they go to validate the wages, the wages in the Unemployment Insurance (UI) wage record system have changed because they have been updated. How should states deal with the dynamic nature of wage records?

Wage records are dynamic information: new information may arrive after the participant extract file is created. States need to account for this when validating wages. In other words, they must find a way to determine the actual wages at the time they calculate their annual report. This can be done in many ways, including freezing the wage record file by making a copy of the appropriate records at the time the extract file is created or working with the state's UI division to obtain the accurate wage record information.

How do we access/use FEDES data? For instance, the data are annualized.

ETA is developing technical assistance instructions around the use of FEDES data so that every state is consistent in its approach using these data sources. For more information about FEDES, states are encouraged to contact Heather Parker in the National Office and she will put them in touch with the contractor.

Wage Record Interchange System (WRIS)

What will be the governance structure for the WRIS?

Resolution of WRIS issues that were previously mediated through the Executive Committee of the National Association of State Workforce Agencies will not be unilaterally resolved by the Employment and Training Administration. ETA will consult with states on the best approach to structuring collaboration on resolving WRIS issues. The consultation will seek to identify the most cost effective and administratively efficient approach to issue resolution.

How will WRIS policy be developed and approved?

The WRIS will continue to operate under policies previously established under NASWA's stewardship. Any changes to existing policies would be made through the new governance vehicle once established.

How will monitoring be performed to ensure proper use of the WRIS data?

States will continue to engage in self-monitoring, using the self-assessment process they used in the past. In addition, periodic on-site monitoring will be conducted by ETA regional offices to ensure data confidentiality is maintained. These reviews will be conducted as part of the ongoing reviews of WIA and UI programs.

A schedule of reviews and the results will be posted on the WRIS section of www.doleta.gov/performance/WRIS.cfm and arrangements will be able to be made to allow interested states to participate in the portion of state reviews that pertain to confidentiality compliance if desired.

Will confidentiality compliance reviews be conducted, and if so, by whom?

Please refer to the answer above.

Who will decide on what is an appropriate research purpose for which data obtained through the WRIS can be used?

Per subparagraph 5 of paragraph C of Section V of the WRIS Data Sharing Agreement, ETA will develop and coordinate a process for the distribution of research proposals to the impacted WRIS states for consideration. ETA will initially subject the research and evaluation proposals and justifications (which must specify the uses to which the WRIS data will be put) against the “direct benefit to one or more of the programs described in subparagraphs 1 through 4 of paragraph C in Section VI of the Agreement” criteria. If a proposal appears to meet the criteria, ETA will convene the states impacted by the proposal to put them in touch with the proposing researcher to negotiate appropriate means to provide them with data as appropriate and allowable.

Who will be the WRIS Operations Contractor?

The WRIS infrastructure continues to be operated through the same cooperative agreement with the State of Maryland that is used to operate the Interstate Communications Network (ICON). Maryland currently contracts with Affiliated Computer Services to operate the ICON and the WRIS.

Has the Agreement been reviewed by ETA's UI staff for conformity with UI laws in the Federal-State partnership and the new confidentiality regulations?

ETA's UI program staff was consulted during the drafting of the new WRIS Data Sharing Agreement and provisions referencing the new UI confidentiality regulations at 20 CFR Part 603 were inserted into the Agreement where needed to be consistent with the regulations, per the guidance of UI program staff and comments provided by the Department's Office of the Solicitor during the Agreement drafting process.

How will the Agreement be amended once signed?

Once the Agreement has been signed, it will be subject to the amendment procedures specified in Section IX of the WRIS Data Sharing Agreement. Any amendments that are adopted through the procedures detailed in Section IX, (i.e., providing wage record data to local areas/Workforce Investment Boards, or expanding use of the data to other programs), will be documented in an amendment to the Agreement that will be signed by both a state's SUIA and PACIA officials and ETA, in the same manner as the original Agreement.

Will states be able to electronically submit their validation results directly to the Department of Labor?

States should feel free to submit any questions they may have about WRIS in general, or questions specific to the WRIS Data Sharing Agreement, to wris@dol.gov.

An e-mail response will be sent directly to the individual who posed the question in addition to it being posted to the WRIS FAQs page on ETA's website at: http://www.doleta.gov/Performance/WRIS_FAQ.cfm.

An e-mail will also be sent to everyone who attended the November 28, 2006 webinar on the WRIS Data Sharing Agreement to notify them when new FAQs are posted to the page. It will be important to review the new FAQs when they are posted to see if there is an answer to any questions you posed during the webinar. Unfortunately, in many cases, it isn't possible to identify the specific individuals that posed questions during the webinar, so you may not receive a direct e-mail response to questions you posed during the webinar.

Who will be signing the WRIS Data Sharing Agreement on behalf of ETA?

The WRIS Data Sharing Agreement will be signed by the Assistant Secretary for the Employment and Training Administration.

Under Section V.C.2 of the WRIS Data Sharing Agreement, why was the “Maintaining the confidentiality” language contained in the original agreement changed to “Facilitating the confidentiality” in the new Agreement?

While ETA agreed with the spirit of the original language, the agency felt that “maintaining” the confidentiality of data exchanged through the WRIS was not a task that the administrative entity (whether that entity is ETA, or the National Association of State Workforce Agencies) could physically perform. Responsibility for “maintaining” data confidentiality lies with the individuals in the SUIAs and PACIAs in the states that actual see and handle the Wage Data on a regular basis. As ETA will not actually handle any Wage Data in its administrative role in the normal course of operations of the WRIS, its role under the Agreement only allows ETA to perform actions that “facilitate” data confidentiality rather than “maintain” it. Hence the language in the new Agreement was changed to clarify the actual role and responsibility that ETA will assume from National Association of State Workforce Agencies under the Agreement.

When is data element validation for the FY 2005 TAPR due?

States should submit their data element validation results for the FY 2005 TAPR by February 1, 2006.

What are National Farmworker Jobs Program (NFJP) grantees required to validate?

The NFJP grantees are not required to submit an annual report but are required to submit individual participant records. Therefore, there is no report validation required for NFJP grantees. The final NFJP participant data for PY 2004 is due February 15, 2006. Data element validation for PY 2004 must be completed and submitted by June 15, 2006.

Why were amendments to the Consolidated WRIS Data Sharing Agreement recommended by the WRIS Advisory Committee not included in the new Agreement?

ETA's intent in drafting the new Agreement was to keep it as true to the previous agreement as feasible to ensure that all of the states that had signed the previous agreement would be able to sign the new Agreement as quickly as possible so the WRIS can once again operate with as close to full state participation as possible. Once the “status quo” is reestablished, amendments to the new Agreement will be considered and states can submit the amendments recommended by the WRIS Advisory Committee for consideration by the new governance structure.

Why does the new Agreement last into perpetuity, as opposed to being in effect for a period of 4 years and then being renewed?

ETA's intent in drafting the new Agreement was to keep it as true to the previous agreement as possible to ensure that all of the states that had signed the previous agreement would be able to sign the new Agreement, so the WRIS can once again operate with as close to full state participation as possible. The previous agreement had an indefinite duration because it did not have an expiration date and provided specific procedures for termination of the Agreement. The new Agreement merely states explicitly that it will continue to be in effect until one of the measures to terminate it has been taken.

Please elaborate on Section IV.D, regarding the Distributed Database Index (DDBI). Will states update the DDBI continuously or quarterly as was done in the past?

The DDBI will continue to be updated quarterly according to the schedule provided by the Operations Contractor, as was the case in the past. Section VI.A. of the Agreement specifically provides that the SUIA shall make submissions no later than the quarterly upload date established by the Operations Contractor. Although the definition of the DDBI in Section IV.D. is not identical to the DDBI definition in the former NASWA Agreement, there was no intent to modify the current DDBI updating process.

What data will be provided to the national grant programs operated by the Department of Labor, such as Job Corps, and how will that be accomplished?

ETA has negotiated an agreement with the State of Kansas, under which Kansas will request Wage Data for program participants of each of the grantees and calculate the common measures and other outcomes on behalf of the national grant program grantees. ETA will receive only a quarterly aggregate outcomes report for each grantee from the State of Kansas.

The process for developing the quarterly aggregate outcomes reports for ETA is as follows: The national grantees will collect and submit to ETA individual records that contain SSNs on those participants that complete the program. ETA will transmit the individual client data to Kansas for matching purposes against the WRIS. Kansas will then populate longitudinal files with appropriate Wage Data to facilitate the production of the quarterly common measures reports. Kansas will calculate the common measures outcomes for each grantee and send a quarterly aggregate performance outcomes report for each grantee back to ETA for dissemination to the grantees.

No individual outcomes or Wage Data will be shared with ETA or any of the national grantees.

Youth Participants

Is a youth considered in-school if they’re in a GED training program that is offered by a private CBO versus a regular school?

It depends. If the school is considered an alternative school as defined by the state, the answer is yes: the young person is an in-school youth. If the school is not considered an alternative school by the state, then the answer is no. Each state must define what they consider as ‘alternative school’ and youth in such alternative schools are considered in-school youth.

For youth, what is the maximum amount of time between eligibility determination and providing the first service?

There is no maximum amount of time required. However, if there is a long time delay between eligibility determination and the delivery of needed services, this may be indicative of a program design issue.

When do youth follow-up services begin? Is it after WIA exit or exit from all partner services?

Follow-up services for WIA youth begin following exit from the WIA program (or the last expected WIA youth service). Follow-up may begin at the last expected WIA youth service since it will not be known for 90 days that the last WIA youth service will become the official exit date.

What happens if we give a youth their pre-test after the 60 days?

All out-of-school youth must be pre-tested within 60 days from first youth program service. If they have not been pre-tested, it will result in less time for the youth to achieve a literacy/numeracy gain since gains must occur within one year from first youth program service.

If during the year an out-of-school youth participant acquires a job or enrolls back into school, will this impact a program’s performance with regards to the literacy/numeracy measure? Is there a possibility of excluding the participant from the measure? And if not, why not, since obtaining employment or returning to school are the ultimate goals of the program?

No. Once youth participants are in the measure, they remain there. When someone enters the job market or returns to school, we still must monitor his/her progress towards improving any skills deficiencies identified during the assessment process. Skills deficiencies will impact an individual’s ability to advance in the workplace and we need to make sure youth are strengthening their reading and math skills so they are able to compete in the workplace.

If you have a youth ages 19-21 that is identified as a veteran, do you count the participant in the older youth or the adult performance group?

A youth between the ages of 19 and 21 who is identified as a veteran should be accessed with respect to the services needed to overcome any existing barriers to employment. If services for older youth are most appropriate, the individual should be served by the youth program and included in the youth program’s performance calculations. If adult services are more appropriate, the individual should be served by an adult program and included in that program’s performance calculations. The individual’s veteran status is a personal characteristic that should be recorded by either the youth or adult program. The fact that the youth in this instance is a veteran should not, by itself, be the basis for assignment to adult services or for inclusion in adult performance calculations.

If a youth has a gap in service and does not return to the program what is the exit date?

The exit date is the date of the last service.

What changes have been made to the current 7 youth measures and when will those changes take effect? For instance, will the definition of advanced training/occupational skills training in TEGL 17-05 be applied to the Older Youth Credential Rate and, if so, when?

The 7 WIA youth statutory measures remain intact for PY 2005 and PY 2006. However, beginning PY 2006, some definitional changes will occur with respect to the older youth credential measure and the definition of advanced training/occupational skills training. These changes will not be retroactive, however. Please refer to Attachment D of TEGL 17-05, which specifies the changes that will be effective for participants who commence services after July 1, 2006.

What is needed to document a youth with a disability?

WIA programs should work with their local partners to determine what documentation is acceptable. Workforce professionals will need to work with partner agencies to help determine and document disability.

Do supportive services count as a follow-up service for youth?

Supportive services for youth can be counted as follow-up services if they are provided as part of the required 12-month follow-up services.

When is school status determined and does it change?

School status is determined at date of first youth service and is not changed even if the individual’s status changes during the course of program participation.

What's the relationship between the “date of first youth service” for the Literacy/Numeracy common measure and the “date of participation” for the Younger Youth Skill Attainment Rate?

The methodology between the two measures is different in the sense that achievement of the Younger Youth Skill Attainment measure is based on when the “goal was set,” not the “Date of Participation.” The Literacy/Numeracy measure looks at one-year achievement based on the “Date of First Youth Service.” We understand the confusion, which is why we put a specific date of first youth service in the methodology for the Literacy/Numeracy measure. Also, we intentionally wanted to keep the specifications for the current WIA Youth measures consistent with how states/local areas are implementing them now. We have looked at historical WIASRD data submitted by states over the last three full program years, and have found only 1,400 records where states indicate that the youth participant was co-enrolled in the adult program. Even then, it might be challenging to determine whether the adult program was the “program of first service” for these customers or vice versa.

Let’s say I provide school status information when I become a Wagner-Peyser participant, and I am in high school. Six months later I become a WIA youth and no longer am in high school. Am I considered an in-school or out-of-school youth for WIA? This affects performance and could be significant.

See previous answer. This particular element impacts performance and should reflect the school status of the individual at the time of participation in the youth program.

How is the age of youth calculated? In the validation software, it’s calculated based on date of first youth service. The TEGL says the youth’s age is calculated based on the date of participation but the example in the TEGL implies date of first youth service. This relates to Younger Youth Skill Attainment as well.

The reporting logic in the WIA Quarterly/Annual Reporting instructions, which can be found at www.doleta.gov/performance, clearly outlines how program performance groups for youth (older, younger, all youth 14-21) are established. The reporting logic uses the “Date of First Youth Service” to determine the age of youth for calculations.