The U.S. Department of Education’s Office of Special Education and Rehabilitative Services (OSERS) and Office of Career, Technical, and Adult Education (OCTAE) invited the public to submit comments and recommendations to help implement the Workforce Innovation and Opportunity Act (WIOA), signed by President Obama on July 22. This new law seeks to maximize opportunities for youth and adults, with and without disabilities, to succeed in postsecondary education and in high-skill, high-wage, high-demand jobs in the 21st century economy. The Departments specifically sought comments to assist in the process of implementing the amendments to the Rehabilitation Act of 1973 that were made by Title IV of WIOA and of the new version of the Adult Education and Family Literacy Act (AEFLA), in Title II of WIOA.

Below is Talbot Consulting’s response:

Talbot Consulting is an independent, education management consulting practice providing innovative solutions to community-based organizations and Pre-K-12 schools. Much of our recent work has focused on the academic and non-academic needs of off-track youth. For these reasons, we provide the following comments – focused specifically on Sections 116 and 171 – of the federal Workforce Innovation and Opportunity Act (WIOA). We believe our recommendations, if adopted, would strengthen the educational integrity and accountability of secondary and adult education programs.

While we applaud the Department for requiring states to align adult education standards with the Elementary and Secondary Education Act of 1965, we do not believe this provides sufficient guidance to alternative education high schools with career with technical education (CTE) programs, and to adult education programs, like YouthBuild. However, we believe, as proposed the WIOA is still heavily compliance- rather than accountability-focused. The WIOA should yield not just increased numbers of trained participants, but also increased numbers of trained participants with content and skill knowledge required of a 21st century economy for persistent employment to span a lifetime. Therefore, we recommend the following:

  • Require states to hold alternative education high schools with CTE programs and adult education programs to administer Common Core State Standards (CCSS)-aligned assessments to baseline and benchmark content program participants’ content knowledge and skills. There are a number of commercial assessments that are appropriate for this student population. While we do not endorse any one product, for example purposes states may consider the NWEA MAP, Renaissance Learning’s Accelerated Reader and Math assessments, and so forth.
  • To ensure adult education students are receiving rigorous instruction, require states to phase out administration of the Test of Adult Basic Education (TABE). The TABE is not CCSS-aligned, and does not measure 21st skills required for college and career readiness.
  • “Measurable skill gain” should include at least one grade-level of increased performance within a program cycle based on the state’s department of education-certified CCSS-aligned baseline and benchmark assessment. While we believe job-readiness skills are important, 21st century employers seek highly skilled labor. This means students graduating from CTE and adult education programs must be able to read and write well, and complete algebraic equations.
  • We applaud the Department for emphasizing the importance of connecting job seekers and workers with the needs of employers and the regional economy. However, we are disappointed that the department stopped short of issuing competitive sub-grant opportunities for states that create school-to-work pipelines in high growth industries. Current examples include the P-Tech program referenced in President Obama’s 2013 State of the Union Address. We highly recommend that the Department consider the inclusion of similar pipeline programs for young people ages 16-24 to ensure increased numbers of disadvantaged populations have access to college and career leading to a life-long living wage. We believe this will best serve employers and program participants and yield increased numbers of tech-skilled workers.
  • We recognize that the aforementioned recommendation would mean an increase in the duration of the typical adult education program. However, we believe America’s high schools should not be the only provider of CTE or school-to-work programs leading to careers in high-growth industries. There are many youth development and workforce training programs poised to offer these educational services (e.g., YouthBuild, Urban League, National Council of LaRaza, and many others). To do so, they would need funds for capacity-building to increase academic rigor and amend existing higher education and employer partnerships.
  • The aforementioned comment leads to another recommendation: most workforce training and adult education programs hire instructional staff who have not been certified to teach secondary education. As such, many have not received Common Core training. The lack of rigor and academic accountability in too many workforce training and GED programs is directly related to the inadequate pre- and in-service training of their instructional staffs. We believe this will prove to be a significant challenge and drag on the performance of workforce training programs nationwide – particularly as states adopt the new High School Equivalency Exam over the former GED, and 21st century industries require higher skills.
  • We are disappointed that the proposed amendments to the WIOA does not require states to increase the number and quality of CTE, school-to-work and/or workforce training programs within juvenile detention and/or department of corrections (DOC) centers. It is a well-known fact that the majority of incarcerated youth do not have a high school diploma. Talbot Consulting believes the omission of DOC education programs within the WIOA supports recidivism and provides an access barrier to large numbers of off-track youth.

We recommend the following timeline for implementing the aforementioned recommendations:

  • Years 1-2: statewide planning for strategies to increase the academic rigor and accountability of adult education and workforce training programs. Planning teams should include representation from LEAs, DOCs, WIBs, community-based organizations, employers, public/private funders, and individuals/organizations with demonstrated experience in evaluating CTE, workforce and/or school-to-work programs. The plan should include strategies for 1) increasing academic rigor; 2) increasing the pre-service preparation, ongoing development and certification requirements of instructional staff; 3) phasing out the TABE and/or similar assessments in favor of adopting CCSS-aligned tests; 4) creating cross-sector public and private agency collaboration to improve the educational and workforce readiness of program participants, and 5) determining how the state and programs will measure success.
  • Years 3-4: begin implementing the state’s strategic plan.

In sum, Talbot Consulting recommends the Department refocus the WIOA to include 1) more requirements for cross-sector agency collaboration; 2) increased regulation for education program rigor, instructional staff, and accountability; 3) the introduction of pilot pipeline programs similar in nature to New York’s P-Tech program, but targeting out-of-school youth and adult education program participants; and 4) provide requirements, timelines and milestones for states to align workforce training programs to states’ departments of education student performance measures.



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