Joint Comments from New York, Missouri and Massachusetts
Our comments in this section track the Workforce Innovation and Opportunity Act—
Participant Individual Record Layout (ETA 2015-00007-0009).
Priority concerns with Workforce Innovation and Opportunity Act – Participant
Individual Record Layout (PIRL)
No. 100 - Unique Individual Identifier
Is it required that all partners use the same
unique identifying number for the same
client?
No. 202 - Individual with a Disability
Would learning disabilities meet this
definition? We would expect that it would.
No. 704 - Low Levels of Literacy
What would determine problems
concerning levels of proficiency in terms of
functioning on the job for those who don’t
have a job? If they have a job, is it
assumed that they have the necessary level
of proficiency?
No. 705 - Cultural Barriers
Adult education providers will need
guidance on how to identify these
participants. For instance, what counts as
a “practice”?
No. 500 - Migrant and Seasonal
Farmworker
Many migrant fruit pickers go back to their
home country in the off-season. Will that
action still comply with the definition?
Status
No. 601 - Exhausting TANF Within 2
Years
(Part A Title IV of the Social Security
Act)
How will Title II recipients access this
data?
No. 704 - Single Parent
How is primary responsibility for
dependent children determined? If it is the
legal determination, how is that data
Page 1 of 12
accessible?
No. 410 - Highest School Grade
Completed
Are there foreign country equivalents to
some of these categories that would be
counted?
While many countries issue HS diplomas,
they are not equivalent to a US diploma.
Are they counted regardless?
No. 411 - School Status at Participation
Are there foreign country equivalents to
some of these categories?
No. 803 - Basic Skills Deficient
For part (b): What would determine
problems concerning levels of proficiency
in terms of functioning on the job for those
who don’t have a job? If they have a job, is
it assumed that they have the necessary
level of proficiency?
When the limit of 8th grade equivalent is
indicated, does that include 8.0 through
8.9?
No. 900 - Date of Program Entry
Within 677.150 it says, “For the AEFLA
program, reportable individuals who have
been determined eligible and who have
completed at least 12 contact hours in an
adult education and literacy activity under
AEFLA would be considered participants
and, thus, be included in performance
calculations. Does this mean that programs
will have to determine the specific date by
which a participant had reached his/her
12th hour of attendance?
No. 971 - Exclusionary Reasons
Should “98 = Retirement” be added to the
list of Code Values? The Data Element
Definitions/ Instructions for this item
speak of retirement only in terms of an exit
Page 2 of 12
reason. Will programs now be required to
collect information related to exit reason
on every participant? If so, what should
programs do to collect and report this
information in cases where participants do
not provide their exit reason prior to
ceasing their use of the services?
The statement “Record 00 if the participant
exited for a reason other than one of the
conditions listed above” implies that the
code values correspond only to exit
reasons. Should participant records for
those who have not exited services because
the services they received were offered
within correctional settings receive code
values of 01?
No. 1200 - Received Training
While training may lead to a credential, to
be counted in this category, does the
participant have to achieve the credential?
No. 1300 - Date Enrolled in Education
or Training Program Leading to a
Recognized Postsecondary Credential
or Employment During the Program
What criteria determine a “Recognized
Postsecondary Credential”?
No. 1301 - Enrolled in Secondary
Education Program
Does the student’s assessment gauge the
enrollment into Secondary Education
Programing (9.0 – 12.9) for adult education
students?
No. 1501 - Type of Employment Match
1st
Quarter After Exit Quarter
This mentions, “If participants are not
found in the wage records, grantees
may then use supplemental data
sources.” This corresponds to a code
value of 6. However, there seems to be
a contradiction since the Data Element
Specifications document mentions for
Report Items #14, 16, 17, 19, 27, & 29
that in lieu of wage records only “5 =
Other Administrative Wage Records”
Page 3 of 12
can be used to count employment for
those outcomes.
No. 1700 - Type of Recognized
Credential
Clarification is needed on what constitutes
a certificate. Is this a state decision?
No. 1802 Date of Most Recent
Adult educational programs offering
Measurable Skill Gains: Secondary/Post- instruction at the secondary level do not
Secondary Transcript/Report Card
typically issue transcripts or report cards.
Could anything else be used in lieu of the
date related to a transcript or report card
for the purposes of recording the value
related to this data element?
No. 1802 Date of Most Recent
Measurable Skill Gains: Training
Milestone
No. 1803 - Date of Most Recent
Measurable Skill Gains: Skills
Progression
No. 1804 - Date of Most Recent Career
Service
Where will adult education programs
receive this information? How will training
providers notify Adult education programs
when participants achieve training
milestones?
From where and how do adult education
programs collect this information?
Page 4 of 12
Our comments in this section track Data Element Specifications ETA-2015-0007-0006.
Priority concerns with Workforce Innovation and Opportunity Act – Data Element
Specifications
In addition to the specific concerns enumerated below, we want to express one
overarching concern: The phrase “Report period” appears throughout the Data Elements
Specifications but is not defined anywhere in the document. The document should be
revised to include dates that show the beginning and end of the Report period.
No. 10 - Percent Co-Enrolled
How would our state’s adult education data
system identify Funding Stream?
No. 12 - Participants Served
Will adult education students have to meet
a certain threshold of attended hours, for
example >=12, and if so, do those hours
need to be instruction or any services?
No. 13 Participants Exited (Current PY)
The term “Funding stream” is not defined
in the Participant Individual Record
Layout. The document should clarify that
“Funding Stream” means each Title.
Nos. 14-19 Employment Rate Numerators, Denominators, and
Rates
We agree with not including “not in the
labor force” in all employment rates. Plain
Text should indicate “excepting those ‘not
in the labor force.’”
The median earnings calculation should
Page 5 of 12
No. 26 - Median Earnings
not include participants who are “not in the
labor force” because doing so might
artificially deflate median earnings, if such
data exist. We suggest adding wording to
the Plain Text to read “excepting those not
in the labor force.” We also suggest
changing the technical specifications to
read: “The value of 2nd quarter after exit
wage that is the midpoint between the
value of the lowest wage reported and the
value of the highest wage reported for the
Unique Records where (Funding Stream)
and (Employment Status at Program Entry
is < 3) AND (Date of Program Entry is not
null) AND the Date of Exit is within the
reporting period) and (Exclusionary
Reasons is null or …” We believe that if a
participant is deemed to be “not in the
labor force” and is not used for
employment measures, he/she should not
be used for the median earnings measure.
This raises a technical question: If the
Exclusionary Reasons for a participant fall
into one of the categories corresponding to
those included for this measure (is null, 00
or 98) but the data match does not yield a
wage for the second quarter, should the
income be considered as “missing” or be
recorded as 0?
No. 27 Credential Rate Numerator
It appears as though the parentheses do
not correctly indicate the order of
operations regarding the technical
specification but they are critical to
understanding the meaning of the
formulas. We cannot comment until this is
corrected or clarified.
ENROLLED IN EDUCATION OR TRAINING
PROGRAM LEADING TO A RECOGNIZED
POSTSECONDARY CREDENTIAL OR
EMPLOYMENT OR ENROLLED IN
SECONDARY EDUCATION PROGRAM is
Page 6 of 12
mentioned in two places. In one of them, a
code value of 1 or 2 is specified, however,
this element does not have a corresponding
code value within the PIRL. Are the code
values for this element incorrectly stated in
one or both of these places?
It appears to need to be changed to field
1200 – Received Training which has “1”
and “2” options, but if so, “2” is not
considered a “credential.” We cannot
comment on the technical specifications
or the comparison to the Plain Text
until a full description is available.
Another Technical specification issue: we
believe the Highest School Grade
Completed should be < 13 not 12. Thirteen
(13) is the high school diploma. If we
exclude high school seniors we will be
eliminating important participants. We
believe this should read Highest School
Grade Completed > 8 and < 13 or use 1302
– Enrolled in Secondary Education
Program.
Would ABE participation in classes at 9th
Grade Level Equivalent or Higher count as
ENROLLED IN SECONDARY EDUCATION?
Would the DATE ATTAINED DEGREE OR
CERTIFICATE OR CREDENTIAL if within
the dates of participation have to be within
the reporting period to be counted or
would a date value from this variable such
as one from several years back still count if
within the participation period?
Two examples where this
clarification is needed:
Example: A student earned their
high school equivalency during their
participation in an adult education
program in 2007. This same
Page 7 of 12
student left and then came back to
the program in 2012 receiving ESOL
instruction and then exits in 2017.
Can we count the outcome of
credential attainment for this
student during the 2017 federal
report if they were employed in one
of the four quarters following their
program exit?
Second example:
A student exits in May 2017 but had
not yet earned their high school
equivalency. This student attained
employment during the first quarter
following their exit and shows
wages for that quarter but then
loses that job in August 2017 and
shows no wages for the second,
third, or fourth quarters. This
student receives their high school
equivalency in December 2017 but
never goes back to work. Will their
high school equivalency outcome
count?
No. 28 - Credential Rate Denominator
ENROLLED IN EDUCATION OR TRAINING
PROGRAM LEADING TO A RECOGNIZED
POSTSECONDARY CREDENTIAL OR
EMPLOYMENT OR ENROLLED IN
SECONDARY EDUCATION PROGRAM is
mentioned in two places. In one of them, a
code value of “1” or “2” is specified.
However, this element does not have a
corresponding code value within the PIRL.
Are the code values for this element
incorrectly stated in one or both of these
places? Would ABE participation in
classes at 9th Grade Level Equivalent or
Higher count for this?
If the answer is yes, is the level determined
by the assessment/curriculum/program
level-design?
Page 8 of 12
It appears to need to be changed to field
1200 – Received Training which has “1”
and “2” options, but if so, “2” is not
considered a credential.
No. 29 - Credential Rate
ENROLLED IN EDUCATION OR TRAINING
PROGRAM LEADING TO A RECOGNIZED
POSTSECONDARY CREDENTIAL OR
EMPLOYMENT OR ENROLLED IN
SECONDARY EDUCATION PROGRAM is
mentioned in two places. In one of them, a
code value of “1” or “2” is specified.
However, this element does not have a
corresponding code value within the PIRL.
Are the code values for this element
incorrectly stated in one or both of these
places? Would ABE participation in
classes at 9th Grade Level Equivalent or
Higher count for this rate?
It appears to need to be changed to field
1200 – Received Training which has “1”
and “2” options but, if so, “2” is not
considered a “credential.”
Would the DATE ATTAINED DEGREE OR
CERTIFICATE OR CREDENTIAL, if within
the dates of participation, have to be within
the reporting period to be counted or
would a date value from this variable such
as one from several years back still count if
within the participation period?
Furthermore, does the education provider
or the participant report the attainment of
credential? What documentation, if any is
required?
No. 30 - Measurable Skill Gains Numerator
ENROLLED IN EDUCATION OR TRAINING
PROGRAM LEADING TO A RECOGNIZED
POSTSECONDARY CREDENTIAL OR
EMPLOYMENT OR ENROLLED IN
SECONDARY EDUCATION PROGRAM is
mentioned within part of the Technical
Specifications, however no value is given
after the = sign.
Page 9 of 12
Also, should there be an = sign after
EMPLOYMENT in the same section and a
code value there as well?
Also, should the word DATE appear before
“ENROLLED IN EDUCATION…” and the
words ”DURING THE PROGRAM” at the end
of the name for the data element to
correspond to what is given in PIRL?
Relevant example:
A student advances from the “High
Intermediate ABE” Educational
Functioning Level to “Low Adult
Secondary Education” Educational
Functioning Level according to pre
and post tests during 2017 and thus
has a Measureable Skill Gain. This
same student shows a pretest score
of “High Intermediate ABE” at the
beginning of program year 2018. If
this student post tests at the “Low
Adult Secondary Education”
Educational Functioning Level,
would a Measurable Skills Gain
count for that student in 2018?
Although the Plain Text Specifications
mention “five types of gains”, only four of
them are specified by the data elements
appearing within the Technical
Specification. Should another data
element be included within the Technical
Specifications to bring the total number of
gain types up to five? Would this
additional data element need to be also
defined in the PIRL and would it need to
specifically account for what is stated as
“2) high school diploma or equivalent”
Page 10 of 12
within the Plain Text Specifications?
No. 30-32 Measurable Skill Gains Denominator
Symbols that usually follow data elements
such as =, =>, =<, >, or < and code values
do not appear following
ENROLLED IN EDUCATION OR TRAINING
PROGRAM LEADING TO A RECOGNIZED
POSTSECONDARY CREDENTIAL OR
EMPLOYMENT. These data elements do
not have a field reference in the PIRL. The
same is true for ENROLLED IN
SECONDARY EDUCATION PROGRAM.
We cannot comment on technical
specifications or the comparison to the
Plain Text until a full description is
available. It appears to need to be changed
to field 1200 – Received Training which
has “1” and “2” options but if so, “2” is not
considered a “credential.”
No. 33, 34 – Age bracket 14-15 and 16-18
Why is the length of the age range different
from the others?
No. 50 - Low-income Individuals
What is meant by “youth living in a highpoverty area” in the PIRL definition (No:
702)?
No. 51 - Individuals With Disabilities, Including Youth
Are learning disabilities included in this
cohort? What is definition of “mental
impairment that substantially limits one or
more of the person’s major life activities”,
how is that decision supported?
(PIRL No. 202) Does this cohort include
developmentally disabled persons?
No. 52 - Ex-offenders
Data element “Offender” does not align
with same name in PIRL. Is this selfreported?
No. 53 - Homeless Individuals or Runaway Youth
Data element “Homeless Individual and/or
Page 11 of 12
Runaway Youth” does not have the same
exact name shown for it in PIRL
No. 55 - English language learners, Low Levels of Literacy,
Cultural Barriers
Adult education providers request
guidance on how to identify Cultural
Barriers for these participants. For
instance, what counts as a “practice”?
For Low Levels of Proficiency: What would
determine problems concerning levels of
proficiency in terms of functioning on the
job for those who don’t have a job? If they
have a job, is it assumed that they have the
necessary level of proficiency?
No. 56 - Migrant and seasonal farmworkers
FARMWORKER STATUS from the Technical
Specifications does not have the same exact
name shown for it in PIRL.
No. 58 - Single parents (including single pregnant woman)
Within the PIRL definition: How is primary
responsibility for dependent children
determined? Can the other living parent
also in some way be considered to share in
that primary responsibility?
Documentation needed?
Example: An adult education student has
sole responsibility for dependent(s) two
weekends a month: Does sole
responsibility occurring over short term
periods such as weekend count in some
way as a primary responsibility?
Finally, there is no formulation for Employer Satisfaction.
Page 12 of 12