TEGL_14-18_Attachment-4_Acc.pdf

ETA Advisory File Text

Attachment 4 JVSG -1- Attachment 4 Jobs for Veterans State Grants I. Introduction This attachment describes the program-specific details of the performance accountability guidance for the Jobs for Veterans State Grants JVSG program. Please note that the Department of Labor Department or DOL has made a concerted effort to align the performance accountability guidance of its various workforce programs. In particular the Veterans Employment and Training Service VETS is statutorily required to establish and implement a comprehensive performance accountability system to measure the performance of employment service delivery systems including the Disabled Veterans Outreach Program DVOP specialists and Local Veterans Employment Representatives LVERs providing employment and placement services. This performance accountability system must be consistent with state performance accountability measures applicable under Workforce Innovation and Opportunity Act WIOA section 116 b at 38 U.S.C. 4102A f . This attachment describes the convergence of JVSG s performance accountability measures with the WIOA measures since July 1 2016 and highlights areas where JVSG differs from the shared DOL performance guidance described in the main body and appendices of this Training and Employment Guidance Letter TEGL . Note that references in this attachment to section numbers of this guidance refer to the body of the TEGL. II. Differences from Shared Guidance 1. Primary Indicators of Performance. A. Employment Rate 2nd Quarter After Exit The percentage of participants who are in unsubsidized employment during the second quarter after exit from the program. The JVSG program applies this indicator as it is described in Appendix I to this guidance with the operating parameters and methodology described there. B. Employment Rate 4th Quarter After Exit The percentage of participants who are in unsubsidized employment during the fourth quarter after exit from the program. The JVSG program applies this indicator as it is described in Appendix I to this guidance with the operating parameters and methodology described there. C. Median Earnings 2nd Quarter After Exit The median earnings of participants who are in unsubsidized employment during the second quarter after exit from the program. The JVSG program applies this indicator as it is described in Appendix I to this guidance with the operating parameters and methodology described there. D. Credential Attainment The JVSG program does not report on this indicator. E. Measurable Skill Gains The JVSG program does not report on this indicator. Attachment 4 JVSG -2-F.Effectiveness in Serving Employers The percentage of program participants who exit and are employed with the same employer in the second and fourth quarters after exit. The JVSG program applies this indicator as it is described in Appendix I to this guidance with the operating parameters and methodology described there. 2.Categories of Enrollment Reportable Individual Participant Date of Program Exit A.Reportable Individual This category does not apply to the JVSG program. B.Participant The JVSG program defines a participant as an individual who has received a JVSG-funded service in WIOA from a Disabled Veteran Outreach Program DVOP specialist after satisfying all applicable programmatic requirements for the provision of services such as an eligibility determination. It is still required for DVOP specialists to provide individualized career services when available. C.Exit Consistent with section 7 of this guidance the date of exit from the program is the last date of service. Specifically The date of exit cannot be determined until 90 days have elapsed since the participant last received services furthermore there must be no future planned services scheduled to provide the participant with future services. At that point the date of exit is applied retroactively to the last date of service. For determining whether 90 days have elapsed since the participant last received services receipt by the participant of any self-service information-only services or activities or follow-up services regardless of the providing program do not delay postpone or affect the date of exit. Because the date of exit is retroactive to the last date of service follow-up services may begin immediately following the last date of service if it is expected that the participant will not receive any future services other than follow-up services. Provision of follow-up services does not extend the date of exit.1 PIRL data element 901 Date of Program Exit is used to collect and report the date of exit. For exit-based performance measures the quarter for collecting follow-up data is determined by the quarter in which the date of exit occurs. For example if the date of exit is between January 1st and March 31st the first quarter after exit would be April 1st through June 30th. 1 Note that JVSG does not provide follow up services. This provision is still applicable in the scenario where a participant in a State that has a common exit policy that includes the JVSG program is co-enrolled in a program that does provide follow up services. Attachment 4 JVSG -3-D.Common Exit As stated in section 7 of this guidance while the Department encourages states that implement common exit policies to include DOL-administered non-core programs as within the scope of the state s common exit policy the Department also recognizes that the decision of whether to retain or develop a common exit policy and the scope of the such policy is ultimately left to the states subject to the requirements for common exit stated in section 7 of this guidance. Grantees should be aware that co-enrollment without common exit may result in multiple exit dates based on the service end dates individual programs. If the state s common exit policy includes JVSG then a JVSG participant will not exit until the last date of service in all programs included in the common exit policy. E.Co-Enrollment Regardless of whether a state has adopted a common exit policy the Department strongly encourages the co-enrollment of JVSG participants in the title III Wagner-Peyser Act Employment Service ES program2 to ensure more efficient service delivery compliance with reporting requirements.3 States may elect to co- enroll all JVSG participants in the title III ES program. Under WIOA the required data elements for reporting outcomes for JVSG participants are the same as for participants in the title III ES program. The data submission requirements for JVSG participants are found in the DOL-only Participant Individual Record Layout PIRL which is shared by other various DOL workforce programs including the core programs under title I and title III of WIOA. 3.Self-Service and Information Only Services and Activities This does not apply to the JVSG program. 4.Period of Participation The JVSG program is aligned with the title III ES program. The JVSG program adopts the definition of period of participation as stated in section 9 of this guidance. Reporting Unique Participants The Department has determined it necessary to calculate the unique number of participants being served each program year by the JVSG program. To meet this requirement JVSG grantees must 2 Although this program is authorized under the Wagner-Peyser Act it was amended by title III of WIOA and is a core program of WIOA as defined at WIOA section 3 12 . Throughout this guidance it is referred to as the title III Employment Service. 3 The Department acknowledges that this statement is inconsistent with Attachment II to TEGL 16-16 One-Stop Operations Guidance for the American Job Center Network which described co-enrollment and common exit between the JVSG program and the title III ES program as a requirement. Attachment II to TEGL 16-16 will be revised to describe co-enrollment between JVSG and the title III ES program as a strongly encouraged practice but not as a requirement. Attachment 4 JVSG -4- 1. d evelop systems to track multiple periods of participation within a program year 2. calculate a unique count of individual participants across multiple periods of participation in any given program year and 3. either a establish a unique identification number that will be retained by the same individual across the DOL-administered title I and title III core programs or b submit data for JVSG participants under the full PIRL such that the record submitted would show an individual s participation the JVSG program as well as all DOL-administered core programs. The Department notes that the requirement to either submit a unique identification number or to report under the full PIRL is integral to its analysis of whether veterans and eligible spouses are receiving priority of service for receipt of employment training and placement services. See TEGL 10-09 Implementing Priority of Service for Veterans and Eligible Spouses in all Qualified Job Training Programs Funded in whole or in part by the U.S. Department of Labor DOL https wdr.doleta.gov directives corr doc.cfm DOCN 2816. TEN 15-10 Protocol for Implementing Priority of Service for Veterans and Eligible Spouses in all Qualified Job Training Programs Funded in whole or in part by the U.S. Department of Labor DOL https wdr.doleta.gov directives corr doc.cfm DOCN 2954 . 5. Workforce Integrated Performance System WIPS and How to Functionally Report States as JVSG program grantees report using WIPS to submit individual records based on the PIRL for JVSG program participants. In addition to the guidance provided in section 10 of this TEGL States must comply with the following guidance specific to JVSG. States must either submit all JVSG-funded participant records into the Workforce Integrated Performance System using one of the WIPS schemas allowable for JVSG which can be found on ETA s WIPS resource page https doleta.gov performance wips . Note that JVSG participant records are no longer submitted as a subset of participant records for title III ES. After the data file is submitted and all errors have been corrected a report specific to participant services provided by JVSG-funded staff will be generated. This report will be automatically formatted for uniformity with the other DOL-administered programs that use the PIRL OMB 1205 -0521 form number ETA-9173 . Grantees are required to submit JVSG individual record data files each calendar year on a quarterly basis. 6. State Annual Report Narratives This does not apply to the JVSG program. However the quarterly reporting requirements for JVSG grantees include the submission of quarterly narrative reports Manager s Report on Services to Veterans and Technical Performance Narrative TPN as described in Veterans Program Letter VPL 01 -15 Jobs for Veterans State Grants Recurring Report Requirements. Given these existing Attachment 4 JVSG -5- reporting requirements DOL does not require JVSG grantees to additionally submit a separate annual narrative report. 7. Eligible Training Provider ETP Performance Reporting This does not apply to the JVSG program. 8. Pay-for-Performance Reporting This does not apply to the JVSG program. 9. Quarterly Narrative Reports for Discretionary Programs This does not apply to the JVSG program. As stated above the quarterly reporting requirements for JVSG grantees includes the submission of quarterly narrative reports Manager s Report on Services to Veterans and Technical Performance Narrative TPN as described in VPL 01-15 . 10. Use of Social Security Numbers and Direct Wage Match for Performance Reporting In accordance with section 15 of this guidance JVSG program grantees are directed to request participants SSNs and to report corresponding wages for the quarter required to the Department through the DOL-only PIRL. While states as JVSG program grantees are required to request participants SSNs participants cannot be denied services if they choose to not disclose an SSN. 11. Supplemental Wage Information As described in section 16 and Appendix VI of this guidance JVSG program grantees may collect and document supplemental wage information to calculate the employment- related primary indicators of performance. Supplemental wage information is the only means for grantees to report exit-based outcomes each of which has an employment- related component for those participants who do not provide SSNs and frequently the only means to report such outcomes for participants for whom wage record data is not predicted to be available. Additional details regarding circumstances for collecting supplemental wage information and methods and procedures for doing so are provided in Appendix VI of this guidance. III. Unique Features of JVSG JVSG Policies under WIOA. Under the Workforce Investment Act WIA DVOP specialists were directed to provide higher rates of intensive services to eligible veterans. VPL 03-14 Jobs for Veterans State Grants JVSG Program Reforms and Roles and Responsibilities of American Job Center AJC Staff Serving Veterans Attachment 4 JVSG -6- https www.dol.gov vets VPLS VPLDirectory.html TEGL 19 -13 Jobs for Veterans State Grants JVSG Program Reforms and Role s and Responsibilities of American Job Center AJC Staff Serving Veterans https wdr.doleta.gov directives corr doc.cfm DOCN 7239 . This requirement continues under WIOA although the terminology of the services delivered is slightly altered . Instead of core and intensive services used under WIA WIOA uses the terms basic career services and individualized career services . It is these individualized career services that DVOP specialists are to provide as appropriate . For more information on these service types please refer to the body of the accompanying guidance as well as TEGL 10 -16 Change 1 Attachment 7. Additional guidance is being developed covering responsibil ities for DVOP specialists and LVERs. Performance Management and Target Setting . WIOA s ection 116 b 3 requires that states negotiate performance goals on the primary indicators of performance for the WIOA core programs with DOL and the Department of Edu cation and that a statistical adjustment model be employed in this negotiation process. See TEGL 26 -15 Negotiating Performance Goals for the Workforce Innovation and Opportunity Act WIOA Title I Programs and the Wagner -Peyser Employment Service as ame nded by Title III for Program Year PY 2016 and PY 2017 https wdr.doleta.gov directives corr doc.cfm DOCN 9363 . The Department also require s state s as JVSG program grantees to negotiate performance targets for the following primary indicators of performance with VETS Employment in the 2 nd Quarter After Exit Employment in the 4 th Quarter After Exit and Median Earnings in the 2 nd Quarter After . More specific guidance on this topic will be forthcoming and will include how to use the statistical adjustment model to help negotiate performance goals timeline for negotiations in PY 201 9 and threshold to be considered passing an indicator. VETS may also develop program -specific performance targets for JVSG -funded staff. Uniform National Threshold Entered Employment Rate UNTEER . In accordance with statutory requirements the Department has established a uniform national threshold entered employment rate UNTEER achi eved for veterans and eligible persons served by the state employment service delivery systems . 38 U.S.C. 4102A c 3 B . The regulations implementing the UNTEER requirements are applicable to all State agencies that are recipients of Wagner Peyser Sta te Grants and or Jobs for Veterans State Grants. 20 CFR 1001.160 -1001.167. For additional information regarding the UNTEER see VPL 03 -15 Applying the Uniform National Threshold Entered Employment UNTEER to States Program Year PY Veterans Entered Employment Rates VEERS to Determine Compliance and Identify Need for Remedial Action https www.dol.gov vets VPLS VPLDirectory.html and the corresponding TEGL 2 -13 https wdr.doleta.gov directives corr doc.cfm docn 7064 . Participant - level data reported through WIPS will serve as the basis for this calculation. The latest UNTEER calculations can be found at https www.dol.gov vets grants state jvsg.htm .