TEGL 23-19 Change 3 (Accessible PDF)(0001).pdf

ETA Advisory File Text

EMPLOYMENT AND TRAINING ADMINISTRATION ADVISORY SYSTEM U.S. DEPARTMENT OF LABOR Washington D.C. 20210 CLASSIFICATION OWI CORRESPONDENCE SYMBOL OPDR DATE November 25 2025 RESCISSIONS TEGL 23-19 Change 1 TEGL 23-19 Change 2 EXPIRATION DATE Continuing ADVISORY TRAINING AND EMPLOYMENT GUIDANCE LETTER NO. 23-19 CHANGE 3 TO STATE AND LOCAL STAKEHOLDERS IN THE WORKFORCE INNOVATION AND OPPORTUNITY ACT STATE WORKFORCE AGENCIES STATE WORKFORCE ADMINISTRATORS STATE WORKFORCE LIAISONS H-1B SKILLS TRAINING GRANT PROGRAM RECIPIENTS INDIAN AND NATIVE AMERICAN PROGRAM INAP GRANT RECIPIENTS JOB CORPS CONTRACTORS JOBS FOR VETERANS STATE GRANTS JVSG GRANT RECIPIENTS STATE MONITOR ADVOCATES NATIONAL FARMWORKER JOBS PROGRAM NFJP GRANT RECIPIENTS NATIONAL DISLOCATED WORKER GRANT RECIPIENTS DWG STATE APPRENTICESHIP AGENCIES OFFICE OF APPRENTICESHIP OA STATE DIRECTORS APPRENTICESHIP GRANT RECIPIENTS OA-MANAGED REENTRY EMPLOYMENT OPPORTUNITIES REO GRANT RECIPIENTS SENIOR COMMUNITY SERVICE EMPLOYMENT PROGRAM SCSEP GRANT RECIPIENTS YOUTHBUILD GRANT RECIPIENTS FROM LORI FRAZIER BEARDEN Acting Assistant Secretary SUBJECT Guidance for Validating Required Performance Data Submitted by Grant Recipients of U.S. Department of Labor DOL Workforce Programs 1. Purpose. To announce revisions to Training and Employment Guidance Letter TEGL 23- 19 Change 1 and Change 2 Guidance for Validating Required Performance Data Submitted by Grant Recipients of U.S. Department of Labor DOL Workforce Programs. This guidance prov ides information to grant recipients of the U.S. Department of Labor workforce programs including states and provides guidelines for grant recipients to use in developing procedures for ensuring the data submitted for performance reporting are valid and reliable. 2 With this issuance DOL the Department updates the guidance to align it with changes made by the Workforce Innovation and Opportunity Act WIOA Effectiveness in Serving Employers Performance Indicator final rule 89 FR 13814 Feb. 23 2024 Final Rule which took effect March 25 2024. This Final Rule defined the Effectiveness in Serving Employers primary indicator of performance as required by WIOA section 116 b 2 as Retention with the Same Employer it also clarifies what can be counted as an Educational Functional Level gain type for the Measurable Skill Gains indicator outlined in TEGL 10-16 Change 3 Performance Accountability Guidance for Workforce Innovation and Opportunity Act WIOA Core Programs issued June 11 2024. This guidance also revises source documentation in Attachment II to be consistent with Departmental guidance including TEGL 26-16 Change 1 Guidance on the use of Supplemental Wage Information to implement the Performance Accountability Requirements under the Workforce Innovation and Opportunity Act WIOA issued July 10 2025. 2. Action Requested. Please replace the PDF and Excel versions of attachments to TEGL 23- 19 Changes 1 and 2 with the revised versions attached to and posted with this advisory to ensure that the guidance properly reflects revised data validation and source documentation information for WIOA core and non-core programs. 3. Summary and Background. Summary This guidance replaces Training and Employment Guidance Letter TEGL 23- 19 Changes 1 and 2 Guidance for Validating Required Performance Data Submitted by Grant Recipients of U.S. Department of Labor DOL Workforce Programs published October 25 2022 and May 12 2023 respectively. This guidance provides clarifying language and revisions to data validation requirements specific to grant recipients of DOL workforce programs. The guidance aligns with and expands on the DOL Department of Education Joint Guidance in TEGL 07-18 Change 1 Guidance for Validating Jointly Required Performance Data Submitted under the Workforce Innovation and Opportunity Act WIOA and provides specific data validation guidance for the WIOA core programs and other DOL-funded programs not addressed in TEGL 07-18 Change 1. Background Data validation is a series of internal controls or quality assurance techniques established to verify the accuracy validity and reliability of data. Establishing a shared data validation framework across programs ensures all program data consistently and accurately reflect the performance of each grant recipient. To that end the purposes of validation procedures for both DOL-only and jointly required performance data are to Verify that the performance data reported by grant recipients to DOL are valid accurate reliable and comparable across programs Identify anomalies in the data and resolve issues that may cause inaccurate reporting Improve program performance accountability through the results of data validation efforts and Describe source documentation required for common data elements. 3 This issuance provides additional DOL-specific guidance on data validation for DOL programs for both the DOL-administered WIOA core programs and those that are not WIOA core programs referred to in this guidance as non-core programs . Non-core programs include programs authorized by WIOA as well as programs authorized by other Federal legislation. Collectively the non-core programs include Indian and Native American Program INAP under WIOA section 166 Job Corps under WIOA sections 141-162 National Farmworker Jobs Program NFJP under WIOA section 167 YouthBuild under WIOA section 171 Reentry Employment Opportunities REO under WIOA section 169 National Dislocated Worker Grants DWG under WIOA section 170 H-1B Skills Training Grant Programs authorized under section 414 c of the American Competitiveness and Workforce Improvement Act of 1998 29 U.S.C. 3224a Senior Community Service Employment Program SCSEP authorized under title V of The Older Americans Act of 1965 42 U.S.C. 3056 et seq. Apprenticeship Grants administered by the Office of Apprenticeship OA authorized by the National Apprenticeship Act of 1937 29 U.S.C. 50 and Jobs for Veterans State Grants JVSG authorized under 38 U.S.C. chapter 41. In addition the data validation requirements in this guidance also apply to the Monitor Advocate System. The Monitor Advocate System protects the standard of services provided to migrant and seasonal farmworkers MSFW under the Wagner-Peyser Act Employment Service program. Therefore as part of a WIOA core program all the requirements that apply to the Wagner-Peyser Act Employment Service for data validation will apply to the Monitor Advocate System. DOL jointly with the Department of Education issued TEGL 07-18 Change 1 Guidance for Validating Jointly Required Performance Data Submitted under the Workforce Innovation and Opportunity Act WIOA which elaborated on the data validation guidelines for performance accountability required under WIOA section 116 d 5 . This DOL-only data validation guidance fits within the framework established in TEGL 07-18 Change 1 and provides DOL grant recipients with additional details on the framework for data validation. Grant recipients must develop data validation policies and procedures consistent with the instructions in this guidance. Implementation Grantees may implement the revisions outlined in this guidance at their convenience but no later than with participants who have a start date of July 1 2026. 4. DOL Data Validation Requirements. Requirements for WIOA Core Programs and Non-Core Programs. i. WIOA Core Programs WIOA establishes performance accountability indicators and performance reporting requirements to assess the effectiveness of states and local areas in achieving positive outcomes for individuals served by the workforce development system s six core programs. WIOA core 4 programs must follow the data validation framework described in this section as well as any program-specific guidance outlined in Attachment I. ii. Non-Core Programs Non-core programs must follow the program-specific instructions and guidance related to their programs as discussed in Attachment I. Data Validation Framework. The WIOA core programs must use a data validation strategy. However these programs and the other non-core program grant recipients have the discretion to decide the specific design implementation and periodic evaluation of that strategy so long as the strategy and procedures adhere to this guidance. All core and non-core programs must collect source documentation in compliance with program- specific instructions in Attachment I and Attachment II. Data validation helps ensure the accuracy of required performance reports safeguards data integrity and promotes the timely resolution of data anomalies and inaccuracies. DOL recommends that grant recipients incorporate their data validation policies procedures and methodology into their data quality assurance process internal controls and the required monitoring policies and procedures in 2 CFR 200.328. DOL also recommends that grantees maintain independence between program or grant staff who collect and report data and those who validate reported data and source documentation. WIOA core programs must develop data validation procedures that include Written procedures for conducting data validation reviews that contain a description of the process for identifying and correcting errors or missing data which may include electronic data checks Regular data validation training for appropriate program staff DOL recommends at least annually Monitoring protocols consistent with 2 CFR 200.328 to ensure that program staff are following the written data validation policy and procedures and take appropriate corrective action if those procedures are not being followed Regular data integrity review of program data DOL recommends quarterly for errors missing data out-of-range variances in values reported and other anomalies Documentation that missing source documentation and erroneous data identified during the review process have been corrected Documentation processes for maintaining records per the Federal records retention policy which may include copies of worksheets on data elements or records reviewed frozen quarterly wage records for wage record matching used for reporting outcomes trends in common data accuracy issues error rates and corrective action efforts made after data validation reviews and Regular assessments of the effectiveness of the data validation process DOL recommends at least annually and revisions to that policy and process as needed. 5 On a quarterly basis DOL will provide grant recipients with feedback regarding their performance reports to aid in data integrity efforts and support data accuracy e.g. Quarterly Report Analysis performance scorecards etc. . The analysis will include but is not limited to a review of the data submitted anomalies and outliers and other potential data quality issues which may indicate reporting inaccuracies. Grant recipients are encouraged to both incorporate and utilize the DOL-provided analysis in their data validation processes to improve the accuracy of required reports. Data Validation Parameters. States must validate the information in annual reports for WIOA core programs each program year before submitting the reports to DOL. As noted above DOL recommends that all grant recipients engage in data validation activities on a quarterly basis to ensure their data are accurate. Establishing quarterly data reviews is a best practice for identifying and correcting errors to improve performance reporting and ensuring that the data reflects the program participants services and outcomes. DOL will not provide a specific statistical validation sampling methodology or specific data validation software but encourages grant recipients to incorporate a comprehensive random sampling methodology and procedure for reviewing the source documentation of participant files including Exiters into their data validation processes. Grant recipients should use a random sampling methodology provide a sufficient representation of records from each program and for each of the required elements as described in Attachment II. 1 Grant recipients should also consider mechanisms for ensuring that zeros blanks or null values and negative responses are accurate. Approaches could include incorporating internal edit checks outlier reports and processes for resolving any issues resulting in unreported or missing elements identified through participant file reviews. Source Documentation. In Attachment II of this guidance programs mentioned above must identify acceptable source documentation necessary to validate these selected data elements. Grant recipients may 1 require source documentation for additional program- specific data elements not included in this guidance 2 maintain supporting source documentation for data elements not included in this guidance and or 3 conduct validation on additional data elements not included in this guidance. For any additional data that grantees want to validate beyond the requirements set forth in Attachment II DOL recommends that grant recipients reduce burden by leveraging the source documentation outlined in Attachment II. Documentation of Eligibility. While the collection of source documentation for data validation will often take place at the same time as the determination of an individual s program eligibility these actions serve different purposes. Eligibility determination only needs to confirm that an individual meets the requirements of the relevant program before becoming a participant in the program. The list of source documentation outlined in Attachment II describes documents that could be used for eligibility determination. 1 Grant recipients may use publicly available calculators and tools for determining sample size based on total records 6 Reporting Requirements. Grant recipients must describe their data integrity measures data validation methodology policies and procedures as required by their individual program guidance in Attachment I. Grant recipients should contact their appropriate regional or program offices for technical assistance. Monitoring. DOL will conduct monitoring of these requirements through the appropriate regional or program office. During these reviews grant recipients can expect Federal staff to conduct monitoring activities that include but are not limited to 1 checking for data validation policies processes and procedures conform to guidance 2 verifying the grantee s compliance with its established policies processes and procedures 3 verifying if grantees are training staff and if any corrective action is needed or implemented 4 reviewing files and source documentation 5 reviewing data validation results maintained per Federal records retention policy per 2 CFR 200.334 and 6 analyzing data integrity reports generated by DOL. Reviews may result in findings or requirements for corrective action. 5. Inquiries. Please direct inquiries to the appropriate regional or program office. 6. References. Workforce Innovation and Opportunity Act Pub. L. 113-128 Government Performance and Results Act GPRA of 1993 Public Law 103-62 107 Stat. 285 Joint Rule for Unified and Combined State Plans Performance Accountability and the One-Stop System Joint Provisions Final Rule WIOA Joint Final Rule published at 81 FR 55792 Aug. 19 2016 Employment and Training Administration Workforce Innovation and Opportunity Act Final Rule WIOA DOL Final Rule published at 81 FR 56071 Aug. 19 2016 Workforce Innovation and Opportunity Act WIOA Common Performance Reporting OMB No. 1205-0526 DOL-only Performance Accountability Information and Reporting System OMB No. 1205-0521 TEGL 10-16 Change 3 Performance Accountability Guidance for Workforce Innovation and Opportunity Act WIOA Core Programs June 11 2024 TEGL 18-16 Change 2 Revisions to Training and Employment Guidance Letter 18-16 Change 1 Program Eligibility and Enrollment Guidance for the National Farmworker Jobs Program January 17 2025 TEGL 19-16 Guidance on Services provided through the Adult and Dislocated Worker Programs under the Workforce Innovation and Opportunity Act WIOA and the Wagner- Peyser Act Employment Service ES as amended by title III of WIOA and for Implementation of the WIOA Final Rules March 1 2017 TEGL 11-19 Change 2 Negotiations and Sanctions Guidance for the Workforce Innovation and Opportunity Act WIOA Core Programs January 6 2025 7 TEGL 07-18 Change 1 Guidance for Validating Jointly Required Performance Data Submitted under the Workforce Innovation and Opportunity Act WIOA July 10 2025 TEGL 26-16 Change 1 Guidance on the use of Supplemental Wage Information to implement the Performance Accountability Requirements under the Workforce Innovation and Opportunity Act WIOA July 10 2025 TEGL 14-18 Aligning Performance Accountability Reporting Definitions and Policies Across Workforce Employment and Training Programs Administered by the U.S. Department of Labor DOL March 25 2019 TEN 19-22 Change 1 Change 1 to Training and Employment Notice No. 19-22 Reporting Training in the U.S. Department of Labor s DOL Participant Individual Record Layout PIRL March 31 2023 Employment and Training Administration source for WIOA requirements https www.dol.gov agencies eta wioa and The Performance website addresses how performance is measured reported and evaluated at the Employment and Training Administration https www.dol.gov agencies eta performance . Attachment s . Revised Attachment I Program-Specific Instructions Revised Attachment II Source Documentation for WIOA Core Non-Core Programs