TEGL 07-25.pdf

ETA Advisory File Text

EMPLOYMENT AND TRAINING ADMINISTRATION ADVISORY SYSTEM U.S. DEPARTMENT OF LABOR Washington D.C. 20210 CLASSIFICATION WIOA State Plans CO RRESPONDENCE SYMBOL OWI DATE January 26 2026 RESCISSIONS TEGL No. 04-23 EXPIRATION DATE Continuing ADVISORY TRAINING AND EMPLOYMENT GUIDANCE LETTER NO. 07-25 TO STATE WORKFORCE AGENCIES STATE WORKFORCE ADMINISTRATORS STATE WORKFORCE LIAISONS STATE LABOR COMMISSIONERS STATE AND LOCAL WORKFORCE BOARD CHAIRS AND DIRECTORS AMERICAN JOB CENTER DIRECTORS STATE LABOR MARKET INFORMATION DIRECTORS STATE APPRENTICESHIP AGENCIES STATE DIRECTORS OF THE OFFICE OF APPRENTICESHIP STATE EDUCATIONAL AGENCIES STATE CTE DIRECTORS STATE EDUCATION COMMISSIONERS STATE AND LOCAL STAKEHOLDERS IN THE WORKFORCE INNOVATION AND OPPORTUNITY ACT FROM HENRY MACK Assistant Secretary SUBJECT Modification Requirements for Workforce Innovation and Opportunity Act WIOA State Plans for Program Years PYs 2026 and 2027 1. Purpose. This Training and Employment Guidance Letter TEGL outlines the priorities modification requirements submission process and deadline for the required modification of the WIOA Unified and Combined State Plans State Plans for PY 2026 and PY 2027 in accordance with Sections 102 and 103 of WIOA. 2. Action Requested. I n accordance with WIOA its implementing regulations and the information collection request ICR Workforce Innovation and Opportunity Act WIOA Unified and Combined State Plan Requirements approved under Office of Management and Budget OMB control number 1205-0522 states must submit a two-year modification of their WIOA Unified or Combined State Plans a four-year plan to the U.S. Departments of Labor and Education the Departments . While states should generally submit plan modifications by March 3 2026 using the online portal described in Section 4.d. of this guidance the Departments are offering additional flexibility to empower states to align the planning submission timeline with Perkins V and submit plan modifications until April 30 2026. If States want to avail themselves of this additional flexibility States must notify their relevant Employment and Training Administration ETA Regional Administrator in writing 2 by March 3 2026 and provide an explanation of the state s need for additional time as well as an estimated date of submission which cannot be later than April 30 2026 . Once submitted the Departments will review and provide a decision within 90 days for the core programs as required by section 102 c 2 B and 3 B of WIOA. 3. Summary and Background. a. Summary This joint guidance outlines the WIOA planning requirements for the required two-year modification of the four-year State Plan and provides submission deadlines and procedures. b. Background WIOA requires the Governor of each state to submit a Unified or Combined State Plan that includes a four-year strategy and operational plan for the continuing implementation of the state s workforce development system with an update after two years. States must have federally approved State Plans to receive funding under the six core programs Adult Dislocated Worker Youth Adult Education and Family Literacy Act AEFLA Wagner-Peyser and the Vocational Rehabilitation VR programs . All states have approved four-year WIOA State Plans for PYs 2024-2027. WIOA requires that states review their plan every two years and update State Plan strategies to account for changes in the labor market and economic conditions or other factors affecting the implementation of the State Plan. Such factors may include reorganization of State agencies administering WIOA programs redesignation of local areas or establishment of new planning regions the addition of new partner programs such as Perkins V 1 into a Combined State Plan changes to methodology used to determine local allocation of funds and other significant strategic or operational changes within states. States may also elect to change from a Unified to a Combined State Plan to include additional partners such as Perkins V during the modification process to maximize alignment between programs. Under WIOA the Unified and Combined State Plans communicate the State s vision for its public workforce system and broader talent development system. WIOA planning requirements seek to align federal investments in job training and education programs improve service delivery efficiency and match individuals skills with high-paying job opportunities and employers. Cross-program planning promotes a shared understanding of the workforce needs and enables the public workforce system to provide a wider range of services that require coordination to meet the needs of employers youth and adult learners and workers including individuals with disabilities and individuals facing barriers to entering and persisting in paid employment. 1 Perkins V is the Carl D. Perkins Career and Technical Education Act of 2006 as amended by the Strengthening Career and Technical Education for the 21st Century Act. 3 4. Content. a. WIOA Planning Strategic Priorities. On April 23 2025 President Trump issued Executive Order 14278 titled Preparing Americans for High-Paying Skilled Trade Jobs of the Future that directed the U.S. Departments of Labor Education and Commerce to articulate a comprehensive worker investment and development strategy. Subsequently the Departments published America s Talent Strategy Building the Workforce for the Golden Age that articulates a shared vision for America s workforce development efforts including the public workforce system with five strategic pillars. States are encouraged to review their currently approved State Plans and align their strategies and investments to these pillars which are summarized below. PILLAR I Industry-Driven Strategies The skill demands and hiring needs of industry must drive how workforce development programs train and prepare the participants they serve. Local employers should play a central role in defining in-demand skills validating training models and steering investments toward the roles and credentials that propel workers into secure well-paying and high-need American jobs. The public workforce system can support this pillar by prioritizing Registered Apprenticeships Integrated Education and Training programs and other high-quality work-based learning models organizing employers into industry sector partnerships to identify high-wage high-skill or in-demand industry sectors and occupations and design workforce strategies to address their needs aligning eligible training programs to career pathways within the State or regional economy and targeting investments towards employer-led upskilling initiatives designed to fill talent shortages in priority industries. PILLAR II Worker Mobility Individuals returning to the workforce or seeking better career opportunities should be able to take tangible steps that lead to upward mobility and long-term economic independence. Next-generation workforce and labor market intelligence tools should help participants identify their skills understand skills-aligned career options and take intentional steps toward better-paying jobs. The public workforce system can support this pillar through several targeted strategies such as clearly identifying credentials that are valued in the labor market to support informed decision making and support jobseekers to earn such credentials developing informed customer choice policies designed to mitigate benefits cliffs advancing innovative use of technology and labor market data including employing competency-based assessments and benefits cliff navigation tools during intake into the public workforce system and integrating Artificial Intelligence AI -powered tools including comprehensive talent marketplaces composed of comprehensive learner records or learning and employment records solutions credential registries and skills-based job description generators that allow workers to advance based on demonstrated competencies. The public workforce system can also help connect disconnected workers to training opportunities that lead to self-sufficiency. 4 PILLAR III Integrated Systems The public workforce system must be unified navigable and built around the needs of its users. Job seekers should be able to access training and employment opportunities without getting lost in a maze of government agencies and employers should be able to engage with the system just as easily to find talent and grow their workforce. The public workforce system can support this pillar by integrating disparate funding streams and improving service delivery through adopting shared eligibility standards across programs implementing and scaling virtual service delivery practices to reduce overhead expenses and advancing education and workforce alignment streamlining intake processes and implementing digital tools that help frontline staff guide individuals to the right services. PILLAR IV Accountability Taxpayer funded workforce development programs must deliver measurable and transparent results for job seekers and employers. Ineffective training providers should be removed from public funding lists. Grantees funding models should tie resources to outcomes including through the expanded use of pay-for- performance contracts to ensure public investments generate measurable returns in employment earnings and credential attainment. The public workforce system can support this pillar by identifying and eliminating ineffective activities adopting state- driven measures of program performance establishing state and local area postsecondary attainment and labor force participation goals redirecting funding to programs and providers that demonstrate success in connecting Americans with high-wage jobs and enhancing data linkages including by exploring enhanced wage records and publishing education and training programs in structured open linked and interoperable data formats to produce valid and transparent data that assesses the return on investment and the impact on closing talent gaps. PILLAR V Flexibility and Innovation The public workforce system must be adaptable and designed for continuous iteration with exponentially faster feedback loops between employers educators and training providers to ensure that programs can evolve in step with economic shifts particularly those driven by AI. States and local communities need more control to tailor solutions to their regional economies without being constrained by outdated program rules or processes. The public workforce system can support this pillar by leveraging existing statutory authorities to promote flexibility and innovation within the system braiding federal and state funding streams from multiple sources to support integrated career pathways creating new models of workforce innovation built to match the speed and scale of AI-driven economic transformation prioritizing AI literacy and skills development across the public workforce system and developing pilot projects to drive rapid reskilling and fuel other AI-era innovations. Additional Planning Priorities It is particularly critical for purposes of developing and submitting the State Plan modification for PYs 2026 and 2027 that states reassess economic and labor market information LMI and adjust strategies for what may now be a different set of growing and declining industries occupations and skills thereby ensuring the State Plan modification reflects changes in the labor market and economic conditions and other factors affecting implementation of the State Plan as required by section 102 c 3 A of WIOA. Additionally state plans must not only include the in- 5 demand sectors and occupations but also the employment needs of employers and the associated competencies required in those industries and occupations and align training provided through the workforce system with the hiring needs. LMI informs the public workforce system by offering data insights to keep up with a rapidly changing economic environment driven by AI advanced industries and new national priorities. State planners must work closely with the LMI directors within their states to understand the current and growing needs of their economy. The State Plan modification must reflect any such strategic re-focusing. The Departments encourage states to widely share State LMI including the State LMI used in State plans across State agencies regardless of inclusion in the WIOA State Plan to support data-informed decisions. For example such data analysis could support Perkins V subrecipients in carrying out comprehensive local needs assessments in tandem with public workforce system stakeholder engagement at the state and local area levels. 2 Moreover states are encouraged to reassess how their public education and workforce systems capture verify and communicate the competencies knowledge skills and abilities individuals acquire. Talent marketplaces solutions enable student and worker employment and mobility more effectively mapping skills to occupational and employer needs in real time. Talent marketplaces also allow for individuals to own and make portable their skills and learning assertions controlling what where when and with whom verified skills and credentials are shared. States are particularly encouraged to prepare for implementation of Workforce Pell Grants connecting jobseekers and students with high-quality short-term training authorized under Section 83002 of the One Big Beautiful Bill Act Public Law 119-21 . Workforce Pell Grants will provide access to federal financial aid for students enrolled in high-quality short-term workforce programs that are defined as at least 150 clock hours of instruction and less than 600 clock hours or the equivalent in credit hours and at least 8 weeks but less than 15 weeks in duration among other criteria. Steps to prepare for Workforce Pell might include using the latest labor market information to refresh the state s identification of in-demand industry sectors and occupations deepening system integration across education and workforce systems and enhancing data collection i.e. by enhancing unemployment insurance wage records that allow states to establish program-to-occupational linkages and to crosswalk education and training programs to competency-based industry-recognized qualifications frameworks and data sharing. As states develop their plan modifications for PYs 2026 and 2027 grantees must not use federal funds in any manner that violates the United States Constitution Title VI or Title VII of the Civil Rights Act of 1964 42 U.S.C. 2000d et seq. or 42 U.S.C. 2000e et seq. Title IX of the Education Amendments of 1972 20 U.S.C. 1681 et seq. section 504 of the Rehabilitation Act 29 U.S.C. 794 the Age Discrimination Act of 1975 42 U.S.C. 6101 et seq. Title II of the Americans with Disabilities Act of 1990 42 U.S.C. 12131 et seq. the Boy Scouts of America Equal Access Act of 2001 20 U.S.C. 7905 2 Section 135 c of Perkins V requires comprehensive local needs assessments. 6 section 117 of the Higher Education Act of 1965 as amended 20 U.S.C. 1011f or other applicable federal law. It is important to note the provisions of Executive Orders 14151 14168 14173 and 14190 as well as the U.S. Department of Justice s July 29 2025 non-regulatory Guidance for Recipients of Federal Funding Regarding Unlawful Discrimination. States and subgrantees that have implemented diversity equity and inclusion DEI activities and any other initiatives that discriminate on the basis of race color religion sex or national origin may risk violating federal civil rights laws referenced above and jeopardizing federal funding. This includes any discriminatory equity ideology in violation of a Federal anti-discrimination law. The definition of discriminatory equity ideology is in Section 2 b of Executive Order 14190. To the extent that a U.S. Department of Education the Department grantee uses grant funds for unallowable activities the Department reserves the right to take appropriate enforcement action including under section 451 of the General Education Provisions Act GEPA which may include the recovery of funds under section 452 of GEPA. b.Planning Requirements. States must use the ICR Workforce Innovation and Opportunity Act WIOA Unified and Combined State Plan Requirements OMB control 1205-0522 to develop and submit both the WIOA Unified or Combined State Plan and the two-year modification. A copy of the ICR which complies with statutory requirements set forth in as appropriate sections 102 and 103 of WIOA is available at https www.dol.gov agencies eta wioa resources. A copy of these requirements is also available through the State Plan portal https wioaplans.dol.gov developed specifically for the required electronic submission. Note that the ICR includes a requirement for states to describe how they will use State merit staff for the provision of Wagner-Peyser Employment Services. The Department of Labor will notify states of any changes to this planning requirement because of ongoing rulemaking related to proposed flexibility in Employment Service staffing as described in the notice of proposed rulemaking entitled Wagner-Peyser Act Employment Service Staffing published on July 1 2025 90 FR 28239 . c.Stakeholder Collaboration and Comment. The State Workforce Development Board State Board assists the Governor in the development implementation and modification of the State Plan and convenes all relevant programs required partners and stakeholders. The Departments encourage inclusion of the state LMI chief information officers state higher education executive officers education and articulation offices Career and Technical Education agencies and workforce and education evaluation offices or their equivalent during plan development and modification to obtain labor market data and related evidence and analysis. States are also encouraged to engage the Perkins V eligible agency and stakeholders in the modification processes even if the Perkins V program is not already included in the State Plan. The Departments have received feedback from states and recognize that some states may need additional time to conduct planning activities as they align WIOA and Perkins V programs prior to the submission of their plan modifications. As such as noted 7 above the Departments will accept plan modifications through April 30 2026 to accommodate cross-program planning for this cycle see Section 2 of this guidance . States are encouraged to hold concurrent public engagement sessions with Perkins V stakeholders from other core and partner programs to the public workforce system. These stakeholders may include state and local educational agencies community and technical colleges state workforce agencies business and industry partners and others. A combination of virtual and in-person stakeholder engagement sessions are encouraged at both the state and local area levels. The State Plan must be developed with the assistance of the State Board as required by Section 101 d of WIOA and in coordination with administrators that have optimal policymaking authority for the core programs and required one-stop partner programs. For Combined State Plans the portions of the plan that cover partner programs other than the core programs are subject to any public comment requirements applicable to those partner programs. 3 States must provide the opportunity for public comment and input which allows interested stakeholders to participate actively effectively and transparently in the development of the plan and the modification including via accessible means for individuals with disabilities. The Governor must ensure that the State Plan modification is developed with an opportunity for public comment from representatives of Local Workforce Development Boards and chief elected officials businesses labor organizations community-based organizations state educational agencies adult education providers faith-based organizations institutions of higher education other stakeholders with an interest in the services provided by the six core programs and the general public including individuals with disabilities. The State Board also must make information regarding the modification of the State Plan and planning process available to the public through electronic and accessible means and by holding regularly occurring open meetings in accordance with state law prior to the submission of the State Plan. 4 d.Instructions for State Plan Modification Submission. States must submit their modification of their State Plan via the State Plan Portal which has been developed for the purpose of cross-program collaboration in states and to facilitate the simultaneous receipt and review of plans across multiple federal agencies. While multiple individuals in states may enter content into the portal only one individual from each state may submit to the Departments the entire plan on behalf of the Governor for all included programs. The Office of the Governor for each state must notify the Departments of the 3 See 20 CFR 676.143 c 3 and 34 CFR 361.143 c 3 and 463.143 c 3 . 4 See WIOA Section 101 g and 20 CFR 676.130 d and 34 CFR 361.130 d and 463.130 d . 8 individual designated to submit the plan modification on behalf of the Governor for all programs included in the State Plan even if that designee has not changed since the PY 2024 submission. By February 02 2026 the Governor s office must submit a letter or email with the name of the designee to WIOA.Plan dol.gov with a copy to the appropriate ETA Regional Office. To request a State Plan portal user account or to update existing account login information visit https wioaplans.dol.gov. Previously approved WIOA State Plans are available within the portal content from currently approved four-year plans will be available in the data entry fields for editing or updating so State editors can either delete entire sections or update specific portions of the plan. e. Performance Negotiations for Core Programs. To outline the requirements for reaching agreement on the negotiated levels of performance for the states outlined in WIOA section 116 the Departments issued joint guidance titled Negotiations and Sanctions Guidance for the Workforce Innovation and Opportunity Act WIOA Core Programs ETA TEGL 11-19 Change 2 OCTAE Program Memorandum 20-2 revised January 2025 and RSA TAC-20-02 revised January 2025 . The Departments will continue to negotiate program specific levels of performance. The Unified and Combined State Plan ICR Appendix 1 also discussed in Attachment I of this guidance reflect which indicators the Departments will negotiate for which programs for PYs 2026 and 2027. See Attachment I of this guidance for more instructions on submitting expected levels of performance and establishing negotiated levels of performance. f. Waivers. As articulated in ETA TEGL 05-25 Maximizing Innovation in Workforce Innovation and Opportunity Act Programs states are encouraged to request waivers of existing WIOA statutory or regulatory requirements that can help overcome specific barriers to innovation and align with the Five Strategic Pillars for workforce investment. Waivers are a tool for reducing barriers to WIOA implementation and spurring innovative programming options. The Secretary of Labor s waiver authority is outlined in WIOA sec. 189 i 3 A the Secretary may waive certain provisions of WIOA Title I subtitles A B and E and provisions found in Sections 8 10 of the Wagner-Peyser Act. States may submit WIOA Title I and III waiver requests as part of their State Plan or as a separate waiver plan. For more information on the process for states to request waivers see ETA TEGL 08-18 Workforce Innovation and Opportunity Act WIOA Title I and Wagner-Peyser Act Waiver Requirements and Request Process. States are encouraged to involve the Perkins eligible agency and stakeholders in the development of innovation and flexibility waivers. States are encouraged to review all currently approved waivers along with their respective expiration dates to consider renewing or resubmitting new waivers. 5 Therefore states should submit new waiver requests as part of the State Plan modification submission for re-consideration if they wish to continue implementing particular waivers that had been approved previously but are expiring. As articulated in 5 For waivers related to the 75 out-of-school youth expenditure requirement waivers are in effect for the full amount of time that states have to spend program year funds. 9 waiver approval letters states agreed to meet certain performance or other program measures resulting from the waiver. States requesting a waiver must provide the most recent data available about the outcomes of the waiver in the renewal request. 6 The Department of Labor will consider this information as part of its thorough consideration on whether to approve the requested waiver. Find waiver-related resources at https www.dol.gov agencies eta wioa waivers. 5.Inquiries. Please direct inquiries to the appropriate Regional Office. 6.References. Workforce Innovation and Opportunity Act WIOA Pub. L. 113-128 July 22 2014 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 56072 Aug. 19 2016 State Vocational Rehabilitation Services Program State Supported Employment Services Program Limitations on Use of Subminimum Wage Final Rule Office of Special Education and Rehabilitative Services OSERS Final Rule published at 81 FR 55630 August 19 2016 Workforce Innovation and Opportunity Act Miscellaneous Program Changes Final Rule WIOA OSERS Final Rule published at 81 FR 55562 August 19 2016 Programs and Activities Authorized by the Adult Education and Family Literacy Act Title II of WIOA Final Rule WIOA OCTAE Final Rule published at 81 FR 55526 August 19 2016 Information Collection Request Required Elements for Submission of the Unified or Combined State Plan and Plan Modifications Under the Workforce Innovation and Opportunity Act approved under Office of Management and Budget OMB control number 1205-0522 and ETA TEGL 08-18 Workforce Innovation and Opportunity Act WIOA Title I and Wagner-Peyser Act Waiver Requirements and Request Process dated December 19 2018. 7.Attachment. Attachment I Performance Goals and Instructions for the Core Programs 6 See 20 CFR 679.620 d 7 . I-1 Attachment I WIOA Performance Accountability and Instructions for the Core Programs State Plan modifications must identify expected levels of performance for each primary indicator of performance for the two years covered by the plan modification. The State must reach agreement with the Secretary of Labor in conjunction with the Secretary of Education on the negotiated levels of performance for the indicators for each of the two years of the plan modification. The Adult Dislocated Worker Youth Adult Education and Family Literacy Act and Vocational Rehabilitation programs will have sufficient data available to make reasonable determinations of expected levels of performance for the following indicators for PYs 2026 and 2027 Employment 7 Second Quarter after Exit Employment 8 Fourth Quarter after Exit Median Earnings Second Quarter after Exit Credential Attainment Rate and Measurable Skill Gains. The Wagner-Peyser Act Employment Service program will have sufficient data available to make a reasonable determination of expected levels of performance for the following indicators for PYs 2026 and 2027 Employment Second Quarter after Exit Employment Fourth Quarter after Exit and Median Earnings Second Quarter after Exit . The Credential Attainment Rate and Measurable Skill Gains indicators do not apply to the Wagner-Peyser Act Employment Service program therefore this program will not submit expected levels of performance for these indicators. The Departments determined that the Effectiveness in Serving Employers ESE indicator will be measured as a shared outcome across all six core programs within each State to ensure a holistic approach to serving employers. The approach to measuring ESE was defined in the Workforce Innovation and Opportunity Act Effectiveness in Serving Employers Performance Indicator final rule 89 FR 13814 Feb. 23 2024 Final Rule . This final rule took effect March 25 2024 and defined the ESE primary indicator of performance as required by WIOA section 116 b 2 as Retention with the Same Employer. For the PYs 2026-2027 plan modifications the Departments used the transition authority under section 503 a of WIOA to designate the ESE primary indicator of performance as a baseline indicator. A baseline indicator is one for which states do not propose an expected level of 7 For Title I Youth programs employment education or training. 8 For Title I Youth programs employment education or training. I-2 performance and do not come to agreement with the Departments on negotiated levels of performance because sufficient data are not available to establish such performance levels. As a result baseline indicators are not used in the end of the year adjustment of performance levels and are not used to determine failure to meet adjusted levels of performance for purposes of sanctions. The Departments designated indicators as baseline based on the likelihood of a State having insufficient data with which to make a reasonable determination of an expected level of performance. Include the State s expected levels of performance for the primary indicators of performance described in section 116 b 2 A of WIOA. Each state must then update its plan modification to include the agreed-upon negotiated levels of performance before the Departments approve the plan modification. Title I Adult Program PY 2026 Expected Level PY 2026 Negotiated Level PY 2027 Expected Level PY 2027 Negotiated Level Employment Second Quarter after Exit Employment Fourth Quarter after Exit Median Earnings Second Quarter after Exit Credential Attainment Rate Measurable Skill Gains I-3 Title I Dislocated Worker Program PY 2026 Expected Level PY 2026 Negotiated Level PY 2027 Expected Level PY 2027 Negotiated Level Employment Second Quarter after Exit Employment Fourth Quarter after Exit Median Earnings Second Quarter after Exit Credential Attainment Rate Measurable Skill Gains Title I Youth Program PY 2026 Expected Level PY 2026 Negotiated Level PY 2027 Expected Level PY 2027 Negotiated Level Employment Second Quarter after Exit Employment Fourth Quarter after Exit Median Earnings Second Quarter after Exit Credential Attainment Rate Measurable Skill Gains I-4 Title II Adult Education and Family Literacy Act Program PY 2026 Expected Level PY 2026 Negotiated Level PY 2027 Expected Level PY 2027 Negotiated Level Employment Second Quarter after Exit Employment Fourth Quarter after Exit Median Earnings Second Quarter after Exit Credential Attainment Rate Measurable Skill Gains Title III Wagner-Peyser Act Employment Service Program PY 2026 Expected Level PY 2026 Negotiated Level PY 2027 Expected Level PY 2027 Negotiated Level Employment Second Quarter after Exit Employment Fourth Quarter after Exit Median Earnings Second Quarter after Exit I-5 Title IV Vocational Rehabilitation Program PY 2026 Expected Level PY 2026 Negotiated Level PY 2027 Expected Level PY 2027 Negotiated Level Employment Second Quarter after Exit Employment Fourth Quarter after Exit Median Earnings Second Quarter after Exit Credential Attainment Rate Measurable Skill Gains All WIOA Core Programs Additional Indicators of Performance 1. 2. 3. 4. 5. 6. PY 2026 Expected Level PY 2026 Negotiated Level PY 2027 Expected Level PY 2027 Negotiated Level Effectiveness in Serving Employers Baseline Baseline Baseline Baseline