Public Comment: Execution of Workforce Development Under Workforce Innovation & Opportunity Act

Frank Waterous, senior policy analyst at the Bell Policy Center, provides public comment on Colorado’s draft combined plan for workforce development.

Thank you for the opportunity to present this public comment. I am Frank Waterous, senior policy analyst with the Bell Policy Center. The Bell is a nonpartisan, nonprofit research and advocacy organization founded on progressive values and dedicated to making Colorado a state of opportunity for all. The Bell is also a member of the Skills2Compete-Colorado coalition, which served as a focus group in the development of the draft state plan.

We have five comments to offer on the draft plan today. We will also be providing these comments in writing through the formal submittal process before the February 9, 2016 deadline.

First, we are pleased with the strong emphasis in the draft plan’s strategic vision and goals on creating a customer-centric, holistic workforce system in our state, driven by a “no-wrong-door” philosophy. To achieve this goal, the plan correctly identifies the need for cross-education and training of staff on different programs, resources and processes, as well as the importance of engaging staff at all levels on how to strengthen the system and make it work better for all concerned.

However, one area on which we would like to see more system-wide emphasis in the plan is the use of “navigators” or coaches — an approach that has been highly effective in helping customers find their way through a variety of complex systems and achieve successful outcomes. The navigator role is discussed in the plan in conjunction with how some of the core programs and partners perform their work. However, it is not identified as a strategic opportunity or potential best-practice for the system as a whole. We believe the plan needs more explicit discussion and emphasis on the role of navigators as a system-wide strategic innovation that would lead to increased customer success.

Second, an essential component of a customer-centric system that serves individuals in a holistic fashion is the provision of Supportive Services, such as child care and transportation, through a two-generation approach focused on addressing issues many of these individuals and their families face in overcoming barriers to education, training, and employment. Supportive Services are discussed in a variety of places in the draft plan, primarily in relation to the activities of particular core programs and partners.

However, the plan does not address the significance of, or the state’s proposed support for, Supportive Services as a crucial strategic priority for improving the system and helping more customers succeed. We urge you to incorporate a more detailed discussion of a two-generation Supportive Services approach in the plan, including specifics on its importance for achieving the state’s system-wide vision and goals, and on how such services will be supported and provided system-wide.

Third, WIOA provides an increased opportunity for, and places a strong emphasis on, the development and expansion of Integrated Education and Training (IET) programs. IET programs combine adult education and literacy instruction with postsecondary career, technical and occupational coursework. They have proven highly successful in helping low-literacy, low-skilled adults complete postsecondary credentials and successfully enter the workforce.

Yet, despite the importance placed on these programs in WIOA, there is only minimal mention of them in the draft state plan, especially regarding their role as a key strategic element in a collaborative and integrated workforce system that connects all core programs and partners. This is a significant weakness in the draft plan. We urge you to include explicit and detailed information in the plan on the strategic importance of IET programs for the state — as well as specifics on how various core programs, partners and other key parties will encourage and support their expansion, use and connection to career pathways.

Fourth, another key provision of WIOA is the “Priority of Service” for adults who are low income, public assistance recipients or basic skills deficient. This provision is critical for ensuring that those with the greatest needs are served by our workforce system. Priority of Service is mentioned in the draft state plan, and a link is provided in the required assurances to the state’s recent Policy Guidance Letter on Priority of Service for Title I Adult Programs. However, given the importance of this provision in WIOA, we believe that the details of how the state will implement, deliver, and ensure Priority of Service for these individuals should be given much fuller and more explicit discussion in the body of the plan itself.

Fifth, the draft plan rightly identifies Colorado as a leader in the development of sector partnerships and career pathways. It also notes the state’s intent to continue its work in these areas. However, specifics on what the state has done and what future steps it envisions to expand sector partnerships and career pathways — and to link all core programs and partners into these efforts — are lacking in the draft. We believe the plan would be strengthened by the addition of more detailed descriptions of the state’s current accomplishments and future goals in its sector partnership and career pathway efforts.

As a final note, one further issue will be vital for ensuring that the vision and goals outlined in the draft plan can be achieved. Stated simply, the state must support maximum flexibility in rules, procedures, and the use and blending of funding streams in order to encourage the type of innovation needed for success. To the fullest extent possible, the state’s commitment to such program and funding flexibility should be clearly stated in the plan.

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