May 20, 2016 | PERMALINK »
CLASP Provides Model Comments on SNAP E&T Reporting Measures
Under the Supplemental Nutrition Assistance Program Employment and Training program (SNAP E&T), states can operate employment and training programs to serve individuals receiving SNAP nutrition assistance. Some of these programs are voluntary; others are mandatory, meaning individuals who fail to participate may lose their SNAP benefits. It has been historically difficult to assess the programs’ outcomes due to lack of data. However, under the 2014 Farm Bill, the U.S. Department of Agriculture’s Food and Nutrition Service (FNS) now requires states to collect and report on participant outcomes from SNAP E&T.
On March 24, 2016, FNS issued an interim final rule regarding the SNAP E&T reporting measures. Although this rule was issued on an interim final basis, meaning it was effective immediately, FNS is accepting comments on the regulations until May 23, 2016.
In general, this is a welcome step toward better understanding SNAP E&T, its components, and the employment outcomes of its participants. However, FNS should improve the rule by capturing data to better reflect the full outcomes of the program, including the impact of mandatory participation requirements and sanctions as well as individual components within E&T programs. Further these measurements should be more closely aligned with the Workforce Innovation and Opportunity Act (WIOA). CLASP’s comments on the regulations are available on our website.
Feedback from workforce development practitioners and advocates, who have considerable experience with reporting outcomes, would benefit FNS. CLASP is providing model comments that organizations or individuals may use in submitting their own comments. The Center on Budget and Policy Priorities has also developed comments focused on the urgency of adding information on the effects of mandatory participation. We encourage you to use the model comments to make your voice heard.
May 19, 2016 | PERMALINK »
Federal Guidance Explains How the Ability to Benefit Provision Aligns with a Career Pathway
The Ability to Benefit (ATB) provision in the Higher Education Act (HEA) allows low-skilled individuals to access necessary workforce training and education that can help lift them out of poverty. It does so by allowing individuals without a high school diploma or equivalent to qualify for federal financial aid for postsecondary education when they participate in an eligible career pathway. Five months ago, Congress passed the Consolidated Appropriations Act of 2016 which made changes to the amount of Pell Grant for which ATB students are eligible and to the definition of career pathway used in determining eligibility for ATB. To help postsecondary institutions implement these changes, the U.S. Department of Education (ED) released updated guidance last week. Individuals and organizations, like CLASP, concerned with low-skilled students’ access to Title IV aid should be pleased with the results.
First, students who participate in an ATB alternative are now eligible for the full Pell award—$5,815 in the 2016-2017 award year. Formerly, ATB students were eligible for a reduced award, which created an unfair and unprecedented two-tier Pell eligibility standard.
Second, the new ATB eligible career pathway definition mirrors the Workforce Innovation and Opportunity Act (WIOA), aligning the career pathway development and implementation underway for WIOA with access to federal financial aid. The previous standard required students to be “concurrently” enrolled in both adult education and postsecondary programs, and it did not well define what could be characterized as adult education. The new definition provides that the career pathway “enables an individual to attain” a high school diploma or equivalency. This clarifies the intent of ATB to support students without a high school diploma or equivalency in both secondary and postsecondary credential attainment.
Further, in its updated Q&A document, ED clearly states that students are not required to be concurrently enrolled in both an adult education and Title IV student financial aid-eligible program, but must at least “participate in the [adult education] component” before completing the postsecondary credential (emphasis added).
ED also reiterated previous applicable guidance, including that institutions must document how their program meets each of the seven elements of the career pathway definition, how students who receive aid under ATB are eligible for such aid, and that programs do not need to obtain (and ED will have no process to undertake) formal approvals as a career pathway program. This should inspire institutions to take action, knowing there are not extensive barriers in place that limit starting up such a program.
We encourage postsecondary education officials, particularly financial aid administrators, to take notice of this guidance and consider starting your research on eligible career pathways at CLASP’s ATB resource page. Since the new definition of career pathways aligns with the WIOA definition, there are likely career pathways being developed in your local area to connect with and leverage. WIOA agencies now developing such pathways should also provide information to reassure postsecondary institutions that they meet all seven elements of the “eligible career pathway” definition, which will allow individuals pursuing these pathways to obtain federal financial aid.
Two examples of adult education state initiatives illustrate how local providers are delivering programs that “enable an individual to attain a high school diploma or its recognized equivalent” and encourage innovation and partnership with postsecondary education. Both could be tailored to an ATB eligible career pathway program:
- Wisconsin’s High School Equivalency Diplomas and Certificates legislation offers a menu of alternative high school credentialing processes, including the attainment of at least 24 postsecondary semester credits (Pl 5.07) or the completion of a program approved by the state superintendent (Pl 5.09).
- State of Washington’s 21-Plus competency-based high school equivalency program expands existing secondary completion options with a comprehensive assessment of academic, career, and personal competencies.
With this new definition in the HEA law, it’s clearer than ever that postsecondary institutions have many WIOA partners available to work with them in supporting postsecondary success of adult learners.
May 9, 2016 | PERMALINK »
Career Pathways: A Step Forward and a Potential Step Back
Today, career pathways efforts around the country received another important nod from the federal government with the release of a joint Dear Colleague letter from the White House National Economic Council, the Office of Management and Budget (OMB), and thirteen federal agencies, all members of the Obama Administration’s “Skills Working Group.” The letter is intended to demonstrate the administration’s continued commitment to promote career pathways, including efforts to ensure career pathways are accessible to low-skilled youth and adults. CLASP applauds the administration for bringing so many partners together to affirm and encourage the career pathways approach.
“Too often,” the letter says, “our systems for preparing low-skilled youth and adults with marketable and in-demand skills can be complex and difficult to navigate…Career pathways can offer an efficient and customer-centered approach to training and education by connecting the necessary adult basic education, occupational training, postsecondary education, career and academic advising, and supportive services for students to prepare for, obtain, and progress in a career.” CLASP strongly agrees that a career pathway effort that truly connects these programs and systems can help prepare low-skilled youth and adults for jobs with family-sustaining wages.
However, for these systems to work together effectively in career pathways, they should be aiming for the same or similar goals. Common performance measures across core programs in the Workforce Innovation and Opportunity Act (WIOA) are a good example of aligning performance measures so programs can work together to meet participants’ needs.
An important example of a shared performance measure in WIOA, the measurable skill gains indicator, holds great promise for encouraging innovative partnerships to support career pathways with braided funding from multiple programs. However, such innovative program designs would be greatly hindered by a recent proposal to restrict the types of reportable measurable skill gains that can be used by Adult Education and Family Literacy programs under Title II of WIOA. The recent Information Collection Request (ICR) issued by the U.S. Departments of Education and Labor on WIOA Common Performance Reporting includes a detailed explanation of the five types of skill gains that can be counted toward the Measurable Skill Gain indicator:
- Achievement of at least one educational functioning level of a participant in an education program that provides instruction below the post-secondary level;
- Attainment of a high school diploma or its equivalent;
- Transcript or report card for either secondary or post-secondary education that shows a participant is achieving the state unit's academic standards;
- Satisfactory or better progress report towards established milestones from an employer/training provider who is providing training (e.g., completion of on-the-job training, completion of one year of an apprenticeship program, etc.); and,
- Successful completion of an exam that is required for a particular occupation, progress in attaining technical or occupational skills as evidenced by trade-related benchmarks such as a knowledge-based exam.
These five types of gains, however, may not be shared performance measures for all the partners in a career pathway initiative. Appendix A of the ICR indicates that Title II Adult Education and Family Literacy will be limited to only the first skill gain, “achievement of at least one educational functioning level.” This restriction will limit the ability of Title II programs to effectively partner with other core WIOA programs on innovative career pathways programs and systems that have so much promise for serving low-income participants. Such partnerships would be required to perform unnecessary assessments of participants solely for the purpose of meeting the Title II program’s educational functioning level gain metric, even if the success of the integrated program as a whole would be more effectively evaluated by participants’ achievement of technical or occupational skill gains.
CLASP urges OMB to allow Title II to use the same common performance measures available to WIOA’s other core programs to facilitate effective career pathways, and we will submit comments to that effect. OMB is accepting comments on the IRC through May 26, 2016. We encourage others to file comments on this issue.