On May 9, 2016, 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:     

1. Achievement of at least one educational functioning level of a participant in an education program that provides instruction below the post-secondary level;
2. Attainment of a high school diploma or its equivalent;
3. Transcript or report card for either secondary or post-secondary education that shows a participant is achieving the state unit’s academic standards;
4. 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,
5. 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.