Last week, as part of implementation of the Workforce Innovation and Opportunity Act (WIOA), the U.S. Departments of Education (ED) and Labor (DOL), together with three other federal agencies, released a formal Information Collection Request that contains proposed required elements of states’ mandatory Unified Plans or optional Combined Plans. Comments will be accepted at regulations.gov until October 5, 2015.

An ICR is primarily intended to collect comments on the potential benefits and burdens of complying with federal collection of information. However, this ICR is notable because it offers an early look at  the elements states will have to include in their WIOA state plans, in advance of the Departments’ expected operational guidance on planning.

Under Unified Plans, states are required to explain how they will implement WIOA’s six core programs: Title I Adult, Title I Youth, Title I Dislocated Worker, Title II Adult Education and Family Literacy, Title III Wagner-Peyser, and Title IV Vocational Rehabilitation. States can choose to expand the list of programs in the plan—creating a Combined Plan—by adding any of the optional 11 combined planning partners.*

State plans will be strategic—analyzing economic conditions, workforce characteristics, and workforce development goals—and operational, including descriptions of state operating systems and policies. Data alignment and integration will require developing a common intake process and the ability to track participation across all programs in the plan.

According to the ICR, the state planning process should yield “more comprehensive and integrated [education and training] approaches, such as career pathways and sector strategies, for addressing the needs of businesses and workers.” To accomplish that, states will need to build strong relationships across all of the core WIOA programs and any of the optional combined planning partners. 

The ICR also identifies priority of service requirements. State plans must go beyond strategies for the general population; they must expressly define coordination of services for individuals with barriers to employment, veterans, unemployed workers, and youth. There are also program-specific requirements. For instance, Title I Adult programs must provide priority of service “to individuals who are low income, public benefit recipients, or basic skills deficient,” while Title II programs must prioritize incarcerated populations likely to re-enter society within 5 years of program participation.

Plans will also include assurances that the state had “input into the development” and “provided an opportunity to comment” to a wide range of stakeholders, including the general public.

State plans are due to the federal agencies on March 3, 2016. In the coming weeks, CLASP will be releasing “Opportunities for Action,” a series of short topical memos with recommendations for WIOA state plans, local plans, policies and guidance, and budget choices that can realize the promise of WIOA for helping low-income youth and adults succeed economically. Do not miss this important opportunity to shape critical workforce development services in your region.

* Career and technical education programs authorized under the Carl D. Perkins Career and Technical Education Act of 2006 (20 U.S.C. 2301 et seq.);Temporary Assistance for Needy Families Program (42 U.S.C. 601 et seq.); Employment and Training Programs under the Supplemental Nutrition Assistance Program (Programs authorized under section 6(d)(4) of the Food and Nutrition Act of 2008 (7 U.S.C. 2015(d)(4))); Work programs authorized under section 6(o) of the Food and Nutrition Act of 2008 (7 U.S.C. 2015(o)); Trade Adjustment Assistance for Workers Programs (Activities authorized under chapter 2 of title II of the Trade Act of 1974 (19 U.S.C. 2271 et seq.)); Jobs for Veterans State Grants Program (Programs authorized under 38, U.S.C. 4100 et. seq.); Unemployment Insurance Programs (Programs authorized under State unemployment compensation laws in accordance with applicable Federal law); Senior Community Service Employment Program (Programs authorized under title V of the Older Americans Act of 1965 (42 U.S.C. 3056 et seq.)); Employment and training activities carried out by the Department of Housing and Urban Development; Community Services Block Grant (Employment and training activities carried out under the Community Services Block Grant Act (42 U.S.C. 9901 et seq.)); Reintegration of Ex-Offenders Program (Programs authorized under section 212 of the Second Chance Act of 2007 (42 U.S.C. 17532)).