New York State Workforce Development System New York State
Technical Advisory
 
May 3, 2005
Workforce Development System Technical Advisory #05-6
 
TO: Chairpersons of Local Workforce Investment Boards
Chief Elected Officials
WIA Grant Recipients
WIA Fiscal Agents
WIA Local Area Contact Persons
Attention:Local Workforce Investment Areas (LWIAs) that will use a local proprietary system for WIA case management and reporting under common measures.
SUBJECT:Requirements of the LWIA Compliance Plans for Modifying Proprietary Case Management and Reporting Systems to address U.S. Department of Labor, Employment and Training Administration’s (USDOL/ETA’s) Common Measures Policy
PURPOSE:In follow up to WDS Technical Advisory (TA) #05-2, issued February 4, 2005, to issue requirements of the LWIA Compliance Plan for bringing a local proprietary WIA case management and reporting system into compliance with USDOL/ETA’s Common Measures Policy
Background:WDS TA #05-2 advised LWIAs that use a local proprietary WIA case management and reporting system, of their responsibility for implementing USDOL/ETA’s Common Measures Policy. The TA advised LWIAs that the Department would be providing requirements of the LWIA Compliance Plan in a subsequent TA.

Subsequent to WDS TA #05-2, USDOL/ETA issued the following additional guidance on their Common Measures Policy. These documents are of critical importance in developing the local compliance plan.

  • “Common Measures Policy” USDOL/ETA Training and Employment Guidance Letter (TEGL) 28-04, April 15, 2005 (Rescission of TEGL 15-03)
  • Workforce Investment Act Standardized Reporting Database (WIASRD) specifications for common measures – USDOL/ETA Information Collection Request (ICR) / WIA Management Information and Reporting System / Federal Register / Vol.70, No.59 / Tuesday March 29, 2005 / Notices
Additional References

  • WDS TA #05-2, LWIA plans and strategies to comply with reporting requirements under the U.S. Department of Labor’s (USDOL) “Common Measures Policy” and “ETA Management Information and Longitudinal Evaluation (EMILE) Reporting System,” February 4, 2005
  • NYSDOL Comments on EMILE Reporting System, September 10, 2004 – In response to USDOL’s Federal Register Notice of July 16, 2004 (below)
  • USDOL/ETA, “Proposed Information Collection Request Submitted for Public Comment and Recommendations; ETA Management Information and Longitudinal Evaluation (EMILE) Reporting System,” Federal Register / Vol. 69, No. 136, July 16, 2004
  • WDS TA #04-18, “Common Measures Youth Literacy and Numeracy Gains – New Requirement to Provide Guidelines on Entering Literacy and Numeracy Data into OSOS,” September 20, 2004
  • WDS TA #04-5, “NYSDOL Policy Regarding the Implementation of Common Performance Measures for Workforce Investment Act Title 1B Employment and Training Programs,” May 7, 2004
  • USDOL/ETA, “Common Measures Policy”, TEGL 15-03, December 10, 2003
Action:The LWIA Compliance Plan should be submitted to NYSDOL by July 1, 2005 via email to Anthony.Joseph@labor.state.ny.us.

The requirements of the LWIA Compliance Plan for bringing the local WIA proprietary system into compliance with USDOL’s Common Measures Policy are as follows:

  1. Expertise
    List the individuals to be engaged in identifying and completing the required modifications to the local proprietary WIA case management and reporting system, specify their role, and describe their qualifications.

  2. Modifications
    Describe in detail, each modification that will be required to address each of the new WIASRD Reporting requirements. Attachment A “Description of Required Modifications” provides a template (listing each required WIASRD item) which is to be used to describe the required modifications, include the procedure for testing the accuracy of the modification. NYSDOL is particularly interested in the LWIA’s plan regarding reporting on individuals who “Received Core Self-Services and Informational Activities” (Item 331) and “Date of Exit” (Item 303). The completed Attachment A “Description of Required Modifications” is to be submitted with the compliance plan. The local area should refer to Federal Register Notice, March 29, 2005, Attachment A, WIASRD, General Reporting Instructions and Specifications) for definitions of the listed WIASRD items.

  3. Access
    Describe the plan / modifications necessary to provide NYSDOL oversight staff with the same level and type of access as provided under the OSOS.

  4. Management Reports
    Describe the plan / modifications necessary to provide NYSDOL staff with the same management reports capability as provided under the OSOS LWIA MR.

  5. Project timeline
    Attachment B “Project Time-Line” provides a template which is to be used to specify the timeframe to complete each required modification identified in Attachment A, including testing. The completed Attachment B “Project Time-Line”” is to be submitted with the compliance plan.

  6. Project Budget
    Prepare a detailed project budget identifying the financial resources needed to complete the modifications. In addition, the project budget must address the following:

    1. State level WIA funds are not available to support bringing a local proprietary system into compliance with federal reporting requirements. The project budget must identify the local formula Program Year resources to be used to support the work to be completed.
    2. Commencing with the WIA PY 2005 Quarter 2 report to USDOL (i.e., December 31, 2005), the processing by NYSDOL of a WIASRD submittal from a local proprietary system will be a fee for service activity. Specifically, the costs incurred by NYSDOL, attributable to accepting and processing a WIASRD submittal will be charged to the local area at a rate of $150 per hour. This would apply to a Local area that has not completed conversion to OSOS.

      The project budget must include an allocation for WIASRD processing. To estimate the allocation, Local areas should contact NYDOL’s Division of Research & Statistics, via email to William.Meehan@labor.state.ny.us, to request an estimate of the number of hours based upon prior history of WIASRD processing. Please note that funds estimated for WIA processing will be retained from the LWIA’s NOA. Any balance will be refunded at the conclusion of each program year.

  7. EMILE
    USDOL/ETA has moved implementation of the EMILE reporting system to PY 2006, to allow States to first implement the common measures component of their EMILE initiative. Compliance with the

    1. Job seeker Standardized Individual Record (SIR) across the multiple programs reported on the SIR, including a single “soft” exit across these programs (based on the 90 day soft exit rule), and the
    2. Business SIR across multiple programs,

    as proposed in USDOL’s EMILE Reporting System, Federal Register Notice (Vol. 69, No. 136, July 16, 2004) will require substantial modifications to local area proprietary systems, beyond those required for compliance with TEGL 28-4. Therefore, the local compliance plan must recognize that additional work will need to be done when USDOL begins implementation of the EMILE reporting system.

The Department will be issuing a Technical Advisory containing the exact file specifications for the WIASRD Quarterly and Annual reports. Note that, the specifications will be similar to that presented in Attachment A of the USDOL/ETA ICR (March 29, 2005). In addition, NYSDOL will continue to require LWIAs to report social security number, office identification (ID) number, office name, and State supplemental funding indicators and date of last service.

Questions may be directed to Mr. Stephen Ryan at (518) 457-0000 or at Stephen.Ryan@labor.state.ny.us

Attachments: A. Description of Required Modifications
B. Project Time Line