NAWB is pleased to share our feedback on the Senate discussion draft to reauthorize the Workforce Innovation and Opportunity Act (WIOA). As noted on NAWB Blog, the Senate Health, Education, Labor, and Pensions (HELP) Committee released a discussion draft and opened a process for collecting feedback prior to a formal bill introduction.
All feedback is due to the Senate HELP Committee in a specific format by 5pm ET on Friday, July 5, 2024. NAWB members are encouraged to participate in this process, either reinforcing the messages below, or with their own feedback.
NAWB worked closely with our members and partners, including organizations focused on the needs of local communities; convened NAWB members through a Public Policy PowerUp, formerly known as Policy, Coffee and Conversation; and convened the Campaign to Invest in America’s Workforce coalition, to gather feedback on the proposal and develop strategies for engagement.
We are concerned with several provisions of the discussion draft:
Redesignation of Workforce Development Areas Must be Based on Local Needs, Result in Improved Outcomes, and Ensure Service Delivery (sec. 115; p. 23-30)
Local workforce systems and related infrastructure exist to address the unique needs and challenges of the communities that they are designed to serve. Redesignation of local workforce areas should only be undertaken if they will result in improved outcomes for WIOA participants. Strong quality assurances must be in place to prevent inequitable service delivery for the underserved and marginalized populations WIOA prioritizes and to ensure adequate service delivery in rural communities and for small and medium sized employers.
Feedback: NAWB recommends a redesignation only take place with the consent of local workforce leaders and that a redesignation process lead to improved outcomes and service delivery.
State Single Area Designations are an Extraordinary Step that Should Not be Taken Lightly
(sec. 115, p. 33-35)
The draft Senate bill would allow 25 states to adopt a single area statewide designation, which would eliminate critical local workforce infrastructure.
Feedback: NAWB recommends that state legislatures have a wider role in such a determination; changing the state population threshold from 5 million to 1 million to be considered for a single-state designation; reducing the number of existing local areas (from five to three) to be eligible for a single state designation; and a shorter reconstitution timeline should a state’s efforts not prove effective.
Requiring Six New Standing Committees Will Divert Staff Time and Resources Away from Essential Services (sec. 116, p. 36-37)
The 2014 reauthorization law streamlined the structure of standing committees. While well-intentioned, standing committees, as proposed in the draft, divert staff time, attention, and related resources towards inward-facing administrative activities rather than on cultivating external partnerships with employers and other stakeholders in the wider community. This is a particularly burdensome requirement because the discussion draft allows states to reserve a quarter of WIOA formula resources for purposes beyond local workforce areas (see "A 25% Set-aside Diverts Resources from Local Communities" below) and encourages consolidation within these same communities. Taken together, these provisions appear to be at odds given that fewer local WIOA resources will necessarily result in reduced local board capacity to regularly administer and operate these newly required standing committees.
Feedback: NAWB recommends standing committees remain optional so local workforce boards can make decisions that best reflect the needs of their communities.
Local Workforce Boards Must Retain Optimum Policymaking Authority (sec. 116, p. 42, line 14)
In current law, members of a local board must have “optimum policymaking authority” within the organization or entity they represent. This existing requirement helps to ensure that decisions and strategic guidance provided by local workforce boards can be implemented effectively. The discussion draft proposes to eliminate this requirement.
Feedback: NAWB recommends retaining this provision of current law.
Establish One-Stop Delivery Systems Where Appropriate (sec. 121, p. 87)
Local workforce boards need flexibility to establish one-stop operators according to local needs.
Feedback: NAWB recommends empowering local workforce boards to serve as one-stop operators if they meet certain conditions.
A 25% Set-aside Diverts Resources from Local Communities (sec. 132, p. 138, line 9)
Under current law, a governor may reserve 15% of WIOA formula funding for statewide initiatives. The draft Senate bill would allow an additional 10% to be set aside for the implementation of industry and sector partnerships, as well as employer-based training activities. While NAWB supports these initiatives, these funds should not come at the expense of local areas.
Feedback: NAWB recommends alternative funding mechanisms for these activities that do not shortchange local communities.
Clarify the Use of Funds for Youth Workforce Experience Activities (sec. 133, p. 155, lines 4-8)
NAWB supports the clarification of local workforce boards’ budgetary authority over the administration of adult, dislocated workers, and youth workforce development activities. However, the changes envisioned within the youth formula funding stream related to mandated work experiences are overly prescriptive and will create significant new disincentives for employers to engage with the public workforce system.
Feedback: NAWB recommends reducing these requirements to maximize flexibility and to ensure that small and medium sized employers can engage with the public workforce system.
Funding the Workforce System Maximizes Local Economic Vitality (sec. 149, p. 234-235)
Through local workforce boards and the more than 2,000 American Job Centers across the nation, nearly three million jobseekers access quality training and supportive services. However, funding for core Title I WIOA programs has eroded steadily over the past several decades, and rampant inflation has made things worse. Without a specific authorized funding amount, NAWB is concerned that the wider Congressional appropriations process will continue to underfund the public workforce system, and thereby reduce its ability to meet current and emerging needs in state and local economies. Increasing investments in WIOA is critical to ensure that employers have the skilled talent they need while also supporting some of our most vulnerable and underserved populations in participating within the labor market.
Feedback: NAWB recommends the bill include a significantly increased authorization of funds for the next five years to provide a clear signal to appropriators that a greater investment is needed to effectuate the changes envisioned within this discussion draft.
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