This is the accessible text file for GAO report number GAO-05-539 
entitled 'Workforce Investment Act: Labor Should Consider Alternative 
Approaches to Implement New Performance and Reporting Requirements' 
which was released on May 27, 2005. 

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Report to Congressional Requesters: 

United States Government Accountability Office: 

GAO: 

May 2005: 

Workforce Investment Act: 

Labor Should Consider Alternative Approaches to Implement New 
Performance and Reporting Requirements: 

GAO-05-539: 

Contents: 

Letter: 

Appendix I: Briefing Slides: 

Appendix II: Additional State Survey Data: 

Appendix III: Comments from the Department of Labor: 

GAO Response: 

Appendix IV: GAO Contacts and Staff Acknowledgments: 

GAO's Related Products: 

Tables: 

Table 1: Which States Have IT Systems that Collect Information on the 
WIA Title I-B Programs and also Currently Capture Program Information 
for Other U.S. Department of Labor (USDOL) Employment and Training 
Administration Programs?

Table 2: Which States Have IT Systems that Collect Information on the 
WIA Title I-B Programs and also Currently Capture Program Information 
for Other One-Stop Partner Programs?

Table 3: Status of Statewide Systems to Collect Unique Identifiers For 
All Jobseekers and Employers Who Use the One-Stop System: 

Table 4: From the time your state first began implementing changes to 
the IT system under WIA, about how long did it take your state to fully 
implement the IT system changes that were necessary to meet the federal 
requirements for the quarterly reports, annual report, and WIASRD 
(Workforce Investment Act Standardized Record Data)?

Table 5: Compared to the effort your state invested in the transition 
from the Job Training Partnership Act (JTPA) to WIA, how much effort do 
you anticipate investing in implementing EMILE, as proposed?

Table 6: About how long do you estimate it will take your state to 
fully implement the necessary changes for EMILE, as proposed, once 
Labor's requirements are final?

Abbreviations: 

EMILE: ETA Management Information and Longitudinal Evaluation: 

ETA: Employment and Training Administration: 

IT: information technology: 

WIA: Workforce Investment Act: 

United States Government Accountability Office: 

Washington, DC 20548: 

May 27, 2005: 

The Honorable Michael B. Enzi: Chairman: 
The Honorable Edward M. Kennedy: Ranking Minority Member: Committee on 
Health, Education, Labor, and Pensions: United States Senate: 

The Honorable Patty Murray: Ranking Minority Member: Subcommittee on 
Employment and Workplace Safety: Committee on Health, Education, Labor, 
and Pensions: United States Senate: 

In a period of significant budget constraints, it is more vital than 
ever for federal programs to have good performance information. The 
Workforce Investment Act (WIA) of 1998 took a significant step in that 
direction by introducing greater accountability for employment and 
training programs than prior programs. WIA established performance 
measures to look at a broad array of participant outcomes such as job 
placement and retention, earnings, skill gains, and customer 
satisfaction. WIA also required 17 programs, funded by four different 
agencies, to centralize service delivery through a one-stop center 
system. More recently, as part of efforts to link program performance 
to the budget, the Office of Management and Budget (OMB) introduced 
common performance measures--similar to some of the WIA measures--for 
most federally funded job training programs that share similar goals. 
The U.S. Department of Labor's (Labor) Employment and Training 
Administration (ETA) further defined the common measures for all 
programs it oversees and proposed a new, standardized reporting format, 
known as the ETA Management Information and Longitudinal Evaluation 
(EMILE) reporting system to facilitate reporting them. However, state 
workforce agencies and others raised substantial concerns about the 
timing and scope of the EMILE reporting system. Despite delaying EMILE, 
Labor recently took steps to move ahead with reporting changes for the 
common measures, requiring states to implement these changes by July 1, 
2005. 

Given the importance of these issues and their potential impact on the 
quality of the performance data, you asked us to examine (1) states' 
concerns about implementing Labor's proposed EMILE reporting system and 
(2) the effect that the implementation of common measures and other new 
reporting changes might have on states' ability to collect data and 
report on WIA's performance. 

To address these issues, we conducted a Web-based survey and received 
responses from 48 of the 50 states. We did not include Washington, D.C. 
and U.S. territories in our survey. In addition, we visited New York, 
West Virginia, California, Texas, and Wyoming, and two local areas in 
each state. We selected these states because they represent a range of 
information technology (IT) systems--statewide comprehensive systems 
versus local systems with a state reporting function, include single 
and multiple workforce areas, and are geographically diverse. To learn 
more about proposed reporting changes, we met with U.S. Department of 
Labor officials and reviewed legislation, federal guidance, and other 
documents relevant to WIA's reporting system. We also reviewed the 
official responses of six associations and 38 states to the July 2004 
Federal Register Notice that introduced the EMILE reporting system. We 
conducted our work from June 2004 through April 2005 in accordance with 
generally accepted government auditing standards. 

On April 21, 2005, we provided a briefing on the results of our work to 
your staff. This report formally conveys the information provided 
during that briefing, which is contained in appendix I. We also 
provided some additional state survey data in appendix II. 

In summary, we found that while many states supported streamlined 
reporting, 36 states indicated that implementing the EMILE system, as 
proposed, would be very burdensome. Most states indicated that 
launching EMILE would require as much or more effort than was required 
of them to meet WIA reporting requirements in 2000. Labor has 
underestimated the magnitude and type of changes EMILE would require 
and the resources states would need in order to implement it. Labor 
developed EMILE with limited consultation with state officials. 

While the use of the common measures could increase the comparability 
of outcome information across programs and provide a more complete 
picture of the one-stop system, states will face challenges in making 
the required changes. For example, states will be required to track all 
jobseekers who receive services at one-stop centers, although it is 
unclear how many states and local areas are prepared to do so. In 
addition, one of the common measures will replace the current WIA 
earnings measure for dislocated workers, which may be a disincentive 
for serving this population. Moreover, states have very little time to 
make the necessary changes before they must begin data collection and 
reporting using the new requirements. While Labor publicized its plans 
to adopt the common measures, states were notified only in late 
February that Labor planned to implement changes on July 1, 2005, and 
final guidance was not issued until April 15, 2005. 

In conclusion, Labor's initiatives to introduce common measures and a 
comprehensive reporting system could foster program integration and 
provide a better picture of WIA's reach, but Labor underestimated the 
cost, time, and effort required of states to make such changes. Ongoing 
consultation with states and pilot testing may have enhanced Labor's 
effort to move forward with EMILE. Labor has not provided guidance in a 
timely manner for states to implement the changes related to the common 
measures. Rushed implementation could negatively affect data quality 
and compromise the potential benefits of proposed changes. While some 
states have the capacity to collect and report data on all jobseekers, 
many others do not, and states and local areas need enough time to 
fully meet these requirements. Moreover, unless Labor ensures that 
states collect the data in a consistent manner, the information will 
not be comparable across states. 

To ensure states' ability to implement proposed reporting system 
changes, we recommend that Labor consider alternative approaches to 
reach the goals of EMILE and perform an assessment that considers the 
costs and benefits. To help states and local areas develop the capacity 
to track all jobseekers who use one-stop services in a consistent 
manner, Labor should use the first year as a test phase and work with 
states to identify promising practices in collecting and reporting this 
data, and provide technical assistance to states that do not have this 
capacity. 

We provided officials at the Department of Labor an opportunity to 
comment on a draft of this report. Labor agreed with our recommendation 
that it work with states in identifying promising practices to ensure 
that states and local areas track all jobseekers in a consistent 
manner. Labor did not respond to our recommendation that it consider 
alternative approaches to reach the goals of EMILE. In addition, Labor 
raised concerns about some of the material in the report. We believe 
these concerns do not require changes to the material. Labor's comments 
and a more detailed discussion of our response are in appendix III. 
Labor also provided technical comments, which we have incorporated in 
our report, as appropriate. 

We will send copies of this report to relevant congressional 
committees, the Secretary of Labor, and other interested parties. We 
will also make copies available to others upon request. The report will 
be available at no charge on GAO's Web site at http://www.gao.gov. 

A list of related GAO products is included at the end of this report. 
If you or members of your staff have any questions about this report, 
please contact me at (202) 512-7215 or Dianne Blank at (202) 512-5654. 
You may also reach us by e-mail at nilsens@gao.gov or blankd@gao.gov. 
Other contacts and staff acknowledgments are listed in appendix IV. 

Signed by: 

Sigurd R. Nilsen, Director: Education, Workforce, and Income Security 
Issues: 

[End of section]

Appendix I: Briefing Slides: 

Workforce Investment Act: States Are Challenged to Meet Proposed New 
Reporting Requirements: 

Briefing to Congressional Requesters: 

April 21, 2005: 

Research Objectives: 

What are states' concerns about implementing Labor's proposed ETA 
Management Information and Longitudinal Evaluation (EMILE) reporting 
system?

What effect might implementation of common measures and other new 
reporting changes have on states' ability to collect data and report on 
WIA's performance?

Scope and Methodology: 

Conducted a Web-based survey of all states (results represent 48 
states);

Visited 5 states (California, New York, Texas, West Virginia, and 
Wyoming) and 2 local areas in each;

Reviewed 6 associations' and 38 states' comments to Federal Register 
Notice on the proposed EMILE reporting system;

Interviewed Labor officials;

Reviewed legislation, federal guidance, and other documents relevant to 
WIA's reporting system;

Our work was performed from June 2004 to April 2005 in accordance with 
generally accepted government auditing standards. 

Summary of Findings: 

While states said they support the overall direction of Labor's EMILE 
reporting system, they have concerns about the burden and time needed 
to implement proposed changes. 

Common measures and new reporting changes can provide a better picture 
of the one-stop system, but implementation will pose challenges for 
states and could affect WIA's reported performance, if not implemented 
carefully. 

Background: WIA Introduced Major Changes to Performance Measurement: 

The Workforce Investment Act (WIA) of 1998 promoted greater 
accountability for job training programs by: 

* establishing new performance measures for the 3 WIA-funded programs 
(Adult, Dislocated Worker, and Youth);

* requiring the use of the Unemployment Insurance (UI) wage records to 
track and report outcomes;

* requiring Labor to negotiate performance goals with states and award 
incentives and impose sanctions based on the performance; and: 

* requiring Labor to conduct impact evaluations of the WIA-funded 
programs. 

Background: Performance Reports for WIA: 

Labor currently collects WIA participant and performance data through 
quarterly and annual reports and a more detailed annual file: 

* Quarterly and annual reports provide a summary of states' performance 
on the 17 core measures. The annual reports are used for determining 
incentives and sanctions. 

* The annual Workforce Investment Act Standardized Record Data (WIASRD) 
provides characteristics, activities, and outcome information on 
registered participants who exited WIA services during a program year. 

Background: Which Job Seekers are Reported: 

WIA Performance Measures Track and Report: 

Adults and Dislocated Workers: 

Those who receive services requiring significant staff assistance and 
who complete or exit WIA and partner services. 

All Youth: 

Those who are determined eligible and receive WIA services. 

Not Tracked and Reported: 

Those using self-assisted services and receiving limited staff 
assistance. 

Background: History of Concerns over WIA Performance Data: 

Timeliness of Guidance: 

Guidance delayed - In a previous study, we found that Labor's final 
guidance on how to report WIA performance data was issued 8 months 
after states were required to begin collecting data. 

Data Quality: 

Data not reliable - We and others have found that WIA performance data 
are not sufficiently reliable to determine outcomes. Concerns include 
the lack of consistent definitions, which leads to variations in 
reporting. 

Data Comprehensivenes: 

Incomplete picture of one-stop system - States are not required to 
track and report on all customers being served. 

Note: Labor implemented new data validation requirements in 2004 to 
address data quality issues. 

Background: OMB Introduced Common Measures for WIA and Other Workforce 
Programs: 

April 2002 - The Office of Management and Budget (OMB) introduced 
common performance measures for WIA and other federal job training 
programs as part of efforts to link program performance to the budget. 

* Common measures provide a tool for comparing performance across 
programs with similar goals. 

* A common goal of job training programs is to improve participants' 
employment and earnings. Yet without common measures, each program 
measures these goals in a different way. 

* Common measures apply to job training programs administered by Labor, 
Education, Health and Human Services, Housing and Urban Development, 
Interior, and Veterans Affairs. 

Dec. 2003 - Labor developed standard definitions for common measures 
for its Employment and Training Administration (ETA) programs. 

Background: Common Measures are Similar to Some of the WIA Measures: 

[See PDF for image]

[End of table]

Background: Labor Followed with a Comprehensive Proposal: 

July 2004 - Labor proposed a comprehensive reporting system as a 
vehicle to collect data for the common measures and to integrate 
reporting for WIA with other ETA job training programs. Labor targeted 
July 1, 2005 for implementation. The proposed ETA Management 
Information and Longitudinal Evaluation (EMILE) system would: 

* Combine 12 program reporting systems into one reporting structure: 

* Replace the current WIA quarterly report, WIASRD, and other programs' 
reports with 3 new reports;

- an employer individual record,

- a  individual record, and: 

- a Workforce Investment Quarterly Summary: 

Note: EMILE was proposed in a Federal Register Notice on July 16, 2004, 
for public comment. 

Background: Labor Delayed EMILE but Moved Ahead with Common Measures: 

Comments to Federal Register Notice Delayed EMILE: 

Following the volume of responses to the July 2004 Federal Register 
Notice on EMILE, (166 responses with comments from 38 states), Labor 
delayed implementation. 

New Guidance to Move Forward on Common Measures: 

* Feb. 2005 - Labor issued guidance notifying states of plans to 
implement the common measures (along with some additional reporting 
changes) for 4 programs: 

- by July 1, 2005 for WIA, Wagner-Peyser, and Veterans' Employment and 
Training Service programs,

- by Oct. 1, 2005 for the Trade Adjustment Assistance program. 

Objective One: States Support Streamlined Reporting, but Concerned with 
EMILE Proposal: 

Of the 38 states that provided comments to the July 2004 Federal 
Register Notice: 

* Nineteen states supported the goal of EMILE to have a more integrated 
reporting system than current individual program systems. 

* Nearly all-36 states-expressed concerns that implementation would be 
burdensome. 

Objective One: Changes to Reporting Systems Involve People, Process, 
and Technology: 

[See PDF for image]

[End of figure]

Objective One: Prior Changes to IT Systems for WIA Required Significant 
Effort: 

All 48 states responding to our survey made changes to their 
information technology (IT) systems under WIA, such as adding new data 
elements and reporting capabilities. 

* 37 states made major system changes such as building a completely new 
system or switching to internet-based software: 

* Four states said that they developed new IT systems when WIA began 
and have changed IT systems again because their first system was 
inadequate. 

Objective One: 24 States Took More than 1 Year to Change IT Systems for 
WIA: 

[See PDF for image]

[End of figure]

Objective One: 31 States Said EMILE Would Require as Much or More 
Effort than WIA: 

[See PDF for image]

[End of figure]

Objective One: States said EMILE Would Affect People, Process, and 
Technology: 

[See PDF for image]

[End of figure]

Objective One: State Estimates of EMILE Start-up Costs Far Exceed 
Labor's Estimates: 

[See PDF for image]

[End of table]

Objective One: Labor's Estimated Burden for State Implementation Is Too 
Low: 

Labor's start-up estimates for EMILE assume that half of the states 
have a consolidated IT system for state-run programs-WIA, Wagner- 
Peyser, Trade Adjustment Assistance, and National Emergency Grants: 

* However, our survey results show that while 21 states have an IT 
system collecting data for these programs, they may not be truly 
consolidated. 

Labor expects states to pay for all of the changes needed for EMILE 
with no additional funding. 

Labor developed its estimates with limited consultation with state 
officials. 

Objective One: New Guidance and Training Would Require as Much Effort 
as IT Changes: 

States That Said Changes Would Require Moderate to Very Great Efforts: 

[See PDF for image]

[End of figure]

Objective One: 20 States Estimate Changes for EMILE Would Take More 
than 1 Year: 

[See PDF for image]

[End of figure]

Objective One: Labor is Now Rethinking EMILE and States Have Suggested 
Alternatives: 

Labor is conducting a feasibility study to gauge the impact of EMILE 
implementation on states. Study is expected to be completed in December 
2005. 

Some states have suggested alternative approaches for implementing 
reporting system changes such as EMILE: 

* Ten states suggested that Labor adopt a phased approach for 
implementing EMILE. 

* Four states suggested that Labor pilot reporting changes prior to 
full implementation. 

Objective Two: Common Measures and Other Changes Have Benefits, but 
Pose Challenge: 

Benefits: 

* Common measures will allow Labor to describe outcomes in a similar 
manner across employment and training programs. 

* New reporting change to track all jobseekers will provide a more 
complete picture of the one-stop system. 

Challenges: 

* Requires new data elements in addition to existing reporting 
requirements. 

* Changes how WIA dislocated workers' earnings outcomes are counted. 

* States may not be prepared to track all jobseekers. 

* States may not have enough time to implement changes. 

Objective Two: Common Measures and New Reporting Include Some Major 
Data Changes: 

New and revised measures: 

- Begin reporting data for 2 new youth measures in addition to WIA 
measures: 

- Changes WIA's earnings measure for dislocated workers: 

New and changed data collection: 

- Collect and report data on all jobseekers by including those who only 
use self-assisted services. 

- No more "hard exits"--exiting a participant on a date of case 
closure, or completion of services. Program exit will be determined 
only when an individual has not received any service from any partner 
program for 90 days. 

Objective Two: Changes to WIA's Performance Measure for Dislocated 
Workers: 

The current dislocated worker program earnings replacement rate measure 
will be changed to a 6-month earnings increase measure. 

[See PDF for image]

[End of figure]

Objective Two: Changes May Negatively Affect Reported Performance: 

Few Dislocated Workers Achieve Wage Gains: 

* Dislocated workers generally earn less after program exit than prior 
to separation from employment. 

* With new measure, pre-program wages for dislocated workers may be 
inflated by severance pay, making it even more difficult to show any 
wage gain. 

Labor's Remedy: 

* Allow states to subtract severance pay from pre-program wages found 
in the UI wage records, although it is not clear whether states have 
the capacity to do this. 

Objective Two: State Capacity to Collect Data on All Jobseekers Varies: 

While 30 states reported on our survey that they have a state system to 
track all jobseekers, it is not clear how many are ready to report this 
information to Labor. 

* Texas and California can track all jobseekers in their state IT 
systems, but do not require local areas to report this information. 

* A previous GAO study found that just over half of local areas track 
jobseekers who repeatedly use one-stops, suggesting that some locals 
have capacity to uniquely identify and track each jobseeker. 

* New York took 1 ½ years to implement local swipe card systems across 
the state to collect information on all jobseekers at one-stops. 
However, the local swipe card systems are not connected to the state's 
WIA reporting system. 

Objective Two: Timeline for Implementing New Common Measures Reporting 
Requirements: 

[See PDF for image]

[End of figure]

Conclusions: 

Labor's plans to implement comprehensive reporting and common measures 
across workforce programs could help foster integration and provide a 
better picture of the one-stop system. 

However, Labor underestimated costs, time, and efforts for states to 
make changes. 

While Labor is now conducting a feasibility study of EMILE, ongoing 
consultation with states and pilot testing may have enhanced Labor's 
earlier efforts. 

In the past and with new requirements, Labor has not provided guidance 
in a timely manner for states to implement changes. 

Rushed implementation could negatively affect data quality, and 
compromise the potential benefits of proposed changes. 

Collecting data on all jobseekers using one-stops can help provide a 
better picture of the full reach of WIA. 

* Some states have this capacity, but many do not. 

* States and local areas need time to fully develop capacity to collect 
and report this information. 

* Unless Labor ensures that data collection is done in a consistent 
manner, the information will not be comparable on a national level. 

States may see the earnings increase measure as a disincentive for 
serving dislocated workers if these changes are not accounted for in 
negotiating performance goals. 

Recommendations: 

To ensure states' ability to implement proposed reporting system 
changes: 

Labor should consider alternative approaches to reach the goals of 
EMILE and perform an assessment that considers the costs and benefits 
of such investments. Alternative approaches could include: 

* ongoing consultation with key stakeholders;

* implementing changes in phases; and: 

* pilot testing and evaluating changes before full implementation. 

To help states and local areas develop the capacity to track all 
jobseekers who use one-stop services in a consistent manner, Labor 
should: 

* Use the first year of implementation as a test phase and work with 
states to identify promising practices in collecting and reporting this 
data, and provide technical assistance to states that do not have this 
capacity. 

[End of slide presentation] 

[End of section]

Appendix II: Additional State Survey Data: 

Table 1: Which States Have IT Systems that Collect Information on the 
WIA Title I-B Programs and also Currently Capture Program Information 
for Other U.S. Department of Labor (USDOL) Employment and Training 
Administration Programs?

State name: Alaska; 
National Emergency Grants; H-1B Technical Skills Training Grants; Total 
ETA: 2. 

State name: Alabama; 
National Emergency Grants; Welfare-to-Work grant-funded program; 
Employment and training for migrant and seasonal farm workers; Total 
ETA: 3. 

State name: Arkansas; Employment Service (Wagner-Peyser); Veterans’ 
Employment and Training Program; National Emergency Grants; Welfare-to-
Work grant-funded program; Total ETA: 4. 

State name: California; National Emergency Grants; Welfare-to-Work 
grant-funded program; Total ETA: 2. 

State name: Colorado; Employment Service (Wagner-Peyser); Trade 
Adjustment Assistance; Veterans’ Employment and Training Program; 
National Emergency Grants; Welfare-to-Work grant-funded program; 
Employment and training for migrant and seasonal farm workers; 
Responsible Reintegration of Youthful Offender Grants; H-1B Technical 
Skills Training Grants; Total ETA: 8. 

State name: Connecticut; Employment Service (Wagner-Peyser); Veterans’ 
Employment and Training Program; Employment and training for migrant 
and seasonal farm workers; Total ETA: 3. 

State name: Delaware; Employment Service (Wagner-Peyser); Trade 
Adjustment Assistance; Veterans’ Employment and Training Program; 
National Emergency Grants; Employment and training for migrant and 
seasonal farm workers; Total ETA: 5. 

State name: Florida; 
Employment Service (Wagner-Peyser); Veterans’ Employment and Training 
Program; National Emergency Grants; Total ETA: 3. 

State name: Georgia; 
Employment Service (Wagner-Peyser); Trade Adjustment Assistance; 
Veterans’ Employment and Training Program; National Emergency Grants; 
Welfare-to-Work grant-funded program; Employment and training for 
migrant and seasonal farm workers; Total ETA: 6. 

State name: Hawaii; 
Employment Service (Wagner-Peyser); Trade Adjustment Assistance; 
Veterans’ Employment and Training Program; National Emergency Grants; 
Employment and training for migrant and seasonal farm workers; Total 
ETA: 5. 

State name: Iowa; 
National Emergency Grants; Welfare-to-Work grant-funded program; Total 
ETA: 2. 

State name: Idaho; 
National Emergency Grants; Senior Community Service Employment program; 
Total ETA: 2. 

State name: Illinois; Trade Adjustment Assistance; National Emergency 
Grants; Welfare-to-Work grant-funded program; Total ETA: 3. 

State name: Indiana; 
National Emergency Grants; Total ETA: 1. 

State name: Kansas; 
Employment Service (Wagner-Peyser); Trade Adjustment Assistance; 
Veterans’ Employment and Training Program; Unemployment Insurance 
Program; National Emergency Grants; Job Corps; 
Welfare-to-Work grant-funded program; Senior Community Service 
Employment program; Employment and training for migrant and seasonal 
farm workers; Employment and Training for Native Americans; Total ETA: 
10. 

State name: Kentucky; Employment Service (Wagner-Peyser); Trade 
Adjustment Assistance; Veterans’ Employment and Training Program; 
Unemployment Insurance Program; National Emergency Grants; Employment 
and training for migrant and seasonal farm workers; Total ETA: 6. 

State name: Louisiana; Employment Service (Wagner-Peyser); Veterans’ 
Employment and Training Program; National Emergency Grants; Welfare-to-
Work grant-funded program; Total ETA: 4. 

State name: Massachusetts; Employment Service (Wagner-Peyser); Trade 
Adjustment Assistance; Veterans’ Employment and Training Program; 
National Emergency Grants; Employment and training for migrant and 
seasonal farm workers; Employment and Training for Native Americans; 
Total ETA: 6. 

State name: Maine; 
Employment Service (Wagner-Peyser); Trade Adjustment Assistance; 
Veterans’ Employment and Training Program; Unemployment Insurance 
Program; National Emergency Grants; Welfare-to-Work grant-funded 
program; Employment and training for migrant and seasonal farm workers; 
Total ETA: 7. 

State name: Michigan; Employment Service (Wagner-Peyser); Trade 
Adjustment Assistance; National Emergency Grants; Welfare-to-Work grant-
funded program; Total ETA: 4. 

State name: Minnesota; National Emergency Grants; Total ETA: 1. 

State name: Missouri; Employment Service (Wagner-Peyser); Veterans’ 
Employment and Training Program; National Emergency Grants; Welfare-to-
Work grant-funded program; Total ETA: 4. 

State name: Mississippi; National Emergency Grants; Total ETA: 1. 

State name: Montana; 
Total ETA: 0. 

State name: North Carolina; National Emergency Grants; Welfare-to-Work 
grant-funded program; Responsible Reintegration of Youthful Offender 
Grants; Total ETA: 3. 

State name: North Dakota; Employment Service (Wagner-Peyser); Trade 
Adjustment Assistance; Veterans’ Employment and Training Program; 
Senior Community Service Employment program; Total ETA: 4. 

State name: Nebraska; Trade Adjustment Assistance; National Emergency 
Grants; Total ETA: 2. 

State name: New Hampshire; National Emergency Grants; Welfare-to-Work 
grant-funded program; H-1B Technical Skills Training Grants; Total ETA: 
3. 

State name: New Jersey; Employment Service (Wagner-Peyser); Trade 
Adjustment Assistance; Veterans’ Employment and Training Program; 
National Emergency Grants; Welfare-to-Work grant-funded program; 
Employment and training for migrant and seasonal farm workers; Total 
ETA: 6. 

State name: New Mexico; Employment Service (Wagner-Peyser); Veterans’ 
Employment and Training Program; Unemployment Insurance Program; 
National Emergency Grants; Total ETA: 4. 

State name: Nevada; 
Employment Service (Wagner-Peyser); Trade Adjustment Assistance; 
Veterans’ Employment and Training Program; Unemployment Insurance 
Program; National Emergency Grants; Employment and training for migrant 
and seasonal farm workers; Total ETA: 6. 

State name: New York; Employment Service (Wagner-Peyser); Trade 
Adjustment Assistance; Veterans’ Employment and Training Program; 
Unemployment Insurance Program; National Emergency Grants; Employment 
and training for migrant and seasonal farm workers; Total ETA: 6. 

State name: Ohio; 
Employment Service (Wagner-Peyser); National Emergency Grants; Total 
ETA: 2. 

State name: Oklahoma; Employment Service (Wagner-Peyser); Trade 
Adjustment Assistance; Veterans’ Employment and Training Program; 
National Emergency Grants; Welfare-to-Work grant-funded program; Total 
ETA: 5. 

State name: Oregon; 
National Emergency Grants; Total ETA: 1. 

State name: Pennsylvania; Employment Service (Wagner-Peyser); Trade 
Adjustment Assistance; Veterans’ Employment and Training Program; 
Employment and training for migrant and seasonal farm workers; Total 
ETA: 4. 

State name: Rhode Island; Employment Service (Wagner-Peyser); Trade 
Adjustment Assistance; Veterans’ Employment and Training Program; 
National Emergency Grants; Employment and training for migrant and 
seasonal farm workers; Total ETA: 5. 

State name: South Carolina; National Emergency Grants; Total ETA: 1. 

State name: South Dakota; Employment Service (Wagner-Peyser); Trade 
Adjustment Assistance; Veterans’ Employment and Training Program; 
National Emergency Grants; H-1B Technical Skills Training Grants; Total 
ETA: 5. 

State name: Tennessee; Employment Service (Wagner-Peyser); Trade 
Adjustment Assistance; Veterans’ Employment and Training Program; 
National Emergency Grants; Total ETA: 4. 

State name: Texas; 
Employment Service (Wagner-Peyser); Trade Adjustment Assistance; 
National Emergency Grants; Welfare-to-Work grant-funded program; H-1B 
Technical Skills Training Grants; Total ETA: 5. 

State name: Utah; 
Employment Service (Wagner-Peyser); Trade Adjustment Assistance; 
Veterans’ Employment and Training Program; Unemployment Insurance 
Program; National Emergency Grants; Total ETA: 5. 

State name: Virginia; National Emergency Grants; Total ETA: 1. 

State name: Vermont; 
Trade Adjustment Assistance; National Emergency Grants; Total ETA: 2. 

State name: Washington; Employment Service (Wagner-Peyser); Trade 
Adjustment Assistance; Veterans’ Employment and Training Program; 
Unemployment Insurance Program; National Emergency Grants; Welfare-to-
Work grant-funded program; Employment and training for migrant and 
seasonal farm workers; Total ETA: 7. 

State name: Wisconsin; Employment Service (Wagner-Peyser); Trade 
Adjustment Assistance; Veterans’ Employment and Training Program; 
Unemployment Insurance Program; National Emergency Grants; Welfare-to-
Work grant-funded program; Employment and training for migrant and 
seasonal farm workers; Total ETA: 7. 

State name: West Virginia; Employment Service (Wagner-Peyser); Trade 
Adjustment Assistance; Veterans’ Employment and Training Program; 
National Emergency Grants; Job Corps; 
Welfare-to-Work grant-funded program; Employment and training for 
migrant and seasonal farm workers; Total ETA: 7. 

State name: Wyoming; 
Employment Service (Wagner-Peyser); Trade Adjustment Assistance; 
Veterans’ Employment and Training Program; Employment and training for 
migrant and seasonal farm workers; Responsible Reintegration of 
Youthful Offender Grants; Total ETA: 5. 

Source: GAO state survey. 

[End of table]

Table 2: Which States Have IT Systems that Collect Information on the 
WIA Title I-B Programs and also Currently Capture Program Information 
for Other One-Stop Partner Programs?

State name: Alaska; 
Total Partner Programs: 0. 

State name: Alabama; 
Total Partner Programs: 0. 

State name: Arkansas; Total Partner Programs: 0. 

State name: California; Total Partner Programs: 0. 

State name: Colorado; Vocational Rehabilitation program; Adult 
Education and Literacy; Vocational Education (Perkins Act); Temporary 
Assistance for Needy Families; Food Stamp Employment and Training; 
Other One-stop Partners; Total Partner Programs: 6. 

State name: Connecticut; Temporary Assistance for Needy Families; Other 
One-stop Partners; Total Partner Programs: 2. 

State name: Delaware; Total Partner Programs: 0. 

State name: Florida; 
Total Partner Programs: 0. 

State name: Georgia; 
Total Partner Programs: 0. 

State name: Hawaii; 
Food Stamp Employment and Training; Total Partner Programs: 1. 

State name: Iowa; 
Total Partner Programs: 0. 

State name: Idaho; 
Total Partner Programs: 0. 

State name: Illinois; Total Partner Programs: 0. 

State name: Indiana; 
Total Partner Programs: 0. 

State name: Kansas; 
Vocational Rehabilitation program; Adult Education and Literacy; 
Vocational Education (Perkins Act); Community Services Block Grant; HUD-
administered employment and training; Food Stamp Employment and 
Training; Other One-stop Partners; Total Partner Programs: 7. 

State name: Kentucky; Total Partner Programs: 0. 

State name: Louisiana; Community Services Block Grant; Total Partner 
Programs: 1. 

State name: Massachusetts; Total Partner Programs: 0. 

State name: Maine; 
Vocational Rehabilitation program; Total Partner Programs: 1. 

State name: Michigan; Adult Education and Literacy; Temporary 
Assistance for Needy Families; Food Stamp Employment and Training; 
Total Partner Programs: 3. 

State name: Minnesota; Temporary Assistance for Needy Families; Food 
Stamp Employment and Training; Total Partner Programs: 2. 

State name: Missouri; Temporary Assistance for Needy Families; Food 
Stamp Employment and Training; Other One-stop Partners; Total Partner 
Programs: 3. 

State name: Mississippi; Total Partner Programs: 0. 

State name: Montana; 
Total Partner Programs: 0. 

State name: North Carolina; Total Partner Programs: 0. 

State name: North Dakota; Temporary Assistance for Needy Families; 
Total Partner Programs: 1. 

State name: Nebraska; Total Partner Programs: 0. 

State name: New Hampshire; Total Partner Programs: 0. 

State name: New Jersey; Adult Education and Literacy; Temporary 
Assistance for Needy Families; Food Stamp Employment and Training; 
Other One-stop Partners; Total Partner Programs: 4. 

State name: New Mexico; Total Partner Programs: 0. 

State name: Nevada; 
Total Partner Programs: 0. 

State name: New York; Total Partner Programs: 0. 

State name: Ohio; 
Food Stamp Employment and Training; Total Partner Programs: 1. 

State name: Oklahoma; HUD-administered employment and training; Total 
Partner Programs: 1. 

State name: Oregon; 
Total Partner Programs: 0. 

State name: Pennsylvania; Food Stamp Employment and Training; Total 
Partner Programs: 1. 

State name: Rhode Island; Total Partner Programs: 0. 

State name: South Carolina; Vocational Rehabilitation program; Adult 
Education and Literacy; Vocational Education (Perkins Act); Community 
Services Block Grant; HUD-administered employment and training; 
Temporary Assistance for Needy Families; Food Stamp Employment and 
Training; Total Partner Programs: 8. 

State name: South Dakota; Total Partner Programs: 0. 

State name: Tennessee; Adult Education and Literacy; Temporary 
Assistance for Needy Families; Total Partner Programs: 2. 

State name: Texas; 
HUD-administered employment and training; Temporary Assistance for 
Needy Families; Food Stamp Employment and Training; Total Partner 
Programs: 3. 

State name: Utah; 
HUD-administered employment and training; Temporary Assistance for 
Needy Families; Food Stamp Employment and Training; Total Partner 
Programs: 3. 

State name: Virginia; Total Partner Programs: 0. 

State name: Vermont; 
Total Partner Programs: 0. 

State name: Washington; Vocational Rehabilitation program; Adult 
Education and Literacy; Vocational Education (Perkins Act); HUD-
administered employment and training; Total Partner Programs: 5. 

State name: Wisconsin; Food Stamp Employment and Training; Total 
Partner Programs: 1. 

State name: West Virginia; Total Partner Programs: 0. 

State name: Wyoming; 
Total Partner Programs: 0. 

 

Source: GAO state survey. 

[End of table]

Table 3: Status of Statewide Systems to Collect Unique Identifiers For 
All Jobseekers and Employers Who Use the One-Stop System: 

State Name: Alaska; 
State has a statewide system to collect unique identifiers for all 
jobseekers who use the one-stop system; State has a statewide system to 
collect unique identifiers for all employers who use the one-stop 
system. 

State Name: Alabama; 
State has a statewide system to collect unique identifiers for all 
employers who use the one-stop system. 

State Name: Arkansas; State has a statewide system to collect unique 
identifiers for all jobseekers who use the one-stop system; State has a 
statewide system to collect unique identifiers for all employers who 
use the one-stop system. 

State Name: California; N/A.

State Name: Colorado; State has a statewide system to collect unique 
identifiers for all jobseekers who use the one-stop system; State has a 
statewide system to collect unique identifiers for all employers who 
use the one-stop system. 

State Name: Connecticut; State has a statewide system to collect unique 
identifiers for all jobseekers who use the one-stop system; State has a 
statewide system to collect unique identifiers for all employers who 
use the one-stop system. 

State Name: Delaware; State has a statewide system to collect unique 
identifiers for all jobseekers who use the one-stop system; State has a 
statewide system to collect unique identifiers for all employers who 
use the one-stop system. 

State Name: Florida; N/A.

State Name: Georgia; N/A. 

State Name: Hawaii; 
State has a statewide system to collect unique identifiers for all 
jobseekers who use the one-stop system; State has a statewide system to 
collect unique identifiers for all employers who use the one-stop 
system. 

State Name: Iowa; 
State has a statewide system to collect unique identifiers for all 
jobseekers who use the one-stop system. 

State Name: Idaho; 
State has a statewide system to collect unique identifiers for all 
jobseekers who use the one-stop system. 

State Name: Illinois; State has a statewide system to collect unique 
identifiers for all jobseekers who use the one-stop system; State has a 
statewide system to collect unique identifiers for all employers who 
use the one-stop system. 

State Name: Indiana; N/A.

State Name: Kansas; 
State has a statewide system to collect unique identifiers for all 
jobseekers who use the one-stop system; State has a statewide system to 
collect unique identifiers for all employers who use the one-stop 
system. 

State Name: Kentucky; State has a statewide system to collect unique 
identifiers for all jobseekers who use the one-stop system; State has a 
statewide system to collect unique identifiers for all employers who 
use the one-stop system. 

State Name: Louisiana; State has a statewide system to collect unique 
identifiers for all jobseekers who use the one-stop system; State has a 
statewide system to collect unique identifiers for all employers who 
use the one-stop system. 

State Name: Massachusetts; State has a statewide system to collect 
unique identifiers for all jobseekers who use the one-stop system; 
State has a statewide system to collect unique identifiers for all 
employers who use the one-stop system. 

State Name: Maine; 
State has a statewide system to collect unique identifiers for all 
jobseekers who use the one-stop system; State has a statewide system to 
collect unique identifiers for all employers who use the one-stop 
system. 

State Name: Michigan; N/A. 

State Name: Minnesota; State has a statewide system to collect unique 
identifiers for all employers who use the one-stop system. 

State Name: Missouri; State has a statewide system to collect unique 
identifiers for all jobseekers who use the one-stop system; State has a 
statewide system to collect unique identifiers for all employers who 
use the one-stop system. 

State Name: Mississippi; N/A. 

State Name: Montana; N/A. 

State Name: North Carolina; State has a statewide system to collect 
unique identifiers for all jobseekers who use the one-stop system; 
State has a statewide system to collect unique identifiers for all 
employers who use the one-stop system. 

State Name: North Dakota; N/A. 

State Name: Nebraska; State has a statewide system to collect unique 
identifiers for all jobseekers who use the one-stop system; State has a 
statewide system to collect unique identifiers for all employers who 
use the one-stop system. 

State Name: New Hampshire; N/A. 

State Name: New Jersey; State has a statewide system to collect unique 
identifiers for all jobseekers who use the one-stop system; State has a 
statewide system to collect unique identifiers for all employers who 
use the one-stop system. 

State Name: New Mexico; State has a statewide system to collect unique 
identifiers for all employers who use the one-stop system. 

State Name: Nevada; 
State has a statewide system to collect unique identifiers for all 
jobseekers who use the one-stop system; State has a statewide system to 
collect unique identifiers for all employers who use the one-stop 
system. 

State Name: New York; State has a statewide system to collect unique 
identifiers for all jobseekers who use the one-stop system; State has a 
statewide system to collect unique identifiers for all employers who 
use the one-stop system. 

State Name: Ohio; 
State has a statewide system to collect unique identifiers for all 
employers who use the one-stop system. 

State Name: Oklahoma; State has a statewide system to collect unique 
identifiers for all jobseekers who use the one-stop system; State has a 
statewide system to collect unique identifiers for all employers who 
use the one-stop system. 

State Name: Oregon; 
State has a statewide system to collect unique identifiers for all 
employers who use the one-stop system. 

State Name: Pennsylvania; State has a statewide system to collect 
unique identifiers for all jobseekers who use the one-stop system; 
State has a statewide system to collect unique identifiers for all 
employers who use the one-stop system. 

State Name: Rhode Island; State has a statewide system to collect 
unique identifiers for all jobseekers who use the one-stop system; 
State has a statewide system to collect unique identifiers for all 
employers who use the one-stop system. 

State Name: South Carolina; N/A. 

State Name: South Dakota; State has a statewide system to collect 
unique identifiers for all jobseekers who use the one-stop system; 
State has a statewide system to collect unique identifiers for all 
employers who use the one-stop system. 

State Name: Tennessee; State has a statewide system to collect unique 
identifiers for all jobseekers who use the one-stop system; State has a 
statewide system to collect unique identifiers for all employers who 
use the one-stop system. 

State Name: Texas; N/A. 

State Name: Utah; 
State has a statewide system to collect unique identifiers for all 
jobseekers who use the one-stop system; State has a statewide system to 
collect unique identifiers for all employers who use the one-stop 
system. 

State Name: Virginia; State has a statewide system to collect unique 
identifiers for all jobseekers who use the one-stop system; State has a 
statewide system to collect unique identifiers for all employers who 
use the one-stop system. 

State Name: Vermont; 
State has a statewide system to collect unique identifiers for all 
jobseekers who use the one-stop system; State has a statewide system to 
collect unique identifiers for all employers who use the one-stop 
system. 

State Name: Washington; State has a statewide system to collect unique 
identifiers for all employers who use the one-stop system. 

State Name: Wisconsin; State has a statewide system to collect unique 
identifiers for all jobseekers who use the one-stop system; State has a 
statewide system to collect unique identifiers for all employers who 
use the one-stop system. 

State Name: West Virginia; N/A. 

State Name: Wyoming; 
State has a statewide system to collect unique identifiers for all 
jobseekers who use the one-stop system; State has a statewide system to 
collect unique identifiers for all employers who use the one-stop 
system. 

Source: GAO. 

[End of table]

Table 4: From the time your state first began implementing changes to 
the IT system under WIA, about how long did it take your state to fully 
implement the IT system changes that were necessary to meet the federal 
requirements for the quarterly reports, annual report, and WIASRD 
(Workforce Investment Act Standardized Record Data)?

Alabama; 
More than 2 years to 3 years. 

Alaska; 
Less than 6 months. 

Arkansas; 
Less than 6 months. 

California; 
More than 2 years to 3 years. 

Colorado; 
More than 1 year to 2 years. 

Connecticut; 
More than 1 year to 2 years. 

Delaware; 
More than 1 year to 2 years. 

Florida; 
More than 2 years to 3 years. 

Georgia; 
More than 2 years to 3 years. 

Hawaii; 
More than 1 year to 2 years. 

Idaho; 
More than 1 year to 2 years. 

Illinois; 
6 months to 1 year. 

Indiana; 
Less than 6 months. 

Iowa; 
6 months to 1 year. 

Kansas; 
Less than 6 months. 

Kentucky; 
More than 2 years to 3 years. 

Louisiana; 
6 months to 1 year. 

Maine; 
More than 2 years to 3 years. 

Massachusetts; 
No response. 

Michigan; 
6 months to 1 year. 

Minnesota; 
6 months to 1 year. 

Mississippi; 
6 months to 1 year. 

Missouri; 
Less than 6 months. 

Montana; 
No response. 

Nebraska; 
6 months to 1 year. 

Nevada; 
No response. 

New Hampshire; 
6 months to 1 year. 

New Jersey; 
More than 1 year to 2 years. 

New Mexico; 
6 months to 1 year. 

New York; 
More than 2 years to 3 years. 

North Carolina; 
More than 2 years to 3 years. 

North Dakota; 
More than 2 years to 3 years. 

Ohio; 
6 months to 1 year. 

Oklahoma; 
6 months to 1 year. 

Oregon; 
More than 2 years to 3 years. 

Pennsylvania; 
Less than 6 months. 

Rhode Island; 
More than 1 year to 2 years. 

South Carolina; 
6 months to 1 year. 

South Dakota; 
More than 1 year to 2 years. 

Tennessee; 
More than 1 year to 2 years. 

Texas; 
6 months to 1 year. 

Utah; 
More than 3 years. 

Vermont; 
More than 1 year to 2 years. 

Virginia; 
6 months to 1 year. 

Washington; 
Less than 6 months. 

West Virginia; 
More than 1 year to 2 years. 

Wisconsin; 
More than 2 years to 3 years. 

Wyoming; 
More than 1 year to 2 years. 

[End of table]

Source: GAO. 

Table 5: Compared to the effort your state invested in the transition 
from the Job Training Partnership Act (JTPA) to WIA, how much effort do 
you anticipate investing in implementing EMILE, as proposed?

Alabama; 
Much greater effort for EMILE. 

Alaska; 
Much greater effort for EMILE. 

Arkansas; 
Somewhat less effort for EMILE. 

California; 
Much greater effort for EMILE. 

Colorado; 
Much less effort for EMILE. 

Connecticut; 
Somewhat greater effort for EMILE. 

Delaware; 
Somewhat less effort for EMILE. 

Florida; 
Much greater effort for EMILE. 

Georgia; 
Much greater effort for EMILE. 

Hawaii; 
Much greater effort for EMILE. 

Idaho; 
Much greater effort for EMILE. 

Illinois; 
About the same effort. 

Indiana; 
Much greater effort for EMILE. 

Iowa; 
About the same effort. 

Kansas; 
Much less effort for EMILE. 

Kentucky; 
Somewhat greater effort for EMILE. 

Louisiana; 
Much less effort for EMILE. 

Maine
Somewhat less effort for EMILE. 

Massachusetts
Somewhat less effort for EMILE. 

Michigan; 
Much greater effort for EMILE. 

Minnesota; 
Much greater effort for EMILE. 

Mississippi; 
Somewhat greater effort for EMILE. 

Missouri; 
Much greater effort for EMILE. 

Montana; 
About the same effort. 

Nebraska;
Somewhat less effort for EMILE. 

Nevada; 
About the same effort. 

New Hampshire; 
Much greater effort for EMILE. 

New Jersey; 
No response. 

New Mexico;
Much less effort for EMILE. 

New York;
Somewhat less effort for EMILE. 

North Carolina; 
Much greater effort for EMILE. 

North Dakota; 
Much greater effort for EMILE. 

Ohio; 
Somewhat greater effort for EMILE. 

Oklahoma; 
About the same effort. 

Oregon; 
Much greater effort for EMILE. 

Pennsylvania;
Somewhat less effort for EMILE. 

Rhode Island; 
Much greater effort for EMILE. 

South Carolina; 
Much greater effort for EMILE. 

South Dakota; 
About the same effort. 

Tennessee;
Somewhat less effort for EMILE. 

Texas; 
Somewhat greater effort for EMILE. 

Utah;
Somewhat less effort for EMILE. 

Vermont; 
Somewhat greater effort for EMILE. 

Virginia; 
Somewhat greater effort for EMILE. 

Washington;
Somewhat less effort for EMILE. 

West Virginia;
Somewhat less effort for EMILE. 

Wisconsin; 
About the same effort. 

Wyoming;
Somewhat less effort for EMILE. 

Source: GAO. 

[End of table]

Table 6: About how long do you estimate it will take your state to 
fully implement the necessary changes for EMILE, as proposed, once 
Labor's requirements are final?

Alabama; 
More than 1 year to 2 years. 

Alaska; 
More than 1 year to 2 years. 

Arkansas; 
No response. 

California; 
More than 2 years to 3 years. 

Colorado; 
No response. 

Connecticut; 
6 months to 1 year. 

Delaware; 
6 months to 1 year. 

Florida; 
No response. 

Georgia; 
No response. 

Hawaii; 
More than 1 year to 2 years. 

Idaho; 
More than 2 years to 3 years. 

Illinois; 
6 months to 1 year. 

Indiana; 
More than 1 year to 2 years. 

Iowa; 
More than 1 year to 2 years. 

Kansas; 
Less than 6 months. 

Kentucky; 
More than 1 year to 2 years. 

Louisiana; 
Less than 6 months. 

Maine; 
More than 1 year to 2 years. 

Massachusetts; 
6 months to 1 year. 

Michigan; 
6 months to 1 year. 

Minnesota; 
More than 1 year to 2 years. 

Mississippi; 
No response. 

Missouri; 
No response. 

Montana; 
No response. 

Nebraska; 
6 months to 1 year. 

Nevada; 
More than 1 year to 2 years. 

New Hampshire; 
6 months to 1 year. 

New Jersey; 
More than 1 year to 2 years. 

New Mexico; 
Less than 6 months. 

New York; 
More than 1 year to 2 years. 

North Carolina; 
More than 2 years to 3 years. 

North Dakota; 
6 months to 1 year. 

Ohio; 
6 months to 1 year. 

Oklahoma; 
6 months to 1 year. 

Oregon; 
More than 3 years. 

Pennsylvania; 
No response. 

Rhode Island; 
More than 1 year to 2 years. 

South Carolina; 
More than 1 year to 2 years. 

South Dakota; 
No response. 

Tennessee; 
6 months to 1 year. 

Texas; 
More than 1 year to 2 years. 

Utah; 
6 months to 1 year. 

Vermont; 
6 months to 1 year. 

Virginia; 
No response. 

Washington; 
More than 1 year to 2 years. 

West Virginia; 
6 months to 1 year. 

Wisconsin; 
6 months to 1 year. 

Wyoming; 
More than 1 year to 2 years. 

Source: GAO. 

[End of table]

[End of section]

Appendix III: Comments from the Department of Labor: 

U.S. Department of Labor: 

Assistant Secretary for Employment and Training: Washington, D.C. 
20210: 

MAY 17 2005: 

Mr. Sigurd R. Nilsen: Director:
Education, Workforce, and Income Security Issues: U.S. Government 
Accountability Office: 441 G. Street, N.W.: 
Washington, D.C. 20548: 

Dear Mr. Nilsen: 

The Employment and Training Administration (ETA) is in receipt of the 
draft Government Accountability Office (GAO) report entitled, 
"Workforce Investment Act: Labor Should Consider Alternative Approaches 
to Implement New Performance and Reporting Requirements" (GAO-05-539). 
We have significant concerns with the draft report and believe that in 
its current form it presents an inaccurate view of ETA's efforts in the 
area of performance accountability. 

First, we note that the objectives stated in this report are different 
from the objectives originally given to the U.S. Department of Labor 
(the Department) in the entrance interview, when a study on data 
quality was described. As a point of reference, the study was started 
in June 2004 and the notice for public comments on the proposed ETA 
Management Information and Longitudinal Evaluation (EMILE) reporting 
system was published in July 2004. 

We believe it is also important to clarify that the implementation of 
common measures on July 1, 2005, is a separate and independent action 
from the Department's interest in proposing a new standardized 
reporting system, commonly referred to as EMILE. They are two separate, 
albeit related, components of ETA's performance accountability system. 
In our view, the draft transmittal letter tends to weave these two 
issues together in a way that does not distinguish the differences. 

ETA proposed the EMILE reporting system to streamline reporting 
requirements for 12 different ETA-funded programs, minimizing the 
burden on the states and grantees of completing and submitting 21 
separate reports, and enabling consistent measurement and understanding 
of the overall effectiveness of ETA programs in helping job seekers 
find meaningful employment and in helping employers find skilled 
workers. 

We believe the GAO study could provide a more complete view if it also 
included the potential benefits of implementing the EMILE system, such 
as greater administrative efficiencies with fewer separate, often 
conflicting information systems to maintain, and fewer reports to 
submit; greater comparability and understanding of performance 
information by using the same definitions for the measures; and 
enhanced information about services provided to the employer community. 

Furthermore, the transmittal letter states that Labor developed EMILE 
with limited consultation with state officials. ETA engaged in 
significant outreach efforts, including consulting with state and local 
representatives on the concepts of the proposed reporting system, and 
holding information sessions for states with each of the ETA regional 
offices. Over 160 public comments were received in response to the 
Federal Register notice designed to solicit comments and feedback. ETA 
staff also participated in several conferences and online sessions to 
explain the proposed reporting system and solicit comments. After a 
review of the comments, ETA decided to conduct a feasibility study on 
the startup and implementation costs for the proposed reporting system. 

The transmittal letter states that the Department has not provided 
guidance in a timely manner for states to implement the changes related 
to the common measures. The workforce system was first informed in 
December 2003 through an ETA issued Training and Employment Guidance 
Letter (TEGL) 15-03 about the common performance measures policy - 
eighteen months prior to implementation. ETA issued TEGL 28-04 on April 
15, 2005, which updated the operational parameters for implementing the 
common measures beginning July 1, 2005. It is also important to note 
that for the WIA title I programs, all states already collect the 
information necessary to calculate the common performance measures. 

We do support the report's recommendation that Labor work with states 
to identify promising practices in collecting and reporting information 
on One-Stop customers who receive self-services. It is important to 
mention that our recently approved revisions to the WIA reporting 
system require the states to report an aggregate count of customers who 
receive self-services. We believe this reporting change is a critical 
first step in addressing concerns expressed by the GAO in an earlier 
report entitled, "Workforce Investment Act: Improvements Needed in 
Performance Measures to Provide a More Accurate Picture of WIA's 
Effectiveness" (GAO 02-275), which noted that "without any information 
on individuals who use self-services, it will be difficult for Labor to 
show how effectively One-Stops are being used."

To ensure that states collect this information in a consistent manner, 
ETA's revisions to the WIA reporting system also include a minimum set 
of standardized data definitions and specifications for use by the 
states and local areas. We agree that the capacity to track and report 
information on customers who receive self-services will vary across 
states and local areas, and intend to work closely with our state 
partners over the next year to identify best practices and promising 
technology solutions that will facilitate the collection and reporting 
of this important customer information. 

Enclosed are ETA's technical comments on the draft report. If you would 
like additional information, please do not hesitate to call me at (202) 
693-2700. 

Sincerely,

Signed by: 

Emily Stover DeRocco: 

Enclosure: 

GAO Response: 

Labor agreed with our recommendation that it work with states in 
identifying promising practices to ensure that states and local areas 
track all jobseekers in a consistent manner. Labor did not respond to 
our recommendation that it consider alternative approaches to reach the 
goals of EMILE. However, Labor took issue with several statements 
throughout the briefing materials. 

Labor disagreed with our finding that it developed EMILE with limited 
consultation with states. Labor said it engaged in significant outreach 
efforts such as holding information sessions and participating in 
several conferences and online sessions to explain the proposed 
reporting system. Labor also identified over 160 comments it received 
to the July 16, 2004 Federal Register Notice. However, the large number 
of concerns raised by the 38 states that responded to the notice 
suggests that the dialogue was insufficient to resolve concerns in the 
early development of the proposed EMILE reporting system. We continue 
to believe that Labor's efforts to implement a system such as EMILE 
could be enhanced by alternative approaches such as ongoing 
consultation, testing, and implementing changes in phases. 

Labor expressed concern that we did not clearly distinguish EMILE from 
the common measures, stating that, in their view, these are separate 
and independent actions. Yet, in the Federal Register Notice on EMILE, 
Labor clearly linked implementation of the common measures with EMILE, 
stating that the common measures would become effective with reporting 
system changes and EMILE would help standardize data collection by 
using the definitions of the common measures. 

Labor disagreed with our finding that it had not provided guidance in a 
timely manner, noting that the initial guidance on common measures was 
issued in December 2003. Yet the detailed instructions on reporting 
changes were not issued until a March 29, 2005 Federal Register Notice. 
In addition, states will need to provide some information not currently 
required or uniformly collected. As we discussed in our briefing 
materials, states told us that they would need time to make changes 
such as preparing new guidance and training local staff on reporting 
modifications. We continue to believe that rushed implementation 
without adequate time for states to retool may lead to data quality 
errors. 

In addition, Labor states that its reporting change to collect data on 
one-stop customers who use self-services is a critical first step in 
addressing prior GAO concerns. We agree that collecting this 
information and the concepts of EMILE and the common measures are 
consistent with the type of comprehensive performance management system 
we have recommended for WIA and the one-stop system. 

[End of section]

Appendix IV: GAO Contacts and Staff Acknowledgments: 

GAO Contacts: 

Dianne Blank, Assistant Director (202) 512-5654: 

Laura Heald, Analyst-in-Charge (202) 512-8701: 

Staff Acknowledgments: 

Melinda Cordero, Adam Roye, and Leslie Sarapu made significant 
contributions to all phases of the effort. Carolyn Boyce made 
significant contributions in the design and administration of the 
surveys. In addition, Jessica Botsford provided legal support, Avrum 
Ashery and Muriel Coley provided graphic design assistance, and Linda 
Lambert and Eric Trout also provided key technical assistance. 

[End of section]

GAO's Related Products: 

Workforce Investment Act: States and Local Areas Have Developed 
Strategies to Assess Performance, but Labor Could Do More to Help. GAO- 
04-657. Washington, D.C.: June 1, 2004. 

Workforce Investment Act: Labor Actions Can Help States Improve Quality 
of Performance Outcome Data and Delivery of Youth Services. GAO-04-308. 
Washington, D.C.: February 23, 2004. 

Workforce Investment Act: One-Stop Centers Implemented Strategies to 
Strengthen Services and Partnerships, but More Research and Information 
Sharing Is Needed. GAO-03-725. Washington, D.C.: June 18, 2003. 

Multiple Employment and Training Programs: Funding and Performance 
Measures for Major Programs. GAO-03-589. Washington, D.C.: April 18, 
2003. 

Workforce Training: Employed Worker Programs Focus on Business Needs, 
but Revised Performance Measures Could Improve Access for Some Workers. 
GAO-03-353. Washington, D.C.: February 14, 2003. 

Older Workers: Employment Assistance Focuses on Subsidized Jobs and Job 
Search, but Revised Performance Measures Could Improve Access to Other 
Services. GAO-03-350. Washington, D.C.: January 24, 2003. 

Performance and Accountability Series. Major Management Challenges and 
Program Risks: Department of Labor. GAO-03-106. Washington, D.C.: 
January 2003. 

Workforce Investment Act: Better Guidance and Revised Funding Formula 
Would Enhance Dislocated Worker Program. GAO-02-274. Washington, D.C.: 
February 11, 2002. 

Workforce Investment Act: Improvements Needed in Performance Measures 
to Provide a More Accurate Picture of WIA's Effectiveness. GAO-02-275. 
Washington, D.C.: February 1, 2002. 

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