Supporting Statement - Joint Performance ICR

WIOA Common Performance Management Information and Reporting System

ICR Reference Number 201604-1205-002

June 2016

SUPPORTING STATEMENT

Workforce Innovation and Opportunity Act (WIOA) Common Performance Reporting

WIOA Annual Statewide Performance Report Template | WIOA Annual Local Area Performance Report Template | WIOA Joint Participant Individual Record Layout (PIRL) | WIOA Annual Statewide/Local Performance Report Specifications | WIOA Eligible Training Provider (ETP) Performance Report Specifications and WIOA Eligible Training Provider (ETP) Performance Report Definitions

The Department of Labor (DOL) seeks approval of this ICR under the clearance process for “common forms.” The Department of Education (ED) (the two Departments to be jointly referred to as the “Departments”) actively participated in the development of this request and is expected to be a signatory to the “WIOA Common Performance Reporting” collection, which details the requirements for WIOA Statewide performance reporting.

1. JUSTIFICATION

1. Explain the circumstances that make the collection of information necessary. Identify any legal or administrative requirements that necessitate the collection. Attach a copy of the appropriate section of each statute and regulation mandating or authorizing the collection of information.

The data collection instruments proposed under this information collection request (ICR), as required by section 116(d) of WIOA (29 U.S.C. § 3141(d), include separate report templates jointly developed by the Departments for: 1) the Statewide Performance Report, to be used for the reporting of data by entities that administer WIOA core programs; 2) the Local Area Performance Report for certain Title I, Subtitle B programs; and 3) Eligible Training Provider (ETP) Performance reporting requirements for certain Title I programs.

Section 116 of WIOA requires States and Local Areas that operate the six core programs of the workforce development system to comply with common performance accountability requirements for those programs, which are: the Adult, Dislocated Worker, and Youth programs (title I, administered by DOL); the Adult Education and Family Literacy Act (AEFLA) program (title II, administered by ED); the Wagner-Peyser Act program (title III, administered by DOL); and the Vocational Rehabilitation (VR) program (title IV, administered by ED). As such, States and Local Areas that operate core programs must submit common performance data to demonstrate that specified performance levels are achieved. States and Local Areas will report the common performance data through this ICR.

In addition, eligible training providers (ETPs), which are eligible to receive funds from Adult and Dislocated Worker programs authorized under title I of WIOA, will report data on outcomes achieved under those programs through this ICR. This data collection covers only the definitions for the title I ETP Performance Report (see ETA-9171), providing the States the necessary information regarding data elements required for this report. With this information, States will be able to begin their own data collection from the ETPs on the State list. This ICR does not include the specifics on the data collection format (e.g., Excel, comma delimited text file, other program application interface) that must be used to submit the data to DOL (e.g., through an online portal). The specifics on the data collection format will be the subject of a future request that will undergo public comment and a request for approval from the Office of Management and Budget (OMB). Once the mechanism for ETP data collection and reporting has been established and approved, it will be considered a part of this WIOA Performance Management Information and Reporting System.

Section 116(d)(1) of WIOA mandates that the Secretaries of Labor and Education develop a template for performance reports to be used by States, local boards, and ETPs for reporting on outcomes achieved by participants in the six core programs. Corresponding proposed joint regulations for these data collection requirements, including which primary performance indicators apply for each core program, are contained in a joint Notice of Proposed Rulemaking (NPRM) related to: (1) 20 CFR part 677 (which will cover the Adult and Dislocated Worker programs (20 CFR part 680), the Youth program (20 CFR part 681), and the Wagner-Peyser Act program (20 CFR part 652)); (2) 34 CFR part 463, Subpart I (which will cover the AEFLA program); and (3) 34 CFR part 361 Subpart E (which will cover the VR program). The joint NPRM, as well as four other program-specific NPRMs necessitated by WIOA, was published on April 16, 2015, at 80 FR 20573. The comment period for the proposed regulations closed on June 15, 2015.

In accordance with sec. 506(b)(1) of WIOA, section 116 of WIOA will take effect at the start of the second full program year after the date of enactment, which was July 22, 2014. Therefore, the performance accountability system required under section 116 will take effect on July 1, 2016.

If this information collection receives OMB approval, it may be effective before the WIOA regulations are finalized. If this occurs, DOL will resubmit this ICR to OMB for its approval when the Final Rule is published, as required by 5 CFR 1320.11(h). The Departments reviewed and analyzed any comments received on the NPRMs that were relevant to this ICR in addition to the comments received on this ICR, thereby ensuring consistency between the ICR and the Final Rules. These templates have been designed to maximize the value of the reports for workers, jobseekers, employers, local elected officials, State officials, Federal policymakers, and other key stakeholders. At the same time, all of the forms have been designed to reflect the specific requirements of the reports as described in sections 116(d)(2) through (4) of WIOA.

WIOA PARTICIPANT INDIVIDUAL RECORD LAYOUT (PIRL) (ETA-9170)

The PIRL provides a standardized set of data elements, definitions, and reporting instructions that will be used to describe the characteristics, activities, and outcomes of WIOA participants. States and local areas will be required to collect participant information that corresponds with the data elements and descriptions delineated within the PIRL. Once collected, this information will then be aggregated according to the conditions outlined in the WIOA Annual Statewide Performance Report Specifications, which details the common data elements and technical specifications necessary for calculation of the State and Local Area performance report elements that will be used in reporting across all core programs. Once aggregated, the outcomes will then be displayed according to the framework that is the WIOA Annual Statewide Performance Report Template/WIOA Annual Local Area Performance Report Template.

WIOA ANNUAL STATEWIDE PERFORMANCE REPORT TEMPLATE (ETA-9169)

Required annual data for the core programs include information related to the six primary performance indicators, participant counts and costs, and barriers to employment as described below. The following data must be included in the Statewide Performance Report and will be reported on an individual or aggregate basis, depending on the program to which they pertain, as described later in this section.

Primary Indicators of Performance for Core Programs

For WIOA core programs, States must report the results of primary indicators of performance set forth at section 116(b)(2)(A)(i) of WIOA:

1. The percentage of program participants who are in unsubsidized employment during the second quarter after exit from the program;¹

2. The percentage of program participants who are in unsubsidized employment during the fourth quarter after exit from the program;²

3. The median earnings of program participants who are in unsubsidized employment during the second quarter after exit from the program;

4. The percentage of program participants who obtained a recognized postsecondary credential, or a secondary school diploma or its recognized equivalent during participation in or within one year after exit from the program. For those program participants who obtained a secondary school diploma or its recognized equivalent, the participant must also have obtained or retained employment or be in an education or training program leading to a recognized postsecondary credential within one year after exit from the program;

5. The percentage of program participants who, during a program year, are in an education or training program that leads to a recognized postsecondary credential or employment and who are achieving measurable skill gains toward such a credential or employment; and

6. The indicator(s) of effectiveness in serving employers.

All of the above primary indicators of performance will also be displayed as a disaggregate value based on the barriers to employment incorporated into the definition of an “individual with a barrier to employment”, as set forth in WIOA section 3(24). The specific population disaggregation is described below in numbers 22 through 35.

Participant Counts and Cost Information

Under section 116(d)(2), the WIOA Annual Statewide Performance Report must also include the following data:

7. Information specifying the levels of performance achieved with respect to the primary indicators of performance described in WIOA sec. 116(b)(2)(A) for each of the programs described in WIOA sec. 116(b)(3)(A)(ii) and the State adjusted levels of performance with respect to such indicators for each program;

8. Information specifying the levels of performance achieved with respect to the primary indicators of performance described in WIOA sec. 116(b)(2)(A) for each of the programs described in WIOA sec. 116(b)(3)(A)(ii) with respect to individuals with barriers to employment, disaggregated by each subpopulation of such individuals, and by race, ethnicity, sex, and age;

9. The total number of participants served by each of the core programs;

10. The number of participants who received career services during the most recent program year and the three preceding program years;

11. The number of participants who received training services during the most recent program year and the three preceding program years;

12. The amount of funds spent on career services;

13. The amount of funds spent on training services;

14. The number of participants who exited from career services, during the most recent program year and the three preceding program years;

15. The number of participants who exited from training services during the most recent program year and the three preceding program years;

16. The average cost per participant of those participants who received career services during the most recent program year and the three preceding program years;

17. The average cost per participant of those participants who received training services during the most recent program year and the three preceding program years;

18. The percentage of participants in a program authorized under WIOA title I who received training services and obtained unsubsidized employment in a field related to the training received;

19. The number of participants who are enrolled in more than one of the core programs;

20. The number of participants with barriers to employment served by each of the core programs, disaggregated by each subpopulation of such participants; and

21. The percentage of the State’s annual allotment under section 132(b) that the State spent on administrative costs.

Barriers to Employment

Data must be collected in a manner so that the results may be disaggregated by the “Barriers to Employment,” as described in section 3(24) of WIOA, for both number of participants served and performance on primary indicators, and then further disaggregated by age, race and ethnicity, and sex. Under section 3(24) of WIOA, an “individual with a barrier to employment” includes:

22. Displaced homemakers;

23. Low-income individuals;

24. Indians, Alaska Natives, and Native Hawaiians, as such terms are defined in section 166 of WIOA;

25. Individuals with disabilities, including youth who are individuals with disabilities;

26. Older individuals (55+);

27. Ex-offenders;

28. Homeless individuals (as defined in section 41403(6) of the Violence Against Women Act of 1994 (42 U.S.C. 14043e–2(6))), or homeless children and youths (as defined in section 725(2) of the McKinney-Vento Homeless Assistance Act (42 U.S.C. 11434a(2)));

29. Youth who are in or have aged out of the foster care system;

30. Individuals who are English language learners, individuals who have low levels of literacy, and individuals facing substantial cultural barriers;

31. Eligible migrant and seasonal farmworkers, as defined in section 167(i) of WIOA;

32. Individuals within two years of exhausting lifetime eligibility under TANF (part A of title IV of the Social Security Act (42 U.S.C. 601 et seq.));

33. Single parents (including single pregnant women);

34. Long-term unemployed individuals (27 or more consecutive weeks); and

35. Such other groups as the Governor involved determines to have barriers to employment.

To collect this data:

1. The Department of Education’s Rehabilitation Services Administration (RSA) has modified its currently-approved information collection instrument used to obtain data on participants served through the VR program (case service report, RSA-911, OMB Control No. 1820-0508) to collect participant-level WIOA core program data on a quarterly basis from the 80 VR agencies. This modified version of the RSA-911 was available for comment in the Federal Register (Docket ID ED-2015-OSERS-0001). RSA will analyze and aggregate these data for the purpose of computing the performance accountability measures and other figures required in the Statewide performance report that will be reported through OMB 1205-0NEW. Because the proposed RSA-911 was published prior to the 60-day comment period for this joint ICR, the RSA-911 did not reflect all of the changes necessary to align with the PIRL at the date of publication. The final RSA-911 includes new and/or revised data elements and definitions necessary to provide alignment with the PIRL.

2. The Department of Education’s Office of Career, Technical, and Adult Education (OCTAE) will modify its currently-approved information collection instrument, which obtains aggregate data annually from States using a set of reporting tables developed by ED (Implementation Guidelines: Measures and Methods for the National Reporting System for Adult Education, OMB Control No. 1830-0027).  For the purposes of the AEFLA program, States will be required to complete and submit the WIOA Annual Statewide Performance Report template, in addition to the aggregate data tables that States are required to submit to OCTAE under OMB Control No. 1830-0027. 

3. DOL has an additional ICR to collect and report on data elements not specified in this collection. See OMB Control No. 1205-0521. This other collection will take the place of several other currently existing ICRs, such as the: Workforce Investment Act (WIA) Management Information and Reporting System (1205-0420), Wagner-Peyser Labor Exchange Reporting System (LERS)( 1205-0240), YouthBuild Reporting System (1205-0464), Reporting and Performance Standards for WIA Indian and Native American Programs (1205-0422), Reporting and Performance Standards System for Migrant and Seasonal Farmworker Programs Under Title I, Section 167 of the Workforce Investment Act (1205-0425), and Trade Act Participant Report (1205-0392).

WIOA ANNUAL LOCAL AREA PERFORMANCE REPORT TEMPLATE (ETA-9169)

The WIOA Annual Local Area Performance Report Template is a subset of the WIOA Annual Statewide Performance Report Template which, under section 116(d)(3) of WIOA, requires the collection of the same aforementioned costs, counts, and primary indicators for Title I Youth, Adult, and Dislocated Worker programs. Similarly, the counts and primary indicators must be disaggregated by the above listed barriers to employment.

WIOA ETP PERFORMANCE REPORT (Definitions-Only) (ETA-9171)

Section 116(d)(4) of WIOA, regarding Contents of ETP Reports, mandates the collection of specific information for each program of study for each eligible provider of training services under title I Adult and Dislocated Worker programs. DOL has proposed permitting States to use individual training accounts (ITAs) for out-of-school youth WIOA participants ages 16 to 24. See 80 Fed. Reg. 20569, 20868 (proposed 20 CFR §681.550). Therefore, DOL proposes that, for purposes of the annual ETP performance report, WIOA out-of-school youth participating in a program of study using an ITA must be reported like a WIOA Adult in the all student and WIOA participant categories. Likewise, DOL proposes that references to the WIOA Adult Program for purposes of reporting on the ETP Performance Report include out-of-school youth participating in a program of study using an ITA.

This data collection covers definitions for title I ETP Performance and corresponding tabulations (see ETA-9171), which should allow states to begin their own data collection from the ETPs on the State list. This ICR seeks approval for the definitions of ETP terms and corresponding calculations of WIOA performance measures as they relate to the ETP Report (See ETA-9171) and the method for calculating the total number of individuals served in a program of study.

This ICR does not contain the specifics on the data collection format (e.g., Excel, comma delimited text file, other application program interface) that must be used to submit the data to DOL (e.g., through an online portal). Details on the data collection format for ETP reporting as well as the method that must be used for state submission to DOL will be delineated in a future ICR submitted to OMB and for which public comments will be sought. More specifically, the future ICR will address specific methods for collecting the ETP Performance Report from states and displaying the data in a national scorecard similar to the College Scorecard (https://collegescorecard.ed.gov/) to maximize its value for workers, job-seekers, employers, local elected officials, State officials, Federal policymakers, and other key stakeholders. As noted above, WIOA specifies that states must make ETP-related data publicly available, which shall be displayed in a format that maximizes value for these stakeholders. The Departments are also interested in collecting a narrative report, the specifications of which along with the aforementioned ETP reporting instruments will be the subject of a future ICR.

Primary Performance Indicators for the WIOA ETP Performance Report

The ETP Performance Report, applicable only to the title I Adult and Dislocated Worker programs, must report the results of the below four primary indicators of performance (#1-#4), along with the total number of individuals who exit from the program of study (#5), with respect to all individuals who exited a program of study and all individuals who completed a program of study including individuals in the program of study who are not WIOA participants. DOL is further clarifying that a program of study approved on the ETP list is synonymous with a “program of training services” as defined at proposed 20 CFR §680.420. A program of training services is one or more courses or classes, or a structured regimen that provides the training services at proposed 20 CFR §680.200, which reflects the list of services set forth in section 134(c)(3)(D) of WIOA, and leads to the outcomes described at proposed 20 CFR §680.420. As previously mentioned, the data collection format and method for submission are to be included in a future ICR. Listed below are the statutory requirements that mandate the collection of data through the ETP Performance Report. Proposed definitions for the elements that must be collected in order to meet these reporting requirements are included in ETA-9171 of the ICR.

1. The percentage of individuals who are in unsubsidized employment during the second quarter after exit from the program of study;

2. The percentage of individuals who are in unsubsidized employment during the fourth quarter after exit from the program of study;

3. The median earnings of individuals in the program of study who are in unsubsidized employment during the second quarter after exit;

4. The percentage of individuals who obtain a recognized postsecondary credential, or a secondary school diploma or its recognized equivalent during participation in or within one year after exit from the program. For those individuals who obtained a secondary school diploma or its recognized equivalent, the individual must also have obtained or retained employment or be in an education or training program leading to a recognized postsecondary credential within 1 year after exit from the program; and

5. The total number of individuals who exit from the program of study;

The ETP Performance Report must report the results of the below indicators with respect to all WIOA participants in the program of study.

Participant Counts and Cost Information

6. The number of participants exiting from the program of study (or the equivalent);

7. The total number of participants who received training services through each of the Adult program and the Dislocated Worker program authorized under chapter 3 of subtitle B, disaggregated by the type of entity that provided the training, during the most recent program year and the three preceding program years;

8. The total number of participants who exited from training services, disaggregated by the type of entity that provided the training, during the most recent program year and the three preceding program years;

9. The average cost per participant for the participants who received training services, disaggregated by the type of entity that provided the training, during the most recent program year and the three preceding program years; and

10. The number of individuals with barriers to employment served by each of the Adult program and the Dislocated Worker program authorized under chapter 3 of subtitle B, disaggregated by each subpopulation of such individuals, and by race and ethnicity, sex, and age.

Barriers to Employment

Data on the WIOA ETP Performance Report must be collected in a manner so that the results for WIOA participants may be disaggregated by the barriers to employment, as described in the definition of an “individual with a barrier to employment,” in section 3(24) of WIOA, for WIOA participants served as well as disaggregated by age, race and ethnicity, and sex. See complete list of individuals with barriers to employment outlined in the previous section (WIOA Annual Statewide Performance Report Template).

2. Indicate how, by whom, and for what purpose the information is to be used. Except for a new collection, indicate the actual use the agency has made of the information received from the current collection.

WIOA requires States, Local Boards, and ETPs to submit the required data collected by these proposed ICRs. (WIOA Sec. 116(d)(1)).

The Departments will use the data collected to assess the effectiveness of WIOA’s core programs and to monitor and analyze the performance of their grantees. If States do not adequately meet the adjusted level of performance as described in 20 CFR 677.170, they are subject to the five percent sanction discussed in WIOA section 116(f).

This data collection permits the Departments to evaluate program effectiveness, monitor compliance with statutory requirements, and analyze participant activity, while complying with OMB efforts to streamline Federal performance reporting.

Data collected in the WIOA Annual Statewide Performance Report, WIOA Annual Local Area Performance Report, and WIOA ETP Performance Reports (or the data associated) will be made accessible to the public through an annual report published on: www.doleta.gov/performance (the Adult, Dislocated Worker, and Youth programs under title I and the Wagner-Peyser Act program under title III); https://rsa.ed.gov/ (the State VR Services program under title IV); and http://www.ed.gov/about/offices/list/ovae/resource/index.html (the AEFLA program under title II). This performance information will also be distributed to workers and job seekers throughout the WIOA system, including through online formats as are consistent with statute. All reports will comply with the requirements of section 508 of the Rehabilitation Act, which requires electronic and information technology to be accessible to people with disabilities.

It should also be noted that the above report displays will be subject to a data suppression methodology where aggregated values below a certain threshold within a given geographic entity will not be displayed. Specifics on this, including the level at which aggregated values cannot be displayed, will be disseminated jointly by the Departments in subsequent guidance.

3. Describe whether, and to what extent, the collection of information involves the use of automated, electronic, mechanical, or other technological collection techniques or other forms of information technology, e.g., permitting electronic submission of responses, and the basis for the decision for adopting this means of collection. Also, describe any consideration of using information technology to reduce burden.

States are encouraged to collect participant data through electronic means. The majority of the WIOA Annual Statewide Performance Reports and/or individual record data may be submitted electronically through portals established by the Departments. For the VR program, RSA will develop the WIOA Annual Statewide Performance Reports based upon the information VR agencies submit via the RSA-911 data collection.

4. Describe efforts to identify duplication. Show specifically why any similar information already available cannot be used or modified for use for the purposes described in Item 2 above.

This information would be collected in addition to existing program-specific collections under approved OMB Control Numbers/Report titles described in more detail later in this section. This new information collection would incorporate only those data elements that are common to all core programs and required by section 116 of WIOA. The Departments are collaborating to develop common definitions across programs, to the extent applicable, in order to further reduce the chances of duplicative reporting.

The WIOA ETP Report is a new collection and, therefore, is not duplicative of any existing information collection. The DOL notes that this ICR will take the place of several other currently existing information collections.

Information collection burdens associated with this proposed information collection represent only the burden associated with reporting the new common performance data elements by the core programs and information collections that will be continued and are currently approved under various control numbers as outlined later in this section. This ICR does not reflect any burden associated with existing data collections that will continue separate and distinct and that are currently approved under other control numbers.

The currently-approved program-specific data reporting that will continue, as applicable, in addition to the common data ICR discussed herein, for the core programs include:

• Control Number 1205-0420, Workforce Investment Act (WIA) Management Information and Reporting System, with annual burden of 508,589 hours (This package will be in use simultaneously for some time until all WIA reporting requirements have ended.);

• Control Number 1205-0240, Labor Exchange Reporting System, with annual burden of 568,192 hours (This package will be in use simultaneously for some time until all Labor Exchange/Employment Service reporting requirements have ended.);

• Control Number 1830-0027, Measures and Methods for the National Reporting System for Adult Education, with annual burden of 5,700 hours; and

• Control Number 1820-0508, RSA-911 Case Service Report, with annual burden of 6,500 hours.

The Departments anticipate that some, but not all, of the above collections may be phased out or modified, as appropriate, as the WIOA performance measures are fully implemented.

WIOA requirements that are addressed in this new proposed ICR package may also overlap with currently approved information collections under program-specific ICRs previously mentioned. However, it is the intent of the Departments to revise existing requests or create new requests to supplement this collection, as appropriate, to reduce duplication for the States.

For example, as described in response to No. 1 above, RSA has modified its existing RSA-911 Case Service Report for the purpose of collecting individual-level WIOA core program data from the 80 VR program grantees on a quarterly basis. RSA uses no other method for collecting the data required under section 116 of WIOA and there exists no overlap with any other data collection instrument used by RSA.

Performance requirements of the Workforce Investment Act of 1998 (WIA) will continue to apply to the title I Adult, Dislocated Worker, and Youth programs and the title III Wagner-Peyser program for many months after the performance requirements of WIOA take effect. For this reason, the separate packages that address the requirements of WIA and WIOA must be simultaneously active for at least several months to collect the required data. The WIOA burden has been calculated to reflect the estimate of monetary costs and staff hours necessary to operate the WIOA Performance Management, Information and Reporting System once full implementation has taken place. We acknowledge that this results in a temporary but technical overstatement of the combined WIA and WIOA burdens while the new system is phased in and the previous system comes to a close. Throughout the next several years the burden will decrease as overlapping requirements in the WIA Management Information and Reporting System (OMB 1205-0420) and Labor Exchange Reporting System (OMB 1205-0240) are discontinued.

5. If the collection of information involves small businesses or other small entities, describe the methods used to minimize burden.

This data collection does not have a significant impact on small entities. However, grantees must secure the necessary data from all sub-recipients, as applicable, to incorporate into grantee-required reporting formats.

6. Describe the consequence to Federal program or policy activities if the collection is not conducted or is conducted less frequently, as well as any technical or legal obstacles to reducing burden.

Failure to collect the required performance data, and/or report it less frequently than annually, would violate WIOA. Such failure could impact a State’s receipt of Federal funds under WIOA, and/or be a determining factor for a financial sanction on the State pursuant to WIOA Sec. 116(f). Moreover, such failure could impede the Departments’ efforts to ensure compliance with Federal performance requirements, thereby affecting the Departments’ ability to safeguard the Federal interest.

7. Explain any special circumstances that would cause an information collection to be conducted in a manner:

* Requiring respondents to report information to the agency more often than quarterly;

* Requiring respondents to prepare a written response to a collection of information in fewer than 30 days after receipt of it;

* Requiring respondents to submit more than an original and two copies of any document;

* Requiring respondents to retain records, other than health, medical, government contract, grant-in-aid, or tax records, for more than three years;

* In connection with a statistical survey, that is not designed to produce valid and reliable results that can be generalized to the universe of study;

* Requiring the use of a statistical data classification that has not been reviewed and approved by OMB;

* That includes a pledge of confidentiality that is not supported by authority established in statute or regulation, that is not supported by disclosure and data security policies that are consistent with the pledge, or which unnecessarily impedes sharing of data with other agencies for compatible confidential use; or

* Requiring respondents to submit proprietary trade secrets, or other confidential information unless the agency can demonstrate that it has instituted procedures to protect the information's confidentiality to the extent permitted by law.

This ICR implicates no special circumstances.

8. If applicable, provide a copy and identify the date and page number of publication in the Federal Register of the agency's notice, required by 5 CFR 1320.8(d), soliciting comments on the information collection prior to submission to OMB. Summarize public comments received in response to that notice and describe actions taken by the agency in response to these comments. Specifically address comments received on cost and hour burden.

Describe efforts to consult with persons outside the agency to obtain their views on the availability of data, frequency of collection, the clarity of instructions and recordkeeping, disclosure, or reporting format (if any), and on the data elements to be recorded, disclosed, or reported.

Consultation with representatives of those from whom information is to be obtained or those who must compile records should occur at least once every 3 years—even if the collection of information activity is the same as in prior periods. There may be circumstances that may preclude consultation in a specific situation. These circumstances should be explained.

The Departments engaged the public through an NPRM Federal Register notice, published on April 16, 2015 at 80 FR 20573; the regulatory comment period closed on June 15, 2015. The Departments solicited public comments on this information collection prior to submission by publishing a 60-day Federal Register notice at 80 FR 43474 (July 22, 2015).

Following the 60-day comment period, the Departments received 112 comments in response to the Federal Register notice: 26 were submitted by State VR agencies; 47 responses were submitted by State and local workforce agencies, Workforce Investment Boards, One-Stop Career Centers, and State Associations of Workforce Investment Boards; 13 were submitted by organizations, State and local agencies, learning institutions, and contractors who provide adult education services; 8 were submitted by national associations, public interest groups, and research organizations; 7 were submitted by local education departments/institutions; and 11 were submitted by private citizens. A summary of the comments received and the Department’s responses can be found in the Summary of 30-Day Federal Register Notice (FRN) Comments and Responses document, located in the comment section of ROCIS. Full comments are available at https://www.regulations.gov/#!searchResults;rpp=25;po=0;s=ETA-2015-0007;fp=true;ns=true. All responses reflect the agreement of DOL and ED.

9. Explain any decision to provide any payment or gift to respondents, other than remuneration of contractors or grantees.

There are no payments or gifts to respondents.

10. Describe any assurance of confidentiality provided to respondents and the basis for assurance in statute, regulation, or agency policy.

This ICR does not contain assurances of confidentiality, as States are the respondents. This collection of information proposes to collect personally identifiable information (PII) such as birthdates and social security numbers. PII such as Social Security Numbers are requested in SORN RSA-911, Case Service Report; this PII is used for record control purposes (i.e., to cull out duplicates) and for the RSA‑SSA Data Exchange required by section 131 of the Rehabilitation Act of 1973, as amended by title IV of WIOA. Titles I, II, and III will not collect Social Security information.

11. Provide additional justification for any questions of a sensitive nature, such as sexual behavior and attitudes, religious beliefs, and other matters that are commonly considered private. This justification should include the reasons why the agency considers the questions necessary, the specific uses to be made of the information, the explanation to be given to persons from whom the information is requested, and any steps to be taken to obtain their consent.

There are no sensitive questions included in the proposed data collection.

12. Provide estimates of the hour burden of the collection of information. The statement should:

* Indicate the number of respondents, frequency of response, annual hour burden, and an explanation of how the burden was estimated. Unless directed to do so, agencies should not conduct special surveys to obtain information on which to base hour burden estimates. Consultation with a sample (fewer than 10) of potential respondents is desirable. If the hour burden on respondents is expected to vary widely because of differences in activity, size, or complexity, show the range of estimated hour burden, and explain the reasons for the variance. Generally, estimates should not include burden hours for customary and usual business practices.

* If this request for approval covers more than one form, provide separate hour burden estimates for each form and aggregate the hour burdens.

* Provide estimates of annualized cost to respondents for the hour burdens for collections of information, identifying and using appropriate wage rate categories. The cost of contracting out or paying outside parties for information collection activities should not be included here. Instead, this cost should be included under “Annual Cost to Federal Government.”

Summary:

The apportionment of burden between the Departments is discussed later in this section; however, it may be useful to consider the combined burden States will undertake once the collection is in full effect. For purposes of data entry into the reginfo.gov database, this ICR requests only burden for DOL. Once the ICR is approved, ED will submit a request for that agency’s share of the burden. Due to system limitation, burden will be apportioned for data entry purposes by each agency claiming a portion of the total responses; these total responses will reflect the total time burden once two agencies have completed their actions. ED will be unable to make its request until the ICR is approved for DOL use.

For purposes of this ICR, the Governor of a State will report information on an annual basis. The Departments recognize that similar information may be reported to each program on a more frequent basis. Those separate ICRs will claim the burden for program specific reporting. Time burden for each response includes underlying recordkeeping and the filing of each report.

The total hourly burden for this collection is 9,583,009 hours annually with 18,662,193 unduplicated respondents and 37,312,735 responses. As explained elsewhere in this ICR, the DOL share of this burden is 7,965,526 hours, based on the fact that approximately 83 percent of the burden under existing collections is borne by DOL programs. Each Department will claim its burden by claiming a share of the responses, in order to have totals align; thus, DOL is claiming 30,969,570 responses for purposes of this submission. The ED requests will be 6,343,165 responses and 1,617,483 burden hours.

Apportionment Detail:

The annual burden for the information collection of the common performance accountability data is calculated across core programs based on the number of program participants, the time it takes each respondent to complete and submit its report, and the costs incurred by each program to complete the data collection and report submission process. In administering the WIOA core programs, States will collect standardized data elements using this common control number for all core programs, i.e., WIOA adult and dislocated workers, Youth, Wagner-Peyser, AEFLA, and VR programs. The burden for the ETP data collection and reporting is also included as a separate set of tables within this burden estimate. The WIOA Annual Local Area Performance Reports for title I programs are populated based on the information provided within a given state’s WIOA Annual Statewide Performance Report Template, using the exact same data elements and reporting format, and filtered by the local area in question. As such, the local area report incurs no additional collection burden.

a. Statewide Performance Reporting (ETA-9169)

States are required to report on participation in WIOA funded programs annually. There are six programs affected by this requirement. Four of the programs are administered by DOL, and two are administered by ED. However, WIOA requires that both Departments report common information. The ETA-9169, WIOA Statewide and Local Performance Report Template, is used by both departments.

As described in response to No. 1 (page 6) above, RSA will prepare the Statewide performance report for the VR program using the quarterly data VR agencies submit through the program’s Case Service Report (RSA-911) (OMB Control Number 1820-0508). To ensure its accuracy, RSA will send a preliminary report to the VR agencies for their review and feedback. The burden for this process is accounted for in Table 1 below.

Table 1: WIOA Annual Statewide Performance Report Annualized Burden Hour Estimate

PROGRAM	Number of entities reporting to the Governor)	Number of Responses per Respondent (average number of program participants per state)	Total Number of Responses	Burden per Response (in hours)	Total Respondent Burden Hours
Adult, Dislocated Worker and Youth (DOL/ETA) ETA-9169	57	1	57	4	228
Wagner-Peyser (DOL/ETA) ETA-9169	57	1	57	4	228
Adult Education (Education) ETA-9169	57	1	57	6	342
Vocational Rehabilitation (Education) ETA-9169	80	1	80	4	320
Unduplicated TOTALS	251*	1	251	Varies	1,118

*The total number of unique respondents (251) in Table 1 is based on the sum of the following numbers:

• 52 States (as defined in WIOA Sec. 3(56)) (each for ETA, ETP and Adult Education service providers - 156 unique respondents)

• 5 outlying areas (as defined in WIOA Sec. 3(45)) (each for ETA, ETP and Adult Education service providers - 15 unique respondents)

• 80 State agencies (specific to Vocational Rehabilitation)

Total – 251 unique respondents annually

Table 2: WIOA Annual Statewide Performance Report Annualized Burden Cost Estimate

PROGRAM	Total Respondent Burden Hours	Hourly Wage Rate	Total Respondent Burden Cost
Adult & Dislocated Worker and Youth (DOL/ETA)	228	$35.22*	$8,030.16
Wagner-Peyser (DOL/ETA)	228	$35.22*	$8,030.16
Adult Education (Education)	342	$35.22*	$12,045.24
Vocational Rehabilitation (Education)	320	$45.88**	$14,681.60
TOTAL	1,118	Varies	$42,787.16

*Average hourly wage rate (Adjusted using a loaded wage factor of 1.57 to reflect total compensation, which includes non-wage factors such as health and retirement benefits and represents the ratio of average total compensation for the State and local sectors.) for social workers according to the Bureau of Labor Statistics. (2015). May 2015 national industry-specific occupational employment and wage estimates: NAICS 999200 – State Government, excluding schools and hospitals (OES designation). Retrieved from: http://www.bls.gov/oes/current/naics4_999200.htm.

** Based on an hourly wage of $45.88 for Management Analyst (data from the Bureau of Labor Statistics for State-employed Management Analysts, including the appropriate loaded wage factor - BLS OES, May 2015, 21-1015 Management Analysts (http://www.bls.gov/oes/current/naics4_999200.htm).

b. Eligible Training Providers (ETA-9171)

Training providers are required to collect data from participants based on the definitions in ETA-9171, Eligible Training Provider Definitions.

Table 3: WIOA ETP Performance Report Annualized Respondent Hour Burden Estimate

PROGRAM	Number of Respondents	Number of Responses per Respondent	Total Number of Responses	Burden per Respondent (in hours)	Total Respondent Burden Hours
Eligible Training Providers (DOL/ETA) ETA-9171	11,400	1	11,400	6	68,400

The annual burden hours for ETP recordkeeping were determined based on the estimated number of training providers (the total estimated number of annual responses) and the average number of hours necessary to compile the required data. The total estimated number of annual responses was determined based on an estimated 200 training providers per state across 57 states and outlying areas. The annual hour burden is determined by multiplying the ETP annual participant responses (11,400) by 6 hours per record for an estimated annual burden of 68,400 hours. There were a number of public comments stating that our original burden estimate was not high enough because of the burden that would be placed on states and training providers by adhering to the recordkeeping requirements as outlined in the statute for the ETP Performance Report Template. In response, the Departments have adjusted the minutes per record by doubling the estimate from 180 to 360, increasing both the annual burden hours and costs.

Table 4: WIOA ETP Performance Report Annualized Respondent Cost Burden Estimate

PROGRAM	Total Respondent Burden Hours	Hourly Wage Rate	Total Respondent Burden Cost
Eligible Training Providers (DOL/ETA)	68,400	$59.60*	$4,076,640

*Estimated average hourly earnings (Adjusted using a loaded wage factor of 1.57 to reflect total compensation, which includes non-wage factors such as health and retirement benefits and represents the ratio of average total compensation for the State and local sectors.) for Database Administrators (15-1141) who fall under NAICS code 999300 - Local Government, excluding schools and hospitals (OES Designation http://www.bls.gov/oes/current/naics4_999300.htm).

c. Participant Reporting (ETA-9170)

Participants who avail themselves of WIOA funded educational programs and services must provide information about themselves to training providers or state agencies. State agencies must collect this information over the course of a year and annually provide it to either DOL or ED. The burden for reporting the information to ED is accounted for in OMB Control Number 1820-0508. The burden for reporting the information to DOL is accounted for above in Table 1 as all of the information from the DOL sponsored PIRL electronic system is compiled and sent to DOL by the states as part of the annual Statewide and Local Performance Report.

Table 5: WIOA Participant Annualized Third-Party Disclosure Burden Hour Estimate

PROGRAM	Number of Respondents	Number of Responses per Respondent	Total Number of Responses	Burden per Response (in hours)	Total Respondent Burden Hours
Adult & Dislocated Worker and Youth(DOL/ETA)	1,835,799	1	1,835,799	.25	458,950
Wagner-Peyser (DOL/ETA)	14,667,639	1	14,667,639	.25	3,666,910
Adult Education (Education)	1,598,736	1	1,598,736	.25	399,684
Vocational Rehabilitation (Education)	1,000,000	1	1,000,000	.25	250,000
Unduplicated TOTALS	19,102,174	1	19,102,174	.25	4,775,544

The annual burden hours were determined based on the estimated number of annual participant responses per program (the total estimated number of annual responses) and the average number of minutes necessary to collect the required data for each person’s individual record (minutes per record). For example, by multiplying the Wagner-Peyser program’s total estimated number of annual responses (14,667,639) by their minutes per record (15 minutes/.25 hours) and dividing the product by the 60 minutes that make up an hour, an annual burden of 3,666,910 hours is calculated.

Table 6: WIOA Statewide Annualized Recordkeeping Burden Hour Estimate

PROGRAM	Number of Respondents	Number of Responses per Respondent	Total Number of Responses	Burden per Response (in hours)	Total Respondent Burden Hours
Adult & Dislocated Worker and Youth(DOL/ETA) ETA-9170	57	32,207	1,835,799	.25	458,950
Wagner-Peyser (DOL/ETA) ETA-9170	57	257,327	14,667,639	.25	3,666,910
Adult Education (Education) ETA-9170	57	28,048	1,598,736	.33*	527,583
Vocational Rehabilitation (Education) ETA-9170	80	12,500	1,000,000	.36**	360,000
Unduplicated TOTALS	251	Varies	19,102,174	Varies	5,013,443

*The review of public comments resulted in a decision by the Departments that each exit by a participant during a program year will count as a separate response to be used for data collection and outcome reporting for the performance indicators. Prior to WIOA, the AEFLA program reported only unduplicated counts of participant outcomes. Making the change to an accountability structure that is based on reporting outcomes for each exit by a participant during a program year represents a significant operational change for the AEFLA program and will require a commensurate increase in the level of effort needed for implementation. Thus, the minutes-per-record estimate for Adult Education has been increased by five minutes.

**The review of public comments and further review by program experts, resulted in a determination that time per data element provides a better estimate of the additional burden associated with the collection of new data required under WIOA. Vocational Rehabilitation Counselors are estimated to spend an average of 1 minute per data element collecting all the new data elements resulting from the WIOA. For the first year of data collection, the increase in burden will be greater than in subsequent years. Table 6 includes the annualized burden for the first and subsequent years of data collection. However, it has been determined that 36 percent of these elements are those that impact section 116(d) of WIOA, resulting in an estimated annualized burden of 360,000 hours, .

Table 7: WIOA Participant and Statewide Annualized Recordkeeping, and Third-Party Disclosure Cost Burden Estimate

PROGRAM	Total Respondent Burden Hours	Hourly Wage Rate	Total Respondent Burden Cost
Participant Third-Party Disclosures	4,775,544	$7.25**	$34,622,694
Statewide Recordkeeping of Participants information	5,013,443	$35.22*	$176,573,462
Total	9,788,987		$211,196,156

*Average hourly wage rate (including loaded wage factor of 1.57) for social workers. Retrieved from: http://www.bls.gov/oes/current/naics4_999200.htm. (20015)

**Participants’ time, for the purposes of the PRA, is costed out at the Federal minimum wage.

The total number of burden hours is divided between reporting and recordkeeping as follows:

DOL Portion ED Portion

Reporting: 1,118 928 190

Recordkeeping: 5,081,843 4,229,558 852,285

Third-party Disclosure: 4,775,544 4,125,860 649,684

Total Hourly Burden: 9,858,505 8,356,346 1,502,159

Total Unduplicated Respondents: 19,113,825

Total Responses: 38,215,999

DOL Portion:

Respondents: 15,489,620

Responses: 30,969,570

ED Portion:

Respondents: 3,624,205

Responses: 7,246,429

Table 9: Comprehensive Burden Analysis for all Information Collections

Report Item	Number of Respondents	Responses Per Year	Total Responses	Average Hours Per Response3	Annual Burden Hours	Average Hourly Wage	Time Value
ETA-9169	171	1	171	4.66	798	$35.22	$28,106
ETA-9169 Voc. Rehab	80	1	80	4	320	$45.88	$14,682
ETA-9171	11,400	1	11,400	6	68,400	$59.60*	$4,076,640
Participant Reporting (ETA-9170)	19,102,174	1	19,102,174	.25	4,775,544	$7.25	$34,622,694
Statewide Recordkeeping (ETA-9170)	251	76,104	19,102,174	.26	5,013,443	$35.22	$176,573,462
Unduplicated Totals	19,113,825		38,215,999		9,858,505		$215,315,584

13. Provide an estimate for the total annual cost burden to respondents or record keepers resulting from the collection of information. (Do not include the cost of any hour burden already reflected on the burden worksheet).

* The cost estimate should be split into two components: (a) a total capital and start-up cost component (annualized over its expected useful life) and (b) a total operation and maintenance and purchase of services component. The estimates should take into account costs associated with generating, maintaining, and disclosing or providing the information. Include descriptions of methods used to estimate major cost factors including system and technology acquisition, expected useful life of capital equipment, the discount rate(s), and the time period over which costs will be incurred. Capital and start-up costs include, among other items, preparations for collecting information such as purchasing computers and software; monitoring, sampling, drilling and testing equipment; and record storage facilities.

* If cost estimates are expected to vary widely, agencies should present ranges of cost burdens and explain the reasons for the variance. The cost of purchasing or contracting out information collections services should be a part of this cost burden estimate. In developing cost burden estimates, agencies may consult with a sample of respondents (fewer than 10), utilize the 60-day pre-OMB submission public comment process and use existing economic or regulatory impact analysis associated with the rulemaking containing the information collection, as appropriate.

* Generally, estimates should not include purchases of equipment or services, or portions thereof, made: (1) prior to October 1, 1995, (2) to achieve regulatory compliance with requirements not associated with the information collection, (3) for reasons other than to provide information or keep records for the government, or (4) as part of customary and usual business or private practices.

Summary:

There will also be an associated start-up cost for each respondent to implement WIOA. These costs include: enhancements to data collection systems to adhere to WIOA requirements, training staff on data collection rules, and for ETA, associated IT cost for transitioning data intake systems to collect exit information in a new method (e.g., data systems must be able to re-open closed cases if a participant re-enters the program within a given program year). A breakdown of these costs is listed below. It should be noted that the costs included here are one-time only, except for OCTAE’s AEFLA respondents.

Employment and Training Administration

For DOL core programs, the total cost of $5.7 million actual cost to respondents is derived from an estimated cost of $100,000 per each of the 57 respondents using RIA source data.  This cost to State grantees is primarily to upgrade/revise their management information systems to be able to collect the new data elements required under WIOA, to revise some data elements that may have changed as a result of sharing definitions and input values with ED, and to create a unique identifier that can be tracked over time. Any additional cost associated with data collection and reporting will be incurred at the Federal level to accept the revised format of the data files from each respondent.

Office of Career, Technical, and Adult Education

Because individual participant records for OCTAE’s AEFLA program are collected and maintained at the State level by State agencies responsible for administering and supervising adult education policy, significant enhancements and maintenance of state data systems and staff training will be required under WIOA. OCTAE estimates the annual cost of State data system requirements and staff training for compliance with the new collection and reporting of WIOA performance data at $350,000. This annual cost is comprised of $250,000 for data system enhancements, maintenance, and staff training and $100,000 for the additional data matching and staff training required to collect data and report outcomes for each participant exit. The review of public comments resulted in a decision by the Departments that a participant who has more than one exit during a program year will count as a separate participant for each exit for data collection and outcome reporting under the performance indicators. For such participants, the ICR uses the term “period of participation” to refer to the time between each “date of program entry” and the corresponding “date of program exit” during a program year.  Such participants have multiple periods of participation in a given program year. Prior to WIOA, the AEFLA program reported only unduplicated counts of participant outcomes. Making the change to an accountability structure that is based on reporting outcomes for each exit by a participant during a program year represents a significant operational change for OCTAE’s AEFLA program and will require a commensurate increase in the associated annual IT, data matching, and training costs for each respondent.

Rehabilitation Services Administration

All 80 State VR agencies will incur burden for start-up activities associated with modifying their case management systems (CMS) to collect and report data required by WIOA, including data to support the primary indicators of performance and other related performance requirements under section 116 of title I of WIOA. However, the burden for making such changes will vary among the 80 VR agencies dependent upon the size, sophistication of their information technology systems, and whether the agency contracts for outside assistance for developing and maintaining their CMS. We estimate that each of the 80 State VR agencies will require computer systems analysts for the task of modifying and reprogramming their CMS. However, because the level of effort for making such changes will vary, the burden estimates for this work by Computer Systems Analysts has been broken down to reflect this complexity. Roughly 30 of the 80 VR agencies use case management and reporting systems purchased from software providers who are responsible for maintaining and updating software. We estimate that each of these 30 VR agencies will require two Computer Systems Analysts to spend 150 hours integrating the software changes into their own State systems, resulting in 300 hours per agency, or a total of 9,000 hours in additional burden for all 30 agencies. Of the remaining 50 VR agencies that do not have agreements with a software provider to maintain and update software, five of these agencies are categorized as large agencies (with more than 5,000 employment outcomes) and 45 of these agencies are categorized as small to medium-sized agencies (with fewer than 1,000 employment outcomes, and between 1,000 and 5,000 employment outcomes, respectively). We estimate the five large agencies will require five computer systems analysts to spend 1,000 hours each to maintain and update agency software (5,000 hours per agency), for a total of 25,000 hours. We estimate the 45 small to medium-sized agencies will require two computer systems analysts to spend 1,000 hours each to maintain and update the software (2,000 hours per agency), for a total of 90,000 hours in order to make the necessary software changes. This results in a total of 115,000 hours for the 50 agencies without outside vendor support to maintain and update their information systems.

Combining this burden with the 9,000 hours for the 30 agencies that we estimate will only have to integrate the software modifications provided through their vendor contract results in a total burden estimate of 124,000 hours for all 80 VR agencies. Prorating these total burden hours at 36 percent results in an estimated total of 44,640 hours. Using an hourly compensation rate of $56.17 (based on data from the Bureau of Labor Statistics for State-employed Computer Systems Analysts and a loaded wage factor of 1.57), the prorated estimated cost for all 80 VR agencies is $2,507,429.

In addition to maintaining and updating software, 48 agencies that utilize vendor supplied case management software will incur additional software licensing or user fees. Using an average cost of $700 per user annually, we estimate a total cost for the approximate 6,600 users in States served by vendor systems of $4,620,000. However, we estimate that only 20 percent of the increase in such costs, or $924,000, is related to WIOA requirements. Applying the 36 percent proration factor to this estimated amount, the 48 agencies will incur an additional $332,640 in licensing or user fees.

WIOA core programs will need access to quarterly state UI wage data in order to efficiently identify exited participants who are employed in the second and fourth full quarters after exit to report on the employment indicators. These agencies will also need access to the state quarterly UI wage data to identify the individual quarterly wages in the second full quarter in order to calculate the median wage indicator. Prior to WIOA, DOL and Adult Education programs obtained quarterly UI wage data on their participants. However, this will be the first time that State VR agencies will be required to obtain and report UI wage data. VR programs will need to contribute a reasonable and proportional share of the costs for the maintenance and use of the State UI wage system and interstate wage information systems, on a per individual, per query, monthly, quarterly or annual basis. For State VR agencies, the Departments estimated this cost by first multiplying the data query cost for large VR agencies ($20,000) by the number of large VR agencies (10). We then multiplied the data query cost for medium VR agencies ($8,000) by the number of medium VR agencies (42). Finally, we multiplied the data query cost for small VR agencies ($4,000) by the number of small VR agencies (28). We summed the annual data query cost for all VR agencies to obtain a total estimated cost of $648,000.

Collection of Unemployment Insurance Wage Data
Applicable Cost	# of Affected Entities	Total Cost
$20,000	10 (large) VR agencies	$200,000
$8,000	42 (medium) VR agencies	$336,000
$4,000	28 (small) VR agencies	$112,000
TOTAL	80 VR agencies	$648,000

State VR agencies will need to purchase data analytic software and other IT tools, including related training to increase their capability to more effectively analyze their program data for the primary indicators of performance and the disaggregation of the performance data by employment barriers.  In addition, they will need to the capability to integrate data from UI reporting systems into their case management systems. We estimate that these one-time costs will average $25,000 for each of the 10 large agencies, $15,000 for each of the 42 medium-sized agencies, and $10,000 for each of the 28 small sized agencies. These estimated costs of $250,000 for large agencies, $630,000 for medium-size agencies, and $280,000 for small-sized agencies, sum to a total cost of $1,160,000 for all 80 VR agencies.

Finally, the 80 VR agencies will be required to train VR Counselors on the new and modified data elements that need to be collected and entered into their case management system. We estimate that each VR agency has an average of 62 VR Counselors and that each VR Counselor will require 8 hours of training. Using an hourly compensation rate of $35.09per VR Counselor (based on 2015 data from the Bureau of Labor Statistics and a loaded wage factor of 1.57), the estimated cost for VR Counselors to receive such training is $1,392,371 for all 80 agencies, or $17,405 per agency. In addition, we estimate that development of the training materials and methodologies will require 1 Staff Trainer 8 hours per VR agency. Using the Social and Community Service Manager hourly compensation rate ($54.21) as a proxy for the Staff Trainer, the estimated cost for development of the training is $34,694 for all 80 agencies. The total estimated cost for development of the training and VR Counselor participation in the training is $1,427,066 for all 80 VR agencies. Since we are estimating that approximately 36 percent of the burden is related to joint performance accountability, the estimated total cost associated is $513,734, or $6,422 per VR agency.

Summing all of the estimated start-up costs associated with this joint data collection for all 80 State VR agency respondents, results in a total cost burden of $5,161,803.

Start-up Cost Summary for Joint ICR

Department - Agency	Respondents (each providing one response per year)	Start-up Costs (per respondent)*	Total Annual Start-up Cost (for all respondents)
DOL - ETA	57	$100,000	$5,700,000
ED - OCTAE	57	$350,000	$19,950,000
ED - RSA	80	$64,523	$5,161,803
TOTAL	194	$514,523	$30,811,803**

*Annually over a three-year period. The Departments assume these initial costs will also cover any ongoing operation costs.

** For Reginfo.gov database entry purposes, each agency has taken a proportional share of the cost burden based on the number of responses. The amortized cost per response over the responses provided by States is $158,823.73. $30,811,803/194 responses = $158,823.73.

14. Provide estimates of annualized costs to the Federal government. Also, provide a description of the method used to estimate cost, which should include quantification of hours, operational expenses (such as equipment, overhead, printing, and support staff), and any other expense that would not have been incurred without this collection of information. Agencies may also aggregate cost estimates from Items 12, 13, and 14 in a single table.

Based on previously estimated software development costs for the programs listed below, and considering the changes required by WIOA and the proposed regulations, a preliminary estimate of the cost for the development of the software needed to accept these reports for the Departments is $1,674,648, including:

• $750,000 for the Adult and Dislocated Worker programs under Title I and Wagner-Peyser programs under Title III (Employment and Training Administration of the DOL). (The federal IT costs will increase if DOL decides to utilize a common reporting portal to obtain ETP data, that cost would be reflected in a future ICR);

• $750,000 for the AEFLA program under Title II (Office of Career, Technical, and Adult Education of the ED); and

• $174,648 for VR under Title IV (RSA of the ED).

The contract costs over 3 years average is $558,216. $1,674,648/3 years = $558,216. (Costs include loaded wage factor of 1.63.)

VR will develop its software using new staff positions. We estimate that it will take two full-time Data Management Specialist positions, one at GS-13 Step 5 and one at GS-14 Step 5, to complete the necessary database programming requirements. With an hourly wage of $64.71 for the GS-13 position and $76.48 for the GS-14 position, the total VR cost for software development $293,675. Since we are estimating that approximately 36 percent of the burden is related to joint performance accountability, the total attributable to the joint burden is $105,723. In addition, RSA will need to purchase software that will enable RSA to compile the quarterly data reported by VR agencies into the Annual Reports required under WIOA. The estimated cost of the needed software is $68,925.

(1 staff x 2,080 hours x $64.71 hourly wage = $134,597.

(1 staff x 2,080 hours x $76.48 hourly wage = $159,078.

$134,597 + $159,078 = $293,675 ($293,675 x .36% towards Joint Performance = $105,723)

$105,723 Joint Performance Cost + $68,925 Software Costs = $174,648 for RSA

Based on previous estimates for Federal oversight, it is estimated that, on average, 5 GS-13s and 4 GS-14s from each agency will spend a total of 160 hours annually on oversight of each of the three core programs specified above. Assuming hourly pay at the GS-13 Step 5 and GS-14 Step 5 level for the Washington D.C. Metro Area for 2015 is $80.39 and $94.99, respectively.

The Federal oversight costs are estimated to result in a total annualized cost of $420,912.

(5 staff x 3 programs x 160 hours x $80.39 hourly wage) = $192,936

(4 staff x 3 programs x 160 hours x $94.99 hourly wage) = $227,976.

Federal annual oversight costs: $420,912. $192,936+ $227,976= $420,912.

Total Annualized Cost to the Federal Government is: $979,128

Total annualized costs of the initial development (contract) costs = $558,216.

Federal oversight costs = $420,912

15. Explain the reasons for any program changes or adjustments reported on the burden worksheet.

This is a new collection of information.

16. For collections of information whose results will be published, outline plans for tabulation and publication. Address any complex analytical techniques that will be used. Provide the time schedule for the entire project, including beginning and ending dates of the collection of information, completion of report, publication dates, and other actions.

WIOA ANNUAL STATEWIDE PERFORMANCE REPORT (ETA-9169)

The Annual Report to be provided to Congress and the public via the Departments’ websites will be tabulated in a manner that corresponds to section 116(d)(2)(A)-(J) of WIOA:

1. Information specifying the levels of performance achieved with respect to primary indicators of performance for WIOA Youth, WIOA Adult, WIOA Dislocated Worker, Wagner-Peyser, Adult Education and Family Literacy Act, and the Vocational Rehabilitation programs, and the State adjusted levels of performance with respect to such indicators for each program.

2. Information specifying the levels of performance achieved with respect to the primary indicators of performance for WIOA Youth, WIOA Adult, WIOA Dislocated Worker, Wagner-Peyser, Adult Education and Family Literacy Act, and the Vocational Rehabilitation programs with respect to individuals with barriers to employment, disaggregated by the following subpopulations: displaced homemakers, low-income individuals, Indians, Alaska Natives, and Native Hawaiians as such terms are defined in section 166 of WIOA, older individuals, low levels of literacy or English proficiency, disability status, homelessness, youth who are in or have aged out of the foster care system, migrant and seasonal farmworkers, single parents (including single pregnant women), ex-offender status, and welfare dependency of such individuals, and disaggregated by race, ethnicity, sex, and age.

3. The total number of participants served by each core program.

4. Number of participants who received career services and training services, respectively, during the most recent program year and the three preceding program years and the amount of funds spent on each type of service.

5. The number of participants who exited from career services and training services, respectively, during the most recent program year and the three preceding program years.

6. The average cost per participant of those participants who received career services and training services, respectively, during the most recent program year and the three preceding program years.

7. The percentage of participants in a program who received training services and obtained unsubsidized employment in a field related to the training received.

8. The number of individuals with barriers to employment served by each core program disaggregated by each subpopulation.

9. The number of participants enrolled in more than one core program.

10. The percentage of the state’s annual allotment under section 132(b) that the state spent on administrative costs.

WIOA ETP PERFORMANCE REPORT (ETA-9171)

Although further details on the method for state submission and format for the ETP Performance Report will be further outlined in a later publication, please refer to the corresponding definitions in ETA-9171. In this future request, DOL will seek specific comments regarding the best methods for collecting the ETP Performance Report from states and displaying the data in a national scorecard similar to the College Scorecard (https://collegescorecard.ed.gov/) to maximize its value for workers, job-seekers, employers, local elected officials, State officials, Federal policymakers, and other key stakeholders. As noted above, WIOA specifies that states must make ETP-related data publicly available in a format that maximizes value for these stakeholders.

Data shall be reported by each eligible provider of training services under section 122 of WIOA, with respect to each program of study, in a manner that is tabulated as described in section 116(d)(4)(A)-(F) of WIOA, summarized below:

1. Information specifying the levels of performance achieved with respect to the primary indicators at WIOA sec. 116(b)(2)(A)(i)(I)-(IV) and 116(b)(2)(A)(ii)(I)-(III);

2. The total number of individuals exiting from the program of study (or the equivalent);

3. The total number of participants who received training services through each of the adult program and the dislocated worker program authorized under chapter 3 of subtitle B of title I of WIOA, disaggregated by the type of entity that provided the training, during the most recent program year and the three preceding program years;

4. The total number of participants who exited from training services, disaggregated by the type of entity that provided the training, during the most recent program year and the three preceding program years;

5. The average cost per participant for the participants who received training services, disaggregated by the type of entity that provided the training, during the most recent program year and the three preceding program years; and

6. The number of individuals with barriers to employment served by each of the adult program and the dislocated worker program authorized under chapter 3 of subtitle B, disaggregated by race and ethnicity, sex, age, and each subpopulation of individuals with barriers to employment.

17. If seeking approval not to display the expiration date for OMB approval of the information collection, explain the reasons that display would be inappropriate.

The expiration date will be included on the forms associated with this ICR.

18. Explain each exception to the topics of the certification statement identified in “Certification for Paperwork Reduction Act Submissions.”

There are no exceptions.

2. COLLECTIONS OF INFORMATION EMPLOYING STATISTICAL METHODS

The collection does not employ statistical methods.

1

2¹ For the Title I Youth program, the percentage of WIOA youth participants includes those who are in education or training activities, or in unsubsidized employment, during the second quarter after exit from the program (WIOA sec 116 (b)(2)(A)(ii)(I)).

For the Title I Youth program, the percentage of WIOA youth participants includes those who are in education or training activities, or in unsubsidized employment, during the fourth quarter after exit from the program (WIOA sec 116 (b)(2)(A)(ii)(II)). 

3 Specific hourly burden per response is delineated in the tables above. For the purposes of Table 9, the average hourly burden per response is calculated by dividing the annual burden hours for the report item by the total responses.

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