DOL-ONLY PIRL 
				
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				(Texas) DOL has proposed a
				large number of changes to the 9172.  While some are relatively
				minor clarifications to existing elements (updating details to
				match current practices), others are more substantive –
				including adding dozens of new data elements that will cost
				significant amounts of money to implement in grantee case
				management systems. 
				Even
				the proposals to make existing elements required for additional
				programs will require programming changes minimally in the code
				that produces the PIRL and possibly in the case management system
				if an element is not currently tracked for that program and there
				is no existing way to enter it.  We therefore urge DOL to
				consider whether the value of gathering additional data is worth
				the cost.  In most cases, the cost of adding a new element to a
				case management system and to the PIRL coding is largely the same
				whether applicable to <1% of participants or to nearly all
				participants.  We
				recommend that DOL reconsider whether these changes are really
				necessary and worth the cost given that while DOL estimates a
				cost to implement/comply with the ICR, it doesn’t provide
				additional money to grantees for this purpose.
				 Between biennial updates to the PIRL, three-four times per year
				edit changes, and new quarterly data integrity improvement
				efforts that often require programming to change, grantees are
				having to dedicate ever-greater amounts to capturing and
				reporting data that may be of limited value and this comes at the
				expense of funding for other activities. 
				We
				are particularly concerned about some of the larger changes, such
				as updating the ONET codes used in reporting occupational
				outcomes and the proposal new element for reporting whether
				individualized services were provided in person or remotely. 
				While we see the value of both of these pieces of information,
				the fact is that many states may not have been tracking this and
				will not be able to report the data retroactively. 
				Bigger
				changes like this have both programming and reporting challenges.
				 On the question of in person vs. remote service, for example,
				our system doesn’t track in person vs remote service
				separately.  If we report on a person who has exited prior to
				this going into effect, we won’t be able to answer this
				question affirmatively as yes or no. because of this.  Talking to
				states that use some of the larger vendor products, it seems like
				we’re not alone, as many of those products don’t do
				this tracking either. 
				As
				to the effective date of changes, we face a different problem. 
				It appears that DOL intends to implement this proposed PIRL
				effective July 1, 2021 but we won’t know what the final
				requirements are until May or June given that this has to go back
				out for public comment again and those comments could result in
				removal, addition, or modification of proposed changes.  We
				recommend that changes ultimately adopted through this ICR not be
				made mandatory until July 1, 2022 and that they not be applied
				retroactively to customers who exited prior to the changes going
				into effect. 
				The delayed implementation will provide time for states to make
				changes and the non-retroactivity will ensure that states are not
				required to go back and try to gather data that would normally
				have been gathered during either the eligibility or service
				delivery phases of participation. 
				What
				follows are comments on specific proposed changes including other
				recommendations for DOL PIRL elements that should be considered. 
				 
				 
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				Thank you for your comment. DOL will issue additional guidance on
				the timing of the adoption of these changes. 
				 
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				N/A 
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				(Texas Comments #1-#53) Element
				401 UC Eligible Status – ADDITIONAL
				RECOMMENDATION
				- DOL has indicated that they plan to administer the new
				Reemployment Service and Eligibility Assessment (RESEA) program
				measures using the PIRL.  However, those measures depend in part
				on identifying who was an RESEA Participant.  While Element 401
				indicates if a person was referred by RESEA, it does not indicate
				if that person actually received all the RESEA-required services.
				 A person might have come in and only received some of the
				services or might have been a Wagner-Peyser Participant prior to
				becoming a UI claimant and selected for RESEA and elected to not
				participate in RESEA.  There are two ways to address this
				problem: 
				
					
						Modify
						the response options in this element to indicate if RESEA
						Referred AND Participating or RESEA Referred but NOT
						Participating, OR 
						Add
						a new RESEA Program Participation element to the 900 series of
						elements that specifies that the person was both referred for
						RESEA services AND received the required services. 
					 
				 
				 
				 
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				The Department agrees with the commenter and has modified the
				definition of the PIRL data element. 
				 
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				ETA 9172- DOL only PIRL 
				 
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				Element
					808 MSFW – proposes element name change with additional
					language clarifying intent of the element and matches proposed
					Common PIRL change – Support 
					Element
					1301 – Support
					– clearly a typo correction and not change in the
					requirements. 
					Element
					1304 ETP Program of Study by Potential Outcome – Support
					– This is just an element Name change and has no
					functional impact on what and how the element is reported. 
					Element 1406 Post
					Exit- Enrollment in PSE – Support
					– Non-substantive, clarifying change. 
				 
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				Thank you for your supportive comments. 
				 
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				N/A 
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				Element 915 TAA Petition
				Number – Need
				Clarification –
				the proposal is to remove language instructing states to create
				multiple PIRL rows on TAA customers who have more than one
				applicable TAA Petition Number (primarily when in the same Period
				of Participation).  What’s not clear is if this is to bring
				the element in line with current reporting guidance (and thus not
				a substantive change) or if it represents a new policy for
				reporting.  If the latter, please provide additional guidance or
				clarification about what to states should do when reporting a
				Participant who has more than one applicable TAA petition. 
				 
				 
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				Thank you for your comment. This revision brings the element in
				line with current reporting guidance by removing erroneous
				reporting instructions provided under old reporting mechanisms. 
				This does not represent a change in in reporting guidance from
				the current PIRL reporting. 
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				N/A 
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				Making
					Elements 1000, 1001, and 1201 mandatory for TAA –
					Ambivalent –
					there may be cost to modifying PIRL coding to populate these
					elements for TAA-only Participants but this should be an easier
					change than some of the other proposals to make new data
					required for new programs. 
					Making
					Element 1103 mandatory for REO Adult, 1004 and 1210 mandatory
					for REO Youth and 1205 mandatory for both REO programs –
					Ambivalent –
					there may be cost to modifying PIRL coding to populate these
					elements for REO-only Participants but these should be an easier
					change than some of the other proposals to make new data
					required for new programs. 
					Element
					1300 Received Training – Ambivalent
					–
					proposes to add
					“as defined by program specific guidance” to the
					“Received Training = Yes” definition – Support
					– This is largely as DOL has been operating and therefore
					doesn’t represent a meaningful change. 
				 
				 
				 
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				Thanks you for your comment. The Department strives to keep
				burden down while ensuring cross program alignment to facilitate
				easier common reporting. 
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				N/A 
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				Modifying Element 1114
				Referred to Jobs for Veterans State Grants Services to have an
				additional value for Vietnam-era veterans – Concerned
				– DOL has provided no context for this change.  Why
				Vietnam-era veterans only? What about veterans of the original
				Gulf War or more recent military conflicts?  This will likely
				required both IT case management costs (will need to now capture
				the date of entry into military service for people who left the
				military after May 1975 since they may have served during the
				Vietnam-era) and PIRL changes. 
				 
				 
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				Veterans’ Program Letter No. 03-19 added “Vietnam-era
				veterans” as a sub-population who are eligible to receive
				services from Disabled Veteran Outreach Program specialists.  As
				such, it is important for VETS to be able to separate out
				participants who fall into this category for analytic purposes. 
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				N/A 
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				Elements 1306, 1311, 1316,
				1612, and 1613 (related to updating ONET codes used in reporting)
				– Very
				Concerned –
				there could be significant costs to implementing this data in
				case management systems depending on how those systems were
				created and the degree to which there may be secondary systems or
				functions that are based on the older standards. 
				 
				 
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				The Department appreciates the challenges associated with making
				this change and will therefore implement a phased implementation
				of this change  in order to allow states time to determine how
				best to make these adjustments. To accomplish this, the
				Department will continue to allow older ONET codes via its edit
				checks during the transition period. 
				 
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				N/A 
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				Element 1322 – Not
				clear why the name is proposed to be changed to not align to the
				other “Date of Most Recent ____________ Service” data
				elements.  Recommend
				either not changing or changing all the other applicable elements
				to this naming convention. 
				 
				 
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				Accepting recommendation to align name to include “Date
				of…” 
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				ETA 9172- DOL only PIRL 
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				Element 1328 Training
				Provided Virtual/Online (previously titled “Distance
				Learning”) – Very
				Concerned –
				we understand the value of this and while the addition of a “Mix
				of In Person and Online” option might seem easy – the
				reality is that it may not be.  TWC has tracked remote vs in
				person training data but at the Eligible Training Provider
				Program-level.  Students did one or the other.  COVID-19
				obviously caused many programs to shift from in person to online,
				but we don’t have a means to track that.  Texas has
				hundreds of Eligible Training Providers with several thousand
				approved programs – trying to retroactively find out which
				classes were being offered in person vs online at different
				points in time is not feasible.  We
				can only support this if the new “both” value is
				applicable to training conducted after the effective date of the
				element change. 
				 
				 
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				DOL concurs with this element only be required for training
				occurring after the effective date of the element change, but
				states may voluntarily report “both” on prior
				training if the data is readily available. 
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				N/A 
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				Element 1332 Participated
				in PSE during Participation – proposes to add “clarifying”
				language to the “No PSE” response and to eliminate
				the option to record “blank” if not applicable. 
				
					
						The
						additional clarifying language is essentially restating the
						existing language to try to clarify intent – Support 
						Removal
						of the option to leave blank if not Applicable – OPPOSE
						– This data element is used to drive the Credential Rate
						denominator.  The Credential Rate is not applicable not
						applicable if a participant in a WIOA program is also enrolled
						in PSE unrelated to their services from workforce system (other
						than for Title I in-school Youth). 
					 
				 
				For
				example, if we have a person enrolled in WIOA Adult who happens
				to be in PSE during participation but we are not paying for that
				education directly or with support payments and are instead only
				serving to help the person find employment while in school, then
				that person should not be in the Credential Rate denominator. 
				The
				proposed change requires the state to record a yes or no on every
				person, even those for whom the element is not applicable such as
				in the example identified above.  Without the blank if not
				applicable option, many states and locals may have confusion
				about how to respond.  If they answer “Yes” to on a
				record like the above WIOA Adult example, then that will put the
				person in the Credential Rate denominator even if the participant
				was early in their education and only needed school-compatible
				employment assistance.  This element should be entirely written
				as follows: 
				Record
				1 if the participant was in a postsecondary education program
				that leads to a credential or degree from an accredited
				postsecondary education institution at any point during program
				participation
				and the program provided services that directly supported that
				enrollment. 
				Record
				0 if the participant was not in a postsecondary education program
				that leads to a credential or degree from an accredited
				postsecondary education institution during program participation
				OR was in such
				education but the program did not provide services that directly
				supported that enrollment.  Note:
				this includes if the participant was enrolled in a postsecondary
				education program that does not lead to a credential or degree
				from an accredited postsecondary education institution at any
				point during program participation. 
				Note:
				This data element relates to the credential indicator denominator
				and those who are recorded as 1 are included in the credential
				rate denominator.  This element is a subset of PIRL 1811.  Do not
				record 1 if the participant was first enrolled in postsecondary
				education after exiting the program
				OR if the program was not directly supporting the post-secondary
				education. 
				 
				 
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				The Departments have agreed to add back in a “leave blank”
				option into 1332 to ensure that all possibilities are
				appropriately accounted for. The language will read “Leave
				blank if the participant was not in a postsecondary education
				program, as defined in program specific guidance.” 
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				ETA 9172- DOL only PIRL 
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				Making Elements 1403 and
				1405 applicable to REO Adult and REO Youth programs and Elements
				1408 and 1415applicable to REO Youth – Concerned
				– Are the required system change costs worth the value of
				these elements if grantees are not currently capturing this
				information on these programs? 
				 
				 
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				Thank you for your comment.  The purpose of making these items
				applicable to our adult and youth reentry programs is to have our
				grantees report on these items, so if the items are approved
				grantees will capture and report on them.  PIRL 1403 is for
				Alternative School Services.  This item will allow us to document
				in both our adult and youth reentry grants the number of
				participants who are provided high school equivalency classes. 
				40 percent of participants in our adult offender grants over the
				years did not have a high school diploma or equivalency and a
				quarter of participants in our recent youth offender grants that
				included data on school status were high school dropouts.  PIRL
				1405 is for work experience.  Given the immediate need for many
				adult offenders and older youth offenders to find a job to
				support themselves work experience and transitional jobs are an
				important way the reentry grants can serve these individuals, and
				the DOL should be able to document how many individuals we have
				provided work experience and transitional jobs.  
				 
				PIRL 1415 is for post-secondary education and preparatory
				activities.  DOL should be able to document the extent to which
				reentry programs have provided college bound services to young
				offenders.  PIRL 1408 is for leadership development activities. 
				PIRL 1408 is already in the youth offender schema and we are
				requesting that it also be applicable to the adult reentry grants
				because it is a valuable service, and the DOL should be able to
				document the extent it has provided this service to adult
				offenders. 
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				N/A 
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				Propose to change Elements
				1506, 1507, 1509, 1510, 1514, 1515, 1519, 1520, 1524, 1525, 1529,
				1530, 1536, and 1538 from reporting amounts “paid” to
				“expenditures accrued” – Need
				Clarification –
				“Paid” and “accrued” have very different
				meanings in accounting.  If the change is nonsubstantive and
				merely line up the language with the existing guidance, please
				provide reference to that guidance in response to public
				comments.  However, if these change represent actual changes to
				what is to be reported (accrued vs. paid), we OPPOSE
				the change as being too costly to implement in accounting
				systems, benefit systems, case management systems, and PIRL
				coding which would all need to be modified for a change that does
				not clearly provide information that is essential and superior to
				the “paid” amounts reported currently. 
				 
				 
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				This language change from “paid” to “expenditures”
				accrued is to align with current guidance on how to populate
				these fields throughout TAPR and PIRL.  Accrual reporting is
				required under 20 CFR 618.860, TEGL 01-19, TEGL 06-09 (including
				Change 1 and Change 2), and has long been discussed in technical
				assistance materials such as webinars and reporting FAQ sheets
				available to states. 
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				N/A 
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				Element 1542 A/RTAA
				Overpayment – OPPOSE
				– given that WIPS is a longitudinal data system, it is not
				clear why this change is necessary.  It is possible for DOL to
				determine whether there was an overpayment in a POP by looking at
				each PIRL submission rather than 50+ states, territories, and
				Washington DC all having to make a programming change. It would
				be far cheaper for DOL to use the data they already get to track
				overpayments.  DOL would only have to write or modify one query
				and apply it to all the PIRL submissions they’ve received. 
				 
				 
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				The DOL understands this overpayment element to be necessary to
				track what kinds of participants are receiving overpayments to
				better provide guidance on how to avoid overpayments in a program
				that has long received concerns about overpayment risk.  This
				element has been consistent for TAA participant reporting since
				FY 2009. 
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				N/A 
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				Element 1608
				Employment-Related to Training Q2 – Added the ability to
				record “unknown” in the element – STRONGLY
				SUPPORT –
				Few states receive occupational data as part of their wage
				records which means that the only way to report this element is
				through follow-up contacts with the Job Seeker or perhaps the
				Employer.  Given that we must wait until the 2nd
				quarter after exit to contact the Exiter to obtain the
				information, sometimes we will not have current contact
				information and be unable to contact the Exiter. 
				Contacting
				the employer to obtain information about the occupation the
				Exiter is employed in adds another 2+ months to the lag because
				of the delay in receiving wage records and TWC does not support
				contacting employers to obtain information about their employees
				absent a true statutory purpose like to determine unemployment
				eligibility information.  Further, employers do not want to be
				contacted for WIOA performance accountability purposes.  That was
				made perfectly clear to the Departments when they sought employer
				input on the WIOA “Effectiveness in Serving Employers”
				measure.  While this element is unrelated to the employer
				measures, the underlying message – “don’t call
				us, we’ll call you” – is still applicable. 
				HOWEVER,
				we also think that the “Leave Blank” provision needs
				to be clarified to state that we also leave it blank if the
				Exiter was not employed in the 2nd
				Quarter After Exit (Q2).  While this may not be the Departments’
				intent, the currently proposed set of options does not provide
				guidance on what to record (1, 0, or 9) if the Exiter was not
				found employed in Q2 post-exit.  All three options include the
				condition “and obtained employment” which makes none
				of the 3 options appropriate if the person was unemployed in Q2. 
				 
				 
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				Thank
				you for your comment. 
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				N/A 
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				1700 Series – 
				ADDITIONAL RECOMMENDATION
				– given there is significant seasonality in employment and
				earnings by calendar quarter (Q4 tends to have the highest number
				of people employed and many people get second, holiday jobs which
				raises earnings for the quarter), we recommend that DOL add an
				additional Element for the 4th
				Quarter Prior to Participation Quarter.  This would improve
				pre-post participation earnings employment and comparisons by
				ensuring that there is a full 4 quarters of both pre and post
				participation earnings available for analysis. 
				 
				 
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				Thank you for this recommendation. In the interest of minimizing
				burden, DOL will not be collecting this data at this time, but
				notes that states may collect additional information they deem
				important to their program management. 
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				N/A 
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				Elements 1703-1706
				Earnings in Xth Quarter after Exit Quarter – Changing the
				word “Wages “to “Earnings” Support
				– This change aligns the elements better with the reality
				that we work with people who are self-employed or contractors or
				gig workers.  The term “wages” is more limiting.  In
				addition, the data element definitions/instructions always used
				the word earnings. 
				In
				addition, we have two related comments to offer: 
				
					
						First,
						there is no need to report 999999.99 when wages are “not
						yet available” and we recommend removing this language.
						 The Departments of Education and Labor have set out a
						reporting schedule which identifies when earnings for a given
						quarter are deemed to be available and the Departments have
						data edit checks to make sure that states are not reporting
						earnings as “not yet available” when they clearly
						should be available based on the calendar.  Therefore, there is
						no need for states to code the “999999.99- data not
						available” data.  Further, it makes it impossible to
						actually report $999,999.99 as “real earnings” on
						the off chance that it occurs – reserving what is
						otherwise a valid number in a monetary field to represent
						something other than a monetary value is not a good data
						practice – it makes the data harder to use by introducing
						an additional data cleansing step.  States should report nulls
						until the data is mature and if there are no earnings once the
						data matures, they should record a 0. 
						This
						then leads to our second recommendation – add an extra
						digit to these fields as well as to the earnings prior to
						participation data elements.
						 Yes, it is very rare that we serve a person who earns more
						than $1M in a given quarter but it does happen.  It happened
						during the Great Recession when a lot of very highly
						compensated finance workers and executives were laid off or
						their companies closed.  This is likely happening again with
						participants in the COVID-19 period obtaining extraordinarily
						high levels of earnings pre and post-exit.  To be clear, this
						is a rarity for most states but some states with high
						concentrations of very highly paid workers (Wall Street,
						Silicon Valley, etc.) could have this legitimately show up in
						their records.  In the absence of adding a digit, we request
						that the instructions be modified to explicitly define what we
						should report in an instance where the Exiter legitimately had
						earnings of more than $1M in a given quarter.  Of note is that
						Element 2203 which is to report HOURLY wage at placement is
						allows reporting of up to $9,999,999.99. 
					 
				 
				 
				 
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				Thank you for your comment. The Departments are increasing the
				field length to address the Commenters concern, but the
				Departments are keeping the option to report all 9’s when
				wages are “not yet available.” 
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				ETA 9172 DOL only PIRL 
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				Elements 1811 and 1813
				Date Enrolled (or Completed) Education or Training during Program
				Participation – STRONGLY
				SUPPORT Removal
				of the word “Postsecondary” from the element titles
				will greatly reduce confusion about the applicability of these
				elements to people in secondary education.  The detailed
				instructions on how to record the element always made it clear
				that this included people enrolled in secondary education, but
				the element name didn’t seem consistent with that guidance.
				 This made training and consistent coding/application of the
				business rules more complicated. 
				 
				 
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				Thank you for your comment. 
				 
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				N/A 
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				Elements 1902, 1909, and
				1916 Category of Assessment – Ambivalent
				– Not clear why the change is proposed, particularly the
				removal the ability to report a person being assessed in both ABE
				and ESL. 
				 
				 
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				Thank you for your comment. These changes were made to better
				align with the most recent version of these assessments. 
				 
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				N/A 
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				Element
					1905, 1908, 1912, 1915, 1919, and 1922 Pre and Post Test
					Assessment Scores – Support
					– these changes simply update the language to match
					current reporting policy. 
					Elements
					2003 and 2004 related to DWG – Support 
					Element
					2126 – Support
					– nonsubstantive naming change. 
					Addition
					of Individualized Services Provided Virtual/Online –
					Support
					subject to the conditions noted in the introduction about
					providing time to implement the automation changes to track this
					and that it not be applied retroactively to periods in which it
					was not possible to identify whether a service was provided in
					person or online. 
				 
				 
				 
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				Thank you for your comment. 
				 
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				N/A 
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				Elements 2109-2113 related
				to Type of Training – OPPOSE
				– Why would DOL remove Registered Apprenticeship as an
				option to report on these elements given the great interest in
				Registered Apprenticeship as well as the significant amounts of
				funding that have gone to Apprenticeship Expansion Grants?  Yes,
				there is some redundancy to Element 2207, but the values are
				currently reported and there is no cost to continuing to report
				them. 
				 
				 
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				Please see response from DOL’s Office of Apprenticeship in
				the document below. 
				 
				 
 
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				ETA 9172 DOL Only PIRL 
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				Making Elements 2203,
				2204, 2207, 2209, 2210, 2211, 2212 applicable to REO Adult
				program (and RIO Youth for 2210 – OPPOSE
				on basis of cost to modify IT systems and PIRL coding to
				record/report these items. 
				 
				 
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				Thank you for your comments.  We believe that the value of making
				these items applicable to our reentry programs outweighs any
				costs for modifying IT systems and PIRL coding.  Items 2203 and
				2204 are for hourly wages and weekly hours of jobs in which
				reentry grants placed participants.  Finding a job is the main
				reason offenders apply for our programs and DOL should be able to
				document the wages and weekly hours of the jobs in which we place
				individuals.  Items 2209, 2210, 2211, and 2212 are for supportive
				services relating to transportation, health care, child care, and
				housing.  Many ex-offenders are in dire financial situations and
				are in need of supportive services.  Over the course of the
				years, 75 percent of participants in our adult offender grants
				have received supportive services and we should be able to
				document what type of supportive services that they have
				received.  Child care is relevant because women make up almost a
				quarter of participants in our adult offender programs. 
				Similarly, the value of making 2210 applicable to youth reentry
				programs outweighs any costs modifying IT systems because DOL
				should be in a position to document the number of participants
				receiving health-related supportive services.  As a benchmark, 20
				percent of participants in our adult reentry grants have received
				health-related supportive services.  
				 
			 | 
			
				N/A 
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				Element 2212 Housing
				Services – Support the name change but don’t
				understand removal of the option to report “both”
				since a person might initially receive temporary housing
				assistance and then also receive permanent housing assistance
				when an opportunity arises. 
				 
				 
			 | 
			
				The Department agrees with the commenter and has added the option
				to report “both” back in the data element. 
				 
			 | 
			
				ETA 9172 DOL only PIRL 
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				All Other Section E.11
				Elements – OPPOSE
				– No justification was provided for the need to add these
				data elements and while they might be useful in some regard, it
				is not clear for what purpose or that the value of the data
				outweighs the cost of implementing them.  These elements will
				require changes to case management systems and PIRL coding.  In
				addition, the Wagner-Peyser registration requirements were
				substantially expanded under WIOA and require answering 100
				questions (since not all elements can be asked in the PIRL format
				and still be understandable to lay people).  Time spent gathering
				data is time that can’t be spent serving the customer so
				the data that is gathered has to be of highest value to make it
				worth the diversion of attention from the customer and the
				creation of additional hoops for them to jump through. 
				 
				 
			 | 
			
				Thank you for your comment. 
				 
				The 4 elements added for REO are
				needed to populate the REO QPRs. 
				The elements for virtual
				services, given the rapid expansion the use of virtual services,
				the Department believes it’s necessary to capture
				additional information. 
				Individualized Services Provided
				Virtually: with the increasing capabilities of technology and the
				unfortunately circumstances of the pandemic, it seems possible
				and probable that individualized career services could be
				delivered virtually.  This will be an important distinction as
				DOL analyzes performance outcomes. 
				Transitioning Service Member
				Warm Handover/Housing Plan: As part of the ongoing partnership
				with the Dept. of Defense, it is necessary to ensure that the
				Warm Handover requirement (any military member who is deemed not
				career ready must be referred to the AJC)  is being carried out
				as intended.  Additionally, if someone is deemed to be at risk of
				homelessness, a housing plan is also required. 
				Referred from VA: In a partnership with the Dept. of Veteran’s
				Affairs, it is important for DOL to determine what additional
				services a veteran has received in addition to the ones received
				at the AJC.  To fully analyze the performance outcomes of
				veterans, DOL must also know as many non-DOL services received as
				possible. 
			 | 
			
				 
				 
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				Suggestion related to
				PIRL Elements currently reported based on Status at Date of
				Program Entry but which can change during participation:
				We suggest that reporting on a participant’s Status at Exit
				would be more valuable for analyzing the success of program
				efforts.  Ultimately,
				it doesn’t matter what the person’s status was at
				Date of Program Entry.  Status at Exit reflects the challenges
				that participants face or advantages they have in navigating the
				labor market after their program participation ends.
				 Do these characteristics change over time for a large portion of
				the population?  Maybe not, particularly in a program like
				Wagner-Peyser that serves a very high volume of people and
				typically for relatively short periods.  However, for smaller
				programs and programs where participation tends to occur over
				longer periods of time (like Youth and Vocational
				Rehabilitation), a greater proportion of Participants will have
				life changes that are important to note to tell the story of the
				workforce system, those we served, and what we together were able
				to achieve. 
				Many
				of these data elements, particularly those related to what WIOA
				calls “Barriers to Employment” are utilized in the
				WIOA statistical adjustment models as well as to break out
				participants and result in the annual and quarterly report
				templates.  As relates to the barriers, they statistically tend
				to correlate to lower outcomes – that is, all other things
				being equal, a person with a barrier is less likely to have as
				successful a set of outcomes as a person who is in every other
				way statistically similar but does not have any barriers. 
				One
				example of this is if you had two people of the same age,
				demographic characteristics, gender, geographic location, work
				history, education levels, certifications, etc. but one with a
				felony conviction and the other without, we know that the person
				with a felony conviction is statistically less likely to have as
				strong a set of outcomes as the person without a felony
				conviction. 
				In
				addition, some of the most common questions from elected and
				appointed officials, partners, and other stakeholders relate to
				the number of people served and their outcomes based on
				demographic and other characteristics.  Some of the most
				requested characteristics are: 
				
					Veterans 
					People
					with a Disability 
					Ex-Offenders 
					Foster
					Youth 
					Low
					Income 
					Single
					Parents. 
				 
				When
				we’re asked these questions, they are not interested in a
				count based on status at date of participation.  That is not
				relevant to the question.  If the system begins serving an Active
				Military member before he or she musters out and is providing
				participatory level services, the current Joint PIRL requires
				this person to be reported as “Non-Veteran.”  But the
				reason this person came to us was in preparation for leaving the
				military and could in fact do so during that same Period of
				Participation.  Assuming the discharge type was not disqualifying
				for veteran status, this person is now a Veteran.  We served a
				Veteran and yet we can’t report it in any of the data we
				report to the Departments of Labor and Education through our
				quarterly and annual reports because the requirements are to
				report based on status at Date of Participation. 
				A
				similar example would be a person who had no disability when
				participation began but who had an accident during their Period
				of Participation and now has a disability – we have served
				a person with a disability but have no way to report it.  That
				means that the Statistical Adjustment Models used to evaluate
				program performance based on the characteristics of those served
				and the economic conditions in which they were served does not
				get a true picture of who was served and therefore can’t
				account for that true casemix in evaluating performance at the
				end of the year.  This undermines the legitimacy of the WIOA
				performance accountability system which is predicated on the
				creation of a model that can account for factors outside the
				program’s control that impact outcomes (positively or
				negatively). 
				Further,
				for the Title I programs, the populations in question are much
				smaller when running local workforce development board
				performance and therefore the impact of each participant on the
				casemix becomes all the more important.  If a local board has an
				unusual number of these kind of life changes in a group of
				exiters, the impact of not being able to update the record to
				reflect these changes will be much more pronounced. 
				Our
				recommended solution is to change these data elements to not be
				limited to status at Date of Program Entry but rather to allow
				states to update values as appropriate to reflect the relevant
				characteristics of those we serve as they enter/reenter the labor
				market: 
				
					202
					Individual with a Disability – As discussed above. 
					400
					Employment Status – This one is slightly unique –
					what we’re particularly concerned with is the “negative”
					status on an element, the characteristics/statuses that are more
					likely to make a positive outcome harder to achieve.  So in this
					case, we recommend that if at any point during participation,
					the participant becomes “Unemployed” we would report
					it as such and would not update that back to “Employed”
					if the person became employed during participation.  This may
					seem inconsistent but from a reporting and service perspective,
					that person was unemployed and we served them while unemployed
					and we helped that person achieve a positive employment outcome
					(which will be reflected in wage records later). 
					402
					Long-term Unemployed – In the current pandemic it is clear
					that a large portion of those we serve will not be “long
					term unemployed” at Date of Program Entry but will be
					unable to find employment for quite some time (new claimants
					from March will hit 27 weeks of unemployment by the end of
					October).  If a person comes to us immediately after being laid
					off, they can still become long-term unemployed and employers
					may be more hesitant to hire them as they may have concerns that
					the person’s skills have atrophied through long term
					disuse. 
					407
					Highest School Grade Completed / 408 Highest Education Level
					Completed – If in 11th
					grade at program entry but a HS or college grad or certificate
					holder at exit, the education level at exit is more relevant to
					their opportunities of success in the labor market. 
					704
					Foster Care Youth Status – again, if we have a young
					person who was in their original family at participation and has
					a family tragedy that results in that person becoming a Foster
					Youth during participation, we have served a foster youth and
					that person is going to face all of the challenges that being a
					foster youth brings when it comes to completing their high
					school education, advancing to postsecondary education, and
					transitioning into the workforce. 
					800
					Homeless Individual, Homeless Children and Youths, or Runaway
					Youth – as above, if a person had a stable family
					environment/home and then that changed during participation,
					that person is now going to face all the challenges that being
					homeless or a runaway bring.  Their outcomes are statistically
					unlikely to be as good as those whose family/home status did not
					deteriorate during participation. 
					801
					Ex-Offender – As discussed above. 
					802
					Low Income – As with Long Term Unemployed discussed above,
					a person might come to the system with good income but over
					their period of participation, particularly through the
					pandemic, may have to apply for and receive public assistance
					(not unemployment insurance).  There is keen interest in how the
					system helps people on public assistance to become
					self-sufficient.  Cases that transition like this are not
					reportable in the existing system. 
					806
					Single Parent – This status can certainly change during
					participation and creates an entirely new set of challenges for
					the participant. 
					807
					Displaced Homemaker – as with single parent status, this
					can change during participation and impact outcomes and again,
					represents a priority population that WIOA requires us to report
					on. 
				 
				Most
				of the above elements-relate to “Barriers to Employment”
				under WIOA.  The statute in its very first sentence says that
				“The purposes of this Act are the following: (1) To
				increase, for individuals in the United States, particularly
				those individuals with barriers to employment, access to and
				opportunities for the employment, education, training, and
				support services they need to succeed in the labor market.”
				 It goes on to define these barriers in WIOA Sec.3 (24) and in
				WIOA 116(b)(3) requires the Departments of Labor and Education to
				develop a statistical model that accounts for the barriers
				(though it doesn’t call them barriers in WIOA Sec.
				116(b)(3)(A)(v)(II)(bb), it does list many of the barriers as
				examples of factors to be considered by the model).  Finally,
				WIOA Sec. 116(d)(2)(B) and (H) require performance data to be
				disaggregated by each subpopulation of individuals with barriers
				to employment. 
				In
				short, WIOA defines a key part of its purpose to serve people
				with “Barriers to Employment,” requires the
				performance accountability system to account for the
				characteristics of those served including factors that may
				negatively impact performance – like “Barriers to
				Employment” – and, finally, requires reports to break
				performance data out by demographic characteristics and barriers
				to employment.  However, the current Joint PIRL specs are not
				aligned with these statutory provisions because they focus on the
				person on at the beginning of participation and it is their
				status at the end of participation that will have the greatest
				influence on their outcomes in the vast majority of cases. 
				In
				order to ensure that the national workforce system’s
				service to people with barriers as well as the outcomes achieved
				are fully reflected in the quarterly and annual reports as well
				as the statistical adjustment models, we urge the Departments to
				revisit the existing standards and modify them to be more
				reflective of the people we serve and the challenges they face
				during that period of service and transition to either
				Post-Secondary Education or Employment. 
				 
				 
			 | 
			
				The Department thanks the Commenter for this suggestion and notes
				that not all of the referenced elements are based on status at
				date of program entry. For those that are based on status at date
				of program entry, it is acceptable to change information in an
				individual’s PIRL record based on new information if that
				new information reflects their status at program entry. If the
				participant’s status changes during participation, however,
				these elements must not be updated to reflect such changes. For
				example, if a participant discloses that they had been previously
				incarcerated but were uncomfortable discussing that when first
				entering the program, then PIRL DE801 (Ex-Offender Status at
				Program Entry) can be changed to a “1”, but if a
				participant who was unemployed starts working a part time job
				after entering the program then PIRL DE400 (Employment Status at
				Program Entry) cannot be changed. Additionally, elements that are
				not specifically designated as taking place at program entry,
				such as PIRL DE202 (Individual with a Disability) can be updated
				at any time to reflect the most accurate information about the
				participant. 
				Special consideration for common
				reporting of co-enrollment. While ETA encourages the use of prior
				assessments when possible to determine participant eligibility,
				needs, etc. it may be the case that a participant in one program
				may have a change in status that leads to them becoming eligible
				for services in another program. In such a scenario, it is
				acceptable to update the relevant “at program entry”
				elements to reflect the participant’s status at entry into
				the subsequent program to better facilitate common reporting. 
				The Department will not be making changes to the collection in
				response to this comment. 
				 
			 | 
			
				N/A 
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				(Pennsylvania #54-#55) 
				Request
				to modify current definitions: 
				 
				 
				The following proposals are being
				made to address definitional issues for the purpose of easing
				burden and improving reliability of the data: 
				 
				 
				413 -
				Migrant and Seasonal Farmworker Designation as defined at 20 CFR
				651.10 
				808 -
				Eligible Migrant and Seasonal Farmworker Status (WIOA sec. 167) 
				 
				 
				It is
				understood that 413 and 808 have definitional differences and
				that 808 is a common element across all core programs.  However,
				we respectfully request a review of the two elements to identify
				a way to capture and report in a single element, including
				directions that only certain responses are applicable to Titles I
				and III.  It is felt this would allow for a more robust look at
				MSFW's served by the workforce system. 
				 
				 
				907 -
				Recipient of Incumbent Worker Training 
				
				The requirement to report multiple values identifying the program
				of funding is slightly redundant, given the values could be
				derived based on the programs of participation captured in other
				PIRL elements. 
				 
				 
				1306, 1311,
				1316 – Occupational Skills Training Code – 
				 
				
				The requirement to align the codes in these fields with a
				specific O*NET SOC taxonomy will result in significant costs to
				adjust current systems to utilize the updated taxonomy.  Not only
				will the cost be to incorporate the new taxonomy but also to
				ensure all prior recorded codes align with the current taxonomy. 
				In addition, the realignment of these codes may lead to
				inaccuracies when analyzing the types of trainings being
				provided, as some codes stay the same but the definition changes. 
				 
				 
				 
				 
				1812 -
				School Status at Exit 
				 
				
				This element is applicable to Youth program participants only. As
				such, the definition should be modified in such a way as to
				indicate the information should be captured at the conclusion of
				youth services.  
				 
				 
				 
				 
				 
				 
				 
				 
				 
				1814 - Date Attained Graduate/Post
				Graduate Degree (WIOA) 
				This
				information should not be required for Title I and programs since
				a master's degree is not a program/performance focus. 
				 
				 
				 
				 
			 | 
			
				Thank you for your comment. 
				 
				 
 
				 
				 
 
				 
				 
 
				 
				RE 413/808: There are
				statutorily reasons why the definitions exist, and the Department
				will provide additional technical assistance on reporting these 2
				elements. 
				 
				 
 
				 
				 
 
				 
				 
 
				 
				 
 
				 
				RE 907: Due to different
				requirements for providing Incumbent Worker Training in the
				various programs and the possibility for combined reporting, the
				Department finds it necessary to collect this element using
				multiple values. 
				 
				RE 1306,1311,1316: The
				Department appreciates the challenges associated with making this
				change and will therefore implement a phased implementation of
				this change  in order to allow states time to determine how best
				to make these adjustments. To accomplish this, the Department
				will continue to allow older ONET codes via its edit checks
				during the transition period. 
				 
				 
 
				 
				RE 1812: The Department
				disagrees with the commenter.  This element is required for WIOA
				Youth, NFJP, INA, and REO Youth so it’s not just a youth
				element.  Also, it’s important this element remain as
				status at exit because DOL compares school status at enrollment
				to school status at exit to assess the program’s impact on
				school status over the life of the program.  
				 
				RE 1814: This is a joint element and is included for
				title I in case grantees want to report this attainment for
				programs the individuals are co-enrolled in, and can be left
				blank if not applicable. 
				 
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				Requests to remove data elements from the PIRL structure: 
				 
				 
				204  - 209 – Types of
				Disability-related services received – small, specialized
				populations 
				 
				
					Attempts to work with state
					Departments of Human Services to obtain crossmatches have
					indicated there is a lack of clarity at the state level as to
					what this means.  Where clarity exists, extensive IT development
					is required to obtain the information from what research has
					shown to be a very small crossmatch of individuals. 
					Information may be germane to
					service delivery/planning/goal setting but to make it mandatory
					data entry with coded values when applicable to such a small
					percentage of the population we serve is burdensome and costly. 
					The collection of this
					information by workforce development front-line staff, who are
					unfamiliar with these services, require individual
					interpretation leading to inconsistencies and a lack of intended
					value. 
					 
				 
				 
				 
				 
				 
				 
				 
				 
				 
				 
				 
				 
				 
				 
				 
				 
				 
				 
				 
				 
				 
				 
				 
				 
				 
				 
				 
				 
				 
				 
				 
				 
				 
				 
				 
				 
				 
				 
				 
				 
				 
				 
				 
				 
				 
				 
				 
				 
				 
				 
				 
				 
				 
				 
				 
				 
				 
				 
				 
				 
				 
				 
				 
				 
				 
				 
				 
				 
				 
				 
				 
				 
				 
				 
				 
				 
				 
				 
				 
				 
				 
				 
				 
				 
				 
				 
				 
				 
				 
				 
				 
				308 – Homeless Veteran 
				The inclusion
				of this data element is seen as an unnecessary data collection,
				as this demographic can be derived from two other elements (301 &
				800) 
				 
				 
				 
				 
				315 – Other Significant
				Barrier to Employment 
				Lack of clarity
				exists as to what would be captured here.  Including a data
				element in the PIRL data file that is rarely populated does not
				fit with good data file design principles. 
				 
				 
				 
				 
				 
				 
				934 – Rapid Response Event
				Number 
				While
				recognizing US DOL’s desire to retain this element to allow
				continued capture of data from those states that implemented an
				internal tracking system, the inclusion of this element adds
				unnecessary cost and burden to states who did not implement such
				a system. 
				 
				 
				 
				 
				 
				 
				 
				 
				 
				 
				 
				935 – Accountability Exit
				Status (code value 3) – 
				Discussions
				indicate the applicability of this code value is very limited
				across states, even those with large numbers of Trade
				participants.  In addition, the time and cost associated with
				tracking and recording it from the case management system to the
				PIRL report is burdensome. 
				 
				 
				 
				 
				 
				 
				 
				 
				939 & 940 - Individual with A
				Disability Individualized Education Program/Disability Section
				504 Plan 
				Information may
				be germane to service delivery/planning/goal setting, but to make
				it mandatory data entry with coded values when applicable to such
				a small percentage of the populations is burdensome and costly. 
				 
				 
				 
				 
				1902 – 1922 –
				Educational Functioning Level testing information 
The
				inclusion of these data elements is seen as an unnecessary data
				collection, as the information is not necessary for determination
				of an EFL gain in relation to the measurable skill gains metric. 
				In addition, significant changes to the assessment tools from
				which this data was captured has led to the misalignment of code
				values to information available. 
				 
			 | 
			
				While the Department understands the complexities of collecting
				and tracking data, it is important for front-line staff to learn
				new methods in which to collect data through professional
				development, as well as the reasons why the data provides
				critical information to the workforce development system. This
				data is useful to the system in multiple ways, including: 
				1.  States and localities can
				improve programmatic accessibility for individuals by better
				understanding who is being served. 
				2.  Multiple agencies and
				organizations serve participants under the Workforce Innovation
				and Opportunity Act (WIOA).  Collecting common data elements
				enables the Department to learn who is being served, and by which
				agencies, allowing the Department to enhance collaboration among
				required and non-required partners. By expanding partnerships,
				WIOA programs can leverage funding to provide additional services
				and ultimately decrease service silos through better
				coordination.  This also leads to improved services and outcomes
				for participants. 
				3.  Tracking of disability data
				will help the Department get a better understanding of outcomes
				that are resulting under WIOA, including for new requirements
				such as those relating to Competitive Integrated Employment and
				other work options (such as Customized Employment).  Analyzing
				these outcomes will also assist the DOL to identify needs to
				provide targeted technical assistance in areas where outcomes are
				lacking. 
				The Department has released a
				suite of materials in the last fiscal year, including: 
				
					A policy and analysis brief
					to explain the disability related data elements, and analyze
					state reporting across all these elements, which is available
					here:
					http://leadcenter.org/resources/report-brief/disability-related-reporting-participant-individual-record-layout-pirl. 
				 
				 
 
				 
				
					A WIOA PIRL Data
					Visualization Tool to help states understand their own levels of
					reporting on the disability-related PIRL data elements,
					available at
					http://drivedisabilityemployment.org/wioa-reporting. 
					Two webinars to help state
					and local workforce systems better understand and collect these
					data. These webinars are available at:
					http://www.leadcenter.org/webinars/understanding-wioa-disability-related-reporting-tools-data-visualization
					and
					http://leadcenter.org/webinars/wioa-disability-related-reporting-deep-dive-participant-individual-record-layout-pirl-0. 
				 
				The Department is currently
				working on additional technical assistance materials relating to
				the PIRL disability data elements to be released later this
				fiscal year. 
				 
 
				 
				RE 308: The Department
				agrees with the Commenter and will remove PIRL 308. 
				 
				 
 
				 
				RE 315: PIRL 315 is an
				important data element as JVSG requirements can change before
				PIRL revisions occur.  For example, Vietnam-era veterans was
				added as a significant barrier to employment on February 7, 2019,
				but there was not an existing data element to capture this.  PIRL
				315 can be used in the interim until a permanent solution is
				implemented. 
				RE 934: The Department
				notes this element is optional, so it adds no burden other than
				having a blank column in the file submission.  This element has
				been used by states meaningfully to help improve tracking of
				rapid response events and according to a recent analysis,
				approximately 1/3 of states are utilizing this field
				meaningfully.  While there may be no current plans to create a
				national system, when this data is available it provides
				important insights into the number of rapid response events. 
				RE 935: DOL agrees with
				this comment that this element is particularly burdensome for
				TAA.  The Department will remove code value 3.  However, to track
				TAA participants who receive services under multiple petitions,
				PIRL 915 will be modified to accept a delimited list of values. 
				The Department recommends only
				collecting this data when an individual indicates they have a
				disability. 
				 
				 
 
				 
				RE 939/940: The
				Department recommends only asking this question to participants
				that indicate they have a disability 
				 
 
				 
				 
 
				 
				RE 1902 – 1922: The department agrees that
				it would be reasonable to removed elements 1902-1922 for the
				formula programs. DOL is going to keep these elements in the PIRL
				as required for YouthBuild, REO Adult, and REO Youth, Job Corps,
				NFJP as they have specific uses for these elements for monitoring
				and these elements are already included in their national case
				management systems so it’s not an additional burden for
				them to stay as required PIRL elements for those programs. 
			 | 
			
				ETA 9172 DOL Only PIRL 
			 | 
		
		
			
				 
				
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				Error: Reference source not found
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				(Pennsylvania) 
				 
				Request
				to remove the following elements as ‘required’ for
				Apprenticeship reporting 
				 
				 
				The
				Apprenticeship program is unique from other workforce programs in
				that the individual is already employed through a connection
				outside the traditional workforce system.  Required collection of
				this information would be burdensome to the employer who must
				provide this information to the grantee for tracking purposes and
				in some cases require the employer do an assessment to determine
				applicability to the apprentice: 
				 
				 
				 
				Element
				108-A – ETA-assigned 1st Local Workforce Board
				Code 
				 
				Element 301
				– Eligible Veteran Status 
				 
				Element 303
				– Disabled Veteran 
				 
				Element 401
				– UC Eligible Status 
				 
				Element 409
				– School Status at Program Entry 
				Element 804
				– Basic Skills Deficient/Low Levels of Literacy at Program
				Entry 
				Element 806
				– Single Parent at Program Entry 
				Element 807
				– Displaced Homemaker at Program Entry 
				Element 903
				– Adult Program Participant 
				Element 904
				– Dislocated Worker Program Participant 
				Element 905
				– Youth Program Participant 
				Element 910
				– Adult Education Program Participant 
				Element 911
				– Job Corps Program Participant 
				Element 913
				– Indian and Native American Program Participant 
				Element 914
				– Veterans’ Program Participant 
				Element 915
				– TAA Petition Number 
				Element 916
				– Vocational Education 
				 
				Element 917
				– Vocational Rehabilitation 
				Element 918
				- Wagner-Peyser Employment Service 
				 
				Element 919
				– YouthBuild 
				Element 938
				– H-1B 
				Element 1210
				– Received Pre-Vocational Activities 
				Element 1333
				– Received Training from Programs Operated by the Private
				Sector 
				Element 2413
				– Incarcerated at Program Entry 
				 
				 
				In addition,
				Element 1301 – Eligible Training Provider – Name –
				Training Service #1 should not be required because Registered
				Apprenticeships are not required to be included on the state
				Eligible Training Program list.  In addition, not all
				Apprenticeship grantees have access to state Eligible Training
				Program lists, nor are they required to compile one. 
				 
				 
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				(From NC Community College) 
				Based upon the information provided
				and the request to evaluate whether the collection of information
				is necessary for the proper performance of the functions of the
				agency, I have to say that it is not.  This is requiring 131
				data elements that are to be collected for apprenticeship, many
				of which are not relevant to the apprentice.  Apprentices do
				not complete intake forms and are hired by the employer, through
				the means that the employer finds the most efficient. 
				 
				Employers are referred WIOA
				participants, but the company does not choose to hire them. 
				Therefore, this data collection burden is placed on the
				employer.  Employers do not have time to collect this
				additional data, especially now that they are dealing with the
				pandemic and continuing to run a company.  Employers are
				viewing this as a burden of additional paperwork and are more and
				more becoming uninterested in apprenticeship because of it. 
				The information already collected
				is enough to follow the apprentice through training and after
				training.  We must minimize the burden of collecting
				information, not create more of a burden.  
				 
				This does not follow the paperwork
				reduction act of 1995 (PRA), but is just the opposite. 
				 
				 
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				Montana 
				The Montana Department of Labor &
				Industry (MTDLI) is committed to facilitating and developing
				high-quality registered apprenticeship (RA) programs in order to
				recruit, train and retain a diverse and highly skilled workforce.
				No other education and training system brings together
				government, education, business and labor so effectively to
				produce such high-performance outcomes. With that context, MTDLI
				respectfully asks that the RA Expansion grants be left off the
				list as DOL/ETA considers this extension of authority. 
				 
				 
				RA is an industry-recognized,
				voluntary and employer-driven system. If DOL/ETA is to evaluate
				whether the proposed collection of information is necessary for
				the proper performance of the functions of the agency, including
				whether the information will have practical utility, it should
				take into consideration the Fitzgerald Act and resultant and
				related State regulations put in place to ensure accountability
				and equal employment opportunity. Employer and Labor sponsors of
				RA programs are already subject to a myriad of legally binding
				provisions in both federal and state law. MTDLI sees no utility
				in applying WIOA, pre-employment-based performance metric
				requirements to an already well regulated, high-performing,
				employment-based, career building program. 
				 
				 
				 
				MTDLI is committed to a national
				System of Registered Apprenticeship. While we are encouraged by
				recent public investments in the model, we are also concerned
				that the proposed extension of data gathering authority to
				include Federal RA Expansion Grants underestimates the burden
				already imposed on registered sponsors and could negate the
				significant gains seen in recent years per that public
				investment.  
				 
				 
				 
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				For comments pertaining to data collection, please see response
				from DOL’s Office of Apprenticeship in the document below.
				The comments pertaining to WIPS are outside of the scope of the
				ICR and will be addressed through technical assistance. 
				 
				 
 
				 
				 
 
				 
 
				 
				 
				 
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