60D Comment Response

National Reporting System (NRS) for Adult Education
Information Collection Request
OMB Control Number NRS 1830-0027
Responses to Public Comments Received During the 60-Day Notice

Comment
Several commenters questioned why certain types of Measurable Skill Gain (MSG) were only
applicable to Integrated Education and Training (IET) participants and not available for all
participants. They suggested allowing all types of MSG for all adult education participants and
expanding the reporting on MSG outcomes to other types of programs beyond IET for the
purpose of transition to postsecondary education or training or career advancement. One
commenter suggested revising Table 4, Column G and a similar edit to Column N to read:
“Number of participants in postsecondary education or training transition or employment
activities who achieved an MSG other than an educational functioning level (EFL) gain and
secondary school diploma.” Another commenter recommended expanding the reporting
parameters on Table 4 to allow adult education providers to report not only IET activities using
all MSG indicator types but also programming common for internationally trained professionals
including workplace literacy, Integrated English Literacy and Civics Education, and workforce
preparation activities. Several commenters suggested the use of digital literacy assessments as a
means for allowing the achievement of MSG type 5 (successful passage of an exam) for all adult
education participants.
Discussion
The Departments described an approach to implementing the Measurable Skill Gain indicator of
performance in the preamble of the joint WIOA Notice of Proposed Rulemaking (April 16, 2015,
80 FR 20574) as including a variety of types of gain intended “to capture important progressions
through pathways that offer different services based on program purposes and participant needs
and can help fulfill the Departments’ vision of creating a workforce system that serves a diverse
set of individuals with a range of services tailored to individual needs and goals…[f]or lowskilled adults, this proposed indicator provides an opportunity to track progress in reading,
writing, mathematics, and English proficiency while they are participating in an adult education
program prior to completing the high school credential and entering post-secondary education or
training or employment.” Public comment supported this approach.
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The Departments received comments in the proposed joint performance information collection
related to types of gain that would apply to the adult education program. The Departments
responded that they would issue program guidelines to identify the types of gain appropriate for
each core program. On August 23, 2017, OCTAE issued Program Memorandum 17-2
Performance Accountability Guidance for Workforce Innovation and Opportunity Act Title I,
Title II, Title III and Title IV Core Programs. The guidance states that the decision to use types
of gain only for services which the adult education program is authorized to provide is intended
to keep accountability focused on the educational measures and activities authorized in statute,
acknowledging basic skills are the foundation to success in other workforce services.
OCTAE identified achievement of at least one EFL and documented attainment of a secondary
school diploma or its recognized equivalent as appropriate types of gain for use under the
Measurable Skill Gain indicator based on the adult education and literacy services authorized
under the Adult Education and Family Literacy Act (AEFLA). However, we recognize that
achieving an MSG via a Secondary or Postsecondary Transcript, Progress Toward Milestones, or
Passing Technical/Occupational Skills Exam, listed as the third, fourth, and fifth types of gain in
the joint WIOA final rule at 34 C.F.R. § 463.155(a)(1)(v)(C)(D)(E), is appropriate for adult
education participants in the context of an IET program authorized under AEFLA. States have
reported these types of gain on Table 11 in this information collection for participants enrolled in
IET programs. We used the data reported by States to determine that this type of gain should be
identified for performance accountability in the proposed revisions to the columns on Table 4.
OCTAE believes that the types of gain listed as the third, fourth, and fifth types of gain in the
joint WIOA final rule at 34 C.F.R. § 463.155(a)(1)(v)(C)(D)(E) are not appropriate types of gain
to use for adult education participants who are receiving educational services below the
postsecondary level and are not enrolled in an IET program.
The third type of gain described in 34 C.F.R. § 463.155(a)(1)(v)(C), a secondary or
postsecondary transcript or report card for a sufficient number of credit hours that shows a
participant is meeting the State unit’s academic standards, is not a type of gain appropriate to use
for measuring accountability of programs serving adult education participants who are not
enrolled in an IET program for two reasons. First, with respect to a secondary transcript, an
individual enrolled in secondary school under State law is not an eligible individual under
AEFLA; thus, individuals participating in AEFLA are not enrolled in secondary school and not
positioned to receive secondary transcripts. The Departments expanded the definition of EFL
gain to include the awarding of credits or Carnegie units in order to provide an appropriate
measure for adults enrolled in credit-based adult education. Second, with respect to a
postsecondary transcript, adult education is defined in WIOA as “academic instruction and
education services below the postsecondary level” (see section 203(1) of WIOA), which means
that AEFLA participants, who are not enrolled in an IET program, are not positioned to earn
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postsecondary credit hours. A postsecondary transcript is therefore an inappropriate
accountability measure for those participants. A State, however, may register a gain under an
EFL if a participant exits the AEFLA program and enters postsecondary education. We believe
the expansion of the EFL definition to add credit completion and entrance into postsecondary
education provides appropriate ways to measure the success of adult education participants who
are not enrolled in an IET program.
The fourth type of gain described in 34 C.F.R. § 463.155(a)(1)(v)(D), a satisfactory or better
progress report towards established milestones from an employer or training provider who is
providing training, is not an appropriate type of gain to use to determine MSG for adult
education participants who are not enrolled in an IET program. Programs and services
authorized in title II of the statute, which are not delivered in the context of an IET program, do
not include “placing” a participant with an employer or training provider, as do other core WIOA
programs. For example, the vocational rehabilitation (VR) program may pay for the placement
of a participant in a training program and appropriately measure success of the VR program on
this type of gain. With the exception of IET programs authorized under AEFLA, adult education
providers deliver educational services below the postsecondary level through direct service
rather than via “placement” with a training provider or an employer.
The fifth type of gain described in 34 C.F.R. § 463.155(a)(1)(v)(E), successful passage of an
exam that is required for a particular occupation or progress in attaining technical or
occupational skills as evidenced by trade-related benchmarks such as knowledge-based exams, is
not an appropriate type of gain to use to determine MSG for adult education participants who are
not enrolled in an IET program. Programs and services authorized under AEFLA, which are not
delivered in the context of an IET program, do not include the administration of such exams to
measure the attainment of technical or occupational skills, as do other core WIOA programs.
Except for IET programs authorized under AEFLA, adult education providers deliver
educational services that are not designed to provide the technical or occupational training
required for a particular occupation or to prepare participants to pass the content of technical or
occupational skills exams.
Change
No change.
Comment
While there was support for the proposed new columns on Table 4 for participants enrolled in
IET programs, several commenters questioned whether the proposed changes should be effective
for program year 2020 data reported on October 1, 2021. They emphasized that States would
need time for training, updates to data collection systems, and consideration of parallel changes
needed on other tables. They suggested delaying the implementation of the proposed changes to
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Table 4 to allow for these activities. One commenter added that the proposed changes would
require time to secure data-sharing agreements.
Discussion
We agree with the commenters that some States may not be able to use the new columns on
Table 4 for IET participants, when performance data for program year 2020 are reported on
October 1, 2021. However, their use is not required. If a State does not yet have the data to
report in those columns, they may leave them blank. As States expand their IET programs and
collect the outcome data associated with those participants under the MSG indicator, we
anticipate that the use of the new columns on Table 4 will increase. Additionally, many States
have been collecting these data to report MSG outcomes for IET participants on Table 11. We
do not believe it would be reasonable to delay the opportunity for those States to report the data
they have already collected. However, we will include language in the supporting statement that
States are not required to use the new columns in 2021, if they do not yet have the data to report
in those columns.
Change
No change.
Comment
One commenter questioned whether it was necessary to break out IET participants on Table 4,
when all types of MSGs for IET participants are already counted on Table 11.
Discussion
Table 11 is designed to allow multiple MSGs outcomes to be reported for each period of
participation but is not used to calculate performance. Table 4 requires only the most recent
MSG outcome to be reported and is used to calculate performance outcomes consistent with the
requirements of the joint information collection.
Change
No change.
Comment
One commenter suggested adding a note to Table 4 that would define the applicable AEFLA
activities for reporting. The commenter proposed the following language: “Activities for the
purpose of postsecondary education or training transition or employment mean integrated
education and training, workforce preparation activities and workplace adult education and
literacy activities.”

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Discussion
Section 203(2) of WIOA defines adult education and literacy activities as “programs, activities,
and services that include adult education, literacy, workplace adult education and literacy
activities, family literacy activities, English language acquisition activities, integrated English
literacy and civics education, workforce preparation activities, or integrated education and
training.” The definition suggested by the commenter is not consistent with the definition in the
statute. Because Table 4 and its instructions do not reference the term “AEFLA activities,” we
do not believe it is necessary to define it as a footnote to the table.
Change
No change.
Comment
One commenter suggested adding a column to Table 4 labeled: “Number who attained one or
more subtests leading to a secondary school diploma or its recognized equivalent.”
Discussion
The purpose of Table 4 is to report the different types of MSGs that count toward State
performance. Attaining one or more subtests leading to a secondary school diploma or its
recognized equivalent is not one of the five types of MSG defined in the joint regulations at 34
C.F.R. § 463.155(a)(1)(v). Thus, the commenter’s proposed addition of a new column on Table
4 to collect such as measure would not be compliant with the joint rule or consistent with the
purpose of Table 4.
Change
No change.
Comment
Several commenters proposed adding a new row on Table 4 for participants who did not receive
an NRS approved pre-test and thus could not be assigned to an appropriate EFL.
Discussion
34 C.F.R. § 462.42(a) requires that a local eligible provider use the results of the pre-test
described in 34 C.F.R. § 462.41(b) to initially place students at the appropriate NRS educational
functioning level. However, during the COVID-19 pandemic and consistent with the flexibilities
provided in OCTAE program memorandum 20-5 Adult Education and Family Literacy Act and
COVID-19 – Frequently Asked Questions, Part 3, a local program may use other assessment

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methods to provisionally assign an EFL for the purpose of placing students into the NRS when
an approved NRS pre-test cannot be administered.
Change
No change.
Comment
Several commenters suggested removing the “exit” requirement from the instructions in Table 4
which applies to counting an EFL gain for participants who exit the program and enroll in
postsecondary education or training during the program year. They proposed replacing the
instruction with the following language: “States may report an EFL gain for participants who
transition from adult education and literacy activities and enroll in credit or transcript-bearing
postsecondary education or training during the program year.” Similarly, other commenters
proposed adding a new MSG 1(d) measure: “States may report an educational functioning level
gain for participants who transition from a program below the postsecondary level and dually
enroll in a program below postsecondary level and a postsecondary education and training during
the program year.” Another commenter stated that requiring participants to exit in MSG 1c can
exclude participants from earning the measure in the fourth quarter because the measure needs to
be achieved by June 30.
Discussion
The Joint Participant Individual Record Layout (ETA-9170), which is part of the joint
information collection Workforce Innovation and Opportunity Act (WIOA) Common
Performance Reporting under OMB Control No. 1205-0526, defines EFL gain as follows: “EFL
gain may be documented in one of three ways: 1) by comparing a participant’s initial EFL as
measured by a pre-test with the participant’s EFL as measured by a participant’s post-test; or 2)
for States that offer secondary school programs that lead to a secondary school diploma or its
recognized equivalent, an EFL gain may be measured through the awarding of credits or
Carnegie units: or 3) States may report an EFL gain for participants who exit the program and
enroll in postsecondary education or training during the program year.” Changing the definition
of EFL gain is not within the purview of this information collection. Regarding the comment
about exiting during the fourth quarter, participants may achieve an EFL gain even if they exit
the program and enroll in postsecondary education or training on the same day, such as June 30.
Change
No change.
Comment

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Two commenters proposed replacing the EFL levels on Table 4 with participant age categories
as in Table 2. They also recommended deleting Table 1 and only collecting participant sex, age,
and ethnicity/race on Table 2.
Discussion
The purpose of Table 4 is to report the different types of MSGs that count toward State
performance, including EFL gain. The EFL levels in Table 4 are required for this purpose.
MSG performance, including EFL gain, is disaggregated by age on the Statewide Performance
Report (ETA-9169) in the joint information collection Workforce Innovation and Opportunity
Act (WIOA) Common Performance Reporting under OMB Control No. 1205-0526.
Change
No change.
Comment
One commenter suggested expanding Table 4 to account for gains in workplace literacy,
workforce preparation, and digital literacy.
Discussion
Workplace adult education and literacy, as defined in AEFLA section 202 (16) is defined as
adult education and literacy activities offered in collaboration with an employer or employer
organization. As such, the services received in workplace programs must include instruction to
read, write, and speak English, compute and solve problems, the same skills measured in Table
4. Workplace preparation skills and digital literacy are currently encompassed in the NRS
descriptors. Participants in these programs who achieve a gain are included on Table 4. In
addition, the new Table 4 columns we have proposed for reporting other MSGs for IET
participants are intended to collect outcome data for programs that provide adult education
services concurrently and contextually with workforce preparation activities and workforce
training. We believe that creating additional columns to collect data for the same outcomes
would create an unnecessary reporting burden to States and local programs.
Change
No change.
Comment
One commenter felt that the instructions for calculating and tracking MSG 1c in Table 4,
“participants who exit a program below the postsecondary level and enroll in postsecondary
education and training during the program year” is complicated and confusing.

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Discussion
The language for the instruction in Table is based on language in the Joint Participant Individual
Record Layout (ETA-9170), which is part of the joint information collection Workforce
Innovation and Opportunity Act (WIOA) Common Performance Reporting under OMB Control
No. 1205-0526. Changing the language is not within the purview of this information collection.
However, we will review our technical assistance and consider developing materials to help
clarify the instruction.
Change
No change.
Comment
One commenter stated that internationally trained professionals often participate in English as a
second language (ESL) to build the English literacy needed to enter college or university classes
and recalibrate their professional training from their home county to meet U.S. credential and
employment requirements. The commenter indicated that their needs were more focused on
passing English proficiency tests needed to enter postsecondary education or training programs.
The commenter reasoned that, because these participants already have advanced degrees, it
would be rare for them to need or desire IET or Integrated English Literacy and Civics Education
(IELCE) programs. The commenter asserted that IET and IELCE programs are designed for
participants with little or no technical skills. The commenter proposed revising Table 4 to add a
new row in column A labeled “Other Assessment,” or another label, and using the new row to
report internationally trained professionals without pre-testing them with an NRS-approved test
or assigning them to an EFL.
Discussion
We agree with the commenter that participants with advanced degrees from their home countries
often seek adult education and literacy services to improve their English language skills to enter
postsecondary education or to meet U.S. credentialing and employment requirements. Section
203(2) of WIOA includes English language acquisition as one of the activities authorized under
title II of the statute. We believe that English language acquisition programs are well suited for
internationally trained professionals with limited English language proficiency, as such programs
are required by 34 C.F.R. § Part 463.32 to offer educational and career counseling services to
assist participants in their transition to postsecondary education or employment. All adult
education participants, including those enrolled in an IET program, must receive a level of
educational services appropriate for their EFL. We do not agree that internationally trained
professionals with limited English language proficiency should be excluded from assessing their
level of English language skills with an NRS approved pre-test and an appropriate pairing of
English language acquisition services that are commensurate with their educational needs.
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Change
No change.
Comment
Two commenters proposed updating Table 4c to include the full complement of WIOA MSG
types and WIOA exit based measures mapped to participant demographics and individuals with
barriers to employment characteristics, and collect the proportion of distance education that
participants experience (e.g. 0-25%; 26-50%; 51-75%; 75-99%; 100%).
Discussion
We agree with the commenters that Table 4c should be modified to include all of the MSG types
collected on Table 4. We believe that using the same columns on both tables would accomplish
this objective. States determine which participants are reported on Table 4c in accordance with
the distance education business rules established by the State. We do not believe that the
proportion of distance education services that participants receive should be defined at the
federal level. Data for exit based primary indicators of performance are collected on Table 5a.
As such, we do not believe that these data should be included on Table 4c.
Change
We have revised Table 4c to include the same columns as Table 4.
Comment
Two commenters recommended modifying Table 4b to include a column for pre-tested students,
so that the table would be used to report pre-test EFL level data on Table 4b only for participants
who will be measured by pre-test/post-test.
Discussion
The instructions for Table 4b indicate that participants should only be reported in this table if
they have received a pretest and posttest. However, we believe a specific instruction for column
B could be added clarifying that only participants who have received a pretest and posttest
should be reported in that column.
Change
We have revised Table 4b to include an instruction about column B.
Comment
One commenter proposed either eliminating tables 4c and 5a related to distance education or
retaining the tables and counting all adult education students in distance education regardless of
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number of hours or percentage of time spent. The commenter contended that the data captured
in the distance education breakouts on tables 4c and 5a are no longer meaningful, since the
definition of distance education students is determined by individual States. Another commenter
recommended eliminating State definitions of distance education students and replacing Tables
4c and 5a with a single distance education outcomes table that evaluates participant outcomes
through WIOA indicators by the percentage of adult education instructional hours in distance
education (e.g. 0%, 1-49%, 50-75%, and 76-100%). One commenter proposed redesigning
Table 4c as a reporting vehicle for digital literacy, while three commenters advocated for
eliminating Table 4c altogether.
Discussion
As a result of the COVID-19 pandemic, many adult education programs have implemented
enhancements to their delivery system and added an array of distance education options and
formats to support continued educational services for participants. The design and delivery of
distance education services vary by State and by local programs within each State. In addition,
the challenges that States face in providing distance education and tracking the percentage of
hours associated with various formats are also diverse. In many States, distance education may
be delivered through a hybrid model with varying degrees of time spent in the classroom and in a
remote learning environment. We believe that imposing a national definition for distance
education on all States and a uniform requirement that each State track distance education hours
in the same way would be inconsistent with the unique needs of each State and would create
significant burden to local programs. Moreover, we believe that there is an especially critical
and timely need to evaluate the effectiveness of programs serving an increasing number of
distance education participants. We do not believe the distance education tables should be
eliminated or that their purpose should be modified. They serve a key role to guide efforts for
program management and improvement, both now and in the years to come.
Change
No change.
Comment
One commenter emphasized the need to collect data on the number of secondary school
diplomas or their recognized equivalent that participants earned, without restricting the reporting
only to those diplomas that were achieved according to the criteria articulated under the
credential attainment indicator. The commenter suggested adding a row to Table 5 labeled:
“Total Attained a Secondary School Diploma/Recognized Equivalent during Program Year and
corresponding note that this is the total count before applying credential attainment indicator
factors within one year of exit.” Another commenter stated that reporting all secondary school
diplomas or their recognized equivalent that are awarded to AEFLA participants is the metric
that is by far the most requested data element by various funders, stakeholders, and partners.
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The commenter expressed concern about not having an official and complete count of these
important credentials.
Discussion
We agree with the commenters that there is a clear and standing need to collect and report data
on the number of participants who earn a secondary school diploma or its recognized equivalent.
We frequently receive requests for this data. States may report all participants who attain a
secondary school credential or its recognized equivalent on the joint Measurable Skill Gains
table which is part of the Statewide Performance Report (ETA-9169) in the joint information
collection Workforce Innovation and Opportunity Act (WIOA) Common Performance Reporting
under OMB Control No. 1205-0526. The purpose of the joint Measurable Skill Gains table is to
collect data for all participants who attain a secondary school credential or its recognized
equivalent, regardless whether their secondary school credential was the most recent gain and
without the reporting limitations of the postsecondary and employment criteria associated with
the credential attainment indicator.
Change
No change.
Comment
One commenter stated that the EFL measure at entry creates a participant eligibility requirement
that is not in the statute.
Discussion
The definition of eligibility in section 203(4) of WIOA applies to all participants receiving
services under title II. To be eligible for services, an individual must have attained 16 years of
age, not be enrolled, or required to be enrolled in secondary school under State law, and must be
one of the following:
1. basic skills deficient;
2. not have a secondary school diploma or its recognized equivalent, and has not
achieved an equivalent level of education; or
3. an English language learner.
The assignment of an EFL is not a requirement for program eligibility. Although many
programs do use a pretest to determine eligibility, individuals who meet the eligibility
requirements of section 203(4) of WIOA may be enrolled in an adult education program without
a pretest. If a pretest is not used, programs must determine that a student is an eligible individual
for the adult education program by other means identified by the State or the local program.

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States may establish their own guidance or procedures to determine program eligibility without a
pretest.
Change
No change.
Comment
One commenter suggested adding a category for distance education that does not require any
face-to-face contact and a waiver from the standardized pre- and post-testing.
Discussion
Like all participants, participants in distance education must have at least 12 hours of contact
with the program before they can achieve participant status for Federal reporting purposes. The
initial 12 contact hours for distance learners can be any combination of in-person contact and
contact through telephone, video, teleconference, or online communication, where participant
and program staff can interact and through which participant identity is verifiable. §462.42(a)
requires that a local eligible provider use the results of the pre-test described in §462.41(b) to
initially place students at the appropriate NRS educational functioning level. However, during
the COVID-19 pandemic and consistent with the flexibilities provided in OCTAE program
memorandum 20-5 Adult Education and Family Literacy Act and COVID-19 – Frequently Asked
Questions, Part 3, a local program may use other assessment methods to provisionally assign an
EFL for the purpose of placing students into the NRS when an approved NRS pre-test cannot be
administered
Change
No change.
Comment
Two commenters proposed expanding the sex and race/ethnicity categories for self-reporting.
Discussion
We acknowledge that States and local programs have implemented new policies for the
collection of participant demographic data. Additionally, we understand the reasoning behind
the proposal to align the federal data collection process with State and local changes. However,
the participant demographic categories for sex and race/ethnicity in this information collection
must align with those in the joint Statewide Performance Report Template (ETA-9169) which is
part of the joint information collection Workforce Innovation and Opportunity Act (WIOA)
Common Performance Reporting under OMB Control No. 1205-0526.

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Change
No change.
Comment
Several commenters expressed their support, raised clarifying questions, or had concerns about
the proposed new Table 99. Commenters who were concerned with the new table suggested that
it could be duplicative, questioned whether performance rates could be automatically calculated,
and suggested that the denominators could be derived from the data already collected.
Commenters who supported the new table stated that it would ensure more accurate reporting on
the Statewide Performance Report and that the burden to implement the new table would be
negligible. One commenter asked whether the automatically calculated statewide performance
rate, using the numerators and denominators on Table 99, would be the same rate that is
calculated for all levels on Table 4. The commenter also requested clarification about the
relationship between the MSG column on Table 99 and the columns on Table 4. Another
commenter asked for clarification about the purpose of the new table and its use at the federal,
State, or provider level.
Discussion
We appreciate the comments about the proposed table 99 and the opportunity to address the
clarifying questions. Table 99 would not be duplicative. Unlike our federal partner programs,
the National Reporting System (NRS) for adult education does not collect individual participant
record data and thus does not have the denominators for the disaggregated subgroups by
participant characteristics and employment barriers in order to calculate accurate performance
rates for those subgroups on the Statewide Performance Report Template (ETA-9169). To date,
we have used the performance rates and numerators reported to us for the disaggregated
subgroups to calculate inferred denominators, summed them for comparison with the statewide
numbers, and determined that the sum of all inferred disaggregated denominators frequently do
not equal the actual statewide denominators. Over the past 20 years, our experience with other
NRS tables has demonstrated that collecting the numerator and denominator consistently yields
more accurate outcome data, when our data system uses those two variables to automatically
calculate performance rates. Table 99 will result in a user-friendly approach that is aligned with
the familiar data entry procedures for other NRS tables and yield no additional burden for
respondents, as they will enter the denominators instead of the performance rates for each
subgroup under an indicator. Our data system will use the numerators and denominators on
Table 99 to automatically calculate accurate performance rates on the Statewide Performance
Report that match the performance rates calculated on Tables 4 and 5 and to validate the summed
denominators and numerators for disaggregated subgroups within the Statewide Performance
Report. In addition, our data system will validate the denominators, numerators, and
performance rates on the Statewide Performance Report with the corresponding data in the
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columns for all periods of participation on Tables 4 and 5. By using Table 99 to align our data
entry procedures in this way, we believe that the individual and national Statewide Performance
Reports in future program years will provide the public with consistently valid and reliable
performance data.
Change
No change.
Comment
One commenter suggested a lack of data collection of the education levels of students in
federally funded programs limits the ability of programs for English language learners to serve
immigrants and refugees with international credentials appropriately and adequately. The
commenter wrote that providers of English language acquisition programs often offer mixedlevel ESL classes that combine students with varying education levels.
Discussion
Data are collected at intake and reported on Table 6 to report the highest educational level
completed by all participants, including English language learners, prior to program entry. We
believe the use of a pre-test at intake helps to place students at the appropriate NRS educational
functioning level and thus into a class best suited for their educational needs.
Change
No change.
Non-Substantive Comments
Comment
Several commenters made recommendations related to the definition of attainment of a
secondary school diploma or its recognized equivalent. Other commenters disagreed with the
definition of transition to postsecondary education. Some commenters made recommendations
related to the definition of performance under MSG, such as allowing multiple MSGs for
individual students in a given reporting period to demonstrate progress over the course of
participation, making changes to the denominator for calculating EFL gains via the pre-posttest
method, or changing the timeframe for achieving an MSG. Other comments were made about
the definitions of certain terms used for joint performance accountability or raised concerns that
the some of the primary indicators of performance do not align with the adult education program.
Discussion

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The primary indicators of performance described in section 116 of WIOA apply to participants in
all core programs, including adult education participants. The criteria and definitions used for
the primary indicators of performance are articulated in the joint information collection
Workforce Innovation and Opportunity Act (WIOA) Common Performance Reporting under
OMB Control No. 1205-0526. Changing these criteria and requirements is not within the
purview of this information collection.
Change
No change.
Comment
A number of commenters provided recommendations or voiced concerns regarding assessments,
such as removing the requirement for pre-testing, allowing alternatives to testing and reporting
outcomes, eliminating the categorization of all participants by educational functioning levels,
changing the hours required for post-testing with specific assessments, and modifying
regulations that pertain to assessment administration,
Discussion
These recommendations are not within the purview of this information collection, as they fall
under the authority of the regulations at 34 C.F.R. §462 or the joint information collection
Workforce Innovation and Opportunity Act (WIOA) Common Performance Reporting under
OMB Control No. 1205-0526.
Change
No change.
Comment
Several commenters offered recommendations to collect individual student records, create
crosswalks to MSG types, assist those with no internet access, or suggested studies to determine
more effective measures for professional immigrants and refugees with international credentials.
Discussion
These recommendations are not within the purview of this information collection, as they relate
to issues and activities external to the adult education program and the NRS.
Change
No change.

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