30D 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 30-Day Notice

Comment
Several commenters recommended that the types of gains that apply to the Measurable Skill
Gains indicator be expanded for participants enrolled in workplace literacy programs and
workforce preparation activities. Numerous commenters expressed a need to measure digital
literacy or computer skills in the National Reporting System (NRS) for adult education.
Discussion
We agree with the recommendation to expand the types of gains that can be used to document a
measurable skill gain for participants that are enrolled in workplace adult education and literacy
activities. Section 202 of the Workforce Innovation and Opportunity Act (WIOA) defines
workplace adult education and literacy activities as “adult education and literacy activities
offered by an eligible provider in collaboration with an employer or employee organization at a
workplace or an off-site location that is designed to improve the productivity of the workforce.”
We recognize that some workplace adult education and literacy programs have barriers to
demonstrating progress towards skill gains using educational functioning level gains or high
school completion, the two types of gain under the Measurable Skill Gains indicator that are
currently available to AEFLA funded programs. For individuals enrolled in workplace adult
education and literacy programs, an appropriate way to document progress may include a
satisfactory or better progress report towards established milestones from an employer who is
providing training. Another appropriate way to document progress may be successful passage of
an occupational exam that is required for a particular occupation, or progress in attaining
technical or occupational skills as evidenced by trade related benchmarks, such as knowledgebased exams. These two types of gain are included in the definition of the Measurable Skill Gain
indicator in the joint WIOA information collection approved by the Office of Management and
Budget (OMB) on June 30, 2016, under OMB No. 1205-0526.
We do not agree that workforce preparation activities can be appropriately documented using the
same documentation methods as workplace adult education and literacy activities discussed
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above. Workforce preparation activities are defined as “activities, programs, or services
designed to help an individual acquire a combination of basic academic skills, critical thinking
skills, digital literacy skills, and self-management skills, including competencies in utilizing
resources, using information, working with others, understanding systems, and obtaining skills
necessary for successful transition into and completion of postsecondary education or training,
or employment.” Workforce preparation activities are implemented widely across other adult
education and literacy activities and are not used exclusively in workplace education programs.
While we agree that some workforce preparation activities, such as digital literacy, merit further
consideration in WIOA performance reporting, other workforce preparation skills, such as
critical thinking skills, are embedded in NRS assessments. We will further consider how the
current Measurable Skill Gain definition may be used to measure workforce preparation
competencies, particularly digital literacy, through a wider consultative process.
Change
We have revised columns G and N on Table 4 to include participants in workplace adult
education and literacy programs. We have also made congruent revisions to the instructions for
Table 4 and the columns G and N on Table 4c.
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.
Discussion
As noted in our previous response, we have made the additional change on Table 4 to allow the
reporting of all MSG types for participants enrolled in a workplace adult education and literacy
program. Except for participants enrolled IET programs or workplace adult education and
literacy programs, as explained in our response to public comments published in the Federal
Register on November 19, 2020, we do not agree that all MSG types are applicable to adult
education participants who are not enrolled in such programs. We believe that educational
outcomes are those that are consistent with the fundamental purposes of the program.
Change
No change.
Comment
One commenter suggested expanding MSG types to include the reporting of one or more high
school equivalency (HSE) subtests, the reporting of high school course completion toward a high
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school diploma, or counting participants who obtained U.S. citizenship as an outcome under the
MSG indicator. The commenter also requested that all participants, who completed a secondary
school diploma or its equivalent during the program year, be reported as an MSG outcome.
Another commenter acknowledged that while states may report all HSEs on the MSG table of
the Statewide Performance Report, the MSG table was not sufficient due to calculations not
being standardized across states. The commenter expressed a concern that the reporting of all
HSEs is not part of the NRS reporting tables.
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 Educational Functioning
Level (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.” Attaining one or more subtests leading to a secondary school diploma or its
recognized equivalent, completing high school courses, or obtaining U.S. citizenship is not one
of the three ways that EFL gain may be documented. These methods are also inconsistent with
the five types of MSG defined in the joint regulations at 34 C.F.R. § 463.155(a)(1)(v). Changing
the definition of MSG or EFL gain is not within the purview of this information collection.
Thus, the commenter’s proposal would not be compliant with the joint rule or joint information
collection that applies to performance reporting for all core programs, including AEFLA.
States may report all participants who attain a secondary school diploma 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 diploma or its recognized equivalent, regardless whether their secondary
school diploma was the most recent gain and without the reporting limitations of the
postsecondary and employment criteria associated with the Credential Attainment indicator. We
believe creating an additional NRS table to collect the same data would unnecessarily duplicate
burden, since data on the attainment of secondary school diplomas are already collected on the
Measurable Skills Gain table which is incorporated into the NRS performance accountability
framework. We are actively providing technical assistance to states to improve the data reported
on the MSG table.

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Change
No change.
Comment
Several commenters provided recommendations related to reporting distance learners. Several
commenters advocated for developing an updated definition of distance learning that would be
used by all states for NRS reporting purposes. Some commenters expressed concern about the
limitations of the current tables due to differences in state reporting policies. They
recommended that the tables be updated to improve the meaningfulness of the data or be
removed. Commentors requested a national conversation to rethink distance education policy.
Discussion
We agree that state variations in counting students as distance learners on tables 4C and 5A do
result in limitations on how the data can be used. Nonetheless, we believe that distance learning
is a significant delivery system for adult education students for which federal reporting provides
important visibility. We are interested in how the current reporting structure could be revised to
provide more meaningful data and are committed to expanding stakeholder consultation on the
topics raised by public comment received through this information collection.
Change
No change.
Comment
Two commenters suggested removing the “exit” requirement from counting an EFL gain for
participants who exit the program and enroll in postsecondary education or training during the
program year. One commenter contended that a student should not have to be exited from adult
education in order to be counted as an outcome for transition to workforce training. Another
commenter stated that the Measurable Skill Gains indicator is used to measure interim progress
of participants who are enrolled in education or training services for a specified reporting period
and is, therefore, not an exit-based measure. The commenter requested that OCTAE fix the error
in interpretation of the MSG for transition to postsecondary as an exit-based measure.
One commenter stated that the NRS levels do not always meaningfully reflect actual educational
growth and achievement. The commenter suggested providing alternative methods to measure
student performance that would allow programs to have greater flexibility to work with their
students in meaningful ways. Another commenter asked that OCTAE sponsor a working group
to develop recommendations for a multiple measures EFL gain strategy in exchange for OCTAE
encouraging a two-year paired standardized testing optional environment.
Discussion
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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.
Change
No change.
Non-Substantive Comments
Comment
Several commenters made recommendations related to methods for measuring prior education
accomplishment, especially for English language learners and expanding demographic data to
reflect populations served in the adult education program. Another commenter suggested
developing approaches to recognizing transitions from spring to fall, even though adult education
programs operate within a July to June reporting period. One commenter recommended
eliminating testing altogether and allowing students to earn gains in other ways. The commenter
contended that standardized testing is antiquated and does not show the growth of a student
accurately. Another commenter endorsed documenting skills that make students more
employable rather than relying on academic standards which, the commenter asserted, often do
not translate well.
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.

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