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WIA Strategic Planning: Questions and Answers, Employment & Training Administration (ETA) - U.S. Department of Labor

The Department of Labor's (DOL) Employment and Training Administration (ETA) continues to receive a number of questions from states currently engaged in the strategic planning process set forth in Training and Employment Guidance Letter (TEGL) 13-06. The agency posts these questions and its responses for the benefit of all states.

Please note, however, that this information is provided as a public service by the Department. It represents the Department's best effort to provide useful information in a timely manner. ETA will periodically update this material, as necessary, to address issues related to the strategic planning process. These questions and answers do not represent official agency policy. If you have any questions regarding the application of a question or answer to your particular circumstances, please contact your ETA Regional Office.

As of May 17, 2007, our responses address:
  • Peformance Negotiations;
  • Unified Planning;
  • Plan Alignment with National Objectives;
  • Plan Format;
  • Public Comment Period.

Performance Negotiations

Question 1
States with newly-elected governors (listed in Section 5 of TEGL 13-06, Change 1) have been provided the option of submitting their proposed modification to their State Strategic Plan by June 30, 2007. For states that choose this option, when should performance negotiations for Program Year (PY) 2007 and PY 2008 be negotiated?


Answer 1
The State and Regional Administrator must negotiate goals for PY 2007 by 6/30/07, and negotiate goals for PY 2008 by 9/28/07. If a state finds that the PY 2007 negotiated goals are significantly different from actual results due to changes in economic or other unanticipated circumstances, the state does have the ability to request renegotiation.

Unified Planning

Question 1
Our State will submit a modification for its 2007 Unified Plan requirement using the April 12, 2005 guidance. Can you advise what official title we should use when referring to this year's Unified Plan?


Answer 1
If we are consistent with the approach of 2005, ETA will refer to the state's Plan in its response (approval/disapproval letter) to the state as follows: "the (State name) Unified Strategic State Plan for the two-year period, July 1, 2007 through June 30, 2009." However, the state can develop a more descriptive like: "(State Name) Unified Strategic State Plan for Program Years 2007 and 2008 (July 1, 2007 through June 30, 2009) which are the third and fourth years of the five-year planning cycle beginning July 1, 2005, and ending June 30, 2010."

Question 2
Our past plan provided complete responses to each question, which required the duplication of similar if not identical text in various areas of the Unified Plan. This year, our state is considering including references to stated text instead of repeating text in various sections. Will this approach meet the Department's needs?


Answer 2
TEGL 13-06 (page 3) provides ETA's recommendation on this issue:

To facilitate public review and comment, as well as DOL review of the modified plans, ETA recommends that states integrate the proposed modifications into existing plans and develop a fully revised Strategic Plan following the format provided in either the stand-alone planning guidance issued on April 12, 2005, or unified planning guidance, also issued on April 12, 2005, and attach a list to identify modified portions of the plan. Providing an opportunity for meaningful public input and comment during the development of the State Plan is a critical part of the strategic planning process.

We encourage you to examine the questions carefully. While they may relate to the same subject, generally, they were framed for different purposes; it may not always be appropriate to simply respond with the same text from a prior question. There is no prohibition against referring to prior text as the response, but you are also encouraged to consider making review of the document easy for the public as well as for ETA.

Question 3
Our state may request a waiver to have this year's Unified Plan extended an additional year, for year five of the planning cycle, through June 30, 2010. Do you know of any other states that have or plan to request a similar waiver?


Answer 3
No states have thus far, and as far as we know, no other states are planning to submit such a waiver request. ETA encourages you to consider waiting to request such a waiver until later in the planning cycle when we will have some idea about WIA reauthorization from Congress.

Question 4
Do we need to adjust the time frames in questions or just reflect the most recent time frames in our responses? (Most likely TEGL 13-06's Change 1 will answer the question below, but we would be grateful if you could provide an answer earlier.)


Answer 4
There is no need to revise the questions' contents in the Planning Guidances, regardless of which Planning Guidance the state will use. Using your best judgment, please substitute current time frames in your response.

Question 5
Where can we find Department of Education guidance on State planning under Perkins?

Answer 5
The Department of Education’s Office of Vocational and Adult Education has issued its final Perkins IV State Plan Guide. The Guide can be found at
www.ed.gov/about/offices/list/ovae/pi/memoperkinsiv.html.


Plan Alignment with National Objectives

Question 1
The Strategic Plan Writing Team for our state will review existing verbiage in the current plan. They will modify this verbiage to reflect the current state vision, mission, and status on national objectives. In reviewing the requested information, we were trying to align the new directions with existing questions; however, they do not clearly align.


Answer 1
We do not see this as an insurmountable problem. Many of the action items in the existing Planning Guidances address issues identified in the new National Strategic Direction. As indicated in TEGL 13-06, the new National Strategic Direction "provides a frame of reference for the development of the modification to the State Plan for years three and four of the five-year planning cycle."

The above notwithstanding, ETA recognizes that states will exercise flexibility in interpreting the applicability of some action items in the Planning Guidances. There are some action items to which ETA no longer expects responses. The following two examples are from the Stand-Alone Planning Guidance:

IX.G.2. If your State is participating in the ETA Personal Re-employment Account (PRA) demonstration, describe your vision for integrating PRAs as a service delivery alternative as part of the State's overall strategy for workforce investment.

X.D.7. What steps has the State taken to prepare for implementation of new reporting requirements against the common performance measures as described in Training and Employment Guidance Letter (TEGL), 15-03, December 10, 2003, Common Measures Policy?

There are other action items in the Planning Guidances that require flexibility in responding. For example, in V.B. (of "Overarching State Strategies'), the action item asked, "What strategies are in place to address the National Strategic Direction discussed in Part I of the guidance.". In this case, ETA expects the state to focus on the new National Strategic Direction as described in TEGL 13-06.

Similar challenges may exist with other items in both the Stand-Alone and Unified Planning Guidances. With regard to such items, the state can submit a specific inquiry to ETA for additional guidance. Otherwise, ETA expects states to use their best judgment to develop meaningful responses that comply with the intent of the Planning Guidances and TEGL 13-06.


Plan Format

Question 1
Does the ETA National Office want the state to blend the responses into the existing document or do we add the new responses to the end of the document as an addendum?


Answer 1
TEGL 13-06 (page 3) provides ETA's recommendation on this issue:

To facilitate public review and comment, as well as DOL review of the modified plans, ETA recommends that states integrate the proposed modifications into existing plans and develop a fully revised Strategic Plan following the format provided in either the stand-alone planning guidance issued on April 12, 2005, or unified planning guidance, also issued on April 12, 2005, and attach a list to identify modified portions of the plan. Providing an opportunity for meaningful public input and comment during the development of the State Plan is a critical part of the strategic planning process.

In summary, the state should revise the existing Plan rather than add new responses to the end of the document as an addendum.


Public Comment Period

Question 1
Our state wants to know if it can simultaneously submit the WIA modification for public comment and review by ETA.


Answer 1
WIA regulations at 20 CFR 661.220 (d) provide the following:

The State must provide an opportunity for public comment on and input into the development of the State Plan prior to its submission.

To comply with the requirements of WIA, the state must provide an opportunity for public comment prior to submission to ETA for review and approval. Accordingly, the state cannot submit a modification for public comment at the same time it submits the modification to ETA for review and approval.

Question 2
Our state wants to shorten the comment period because of the ETA deadline for submitting this major modification. We do not have a minimum public comment period in our statute; we would like to provide for only a fifteen day comment period. We had a thirty day comment period for the last major WIA modification. Is this a problem?


Answer 2
In addition to requiring that the state provide an opportunity for public comment on and input into the development of the State Plan prior to its submission, 20 CFR 661.220 provides the following related to ensuring adequate public comment and input:

The opportunity for public comment must include an opportunity for comment by representatives of business, representatives of labor organizations, and chief elected official(s) and must be consistent with the requirement, at WIA section 111(g), that the State Board makes information regarding the State Plan and other State Board activities available to the public through regular open meetings. The State Plan must describe the State's process and timeline for ensuring a meaningful opportunity for public comment [emphasis added].

Neither the statute nor the regulations specify a number of days to provide opportunity for public comment and input. However, the regulations do provide requirements, as described above, which must be met. The state must ensure that its proposed timeframe for public comment and input enables the state to meet these requirements. A timeframe less than thirty days may be sufficient.