Dear Conferee:

          As you prepare for the upcoming conference on amendments to the Workforce Investment Act (WIA), the State Directors of Adult Education would like to share with you our views on the reauthorization.

          We have attached a side by side which includes our position on Title II, the Adult Education and Family Literacy Act, as well as a number of key Title I issues.

          In preparation of this document, we reviewed the House and Senate provisions and chose the position we believe will improve adult education services and enable providers to better address adult learning needs in the nation. 

          There are a number of issues we believe are crucial to the long-term health of adult education programs and the success of adult learners.  These items are critical to our support of the final conference agreement.

CRITICAL ISSUES:

1. State Management of Critical Services:    Proposals for Governors to take 30 percent of state administrative funds for infrastructure support will cripple state management of adult education services, especially in small states.  The State Directors support a separate line item to support operation of one stop delivery systems OR reducing the discretionary percentage in the Senate bill to .25% to better reflect the actual use/benefit of one stops by adult education programs.

2.    State Leadership:  Restoration of the State Leadership capacity will enable states to meet performance standards, assessment standards, accountability goals and improve instructional quality.  The State Directors support the Senate position, which returns state leadership to a funding level of 15%.

3.    Increased Earnings Performance Measure:  Twenty (20) states have policy not to collect Social Security Numbers and thus cannot use UI data for this proposed measure.  These 20 states must collect pay stubs at enrollment and follow up with mail or telephone surveys and compare their performance data with the 30 states that do data match yield non-comparable data.  The State Directors support deleting this unrealistic data proposal.

4. Incentive Grants:  Uncoupling incentive grants will reward state adult education services that work hard and meet their performance standards.  Twenty-three (23) state adult education programs met or exceeded their performance standards in 2002 but were unable to benefit from the incentive grants because their Title I partners did not meet theirs The State Directors support the House position.

            In addition to the four critical items listed above, we have attached a list of additional conference items of major concern to the State Directors.  The list includes a brief description of our concern, our position on the issue, and the page of our side by side where additional information can be found.

          If you have any questions or comments regarding any of these items, please contact:

OTHER MAJOR ISSUES

In addition to the four critical issues listed in the accompanying letter, the following are the other major issues for the state directors of adult education:

1. Eligible Provider (Title II) —the House bill allows for-profit entities to participate in Title II programs.  There are many instances where irresponsible for-profit entities have taken advantage of high risk populations such as those served by adult education programs.  We support the Senate position.

2. Reporting on 16-18 year olds (Title II) -- The Senate bill requires the reporting of data on the number of 16-18 year olds enrolled in adult education who have been out of school less than a year..  Push-outs from public schools are a growing burden for adult education programs.  Even so, burdening adult education with a labor intensive data collection process is not the answer.  We support the House position.

3. State Plan/WIB areas (Title II) — The Senate bill requires states to align adult education service areas with the LWIB regions.  Such realignment is contrary to the state flexibility tenet of WIA and would cause massive upheavals in the existing service systems.  We support the House position.

4. National Institute for Literacy (Title II) — The House bill severely limits NIFL’s functions and services that the field has grown to depend upon.  Adult education has no other resource for its broad-based needs.  We support the Senate provision.

5. English as a Second Language (Title I) -- The Senate bill proposes to fund English language instruction in Title I.  Title I supports training and job services—not education services.  We support the Senate provision as long as it includes a requirement that adult education services meet the instructional, reporting, and staff standards specified in Title

6. One Stop Special Rule (Title I) -- In some states the chief executive officer responsible for adult education is constitutionally separate from the Governor.  Therefore, WIA provisions that grant the Governor certain authority need a special rule in those cases.  We support the Senate’s Special Rule that accommodates those constitutional cases where in the chief executive officer will consult with the Governor on matters related to the WIA delivery system.

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Our goal is to continue to improve the quality adult education and literacy services we have strived for under the Workforce Investment Act.  We appreciate the guidance Congress has provided with the implementation of the performance indicators and we feel our learners and our practitioners have benefited from this quality focus.  Our suggestions in these documents carry on that tradition of continuing to improve our services.

The accompanying documents provide the background and details that hopefully gives you insights into the proposed provisions and helps you understand our positions on each. 

Feel free to contact Lennox L. McLendon (202.624.5250; dc2@ncsdae.org) in our Washington office in the Hall of States.  He and Lynn Selmser, our policy advisor, are available to follow up with any of these issues.

We look forward to working with you to produce reauthorized legislation that will continue to guide our program improvement.

Sincerely,

Israel Mendoza, Chair