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A growing number of states have applied for and received a waiver to move to common measures under WIA. Beginning in PY 07, more than twenty states will have implemented common measures. For the majority of states, however, the question of seeking such a waiver is still under debate. This article is an attempt to identify the pros and cons of a common measures waiver and to begin a dialogue on this issue. We do not claim to have all the answers, but in our six years of working with states and local areas on performance management, we can identify some of the issues.

What a Waiver Includes

All waiver requests are not the same. Most waivers request eliminating the adult credential rate, the dislocated worker credential rate, the two customer satisfaction measures, and all of the seven youth measures, thus replacing the current 17 measures with the following 9 measures.

WIA Common Measures

Adult Entered EmploymentAdult RetentionAdult Average EarningsDislocated Entered EmploymentDislocated RetentionDislocated Average EarningsYouth Placement in Employment/EducationYouth Attain Degree/CredentialYouth Numeracy & Literacy

No change from current measures.

Some states have further requested that the adult and dislocated measures be combined resulting in only 6 WIA measures. Combining the adult and dislocated worker measures results in a measure that is comparable to the current Wagner-Peyser measures, which do not distinguish between adults and dislocated workers. Regardless of the waiver, separate goals are negotiated for Wagner-Peyser and WIA.

The “Pros” of Moving to Common Measures

Each waiver request requires a state to explain the benefits of implementing a waiver to common measures. The following language is taken from a sampling of the complete waiver requests that can be found at http://www.doleta.gov/waivers/ with the actual requests and approvals at http://waivers.doleta.gov/lettersState.cfm

Provides for a simplified and streamlined performance measurement system.Facilitates integrated, system-wide performance accountability to ensure successful integration of our workforce development programs as we move toward common goals, and provides a mechanism to begin the process of using the common performance measures across programs.Provides cohesion across workforce development programs.Reduces paperwork and labor cost associated with data collection and analysis. Provides clear and understandable information to Congressional and legislative leaders and the general public concerning the use of public funds and the return on the investment.Provides a more useful program management tool.Provides an opportunity to better implement the Department of Labor’s Youth Vision, which includes increased accountability for employment and/or increased secondary and post-secondary education outcomes.

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A Waiver to Common Measures…the Good, the Bad, the Blog

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Creates the opportunity for state-specific performance measures through a reduction in the federally mandated measures.Increases program integration by focusing the system on common goals.Improves evaluation of the employment and training system.Provides commonality across workforce development programs.Provides for better service coordination and information sharing among programs

Eliminates the need for duplicate data entry to co-enroll participants in Wagner-Peyser and WIA through the use of an automated process.Achieves the overarching goal of a fully integrated workforce development system with an unobtrusive data collection process capable of assessing our performance at the system-wide and individual client levels.

In addition to these integration-related benefits included in formal waiver requests, there are additional and more practical benefits of moving to common measures.

Greater Flexibility for Training Activities

The adult and dislocated worker credential rates are sometimes a disincentive to provide training. This is particularly true for OJT and incumbent worker training, where a credential can be difficult to achieve. The elimination of these credentials provides greater flexibility for training activities. States and local areas are still free to create their own “credential” goals and definitions.

Youth Measures Simplified

The seven current youth measures, particularly the older youth measures, have provided the most serious challenge to states and local areas. For older youth, very often just a few participants can mean the difference between passing and failing a measure. Youth providers are often baffled by the complexity of the current WIA youth measures. The three youth common measures are more manageable, include both older and younger youth and are more realistic to meet and exceed. The new Literacy/Numeracy measure, however, does present some unique challenges.

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Reporting Systems in Place

States already have or should have systems in place to capture and report common measures. All that is needed, once a waiver is approved, is to negotiate realistic goals with ETA.

Cost Savings

The cost of customer satisfaction surveys at approximately $20 a completion is realized by states that completely abandon customer satisfaction surveys. However, many states, even with a waiver, are continuing to conduct some customer satisfaction activity.

What Are the “Cons” of Moving to Common Measures?

It is difficult to identify specific risks inherent in implementing common measures. For example, among the states that have requested this waiver, which required public notice and comments, essentially no objections or concerns were raised.

There appears to be a number of reasons why states have not applied for this waiver.

Avoiding Change – after seven years of struggling with definitions, reporting systems, and ongoing changes to the definition of WIA measures, many states and local areas finally feel comfortable with the seventeen measures and are just not ready to make a change that they are not required to make.Are these measures really final? – Many practitioners are skeptical and believe that the current version and definitions for common measures will be changing again either as a result of reauthorization or through some tweaking by ETA. Timing – If a state were just approved for common measure implementation in PY 07, two of the youth measures would apply retroactively to youth that exited as far back as October 1, 2006. At that point, most areas were not implementing youth programs with these new measures in mind and are reluctant to have the new rules apply retroactively.

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Cost – While eliminating customer satisfaction surveys saves costs, implementing common measures can be expensive. These additional costs include extensive staff time and training as well as changes in IT and reporting systems. One large early implementing state estimated these extraordinary costs to be well over $200,000.Incentive Issue – While this policy could be changing, as of PY 06, states approved for a common measures waiver were not eligible for incentives awards based on performance.

An Invitation to Join the Discussion

“This new performance measurement system under WIA is a high-stakes game - a state’s future funding and, therefore, its ability to serve its citizens may depend upon how well it performs compared to how well it is expected to perform.” General Accounting Office Report GAO-02-272, February 2002

The decision to seek a waiver to common measures will vary from state to state for some good reasons. It is important, however, that this decision be an informed decision. This article identifies some issues and more importantly begins a dialogue within the workforce community. We have continued the discussion and have posted additional resources on the youth common measures on our Common Measures Waivers blog at http://commonmeasureswaivers.blogspot.com. We invite all to participate, especially state and local areas that have implemented common measures…post your questions, opinions etc.

Ken Ryan is Partner and CEO of FutureWork Systems, LLC located in Ringwood, New Jersey. FutureWork Systems provides performance management technology and technical assistance services to the workforce community. Learn more about the company, its products and services at www.futureworksystems.com.

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