ESE Responses to Questions Submitted by the Directors’ Council

Note: This document contains responses to questions posed by the Directors Council (DC) and shared with DC members during a meeting in June, 2016. We plan to formally codify much of the information contained within this document in the updated ACLS Policy Manual and the FY18 Open and Competitive ABE RFP, expected to be completed in late October and Mid-November respectively. Please contact [email protected] with questions or concerns.

Performance Standards Q.1 Please explain how the 6 WIOA measures (mostly relating to employment) will impact program design. A.1. The state accountability system for Title II (ABE) under WIOA will assign most weight for educational outcomes (e.g., EFL completion, high school equivalency credential, postsecondary enrollment). Employment targets for ABE will be based on the statistical adjustment model and will reflect the population served under Title II (ABE). ACLS expects that employment targets may be lower for ABE than for our workforce partners.

Program directors should think about ensuring that program design and classroom instruction meet the needs of students and help move students through EFL completions.  Programs are working hard to develop and use standards-based curriculum, align instruction with the standards, implement strategies aligned with the instructional shifts the ELA and Math standards demand, and build staff capacity to implement rigorous, standards-based instruction. These processes all contribute to student educational achievement and EFL completion.  Programs with students looking for employment should have connections with One-Stop Career Centers (OSCC) and co-enroll eligible students in OSCC services.  Programs with students who will be moving to postsecondary education and/or training should have classes to support them in that transition (e.g., ACCUPLACER prep, bridge math class, bridge writing class, online options, adequate integration of digital literacy).  It is also suggested programs review EFL completion information provided in the National Reporting System Implementation Guidelines at http://www.nrsweb.org/foundations/implementation_guidelines.aspx.  Performance measures will be informed by the National Reporting System (NRS) guidance and final regulations.

Q.2. Please explain how the 6 WIOA measures will impact staffing. A.2. Title II (ABE) programs have been reporting on employment outcomes under the current performance standard for student employment goals. Under WIOA, reporting on employment will continue. However, as a system we will need to do a better job gathering post-exit employment outcomes that are not data matched. This has implications for follow up when data matching on employment measures are not available. Staffing needs for follow up will vary by program depending on the population served and how many students will be data matched vs. how many require a follow up through survey. ACLS will provide guidance and share examples of how surveys can be conducted.

Advising is another example of potential staffing impact. Programs must ensure that sufficient and effective advising is offered.

Page 1 of 8 For individuals not yet ready to participate in the labor market, ABE serves as an on-ramp to the workforce development system, preparing students to acquire the skills needed to succeed in jobs that pay family sustaining wages. The response to question 1A provides examples of possible staffing impacts related to helping students move through EFL completions.

Q.3. Please explain how ACLS or SABES will offer trainings on EFL and how to improve EFL completion in every region and in timely way. A.3. Quality curriculum and instruction are the foundation for EFL completions. The single best thing programs can do to improve EFL completion is to align curriculum and classroom instruction to the College and Career Readiness Standards for Adult Education (CCRS) and instructional shifts for ELA/Literacy and Mathematics. SABES will continue to provide high-quality PD to help programs integrate the CCRS at every level of instruction. Teachers who need support in teaching the CCRS and the shifts and Directors who need support in setting higher expectations for teachers should participate in SABES PD.

ACLS posted guidance to help program staff understand EFLs on the ACLS website at h ttp://www.doe.mass.edu/acls/assessment/EFL-FAQ.html. Additionally, ACLS and SABES will collaborate to design and offer informational webinars to help the field better understand EFL completion. SABES will also integrate information about EFL completion in relevant offerings of the PD centers.

It is also suggested programs review EFL completion information provided in the National Reporting System Implementation Guidelines at http://www.nrsweb.org/foundations/implementation_guidelines.aspx.

Q.4. We were told at the Performance Standards sessions at the Directors’ Meeting that programs will be “held harmless” for FY17 performance data. Can you confirm this? A.4. ACLS will not be including past performance data for FY17 in the Open and Competitive RFP process but will be required to report program performance to OCTAE. In other words, program performance data will be used to document the extent to which Massachusetts meets EFL targets.

Q.5. Please explain what accommodations will be offered to corrections programs relative to the performance standards given their unique situation. A.5. The state performance measures framework will be adjusted for corrections. ACLS will work with the roundtable to make sure that the selected measures are relevant and fair. EFL completion rates will apply the same way they do for CALCs.

Funding Q.6. You speak often of “leveraging resources” to offset the increased costs associated with Integrated Education and Training (IET). Please cite examples of specific resources that you have in mind. A.5. There are a variety of ways funding can be leveraged or braided: - Local programs can collaborate to offer a program/class that provides education and training services where the program/class components are paid for with more than one funding source. - For out-of-school youth, ABE programs can provide education services such as HSE preparation and leverage Title I workforce resources for employment training. Page 2 of 8 - For older adults, ABE programs can provide education services and support student co-enrollment in workforce programs using Individual Training Accounts (ITAs). - National Emergency Grants, now Dislocated Worker Grants (NDWG), can be utilized to support integrated ESOL/Occupational Training programs. Trade funds may be similarly utilized. - Workforce Development Boards (WBD) can issue RFPs for integrated education and training models to promote collaboration between Title I and Title II by encouraging partnerships between training providers and ABE programs. - Private and/or foundation funds can be leveraged for training and other services as appropriate. - For corrections, leveraging resources is possible by combining an existing ESE funded class at the correctional institution with a training program paid with non-ESE funds. WIOA core partners at the state level will gather examples of ways to leverage funding and share them with the field.

Q.7. Many programs fear that we will not be able to continue serving lower level learners or the undocumented. Please cite examples of funding sources that will enable those populations to access education and training. A.7. Adults with the lowest skills are a priority population under WIOA. The Massachusetts ABE system will continue to serve these students and provide pathways and opportunities that help them progress and obtain the skills needed to succeed in today’s economy. ABE services must be available to all students in need of education.

Adults do not need to provide a social security number to enroll in Title II (ABE) programs. However, programs should ask in a neutral manner for a SSN that can be helpful for data matching purposes. For students who do not provide SSN, follow up on employment related outcomes will be needed.

Q.8. Without additional funding, programs will be forced to decrease intensity, eliminate classes, and reduce staff in order to pay for the cost of workforce training and the increased costs associated with the extensive collaboration required under WIOA. Please explain what policy changes ACLS is planning to enable programs to continue operating. Will ACLS drop the requirement for a sequence of three and/or modify the requirements for education and career plans? A.8. Program design should support the need in the community and effectively meet the academic needs of enrolled students. - Accelerated models are encouraged to promote the progression of students from one EFL to another and to assist those who are ready to move to postsecondary, training and/or employment through local partner collaborations (e.g., creating pathways for students, leveraging resources). - Programs that want to use Adult Career Pathways funds to offer IET should discuss their proposed programming with their assigned Program Specialists and the WDB. - Programs that want to use ABE funds for a training component can apply for an IET pilot. Programs that are able to leverage money for the training component can offer IET independently of the pilot. - ACLS is reviewing current policies in preparation for the O&C RFP. It is not yet clear if the sequence of three will continue to be a policy requirement. However, it is clear that students at the lowest levels must continue to have access to services.

Page 3 of 8 Q.9. Will ACLS allow community planning funding to be used for regional planning and collaboration under WIOA? A.9. Yes. Community planning funding can be used for WIOA collaborations.

Training Q.10. Please define IET. Are all programs required to have at least one IET class? A.10. Please read the ACLS guidance provided in the FY2017 Policy Changes document distributed at the Directors’ Meeting on May 24. IET models require that ESOL or ABE instruction is provided concurrently and contextually with training that offers industry recognized certificate(s). More information can also be found in the pilot IET RFP at http://www.doe.mass.edu/grants/2016/359-686/ and WIOA regulations. IET, based on I-BEST, is considered an accelerated model. - In the WIOA Combined State Plan for FY2017-FY2020, it is proposed that IET and/or IEL/CE will be offered in each region, not at each program. - In FY17, IET and IEL/CE will be piloted in programs that received IET funding in FY16. Another RFP for additional pilots was posted on July 14, 2016. - Current 359 EL Civics funding (approximately $2 million) will be set aside for Integrated English and Civics Education (IEL/C E) models (i.e., ESOL instruction combined with civics education that is contextualized and concurrent with a training leading to industry recognized credentials). This funding will no longer support stand alone ESOL classes starting in FY18

Q.11. Please explain the difference between IET and Career Pathways programming. A.11. Career pathways as an approach to service delivery connects progressive levels of education, training, support services, and credentials for specific occupations in a way that optimizes the progress and success of individuals with varying levels of abilities and needs. This helps individuals earn marketable credentials, engage in further education and employment, and achieve economic success. It is not simply a new model; it is a way to transform systems. The development of career pathways is foundational to the success of WIOA. For more information on career pathways, see Shared Vision, Strong Systems at http://www.clasp.org/resources-and-publications/files/aqcp-framework-version-1- 0/AQCP-Executive-Summary-FINAL.pdf. - IET grants/programs: Please read the ACLS guidance provided in the FY2017 Policy Changes document distributed at the Directors’ Meeting on May 24. IET models require that ESOL or ABE instruction is provided concurrently and contextually with training that offers industry recognized certificate(s). More information can also be found in the pilot IET RFP at http://www.doe.mass.edu/grants/2016/359-686/ and WIOA regulations. IET, based on I-BEST, is considered an accelerated model. - Adult Career Pathways (ACP) grants/programs: Most ACP programs are ESOL or ABE classes with hands on career exploration that leads to training or postsecondary education in a sequential manner. In most cases, the services are not concurrent as they are with IET programming.

Q.12. We understand from the Directors’ meeting that all programs are not required to offer IET as long as there is one IET program per region. But included in our packets at the Directors’ meeting is a policy sheet that seems to suggest that IET WILL be required in FY18. Please clarify. A.12. In the combined state plan MA proposed that we will offer IET in every region. The IET guidance in the packet is for programs that are interested to apply for the IET pilots that will be offered in FY17. Not all programs are required to offer IET.

Page 4 of 8 Q.13. Rural programs are concerned that there will not be sufficient numbers of students wanting to pursue the same job training. A.13. In the WIOA Combined State Plan for FY2017-FY2020, it is proposed that IET and/or IEL/CE are offered in each region, not at each program. Programs in rural areas should pursue options to serve students wanting to pursue job training with core partners during local MOU collaborations.

Q.14. Contextualizing curriculum to specific workforce sectors is incompatible with preparing students to pass the HiSET and enter post-secondary training. Which is the higher priority: to help students achieve high school equivalency; to prepare students to enter certain employment sectors; or to prepare students for post-secondary education? A.14. Contextualized curriculum does not preclude rigorous academic instruction that also leads to a high school equivalency credential and success in postsecondary education and/or training. ACLS’ priority is for programs to help students develop the skills needed to succeed in their next steps, whether those next steps are higher education and/or training. Under WIOA, it is the responsibility of programs and local partners to identify opportunities to create programming that prepares students for those next steps.

In each region, students should have different pathways to meet their needs (e.g., IET and/or IEL/CE programs contextualized to a specific industry sector, Adult Career Pathways programs focused on transitioning students to a community college, training, and/or employment). Program design should consider the needs of different students and services should be available to meet those students’ needs.

Q.15. Please explain how students who have not achieved high school equivalency will enter the workforce in which employers are increasingly requiring the high school diploma or its equivalent even for entry-level employment. A.15. ABE programs work with adults to help them get their high school equivalency credential and assist them in transitioning to postsecondary education and training. Programs can offer high intensity HiSET preparation (e.g., boot-camp in math, blended learning or other accelerated classes) to help students get the skills needed to pass HiSET and seek employment.

Collaboration Q.16. Programs have serious concerns about collaboration with the core partners. Who, exactly, is responsible for coordinating the development of the local MOUs? Is it Workforce Development or one of the other partners? A.16. WDBs are responsible for convening regional partners and coordinating the development of local MOUs. Joint guidance for local MOU development will be released by WIOA core partners at the state level to support all core programs at a local level.

Q.17. Which partner is responsible for doing follow up? A.17. The program from which a student exits is responsible for follow up. For example, when a student exits from an ABE program, the ABE program is responsible for follow up.

Q.18. Who does intake and who will develop any common intake form? A.18. Currently each program does its own intake. State agencies are waiting for final regulations to determine which data elements need to be collected during intake. WIOA core partners at the state Page 5 of 8 level are looking to develop a common intake mechanism for shared customers. However, this work has just begun. The field will be informed as more information becomes available.

Q.19. We are told that the workforce partner determines eligibility under WIOA and will be conducting assessments. If these are educational assessments, what plan is in place to train career center staff on assessment? Will they be using the ACLS required assessments? If not, how will ACLS minimize the impact of repeated testing on potential students? A.19. Each WIOA funded program has its own eligibility requirements. Shared customers need to meet the eligibility requirements of all WIOA programs they enroll in. During local MOU planning, assessment requirements should be discussed to determine ways to streamline testing for students.

Q.20. If the WDB is administering assessments to determine eligibility for services, and they will not necessarily use ACLS’s required assessments, prospective students will be taking the TABE and the ABE program’s placement assessment and then once enrolled, the MAPT. How will ACLS minimize the impact of repeated testing on students? A.20. Decisions about testing are to be made at the local/regional planning level.

Q.21. At the Directors’ meeting, you indicated that the LWIBs in each region can decide whether the shared customers will displace already waitlisted ABE/ESOL students. Follow up question: If ACLS is ceding the authority to make policy decisions that affect our constituents to the LWIBs, this may result in an unfair advantage to some programs on the performance standards throughout the grant cycle. How will ACLS balance this advantage to ensure fair treatment for all programs? A.21. WIOA partners must work to determine how to serve shared customers but decisions about serving them are to be made at the local/regional planning level. Individual program policies might need to be developed to ensure that programs are able to serve shared customers as defined in that region.

Additional concerns Q.22. We know that in the majority of cases, students require longer than one fiscal year to make the 100 pts it will take for some to achieve an increase in EFL. Can EFL be tracked longitudinally over the 5-year funding cycle, with programs getting credit for gain that occurs anywhere within the 5-yr cycle? A.22. Massachusetts is aligning performance standards with the federal accountability measures that states are held accountable for. While ACLS can consider tracking EFL over periods longer than one year, performance reporting to OCTAE will continue on an annual basis.

Q.23. There is a large gap between the highest scale score on the TABE-L and the lowest possible score (200) on the MAPT. Is there any plan to adopt or create a new assessment for the 0-2.9 learners who are not yet able to take the MAPT? Will moving from the TABE-L to taking the MAPT count in itself as an EFL completion? A.23. There are no plans to develop a new assessment. Moving from the TABE-L to taking the MAPT will not count in itself as an EFL completion.

Q.24. Curriculum: We believe that the current deadline for the completion of curriculum revision is unrealistic given the changes and challenges of WIOA. Will ACLS consider extending the deadline beyond June, 2019? A.24. See the curriculum policy update.

Page 6 of 8 Q.25. What is the policy regarding career center-referred “shared customers” and the ABE waitlist? That is, will shared customers move ahead of already waitlisted students? A.25. Please refer to ACLS guidance provided in the ACLS Guidance for Adult Education Programs on WIOA Implementation: Shared Customers document distributed at the Directors’ Meeting on May. During regional planning, local programs should discuss waitlists and develop policies that promote both sequential and concurrent enrollment in partner services so that individuals who are in need of ABE services and core partner services can be better served.

Q.26. Documentation and outcomes: Given that there is no common database for the core partners, how will partners access data on shared customers? How will outcomes be tracked? A.26. Programs are responsible for their own outcomes and follow-up. WIOA core partners at the state level are looking into an interface that would allow data sharing. The field will be informed as more information becomes available.

Q.27. We have heard about a database that is an open source database from NASWA (National Association of Workforce Agencies) that might serve these needs. What do you know about this? A.27. EOLWD is convening a WIOA systems integration working group that will provide input into an integration/interface of information systems across the WIOA Partner agencies. More information will be shared as it becomes available.

Open and Competitive RFP Q.28 Open and Competitive RFP: MUST be released no later than October of 2016. New directors will require training. Can you confirm that the release of the RFP will occur no later than October? What is the plan for training new directors? A.28. ACLS will make every effort to release the RFP in the fall of 2016. The O&C RFP is scheduled to be released on November 15, 2016. Bidders’ conferences and program planning information will be provided to all potential bidders including new directors.

Q.29. Will ACLS allow for ample time between the release of the RFP and the first bidders’ conference? A.29. The Department plans to schedule bidders’ conference approximately 2 weeks after releasing the RFP to allow time for interested applicants to review the RFP materials. We are also planning for one bidders’ conference to be done through a webinar. There will be a mailbox set up for questions and answers will be posted weekly on the ACLS website.

Q.30. Will ACLS allow a minimum of 12 weeks from the last bidder’s conference to the RFP submission deadline? A.30. The Department plans for the submission deadline to be 3 months from the release of the RFP.

Q.31. Will ACLS commit to updating the FAQs no less than weekly? A.31. The Department plans to update FAQs weekly.

Q.32. Will ACLS commit to producing a simplified, clearly written RFP with a minimum of redundancy? A.32. The Department will work with internal and external groups to develop the RFP and aims for a simplified and clearly written RFP.

Page 7 of 8 Q.33. Will ACLS commit to recruiting qualified readers who have direct knowledge of and experience in the field of ABE? A.33. Reader teams consist of ACLS staff, ESE staff, WDB representatives and may include external contractors who are qualified and have knowledge and experience in ABE.

Q.34. Will ACLS commit to assigning readers to regions where they have no vested interest in either the success or failure of the applicants? A.34. Reader teams are well trained and the review is based solely on the responses provided in the proposal and rubrics released with the RFP. Reader review team comments are available upon request and can be reviewed. The Department will ensure that individual readers do not have any conflicts of interest.

Q.35. Will ACLS commit to notifying programs about their funding not less than 30 days before the end of the fiscal year? A.35. The Department plans to notify programs of funding in April, however depended on state budget availability final grant amounts might not be finalized.

Q.36. Will ACLS commit to retaining individual readers’ scores for at least six month in the event that award decisions or scores are challenged? A.36. The Department retains all reader scores and comments. Individual reader scores and comments are not required; most teams only produce team comments and scores.

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