[NIFL-FAMILY:2625] FW: NLA Summary: Part 2 of Q&A: WIA, AEFLA, and the NRS

From: Nancy Sledd (nsledd@famlit.org)
Date: Wed Dec 22 1999 - 15:44:43 EST


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Subject: [NIFL-FAMILY:2625] FW: NLA Summary: Part 2 of Q&A: WIA, AEFLA, and the NRS
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Thanks again to Harriet for compiling these questions and answers off the
NLA list.  Nancy Sledd

-----Original Message-----
From: nla-approval@world.std.com [mailto:nla-approval@world.std.com]On
Behalf Of Harriet Vardiman Smith
Sent: Wednesday, December 22, 1999 11:50 AM
To: nla@world.std.com
Subject: NLA Summary: Part 2 of Q&A: WIA, AEFLA, and the NRS



Part 2 of Questions and Answers:
WIA, AEFLA, and the National Reporting System

The following questions were posted to the National
Literacy Advocacy (NLA) listserv sponsored by the
National Institute for Literacy. During December 1999,
the answers were provided by Ron Pugsley, Director
of the Division of Adult Education and Literacy in the
U.S. Department of Education.
-----------------------------------------------------

Question:
Can the six levels of performance be
modified by states and can performance be measured
on only one of the three areas, such as listening
and speaking for ESL?
Gloria Gillette

Answer:
Gloria, there are a couple of separate questions here.
But they are related. First, for federal reporting purposes,
States must use the six levels of performance on our
report forms which reflect statutory requirements in WIA.
As you know the functional level descriptors describe
what a learner entering that level can do in the areas of
reading and writing, numerically, speaking and listening
and/or functional or workplace skills.  The local program
need not assess the learner in all areas, but the assessment
should be in the areas in which instruction will be focused.

Additional indicators that States want to include may be
used at the States' option.  In fact, a number of States have
requested--and we have included in the NRS--optional
indicators States can use to report outcomes for family
literacy and workplace literacy programs.  But the legislation
clearly allows States to develop their own performance
indicators beyond the statutory ones they must report to us.

One issue in your question may touch on is the extent to
which project learners, who meet their objectives, may be
counted.  Although these learners would no longer be
included in federal reports, they could still be aggregated by
States and used for State and local reporting.  Washington
State is one State that has been fairly successful in devising
a method for doing this and including that method in its
State plan.  The contact persons would be
mendoza@sbctc.ctc.edu or bkanes@sbctc.ctc.edu.

------------------------------------------------------------
Question:
Does WIA "preclude" sampling?
David Rosen/George Demetrion

Answer:
It's true that WIA precludes sampling, but here's how.
There is no specific statutory language in WIA's Title II that
says "no sampling allowed."  There is, however, very specific
language about what the performance measures must be,
how each State's adjusted levels of performance will be
expressed and how achievement on those levels must be
compared to those of other States.  In order to comply with
the latter statutory language, sampling is unlikely to produce
comparable data among States on the performance indicators
based on specific learning outcomes of individual students in
the various educational functioning levels.

Regarding the core outcome measures for employment and
employment-related activities, data match procedures would
be far less costly and cumbersome than sampling.  There is
the further issue that sampling may not provide an accurate
basis for paying performance awards to States that exceed
their performance targets for Title I, Title II and vocational
education.

------------------------------------------------------------

Question:
Further comment on this question from section 1:
Is this true or is it possible that other measures [than
standardized tests] could be used, such as portfolio
documentation that demonstrates level gain according to
specific statewide criteria?
Gretchen Bitterlin, ESL Coordinator
Continuing Education Centers
San Diego Community College District

Answer:
You raise a good question about the use of standardized tests.
What Sec. 212 of WIA requires is that the state's
performance levels on the statutory core indicators be
"expressed in an objective, quantifiable and measurable form."
And those core indicators must reflect "demonstrated
improvements" in certain skills.  Now the quickest way to get
to that is by using standardized tests, although I don't think that
anyone is very happy with the state of the art in standardized
tests for adult education.  That is not to say that other measures
that could reach these objectives, such as portfolio assessment
against statewide criteria which included the WIA core
indicators could not be used.  But it would be more difficult for
the state to standardize this process.  Colorado has a very
good portfolio assessment system that you might look into,
although the extent to which it can accommodate the WIA
core indicators is not clear.  The contact person would be
Pam Smith or Mary Willoughby at 303/866-6638

While the selection of standardized tests for adult basic and
English as a second language programs is not ideal in any
sense of the word, it will as [David Rosen] point[ed] out,
take a significant investment of time and effort to improve the
situation.  What the role of the federal Department is in this
sort of policy question has been vigorously debated, but the
most effective one at the moment appears to be to provide
a catalyst for discussion in this area rather than to identify and
fund the development of a government test.  As you note, the
improvement of adult education tests is a long-term project
and we will have to use what is available to support the NRS
for the time being.

-------------------------------------------------------------

Question:
One question I would like to have Ron address is how
Federal ABE funds are distributed. Many people don't realize
that there is an established formula. Perhaps Ron could speak
to it. Also there is a state-by-state list of funds. How can
someone access it? And lastly, how much discretion do
states have when they distribute federal funds within a state?
J. Cretella

Answer:
The Federal Adult education funds are allocated to the states
and outlying areas through a formula based on certain
population factors.  First, each state is given a base amount
of $250,000.  All outlying areas receive a base of $100,000.
The remainder of the allocation is based on the relative number
of qualifying adult in each state or outlying area to the total
number of such qualifying adults in all states and outlying areas.
A "qualifying adult" is defined as a person who is at least 16
years of age, but less than 61: who is beyond the age of
compulsory school attendance of the state or outlying area;
does not have a secondary school diploma or its recognized
equivalent; and is not enrolled in secondary school  (Note:
The 16 to 61 age range used in this formula has nothing to do
with who may be served in programs.  Persons over 61 may
be provided  services.)  The number of "qualifying adults" is
based on Census data and is updated at the time of the Census
(every ten years).  Although the next Census will take place in
2000, we do not expect the new population counts to be
available until at least 2002.

The legislative language describing the allotment of funds to
states, including additional provisions concerning the Outlying
areas can be found in Section 211 (c-g) of the Adult
Education and Family Literacy Act.

Each year the Office of Vocational and Adult Education
prepares an allocation schedule containing level of adult
education state grant funds that each State and Outlying
Area will receive.  This information is placed on the
Division of Adult Education and Literacy Web-site and may
be accessed at  WWW.ed.gov/offices/OVAE/allots.html.

It is very difficult to answer your question about how much
discretion states have to distribute federal funds.  It is really
based on an individual point of view.  Let me describe some
of the conditions under which States distributed federal funds
and you can decide how much discretion there is.

First, the federal statute establishes the purposes of the
program and generally describes how the funds may be
used (allowable costs).  At the general policy level, states
must spend money to support adult education and literacy
services, including workplace literacy, family literacy
services, and English Literacy services.  Of the funds
allocated to a State, up to 5% may be spend for state
level administration, up to 12% may be spent for state
leadership activities, and 82.5% shall be used to award
grants and contracts to local providers.  Of the funds
allocated to local programs, some funds must be spent to
provide programs for corrections education and other
institutionalized adults but not more than 10% of the funds
made available to local programs.  The state must fund
multi-year grants or contracts, on a competitive basis,
to eligible providers as defined in AEFLA.  The state
must consider a set of 12 considerations (defined in
Section 231(e) of AEFLA) in awarding local grants or
contracts.  States may add other criteria as well to the
competitive funding process.  These are some of the
conditions under which funds are distributed.

--------------------------------------------------------

Question:
Along the same lines as assessment and funding - what
about learners who aren't working and don't have "attaining
employment" as one of their goals? I'm thinking of students
who are elderly, or who receive disability benefits, or who
are homemakers. Will the fact that their goals do not fit into
DOE funding goal frameworks adversely affect a program's
funding?
Erica Walch, Instructor
Read-Write-Now Adult Learning Center
Springfield, MA

Answer:
You'll be pleased to know that next year we'll be counting for
employment purposes only those who actually had as a goal
getting a job or obtaining job advancement.   Concerning the
impact on funding of enrolling learners who do not have
employment as a goal from the federal perspective, there is no
impact.  Federal funds flow on a formula basis to eligible
persons that do not take their learning goals--or even if they
are interested in learning--into account.  The formula only
counts the number of persons who could legally be eligible
for services in each state.  The legislation does not tie federal
funding to learner goals or even to the extent to which states
achieve their predicted performance levels, except that
financial incentives are provided to states that exceed their
negotiated performance levels for WIA Title I, Title II and
vocation education programs.

--------------------------------------------------------------

Question:
Someone asked me recently if there was WIA, title II funding
available for Native Americans on reservations.  I know that in
some of the k-12 programs there are set-asides for this
purpose.  Does DAEL fund programs on reservations?  If not,
do you know if the BIA or some other agency has funding for
this purpose?
Andy Hartman
National Institute for Literacy

Answer:
Andy, there are a couple of questions here, so let me take
them in order. There is no specific WIA Title II funding
targeted to or set aside for Indians living on reservations.
However, as with the Adult Education Act, it is possible for
local tribal education agencies, community colleges,
community-based organizations of demonstrated effectiveness
to compete for adult education funds like other agencies and
organizations in the States under Title 2.  My understanding is
that the Bureau of Indian Affairs no longer has funds for adult
education.

-------------------------------------------------------------

Question [somewhat abbreviated]:
Tom Sticht has … raised some important issues … as well as
Catherine King on the relationship between federal policy and
democracy.  There's a lot more that could be said, but the
obsession with counting--"objective, measurable, quantitative,
"at least goes to a significant core to where my critique is at.
"Secondary measures" are fine, I suppose, but if they are not
what "really" counts, I don't know why hard pressed programs
are going to spend quality time documenting them, too, in
addition to documenting what "really" counts.

As I have understood it, EFF all along was designed to link
pedagogy with policy wherein the standards (the generative
skills) would be the mechanism of assessment through its
performance indicators…These, however, do not easily break
down into "objective, measurable, quantitative," so they're off
the table, at least as far as primary indicators.  Without the
clout of a legitimizing assessment system, where does that
place the policy objectives of EFF?

On the sampling issue--not that I have any final answer here,
but at least (even from your comments) there seems to be
room for interpretation, if not  negotiation.  Think of what the
alternative is, attempting to obtain data information, pre and
post of whatever, on every student, an impossible standard,
particularly for decentralized volunteer tutoring programs, and
a dubious task in any event,-- all  just because a certain
interpretation of the law says that that is what's "really"
needed for the enforcement of policy mandates.

If there are some real problems here with the WIA and
particularly with the NRS, why not put a moratorium on the
data collection process for a year so that we can put together
some of our top practitioners, researchers, policy folks, and
reps from VALUE to take a good hard look so we might
come up with some other alternatives, including sampling.
George Demetrion
LVA-Connecticut River East

Answer:
George, thank you for the fine summary.  The issues you
raised are requirements of the Workforce Investment Act,
including what to measure, when it must be reported
(annually), how the Department must report it to Congress.
Because the Act requires core indicators that are not
EFF's standards, EFF's standards are in the category of
additional, useful measures a State may choose but which
are not mandated by law.  No one can declare a
moratorium on data collection under WIA because it is a
statutory mandate.  We all will have to work on improving
it as we go along.  WIA is the work of Congress, not the
Department of Education.  To keep things simple, the
Department even chose not to regulate on the new Act -
for the first time since adult education programs have been
authorized in federal education law.  As for expressing the
"debate on policy needs in the public airwaves," I do hope
my earlier offer of webcast/satellite dialogues this winter will
help get more people involved in the process.  I look
forward to keeping in touch with all of you on these issues
as we move forward.

Ron Pugsley, Director
Division of Adult Education and Literacy
U.S. Department of Education.
----------------------------------------------------------

Harriet Vardiman Smith
Materials/Research Coordinator
Texas Adult Literacy Clearinghouse
800-441-READ
409-862-6519
website:  http://www.cdlr.tamu.edu/tcall/



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