The draft includes many strong features, including the 10 reforms that were part of the 2014 Unified Plan, including but not limited to the development of common intake, assessments, and case management; encouraging co-enrollment; increasing career counseling; and implementing common performance measures. Also, the draft continues the alignment of Career and Technical Education (CTE) with other workforce development programs that was established in the Unified Plan.
The draft combined plan builds on these reforms by including increased integration with Temporary Assistance for Needy Families (TANF); and state support and requirements for CTE Programs of Study, stackable credentials, and articulation.
The draft plan, however, misses some major opportunities.
The plan mentions Ohio’s Workforce Alliances, but fails to highlight these sector partnerships as a key strategy with broad applications. For example, the state could use the Alliances to inform CTE programs of study and avoid burdening employers with overlapping requests for engagement. The plan does not include a way of funding the Alliances after June 30, 2017.
The draft plan does not discuss the planned uses of the Governor’s reserve fund as required by WIOA, including the use of reserve funds to support sector partnerships.
The plan does not discuss how the state will implement the priority of service for low-income individuals, public assistance recipients, and individuals with low basic skills. This is an important new requirement of WIOA that should be emphasized in the plan and in a separate WIOA policy guidance letter developed by the Ohio Department of Job and Family Services. The U.S. Department of Labor has recently indicated that they will require a description of the state’s process for priority of service in the state plan. Ohio should specifically include a statewide policy on priority of service and set service goals to ensure that people with barriers to employment are being prioritized through the workforce system.
The draft plan fails to provide data on the state’s immigrant population and the steps that will be taken to serve this population.
The Title II section of the plan indicates that in the second year of the plan Integrated Education and Training (IET) activities will be required. The plan would be stronger if this important strategy were highlighted as a key reform in the strategic portion of the plan, and not mentioned only in the Title II program plan. In addition, the Perkins part of the plan should discuss steps Ohio will take to integrate postsecondary CTE and adult basic education, including professional development.
Important steps to support career pathways are mentioned at places in the plan (including in discussions of the Comprehensive Case Management and Employment Program (CCMEP), IET, and CTE), however the development of career pathways is not highlighted as a key strategy in the strategic portion of the plan.
The plan is unclear whether or not the WIOA common measures will be applied to TANF E&T and whether TANF E&T will be included in the state’s dashboard. These would be positive steps that would enhance coordination.
The draft plan indicates that CTE is part of the state’s dashboard and common measures; however, the Perkins portion of the plan does not include the additional state indicators that are among the state’s common measures.
The draft plan misses the opportunity to include SNAP E&T as part of the combined plan, in particular state actions to increase resources by obtaining SNAP E&T 50-50 funds.
The analysis of the state’s labor market understates the need for postsecondary training by using the BLS category of occupations that require only a high school education, without recognizing that about half of these occupations require some form of postsecondary training of at least a month in length.
The draft plan for Eligible Training Providers seems to rely on providers self-reporting performance. In order to increase consistency, validity, and reliability, instead of relying on self-reports the state should require providers to send administrative records on all students/participants to the state for matching with wage and other administrative records.
The plan should also identify steps that the state will take to provide a comprehensive student scorecard system on training providers so that the public has sufficient information to make informed choices.