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 AACC's Position on the Reauthorization of the Workforce Investment Act and the Carl D. Perkins Act 


Perkins Act

Issue 1: Increased Focus on Postsecondary Career and Technical Education: Community colleges think that the Perkins Act should better reflect and support postsecondary career and technical education programs. AACC members feel that increased recognition and support for their programs is a key element in building a modern and cohesive career and technical education (CTE) system that serves the needs of secondary students, "traditional" college age students, and adult learners. In order to achieve this, community colleges believe that provisions of the Perkins Act that were drafted with secondary programs primarily in mind, including the performance indicators and the "uses of funds" language for the Basic State Grants, need reworking. Neither of these sections of the Perkins Act fully reflects the community college mission and the diverse goals of their students.

Currently, the required and permissive uses for Basic State Grants are laid out in general provisions that apply to both secondary and postsecondary programs. This language contains references that are inapplicable to postsecondary programs (e.g., referring to "parents" in many provisions) and lacks other references that should be present (e.g., explicit recognition of the postsecondary role in serving all members of society who are beyond the high school age).

The current "Uses of Funds" provisions are general, and give secondary and postsecondary institutions wide latitude as to how they are spent. States have broad discretion to determine the "split" between making investments in secondary and postsecondary education. AACC supports continuing to give states the responsibility to allocate the split between secondary and postsecondary vocational education. That said, more and more of the jobs filled by career and technical education students require high-level skills obtained at the postsecondary level, built on the solid academic foundation and skills attained in secondary CTE programs that provide students with a clear pathway to postsecondary programs. Study after study has shown that the gateway to a middle class lifestyle is postsecondary education. The Perkins Act should more fully reflect this reality.

AACC Position: The Perkins Act should include separate provisions governing the uses of Basic State Grant funds at postsecondary institutions. These provisions should explicitly recognize and support the community college role in upgrading the skill levels of individuals at all stages of their careers. In addition, only secondary programs that provide a clear pathway to the acquisition of high-order skills and academic knowledge taught at the postsecondary level should be supported by Perkins Act funds.

Issue 2: Separate Postsecondary Performance Indicators: Like the "Uses of Funds" provisions, the Perkins Act contains one set of core performance indicators that apply to both secondary and postsecondary grantees. These indicators are largely directed toward secondary programs, and focus on a narrow view of "completion" more appropriate to the relatively homogeneous goals of secondary students than the multitude of goals that community college students bring into Perkins-funded programs. Consequently, community colleges have struggled to comply with these unrepresentative indicators, which are, not incidentally, often unrelated to the way that Perkins funds are used at community colleges.

AACC Position: In May, 2002, AACC submitted recommended accountability measures for the Perkins Act and the Workforce Investment Act to the Departments of Labor and Education. The proposed measures are crafted to reflect the range of successful student outcomes for community college students in Perkins-funded programs. Therefore, the successful outcomes include not only attainment of a degree or certificate, but also skill attainment measured in a number of ways, and fulfillment of student-defined goals that do not fit into the other categories. In addition, the proposal would allow community colleges to submit data required by states if those data more clearly represent the use made of Perkins funds on a campus than the current indicators. Such data might include measures of student and business satisfaction with community college program offerings and outputs.

The Perkins list of "successful outcomes" is identical to proposed Workforce Investment Act accountability provisions, establishing a uniformity of federal accountability requirements in this area long sought by community colleges.

Issue 3: Postsecondary Linkages Program: Community colleges play a central role in making career and technical education programs more cohesive and responsive to the needs of various community stakeholders. Community colleges maintain a wide variety of working relationships with these stakeholders, including secondary schools, local businesses, and other community organizations. This integrative function is essential to precluding the social and individual costs that result from "seams" or schisms in our economic and educational system. Community colleges believe that the Federal government needs to enhance this role, emphasizing innovation, best practices, and information dissemination. The needs are enormous, and, as they pivot on relations between discrete organizations, often go ignored. A disturbing example of this dynamic is the lack of coordination often found between the curricula of high schools and postsecondary institutions.

AACC Position: The reauthorized Perkins Act should include a new national, competitive program to support innovative linkages between community colleges and other community stakeholders. Linkages eligible for funding would include those between community colleges and K-12 systems, local businesses, baccalaureatedegree granting institutions, adult education and G.E.D. programs, and other community-based organizations. Examples of specific projects that might receive funds are dual enrollment programs for secondary school students, clearer articulation pathways for career and technical education students into four-year programs, and professional development opportunities for community college faculty with local industries.

This program would serve as an incubator for innovative approaches to these various linkages. The successful ideas that emerge from this program could then be replicated and adapted by other institutions, using Basic State Grant funds.

Issue 4: Tech-Prep Program: Community colleges often experience a lack of coordination and agreement between colleges and secondary schools over Tech-Prep program expenditures. The result is often one of the consortium partners expending federal resources at its discretion in a manner inconsistent with the original project proposal.

AACC Position: The Tech-Prep program should continue to foster education reform as a separate program. However, the program should be modified to require that contracts between consortium partners be renewed  every 2-3 years, governing the details of the program and the expenditure of program funds.

Issue 5: High Demand Occupations: Community colleges are leaders in responding to the needs of industries where skilled workers are in short supply. If the reauthorized Perkins Act is to place a greater emphasis on economic development, attention must be paid to areas where there is the greatest need.

AACC Position: The Perkins Act should contain a unique funding source, whether from existing or new funds, dedicated to improving career and technical education programs serving high-demand occupations.

Workforce Investment Act

Issue 1: Subsequent Eligibility Requirements for Training Providers: The current reporting requirements for training providers have discouraged many community colleges from making more, and in some cases any, programs eligible for WIA training referrals. Many institutions find the reporting requirements overwhelmingly burdensome and counterproductive, especially in light of the low number of training referrals they receive. Community colleges often cite the need to collect information on every student in an eligible program, not just WIA participants, as a particularly onerous burden, especially in regard to job placement and wage data. Community colleges are also frustrated with conflicting federal reporting requirements and their inability to use similar data reported to a state or other oversight body to satisfy WIA requirements. These tangled reporting requirements go far beyond ensuring "accountability" or providing useful information to customers; they simply divert resources from being put to more useful purposes. The flawed WIA eligibility requirements have been well-documented by the General Accounting Office (GAO), DOL, and numerous non-governmental parties.

AACC Position: AACC has submitted to the Department of Labor proposed new WIA accountability provisions that would address community colleges’ concerns with the current requirements, yet still provide WIA participants with the information they need to make an informed choice of training provider. Under the proposal, community colleges would report on the percentage of all students in an eligible program who achieve a "successful outcome." The definition of "successful outcome" is the same as AACC has proposed for the Perkins Act, achieving the symmetry between these federal laws long sought by community colleges. The AACC proposal would also limit reporting on placement and wages to WIA recipients, and require states to make wage records available to facilitate that reporting. Institutions would also be able to satisfy WIA requirements by reporting similar data that has already been provided to a state or other entity.

Issue 2: Increased Emphasis on Training: Many community colleges are frustrated by the low number of training referrals they have received from the One-Stop centers. The promise of WIA—a more dynamic, market-sensitive federal job training system, driven by the needs of workers and business—has not yet materialized. There are several reasons for the lack of training being supported through WIA, including the need to initially dedicate large amounts of resources to establish One-Stop centers, but WIA’s "work first" emphasis is the primary cause. WIA requires that services be provided to customers in a sequence that starts with core services, moves to intensive services, and only then potentially provides training. Only a failure to place a WIA participant back into employment at one level of services will qualify that participant to move to  the next level. As a result, the amount of training being done at community colleges through WIA is actually lower in many places than under the Job Training Partnership Act. Furthermore, placement into employment of any kind counts as a success under state and local accountability provisions, regardless of the fact that training may be necessary to achieve long-term success. This set of incentives works contrary to the long-term interests of the economy, business, and WIA participants.

AACC Position: WIA’s progression of services should be modified to make training an immediate option when an individual’s abilities and career goals recommend it. One-Stop centers should be authorized to assess WIA participants and immediately refer them for training when it is necessary to achieve a long-term, successful employment outcome.

Issue 3: Operation of the One-Stop Centers: WIA’s drafters envisioned fully integrated One-Stop centers where customers could receive or be referred to any type of service they required. To achieve this integration, the act requires several different federal program providers to contribute to the operation of the One-Stop centers, through memorandums of understanding between them. Most community colleges are mandatory partners in the One-Stop because most of them are postsecondary Perkins Act grantees. Accounts from the field, as well as studies conducted by the General Accounting Office and others, have documented that this full integration has not come to pass, largely because many of the mandatory partners are unable or unwilling to provide the resources that are required. It is also hard to justify the mandatory redirection of funds originally provided for a much different purpose.

AACC Position: To fully achieve the vision of integrated service provision to WIA customers, the federal government must provide direct and complete support for operation of the One-Stop centers.

Issue 4: Funds for Training Outside of the WIA ITA Framework: Under WIA’s customer-based system, federal training funds flow to community colleges primarily through the Individual Training Accounts controlled by WIA participants. These funds cover tuition and fees for the WIA participants, but not the other costs of developing and implementing training programs. These costs usually far exceed those of the tuitions paid.

AACC Position: WIA should provide limited funding outside of the ITA framework to support training program development. One option is to allow for training contracts with institutions in emergency situations, such as mass layoffs.

Issue 5: WIA and TANF Integration: During consideration of the extension of the welfare law, many policymakers expressed their desire to achieve greater integration between the WIA programs and the welfare system. The welfare reauthorization bill passed by the House in the 107th Congress makes TANF a mandatory partner in the One-Stop centers. However, concerns remain that the distinct needs of the two populations would not be well served by an integrated system.

AACC Position: Greater integration between WIA and TANF programs may have positive effects, but the primary role for community colleges in regard to these individuals should be providing increased education and training opportunities. This may be achieved through incorporating TANF service delivery into the WIA system.

Issue 6: Adult Education: Community colleges seek to play a greater role in federal adult basic education programs, where their participation does not reflect the massive involvement of community colleges in this area. One cause of this lack of harmony between federal policy and institutional practice may be that policymakers often do not view adult basic education to be central to the community college mission, while in fact adult basic education, literacy, and English as a Second Language training is directly related to workforce development. Employers often cite these issues as some of their greatest obstacles to finding qualified employees.

AACC Position: Adult basic education should be explicitly linked to the workforce training mission of community colleges. Federal grants with a required match should be considered to motivate greater state and private investment in adult basic education and literacy training.

AACC Contact: Jim Hermes, Senior Legislative Associate,

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