WIA Strategic Planning: Questions and Answers



Question 1
States with newly-elected governors (listed in Section 5 of TEGL 13-06, Change 1) have been provided the option of submitting their proposed modification to their State Strategic Plan by June 30, 2007. For states that choose this option, when should performance negotiations for Program Year (PY) 2007 and PY 2008 be negotiated?

Answer 1
The State and Regional Administrator must negotiate goals for PY 2007 by 6/30/07, and negotiate goals for PY 2008 by 9/28/07. If a state finds that the PY 2007 negotiated goals are significantly different from actual results due to changes in economic or other unanticipated circumstances, the state does have the ability to request renegotiation.


Question 1
Our State will submit a modification for its 2007 Unified Plan requirement using the April 12, 2005 guidance. Can you advise what official title we should use when referring to this year's Unified Plan?

Answer 1
If we are consistent with the approach of 2005, ETA will refer to the state’s Plan in its response (approval/disapproval letter) to the state as follows: "the (State name) Unified Strategic State Plan for the two-year period, July 1, 2007 through June 30, 2009…" However, the state can develop a more descriptive like: "(State Name) Unified Strategic State Plan for Program Years 2007 and 2008 (July 1, 2007 through June 30, 2009) which are the third and fourth years of the five-year planning cycle beginning July 1, 2005, and ending June 30, 2010."

Question 2
Our past plan provided complete responses to each question, which required the duplication of similar if not identical text in various areas of the Unified Plan. This year, our state is considering including references to stated text instead of repeating text in various sections. Will this approach meet the Department’s needs?

Answer 2
TEGL 13-06 (page 3) provides ETA’s recommendation on this issue:


We encourage you to examine the questions carefully. While they may relate to the same subject, generally, they were framed for different purposes; it may not always be appropriate to simply respond with the same text from a prior question. There is no prohibition against referring to prior text as the response, but you are also encouraged to consider making review of the document easy for the public as well as for ETA.

Question 3
Our state may request a waiver to have this year's Unified Plan extended an additional year, for year five of the planning cycle, through June 30, 2010. Do you know of any other states that have or plan to request a similar waiver?

Answer 3
No states have thus far, and as far as we know, no other states are planning to submit such a waiver request. ETA encourages you to consider waiting to request such a waiver until later in the planning cycle when we will have some idea about WIA reauthorization from Congress.

Question 4
Do we need to adjust the time frames in questions or just reflect the most recent time frames in our responses? (Most likely TEGL 13-06’s Change 1 will answer the question below, but we would be grateful if you could provide an answer earlier.)

Answer 4
There is no need to revise the questions’ contents in the Planning Guidances, regardless of which Planning Guidance the state will use. Using your best judgment, please substitute current time frames in your response.

Question 5
Where can we find Department of Education guidance on State planning under Perkins?

Answer 5
The Department of Education’s Office of Vocational and Adult Education has issued its final Perkins IV State Plan Guide. The Guide can be found at
www.ed.gov/about/offices/list/ovae/pi/memoperkinsiv.html.



Question 1
The Strategic Plan Writing Team for our state will review existing verbiage in the current plan. They will modify this verbiage to reflect the current state vision, mission, and status on national objectives. In reviewing the requested information, we were trying to align the new directions with existing questions; however, they do not clearly align.

Answer 1
We do not see this as an insurmountable problem. Many of the action items in the existing Planning Guidances address issues identified in the new National Strategic Direction. As indicated in TEGL 13-06, the new National Strategic Direction "provides a frame of reference for the development of the modification to the State Plan for years three and four of the five-year planning cycle."

The above notwithstanding, ETA recognizes that states will exercise flexibility in interpreting the applicability of some action items in the Planning Guidances. There are some action items to which ETA no longer expects responses. The following two examples are from the Stand-Alone Planning Guidance:


There are other action items in the Planning Guidances that require flexibility in responding. For example, in V.B. (of "Overarching State Strategies’), the action item asked, "What strategies are in place to address the National Strategic Direction discussed in Part I of the guidance…". In this case, ETA expects the state to focus on the new National Strategic Direction as described in TEGL 13-06.

Similar challenges may exist with other items in both the Stand-Alone and Unified Planning Guidances. With regard to such items, the state can submit a specific inquiry to ETA for additional guidance. Otherwise, ETA expects states to use their best judgment to develop meaningful responses that comply with the intent of the Planning Guidances and TEGL 13-06.



Question 1
Does the ETA National Office want the state to blend the responses into the existing document or do we add the new responses to the end of the document as an addendum?

Answer 1
TEGL 13-06 (page 3) provides ETA’s recommendation on this issue:


In summary, the state should revise the existing Plan rather than add new responses to the end of the document as an addendum.



Question 1
Our state wants to know if it can simultaneously submit the WIA modification for public comment and review by ETA.

Answer 1
WIA regulations at 20 CFR 661.220 (d) provide the following:


To comply with the requirements of WIA, the state must provide an opportunity for public comment prior to submission to ETA for review and approval. Accordingly, the state cannot submit a modification for public comment at the same time it submits the modification to ETA for review and approval.

Question 2
Our state wants to shorten the comment period because of the ETA deadline for submitting this major modification. We do not have a minimum public comment period in our statute; we would like to provide for only a fifteen day comment period. We had a thirty day comment period for the last major WIA modification. Is this a problem?

Answer 2
In addition to requiring that the state provide an opportunity for public comment on and input into the development of the State Plan prior to its submission, 20 CFR 661.220 provides the following related to ensuring adequate public comment and input:


Neither the statute nor the regulations specify a number of days to provide opportunity for public comment and input. However, the regulations do provide requirements, as described above, which must be met. The state must ensure that its proposed timeframe for public comment and input enables the state to meet these requirements. A timeframe less than thirty days may be sufficient.