The purpose of this memorandum is to clarify the (1) most recent 9c cuts, (2) FY17 and FY18 reporting requirements, and (3) how past performance will be factored into the upcoming open and competitive request for proposals (RFP).
Good news: The recent 9c cuts will not impact grants in FY17. ACLS was able to offset these cuts by eliminating earmarks and using federal roll over funds and returns to cover the balance.
Not so good news: Though nothing is settled until the FY18 budget process is completed, it is highly likely that there will be less funds in FY18 to distribute to programs as the federal roll-over funds, which have allowed ACLS to maintain funding levels, have been mostly used. Programs will be notified about approximate funding amounts for FY18 in the continuation RFP which will be issued in the spring.
FY17 and FY18 Reporting Requirements
The new state accountability performance system, based on student outcomes, will be piloted in FY17 and FY18. ACLS and programs will review program performance relative to Measurable Skill Gain (MSG) targets to determine if the new standard is successfully helping Massachusetts meet the state target set by OCTAE. The standard might be adjusted accordingly based on the results from the pilot.
It is important to note that while the state MSG standard is being piloted, Massachusetts is accountable to OCTAE for Measurable Skill Gain which is defined as the percentage of program participants who, during a program year, are in an education or training program that leads to a recognized postsecondary credential or employment and who are achieving measurable skill gains toward such a credential or employment.
Although, ACLS is only piloting the standard for MSG, Massachusetts is required to report aggregate student data including, but not limited to, the following:
- educational outcomes as determined by Educational Functioning Level (EFL) completions
- enrollment and attendance
- obtainment of a high school equivalency credential
- enrollment in postsecondary education or training
- employment rates
- retention with the same employer
- barriers to employment
Thus, in FY17 and FY18, ABE programs are required to submit relevant student data and outcomes to ACLS via SMARTT.
As outlined in the July 25, 2016 letter to the field, ACLS has eliminated the SMARTT reporting requirement for goals. Programs no longer need to collect and report that information in SMARTT (with an exception of data elements required under WIOA related to employment follow-up and HSE and post-secondary attainment). Because federal legislation requires that states and programs document the post-secondary and employment outcomes of our former students, cohort follow-up is still required. (NOTE: ACLS is developing new screens in SMARTT to support such follow-up and will offer webinar trainings on the follow-up process and new screens). Moving forward, ACLS will refer to goal setting as an essential activity in the career planning process not as a performance measures standard.
Past Performance and the Open and Competitive Request for Proposals
In prior open and competitive RFPs, for applicants funded by ESE, past performance points were automatically assigned based on the program results related to the state performance standards and contributed to the overall score in their proposals. New applicants (outside the system) provided performance data in an alternative format which was scored during the review process.
ACLS intended to apply the same strategy to the upcoming competition; however, legislative and regulatory changes require that "all eligible providers have direct and equitable access to apply and compete for grants or contracts (and that) the same grant or contract announcement and application processes are used for all eligible providers," (Federal Register, Department of Education, 34 CFR § 463.20(d)(3)). Upon further clarification from OCTAE, it became clear that ACLS cannot apply one method for scoring past performance for previously funded programs and another for applicants outside the current system. As a result, past performance points awarded to the currently funded programs in this funding cycle will not be included in the scoring of the proposals in the upcoming O&C RFP.
However, as stated in Sub part C of the Federal Register (34 CRF § 463.20(c)(1)(2)) "In awarding grants or contracts for adult education and literacy activities to eligible providers, the eligible agency must consider … (3) The past effectiveness of the eligible provider in improving the literacy of eligible individuals, especially those individuals who have low levels of literacy, and the degree to which those improvements contribute to the eligible agency meeting its State adjusted levels of performance for the primary indicators of performance [.]"
Therefore, evidence of past performance will be used as (1) an eligibility criterion and (2) a way to demonstrate past effectiveness. Programs can anticipate questions regarding past performance, especially around student outcomes identified under WIOA performance measures. Past performance data will include FY17 outcomes as well as previous years' data available to the program.