ACLS Response to Stakeholder Feedback on Proposed Adult Education Local Workforce Allocation and Program Methodologies for FY19- Massachusetts Department of Elementary and Secondary Education
Adult and Community Learning Services (ACLS)
ACLS Response to Stakeholder Feedback on Proposed Adult Education Local Workforce Allocation and Program Methodologies for FY19
|To:||Adult Education Directors|
|From:||Jolanta Conway, Adult Education State Director|
|Date:||July 21, 2017|
Thank you for your thoughtful and informative responses to the June 12, 2017 memorandum on proposed adult education local workforce allocation and program funding methodologies for fiscal year 2019 (FY19). Below you'll find key adjustments made to the proposed methodology based on stakeholder feedback, along with a summary of the feedback and ACLS's responses.
Key adjustments to the proposed methodology based on stakeholder feedback
Adjustment 1: ACLS revisited the data for the seat range, and after additional analysis of current seat allocations, was able to increase the range to $2,300 to $3,300 per seat without sacrificing overall service levels across the state. See the additional guidance below regarding the seat range:
- A program can have seats that cost more than the threshold as long as the average is within the range.
- Foundation, unrestricted, and supplemental funding are now reflected in the allowable range.
- Programs will have to provide a compelling rationale for designs of an average per seat cost over $3,300. This may include costs related to a wide geographic service area or other factors.
- Integrated education and training (IET) and integrated English literacy and civics education (IELCE) models will not be held to this funding structure, and IET/IELCE proposals will be considered separately in a sub-competition.
- As part of local planning, adult education providers should work with One Stop Career Centers (OSCCs) to develop a program that meets the needs of adult learners in their areas, including shared customers.
- Ongoing service refers to availability during the academic year (September to June). Programs with designs that do not align with the academic calendar must provide a rationale for the structure. Additional programming (e.g., summer) is encouraged and can serve as the basis for a rationale for higher funding levels. The minimum seat requirement will not apply to summer classes.
- Attention to cost will be balanced by a closer focus on student outcomes. As indicated in the memo, we are considering performance-based models that will include incentives for exceeding targets.
Adjustment 2: After applying the 40% adult education need, 10% adult education demand, and 50% historical funding methodology, in order to mitigate extreme shifts in funding levels within a local workforce area, ACLS will apply an additional "hold-harmless" provision and will endeavor to prevent any local workforce area from losing more than 15% of its funding, assuming level funding across the system for the FY19-22 funding cycle. In Table 1 posted in the regional open and competitive request for proposals (RFP), the workforce area allocations were calculated by applying the percent shares (column S in the attached Excel worksheet) based on the new funding methodology to distribute the estimated $28,000,000. Then allocations were compared to FY18 percent shares (column O) of $28,000,000. Areas that realized a relative percent change of more than -15% were adjusted to 85% of the FY18 percent shares of $28,000,000. Areas that realized relative increases under the new methodology were adjusted downward slightly to support the "hold harmless" provision. This is a one-time intervention and any increases during the FY19-22 funding cycle will be distributed based primarily on adult education need. Programs should expect that the next contract cycle beginning in FY23 will be based on an allocation formula that fully phases out historical funding pattern. Despite the relative stability of a multiyear cycle, adult education is always subject to variability due to changes in state and federal appropriations. The allocation information in the RFP, therefore, should be considered estimates only.
Adjustment 3: When granting FY19 awards, ACLS reserves the right to adjust local workforce area allocations based on local need and provider capacity within the seven workforce planning regions and to adjust allocations within individual workforce areas based on the communities' need for ABE and ESOL services.
Summary of Feedback and Responses
Local Workforce Allocation Methodology
Issue #1: More context needed on the proposed allocation methodology
Response: WIOA requires states to compete adult education grants by workforce area. For all three variables: need for adult education, demand for service, and historical funding, workforce area data were numerators and statewide data were denominators. In the worksheet, the three variables are weighted, under the "Workforce Area Weighted Percentages Variables and Proposed Allocation Percentages" section, Berkshire's percent of the statewide allocation would be 1.87% [(1.14% x 0.40) + (0.83% x 0.10) + (2.67% x 0.50) = 1.87%] of statewide funding. However, while ACLS is committed to a data driven methodology that allocates resources primarily based on need, we also recognize the challenges brought about sudden shifts to the system. The "hold harmless" provision described above is our strategy to mitigate disruption. The proposed allocation methodology applies to adult education services (e.g., community adult learning centers (CALCs), including integrated education and training (IET) and integrated English literacy and civics education (IELCE) models) that ACLS will compete regionally for the cycle starting in FY19. Adult education in correctional institutions (AECI), primary instruction by volunteers (PIV), distance learning (DL) hubs, and the System for Adult Basic Education Support (SABES) will be competed statewide.
Issue #2: Data sources and how ACLS determined the percentages
Response: The primary variable was educational need based on data from the 2015 American Community Survey (ACS) Five Year Estimate for each of the 16 workforce areas (ACS does not provide data by MA workforce area; ACLS had to 'roll up' data for all towns in each area). ACLS compared each area's need to that of the state and calculated the percentage as shown in the "Need for Adult Education" section of the attached table (e.g., in the Berkshire workforce area, there are 11,583 adults without a high school credential and/or identified as limited English proficient. Across the Commonwealth there are 1,016,427 adults without a credential or in need of ESOL instruction. The Berkshire need is 1.14% [11,583 ÷ 1,016,427 = 0.0114]). ACLS assigned a weight of 40% to this variable when determining each area's allocation.
Issue #3: Many students leave communities for services in other workforce areas because of work or transportation. Reallocating based on residence (ACS) would move resources away from where they are needed and commit them to areas without demonstrated capacity to provide adult education services.
Response: While there is evidence that a significant number of students from other workforce areas attend Boston programs, it is unclear that they would prefer these programs over programs in their own communities if they existed. ACLS would need more compelling evidence to assign less than 40% to ACS need. In addition, we analyzed the non-resident enrollment of other Greater Boston area programs with access to public transportation (e.g., Malden and Somerville), which yielded significant percentages of non-resident students enrolled. See adjustment #3 above.
Issue #4: Please provide context for this variable
Response: Because need for adult education is not the same as demand, ACLS considered data available in SMARTT, average monthly enrollment and average monthly waitlist (September to June). After removing duplicates at the provider and workforce area levels, ACLS determined each area's demand for adult education services. ACLS compared each area's demand to the total state demand (see the "Demand for Adult Education," column M).
Issue #5: Regarding the use of enrollment and waitlist data to demonstrate demand for services, one response indicated that this variable should be weighted more heavily because the data indicated that demand exceeded capacity and the need for increased funding. Another respondent, however, expressed concern about incorporating waitlist information into the formula citing that programs use the waitlist differently and that even though ACLS requires grantees to maintain accurate lists, many programs do not remove applicants which inflates the numbers.
Response: ACLS analysis considered waitlist duplication and enrollment within a region. ACLS proposed a lower weight of 10% for "demand" data (i.e., enrollment and waitlist data) in the allocation methodology due to the recognized need to establish statewide standards for the reporting/maintenance of waitlist data, a technical challenge to be tackled in the next contract cycle. Providers suspected of falsifying or providing misleading data risk audits and reduction or termination of grants.
The FY18 Funding (column O) in the attached table shows the third variable, historical funding, factored into the methodology. As with Need and Demand, the percent share is each area's FY18 allocation divided by the statewide allocation. This variable receives the greatest weight, 50%, in the methodology.
Issue #6: A sudden reduction in one area's allocation would result in fewer students being served; could ACLS weight the historical variable more heavily for FY19 and decrease the weight each subsequent year, similar to One Stop Career Center (OSCC) funding?
Response: When developing the methodology, ACLS had considered this strategy but concluded that asking providers to develop multiyear budgets based on a shrinking or growing allocation would cause too much turbulence. The benefits of stable, multiyear grants outweigh the challenges brought about by an initial shift in resources.
Issue #7: Consider specific town-level data instead of workforce area data because in large, diverse areas, the needs of communities can be masked; rural areas are competing with urban areas for resources.
Response: In a limited-resource environment, ACLS must commit funding to serve as many students as possible across workforce areas. The methodology values the number of adults in need; however, a higher percentage is applied to historical funding levels. Moreover, we are committed to access in rural communities.
Issue #8: Stakeholders from areas that would experience a relative decrease shared concerns about the consequences of a sudden shift to the provider landscape and to services where adult education is almost entirely dependent on state funding.
Response: ESE recognizes the impact that this methodology would have on areas with significant decreases in funding. See adjustment #2 above.
Program Funding Methodology
Issue #9: Questions about per annualized seat, managed enrollment, and the minimum of 50 students
Response: Per annualized seat is a seat filled by one, unique and unduplicated student. Providers should develop policies that best support their students and promote outcomes. ACLS recognizes that enrollment may drop toward the end of a cycle. However, persistently under-enrolled programs contribute to cost inefficiencies. AECI programs also need to have a minimum of 50 student seats.
Issue #10: An incentive for programs serving GLE 0-3; these classes are often under-enrolled
Response: ACLS is motivated to set targets and incentives that reward outcomes. However, we do not want to create "creaming" conditions (i.e., enrolling easier-to-educate students) conditions. ACLS recognizes that adults at basic skill levels require more resources and intends to reward programs that demonstrate the ability to retain and support these students in making progress.
Issue #11: Intensity and outcomes
Response: ACLS reviewed the correlation between intensity (e.g., hours per week), average attended hours, and outcomes. Though counterintuitive, there does not appear to be any strong relationship between intensity and outcomes. It is important not to confuse intensity with persistence (i.e., a student enduring and completing a course of study), which may have a stronger relationship to outcomes than intensity alone. Accordingly, ESE is allowing a range of flexibility on class intensity and design, with a focus on outcomes over structure. ACLS acknowledges that there is a need for intensive 20-hour classes, and programs that plan to offer intensive services like this can provide a rationale and request a higher rate for these services. ESE is planning a rigorous evaluation of design and the relationship to outcomes in the next funding cycle.
Issue #12: Concern about 25% administrative cost and "off the book" match
Response: 70% of line 1 and related fringe will contribute to admin cost. Capacity is important but not the only factor that will be considered to assess ability to provide high-quality programming. ACLS strongly encourages partnerships between organizations to promote a variety of effective designs while keeping admin costs low. See Indicators of Program Quality and 13 WIOA Considerations.
Proposed changes to Outstationing Services and Adult Career Pathways
Issue #13: Outstationed staff, rural programs, and already-established community connections
Response: Outstationed staff are required to serve all programs within an area. Scheduling and other expectations for outstationing should be articulated in the local Memorandum of Understanding (MOU).
Issue #14: Funding for Adult Career Pathways (ACP)
Response: Funds currently supporting ACP services will support workforce area CALC, IET, and IELCE services.
Issue #15: Classes/initiatives and bridge programs
Response: The ACP funds will be part of the CALC, IET, and IELCE funding and can support bridge classes offered at the CALC that support students' transition to postsecondary education and/or training. ACP programming is encouraged to be continued and supported with CALC funds as it prepares adult learners for career pathways.
Issue #16: Concerns over the elimination of ACP programs, balancing intensity and non-intensive programs, and being responsive to clients served within the overall workforce system
Response: ACLS hopes that partners in all regions are similarly committed to meeting the needs of learners, especially those in the workforce. We encourage workforce development board (WDB) directors to engage with CALCs to design programs to meet the needs of workforce areas. If there is a need for intensive services in an area, that need should be articulated in local plan packages and MOUs. In addition, ACLS will be funding IET models in each workforce area to emphasize the importance of accelerated models that combine education and training and result in industry-recognized credentials and employment and/or postsecondary outcomes. Support of the local WDBs will be instrumental to the success of programs as they design services that support career pathways identified in their local area.
Issue #17: WDBs held to expectations in the memo
Response: ACLS will develop an MOU with WDBs that will list the range of supports for adult education programs.