Comment on FR Doc # 2011-03536

Exempting WIA programs from this requirement goes against everything that is intended to be accomplished for this group. While the JVSG grant in and of itself is separate from WIA funding, the reality is that the acronym VETS contains the term "Training". Aside from the VERY few states that receive funding for a VWIP grant, VETS offers no training. By design, the entire JVSG grant is supposed to be a "full partner" of the Workforce system. Exempting WIA (the ONLY system partner that has funding for training) will only serve to continue the current pattern of systemically excluding veterans from this benefit because they are "too hard to serve". How does exempting this funding stream further support "Priority of Service"? The answer to that is that is that it does not. The only way to ensure WIA provides priority of service to veteran clients and does not systemically exclude them (as is the current practice) is to require them to report and meet on the same performance measures as the Workforce System does. This means mandating that they work with and report their numbers of Veterans, Disabled Veterans, Homeless Veterans, Transitioning Service Members, and Other Eligibile Persons. WIA programs should be required to negotiate (and meet) the exact same performance measures as the JVSG grant recipients.