Comment on FR Doc # 2011-03536

Exempting WIA from this requirement continues to allow that program to operate with no meaningful way of measuring its contribution in achieving the States’ performance in assisting veterans’ employment needs. It would also have the effect of undermining any positive accomplishments achieved through the publication of the final rules on Priority of Service (PoS). This proposed exclusion of WIA will only continue a “status quo” that allows the program to avoid any specific performance measure with regard to veterans. By comparison, the labor exchange system (through the JVSG Grant) has six performance measures specific to veterans. Adding JVSG Grant based measures, there are no less than 12 measures that serve the purpose identifying a performance standard and meeting that goal. Adding another measure to a program that already has a dozen does nothing to improve the outcomes. Furthermore, how can exempting the WIA program from any performance measure specific to veterans provide an increase in performance? Given the vast difference in state economies, it is extremely unlikely that any “national threshold EER” would be effective. Additionally, since the labor exchange system already has numerous performance measures (negotiated individually state by state) the purpose of a national measure can be achieved by an average of all states. Such a measure will at least be generally reflective of the nation as a whole, although it would by nature need to be a “hold harmless” measure for purposes of determining an individual state’s performance. If any additional performance standards are to be implemented, they should outcome based (entered employment rate, and employment retention rate) and also include the total number of veteran clients served through the WIA Adult, Dislocated Worker, and Youth programs. As with labor exchange and JVSG, these should be negotiated state by state.