This letter is in response to the invitation for comment on the proposed rule concerning the unified national threshold entered employment rate for veterans, Regulatory Information Number 1293-AA18.
Let me first emphasize that the Washington State Employment Security Department (ESD) supports measuring performance to improve outcomes for veterans who enter the One-Stop system. Our comment relates specifically to how this proposed rule will impact the corrective action plan process:
Under the proposed rule, each of the states and the Department of Labor would be limited to looking at two-year-old data when evaluating the effect of any corrective actions. The conditions of Jobs for Veterans State Grants (JVSG) require annual performance negotiations. If a state is required to take corrective action, how would the two-year time lag impact those annual performance negotiations? We ask that the Department of Labor clarify this issue.
If you need additional information, please contact Eu-wanda Jenkins, assistant commissioner, at the contact information provided.
Sincerely,
Eu-wanda Jenkins
Assistant Commissioner
Comment on FR Doc # 2011-03536
This is comment on Proposed Rule
Uniform National Threshold Entered Employment Rate for Veterans
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