Utah Reauthorization Project
P. O. Box 270090   Fruitland, UT   84027-0090
(435) 548-2630   FAX (435) 548-2438
wrw@ubtanet.com    www.slcap.org/UREAP/ureap.htm


April 21, 2003

Congressman Jim Matheson
410 Cannon Building
Washington, D.C. 20515

Re:  HR 1261, "Workforce Reinvestment and Adult Education Act of 2003"

Dear Congressman Matheson:

We understand that you and your fellow members of the U.S. House of Representatives will vote on HR 1261, "Workforce Reinvestment and Adult Education Act of 2003" shortly after you return for the Easter recess. This bill is intended to reauthorize the "Workforce Investment Act (WIA) of 1998." The Utah Reauthorization Project (UREAP) is writing to convey some of our ideas regarding Workforce Investment Act (WIA) Reauthorization at this time. UREAP's official membership includes 28 entities with a broad variety of experience and expertise and has statewide coverage (listed below). Over 400 people receive information through an email list and a website (http://www.slcap.org/UREAP/ureap.htm) and, in turn, share it with others in their organizations. Input into UREAP's activities and communications is accomplished via the email list and monthly meetings.

We believe that some provisions of this bill are positive and will solve very real problems inherent in the 1998 WIA Law and have discussed those provisions, among others, in the attached Comment we submitted to the House Committee on Education and the Workforce prior to its mark-up of the bill. In this letter to you, though, we will focus more on troubling provisions of HR 1261, including serious funding issues, and suggest areas where we would ask that you support positive amendments to correct those problems. We will begin by indicating where funding might be found to ensure that the existing WIA programs are able to be effective in addressing the needs of job seekers and employers through a better developed workforce.

Funding for the Personal Reemployment Accounts program better used for existing WIA programs

The Administration proposed and HR 1261 originally included Sec. 113 which would have established a temporary program of Personal Reemployment Accounts (PRAs), described as an effort to help people who have lost jobs and qualify for Unemployment Insurance (UI) to find new jobs more quickly than they otherwise might. HR 444 "Back to Work Incentive Act" has been introduced to implement this idea, as well. The House Committee on Education and the Workforce deleted the PRA program during mark-up, but it remains an important issue.

The concept of PRAs appears to have attractive aspects when viewed by itself (as in HR 444). UREAP greatly appreciates the Administration's willingness to spend $3.6 billion in new money to help unemployed people find work and it's hope that, by doing so, the economy will be stimulated. However, when viewed in the context of the entire WIA system, it is important to address this proposed change as a funding issue, as well as an ambitious program change in its own right. Implementing the program established by HR 444 (and formerly included in HR 1261) commits $3.6 billion to a new, largely untested, and short-term (two year) program at a time when other WIA programs are already underfunded or suffering proposed funding cuts or both. We also do not see Personal Reemployment Accounts as the most effective way to stimulate the economy. (Please see the attached UREAP Comment for a full discussion of our views on this issue.)

We therefore urge you to resist any attempt to reintroduce language establishing the Personal Reemployment Account (PRA) program concept in HR 1261 when it reaches the Floor. We also urge you to vote against HR 444 "Back to Work Incentive Act" when that bill comes to the Floor. As you will see below, we recommend that the original $3.6 billion that would be freed up by rejecting PRAs would be far better spent by adequately funding existing WIA programs and services. With any funds that may remain after that, we recommend that additional weeks of UI be provided to those who have exhausted state and federal unemployment benefits or that eligibility for unemployment be expanded to cover additional groups, such as people who had unemployment insurance paid on their behalf, but who did not qualify for benefits because they only worked part-time or for short periods. Consideration should also be given to providing assistance to unemployed workers in paying COBRA premiums.

We will now turn to our key concerns with HR 1261, as currently written.

Youth WIA Programs should be fully funded and state flexibility retained

HR 1261 would maintain cuts to WIA Youth programs that began in FY2000, but it compounds the problem created by underfunding by vastly reducing the ability of states to decide which at-risk youth to serve. The flexibility in the 1998 law is lost as HR 1261 mandates that two-thirds of funding be spent on out-of-school youth, leaving little to help at-risk youth stay in school. Also lost is the ability of states to focus on prevention. If it is thought that more focus is needed on out-of-school children than is currently being given by states, the Adminstration and Congress should find a better way to send that message than to mandate that states turn away from in-school children. 

We therefore urge you to support an amendment that would delete this funding restriction--the current law should be left as is, allowing states to spend from 30 to 70 percent on out-of-school youth.  Additionally, there is need to devote more resources to services to support all vulnerable children. We urge you to support increased funding for  WIA Youth programs, for example by diverting money from that designated as available to fund Personal Reemployment Accounts.

Funding for One-Stop Career Center Operations should be funded, but not by taking money from partner programs

UREAP agrees with the sponsors of HR 1261 that WIA reauthorization should create a way to fund the cost of the One-Stop system's operations. Failure in the current law to provide a means to support this centerpiece of the workforce investment system defined in WIA can only be considered an oversight. However, mandating contributions by One-Stop partners, the solution proposed by HR 1261, threatens to result in reduced services to job-seekers offered by the various partner entities,. Notably, a number of entities serving people with disabilities are to be added as partners and many interpret the law to mean that these, too, will be assessed.

We therefore urge you to work to delete the funding mechanism for One-Stop Center Operations in HR 1261 and to support the diversion of funding to that purpose from monies designated as available to fund Personal Reemployment Accounts.

Block Granting WIA Adult, Dislocated, and Wagner-Peyser funding streams will jeopardize services

UREAP counsels against block granting WIA Adult, WIA Dislocated Worker, and Wagner-Peyser funding streams. Consolidation of these three programs into a block grant was justified by the Administration as a means to facilitate transferability of funds and to increase collaboration and integration of services. This is an area of this newly implemented system that is best left as is until there is clear evidence that a problem exists. Block granting is likely to jeopardize funding for program areas that are already suffering cuts upon earlier cuts. Block granting also stands likely to reduce accountability for ensuring that various groups of vulnerable adults are served, including TANF parents, people with disabilities, migrant and seasonal farmworkers, immigrants, and Native Americans not living on Reservations.

We therefore urge you to resist the block grant provision in HR 1261 and support any effort to resolve funding shortfalls that may motivate this move by diverting funding from that designated to be available to fund Personal Reemployment Accounts.

Adult Education performance measures should reflect its educational mission, not that of employment services

The importance of Adult Education and Literacy activities to people in need of services encompassed in the Workforce Investment Act is without question. Congress, in 1998, saw fit to signify that importance by incorporating the Adult Education Act into WIA as Title II and making Adult Education a mandatory partner. It is critical during the reauthorization of WIA to make positive refinements, if needed, to the way Title II and the other Titles in WIA interface. Conversely, Congress should exercise caution against making changes that may conflict with the mission of or otherwise jeopardize the Adult Education system. Specifically, we question the wisdom of assigning performance measures to Adult Education--whose mission is raising skills and proficiency--that are traditional for an employment system such as placement in jobs, job retention, and increased wages.

We therefore ask that you support positive relationships between the WIA system and its partners, including the Adult Education system, be fostered by identifying common ground, but without disrupting the mission of any of the involved entities and without reducing funding for services to people. Please support any amendment that would retain existing, education-related performance measures for Adult Education activities.

There is one very important positive change to the 1998 WIA law included in HR 1261 that we wish to underscore here.

Barriers to Intensive and Training Services should be removed through WIA reauthorization

The primary objective of the Workforce Investment Act should be enabling displaced and disadvantaged people to obtain training to prepare themselves for employment at family-sustaining wages. The current, "sequential eligibility" configuration in the 1998 WIA Law has had the lamentable effect of thwarting that objective. "Work-First" is the short name for this configuration, whereby a job-seeker has been allowed to obtain "intensive services" or "training" only when he or she has been "unable" to find work via "core services." HR 1261 takes a very positive step by allowing the receipt of intensive services or training if the jobseeker is deemed to be "unlikely" to find "suitable" employment without them (Sec. 112). Even with less vulnerable job seekers, the lock-step approach does not work, but for low-skilled workers the result of the "Work-First" directive has too often been that they obtain a bad job and are counted as a "success," even though these jobs nearly always lack essential benefits and fall far short of self- or family-sustaining employment. We believe that the Work-First approach in the current law is one of the major reasons for a dramatic reduction in the number of people who have received training under WIA as compared with under the previous job training system, the Job Training Partnership Act (JTPA). (Recent analysis of PY2000 WIA services done by the Center for Law and Social Policy reveals that the number of adults receiving training under WIA dropped to 41,933, whereas 138,739 adults were trained under JTPA in its PY1998; 42,426 dislocated workers were trained under WIA in PY2000, whereas 126,953 were trained under JTPA in PY1998.) It is no wonder that the Department of Labor has found that states have not unexpended all of their WIA training funds, as jobseekers have been statutorily prevented from accessing the more helpful, and also more expensive, services they undoubtedly needed.

We therefore support HR 1261 provisions that will effect greater flexibility in the delivery of core, intensive, and training services, and applaud acknowledgment, via insertion of the word "suitable" before "employment," of the need for system goals to support work with out-of-poverty wages. This is not the total solution, hence we urge you to be watchful for and supportive of an amendment that would change this part of the 1998 law even more effectively.

WIA reauthorization is a matter of great concern to Utah. Our misgivings about the abovementioned problems in HR 1261 are such that, on balance, the bill as currently written, is substantially flawed. We have stressed our hope that you will support amendments to correct various shortcomings in the bill that we believe will be damaging to Utah jobseekers. We find it necessary to ask you to oppose the bill if it cannot be made more positive via amendments.

We appreciate this opportunity to share our initial views on HR 1261 with you and thank you for the work you do for Utah's more vulnerable citizens.

Sincerely,

Shirley Weathers and Bill Walsh, UREAP staff
Walsh & Weathers Research and Policy Studies
P. O. Box 270090
Fruitland, UT 84027-0090
(435) 548-2630
FAX: (435) 548-2438
wrw@ubtanet.com

for the Utah Reauthorization Project and its members:
 
Active Re-Entry, Price, (Southeastern Utah)
Box Elder Family Support Center, Brigham City, (Box Elder County)
Bringing Hope to Single Moms Foundation, Logan, (Cache and Box Elder Counties)
Community Action Services, Provo, (Utah, Wasatch, and Summit Counties)
Disabled Rights Action Coalition (DRAC), Salt Lake City, (statewide)
Family Support and Children's Justice Center of Carbon and Emery Counties, Price
Housing Authority of Salt Lake City, Salt Lake City, (Salt Lake City)
International Rescue Committee, Salt Lake City, (statewide)
JEDI for Women, Salt Lake City, (statewide)
League of Women Voters of Salt Lake, Salt Lake City, (Salt Lake County)
Legislative Coalition for People with Disabilities Salt Lake City, (statewide)
Mental Health Association in Utah, Salt Lake City, (statewide)
Multiple Sclerosis Society, Salt Lake City, (statewide)
New Hope Refugee and Multicultural Center, Salt Lake City, (Salt Lake City)
Options for Independence, Logan, (Northern Utah)
Peace & Justice Commission, Catholic Diocese of Salt Lake, Salt Lake City, (statewide)
People Helping People, Salt Lake City, (Salt Lake County)
Salt Lake Community Action Program (SLCAP), Salt Lake City, (Salt Lake and Tooele Counties)
Tri-County Independent Living Center, Ogden (Weber, Davis, and Morgan Counties)
United Way Executive Directors Association (UWEDA), SLC, (Salt Lake County)
Utah Children, Salt Lake City, (statewide)
Utah Community Action Program Association (UCAPA), (statewide)
Utah Issues, Salt Lake City, (statewide)
Utahns Against Hunger, Salt Lake City, (statewide)
Ute Tribe Social Services, Ft. Duchesne
Valley Mental Health, Salt Lake City, (Salt Lake and Tooele Counties)
Walsh & Weathers Research and Policy Studies, Fruitland
Your Community Connection, Ogden, (Weber County)

For more information about UREAP, including correspondence with Utah's Congressional Delegation and other elected officials, we invite you to visit our website at www.slcap.org/UREAP/ureap.htm. There are also links to Utah and national research at that site.