SUPPORTING STATEMENT for OMB REINSTATEMENT AND APPROVAL
UNDER THE PAPERWORK REDUCTION ACT OF 1995, OMB 1205-0469
PART A – JUSTIFICATION
This is a justification of the Employment and Training Administration’s (ETA) request for 3-year approval to reinstate and extend the existing Workforce Investment Streamlined Performance Reporting (WISPR) reporting system. If they opt to use this system, states adopting the WISPR system consolidate and replace the reporting and recordkeeping requirements of 7 individual workforce programs within adopting states. These programs are the Employment Service (ES), Jobs for Veterans State Grants (DVOP/LVER), the Workforce Investment Act (WIA) Title IB Adult, Dislocated Worker, and Youth, Trade Adjustment Assistance (TAA), and National Emergency Grants (NEGs). To date, two states, Pennsylvania and Texas, also originally demonstration states, have implemented the WISPR system. Attachment A provides a list of the reports and record submissions to be replaced by the WISPR system.
In July 2004, the Department of Labor, Employment and Training Administration (ETA) solicited comments from the general public on the establishment of a single, streamlined reporting and recordkeeping system, formally called the ETA Management Information and Longitudinal Evaluation (EMILE) reporting system. EMILE was designed as a comprehensive reporting structure featuring a single quarterly report format and establishing a common language to standardize data collection for program participants and employer customers. These standardized individual records included information on demographic characteristics, type of services received, and a set of common measures of outcomes defined consistently across all programs.
The proposed EMILE reporting system was designed to replace the current data collection and reporting requirements for the following 12 ETA programs: Wagner-Peyser Act Employment Service (ES), Jobs for Veterans State Grants—Disabled Veterans’ Outreach Program (DVOP) and Local Veterans’ Employment Representative (LVER) programs, Workforce Investment Act (WIA) Title IB Adult, WIA Title IB Dislocated Worker, and WIA Title IB Youth programs, National Emergency Grants (NEG), Trade Adjustment Assistance (TAA), National Farm Worker Jobs Program (NFJP), Indian and Native American Program (INA), Senior Community Service Employment Program (SCSEP), H-1B Technical Skills Training grants (H-1B), and the Responsible Reintegration of Youth Offenders (Youthful Offenders) Program.
ETA received comments from 166 unique entities, representing a variety of voices from across the nation’s workforce system. ETA reconciled these public comments and made appropriate modifications to the original EMILE, which was re-named the Workforce Investment Streamlined Performance Reporting (WISPR) system.
In February of 2006, ETA implemented the use of common performance outcome measures. The impetus for this action was to facilitate meaningful cross-program comparisons of the performance of the various workforce development programs. These measures are now an integral component of ETA’s performance accountability system. The value of common measures is that it provides ETA with the ability to describe in a similar manner the core purposes of the workforce system - how many people found jobs; did people stay employed; and did earnings increase.
The common measures are the key results that ETA programs strive to achieve for their customers, and that ETA and OMB are interested in measuring. However, many of the states recordkeeping systems that are currently in place provide information on a program by program basis. As a result, the full picture of the suite of services provided to any given individual is not provided in any non-WISPR report, as the programs are reported separately. Furthermore, individuals served in multiple programs are reported more than once (once for each program they are enrolled in). The consolidated nature of the WISPR system would address this situation.
The need for a comprehensive and standardized reporting system was also underscored by reviews conducted by external oversight agencies, including the Department’s Office of Inspector General (OIG) and the Government Accountability Office (GAO). These oversight agencies have questioned the validity and comparability of data reported by ETA to Congress.
To address these issues, ETA proposed (October 2008) using its statutory and regulatory authority to redesign and strengthen its various program performance reporting systems into a single comprehensive system, formally called the WISPR system, with the intention of replacing the current reporting requirements of 7 ETA programs, which produce 11 separate quarterly reports and record submissions.
ETA had initially proposed a phase-in of the new WISPR system beginning in July 1, 2009 (i.e., the start of Program Year 2009). However, the challenge posed by the significant role the workforce investment system had to play in the President Obama’s economic recovery plan led ETA to reevaluate the immediate phase-in of WISPR in March of 2009.
Due to this reevaluation, full national implementation was suspended for Program Year (PY) 2009 and beyond. Rather ETA’s top priority became working with partners and stakeholders to meet the information and reporting needs associated with implementation of the American Recovery and Reinvestment Act (ARRA). Those states that were currently serving as WISPR demonstration states were instructed to continue to report using the WISPR system. States that were not demonstration states, but were prepared to begin full implementation on July 1, 2009, were encouraged to work through their Regional Administrator to coordinate implementation with ETA’s national office. However, to date, only two demonstration states, Pennsylvania and Texas, are reporting using the WISPR system. The rest of the states have not opted into this reporting system.
As a result of the immense challenges associated with operationalizing ETA’s responsibilities under ARRA, as well as the current budgetary environment both nationally and especially at the state-level, ETA no longer plans to impose the implementation of WISPR across the nation at this time. However, ETA still seeks to transition to WISPR via an “opt in” process. In addition, ETA still maintains its statutory and regulatory authority to require the WISPR performance reporting format for states and grantees should it elect to do so in a better economic environment. Listed below are the legal and/or administrative requirements that permit ETA to mandate the collection and reporting of data through the proposed WISPR reporting system. A copy of the exact statutory or regulatory provisions can be found in Attachment B.
Wagner-Peyser Employment Service and Jobs for Veterans State Grants
A. Wagner-Peyser Act sec.3(a), 29 U.S.C. 49b(a)
“The Secretary shall assist in coordinating the State public employment services throughout the country and in increasing their usefulness by developing and prescribing minimum standards of efficiency, assisting them in meeting problems peculiar to their localities, promoting uniformity in their administrative and statistical procedures, furnishing and publishing information as to opportunities for employment and other information of value in the operation of the system and maintaining a system for clearing labor between the States.”
B. Wagner-Peyser Act sec. 3(c), 29 U.S.C. 49b(c)
“The Secretary shall –
(2) assist in the development of continuous improvement models for such nationwide system that ensure private sector satisfaction with the system and meet the demands of job seekers relating to the system.”
C. Wagner-Peyser Act sec. 7(b), 29 U.S.C. 49f(b)
“Ten percent of the sums allotted to each State pursuant to section 49e of this title shall be reserved for use in accordance with this subsection by the Governor of each such State to provide –
(1) performance incentives for public employment service offices and programs, consistent with performance standards established by the Secretary, taking into account direct or indirect placements (including those resulting from self-directed job search or group job search activities assisted by such offices or programs), wages on entered employment, retention, and other appropriate factors.”
D. Wagner-Peyser Act sec. 10(c), 29 U.S.C. 49i(c)
“Each State receiving funds under this Act shall –
(1) make such reports concerning its operations and expenditures in such form and containing such information as shall be prescribed by the Secretary, and
(2) establish and maintain a management information system in accordance with guidelines established by the Secretary designed to facilitate the compilation and analysis of programmatic and financial data necessary for reporting, monitoring and evaluating purposes.”
E. Wagner-Peyser Act sec. 13(a), 29 U.S.C. 49l(a)
“The Secretary is authorized to establish performance standards for activities under this Act which shall take into account the differences in priorities reflected in State plans.”
F. Wagner-Peyser Act sec. 15(e)(2)(I), 29 U.S.C. 49l-2(e)(2)(I)
“(e) State responsibilities. –
(2) Duties. – In order to receive Federal financial assistance under this section, the State agency shall—
(I) utilize the quarterly records described in section 2871(f)(2) of this title to assist the State and other States in measuring State progress on State performance measures.”
G. Provisional Guidance on the Implementation of the 1997 Standards for Federal Data on Race and Ethnicity, Executive Office of the President, Office of Management and Budget (66 FR 3829-3831); and “Revisions to the Standards for Maintaining, Collecting, and Presenting Federal Data on Race and Ethnicity, (62 FR 58781-58790).
Workforce Investment Act Title I Programs
WIA section 136
Establishes the performance and accountability requirements for WIA Adult, Dislocated Worker, and Youth programs. The purpose of section 136 is to establish a comprehensive performance accountability system, comprised of the activities described in this section, to assess the effectiveness of states and local areas in achieving continuous improvement of workforce investment activities funded under this subtitle, in order to optimize the return on investment of Federal funds in statewide and local workforce investment activities (section 136(a)).
Further, section 136(d) outlines the minimum requirements for the WIA annual reports that states must submit to the Department of Labor. The annual reports must reflect:
The progress of the state in achieving state performance measures, including information on the levels of performance achieved by the state with respect to the core indicators of performance and the customer satisfaction indicator;
The progress of local areas in the state in achieving local performance measures, including information on the levels of performance achieved by the areas with respect to the core indicators of performance and the customer satisfaction indicator;
Information on the entry by participants who have completed training services provided under section 134(d)(4) into unsubsidized employment related to the training received;
Data on the wages at entry into employment for participants in workforce investment activities who entered unsubsidized employment, including the rate of wage replacement for such participants who are dislocated workers;
Information on the retention and earnings received in unsubsidized employment 12 months after entry into employment;
A description of performance with respect to the indicators of performance specified in WIA section 136(b)(2)(A) (core indicators of performance) of participants in workforce investment activities who received the training services compared with the performance of participants in workforce investment activities who received only services other than the training services (excluding participants who received only self-service and informational activities); and
A summary of performance with respect to the indicators of performance specified in WIA section 136(b)(2)(A) (core indicators of performance) of recipients of public assistance, out-of-school youth, veterans, individuals with disabilities, displaced homemakers, and older individuals.
Sections 172, 185, and 189 provide broad authority to the Secretary of Labor to address performance and accountability issues for all programs authorized under Title I. Section 136 specifically addresses performance and accountability for the WIA Adult, Dislocated Worker, and Youth programs.
WIA section 172
Directs the Secretary to provide for the continuing evaluation of programs and activities authorized under Title I, including demonstration grants. WIA section 172(a) specifies that the evaluations must address:
General effectiveness of such programs and activities in relation to their cost, including the extent to which the programs and activities improve the employment competencies of participants in comparison to comparably-situated individuals who did not participate in such programs and activities and, to the extent feasible, increase the level of total employment over the level that would have existed in the absence of such programs and activities;
Effectiveness of the performance measures relating to such programs and activities;
Effectiveness of the structure and mechanisms for delivery of services through such programs and activities;
Impact of the programs and activities on the community and participants involved;
Impact of such programs and activities on related programs and activities;
Extent to which such programs and activities meet the needs of various demographic groups; and
Such other factors as may be appropriate.
WIA section 185
Broadly addresses reports, recordkeeping, and investigations across programs authorized under Title I of the Act. The provisions of section 185:
Require the Secretary to ensure that all elements of the information required for reports be defined and reported uniformly (WIA section 185(d)(2));
Direct each state, each Local Board, and each recipient (other than a sub-recipient, sub-grantee, or contractor of a recipient) to prescribe and maintain comparable management information systems, in accordance with the guidelines that shall be prescribed by the Secretary designed to facilitate the uniform compilation, cross tabulation, and analysis of programmatic, participant, and financial data, on statewide, local area, and other appropriate bases necessary for reporting, monitoring, and evaluating purposes, including data necessary to comply with section 188 (WIA section 185(c)(2));
Require that recipients of funds under Title I of WIA shall maintain such records and submit such reports in such form and containing such information as the Secretary may require regarding the performance of programs and activities carried out under Title I of WIA (section 185(a)(2));
Compel states to submit to the Secretary, on a quarterly basis, a summary of the reports submitted to the Governor under WIA sections 185(e)(1) and 185(e)(2);
Specify that the reports shall include information about programs and activities carried out under Title I of WIA pertaining to:
Relevant demographic characteristics (including race, ethnicity, sex, and age) and other related information regarding participants;
Programs and activities in which participants are enrolled, and the length of time that participants are engaged in such programs and activities;
Outcomes of the programs and activities for participants, including the occupations of participants and placement for participants in nontraditional employment;
Specified costs of the programs and activities; and
Information necessary to prepare reports to comply with section 188 and 29 CFR Part 37 (section 185(d)(1) (a-e)).
WIA section 189
Requires the Secretary to prepare and submit to Congress an annual report regarding the programs and activities carried out under Title I of WIA. The report must include:
A summary of the achievements, failures, and problems of the programs and activities in meeting the objectives of WIA Title I;
A summary of major findings from research, evaluations, pilot projects, and experiments conducted under WIA Title I in the fiscal year prior to the submission of the report;
Recommendations for modifications in the programs and activities based on analysis of such findings; and
Such other recommendations for legislative or administrative action as the Secretary determines to be appropriate.
Trade Adjustment Assistance Act Program
20 Code of Federal Regulations (CFR) 617
The Trade Adjustment Assistance Reform Act of 2002 (P.L. 107-210) includes provisions that require each state agency to furnish to the Secretary such information and reports and conduct such studies as the Secretary determines are necessary or appropriate for carrying out the purposes of the Act (20 CFR 617.57 and 617.61).
The TAA Reform Act of 2002 reauthorizes the TAA program through fiscal year 2012, and amended certain provisions of the Trade Act of 1974 (19 U.S.C. 2317) resulting in the following changes to the TAA program:
Repealed NAFTA-TAA, consolidating that program into TAA (workers certified for NAFTA-TAA under petitions received before November 4, 2002, however, will continue to receive NAFTA-TAA services for as long as their eligibility lasts);
Expanded eligibility to more worker groups, increases existing services and benefits available and provides tax credits for health insurance coverage assistance;
Increased timeliness for benefit receipt, training and rapid response assistance;
Legislated specific waiver provisions; and
Established other TAA programs, such as the Alternative Trade Adjustment Assistance (ATAA) program for older workers.
ETA’s statutory and regulatory authority to administer job training and employment programs includes provisions for the collection of performance data. Non-WISPR states are currently required to produce separate performance reports using different forms, instructions and submission procedures for each grant. The WISPR data collection will replace the current reporting and recordkeeping systems of 7 ETA programs with a more streamlined reporting structure that will allow for consistent, comparable analysis across ETA-funded employment and training programs in states which implement it. Customers, employers, Congressional leaders and other stakeholders will benefit from the adoption of this reporting system by receiving information about the workforce system that is timely, integrated, and comparable across programs.
ETA and the Veterans’ Employment and Training Service (VETS) use the data to track total participants, characteristics, services and outcomes for job seeker and employer customers. More specifically, ETA and VETS analyze the data to determine the delivery of core One-Stop employment and workforce information services within the Workforce Investment Act (WIA) framework; to study performance outcomes vis-à-vis performance measures, and state policies and procedures; and to help drive the workforce investment system toward continuous improvement of outcomes and integrated service delivery. Within ETA, the data are used by the Office of Workforce Investment, the Office of National Response, the Office of Financial and Administrative Management, the Office of Policy Development and Research, and the Office of Regional Innovation and Transformation (including the regional offices). Other DOL users include the Office of the Assistant Secretary for ETA and the Office of the Assistant Secretary for Policy. The reports and other analyses of the data are made available to the states, members of Congress, veterans’ organizations, research firms and others needing information on public employment and workforce information services.
States and grantees will have to implement the WISPR recordkeeping and reporting requirements with available funds. However, the implementation of the WISPR reporting system will better organize employer and participant data that are already being collected and provide a more complete picture of the full set of services each customers receives. Attachment C contains the WISPR Data Preparation and Reporting Handbook that includes all the quarterly reporting formats and instructions as well as a full listing of the individual data elements that must be collected in the Workforce Investment Standardized Record Data (WISRD). At a minimum, information collected and reported through the quarterly reports and records will be used by state and local workforce investment areas and Federal agencies for the following purposes:
To provide program and performance information to stakeholders including participants, businesses, taxpayers, Congress, and others;
To continuously improve the quality, effectiveness, and efficiency of job training and employment-based programs to job seeker and employer customers;
To provide management information for use in Federal program administration and oversight, including grant-specific participation, service, and outcome summaries. Selected demographic information will also be used by grantees to demonstrate compliance with equal opportunity provisions in the law, and to prepare and maintain state management reports;
To administer incentives or sanctions for outcomes that exceed or fall short of negotiated levels of performance on the core measures;
Preparation and maintenance of consumer reports on eligible training providers; and,
To measure compliance with the Government Performance and Results Act (GPRA).
Under WIA section 136(d)(3), the Secretary is required to: (a) make the information contained in the annual reports available to the general public through publication and other appropriate methods, (b) disseminate state-by-state comparisons of information, and (c) provide the appropriate congressional committees with copies of such reports. In addition, information obtained through the WISPR system will be used at the national level during budget and allocation hearings, for DOL compliance with the GPRA and other legislative requirements, and during legislative reauthorization proceedings.
A.3 Technology and Obstacles Affecting Reporting Burden
In order to comply with the Government Paperwork Elimination Act, ETA is streamlining the collection of participant data and the preparation of quarterly performance reports by providing uniform data elements and data definitions to states, and through the use of technology. ETA is currently upgrading its data reporting and validation software (DRVS) to enable WISPR quarterly reports to be produced by ETA electronically via the Internet. Upon completion of the new DRVS, states will only be required to submit a consolidated individual record file to ETA via a web-based interface. All reports will be produced consistently by ETA using the state’s uploaded individual record files. However, it is left to the states and local areas to decide the best technology for collecting individual case management data given their unique circumstances and resource availability. At a minimum, states electing to implement WISPR will simply have to produce an “across program” consolidated (i.e. free from duplicate records) WISPR file (i.e. a WISPR WISRD). This must be accomplished at the state and local level as social security numbers are necessary for the across-program matching. The state must then replace the social security numbers in the consolidated file with non-sensitive unique ID’s.
The use of state UI wage records as the primary source of outcomes data on employment and earnings will ultimately result in decreased burden hours under the WISPR system, since grantees will be able to coordinate matching requests across programs by implementing integrated reporting. Furthermore, ETA will minimize respondent burden by continuing financial support for the operation and maintenance of the Wage Record Interchange System (WRIS), which provides for an efficient exchange of UI wage records among states to support federal performance reporting requirements. States and grantees are not charged any fees for using this automated follow-up system.
For states who currently submit individual records to ETA (e.g., WIA and TAA programs), the WISPR requirements should present little or no additional burden. However, states will need to convert from the TAPR and the WIASRD to the integrated individual record contained in the WISPR requirements (as alluded to above), but their electronic submission process will be streamlined. ETA has learned that states with no prior experience in building integrated reporting systems, particularly across WIA and ES programs, will experience a generally higher relative burden per participant record when compared to other states with more integrated case management systems. To address this burden, ETA is currently upgrading its data validation and reporting software for states that will import the raw data, check for data errors and out of parameter records, and produce all the quarterly summary reports and records in both printable and electronic data transfer formats.
The Department has minimized the reporting burden in the revised WISPR system by establishing the number of data elements required commensurate with the level of resources expended and services received for each program. A very limited number of items are required for those using self-services and informational activities and other staff-assisted core services. More items are expected for those receiving intensive, training, and other needs-related services from the WIA and TAA programs. For youth, state data collection is based on the age in which the individual enters the WIA Youth Program.
Data items beyond those collected by existing program reports and individual records are needed to: (1) account for the detailed services provided by multiple agencies to help participants get and keep good paying jobs; (2) better identify overlapping and unproductive duplication of services; (3) generate comparable performance information across ETA-funded programs; (4) generate statistics on self-help and core services which have not been measured before; (5) collect participant data that are not exclusive to those who leave ETA programs; and (6) readily identify and make program changes needed to reduce fraud, waste, and abuse. Information provided through the proposed WISPR system will not be available through other data collection and report systems.
The recordkeeping and reporting requirements contained in the WISPR system are addressed to state formula grant recipients and as such do not impact small businesses or other small entities.
Both the ETA and recipient states are mandated by various program-specific legislative acts, as well as the GPRA, to establish performance standards and make available reports concerning program operations and expenditures. The inability to utilize quarterly program performance data in order to develop strategies for continuous improvement could negatively affect workforce system performance, future Congressional appropriations, and individuals who benefit from services provided through these programs.
ETA’s responsibilities for reporting, oversight, and monitoring of these programs would be severely hampered because there is no other vehicle for judging program performance and participant outcomes. The WIA is very specific about reporting requirements and reporting frequency.
The Final Rule at 20 CFR 667.300(d) (65F.R. 49429 August 11, 2000), which governs the due date, states:
Financial reports and participant data reports are due no later than 45 days after the end of each quarter unless otherwise specified in reporting instructions. A final financial report is required 90 days after the expiration of a funding period or the termination of grant support.
Section 667.300(e)(1) contains the sanctions for failure to file timely annual reports:
A State failing to submit any of these annual performance progress reports within 45 days of the due date may have its grant (for that program or all title I, subpart B programs) for the succeeding year reduced by as much as 5 percent, as provided by WIA section 136(g)(1)(B).
Section 667.300(e)(2) continues with:
States submitting annual performance progress reports that cannot be validated or verified as accurately counting and reporting activities in accordance with the reporting instructions may be treated as failing to submit annual reports, and be subject to sanction. Sanctions related to state performance or failure to submit these reports timely cannot result in a total grant reduction of more than five percent. Any sanction would be in addition to having to repay the amount of any incentive funds granted based on the invalid report.
These data collection efforts do not involve any special circumstances.
A Pre-clearance Notice for sixty days’ public comment was published in the Federal Register on September 2, 2011 (Vol. 76, p 54792). One letter commenting on the request was received – from the State of Alabama’s Department of Industrial Relations, on October 28, 2011. The five comments shared in that letter are summarized in the matrix below with ETA’s responses to each.
Comment |
ETA Response |
“Ala DIR is already operating on a tight budget and the designing and implementation of this new reporting system would adversely impact services provided to job seekers and employers, and require reallocation of already stretched funds. It is understood that there is no new funding to address these costs.”
|
ETA is cognizant of the current budgetary environment. As such, full implementation of the WISPR system is optional at this time. However, ETA has requested the approval to collect this information from all States, Districts and Territories should any states opt to implement. Additionally, in the future ETA may decide to implement one or more of the reports that comprise the WISPR system so ETA is seeking approval. |
Comment |
ETA Response |
“There is no reference to Total Annualized Capital/Startup Costs in the FRN; and the estimated Total Annual Burden Cost for Respondents: $0 is completely unrealistic.”
|
Startup/capital costs are addressed in section A.12. Start-up costs are estimated to be approximately $127,327 per state. This represents an estimate of one and one-half full time equivalent staff persons per state at an hourly rate of $40.81. Multiplied by 52 states/territories (two have already incurred these costs) this yields a total national start-up/capital cost estimate of $6,621,014. The annual burden estimate for all states is approximately 968,438 hours and $39,521,939 as detailed in section A.12. The estimated cost has been calculated using an estimated hourly cost rate of $40.81 for State staff. Since the WISPR system applies to state formula grant recipients, administrative resources are provided as part of the grant to off-set staff costs associated with reporting and systems modifications. As such, there is no additional cost to respondents other than those reported in Section A.12 above.
|
Comment |
ETA Response |
“It is unclear the need for the individual exiter records required in WISRD. Current reporting does not require this level of detail and the need for other than aggregate numbers is not understood.”
|
Aggregate numbers are ultimately derived from individual records. As a result, the underlying individual records have to exist. Furthermore, many of the programs being integrated via WISPR are already collecting and reporting the individual record files (albeit separately).
Wagner-Peyser Employment Service and Jobs for Veterans State Grants are the only programs not currently submitting individual records. Submission of these records for data validation purposes is currently done but the current data validation software does not result in a rolled up national individual record file for Wagner-Peyser Employment Service and Jobs for Veterans State Grants participants. Under WISPR, ETA would receive an integrated individual record file on all participants served by the programs discussed in the supporting statement. This information would facilitate local, state, and federal program integration, as well as, enable better record keeping, programmatic policy analysis, and ultimately more transparency and accountability.
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Comment |
ETA Response |
“Based on the most recent count of exiters in the previous four quarters, individual exiter records for the Alabama Wagner-Peyser Employment Service and Jobs for Veterans’ State Grants alone would number 350,000 records every quarter. Each record requires at least 2,149 bytes (over 2 kilobytes), for an estimated submission of up to 752,000,000 bytes (over 717 Megabytes) each quarter. Our experience with Internet file transfers is that it can take about 3 ½ minutes to transfer a 7.4 Megabyte file (28+ seconds per megabyte). Extrapolating this to a 717 Megabyte file reveals an estimated transfer time of 330+ minutes (about 5 ½ hours).”
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The State of Alabama currently uploads a quarterly WIASRD file (individual records for the WIA Adult, WIA Dislocated Worker, and WIA Youth programs) containing 29,927 records (as of 9/30/2011). The upload time for the largest WIASRD file (1,756,680 records, well in excess of 350,000 records) is less than 10 minutes. The actual time it takes to sit in queue, to be uploaded, to run the file edit checks, and finally to produce an accessible error report is significantly longer (sometimes a number of hours depending on size of the queue). However, this processing is done on an external server and should in no way tie up State resources between file upload and receipt of submission confirmation or an error report. ETA continues to improve and upgrade its management information system (the Enterprise Business Support System (EBSS)) to decrease upload time.
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Comment |
ETA Response |
“While it is not explicitly stated, the implication is that this is to be implemented immediately in all states, DC and territories.”
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ETA has requested the approval to collect the WISPR system reports from all States, DC, and Territories. However, WISPR implementation in any given State is completely optional in this three-year request.
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There are no special payments to respondents other than the formula funds and incentive funds provided for in the authorizing statutes.
ETA is responsible for protecting the privacy of any WISPR system data and will maintain the data in accordance with all applicable Federal laws, with particular emphasis upon compliance with the provisions of the Privacy and Freedom of Information Acts. WISPR system data will not contain any individually identifying information (e.g., Social Security Numbers). States will submit participant-level records to the Department each quarter, but they will submit them using an individual identifier, which must not include the individual’s social security number.
There are no sensitive questions included in the proposed data collection.
The annual national burden for the WISPR system has two broad components:
Record keeping and reporting on job openings and employer services; and,
Record keeping and reporting on participant characteristics, services, and outcomes.
This response provides a separate burden for each component.
The burden estimate for record keeping and reporting on job openings and employer services consists of:
a. The burden of collecting data on job openings and employer services; and
b. The burden of preparing the Employer Services Reports for the Wagner-Peyser Employment Service, WIA Title I, and the Jobs for Veterans State Grants—DVOP/LVER programs (ETA Form 9131).
States must collect and maintain job opening and employer services data to generate the Wagner-Peyser Employment Service, WIA Title I, and Jobs for Veterans State Grants—DVOP/LVER programs’ Employer Services Reports. OMB previously approved an estimate for job order record keeping of one hour per state per quarter (OMB Number 1205-0001) for the data collection required to prepare the 9002 E report on job openings. Approximately three times as many data elements are required to prepare the Employer Services Reports, compared to the 9002 E report. Therefore, the state burden for collecting WISPR job opening and employer services data is estimated to be three hours per state per quarter. While ETA expects that 10 or fewer states/territories will opt to implement WISPR over the next three years without it being specifically mandated, the burden calculations (throughout this document) will remain to be based on assuming all 54 states and territories implement WISPR. As such, for 54 states and territories, the total annual burden estimate for job openings and employer services data is 648 hours (54 x 3 x 4 = 648).
States implementing WISPR will submit a single streamlined quarterly report that covers both the Wagner-Peyser Employment Service and WIA Title I programs, and a separate report for the Jobs for Veterans State Grants—DVOP/LVER programs.
The quarterly reporting burden includes program run times, checking, formatting, and transmitting the quarterly reports to ETA. Note that this function will be automated with the release of the new DRVS (currently under development) and so would render 0 burden hours for this report.
However, in the mean time, this estimate assumes that only some portion of states will use the existing ETA-provided software to generate the quarterly reports. The current OMB-approved burden (OMB No. 1205-0240) for preparing the 9002 E report is 20 hours per state per quarter for a report with 576 cells. The WISPR Employer Services Report has 132 cells (less than one-quarter the size of the 9002 E); the burden for preparing this report is estimated to be 8 hours per state per quarter. Therefore, the total annual reporting burden estimate for a Wagner-Peyser Employment Service or WIA Title I Employer Services Report is 1,728 hours for the 54 states/territories (54 x 8 x 4 = 1,728).
Generating the Jobs for Veterans State Grants—DVOP/LVER programs’ report would be an incremental, 25 percent increase over this amount regardless of the extent of state systems integration, because this report is a subset of the Wagner-Peyser Employment Service report. The reporting burden for the Jobs for Veterans State Grants—DVOP/LVER programs’ report is thus 1,728 x 0.25 = 432 hours per year. Note again, however, that with the release of the new DRVS, these reports will be generated by the system and the burden hours would be 0.
No data collection or reporting burden is estimated for the optional performance measures in Section D of the job opening/employer services quarterly report. Any state performance measures will be data entered.
As shown in the following table, the total annual burden estimate is 2,808 hours. As a point of comparison, the current OMB-approved burden estimate for 9002 E data collection and reporting is 4,536 hours for one-third the number of data elements but over four times the number of report cells.
Program |
Data Collection Hours Per Year |
Wagner-Peyser Employment Service/ WIA Title I Reporting |
Jobs for Veterans State Grants - DVOP/ LVER Reporting |
Number of Reporting States |
Annual National Hours |
Applicable Hourly Rate |
Annual National Quarterly Report Burden Dollars |
WISPR |
648 |
1,728 |
432 |
54 |
2,808 |
$40.81 |
$114,594 |
The burden estimate for record keeping and reporting on participant characteristics, services, and outcomes consists of:
The burden of collecting data on participant characteristics, services, and outcomes;
The burden of preparing the quarterly Workforce Investment Performance Report (ETA Form 9132); and,
Note that burden for this element would be 0 when the new DRVS becomes operational
The burden of preparing the quarterly Veterans, Other Eligible Persons, and Transitioning Service Members Services Report (ETA Form 9133).
Note that burden for this element would be 0 when the new DRVS becomes operational
The WISRD burden considers the amount of information collected and reported on the WISRD that would not have to be collected by the states as part of their customary and usual burden to run the program. Thus the burden reflects the information collected solely to comply with the WISRD/WISPR federal reporting requirements. The WISRD estimate also does not include the burden associated with collecting and reporting information required to meet EEO requirements, which is covered under a separate burden estimate.
The WISRD burden varies by participant based on the intensity of services provided and the number of WISRD elements applicable to the participant. For example, considerably more information is reported on WIA youth than WIA adults and collecting the youth literacy, numeracy, and skill attainment elements is more burdensome than collecting other types of data elements. On the other hand, web-based registrations and the use of wage records for measuring outcomes help to minimize the burden of data collection.
The WISRD data collection burden calculation uses a minutes per record estimate. The minutes per record estimate is derived from the count of WISPR data elements that are required for the record type, as well as the relative burden of collecting that data. For example, it is relatively time consuming to collect each WIA youth literacy, numeracy, and skill attainment element, and there are significantly more data elements that must be collected for WIA youth than for WIA adults. Therefore, youth exiter records have relatively higher minutes per record estimates.
As shown in the following table, the data collection estimate is 911,630 hours per year and $37,203,605. This assumes that all states/territories have integrated data collection processes across the programs, which is now necessary for WISPR reporting. Therefore, overlapping elements are unduplicated in the burden calculation for each program—the minutes per record estimate for each record type reflects the fact that when a data element is required for more than one record type, it will only be collected once for a given participant.
Record Type |
Annual 10 State Counts |
Hourly Rate |
Minutes Per Record |
Annual National Burden Hours |
Annual National Burden Dollars |
Adult, DW, NEG exiters |
1,660,547 |
$40.81 |
10.5 |
290,596 |
$11,859,212 |
Youth exiters |
119,969 |
$40.81 |
45 |
89,977 |
$3,671,951 |
ES participants |
15,016,436 |
$40.81 |
2.1 |
525,575 |
$21,448,726 |
TAA exiters |
60,910 |
$40.81 |
5.4 |
5,482 |
$223,716 |
Total |
16,857,862 |
|
|
911,630 |
$37,203,605 |
Annual counts correspond to PY 2009 for Adult, DW, NEG, Youth, TAA, and Wagner-Peyser Employment service exiters. The hourly rate for state-run programs is the average hourly earnings for employees in state Unemployment Insurance (UI) agencies in FY 2011 (as used for FY 2011 UI budget formulation purposes).
3. Quarterly Workforce Investment Performance Report (ETA 9132)
The WISPR quarterly report burden includes program run times, checking, formatting, and transmitting the quarterly ETA 9132 Workforce Investment Performance Reports to ETA (although this burden will be 0 when the new DRVS is operational). The report burden also includes preparation and submission of the state’s WISRD records. These estimates assume that some portion of states will use ETA-provided software to generate the quarterly report. The basic quarterly reporting assumption is that each state will spend 25 days or 200 hours per quarter on each performance report.
The actual performance reporting burden varies by the extent to which states have integrated reporting systems across the programs included in the WISPR system. In a departure from the previous collection, ETA now mandates integrated reporting systems under WISPR. As a result, this computation (as well as all others) assumes that all of the states/territories have integrated reporting systems (as is now necessary). As shown in the following table, the annual burden estimate is 43,200 hours.
Program |
Hrs. Per Year Per State |
Number of Reporting States |
Annual National Hours |
Applicable Hourly Rate |
Annual National Quarterly Report Burden Dollars |
WISPR |
800 |
54 |
43,200 |
$40.81 |
$1,762,992 |
4. Quarterly Eligible Veterans and Transitioning Service Members Services Report (ETA 9133)
The burden for the quarterly ETA 9133 Eligible Veterans and Transitioning Service Members (TSM) Services Report includes the local and state level tasks required to prepare and submit two reports each quarter from each state/territory on the number of veterans, other eligible persons, and TSM participants, as well as the types of services in relation to all other customers who receive services and are participating in the Wagner-Peyser Employment Service and Jobs for Veterans State Grants—DVOP and LVER programs (once again, the burden associated with creating the reports will be 0 when the new DRVS is operational). The two report submissions are described in further detail in the WISPR handbook. The reporting tasks include, but are not limited to, extracting data from states’ data systems for the applicable programs (this burden will remain even with the new DRVS), formatting reports, reviewing the accuracy of the reports, and transmitting the reports electronically to ETA. The burden estimate assumes that reporting efficiencies are achieved through the use of a standardized report format across these programs, and that a portion of respondents will use the existing ETA-provided software (the current DRVS) to generate the two quarterly reports. All information contained on these reports is readily available to the state without any unnecessary delays in data collection.
Because the two reports use the same report format and are derived from the same data set, the burden for generating the second report is an incremental increase over, rather than identical to, the burden for generating the first report. As detailed in the table below, the burden for Submission #1 is estimated to be 5 business days per state per quarter, or 160 hours per state per year. The burden for Submission #2 is estimated to be 25 percent of the burden of Submission #1, or 1.25 business days per state per quarter or 40 hours per state per year. Thus, the total burden for the two submissions for the assumed 10 WISPR states is 200 hours per state per year, or 10,800 annual national hours.
Report |
Hrs. Per Year Per State |
Number of Reporting States |
Annual National Hours |
Applicable Hourly Rate |
Annual National Quarterly Report Burden Dollars |
Submission #1: Wagner-Peyser Employment Service |
160 |
54 |
8,640 |
$40.81 |
$352,598 |
Submission #2: Jobs for Veterans State Grants—DVOP/LVER programs |
40 |
54 |
2,160 |
$40.81 |
$88,150 |
TOTAL: |
200 |
54 |
10,800 |
|
$440,748 |
The following table summarizes the annual national burden for record keeping and reporting for all of the WISPR system components:
WISPR System Burden Summary
Burden Component |
Annual National Burden (Hours) |
Annual National Burden (Dollars) |
1) Job opening/employer services data collection and reporting (ETA 9131) |
2,808 |
$114,594 |
2) WISRD data collection |
911,630 |
$37,203,605 |
3) Workforce Investment Performance Reports (ETA 9132) |
43,200 |
$1,762,992 |
4) Veterans, Other Eligible Persons, and TSM Reports (ETA 9133) |
10,800 |
$440,748 |
Total |
968,438 |
$39,521,939 |
Start-up/capital costs: WISPR data collection requirements are based extensively on existing data collection requirements for the WIA, Wagner-Peyser Employment Service, and TAA programs. To a lesser extent, the WISPR reports are based on existing reports for the WIA and the Wagner-Peyser Employment Service programs. States therefore have data collection and reporting mechanisms in place that can be modified to comply with the WISPR data collection and reporting requirements. The start-up/capital costs associated with the WISPR requirements are for programming new fields on the WISRD as well as programming the WISPR quarterly report formats (note that this cost will be much lower once the new DRVS is operational). Start-up costs are estimated to be approximately $127,327 per state. This represents an estimate of one and one-half full time equivalent staff persons per state at an hourly rate of $40.81. Multiplied by 52 states/territories (two have already incurred these costs) this yields a total national start-up/capital cost estimate of $6,621,014.
Annual costs: The annual burden estimate for all states is approximately 968,438 hours and $39,521,939 as detailed in the table above. The estimated cost has been calculated using an estimated hourly cost rate of $40.81 for State staff.
Since the WISPR system applies to state formula grant recipients, administrative resources are provided as part of the grant to off-set staff costs associated with reporting and systems modifications. As such, there is no additional cost to respondents other than those reported in Section A.12 above.
To embed the WISPR system into ETA’s data systems, ETA must change its reporting infrastructure (currently the EBSS and DRVS). ETA plans to develop a more comprehensive reporting infrastructure that in addition to incorporating the new WISPR report formats, program system security, program report level edit checks, appropriate user documentation, and will include data reporting and validation. Each WISPR state will upload their WISRD file to the system and it will generate the program reports (9131, 9132 and 9133) and provide a conduit for data element validation all in one upload. This system is currently in the design phase and is expected to be operational in PY 2012. Annual maintenance of this system is estimated to be $800,000 per year, inclusive of the provision of technical assistance.
The total annual hours requested for the WISPR system information collection are 968,438 hours. The increase in burden hours due to the fact that the number of individual records for each program has increased dramatically from the last approval request. In fact, the WIA portion alone has nearly quadrupled. The increase in burden hours would have been much larger over the last approval as a result of the increase in the number of individuals exiting from the respective programs. However, ETA now requires integrated reporting which decreases the time spent working with each record. In addition, ETA is no longer mandating WISPR nation-wide but rather is currently encouraging states to opt-in on their own. ETA anticipates 10 states to implement WISPR over the 3 years covered by this proposed collection.
In short, changes in the number of exiters and participants used in the calculations, changes in the amount of time spent per record (ETA is now mandating integrated reporting for all WISPR states/territories), along with changing the estimated salaries from $32.50 per hour in FY 2003 to $40.81 per hour in FY 2011 lead to changes in the burden costs. As ETA’s new DRVS become operational, ETA will submit an Information Correction Worksheet to reduce burden accordingly for this system, as state burden associated with building the reports goes to 0.
States and territories will submit the ETA 9131, 9132, and 9133 reports on a quarterly basis to DOL within 45 days after the end of each program year quarter. Reports are due on the following dates:
Report Quarter |
Due Date |
1st Quarter PY July to September |
November 14 |
2nd Quarter PY October to December |
February 14 |
3rd Quarter PY January to March |
May 15 |
4th Quarter PY April to June |
August 14 |
Quarterly report data are analyzed by ETA and VETS staff. Data analysis is used to identify strategies for continuous improvement and areas where additional federal guidance is needed. DOL uses these data to prepare GPRA reports, management and budget reports, and other ad hoc reports.
Each year, the Department issues an annual report summarizing program performance against the Secretary’s goals. Some of the data included in the Department’s annual report are generated from the ETA 9131, 9132, and 9133 reports. Additionally, ETA prepares an annual report for WIA which includes performance data on the Wagner-Peyser Act programs. To satisfy its requirements under Title 38, the VETS office publishes an annual report that focuses on services delivered by DVOP and LVER staff. The Department’s annual report, ETA’s WIA annual report, and VETS’ annual report are submitted to Congress. All reports are available on the Internet and accessible to the general public and interested stakeholders.
The expiration date for OMB approval will be displayed.
A.18 Exceptions to Certification
No exceptions are requested.
PART B – COLLECTION OF INFORMATION EMPLOYING STATISTICAL METHODS
This information collection request does not contain statistical methods.
| File Type | application/msword |
| File Title | NOTE: (1) PLEASE |
| Author | Earline Teasley |
| Last Modified By | Naradzay.Bonnie |
| File Modified | 2012-03-26 |
| File Created | 2012-03-26 |