Career Pathways Frequently Asked Questions

CONTENTS

I. DEFINITIONS
II. ELIGIBILITY
III. FUNDING
IV. PERFORMANCE, ACCOUNTABILITY AND TESTING
V. CURRICULUM / WORKFORCE TRAINING

I. DEFINITIONS

1) Question: What is integrated education and training?

Answer: Title II of Workforce Innovation and Opportunity Act defines integrated education and training which must include these three components:

  1. Adult education and literacy activities as described below;
  2. Workforce preparation activities as described below;
  3. Workforce training for a specific occupation or occupational cluster as described below.
Reference: https://www.congress.gov/113/bills/hr803/BILLS-113hr803enr.pdf

2) Question: What are adult education and literacy activities?

Answer: Title II of Workforce Innovation and Opportunity Act defines adult education and literacy activities to mean “programs, activities, and services that include adult education, literacy, workplace adult education and literacy activities, family literacy activities, English language acquisition activities, integrated English literacy and civics education, workforce preparation activities, or integrated education and training.”

3) Question: What are workforce preparation activities?

Answer: Title II of Workforce Innovation and Opportunity Act defines workforce preparation activities to mean activities, programs, or services designed to help an individual acquire a combination of basic academic skills, critical thinking skills, digital literacy skills, and self-management skills, including competencies in utilizing resources, using information, working with others, understanding systems, and obtaining skills necessary for successful transition into and completion of postsecondary education or training, or employment.

4) Question: What is workforce training?

Answer: The workforce training component of IET is defined through a reference to Title I of WIOA, section 134(c)(3)(D) of WIOA, which identifies the activities that constitute training. These include:

  1. occupational skills training, including training for nontraditional employment;
  2. on-the-job training;
  3. incumbent worker training in accordance with subsection (d)(4) of WIOA;
  4. programs that combine workplace training with related instruction, which may include cooperative education programs;
  5. training programs operated by the private sector;
  6. skill upgrading and retraining;
  7. entrepreneurial training;
  8. transitional jobs in accordance with subsection(d)(5) of WIOA;
  9. job readiness training provided in combination with services described in any of clauses (i) through (viii);
  10. adult education and literacy activities, including activities of English language acquisition an integrated education and training programs, provided concurrently or in combination with services described in any of clauses (i) through (vii); and
  11. customized training conducted with a commitment by an employer or group of employers to employ an individual upon successful completion of the training.

5) Question: What is Integrated English Literacy Civics Education (IEL/CE)?

Answer: The term integrated English literacy and civics education means education services provided to English language learners who are adults, including professionals with degrees and credentials earned in their native countries, that enables such adults to achieve competency in the English language and acquire the basic and more advanced skills needed to function effectively as parents, workers and citizens in the United States.
Program requirements differ depending on the source of AEFLA funding used.

  • IEL/CE under WIOA section 231: If funded under section 231, IEL/CE shall include instruction in:
  • literacy and English language acquisition;
  • instruction on the rights and responsibilities of citizenship and civic participation, and
  • may include workforce training.

    Section 203(12) of WIOA.
  • IEL/CE under WIOA section 243: If funded under section 243, IEL/CE shall include instruction in:
  • literacy and English language acquisition;
  • instruction on the rights and responsibilities of citizenship and civic participation; and
  • must be provided in combination with integrated education and training (IET).

    Section 243(a) of WIOA.

As part of the IEL/CE program requirements, each program that receives funding under Section 243 must be designed to: 3 Version 5/13/16 Career Pathways FAQ

  • prepare adults who are English language learners for, and place such adults in, unsubsidized employment in in-demand industries and occupations that lead to economic self-sufficiency; and
  • integrate with the local workforce development system and its functions to carry out the activities of the program.

    Section 243(c) of WIOA.

6) Question: What is the English Language Acquisition Program?

Answer: The term English language acquisition program means a program of instruction -

  1. designed to help eligible individuals who are English language learners achieve competence in reading, writing, speaking, and comprehension of the English language; and
  2. that leads to -
    1. attainment of a secondary school diploma or its recognized equivalent; and
    2. transition to postsecondary education and training; or
    3. employment

7) Question: Who is an English Language Learner?

Answer: The term ‘‘English language learner’’ when used with respect to an eligible individual, means an eligible individual who has limited ability in reading, writing, speaking, or comprehending the English language, and—

  1. whose native language is a language other than English; or
  2. who lives in a family or community environment where a language other than English is the dominant language.

8) Question: What is a recognized postsecondary credential?

Answer: The term recognized postsecondary credential means a credential consisting of an industry-recognized certificate or certification, a certificate of completion of an apprenticeship, a license recognized by the State or Federal Government, or an associate or baccalaureate degree.

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II. ELIGIBILITY

1) Question: What are (if any) the federal guidelines regarding AEL students without a valid SSN? Can programs indiscriminately decide who is eligible to attend?

Answer: There are no federal guidelines related to a requirement to enter a program under the Adult Education and Family Literacy Act that pertain to having a social security number. Programs must follow eligibility guidelines per their TWC contracts and may develop their own criteria to ensure the training and employment success of students.

2) Question: Will there be changes to include "gaining citizenship" as an outcome in any of the performance measures since that would be the first thing needed before gaining long term employment especially for the large amount of those individuals who have expiring green cards? Is the goal for the EL Civics program to move towards only accepting students who want to gain employment vs. those who are just trying to assimilate and/or become citizens?

Answer: As part of the federal IEL/CE program requirements, each program that receives funding under Section 243 of WIOA must be designed to “(1) prepare adults who are English language learners for, and place such adults in, unsubsidized employment in in-demand industries and occupations that lead to economic self-sufficiency; and (2) integrate with the local workforce development system and its functions to carry out the activities of the program.” Reference Section 243(c) WIOA.

3) Question: It sounds like there may not be very much wiggle room for serving those most in need, for instance the undocumented parents of our school-age children (citizen and non-citizen). Are we going to be able to provide additional resources to the Faith-based Organizations (FBO) and Community-based Organizations (CBO) community? It sounds like they may have to take up some slack.

Answer: There is no change to the need to serve individuals most in need of services. Services for these populations, including the provision of family literacy services, are a requirement of TWC RFP 320-14-10.

4) Question: Will all students participating in EL Civics require work eligibility determination for services? Are there exceptions, including DACA or individuals whose status is being adjusted?

Answer: As part of the federal IEL/CE program requirements, each program that receives funding under Section 243 of WIOA must be designed to “(1) prepare adults who are English language learners for, and place such adults in, unsubsidized employment in in-demand industries and occupations that lead to economic self-sufficiency; and (2) integrate with the local workforce development system and its functions to carry out the activities of the program.” Reference: Section 243(c) WIOA.

5) Question: Are there time limitations to these new course delivery models that would limit or may not be prudent to admit lower level (NRS) language learners? In other words, I see work/literacy models for more advanced students, is this the case?

Answer: No, there are no imposed time limitations related to AEL students in career pathways models. It would be a misconception to assume or design career pathways and IET models for higher level students only. The TWC Commissioners have been clear in their intent that these models focus on college and careers for all students regardless of level. The AEL rules are clear:

It is the Commission's intent to support program designs and operations to deliver increased secondary education and career and higher education outcomes for students, including individuals who are low income or have minimal literacy skills.
§805.3. Federal and State AEL Funds

WIOA provides for great flexibility in designing IET models, including models within Integrated English Literacy Civics Education (IEL/CE), for lower level students.

6) Question: Would it be possible to do an Integrated English Literacy Civics Education (IEL/CE) program with employed English Language Learners in a workplace literacy program? Essentially, we would add workforce training and civics components? We think it would be a good way to find work-eligible students and provide a better service to our business community.

Answer: Yes, this would be a good way to implement IEL/CE, support students, and address business demand for skilled workers.

Consider this example: For several years the manufacturing business association in a local area struggled with hiring skilled workers for entry level production jobs. Many began hiring English Language Learners to fill hiring demands. Businesses had concerns about ensuring these workers understood safety requirements as well as potential waste and error rates in the production line that were resulting from communication challenges in the workplace. The association approached the Workforce Board for a solution. With the flexibility provided under the Integrated English Literacy Civics Education (IEL/CE) program, AEL providers can now offer a solution.
AEL providers could use IEL/CE funds under WIOA Section 243 to design an AEL training and education solution for the manufacturing businesses. The service approach would include working with the Workforce Board (IEL/CE WIOA requirement) to work with the association to design a program for both incumbent workers and for new hires as potential new workers for the association. The AEL providers could provide a contextualized English language acquisition class (IEL/CE WIOA requirement) to support participants in understanding safety requirements and other communication needs related to their jobs. In addition, the Workforce Boards and providers could work with a college or other training organization to customize 5S and Kanban Training for the workers. Workforce training is a requirement for an IEL/CE as a component of an IET. The program curriculum would also include an element of civics education (IEL/CE WIOA requirement). For example, a module on the importance of understanding the function of the city council, that supports economic development initiatives, to which support the manufacturing sector would be an appropriate civics module. The AEL provider would deliver digital literacy as Workforce Preparation Activities (IEL/CE WIOA requirement), to support workers in understanding some of the computerized functions of the workplace. Within the association, the employers enthusiastically supported the joint AEL and Workforce Board effort as it efficiently supports the business needs for safety and production, the career growth of incumbent workers and is creating a supply of potential new hires out of the lower-skilled ELL population.

7) Question: If the student has a GED or job, would he/she qualify to be in the IEL/CE program?

Answer: Yes. Student eligibility and program objectives are different criteria. All students must meet WIOA eligibility criteria. In WIOA the term ‘‘eligible individual’’ means an individual—

  1. who has attained 16 years of age;
  2. who is not enrolled or required to be enrolled in secondary school under State law; and
  3. who—
    1. is basic skills deficient;
    2. does not have a secondary school diploma or its recognized equivalent, and has not achieved an equivalent level of education; or
    3. is an English language learner.

Students with a GED or who are employed are eligible for Integrated English Literacy Civics Education if they meet the above eligibility criteria. If a student had his or her GED or was employed, they could still benefit from the civics and integrated education and training elements of the program and work toward subsequent employment advancement objectives provided by the program.

8) Question: Will we be able to serve adult ELLs through the purpose "assist adults who are parents or family members to obtain the education and skills that - (a) are necessary to becoming full partners in the educational development of their children; and (b) lead to sustainable improvements in the economic opportunities for their family?

Answer: Yes, The AEL program must address all purposes of the Adult Education and Family Literacy Act (AEFLA). WIOA retains and expands the purposes of AEFLA. Under WIA, AEFLA aimed to help adults improve their educational and employment outcomes, become self-sufficient, and support the educational development of their children, but under WIOA, AEFLA’s purposes have been expanded to include assisting adults to transition to postsecondary education and training, including through career pathway programs. Further, WIOA formalizes the role of adult education in assisting English language learners to acquire the skills needed to succeed in the 21st-century economy. English language acquisition programs serving English Language Learners must lead to—

  1. attainment of a secondary school diploma or its recognized equivalent; and
  2. transition to postsecondary education and training; or employment.

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III. FUNDING

1) Question: Will monies for IEL/CE automatically be part of an AEL grant in the future? Will new numbers be attached to EL Civics funding along with current IET and Transitions targets or will this be part of already existing grant numbers or not apply at all for year 3?

Answer: The funding / performance model for Integrated English Literacy Civics Education (IEL/CE), and the required element of Integrated Education and Training, is under development. Current TWC AEL grantees can expect the continuation of targets associated with career pathways for Program Year 2016-2017.

2) Question: Will all TWC AEL grantees be required to serve their EL Civics population with an IEL/CE model that includes IET?

Answer: The “EL Civics population” are English Language Learners. TWC AEL grantees funded under RFP 320-14-10 are required to serve English Language Learners and are required to implement Integrated English Literacy Civics Education (IEL/CE), which includes Integrated Education and Training. See the definition of IEL/CE for more detail.

3) Question: Can funding from WIOA Section 243 (Integrated English Literacy Civics Education) be used to pay for IET classes through the college?

Answer: Yes, as long as the training is part of an IET program of study approved after submission through the TWC Career Pathways Implementation Plan portal available at: https://www.surveymonkey.com/r/CareerPathway-Information

4) Question: Traditionally, "workforce training" within an IET project needed to be paid by outside sources. I understand the integration, but from an accounting perspective are either of these appropriate and allocable:

  1. A teacher who happens to hold a certification in a technology field creates a single class to support workforce readiness, A++ certification, English skills, and civics.
  2. An ESL teacher and an A++ trainer are both paid by the program to run a class to support workforce readiness, A++ certification, English skills, and civics.

Answer: Yes, from the information provided in the questions, these elements would be included within an IET program. The three major elements of IET appear to be represented: (workforce readiness” (workforce preparation activities), A++ certification (workforce training), and English skills, and civics (AEL activities). Both the workforce training teacher (example 1) and ESL teacher (example 2) would need to meet the Staff Qualifications of the AEL rules (which are being modified to accommodate better IET models and are planned for implementation on July 1, 2016.

5) Question: Can EL Civics funds be used to pay for technical vocational instructors or for student tuition for a technical certificate program at a college or technical school?

Answer: Yes, as long as the training is part of an IET program of study approved after submission through the TWC Career Pathways Implementation Plan portal available at: https://www.surveymonkey.com/r/CareerPathway-Information

6) Question: Will enrollment targets for EL Civics be lowered to reflect higher costs of IET instruction? Are there any limits on the per student cost under this funding? I seem to have heard there was a $2,000 guideline. Could it be higher if needed?

Answer: A cost per differential for career pathways is being discussed with TWC management for 2016-2017.

7) Question: Is this funding available for 30-hour workplace classes and do they count as IET?

Answer: AEL grantees may fund 30-hour work-based classes through their current grants. These activities may include an IET model if the other program components of an IET are provided. See definitions section of this FAQ. 8 Version 5/13/16 Career Pathways FAQ

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IV. PERFORMANCE, ACCOUNTABILITY AND TESTING

1) Question: Are we going to be required to enroll a certain number of students? Will our enrollment be tied to performance measures?

Answer: Enrollment targets for Program Year 2016-2017 have not been established yet by the Commission. Grantees can expect to have career pathways enrollment targets to support the state in meeting the strategic plan milestone of 20,000 students in career pathways by 2020.

2) Question: Can EL Civics funding be used for ELA learners who tested with TABE? Many of the more educated ELA learners test out of BEST but still need significant help with academic English to be successful in a training program.

Answer: No, testing students with the TABE test identifies the students in the ABE or ASE levels of the National Reporting System and is in violation of the Texas Assessment Guide. Other approved tests that have a validity range into higher levels of English competencies should be used in the instance that the student has “tested out” of the BEST series.

3) Question: Are there any plans to change how we assess progress?

Answer: Yes, with the introduction of the Integrated Education and Training service approach under WIOA, grantees can expect new models of reporting and assessment to be required. Federal guidelines are not yet released, but the Texas Workforce Commission Adult Education and Literacy has already released webinars and tools describing the accountability model for IET. These can be found at: http://www-tcall.tamu.edu/twcael/wioa.htm

In particular reference:

  • March 31, 2016- WIOA Webinar: Integrated Education and Training 2: Reporting Integrated Education and Training Activities
  • March 24, 2016- WIOA Webinar: Implementing the Participant Individual Record Layout (PIRL) in Adult Education: A Quality Model for Student Success
  • April 28, 2016-Integrated Education and Training #4: Reporting IET Part 2

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V. CURRICULUM / WORKFORCE TRAINING

1) Question: Since ESL for Foreign-Trained Professionals is one model of Career Pathways UNDER TWC RFP 320-14-10, may it be used as an alternative to the IET model, as circumstances require, for some students in the English Literacy and Civics Education Program?

Answer: It depends on what the model for the ESL for Foreign-Trained Professionals approach is. If the approach includes all of the elements required in an IET as defined in WIOA, then yes, these services would count as an IET. A sample program of study for internationally trained nurses may include contextualized ELA for health professionals, workforce preparation activities and an NCLEX (National Council Licensure Examination) preparation class for the examination for the licensing of nurses in the United States.

2) Question: Will TWC AEL department align its workforce training requirements with TWC ETPS department for workforce training requirements under WIOA? If AEL workforce training was listed on the TWC ETPS, Workforce Boards could pay for the workforce training activity using WIOA funding for eligible AEL/WIOA customers.

Answer: As of April 2016, TWC AEL programs have no requirements to place the workforce training elements of IET programs on the Eligible Training Provider System (ETPS). AEL providers are free to develop programs that include such courses and which can leverage the funding available through Workforce Board programs.

3) Question: Is there a certain amount of hours the IET has to be to fulfill requirements? What does the implementation process look like, how many hours of each (ELA and IET)?

Answer: As of April 2016, the Department of Education has not released any specific guidance related to the length of IET programs nor the workforce training components of those programs. The adult education and literacy activities within an IET must meet the basic skills hours required per the Texas Assessment Guide.

4) Question: Will all ELA programs be IET or will all ELA programs be required to have an IET component?

Answer: No, under WIOA an English language acquisition program is “a program of instruction designed to help eligible English language learners achieve competence in reading, writing, speaking, and comprehension of the English language and that leads to attainment of a high school diploma or its equivalent and to the transition to postsecondary education and training or employment.” Section 203(6) of WIOA

5) Question: I'm a little confused about the use of the word "activities". Can these be different classes or are they components of a single class? [Side note: I'm truly grateful I don't have to untangle the funding portion of this. I foresee additional "activity codes" in our future.]

Answer: WIOA distinguishes between “activities,” “programs,” and “services.” These perhaps can best be understood viewed by a relational order of service delivery, with activities being the broadest scope. Within activities are programs and within programs are services. This is not always the case in the WIOA statute, but serves as a guiding principle.

Title II of Workforce Innovation and Opportunity Act defines adult education and literacy activities to mean “programs, activities, and services that include adult education, literacy, workplace adult education and literacy activities, family literacy activities, English language acquisition activities, integrated English literacy and civics education, workforce preparation activities, or integrated education and training.” If multiple activities are part of an IET, at this time, those activities should be tracked as separate classes. TWC AEL will provide more specific examples of this in upcoming webinars and resources.

6) Question: We are making plans to rewrite our EL Civics curriculum by taking components of the TISESL curriculum and integrating them into all of our EL Civics and ESL classes. From my listening to Anson's presentation and reading of the PowerPoint, it seems that this would fulfill the Section 243 requirement to offer 'integrated English literacy and civics education in combination with integrated education and training activities'. Are we on the right track?

Answer: Yes and no. Yes, using the TISESL curriculum (Texas Industry Specific English as a Second Language) curricula as a basis for revision of Integrated English Literacy Civics Education (IEL/CE) program curricula would be an advisable option to support a contextualized curriculum for certain occupations. But no, using TISESL alone does not meet the requirements of integrated education and training (IET) as IET must include workforce training and workforce preparation activities. Refer to the definitions sections of this FAQ for information on these elements.

7) Question: What are the restrictions on the vocational side of the IET model? Does a course have to lead to a Level 1 certificate, an industry-recognized certificate or are we saying that any technical training that improves the chances of an immigrant getting a job is sufficient?

Answer: Due to the various options available to meet the workforce training component of an IET program, there is no restriction related to educational certificate (for example Level 1 certificate), or certifications such as an industry-recognized certificate. WIOA regulations, when released, may provide additional guidance. For many options available under workforce training though, certificates and certifications are recommended to meet employment and employability objectives of the Adult Education and Family Literacy Act.

8) Question: Do we have to have these vocational/technical classes pre-approved?

Answer: Yes, for AEL grantees funded under RFP 320-14-10 to provide workforce training under their grant, they must follow the approval guidelines listed in AEL Letter 02-16. See http://www.twc.state.tx.us/files/partners/ael-02-16-twc.pdf

9) Question: Considering that ELA NRS levels among EL Civics students may be too low for many/most CTE certificates or courses, if available could certificate classes be held in native language, e.g. a bilingual diesel mechanics class?

Answer: Yes. In 2005 the Department of Education provided TWC guidance stipulating that foreign language instruction was a state decision. Since 2007 Texas Workforce Commission has promoted bilingual vocational training models and bilingual education is allowable in the authorizing legislation for Adult Education and Literacy in Texas, Senate Bill 307. For more information see:

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