Background

To assist workers who are laid off as a result of international trade,  Congress passed the Trade Expansion Act of 1962 and created the Trade  Adjustment Assistance program. Historically, the main benefits available  through the program have been extended income support and training.  Participants are generally entitled to income support, but the amount of  funds available for training is limited by federal statute. Labor certifies  groups of laid-off workers as potentially eligible for TAA benefits and  services by investigating petitions that are filed on the workers’ behalf.  Workers are eligible for TAA if they were laid off as a result of  international trade and were involved in making a product or supplying  component parts to or performing finishing work for directly affected  firms. Workers served by the TAA program have generally been laid off  from the manufacturing sector.
Congress has amended the TAA program a number of times since its  inception. For example, in 1974 Congress eased program eligibility  requirements, and in 1988 Congress added a requirement that workers be  in training to receive income support. In 1993 Congress created a separate  North American Free Trade Agreement Transitional Adjustment  Assistance (NAFTA-TAA) program specifically for workers laid off  because of trade with Canada or Mexico. The most recent amendments to  the TAA program were included in the TAA Reform Act of 2002   (Pub. L. No. 107-210), which was signed into law in August 2002. The  Reform Act consolidated the former TAA and NAFTA-TAA programs into  a single TAA program, doubled the amount of funds available for training  annually, expanded program eligibility to more workers, extended the time  periods covered by the program, and added new benefits.

		Services Available under the TAA Program

Under the current TAA program, eligible participants have access to a  wider range of benefits and services than before, including:  Training. Participants may receive up to 130 weeks of training, including  104 weeks of vocational training and 26 weeks of remedial training   (e.g., English as a second language or literacy). On-the-job training is also  available under TAA. Participants in TAA-approved training must attend  training full-time.
Extended income support, or Trade Readjustment Allowances  (TRA). Participants may receive up to 104 weeks of extended income  support benefits after they exhaust the 26 weeks of UI benefits available in  most states. This total includes 78 weeks while participants are completing  vocational training and an additional 26 weeks, if necessary, while  participants are completing remedial training. The amount of extended  income support payments in a state is set by statute at the state’s UI  benefit level.
During their first 26 weeks of extended income support, participants must  be enrolled in training, have completed training, or have a waiver from this  requirement; to qualify for more than 26 weeks of extended income  support, participants must be enrolled in training. The TAA statute lists six  reasons why a TAA participant may receive a waiver from the training  requirement, including that the worker possesses marketable skills or that  the approved training program is not immediately available. States must  review participants’ waivers at least every 30 days and if necessary may  continue to renew participants’ waivers each month throughout the initial  26 weeks of extended income support.
Job search and relocation benefits. Payments are available to help  participants search for a job in a different geographical area and to  relocate to a different area to take a job. Participants may receive up to a  maximum of $1,250 to conduct a job search. The maximum relocation  benefit includes 90 percent of the participant’s relocation expenses plus a  lump sum payment of up to $1,250.
Health Coverage Tax Credit (HCTC). Eligible participants may receive  a tax credit covering 65 percent of their health insurance premiums for  certain health insurance plans. To be eligible for the credit, trade-affected  workers must be either receiving extended income support payments, or  they must be eligible for extended income support but are still receiving  UI payments, or they must be recipients of benefits under the wage  insurance program. As a result, trade-affected workers who are still  receiving UI rather than extended income support may register for the  HCTC only if they are in training, have completed training, or have a  waiver from the training requirement.
Wage insurance. The wage insurance program—known as the  Alternative TAA (ATAA) program—is a demonstration project designed  for workers age 50 and older who forgo training, obtain reemployment  within 26 weeks, but take a pay cut. Provided the participant’s annual  earnings at his or her new job are $50,000 or less, the benefit reimburses  50 percent of the difference between the participant’s pre- and postlayoff  earnings up to a maximum of $10,000 over 2 years.

		Certification Process and Eligibility Requirements

The process of enrolling trade-affected workers in the TAA program  begins when a petition for TAA assistance is filed with Labor on behalf of  a group of laid-off workers. Petitions may be filed by entities including the  employer experiencing the layoff, a group of at least three affected  workers, a union, or the state or local workforce agency. The TAA statute  lays out certain basic requirements that all certified petitions must meet,  including that a significant proportion of workers employed by a company  be laid off or threatened with layoff. In addition to meeting these basic  requirements, a petition must demonstrate that the layoff is related to  international trade. The law requires Labor to complete its investigation,  and either certify or deny the petition, within 40 days after it has received  it. When Labor has certified a petition, it notifies the relevant state, which  has responsibility for contacting the workers covered by the petition,  informing them of the benefits available to them, and telling them when  and where to apply for benefits.
Workers generally receive services through a consolidated service delivery  structure called the one-stop system, where they can access a broad range  of services beyond TAA, including the Workforce Investment Act (WIA)  Dislocated Worker program, the Wagner-Peyser Employment Service (ES)  program, and services funded by the WIA National Emergency Grants.  Training for trade-affected workers may be funded by TAA or by one of  the WIA funding sources. Workers often meet one on one with a case  manager who may assess worker’s skills and help decide what services  they need. Because the TAA program has limited funds that can be used  for case management and program administration, these case management  services are often performed by ES or WIA Dislocated Worker program  staff. When this occurs, participants are often co-enrolled in WIA or ES as  well as TAA.

		TAA Funding

About $750 million was appropriated for income support for trade-affected  workers for fiscal year 2005, while another $259 million was appropriated  for training, job search and relocation allowances, and administrative  costs. Of the $259 million, $220 million is set aside for training, and Labor  allocates 75 percent of it to states according to a formula that takes into  account each state’s previous year allocations, accrued expenditures, and  participant levels. Labor holds the remaining 25 percent of training funds  in reserve, to distribute to states throughout the year according to need.  To cover administrative costs associated with training under the TAA  program, Labor allocates additional administrative funds to each state  equal to 15 percent of its training allocation.

		TAA Performance Reporting System

Labor is responsible for monitoring the performance of the TAA program.  In fiscal year 1999, Labor introduced a new participant outcomes reporting  system, the Trade Act Participant Report (TAPR), that was designed to  collect national information on TAA program participants, services, and  outcomes. States are required to submit TAPR reports to Labor each  quarter, with data on individuals who exited the TAA program. The TAPR  data submitted by states are used to calculate national and state outcomes  on the TAA performance measures for each fiscal year, which include   (1) the percentage of participants that found jobs after exiting the program  (reemployment rate), (2) the percentage of those participants who were  employed after exiting the program who were still employed 9 months  later (retention rate), and (3) the earnings in their new jobs compared to  prior earnings (wage replacement rate).
Labor’s guidance requires states to include in their TAPR submissions all  TAA participants who exit the program, that is, stop receiving benefits or  services. Under Labor’s guidance, a participant is defined as any individual  who receives any TAA benefit or service, including extended income  support payments, training, or job search and relocation allowances.  According to this definition, participants would include those who, for  example, received only extended income support and a waiver that  allowed them to forgo training.
TAPR reports include data on each exiter’s characteristics, services  received, and employment outcomes. Data on characteristics, for example,  should include the worker’s date of birth, gender, ethnicity, educational  level, and layoff date. Data on services received should include data on  training (such as dates the participant entered and completed training, and  the type of training received), on other TAA benefits received (such as  extended income support, job search allowance, and relocation  allowance), and on co-enrollment in WIA or other federal programs. Data  on outcomes should include the date the worker exited the TAA or other  federal program, whether the worker was employed in the first full quarter  after exit, whether the worker was employed in the third full quarter after  exit, and the worker’s earnings in these quarters. Where possible, outcome  data are to be obtained from state UI wage records.
Labor uses the TAPR data to track TAA program outcomes against  national goals. Unlike the WIA programs, however, TAA has no individual  state performance goals, and states do not receive incentives or sanctions  based on their performance levels, nor are they otherwise held  accountable for their performance. At the national level, the TAA program  has failed to meet at least one of its performance goals each year since  2001, the first year for which goals were set. Table 1 shows goals and  outcomes for fiscal years 2004 and 2005.
In addition to submitting TAPR data, states also submit data to Labor on  TAA services and expenditures each quarter through the Form 563. Form  563 includes counts of participants receiving TAA services, while TAPR  includes individual-level data on former participants who have exited the  program. States are required to submit each quarter’s Form 563 data about  1 month after the end of the quarter. Form 563 includes data on services  such as the number of new training participants (by type of training— occupational, remedial, and on-the-job), the number of workers in training  at the end of the quarter, the number of training waivers issued, and the  number of recipients of job search and relocation allowances, and  expenditures on extended income support.

		Common Measures

In response to an Office of Management and Budget (OMB) initiative,  Labor recently began requiring states to implement common performance  measures for WIA programs. OMB established a set of common measures  to be applied to most federally funded job training programs that share  similar goals. Labor further defined the common measures for all of its  Employment and Training Administration programs and required states to  implement these measures beginning July 1, 2005. Because it operates on a  fiscal year rather than a program year basis, Labor required the TAA  program to implement the measures by October 1, 2005.
In addition to standardizing the performance measures, the common  measures guidance also standardizes the definition of exiters across all  programs. An exiter is defined as any participant who has not received a  service funded by the program or funded by a partner program for   90 consecutive calendar days and is not scheduled for future services.   The exit date is defined as the last date of service. For TAA participants,  the exit date may be the training completion date, but if additional services  are provided after training is completed, or if the participant is continuing  to receive TRA, he or she would not be exited from the program. Some  services are not significant enough to delay exiting, however. These  include receiving UI benefits, some case management services, and  postplacement follow-up.

		Flow of Data for Collecting and Reporting TAA Data

The process of collecting and reporting TAA performance data involves all  three levels of government. Participant forms and case files are generally  collected and organized by frontline staff in local areas, usually at the one- stop. In some states, local staff may enter some of the information into an  IT system that is either integrated with the state’s IT system or able to  create an electronic file to transmit to the state. In other states, paper case  files are physically transferred to state officials for data entry.
At the state level, TAA data are often maintained in more than one IT  system. For example, benefit payment information is usually in the same  IT system that houses Unemployment Insurance payment information.  However, information on participant characteristics and services  (including status of training and whether or not the individual has exited)  resides in one or more other systems. In some states, this participant  information remains as a paper case file until it is determined that the  participant has exited, and it is time to include him or her in the TAPR  submission.
To compile the TAPR submission, state agencies administering TAA  typically match participant records to their state’s UI wage record system  to determine whether these former participants are employed and, if so,  the wages they are earning. In some states, staff must manually enter  information obtained from the UI wage record system into the TAPR file,  while other states have IT systems capable of automatically matching UI  data with participants’ records. States may also use the Wage Record  Interchange System (WRIS) to match participant records to other states’  UI wage records for participants who found jobs in other states. Some  states may link participant records to other partner programs’ IT systems  to track activities across programs or to determine if the participant has  exited all programs. Once Labor receives the TAPR data, officials perform  edit checks and calculate performance levels at the national and state  level.

	TAA Data Do Not Provide a Complete, Credible Picture of the Program’s Performance

TAA performance data are incomplete and may be inaccurate. States  report that they are not including all TAA participants in their TAPR  performance data, despite Labor’s requirement that all participants be  included after they exit the program. In addition, some states may not have  documentation to verify the accuracy of participants’ exit dates in TAPR  and are not using all available data sources to determine TAA participants’  employment outcomes. Furthermore, 1 state in 5 is using manual rather  than automated processes to compile TAPR data, and others have IT  systems with limited capacity to control for errors. Having such IT systems  could hinder states’ ability to ensure that the data are complete and  accurate. However, many states are planning to make improvements to  their TAA IT systems’ capabilities this year. Some state TAA officials said  that resource constraints have made it difficult to ensure their data are  complete and accurate.

		TAA Performance Data Are Incomplete and May Be Inaccurate

Many states are not including all exiting participants in the TAPR  submissions that Labor uses to calculate performance outcomes for TAA  participants, such as the reemployment and retention rates. Participants  who received training were most likely to be included in states’ TAPR  data, but those who had training waivers and had not received training  were least likely to be included. Only 23 of the 46 states we surveyed  reported that they are including in their TAPR submissions to Labor all  exiting participants, regardless of the type of benefit or service they  received. Fourteen states reported that participants who received waivers  but did not receive training were unlikely to be included in the TAPR   (see fig. 1), and 3 states reported that they do not include any participants  unless they receive training. This finding is consistent with a review by  Pennsylvania’s state auditor that found that participants who received  waivers from training were not included in their TAPR submissions.
Our review of the TAPR data states submitted to Labor during fiscal year  2005 confirms our survey results—some states appear to be excluding  some of their participants in their TAPR data files. For example, 9 states  only included in their TAPR submissions participants who received  training. Another 12 states had TAPR submissions composed almost  exclusively (97 to 99 percent) of participants who received training   (see table 2). However, several states did include relatively more of the  participants who had not received training. For example, for 6 states,  under 60 percent of the participants reported in the TAPR had received  training. We have no other reliable source of data to help us assess what  proportion of participants nationwide actually receive training and,  therefore, what the proportion in the TAPR should be. In a recent study  that examined services and outcomes for five trade-related layoffs,  however, we found that between 9 and 39 percent of potentially eligible  TAA participants enrolled in training. Excluding certain participants from  the TAPR could skew the TAA performance outcomes calculated by Labor  because the outcomes may be disproportionately based on participants  who received TAA-funded training.
Labor does not have a process in place to ensure that states are including  in their TAPR submissions all exiting TAA participants. Labor’s regional  offices may review whether states’ TAPR submissions are complete during  their state monitoring visits. However, because Labor has not had a  standard monitoring tool, there has been no assurance that the regional  offices were consistently reviewing whether all exiting participants are  reported in states’ TAPR data. Labor officials tell us that they are currently  developing a core monitoring guide, but it is not clear if the guide will  address this issue.
Despite the importance of accurately identifying exiters, the exit dates  themselves may not be accurate because some states do not consistently  obtain proper documentation to verify the dates. Accurate exit dates are  critical to TAA performance data for two reasons. First, a participant’s exit  date determines if the individual should be included in the state’s TAPR  submission to Labor. Second, the timing of the date of exit determines  when a participant’s employment outcomes will be assessed. Labor’s  guidance requires that states have documentation for participants’ exit  dates but does not specify the type of information that needs to be  included in the documentation. For example, for participants who  received training, it does not specify that the documentation should  demonstrate that training was actually completed. Such documentation  could include certificates of training completion, attendance records, or  reports from training providers.
TAA officials in 4 of the 5 states we visited said they had a process for  obtaining documentation to show that participants completed training, but  it is not clear whether such processes are uniformly followed by states.  Officials in 3 states said that they receive training certifications, either  from participants or from trainers, that show that training was completed.  In another state, a TAA official said that the state sends participants a  follow-up survey after training to verify that the training was completed,  but some participants do not return the survey. Officials in 1 of the 5 states  we visited said they did not have a process for certifying or documenting  that participants completed training.
A recent review in 4 other states by Labor’s Office of Inspector General  (OIG) confirmed that states do not have effective processes for verifying  exit dates. In its review of 150 TAA case files, the OIG found that there  was no documentation in any of the reviewed files to verify that the  participants had completed the program on the recorded date of exit. OIG  reported that states often recorded an anticipated date of exit when  participants first entered the program, but did not collect any further  documentation to confirm that participants had completed the training,  and if so, whether they had completed training on the originally recorded  date. The OIG recommended that Labor ensure that states collect and  record TAA participants’ actual date of exit, maintain the source  documentation for such exit dates, and make the documentation readily  available for review. According to an OIG official, Labor had not  implemented these recommendations as of January 2006.

		Some States Are Not Using All Available Data Sources to Determine Employment Outcomes for TAA Participants

Some states are not using all available data sources to determine TAA  participants’ employment outcomes. Labor requires states to use UI wage  records to determine the employment outcomes of participants reported  in the TAPR. However, each state’s wage record database includes only  wage data on workers within the state and does not have data on  participants who found employment in another state.
To help track employment outcomes of TAA participants across state  lines, states can obtain their employment and earnings information using  other methods. Labor encourages states to use WRIS, a data clearinghouse  that makes UI wage records available to participating states seeking  information on TAA participants who may have found employment outside  their state. Thirty-four of the 46 states we surveyed reported that they  routinely use WRIS to obtain employment outcome data on former TAA  participants (see fig. 2). Three states reported that they do not use WRIS  but instead routinely use interstate agreements with individual states to  obtain employment outcome data. Opting to use interstate agreements  with individual states instead of using WRIS is likely to result in access to  fewer states’ UI wage records than states would have if they used WRIS  and may result in lower reported outcomes. Seven states use only their  own states’ UI wage records to determine participants’ employment  outcomes. State TAA officials cited several reasons for not using WRIS,  including that it took too long to receive the needed information and it was  not a priority for the state. Six states that do not currently use WRIS said  that they plan to begin using this system in the future.
Nearly half of the 46 states are not routinely using other supplemental  information sources even though it may be the only way to collect  outcome information for certain participants. UI wage records, which  cover about 94 percent of workers, do not include some categories of  workers, such as self-employed persons, most independent contractors,  military personnel, federal government workers, and postal workers. To  document the employment status of these workers in the TAPR, states can  use supplemental data, such as pay stubs and follow-up surveys sent to  participants after they leave the program. Using supplemental data is likely  to provide a more complete picture of participant outcomes because it  helps states avoid inaccurately recording participants as unemployed in  the TAPR. In an earlier report on WIA performance data, 23 of the 50  states told us they needed to use supplemental data in order to meet their  expected performance levels for the reemployment measure under WIA.
Twenty-two states reported that they rarely if ever collect supplemental  data to obtain outcome information on TAA participants (see fig. 3). State  TAA officials said that they did not collect supplemental data because    states’ TAA IT systems lacked the capacity to record supplemental  data;  they judged data collected through UI wage records and WRIS as  sufficient, or collecting supplemental data was not required; and  they lacked sufficient resources.

		Some States’ TAA IT Systems Have Limited Capacity to Help Ensure Data Quality

Some states reported IT system limitations that could hinder the states’  ability to ensure their TAA data are complete and accurate.
GAO, Workforce Investment Act: States and Local Areas Have Developed Strategies to  Assess Performance, but Labor Could Do More to Help, GAO-04-657 (Washington, D.C.:  June 1, 2004). data on employment outcomes into their TAPR data rather than  electronically transferring the data from the UI wage record file. Using  manual rather than automated processes increases the opportunity for  errors to be introduced into the data through data entry. Six states  responding to our survey expressed concern that errors in data entry may  be one of the main causes of incomplete or inaccurate TAA data.
One state’s process for manually compiling the TAPR illustrates  opportunities to introduce errors into the data. In this state, staff at the  state level enter data on TAA participants’ training contracts into a  contract database. To compile the TAPR, they identify participants in the  contract database whose training was scheduled to be completed during  the quarter covered by the TAPR, and they enter data on those participants  into a new spreadsheet. To identify employment outcomes for the TAPR,  the staff look up the exiting TAA participants on printouts from the state’s  UI wage record system and manually enter data on the participants’  employment status and wages into the spreadsheet. The data from the  spreadsheet are then converted into the TAPR reporting format and sent  to Labor.
Limited IT system capabilities. Many states’ IT systems for compiling  TAA data do not have certain IT system capabilities, such as performing  edit checks, that help a state report complete and accurate data to Labor.  Only 15 of the 46 states we surveyed had TAA IT systems with each of  three such capabilities:    Performing edit checks to prevent data errors: Edit checks aid in  identifying invalid data, such as an entry in a date field that is not a  date.
Identifying dates TAA participants completed WIA-funded services:  The ability to identify when TAA participants complete WIA-funded  services can help ensure that TAA participants are not counted in the  TAPR report while they are still receiving services under WIA. If  participants are still receiving services, then it is too soon to assess  their employment outcomes in the TAPR report.
Allowing staff to query the system to assess data reliability and  completeness: Queries allow staff to pull certain information out of the  system to answer questions, and without this capability, staff may not  be able to properly assess data quality and diagnose data problems. For  example, in one local area we visited, a TAA specialist who is  responsible for reporting on numerous TAA participants described  having great difficulty determining if training completion dates had  been entered for participants as appropriate because the specialist  could not query the system to get a list of participants and their training  status.
More than half of the states told us they had plans to make at least one of  these system improvements during the next year. For example, 17 states  reported plans to improve their TAA IT systems’ capability to perform edit  checks (see fig. 4).
Some states with electronic systems may have the capability to track TAA  participants across other programs serving them, but several do not. Out  of the 37 states that told us they had electronic systems to compile their  TAPR data, 29 states said this same system captures program information  for WIA programs, and similarly, 29 said the system captures information  for Employment Services. Thirteen states said that these capabilities  extended to all six programs and benefits that we examined, which  includes, in addition to WIA and ES, Trade Readjustment Allowance,  National Emergency Grants, Veterans Employment and Training Program,  and UI. See appendix II for a complete listing of states’ systems linkages.
In addition, several states commented on our survey that they have  planned enhancements to their TAA IT systems that may help coordinate  across programs and increase the likelihood of capturing more outcomes:  Improving coordination of data across programs: Six states reported  planning changes, such as developing a single case management system  for several programs that would allow more coordination of data  across programs.
Transitioning from manual to electronic processes: Two states that  have been using manual processes reported plans to develop electronic  interfaces to capture needed data for the TAPR.
Adding capacity to record supplemental data: Two states reported  that their IT system changes will enable them to begin recording  supplemental data for use in determining TAA participants’  employment outcomes.

		Some States Told Us Limited Resources Contributed to TAA Performance Data Problems

Some states reported that limited TAA administrative funds hindered their  ability to ensure the quality of the TAA performance data they collect and  maintain. To cover their TAA program’s administrative costs, states  receive an allocation each year equal to 15 percent of their TAA training  allocation. In fiscal year 2006, 9 states received less than $100,000 in TAA  administrative funds, and another 10 states received between $100,000 and  $300,000. These funds are used to cover all the administrative activities of  the program, such as reviewing waivers and training plans, processing  applications for job search or relocation allowances, and any associated  data collection and reporting. Some states also use these funds for direct  case management services to participants because they are the only TAA  funds available to provide these services. However, we recently reported  that state officials told us the TAA administrative funds were often  insufficient to meet the case management needs of the program and they  relied on other programs to provide those services. (For a complete  listing of each state’s TAA training and administrative funds, see app. III.)
State and local TAA officials said that resource shortages contribute to  difficulties in identifying exit dates, using supplemental data sources, and  entering data in a timely manner. For example, one state official  commented on our survey that TAA case managers often do not have  enough time to follow up with participants to learn about their status after  they have been sent to training. Another state official said that insufficient  case management can delay the identification of participants exiting the  program. Officials in 2 other states told us that supplemental data were too  time-consuming and burdensome to collect, given the program’s current  funding levels. Officials said that resource limitations also presented  challenges in entering the data in a timely manner. An official in one local  area we visited reported a tremendous backlog in entering TAA participant  data into the IT system because there were just two staff to handle  approximately 1,000 TAA cases. Similarly, in another local area, the office  manager told us that TAA staff were spread too thinly, a condition that  adversely affected the collection and entry of TAA data.

	Labor Makes Some TAA Performance Data Available, but Its Usefulness Is Limited

Labor reports data on TAA petition and certification activity, program  participation, and key performance measures, but this information may  not be useful for gauging current program performance. The information  may be helpful in providing a long-term national picture of program  outcomes, but it represents past, rather than current, performance. UI  wage records—the primary data source for tracking TAA performance— provide a fairly consistent national view of TAA performance and allow for  tracking outcomes over time. At the same time, the UI wage records suffer  from time delays and, together with the use of longer-term outcome  measures, affect the timing of states’ performance reports to Labor and,  subsequently, the information that Labor makes publicly available. Most of  the outcome data reported in a given program year actually reflect  participants who left the program up to 2 years earlier. In addition, Labor  does not consistently report TAA data by state or industry or by services  or benefits received—a step that would make the data more useful to  policymakers. States responding to our survey reported that they would  like additional information from Labor, such as how their TAA  performance compares to the performance of other states and other  federal employment and training programs.

		Publicly Available TAA Data Do Not Provide a Clear Picture of Current Program Performance

Labor makes some TAA statistics available through postings on its Web  site and through published reports, but they do not provide useful  information on current performance. Labor provides some TAA activity  and participant data by fiscal year including    number of petitions received, certifications issued, and denials by state;    distribution of certifications by industry;    number of new participants receiving extended income support  payments or training; and    summary statistics on former TAA participants (such as race,  education level, and benefits and services received).
In addition to reporting on TAA activity and participant data, Labor also  reports on three key TAA performance measures. The TAPR data  submitted by states are used to calculate national and state outcomes on  the TAA performance measures—wage replacement, reemployment, and  retention—for each fiscal year. In 2005, Labor made state-by-state TAA  outcome information publicly available for the first time. According to  Labor officials, making this information public represents an effort to  emphasize performance, and they intend to post state-by-state outcome  information on the Web site for all future fiscal years. Labor’s regional  offices directly provide states with information on their TAA performance  relative to the program’s national goals. Some regional offices also provide  states with reports showing the performance of all states in the region,  according to officials we interviewed.
However, the information Labor makes publicly available may not provide  a clear picture of current TAA performance because, in addition to being  incomplete and perhaps inaccurate, the data represent past performance  and are not consistently reported by type of service, state, or industry.
Data represent past performance. Because TAA performance is  measured using UI wage records and long-term performance measures  such as employment retention, the most up-to-date TAA performance data  currently available may represent performance from several years in the  past.
Use of wage records: Using UI wage records to measure outcomes  provides a common yardstick for making long-term comparisons  across states because they contain wage and employment  information on most workers. At the same time, these files suffer  delays between the time an individual gets a job and when this  information appears in wage records. State procedures for  collecting and compiling wage information from employers can be  slow and time-consuming. Data are collected from employers only  once every quarter, and employers in most states have 30 days  after the quarter ends to report the data to the state. For example,  the wage report for the last calendar quarter of the year (ending on  December 31) is due to the state on January 31. We previously  reported that for the majority of states, the delay between the time  an individual gets a job and the time this information appears in  wage records is up to 4 months.
Design of measures: In addition to using a job placement measure,  Labor also uses two longer-term measures to gauge TAA  performance—an earnings measure and a job retention measure.  These measures may be useful for assessing how well the program  is meeting its long-range goals to increase the employment,  retention, and earnings of participants. However, the use of these  measures requires states to wait from one to three quarters after  participants exit the TAA program before measuring the outcomes.  For example, although states record whether participants entered  employment in the first quarter after exit, two more quarters must  elapse before employment retention is measured. Participants who  exit the TAA program have their outcomes assessed in the first,  second, and third quarters after exit. However, data to measure all  outcomes are not available until the fifth quarter after exit, and the  outcomes are not submitted to Labor until midway through the  sixth quarter. Figure 5 illustrates the time it takes before a TAA  participant would be included in performance outcome  calculations.

		Most States Find TAA Performance Data Useful, but Many Would Like Additional Information

While approximately one-third of the states found TAA performance  information they currently receive from Labor to be greatly useful, some  would like Labor to provide them with additional information to help  manage their program. Nearly half of the 46 states we surveyed told us that  they find the performance information they receive from Labor to be  moderately useful (see fig. 7), and 8 states reported that Labor’s TAA  performance information is of little or no use for program management.
Nearly half of the states we surveyed told us that they routinely develop  information on their own performance beyond what they submit to Labor.  For example, an official in 1 state reported that it calculates its own  outcomes before receiving them from Labor in order to make managers  and executives aware of the state’s performance, and it uses this  information to engage state and local TAA staff in making program  adjustments. In addition, approximately one-third of the states routinely  develop information on their local areas’ performance. Labor does not  provide analysis of local area performance to states because it does not  collect this type of information in the TAPR.
While many states provide the performance information of their own state  and that of other states to their local area TAA staff, few states provide  information on their local areas’ performance to local TAA staff. Only 27 of  the 46 states in our survey reported that they share information from  Labor with local area staff on how their state’s performance compares to  national TAA performance goals. In addition, only 7 of the 16 states that  generate additional performance information for local areas reported that  they share this information with local TAA staff. One expert we spoke with  told us that regularly sharing performance information with local program  staff enables them to understand how the data they collect are being used  and the importance of complete and accurate data for producing reliable  performance information. Our recent report on performance measurement  also noted that frequent and routine communication of performance  information helps program staff and stakeholders use such information to  accomplish program goals as they pursue day-to-day activities. These  practices could lead to better program management and produce more  reliable performance data to assess TAA performance in the future.
States said that they would like to receive additional performance  information from Labor to help manage their TAA program. Thirty-four  states would like more information than they currently receive on their  own state’s performance, and 39 states reported they would like  information comparing their states’ TAA performance to their WIA  Dislocated Worker performance (see fig. 8). According to one state  official we spoke with, receiving additional TAA performance information  that is displayed by type of service and by state would enable officials to  respond more effectively to performance problems and to learn what  strategies states with similar TAA populations are using to achieve  different performance outcomes.

	Labor Has Taken Steps to Improve the Quality of Performance Data, but Issues Remain

While it has limited authority to hold states accountable, Labor has taken  steps to improve the quality of TAA data states submit, but these steps do  not fully address all issues. Labor has no mechanism to sanction states for  poor performance or poor-quality data because the law and current  regulations do not provide one. However, Labor has begun an initiative  that requires states to review a sample of their data for accuracy. It is too  soon to fully assess whether Labor’s efforts have improved data quality,  but most states reported on our survey that Labor’s new requirements  have increased awareness of data quality at the state and local levels.  States also report that they would like more opportunities to share lessons  learned about issues related to data quality. Labor is requiring changes in  some TAA performance measures to align them with measures for other  federally funded job training programs. Many states reported that the  changes are burdensome, and some states are experiencing delays in  implementing the changes.

		Data Validation Is Having Positive Effects but Does Not Address All Concerns

To address data quality concerns, Labor developed a process for states to  use to validate the TAPR data they submitted to Labor. Starting with data  submitted in fiscal year 2003, Labor required states to review a sample of  participants’ records and compare what was reported for certain data  elements to data in source files. State staff review the source files and  record whether each data element is supported by source documentation  and, therefore, passed data validation. If the source files show a data  element was incorrect or was not supported with documentation, the data  element fails. States use Labor’s software to calculate error rates, and they  submit the results to Labor.
While it is too soon to assess whether Labor’s data validation efforts have  improved data quality, many states said that the efforts are having a  positive effect. Thirty-five states reported that efforts have improved the  accuracy of the data. Thirty-seven of the 46 states told us they have helped  increase the awareness of data quality at the state level, and 25 states told  us they have improved awareness at the local level (see fig. 9).
Until recently, Labor has not had a standard process for ensuring that  states performed data validation correctly. Labor officials tell us, however,  that beginning in 2006, regional offices are conducting data validation  compliance reviews of a subsample of validated records to ensure that the  records were accurately validated and the files contained all required  source documents.
While states report that Labor’s data validation requirements are having  some positive effects, Labor’s data validation efforts do not address two  key problems. First, guidance for data validation defined for the first time  the type of source documents needed to validate TAPR data elements,  including exit dates. However, the guidance does not specify that the  source documents for training completion dates should show that  participants actually completed training. Second, data validation does not  provide for assessing whether TAPR submissions are complete. Because  the data validation process only covers participant records included in  states’ TAPR submissions for the year, it does not look beyond those  records to determine whether all exiting participants were included.

		Labor Has Taken Several Other Steps to Help Improve TAA Data, but States Want More Opportunities to Share Lessons Learned

In addition to implementing data validation, Labor has taken various  actions to better instruct states and to provide tools for improving the data  they submit to Labor.
Technical assistance and training: In 2005 and 2006, Labor  brought together state TAA staff for training conferences on the  new data requirements for implementing common measures.  According to Labor officials, Labor’s regional offices periodically  hold roundtables with states to discuss issues that sometimes  include data quality. Labor provides technical assistance, as  needed, to states through telephone calls and e-mails. According to  Labor officials, Labor is planning to start holding quarterly  conference calls with states about TAA issues, including data  quality.
Guidance on data reporting: Labor issued guidance and  instructions for TAA data reporting, such as instructions defining  how “date of exit” is to be determined under common measures. In  May 2005, Labor issued a guidance letter to states addressing  several issues with data quality, such as the use of WRIS and  supplemental data to determine employment outcomes. In general,  states reported that the guidance and training they had received  from Labor provided a clear understanding of certain data  requirements, such as the requirements for data validation and for  using UI wage records. States were somewhat less likely to say that  Labor had provided a clear understanding of the documentation  needed for the date of exit and how supplemental data could be  used to document TAA employment outcomes.
Monitoring: Labor’s regional offices conduct monitoring visits to  review states’ TAA programs. In the past, Labor did not have a  standard protocol for these monitoring visits, and the monitoring  did not always cover the quality of the TAA data being submitted  by states. However, as of March 2006, Labor was developing a  standard monitoring guide for its regional staff.
Pilot project on federal employment data: Labor collaborated with  the Office of Personnel Management, the U.S. Postal Service, and  the Department of Defense to create a pilot data exchange system  to provide states access to wage record information on federal and  military employment. The system that began operating in  November 2003 can help states obtain more complete employment  outcome data on participants who exited job training programs  because it provides information on federal employment that is not  available in state UI wage records. Many states are using the  system to help determine employment outcomes for job training  programs, such as those funded under the Workforce Investment  Act. However, only 3 of the 46 states we surveyed reported that  they were routinely using this system to obtain employment  outcomes for the TAA program.
Despite Labor’s efforts to improve data quality, most states would like  more help. Most states reported that they do not currently have  opportunities to share lessons learned with other states on topics related  to TAA data quality, such as how to use supplemental data, and they  expressed interest in having such opportunities. For example, 29 states  told us they do not currently have opportunities to share lessons learned  on data validation, and 44 states told us more opportunities to do so would  be helpful (see fig. 10).

		Labor’s Common Measures May Address Some Concerns, but States Are Still Struggling to Implement Changes

In response to an OMB initiative, Labor made changes to some of the TAA  performance measures and to TAA reporting requirements in order to  implement common measures (see table 3). OMB established a set of  common performance measures to be applied to most federally funded job  training programs that share similar goals. Labor further defined the  common measures for all of its Employment and Training Administration  programs and required states to start reporting TAA data under the revised  requirements in fiscal year 2006.
Moving to common measures may increase the comparability of outcome  information across programs and make it easier for states and local areas  to collect and report performance information across the full range of  programs that provide services in a one-stop system. Prior to common  measures, many federal job training programs had performance measures  that tracked similar outcomes but had variation in the terms used and the  way the measures were calculated. For example, the programs used  different time periods to assess whether participants got jobs. Under  common measures, the time period used to assess employment outcomes  is uniform across all covered programs.
Implementation of common measures involved some changes in the data  states collect for the TAPR:  Standardized exit definitions: Labor’s guidance on common  measures provides for a clearer understanding of when TAA  participants should be exited from the program than did earlier  TAA guidance. Under Labor’s guidance, states must wait 90 days  after participants receive their last service or benefit—from TAA,  WIA, or other related programs—to record them as exiters. Prior to  this change, states could exit participants without waiting 90 days.  Most states reported that the guidance and training they received  from Labor provided a clear understanding of the definition of exit  under common measures, but 7 states disagreed.
Coordination of exit dates: Under common measures, states are  encouraged to establish a common exit date for each participant  who is co-enrolled in more than one program. For example, if a  participant receives services under TAA and under WIA, then the  two programs should use the same exit date for the participant.  Coordinating exit dates improves data quality by avoiding the  problem of counting a participant as unemployed in the program’s  performance measures when, in fact, the participant is still  receiving services in another program and is not ready to be  counted in the performance measures.
Changes in IT systems: A number of data fields were added or  changed in the TAPR as part of the new common measures policy,  requiring states to add or change data fields in their IT systems and  to instruct staff on changes in data to be collected on participants  and employment outcomes. Most states reported that the guidance  and training they received from Labor provided a clear  understanding of the changes needed in the TAPR to implement  common measures; however, 7 states disagreed.
Although moving to common measures may ultimately make it easier for  states to collect and report performance information across programs,  most states reported that making changes to implement common  measures had been a burden in terms of time and cost (see fig. 11), and  often viewed coordinating exit dates as burdensome. States were nearly  evenly divided in their views, however, on whether they had been given  sufficient time by Labor to complete the changes. Nineteen states said they  had not been given sufficient time, while 18 states said they had. Twenty- six states reported that they will have provided guidance to staff or  changed data elements in their IT systems by the time the first quarterly  TAPR is due in fiscal year 2006 (see fig. 12). Other states reported that they  would have these changes completed sometime later in 2006, while some  states said they could not estimate when they will complete the changes.  Coordinating exit dates was the change that states considered the most  burdensome. Seventeen states were unable to estimate when they would  be able to coordinate exit dates across programs.
In a previous study, we cautioned that rushed implementation of reporting  changes may not allow states and local areas enough time to fully meet the  requirements and could negatively affect the data quality of the  information reported.

	Conclusions

Since the passage of the TAA Reform Act of 2002, the TAA program has  evolved to become one of the most important means to help the workers  affected by our nation’s trade policies rejoin our nation’s workforce. The  program has seen substantial increases in the population it serves and in  the funds available to serve them. Unfortunately, efforts to monitor the  program’s performance have not kept pace with the program’s  development. Four years after the passage of the reforms, we still do not  know whether the program is achieving what lawmakers intended.
The TAA program has suffered a history of problems with its performance  data that have undermined the data’s credibility and limited their  usefulness. And while we see that Labor has taken some steps aimed at  improving the performance data, the data remain suspect. They fail to  capture outcomes for some of the program’s participants, and many  participants are not included in the final outcomes at all. These failures  may have contributed to the program’s poor performance in achieving its  national goals. Labor lacks the authority to hold states accountable for  their outcomes or for the quality of their data, and as a result, some states  may not see the value of investing more effort to ensure their data are  complete and accurate. In truth, officials tell us the funding to support  their efforts is small, and it fluctuates from year to year, making such an  investment difficult to sustain. But the success of the program is being  judged by the outcomes the program achieves and whether or not it meets  its goals. The current budgetary environment makes it risky not to take all  necessary steps to ensure that the outcomes are an accurate and credible  reflection of the program’s performance.
Labor has taken a major step toward improving the quality of its  performance data through its new data validation requirements. States  report that these requirements have significantly raised the awareness of  data quality at the state and local levels–an essential component in any  effort to improve the accuracy of the data. But these efforts do not fully  address all issues. No steps have been taken to ensure that all participants  are included in the TAA performance data or that exit dates are adequately  documented. Monitoring can help address data issues, but Labor is just  now developing a standard monitoring guide that would help ensure that  key problems are identified during monitoring visits. Until these steps are  complete, the data can not be verified and may remain incomplete.  Providing opportunities for states to share lessons learned may make  states more aware of effective approaches for ensuring data quality, and  several states expressed an interest in more such opportunities.
Labor has recently improved the availability of TAA performance  information by posting the information on its Web site and by making  some state-by-state performance data available. However, the  performance data are not as informative as they could be because they  aggregate all participants and do not show the outcomes of participants  based on the types of services they received. As a result, policymakers  lack the information they need to understand program participation and  performance and to assess future needs.

	Recommendations for Executive Action

While Labor has taken steps to share information with states and to  improve data quality, more work is needed.
To help ensure that TAA participant data reported by states are consistent,  complete, and accurate, Labor should    clarify through guidance and other communications with states  that all participants who exit the program should be included in the  TAPR and  the documentation needed to verify the training completion date;    ensure that the core monitoring guide currently under development for  regional office site visits includes guidance for assessing whether  states’ data collection processes for performance reporting capture all  participants; and    provide states with opportunities to share lessons learned with other  states on issues that may affect data quality.
To make TAA performance information more useful for program  management, Labor should provide this information by the type of  services received by TAA participants.

	Agency Comments

We provided a draft of this report to Labor for review and comment. In its  comments, Labor did not disagree with our findings and recommendations  and said the report will be helpful in its continuing efforts to improve the  quality of TAA performance data.  Labor noted that the issues raised in the  report about administrative costs and the burden of new reporting  requirements are compounded by having a workforce investment system  that is duplicative in its service delivery design, resulting in separate  record-keeping and reporting systems.  Labor also identified a number of  actions that it is taking to ensure that performance accountability is an  expectation of the program.  A copy of Labor’s response is in appendix IV.
As arranged with your offices, unless you publicly announce the contents  of this report earlier, we plan no further distribution of this report until 30  days from the date of this report.  At that time, we will send copies of this  report to the Secretary of Labor, relevant congressional committees, and  others who are interested.  Copies will also be made available to others  upon request.  The report is also available on GAO’s home page at  http://www.gao.gov.
If you or members of your staff have any questions about this report,  please contact me at (202) 512-7215 or nilsens@gao.gov. Contact points for  our Offices of Congressional Relations and Public Affairs may be found on  the last page of this report. GAO staff who made major contributions to  this report are listed in appendix V.

Appendix I: Objectives, Scope, and Methodology

We examined (1) whether the Trade Adjustment Assistance (TAA)  performance data provide a credible picture of the program’s  performance, (2) what TAA performance data Labor makes available to  the public and states and the usefulness of the data for managing the  program, and (3) what Labor is doing to address issues with the quality of  TAA data submitted by states.
To learn more about the factors that affect TAA data quality and to learn  what states are doing to ensure data quality, we conducted a Web-based  survey of state TAA officials and conducted site visits in five states, where  we interviewed state officials and visited local areas or one-stop centers.  We also collected information on the quality of TAA data through  interviews with Department of Labor officials in headquarters and all six  regional offices, nationally recognized experts, and reviewed relevant  literature. Our work was conducted between December 2004 and   March 2006 in accordance with generally accepted government   auditing standards.
To determine the factors that affect the quality of TAA performance data,  we conducted a Web-based survey of workforce officials in the 46 states  that were allocated TAA funds in fiscal year 2005, and we obtained a   100 percent response rate. These officials were identified using Labor’s list  of state TAA officials. We e-mailed the contacts, and they confirmed that  they were the appropriate contact for our survey or identified and referred  us to another person at the state level. Survey topics included   (1) the current status of TAA data collection and reporting systems,   (2) implementation of the U.S. Department of Labor’s data validation  requirements, (3) state and local efforts to ensure the quality of TAA data,  and (4) the implementation of common measures. The survey was  conducted using a self-administered electronic questionnaire posted on  the Web. We contacted respondents via e-mail announcing the survey, and  sent follow-up e-mails to encourage responses. The survey data were  collected between November 2005 and January 2006. We received  completed surveys from all 46 states that were allocated TAA funding in  fiscal year 2005 (a 100 percent response rate). We did not include  Washington, D.C., and U.S. territories in our survey.

	Web-Based Survey

We worked to develop the questionnaire with social science survey  specialists. Because this was not a sample survey, there is no sampling  error. However, the practical difficulties of conducting any survey may  introduce errors, commonly referred to as nonsampling errors. For  example, differences in how a particular question is interpreted or in the  sources of information that are available to respondents can introduce  unwanted variability into the survey results. We took steps in the  development of the questionnaire, the data collection, and data analysis to  minimize these nonsampling errors. For example, prior to administering  the survey, we pretested the content and format of the questionnaire with  four states to determine whether (1) the survey questions were clear,   (2) the terms used were precise, (3) respondents were able to provide the  information we were seeking, and (4) the questions were unbiased. We  made changes to the content and format of the final questionnaire based  on pretest results. We also performed computer analyses to identify  inconsistencies in responses and other indications of error. In addition, a  second independent analyst verified that the computer programs used to  analyze the data were written correctly.

	Site Visits

We visited five states—California, Iowa, Ohio, Texas, and Virginia—and  traveled to local areas or one-stop centers in each of these states. We  selected these states because they represent different TAA data collection  approaches (that is, states where data are entered into information  technology  systems at the local level and those where data are entered  at the state level), received a relatively large share of TAA funds in fiscal  year 2005, and are geographically dispersed. From within each state, we  judgmentally selected local areas to visit (see table 4). In each state, we  interviewed state TAA officials about their collection and use of TAA data,  IT systems used to compile TAA performance data, and efforts to ensure  the data are complete and accurate. Similarly, we interviewed local area  officials about their collection and use of TAA data.
Information that we gathered on our site visits represents only the  conditions present in the states and local areas at the time of our site  visits, from January 2005 through October 2005. We cannot comment on  any changes that may have occurred after our fieldwork was completed.  Furthermore, we cannot generalize the findings from our site visits beyond  the states and local areas we visited.

Appendix II: Program Information in State TAA IT Systems

In our survey, states were asked whether the IT system they use to  compile data for the Trade Act Participant Report (TAPR) currently  captures program information for certain other Labor programs or  benefits.

Appendix III: State TAA Administrative Allocations, Fiscal Years 2005-2006

The TAA Reform Act authorizes up to $220 million per year for training  under the TAA Program. Labor allocates 75 percent of the training funds to  states according to a formula that takes into account each state’s previous  year allocations, accrued expenditures, and participant levels. Labor holds  the remaining 25 percent of training funds in reserve to distribute to states  throughout the year according to need. To cover administrative costs  associated with training under the TAA program, Labor allocates to each  state additional administrative funds equal to 15 percent of its training  allocation. Table 6 shows Labor’s initial 75 percent allocation for training  and associated administrative expenses. States also receive an additional  15 percent of any reserve (25 percent) funding and job search/relocation  allowances for program administration.

Appendix IV: Comments from the Department of Labor

Appendix V: GAO Contact and Staff Acknowledgments

	GAO Contact

	Acknowledgments

Dianne Blank, Assistant Director  Kathy Peyman, Analyst-in-Charge  In addition, the following staff made major contributions to this report:  Vidhya Ananthakrishnan, Melinda Cordero, Laura Heald, Adam Roye, and  Leslie Sarapu served as team members; Amanda Miller and Carolyn Boyce  advised on design and methodology issues; Rachael Valliere advised on  report preparation; Jessica Botsford advised on legal issues; Lise Levie  verified our findings.

GAO Related Products

Trade Adjustment Assistance: Most Workers in Five Layoffs Received  Services, but Better Outreach Needed on New Benefits. GAO-06-43.  Washington, D.C.: January 31, 2006.
Workforce Investment Act: Labor and States Have Taken Actions to  Improve Data Quality, but Additional Steps Are Needed. GAO-06-82.  Washington, D.C.: November 14, 2005.
Workforce Investment Act: Substantial Funds Are Used for Training, but  Little Is Known Nationally about Training Outcomes. GAO-05-650.  Washington, D.C.: June 29, 2005.
Unemployment Insurance: Better Data Needed to Assess Reemployment  Services to Claimants. GAO-05-413. Washington, D.C.: June 24, 2005.
Workforce Investment Act: Labor Should Consider Alternative  Approaches to Implement New Performance and Reporting  Requirements. GAO-05-539. Washington, D.C.: May 27, 2005.
Trade Adjustment Assistance: Reforms Have Accelerated Training  Enrollment, but Implementation Challenges Remain. GAO-04-1012.  Washington, D.C.: September 22, 2004.
Workforce Investment Act: States and Local Areas Have Developed  Strategies to Assess Performance, but Labor Could Do More to Help.  GAO-04-657. Washington, D.C.: June 1, 2004.
National Emergency Grants: Labor Is Instituting Changes to Improve  Award Process, but Further Actions Are Required to Expedite Grant  Awards and Improve Data. GAO-04-496. Washington, D.C.: April 16, 2004.
Workforce Investment Act: Improvements Needed in Performance  Measures to Provide a More Accurate Picture of WIA’s Effectiveness.  GAO-02-275. Washington, D.C.: February 1, 2002.
Trade Adjustment Assistance: Experiences of Six Trade-Impacted  Communities. GAO-01-838. Washington, D.C.: August 24, 2001.
Trade Adjustment Assistance: Trends, Outcomes, and Management  Issues in Dislocated Worker Programs. GAO-01-59. Washington, D.C.:  October 13, 2000.

Summary:
Why GAO Did This Study

In the current tight budgetary environment, program performance is likely to be an increasingly significant factor used to help policymakers assess programs and determine funding levels. Given concerns over the quality of performance data for the Trade Adjustment Assistance (TAA) program and the importance of having meaningful information to assess program performance, we examined (1) whether the TAA performance data provide a credible picture of the program's performance, (2) what TAA performance data the Department of Labor (Labor) makes available to the public and states and the usefulness of the data for managing the program, and (3) what Labor is doing to address issues with the quality of TAA data submitted by states.

What GAO Found

The performance information that Labor makes available on the TAA program does not provide a complete and credible picture of the program's performance. Only half the states are including all participants, as required, in the performance data they submit to Labor--states were more likely to report participants who received training than those who received other benefits and services but not training. In addition, many states are not using all available data sources to determine participants' employment outcomes. This may result in lower reported outcomes because states may be inaccurately recording some workers as unemployed who actually have jobs. To compile their performance data, some states are using manual processes or automated systems that lack key capabilities to help minimizes errors, but many states have plans to improve their systems' capabilities. Labor reports data on TAA activity levels, services provided to TAA participants, and key performance measures. The performance data may be useful for providing a long-term national picture of program outcomes, but it represents participants who left the program up to 30 months earlier and, thus, is not useful for gauging the TAA program's current performance. Also, the performance information is not displayed using categories that would be informative to policymakers, such as type of service received and industry of dislocation. Most states find the performance information they receive from Labor to be at least moderately useful, but many want more information. Labor has taken steps to improve the quality of TAA performance data, but issues remain. In 2003, Labor began requiring states to validate their data, and most states reported that this increased awareness of data quality at the state and local level. However, the validation process does not address the problem of participants being excluded from the performance data. In fiscal year 2006, Labor instituted a set of common measures, and many states reported they are experiencing delays in implementing all required changes. States also expressed interest in receiving more opportunities to share lessons learned on topics relevant to TAA data quality.