Report to Congressional Requesters

United States Government Accountability Office

GAO

December 2004 WORKFORCE 

INVESTMENT ACT 

Labor Has Taken 

Several Actions to 

Facilitate Access to 

One-Stops for Persons 

with Disabilities, but 

These Efforts May Not 

Be Sufficient 

GAO-05-54 
What GAO Found

United States Government Accountability Office

Why GAO Did This Study

Highlights

Accountability Integrity Reliability

www.gao.gov/cgi-bin/getrpt?GAO-05-54.

To view the full product, including the scope 

and methodology, click on the link above. 

For more information, contact Sigurd Nilsen at 

(202) 512-7215 or nilsens@gao.gov. 

Highlights of GAO-05-54, a report to 

congressional requesters 

December 2004

WORKFORCE INVESTMENT ACT

Labor Has Taken Several Actions to 

Facilitate Access to One-Stops for 

Persons with Disabilities, but These 

Efforts May Not Be Sufficient 

Labor has awarded grants to facilitate comprehensive access, which is 

defined in this report as providing people with disabilities the equal 

opportunity to participate in and benefit from the programs, activities, 

and/or employment offered by the WIA one-stop system. States and local 

areas have used these grants for a range of efforts, including increasing staff 

capacity to provide services to persons with disabilities. During our site 

visits to 18 local areas and one-stops, we found that officials at most sites 

were working to implement architectural access requirements. Moreover, 

local areas and one-stops varied in the degree to which they had addressed 

other areas of comprehensive access. For example, a few sites had only 

begun to acquire assistive technology devices; other sites had assistive 

technology and had trained some or all of their staff in how to use it. 

One-stops have established various relationships to provide services to 

persons with disabilities. The structure of the one-stops’ relationships with 

state vocational rehabilitation (VR) programs varied, as did the extent to 

which they have formed relationships with disability-related service 

providers other than VR. A few local areas and one-stops primarily formed 

relationships with VR, while others had also formed relationships with 

community-based disability organizations. 

Although Labor has taken several actions to ensure comprehensive access to 

one-stops, these efforts may not be sufficient. Labor’s Employment and 

Training Administration (ETA), Civil Rights Center (CRC), and Office of 

Disability Employment Policy (ODEP) have issued guidance and assistance 

on the regulatory requirements. CRC also has conducted on-site reviews at 

local areas and one-stops in two large metropolitan areas in two states. In 

both areas, CRC identified instances of noncompliance with these 

requirements. Reviews in two other states will be completed during fiscal 

year 2005, but Labor has not developed a long-range plan for how it will 

carry out its oversight and enforcement responsibilities beyond 2005. To 

date, CRC’s monitoring and enforcement efforts account for less than 2 

percent of the total number of local areas and one-stops nationwide. The 

CRC Director stated that she had not yet determined whether CRC would 

conduct additional on-site reviews. 

The information that Labor publishes on employment outcomes for people 

with disabilities is limited for a variety of reasons. Disclosure about 

disability status is voluntary, thus the information about employment 

outcomes may be misleading. The collection of information on the 

employment outcomes of WIA participants is limited to those who are 

registered for services, and one-stops are not required to register customers 

who participate in self-service or informational activities. The performance 

measurement system may result in customers being denied services because 

local areas may be reluctant to provide WIA-funded services to job seekers 

who may be less likely to find employment. 

The Workforce Investment Act 

(WIA) of 1998 includes provisions 

intended to ensure that people with 

disabilities have equal opportunity 

to participate in and benefit from 

the programs and activities offered 

through one-stop career centers 

(one-stops). But little is known, 

and questions have been raised, 

about how well this system is 

working for persons with 

disabilities. This report examines 

(1) what the Department of Labor 

(Labor), states, and the one-stops 

have done to facilitate 

comprehensive access to the WIA 

one-stop system; (2) the various 

relationships that the one-stops 

have established with disabilityrelated agencies to provide services

to persons with disabilities; (3) 

what Labor has done to ensure that 

the one-stops are meeting the 

comprehensive access 

requirements, and the factors that 

have affected efforts to ensure 

compliance; and (4) what is known 

about the employment outcomes of 

persons with disabilities who use 

the one-stop system. 

What GAO Recommends

GAO recommends that Labor 

develop and implement a long-term 

plan for ensuring that the one-stops 

comply with the comprehensive 

access requirements. In developing 

such a plan, Labor should use the 

expertise of staff from CRC, ETA, 

and ODEP. Labor generally agreed 

with our recommendation and said 

that even more could be done to 

ensure comprehensive access 

within the one-stop system. 
Page i GAO-05-54 Workforce Investment Act 

Letter 1

Results in Brief 5 

Background 8 

Labor, Local Areas, and One-Stops Have Made Various Efforts and 

Degrees of Progress in Facilitating Access 15 

One-Stops and Disability Agencies Have Established Various 

Relationships to Serve Persons with Disabilities 26 

Labor Has Taken Actions to Ensure That One-Stops Comply with 

Access Requirements, but These Efforts May Not Be Sufficient 28 

Information on Employment Outcomes Is Limited 31 

Conclusions 33 

Recommendation 34 

Agency Comments 34 

Appendix I Comments from the Department of Labor 36 

Appendix II GAO Contacts and Staff Acknowledgments 51 

GAO Contacts 51 

Staff Acknowledgments 51 

GAO’s Related Products 52 

Tables 

Table 1: WIA’s Mandatory One-Stop Partner Programs and Related 

Federal Agencies 9 

Table 2: Work Incentive Grants: 2000, 2002, 2003, and 2004 16 

Table 3: Selected Types of Auxiliary Aids and Services 20 

Table 4: Co-location Status of VR Staff in the One-Stops We Visited 26 

Figure 

Figure 1: GAO Site Visits to Local Areas and One-Stop Centers 4 

Contents 
Page ii GAO-05-54 Workforce Investment Act 

Abbreviations 

ADAAG Americans with Disabilities Act Accessibility Guidelines 

 for Buildings and Facilities 

CRC Civil Rights Center 

ETA Employment and Training Administration 

EO equal opportunity 

HUD Department of Housing and Urban Development 

JTPA Job Training Partnership Act 

MOA Methods of Administration 

ODEP Office of Disability Employment Policy 

SSA Social Security Administration 

TDD telecommunications device for the deaf 

TTY text telephone 

UFAS Uniform Federal Accessibility Standards 

VR Vocational Rehabilitation 

WIA Workforce Investment Act 

WIG Work Incentive Grant 

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Page 1 GAO-05-54 Workforce Investment Act 

December 14, 2004 

The Honorable Judd Gregg, Chairman 

Committee on Health, Education, Labor, and Pensions 

United States Senate 

The Honorable Edward M. Kennedy 

Ranking Minority Member 

Committee on Health, Education, Labor, and Pensions 

United States Senate 

The Honorable Tom Harkin 

United States Senate 

The ability to engage in productive employment is the cornerstone of the 

American workforce system, and the programs and services provided 

through the Workforce Investment Act (WIA) of 1998 are intended for 

persons with and without disabilities. WIA unifies previously fragmented 

employment and training programs and creates a more comprehensive 

workforce investment system by bringing together over $15 billion of 

federally funded programs into a single service delivery system—the onestop center system. WIA requires about 17 programs to provide services 

through the one-stop system, including the Department of Education’s 

Vocational Rehabilitation (VR) program, which provides services to 

eligible individuals with disabilities. The Department of Labor (Labor) is 

responsible for providing general leadership and guidance to the one-stop 

system. Within Labor, the Civil Rights Center (CRC) and the Employment 

and Training Administration (ETA) each have a role in ensuring that 

people with disabilities can participate in and benefit from the programs 

and services provided through the one-stop system. Additionally, Labor’s 

Office of Disability Employment Policy (ODEP) has a role in increasing 

employment opportunities for people with disabilities. 

Section 188 of WIA, among other things, prohibits discrimination on the 

basis of disability with respect to the programs funded or otherwise 

financially assisted under WIA. Labor’s regulations implementing WIA 

Section 188 include specific provisions intended to ensure that persons 

with mobility, mental health, hearing, vision, speech, cognitive, or other 

impairments have equal opportunity to participate in or be employed by 

the programs and activities offered through the one-stop system. These 

regulations encompass provisions that oblige recipients of WIA financial 

United States Government Accountability Office

Washington, DC 20548 
Page 2 GAO-05-54 Workforce Investment Act 

assistance to take positive actions to provide people with disabilities the 

equal opportunity to participate in and benefit from the programs, 

activities, and/or employment offered by the one-stop system. For the 

purpose of this report, we use the term comprehensive access when 

referring to these requirements. These requirements include actions such 

as providing architectural access, program accessibility, reasonable 

accommodations or modifications, service delivery in integrated settings, 

and effective communication. Labor’s regulations also include provisions 

prohibiting covered recipients of federal financial assistance from taking 

discriminatory actions that exclude people with disabilities from 

participating in the programs, activities, or employment offered by the 

one-stop career center system, and provisions requiring recipients to 

establish the administrative structure that CRC views as necessary in 

order to ensure nondiscrimination and equal opportunity for members of 

all groups protected by Section 188 of WIA. 

Despite the requirements contained in these provisions, little is known 

about how well the one-stop system is working for people with disabilities. 

As a result, you asked us to examine (1) what Labor, states, and the onestop centers have done to facilitate comprehensive access to the WIA onestop system; (2) the various relationships that the one-stop centers have 

established with disability-related agencies to provide services to persons 

with disabilities; (3) what Labor has done to ensure that the one-stop 

centers are meeting the comprehensive access requirements, and the 

factors that have affected efforts to ensure compliance; and (4) what is 

known about the employment outcomes of persons with disabilities who 

use the one-stop system. 

To address these issues, we interviewed officials at Labor, and we 

conducted document reviews of Labor’s Work Incentive Grants (WIG) and 

the Disability Program Navigator (Navigator) grants.1

 The Work Incentive 

Grants are designed to enhance the employment and career advancement 

of people with disabilities. The Navigator grants are intended to increase 

employment and self-sufficiency of people with disabilities. We used 

information obtained from these grants to help select which states, local 

 1

The WIG and Navigator grants do not represent all of Labor’s grants for disability-related 

activities. For example, the Office of Disability Employment Policy (ODEP) also provides 

grants for serving customers with disabilities in the WIA one-stop system, including grants 

that focus on providing customized employment strategies to create opportunities for 

individuals with disabilities and improving school-to-work transition outcomes for youth 

with disabilities. 
Page 3 GAO-05-54 Workforce Investment Act 

areas, and full-service one-stop career centers (one-stops) to visit. We 

selected these states on the basis of geographical dispersion, as well as 

whether they received one or more types of grants, if any. We conducted 

site visits to six states—California, Illinois, Massachusetts, Mississippi, 

New Mexico, and Tennessee. We visited three local workforce investment 

areas (local areas) and associated one-stop centers in each of these states. 

After discussions with WIA officials within the six states, we selected the 

local areas and one-stop centers to obtain both urban and suburban 

centers and, where possible, one-stop centers in small towns or rural 

areas. Figure 1 shows the 18 locations we visited. At the local workforce 

investment area and one-stop centers, we interviewed WIA officials, onestop staff, and officials from organizations representing people with 

disabilities about issues and practices for providing programs, services, 

and activities to individuals with disabilities. Additionally, we reviewed 

relevant documents from Labor, as well as the WIA statute and regulations 

and other relevant statutory and regulatory provisions. 
Page 4 GAO-05-54 Workforce Investment Act 

Figure 1: GAO Site Visits to Local Areas and One-Stop Centers 

While WIA and its implementing regulations require that persons with 

disabilities can use the one-stop facilities and participate in and benefit 

from the system’s programs, activities, and services, we did not assess the 

extent to which the approximately 1,900 one-stops, located in about 

600 local areas nationwide, meet the comprehensive access requirements. 

Determining whether a particular site meets architectural access 

standards is fairly straightforward, but this is not the case with 

determining whether other comprehensive access requirements have been 

met. While many of the elements of these requirements, such as provision 
Page 5 GAO-05-54 Workforce Investment Act 

of assistive technology devices, are described in existing regulations, the 

regulations allow one-stops to use a variety of methods to meet the 

requirements. Because there is no one list of methods that covers all paths 

to comprehensive accessibility, it is a complex and resource-intensive task 

to determine whether the comprehensive access requirements have been 

met. Determining whether a single one-stop center is in compliance with 

these requirements requires both on-site observations of the facility and its 

equipment, as well as extensive document reviews and interviews with 

one-stop staff. Determining whether one-stops are in compliance with 

comprehensive access requirements on a nationwide basis was beyond the 

scope of this study. 

We conducted our work between September 2003 and October 2004 in 

accordance with generally accepted government auditing standards. 

Labor has awarded grants to facilitate comprehensive access to 

employment and training programs for persons with disabilities, and local 

areas and one-stop centers have also made numerous efforts, as well as 

various degrees of progress, in facilitating comprehensive access to their 

programs and services. Specifically, Labor’s Employment and Training 

Administration has awarded states and local entities over 100 grants 

totaling $80 million for disability-related activities, such as enhancing 

comprehensive access to the one-stops. States and local areas have used 

these grants for a range of efforts, including assessing one-stop 

architectural accessibility, acquiring assistive technology devices, and 

increasing staff capacity to provide services to persons with disabilities. 

During our site visits to 18 local areas and their one-stops, we found that 

officials in most sites were working to implement architectural access 

requirements. Some of these officials told us that they had made at least 

some changes to improve architectural access. For example, some 

changes included installing signage and electric door openers. However, 

we found that the local areas and one-stops we visited varied in the degree 

to which they had addressed other comprehensive access concerns. For 

example, a few sites had only begun to acquire assistive technology 

devices, while other sites had assistive technology devices and had trained 

some or all of their staff in how to use them. 

One-stops, VR, and other disability-related agencies in the community have 

established various relationships to provide services to persons with 

disabilities. From our site visits, we found that the structure of the onestop centers’ relationships with VR varied, particularly in terms of whether 

co-location was occurring. While most of the one-stops we visited had VR 

Results in Brief 
Page 6 GAO-05-54 Workforce Investment Act 

staff on-site at least part of the time, four of the sites we visited had no onsite VR staff. Officials from the sites at which full- or part-time co-location 

of VR staff was taking place said that co-location was beneficial because, 

among other reasons, it helped the one-stop staff provide faster and less 

fragmented services to persons with disabilities. For those locations at 

which VR was not on-site, officials told us that there were a variety of 

reasons for this, such as a lack of space in the one-stop. The one-stop 

centers we visited also varied in terms of the extent to which they formed 

relationships with disability-related service providers other than VR. In a 

few cases, local areas and one-stops primarily formed relationships with 

VR. However, other local areas and one-stops we visited had also formed 

relationships with one or more disability-related organizations in the 

community, such as independent living centers, mental health agencies, 

and cognitive/developmental disability agencies. Officials from local areas 

and their one-stops, as well as those from VR and community disability 

agencies, cited a range of benefits to being able to refer their customers to 

one another for services, when it was appropriate to do so. For example, 

some local area and one-stop officials said the one-stop’s relationship with 

VR allowed the two agencies to combine their resources to maximize the 

services they can provide to their customers. 

Labor has taken several actions to ensure comprehensive access to onestops by persons with disabilities, but these efforts may not be sufficient. 

For instance, Labor has not only funded grants, it has also provided 

training in ways to facilitate comprehensive access in the one-stop centers. 

Further, within Labor, CRC, along with ETA and ODEP, has provided 

guidance and assistance to one-stops on accommodations and other 

comprehensive access requirements. In addition, CRC has responsibility 

for interpreting, monitoring, and enforcing WIA’s statutory and regulatory 

nondiscrimination, comprehensive access, and administrative provisions. 

One key method Labor uses to ensure adherence to these provisions has 

been to require that each state’s governor sign a plan, known as the 

Methods of Administration (MOA), that describes the policies, procedures, 

and systems that each state has established to ensure adherence with 

WIA’s statutory and regulatory requirements. In addition, in 2003, CRC 

completed its first phase of on-site reviews at local workforce areas and 

one-stops in two large metropolitan areas in two states, Miami/Dade 

County, Florida, and New York City, New York. In both metropolitan areas 

it reviewed, CRC identified instances of noncompliance with WIA’s 

comprehensive access and other requirements, including the existence of 

barriers limiting services to persons with disabilities. On the basis of its 

findings, CRC required the two states to provide it with written responses 

of the corrective actions they planned to make. Further, in May 2004, the 
Page 7 GAO-05-54 Workforce Investment Act 

CRC Director requested that all states complete, for themselves and their 

largest local area, a self-assessment tool to assess compliance with the 

requirements of WIA Section 188 and its implementing regulations. CRC 

anticipates using the information provided by the on-site reviews and selfassessments to identify exemplary practices as well as areas needing 

improvement. Although Labor has taken actions to address the 

comprehensive access and other requirements for persons with 

disabilities, these efforts may not be sufficient to ensure one-stop system 

compliance. For instance, although CRC plans to complete on-site reviews 

in two other large metropolitan areas in two states during fiscal year 2005, 

it has not developed a long-range plan that describes how it will carry out 

its oversight and enforcement responsibilities beyond 2005. Currently, the 

CRC reviews that have been completed, or are in process, represent less 

than 2 percent of the local areas and one-stop centers nationwide. At the 

time of our review, the CRC Director said that she had not yet determined 

whether CRC would conduct additional on-site reviews. 

Information about the employment outcomes of persons with disabilities 

is limited by the extent to which disability data are collected and overall 

data collection methods under WIA. Although Labor publishes some 

information on employment outcomes for people with disabilities in areas 

such as job placement, employment retention, earnings change, and skill 

attainment for the WIA-funded programs, this information is limited for 

several reasons. One reason is that the information Labor publishes on the 

employment outcomes of persons with disabilities is limited to the 

subpopulation of persons with disabilities who disclose their disability 

status, and therefore the employment outcomes may be misleading for the 

total population of persons with disabilities receiving services through 

WIA. Labor has issued guidance stating that one-stops must inquire about 

disability status from job seekers upon registration for services. Such 

inquiries must be asked of all job seekers, but an individual’s decision to 

disclose his or her disability status must be completely voluntary. Further, 

the collection of employment outcome information on WIA participants, 

including information on individuals with disabilities, is limited to those 

individuals who are registered for services. Current law does not require 

that one-stops register job seekers who receive services that are selfservice and informational in nature, and thus they are not included in the 

performance measures. Finally, the performance measurement system 

developed under WIA may result in the denial of services to some 

customers because performance levels are tied to incentives and sanctions 

depending on whether states meet these levels. Consequently, local areas 

may be reluctant to provide WIA-funded services to job seekers, including 

persons with disabilities, in situations in which the persons may be 
Page 8 GAO-05-54 Workforce Investment Act 

unlikely to find employment or experience an increase in earnings when 

placed in jobs. In a prior report, we recommended that Labor develop a 

systematic method to account for different populations and local 

economic conditions when negotiating performance levels.2

 Labor agreed 

with the importance of taking economic conditions and characteristics of 

the population into account when setting performance expectations and 

has commissioned a study to address this issue. 

To improve comprehensive access for persons with disabilities to the onestop system, we recommend that Labor develop and implement a longterm plan for ensuring that the one-stop system complies with the 

comprehensive access requirements for persons with disabilities. In 

developing such a strategy, Labor should utilize the expertise of CRC, 

ETA, and ODEP staff. In commenting on the draft of this report, Labor 

generally agreed with our recommendation and said that even more could 

be done to ensure comprehensive access within the one-stop system. 

The Workforce Investment Act of 1998 requires states and localities to 

bring together about 17 federally funded employment and training services 

into a single system—the one-stop system. Funded through four federal 

agencies, these programs, also known as the mandatory partner programs 

(or more simply, mandatory partners),3

 are to provide services through a 

statewide network of one-stop career centers. (See table 1.) 

 2

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). 

3

Co-location of the mandatory partners at the one-stop center is not required. Labor has 

stated that under WIA, one-stop operations can range from coordination, co-location, and 

integration. 

Background 
Page 9 GAO-05-54 Workforce Investment Act 

Table 1: WIA’s Mandatory One-Stop Partner Programs and Related Federal 

Agencies 

Federal Agency Mandatory One-Stop Partner Program 

Department of LaboraWIA Adult 

 WIA Dislocated Worker 

 WIA Youth 

 Employment Service (Wagner-Peyser) 

 Trade Adjustment Assistance Programs 

 Veterans’ Employment and Training Programs 

 Unemployment Insurance 

 Job Corps 

 Welfare-to-Work Grant-Funded Programs 

 Senior Community Service Employment Program 

 Employment and Training for Migrant and Seasonal 

Farm Workers 

 Employment and Training for Native Americans 

Department of Education Vocational Rehabilitation Program 

 Adult Education and Literacy 

 Vocational Education (Perkins Act) 

Department of Health and 

Human Services 

Community Services Block Grant 

Department of Housing and 

Urban Development (HUD) 

HUD-administered Employment and Training 

Source: GAO-04-657. 

a

Labor’s Employment and Training Administration (ETA), in collaboration with the partner programs, 

provides general leadership and guidance to the one-stop system. 

Three of these 17 programs, which were created and funded by Title I of 

WIA to provide services to adults, dislocated workers, and youth, replace 

those previously funded under the Job Training Partnership Act (JTPA). 

The Department of Labor distributes funds for these three programs to the 

states, and the states in turn distribute funds to designated local areas 

within the states based on formulas prescribed by WIA. WIA also 

established performance measures that states and localities must track in 

order to demonstrate the programs’ effectiveness. The performance 
Page 10 GAO-05-54 Workforce Investment Act 

measures primarily focus on entered employment rates, employment 

retention rates, earnings changes, and credential rates.4

WIA programs provide for three levels of services for adults and dislocated 

workers: core, intensive, and training. Core services include basic services 

such as job search and labor market information. These activities may be 

self-service or may require some staff assistance. Intensive services 

include such activities as comprehensive assessment and case 

management, which require greater staff involvement. Training services 

include such activities as occupational skills training or on-the-job 

training. 

WIA requires the establishment of workforce investment boards at the 

state level and in local areas. The state boards are responsible for a 

number of functions, including the development and improvement of the 

statewide workforce investment system and the designation of local areas. 

The state board assists in the preparation of the state plan and the annual 

report, both of which are submitted to the Secretary of Labor. The local 

workforce investment board sets policy for the local area, and its specific 

duties include developing a comprehensive 5-year local plan and selecting 

one-stop operators. 

WIA contains a number of provisions to ensure that individuals with 

disabilities are adequately served. The most important of these provisions 

is Section 188, which prohibits any program or activity funded or 

otherwise financially assisted in whole or part under WIA from 

discriminating on the basis of disability as well as race, color, religion, sex, 

national origin, age, or political affiliation or belief.5

 4

For more information on WIA’s performance measures, see GAO-04-657 and GAO, 

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). 

5

For WIA beneficiaries only, Section 188 also prohibits discrimination on the basis of an 

individual’s status as a citizen or national of the United States, or as an individual lawfully 

authorized to work in the United States, or on the basis of participation in any WIA Title I 

financially assisted program or activity. 
Page 11 GAO-05-54 Workforce Investment Act 

To help states and local areas implement the Section 188 provisions, the 

Department of Labor issued interim final regulations in November 1999.6

These regulations, which have the force of law, describe requirements for 

the recipients of financial assistance under WIA Title I, and for programs 

and activities operated by the one-stop partners as part of the one-stop 

system.7

 The regulations also identify how recipients will be held 

accountable for ensuring nondiscrimination and equal opportunity for 

individuals with disabilities. 

The WIA Section 188 regulations contain certain provisions that prohibit 

recipients of WIA financial assistance from taking certain discriminatory 

actions. For example, recipients must not: 

• provide significant assistance to a person or entity that discriminates in 

providing any aid, benefits, services, or training to registrants, 

applicants, or participants; 

• make a selection for the site or location of a facility that has a 

discriminatory effect; or 

• impose or apply eligibility criteria that screen out or tend to screen out 

individuals with disabilities, unless such criteria are necessary for the 

provision of the aid, benefit, service, training, program, or activity 

being offered. 

Further, WIA Section 188 regulations contain provisions that oblige 

recipients to take certain positive actions to provide comprehensive 

access to WIA programs and services. For example, these regulations 

require some recipients of WIA financial assistance—those who are in 

facilities or parts of facilities that are constructed or altered on their 

behalf—to make those facilities architecturally accessible. In contrast, 

recipients of WIA financial assistance who are in unaltered existing 

facilities are not necessarily required to make those facilities 

 6

See 64 Fed. Reg. 61692. These regulations are found at 29 CFR Part 37 and incorporate, by 

reference, certain portions of the regulations implementing Section 504 of the 

Rehabilitation Act of 1973, as amended, pertaining to employment practices and 

employment-related training, architectural and program accessibility and reasonable 

accommodation. 

7

WIA Section 188 regulations apply to programs and activities that are conducted as part of 

the one-stop system and operated by one-stop partners, regardless of the source of the 

financial assistance for such programs and activities. 
Page 12 GAO-05-54 Workforce Investment Act 

architecturally accessible, but are subject to other requirements for 

accessibility, known as program access, which specify that a recipient 

must operate each service, program, or activity so that it, when viewed in 

its entirety, is readily accessible to and usable by individuals with 

disabilities. Recipients of WIA financial assistance do not have to make 

each of their existing facilities or every part of an existing facility 

accessible to and usable by individuals with disabilities, and can satisfy 

the accessibility requirements for existing facilities by redesigning 

equipment, reassigning services to accessible buildings, assigning aides to 

beneficiaries, and providing home visits, among other options. 

As part of providing comprehensive access, WIA Section 188 regulations 

require recipients of WIA financial assistance to take a number of 

additional actions when administering their programs or activities. Under 

these provisions, recipients must: 

• take steps to ensure that communications with individuals with 

disabilities are as effective as communications with others, including 

providing appropriate auxiliary aids and services where necessary; 

• provide reasonable accommodation to qualified individuals with 

disabilities who are applicants, registrants, or eligible 

applicants/registrants for, or participants in, employees of, or 

applicants for, employment with their programs and activities, unless 

providing the accommodation would cause undue hardship;8

• make reasonable modifications in policies, practices, or procedures, 

unless making the modifications would fundamentally alter the nature 

of the service, program, or activity; 

• provide the most integrated setting appropriate to the needs of 

qualified individuals with disabilities; and 

 8

In the one-stop context, the term reasonable accommodation can include making existing 

facilities accessible; restructuring a program, service, or training, or the way in which it is 

provided; part-time or modified training schedules; making appropriate adjustments or 

modifications to examinations, training materials, or policies; acquiring or modifying 

equipment and devices; and providing qualified readers and interpreters, among other 

possible actions. One-stops and other recipients are required to make a requested 

accommodation unless providing it would create an undue hardship for them, which is 

defined as “significant difficulty or expense,” when considered in light of a list of specified 

factors. The WIA Section 188 regulations also require one-stops to make reasonable 

modifications to their policies, practices, or procedures for persons with disabilities unless 

making the modification would fundamentally alter the nature of the program or activity. 
Page 13 GAO-05-54 Workforce Investment Act 

• take appropriate steps, such as advertising and marketing, to ensure 

that they are providing universal access to their WIA financially 

assisted programs and activities. 

The regulations also require recipients of WIA financial assistance to 

establish an administrative structure so that they ensure compliance with 

WIA’s nondiscrimination and equal opportunity provisions. Each recipient, 

except small recipients9

 and service providers, must designate an equal 

opportunity (EO) officer who is responsible for ensuring that the recipient 

complies with Section 188 regulations. EO officers’ responsibilities 

include: 

• monitoring and investigating activities by recipients of WIA financial 

assistance to ensure that they do not violate WIA Section 188 

regulations, 

• reviewing written policies to ensure that those policies are 

nondiscriminatory, and 

• developing and publishing the recipient’s procedures for processing 

discrimination complaints. 

Recipients of WIA financial assistance must also provide written 

notification that they do not discriminate on the basis of disability or on 

other prohibited bases. This notification must be placed prominently in the 

facility and distributed through other means. In addition, recipients of WIA 

financial assistance must collect and maintain data necessary to allow 

Labor to determine whether the recipient is complying with Section 188 of 

WIA and the implementing regulations. The Director of Labor’s Civil 

Rights Center determines which data are necessary. 

Under WIA Section 188 regulations, the governor of each state is 

responsible for, among other things: 

• oversight of all WIA financially assisted state programs, 

• ensuring compliance with WIA Section 188 and its implementing 

regulations, and 

 9

A small recipient is one that serves a total of fewer than 15 beneficiaries during a grant 

year and employs fewer than 15 employees on any given day in that year. 
Page 14 GAO-05-54 Workforce Investment Act 

• negotiating with recipients to secure voluntary compliance when 

noncompliance is found. 

Moreover, both the Governor and the recipient of WIA financial assistance 

are liable for all violations of Section 188 unless the Governor has, among 

other things, established, signed, and adhered to an MOA.10 The MOA must 

be in writing and describe how the state programs and recipients of WIA 

financial assistance have satisfied the requirements of certain regulatory 

provisions, including those regarding people with disabilities. 

In addition, the Director of Labor’s CRC has oversight responsibilities 

under the Section 188 regulations, which include: 

• conducting compliance reviews, 

• reviewing the activities of a governor, including the adequacy of the 

MOA, and 

• investigating and resolving complaints alleging violations of Section 

188. 

As part of its oversight responsibility, CRC, with assistance from ETA and 

ODEP, issued a compliance checklist on July 25, 2003, to ensure 

nondiscrimination and equal opportunity to persons with disabilities 

participating in WIA programs and activities. This checklist, officially 

known as the WIA Section 188 Disability Checklist,11 identifies the 

regulations implementing Section 188 of WIA, including portions of the 

regulations implementing Section 504 of the Rehabilitation Act, and covers 

requirements applicable to local area grant recipients regarding the 

operation of their programs and activities. The checklist is based on the 

elements required by the MOA and includes lists of questions for each 

element of the MOA. For some of the elements, the questions are followed 

by examples of concrete actions that can be taken to ensure compliance 

with Section 188 requirements. The appendix to the Checklist also 

 10In order to be exempt from liability for Section 188 violations, the governor must also 

enter into a written contract with the recipient outlining the recipient’s obligations under 

Section 188, act with due diligence to monitor the recipient’s compliance with those 

provisions, and take prompt and appropriate corrective action to affect compliance. 

11The WIA Section 188 Checklist is located at 

http://www.dol.gov/oasam/programs/crc/section188.htm. 
Page 15 GAO-05-54 Workforce Investment Act 

includes additional examples of policies, procedures, and other steps that 

local area grant recipients can take to ensure compliance with Section 188. 

Labor has awarded grants to facilitate comprehensive access to 

employment and training programs for persons with disabilities, and local 

areas and one-stop centers have also made numerous efforts, as well as 

various degrees of progress, in facilitating comprehensive access to their 

programs and services. Specifically, ETA has awarded over 100 grants to 

states and local entities for disability-related activities, such as enhancing 

comprehensive access to the one-stops. States and local areas have used 

these grants for a range of efforts, including assessing one-stop 

architectural accessibility, acquiring assistive technology devices, and 

increasing staff capacity to provide services to persons with disabilities. 

Between 2000 and 2004, ETA awarded state and local entities a total of 

approximately $65 million in competitive Work Incentive Grants in order 

to enhance one-stops’ capacity to provide programs and services to 

persons with disabilities, which included improving one-stop accessibility. 

ETA awarded 113 grants in four rounds between 2000 and 2004. (See table 

2.) 

Labor, Local Areas, 

and One-Stops Have 

Made Various Efforts 

and Degrees of 

Progress in 

Facilitating Access 

Federal Grants Have 

Provided Funding to 

Facilitate One-Stop 

Accessibility 
Page 16 GAO-05-54 Workforce Investment Act 

Table 2: Work Incentive Grants: 2000, 2002, 2003, and 2004 

Work Incentive 

Grants 

Total number of 

grants awarded 

Total amount of 

grants awardeda

 States in which grants were awardedb

First round (2000) 23 $20 million Alaska, California, Florida, Illinois, Indiana, Iowa, Louisiana, Maine, 

Maryland, Massachusetts, Michigan, Missouri, Montana, New 

Hampshire, New Mexico, Ohio, Oregon, Pennsylvania, Rhode 

Island, Tennessee, Texas, Vermont, Washington 

Second round (2002) 23 $20 million California, Colorado, Connecticut, Florida, Hawaii, Illinois, Indiana, 

Kansas, Kentucky, Massachusetts, Minnesota, Missouri, New York, 

North Carolina, Oklahoma, Oregon, South Dakota, Tennessee, 

Texas, Virginia, Washington, West Virginia, Wisconsin 

Third round (2003) 42 $17 million Arizona, Arkansas, California, DC, Florida, Georgia, Hawaii, Illinois, 

Indiana, Michigan, Minnesota, Missouri, Nebraska, New Jersey, 

New Mexico, New York, North Carolina, Oklahoma, Oregon, 

Pennsylvania, Tennessee, Texas, Utah, Washington, West Virginia 

Fourth round (2004) 25 $8 million Alabama, Arkansas, California, Connecticut, Florida, Indiana, 

Kentucky, Maine, Michigan, Missouri, Montana, New Jersey, New 

York, North Carolina, Ohio, Tennessee, Texas, Virginia, 

Washington 

Total 113c $65 million 

Source: GAO analysis of Labor’s Work Incentive Grant information. 

a

The Work Incentive Grants are funded through Labor’s annual appropriation. 

b

Grants could either be statewide in scope, meaning that they covered all local areas throughout the 

state, or local, meaning that they covered a designated region within a state (such as a specific local 

area). Although we are classifying grants by their state affiliation, this does not necessarily indicate 

that all local areas throughout the state benefited from the funds. 

c

In the first and second rounds, only one grant was awarded within each state that received a grant. In 

the third and fourth rounds, more than one grant was awarded within some states. 

On the basis of its experience administering the first two rounds of grants, 

ETA has targeted its specific grant objectives—and, therefore, its 

resources—to meet the emerging needs that states, local areas, and onestops have identified in providing programs and services to persons with 

disabilities. ETA’s objectives for the early rounds of grants were relatively 

broad, and as a result, grantees were permitted to use the funds to 

undertake a range of activities, including: 

• assessing one-stops’ architectural accessibility; 

• acquiring assistive technology devices; 

• conducting outreach to the disability community; 
Page 17 GAO-05-54 Workforce Investment Act 

• linking and coordinating with community disability-related agencies, 

such as community mental health agencies and independent living 

centers; 

• training existing one-stop staff on disability issues; and 

• making available staff who have the experience, knowledge, and skills 

necessary to address a broad range of disability-related issues. 

By the third round of grants, in 2003, ETA had begun to focus its priorities 

more narrowly—though not exclusively—on increasing the capacity of 

one-stop staff to provide services to persons with disabilities. According to 

the third round grant notice, previous grantees had found that building 

staff capacity was successful in improving overall service delivery in their 

one-stops. ETA officials said that although they believe that building staff 

capacity will enhance one-stops’ progress toward making their services 

available to persons with disabilities, they recognize that some one-stops 

may also still need to address other issues, such as meeting the 

architectural access requirements. In addition to targeting their grant 

objectives, ETA officials said they plan to change the process by which 

they award grants. ETA used a competitive process to award all four 

rounds of grants, and as a result, according to ETA officials, some states or 

local areas that needed grants may not have received them.12 ETA officials 

said they plan to use a different process in the future, which would allow 

them to target funding toward specific areas, such as states that did not 

receive grants in the first four rounds and/or states where they would like 

to intensify current grant activities. 

ETA, in conjunction with the Social Security Administration (SSA), which 

administers employment support programs for its disability beneficiaries, 

has provided approximately $24 million to fund a demonstration project 

focused on the establishment and training of one-stop Disability Program 

Navigators.13 The Navigators’ role is to address the needs of persons with 

disabilities seeking to use the one-stop system. Since July 2003, Navigator 

 12Through this competitive process, an ETA technical review panel chose grantees by 

evaluating their applications against specified criteria (such as a statement of need). ETA 

officials explained that some applicants, such as those who were less adept at writing 

applications that met technical review standards, may not have received grants even 

though they needed them. 

13Of the $24 million in funds, Labor contributed approximately $15 million and SSA 

contributed $9 million. 
Page 18 GAO-05-54 Workforce Investment Act 

grants have been awarded in a total of 17 states.14 At the time of our 

review, this initiative had led to 221 Disability Program Navigators 

working in or with one-stops in those states. As designed by ETA and SSA, 

in collaboration with ODEP, Navigators are to provide expertise and serve 

as a resource to one-stops as well as persons with disabilities. ETA and 

SSA expected that Navigators would, in part, carry out many of the same 

types of accessibility-related activities that were funded under the initial 

Work Incentive Grants. The third and fourth rounds of the Work Incentive 

Grants have led to the hiring of staff who can perform functions similar to 

those of a Navigator. At the time of our review, 122 Navigator-like staff had 

been established through the Work Incentive Grants. Eleven of the sites 

we visited had either Disability Program Navigators or Work Incentive 

Grant Navigators. Some of the Navigators we interviewed told us they had 

the following job responsibilities: 

• providing disability-related staff training; 

• helping staff locate resources for specific persons with disabilities, 

such as accommodations or services in the community; 

• developing relationships with disability-related service providers, such 

as VR and other community agencies; and 

• helping to ensure the accessibility of the one-stop, such as by 

conducting accessibility assessments or developing accessibility plans. 

During our site visits, we found that local areas and one-stop centers had 

made various efforts and degrees of progress in facilitating comprehensive 

access to the one-stops’ programs and services. Specifically, we found the 

following: 

Architectural access. Our site visits showed that most local area and 

one-stop officials were working to implement architectural access 

standards, which are required by the WIA Section 188 regulations. Nearly 

all of the sites we visited had undergone at least one architectural 

 14In July 2003, ETA and SSA’s Office of Program Development and Research awarded 

Navigator grants to 14 states: Arizona, California, Colorado, Delaware, Florida, Illinois, 

Iowa, Maryland, Massachusetts, New York, Oklahoma, South Carolina, Vermont, and 

Wisconsin. ETA and SSA have since awarded Navigator grants to Mississippi, New Mexico, 

and Oregon. All 17 of these states were chosen for this effort because SSA has employment 

support initiatives in these locations. 

Local Areas and One-Stops 

Have Made Efforts to 

Facilitate Access to the 

One-Stops’ Services, but 

Progress Has Varied 
Page 19 GAO-05-54 Workforce Investment Act 

accessibility assessment within the last few years, and the assessments 

were typically conducted by VR or other disability-related agencies. Our 

review of these assessments showed that there were often considerable 

differences in the degree of architectural access that the locations had 

achieved. For example, some of the sites had either no or few problems 

with regard to architectural access. Other locations had a number of 

access-related problems, including those related to parking, ramps, and 

doors, as well as restrooms and signage. Some officials at these locations 

told us they had made at least some changes to improve architectural 

access. For example, some changes included: 

• adding or changing accessible parking spaces to meet requirements; 

• installing signage or changing existing signage to meet requirements; 

• building a new exterior ramp because the existing one did not meet 

architectural access requirements; and 

• installing electric door openers.15

Auxiliary aids and services. Many of the one-stops we visited had 

acquired auxiliary aids and services, such as assistive technology and 

materials in alternate formats, which the WIA Section 188 regulations 

require that one-stops provide to persons with disabilities when necessary. 

Auxiliary aids and services include a range of devices, equipment, and 

services that provide effective communication for persons with various 

types of impairments. According to ETA, the auxiliary aids and services 

requirement covers any method of communication, including verbal, 

written, computer-based, or telephone communications. Assistive 

technology refers to products or equipment that can be used to help 

people with disabilities perform their major life functions. Some types of 

assistive technology can be used to make existing information technology, 

including computers and telephones, available to persons with disabilities. 

Alternate formats can, for instance, make written or visual materials 

available to persons with visual impairments or make oral information 

available to persons with hearing impairments. Table 3 describes selected 

 15Electric door openers are not required by either the Uniform Federal Accessibility 

Standards (UFAS) or the Americans with Disabilities Act Accessibility Guidelines for 

Buildings and Facilities (ADAAG). However, officials from some sites said that their lack of 

electric doors was an accessibility concern. 
Page 20 GAO-05-54 Workforce Investment Act 

types of auxiliary aids and services that were available in some of the onestops we visited. 

Table 3: Selected Types of Auxiliary Aids and Services 

Type Purpose 

Examples of impairments for which 

the aid or service may be beneficial 

Screen reading software Software programs that present text as speech Visual impairments 

Cognitive impairments 

Screen magnification software Software that can increase the size of characters on a 

computer screen 

Visual impairments 

Closed-circuit television/video 

magnifier 

Electronically magnifies printed text and displays it on a 

monitor 

Visual impairments 

Speech recognition software Software programs that allow users to give commands and 

enter information using speech rather than a mouse or 

keyboard 

Visual impairments 

Mobility impairments 

Cognitive impairments 

Large-screen computer 

monitors 

Increases character size in proportion to computer monitor 

dimensions 

Visual impairments 

Trackball mouse An alternative to a standard mouse, this mouse has 

movable balls on top of a base that can be used to move 

the cursor on screen 

Mobility impairments 

Alternative keyboards Those with larger or smaller than standard keys or 

keyboards, alternative key configurations, keyboards for 

use with one hand, and others 

Mobility impairments 

TTY (text telephone)/TDD 

(telecommunications device 

for the deaf) 

Device that lets people with hearing or speech impairments 

use the telephone to communicate, by allowing them to 

type messages back and forth to one another instead of 

talking and listening 

Hearing impairments 

Speech impairments 

Other assistive listening 

devices 

Devices that amplify sound in specific listening situations 

(e.g., watching television, using the telephone), while also 

reducing the effects of background noise 

Hearing impairments 

Cognitive impairments 

Alternate formats Presenting print or visual materials in Braille or large print, 

on audiotape, or on compact disk 

Presenting spoken information in writing 

Visual impairments 

Cognitive impairments 

Hearing impairments 

Cognitive impairments 

Source: GAO summary of information collected through site visits and from access guides. 

At the time of our site visits, a few one-stops had either recently installed 

assistive technology for the first time or were still in the process of 

acquiring it. However, other sites had assistive technology, and some or all 

of the staff had already received training in how to use it. Some of these 

sites offered a range of devices, which could assist many types of 

impairments. Given the wide variety of devices available, some local areas 

and one-stops targeted their resources, at least initially, toward items that 

might be used frequently. For example, one local area—working with an 
Page 21 GAO-05-54 Workforce Investment Act 

agency that had assistive technology expertise—collected data on the 

types of impairments that were most prevalent among potential customers 

and then used these data to determine which devices to purchase first. In 

addition, a couple of officials said that their one-stops had some materials, 

such as basic orientation materials, routinely available in Braille or largeprint formats. Some officials told us that they did not have any of their 

materials routinely available in alternate formats, although they would 

provide these to customers upon request. In some cases, officials said that 

they could rapidly provide customers with certain types of alternate 

formats, such as Braille, large print, computer diskette, or compact disk, 

through the use of their assistive technology or computers. 

Reasonable accommodations. Some officials and staff we interviewed 

said they try to make reasonable accommodations for persons with 

disabilities. Reasonable accommodations, which are required by the WIA 

Section 188 regulations, enable persons with disabilities to receive aid, 

benefits, services, or training equal to that provided to persons without 

disabilities. For example, a number of officials and staff mentioned that 

although they did not have a qualified American Sign Language interpreter 

on-site at their one-stops, they have obtained an interpreter upon a 

customer’s request.16 However, during our site visits, we also found that 

local area and one-stops’ policies and procedures for providing reasonable 

accommodations varied. For example, officials from a few local areas and 

one-stops said they referred to their state workforce agency’s or their local 

government’s policies for guidance on this issue. A few officials said that 

they had developed their own local accommodation policies or 

procedures, or planned to do so. For example, one local area developed 

written policies and procedures that provided information on how 

customers should request an accommodation, which staff could assist in 

providing a reasonable accommodation, and which staff were responsible 

for determining if the one-stop is able to provide the accommodation. In 

addition, some officials told us that when they have received 

accommodation requests, they have not maintained records on the types 

of accommodations requested or whether the one-stop provided these 

accommodations. However, in at least one of the local areas we visited, 

 16A reasonable accommodation may require making specific structural or other 

modifications, including the provision of auxiliary aids and services such as sign language 

interpreters, telephone amplifiers, or alternate formats, to meet the specific needs of a 

particular customer with a disability. Accommodations are generally provided only after an 

individual with a disability requests it, as opposed to being available up front. 
Page 22 GAO-05-54 Workforce Investment Act 

the local equal opportunity officer—who addressed all accommodation 

requests—said that he maintained records on this information. 

Integrated settings. During our site visits, we found variation in 

viewpoints regarding the practice of automatically referring persons with 

disabilities to VR for services.17 Even though agencies such as VR could 

provide services to persons with disabilities, the WIA Section 188 

regulations require that one-stops allow persons with disabilities the 

opportunity to receive services in the most integrated setting appropriate 

to meet their needs. An integrated setting is one that enables persons with 

disabilities to interact with persons without disabilities. Although a 

referral to VR may be appropriate for some individuals, automatically 

referring all persons with disabilities to VR does not allow for the 

opportunity to receive services along with persons without disabilities. 

Moreover, an automatic referral to VR does not provide customers with an 

individualized assessment of their abilities and needs. 

Some local area and one-stop officials we interviewed acknowledged that 

automatic referrals to VR did occur in the past. However, a number of 

officials and staff understood that this practice is not appropriate, or said 

that it is not currently occurring in their one-stops. Some of these officials 

and staff said that services for persons with disabilities are determined on 

a case-by-case basis and that unless these individuals want or indicate that 

they need VR services, they are not referred to VR. Some WIA officials, as 

well as a few VR officials and others who have provided staff training on 

disability issues, explained that one-stop staff have been trained not to 

automatically refer persons with disabilities to VR. For example, staff were 

trained not to stereotype persons with disabilities or assume that they 

need VR services, or were trained to provide these customers with a 

choice regarding which services they use. 

However, during our site visits, officials in two local areas told us that they 

currently found it preferable or necessary to automatically refer persons 

with disabilities to VR. Officials from one local area stated that while a 

disability-related agency advised them that one-stop staff should not be 

automatically referring persons with disabilities to VR, they took 

exception to this guidance. The local area officials explained that it would 

 17Individuals with disabilities who are eligible for VR services are those persons who have a 

physical or mental impairment that, for an such individual, constitutes or results in a 

substantial impediment to employment, and who can benefit in terms of an employment 

outcome from vocational rehabilitation services. 
Page 23 GAO-05-54 Workforce Investment Act 

be irresponsible of them not to fully utilize the expertise of the only 

mandatory disability partner in the WIA system. Officials from another 

local area said that although their long-term goal is to train one-stop staff 

to work directly with persons with disabilities, they believe that their onestop staff are currently referring these customers to VR. Additionally, 

some WIA, VR, and disability-related agency officials also expressed 

concerns that trying to meet performance standards could provide an 

incentive for one-stops to automatically refer persons with disabilities to 

VR, only serve those with the least severe disabilities, or not serve them at 

all. Some officials explained that it is sometimes more difficult for persons 

with disabilities, particularly those with more severe disabilities, to find 

and retain jobs, and that it is often more costly for the one-stop to serve 

these individuals. 

Marketing and outreach. Some officials and staff we interviewed cited a 

variety of reasons why marketing the one-stops’ services and conducting 

outreach to persons with disabilities, which are activities required by the 

WIA Section 188 regulations, may be important. One of the reasons cited 

was that many individuals in the community, including those with 

disabilities, were still not aware of the types of programs and services that 

one-stops offer. For example, a one-stop official said that one-stops are 

often thought of as an employment service, without recognition that they 

can offer participants education, referrals to disability-related agencies for 

services, and other assistance. Some WIA officials and disability-related 

agency representatives also said that even when the disability community 

knows what the one-stops offer, the one-stops often have to overcome the 

belief that one-stops do not want to, or are not capable of, providing 

services to persons with disabilities. For example, the disability 

community may believe that the one-stops do not have assistive 

technology or provide other assistance to persons with disabilities. 

Additionally, some officials also stated that they believe that persons with 

disabilities are still more likely to seek services from disability-related 

organizations than from one-stops. 

Some of the officials from local areas and one-stops that had engaged in 

marketing and outreach efforts said they had used one or more 

community-based disability organizations in their efforts. For example, 

local areas or one-stops sometimes approached independent living 

centers, agencies that serve individuals with specific types of disabilities, 

or other organizations to inform them about the one-stops’ services and 

their accessible technology. Some officials also said they used brochures, 

television or radio ads, billboards, or other means to market their services 

to persons with disabilities. Other local area and one-stop officials told us 
Page 24 GAO-05-54 Workforce Investment Act 

about the specialized techniques they used, such as holding a yearly job 

fair for persons with disabilities, which provides attendees with 

information about one-stop services. 

Officials in a few local areas and one-stops, however, stated that they were 

hesitant to market their services to persons with disabilities. For example, 

one local area official was not confident about the ability of some one-stop 

staff to handle disability issues and, as a result, did not want to market 

what the one-stops in the area could not provide. An official in another 

local area expressed a similar viewpoint with regard to the lack of 

marketing around an assistive technology device that had not been used. 

The official stated that the local area had not advertised the device 

because he did not believe the one-stops in that area were fully capable of 

providing services to persons with disabilities. 

Staff training. Although the WIA Section 188 regulations do not 

specifically require that one-stop staff, other than the equal opportunity 

officer and his or her staff, receive training on disability, the WIA Section 

188 Checklist includes training as one example of how one-stops can 

ensure compliance with WIA’s comprehensive access requirements. Onestop staff in the majority of the local areas we visited had received some 

disability-related information and training, but the range of topics covered 

varied across sites. For example, officials in at least one local area told us 

that they were still focusing on providing staff with disability awareness 

training, while officials, staff, and staff training providers in other 

locations described a wider range of training topics, such as: 

• disability awareness or sensitivity training;18

• types of services that VR provides, and the agency’s eligibility rules and 

criteria; 

• types of disability-related agencies in the community, as well as who 

they serve, the types of services they offer, and their contact 

information; 

 18Disability awareness or sensitivity training teaches one-stop staff, for example, to use 

people-first language—such as “an individual with a disability” as opposed to “the 

disabled.” It may also include education on how to interact with persons with disabilities, 

such as asking if an individual needs assistance first rather than automatically providing it 

or speaking directly to a person who is deaf instead of speaking to the person’s sign 

language interpreter. 
Page 25 GAO-05-54 Workforce Investment Act 

• how to identify certain disabilities, including hidden disabilities such as 

mental illness or learning disabilities; and 

• WIA Section 188 training. 

We also found that a few local areas and one-stops created comprehensive 

training programs or targeted their training to identified staff needs. For 

example, one local area created an extensive disability-training program 

that provides online and in-class training on a range of relevant disabilityrelated issues and discusses these issues in the context of particular 

disabilities. This training program has been made available on a statewide 

basis. Also, in one state, staff at the three one-stops we visited had 

undergone, or were scheduled to undergo, an assessment of their training 

needs. These assessments were then going to be used to develop training 

plans for each of these one-stops. 

Some officials and staff stated that the available disability-related staff 

training was beneficial and provided positive outcomes. For example, 

some officials and staff said that the available training made staff more 

comfortable interacting with, and providing services to, persons with 

disabilities and helped them learn about the range of disability-related 

services that VR and other agencies in the community offer. However, 

other officials and staff expressed some concerns about the available 

training. For example, a few of these officials and staff said that they 

would like training on specific disability-related topics to be available, and 

in at least one case, local area and one-stop officials had concerns about 

how well their limited training prepared staff for providing services to 

persons with disabilities. Additionally, some of the officials, staff, and staff 

training providers we interviewed said that their training efforts were 

affected by high staff turnover and the prospect of staff forgetting the 

information learned in training if it is not used very often. Some officials, 

staff, and staff training providers said that offering ongoing training was 

important for these reasons or that they would like ongoing training to be 

available in their one-stops. 
Page 26 GAO-05-54 Workforce Investment Act 

One-stops, VR, and other disability-related agencies in the community have 

formed various relationships to provide services to persons with 

disabilities. From our site visits, we found that the structure of the onestops’ relationships with VR varied, particularly in terms of whether 

co-location was occurring. While most of the one-stops we visited had VR 

staff on-site at least part of the time, four of the sites we visited had no 

on-site VR staff. Table 4 shows the co-location status of VR staff at the 

one-stops we visited. 

Table 4: Co-location Status of VR Staff in the One-Stops We Visited 

Co-location status of VR staff Number of sites 

One or more VR staff on-site on a full-time basis 5

One or more VR staff on-site on a part-time basis 9

No VR staff on-site 4

Source: GAO site visits. 

Officials from the sites at which full- or part-time co-location of VR staff 

was taking place said that co-location was beneficial for a variety of 

reasons. For example, some WIA and VR officials said that co-location 

itself helped the one-stop staff provide faster and less fragmented services 

to persons with disabilities because, when the one-stop staff made 

referrals to VR, they did not have to send customers off-site. A few 

officials also stated that co-location facilitated information sharing and 

helped build relationships between the staff in the two agencies. The 

reasons for VR staff not being on-site also varied, and included a lack of 

space in the one-stop, the inability of VR to break its lease at an existing 

local office, and lack of an interface between the one-stops’ and VR’s 

computer systems. 

The one-stops we visited also varied in terms of the extent to which they 

formed relationships with disability-related service providers other than 

VR. Although VR has extensive expertise in providing services to persons 

with disabilities, other disability agencies in the community also have 

expertise and resources that can benefit one-stops. At the time of our site 

visits, a few local areas and one-stops were relying primarily on VR and 

had not formed working relationships with any other disability agencies. 

However, other local areas and one-stops we visited had formed 

relationships with one or more disability-related organizations in the 

community, such as independent living centers, mental health agencies, 

One-Stops and 

Disability Agencies 

Have Established 

Various Relationships 

to Serve Persons with 

Disabilities 
Page 27 GAO-05-54 Workforce Investment Act 

and cognitive/developmental disability agencies.19 In at least one instance, 

a local area formed relationships with agencies that focus on particular 

impairments. This local area conducted a needs analysis and found that 

relationships with organizations that provide services to persons with 

psychiatric impairments, learning disabilities, and substance abuse issues 

were lacking. As a result, the local area conducted outreach to these types 

of organizations in order to initiate relationships with them. 

Officials from local areas and their one-stops, as well as those from VR and 

community disability agencies, cited a range of benefits to being able to 

refer their customers to one another for services, when it was appropriate 

to do so. For example, some WIA and VR officials said the one-stop’s 

relationship with VR allowed the two agencies to combine their resources 

to maximize the services they can provide to their customers. For 

example, for co-enrolled customers, one agency might pay for school 

tuition while another pays for books. Some local area and one-stop 

officials also said that referring customers to VR and other community 

disability agencies is beneficial because those agencies have the ability 

and funding to provide certain services that the one-stops cannot. In 

addition, officials in some local areas and one-stops said that VR and other 

community agencies’ willingness to conduct staff training, provide onestop accessibility assessments, or participate in one-stop access 

committees was beneficial. 

VR and community disability agencies also cited a number of benefits to 

referring their customers to the one-stops, including access to the onestops’ career resource centers’ computers and telephones, their workshop 

or training classes (such as those for computer skills, interview skills, and 

résumé-writing), and a range of job listings and employer connections 

broader than their own. VR officials also cited other benefits. For example, 

when a VR customer is faced with delayed services because VR is waiting 

for documents substantiating the customer’s disability, the one-stops can 

provide other services in the interim. Additionally, VR officials told us they 

find it useful to refer individuals who did not qualify for services through 

 19These community-based disability organizations typically did not co-locate their staff at 

the one-stops on either a full-time or a part-time basis. However, there were some 

exceptions—such as, for example, in cases in which the disability-related agencies were 

the sole or co-operators of a one-stop. 
Page 28 GAO-05-54 Workforce Investment Act 

VR, whether because of limited funding20 or other reason, to the one-stop 

for services. 

Labor has taken several actions to ensure that persons with disabilities 

have comprehensive access to one-stops, including training, monitoring, 

and enforcement activities, but these efforts may not be sufficient. For 

example, Labor has not only funded grants, it has also provided training in 

ways to facilitate comprehensive accessibility in the one-stop centers. 

Specifically, within Labor, ETA and ODEP, along with SSA, provided 

Disability Program Navigator training in November 2003 in which 

successful approaches to ensuring comprehensive access to one-stops 

were discussed. Additional Disability Program Navigator training was 

provided in November 2004. Further, CRC, with assistance from ETA and 

ODEP has provided written guidance and assistance to one-stops on 

accommodations and other ways to improve comprehensive access for 

persons with disabilities. Also within Labor, CRC conducts national equal 

opportunity training annually. Its August 2004 training included topics 

such as new EO officer orientation, implementing an MOA, ensuring 

compliance with WIA Section 188, testing and assessment tools for 

improving services to persons with disabilities, and train-the-trainer EO 

training. 

In addition to providing training, CRC is the entity responsible for 

interpreting, monitoring, and enforcing WIA Section 188 regulations 

regarding programs receiving financial assistance from Labor, including 

the applicable comprehensive access and administrative regulatory 

requirements for one-stop centers. One key method Labor uses to ensure 

compliance with these regulations has been to require that each state’s 

governor establish and sign an MOA, which describes and contains 

supporting documentation of the policies, procedures, and systems that 

each state has established to ensure compliance. By signing the MOA, and 

submitting it to CRC, the governor agrees to adhere to its provisions. CRC 

provides guidance on preparing the MOA, reviews the adequacy of each 

state MOA submitted, and approves those MOAs that meet its standards. 

Currently, all governors have submitted MOAs that have been approved by 

CRC. After initial approval, states are to notify CRC of any updates to their 

 20In states where VR funding is not sufficient to serve all eligible clients, there may be an 

order of selection in place, whereby VR is able to accept only those individuals with the 

most significant disabilities who could benefit from VR services. Of the states we visited, 

only one was not under an order of selection for the general disability population. 

Labor Has Taken 

Actions to Ensure 

That One-Stops 

Comply with Access 

Requirements, but 

These Efforts May 

Not Be Sufficient 
Page 29 GAO-05-54 Workforce Investment Act 

MOAs, and every 2 years Labor requires states to review them and the 

manner in which they have been implemented, and determine whether 

their MOAs continue to be effective in ensuring compliance with the 

requirements of WIA Section 188 and its implementing regulations. 

In addition, CRC monitors states’ compliance with the nondiscrimination, 

comprehensive access, and administrative regulatory requirements by 

conducting on-site technical assistance compliance reviews at selected 

locations. To facilitate the review process, CRC conducts a 2- to 3-day 

training session for state, local workforce investment area, and one-stop 

center staff.21 In 2003, CRC completed its first phase of on-site training, 

technical assistance, and compliance reviews in two large metropolitan 

areas in two states, Miami/Dade County, Florida, and New York, New 

York. According to Labor’s 2003 Annual Report, CRC focuses its reviews 

on large metropolitan areas so as to maximize the use of its resources. The 

annual report notes that the large labor markets in these areas provide the 

opportunity for gaining a representative picture of the degree of 

compliance with nondiscrimination and equal opportunity laws and 

regulations. 

In both metropolitan areas it reviewed, CRC identified instances of 

noncompliance, including the existence of barriers limiting services to 

persons with disabilities. At one of the two metropolitan areas, CRC found 

significant differences between the disability-related requirements in WIA 

Section 188 and its implementing regulations and the policies, procedures, 

and systems that were actually being used. For example, CRC found that 

the local area had developed a service delivery system in which customers 

with disabilities were routinely being served by programs or activities that 

were separate from those used to serve customers without disabilities. 

Officials at the local area told CRC such a service delivery system had 

developed in part because there was a general sentiment among disabilityrelated service providers that many of their customers did not feel 

comfortable in the one-stops. The WIA Section 188 regulations, however, 

require that services to qualified persons with disabilities be provided in 

the most integrated settings appropriate to the needs of those customers. 

Therefore, as noted in CRC’s review, a one-stop center generally should 

not refer customers with disabilities to a separate program or activity until 

 21In addition to CRC staff, presenters at the sessions included staff from ETA and ODEP, as 

well as representatives of the United States Access Board, and the Job Accommodation 

Network. 
Page 30 GAO-05-54 Workforce Investment Act 

after it has conducted an individualized assessment of a customer’s needs, 

and determined that the channels used to serve customers without 

disabilities cannot provide equally effective aid, benefits, services, or 

training to persons with disabilities. In addition, the ultimate decision 

whether to accept the referral to a separate program or activity must be 

left up to the customer with a disability. If the customer declines to accept 

the referral, the one-stop must serve the customer with a disability through 

the same programs or activities used to serve all other customers. 

In addition, CRC found that the EO officer at the local area in that 

metropolitan area had not been provided with sufficient staff, other 

resources, or adequate support from top management to carry out his 

duties. As a result, staff at the local workforce investment area and 

one-stops had little understanding of their disability-related or other 

obligations under WIA Section 188 regulations. 

At the other metropolitan area reviewed, CRC found that some of the 

policies, procedures, and systems in the state’s approved MOA had not 

been fully implemented. For instance, the local workforce investment area 

had developed an intake eligibility form for use by the one-stops that 

included questions concerning whether or not the customer had a 

disability that was or was not a substantial barrier to employment. 

Frontline staff at the one-stop centers told CRC that all customers were 

welcome to use self-service and core services. However, CRC found that 

customers who indicated on the intake form that they had a disability 

could not receive intensive or training services unless they provided the 

one-stop with documentation to support their disability, even when 

disability was not an eligibility criterion to receive such services. CRC 

found that the use of the intake form, combined with the requirement that 

customers provide documentation of their disability, unnecessarily 

screened out people with disabilities from receiving intensive and training 

services, even though Labor’s WIA Section 188 regulations require that the 

one-stops must not deny any qualified person with a disability the 

opportunity to participate in, or benefit from, a WIA-funded program or 

activity because of that person’s disability. On the basis of its findings, 

CRC required the state entities responsible for WIA in which the two 

metropolitan areas were located to provide it with written responses of 

the corrective actions they planned to make. 

In addition, in May 2004, the CRC Director requested that all states 

complete, for themselves and their largest local area, a self-assessment 

tool to assess compliance with the equal opportunity and 

nondiscrimination laws and regulations. The self-assessment tool, which 
Page 31 GAO-05-54 Workforce Investment Act 

provides a structured approach for monitoring compliance, was adapted 

from the WIA Section 188 Disability Checklist. For each state and its 

largest local workforce investment area, the self-assessment tool asks 

whether or not each measure of compliance has been met. For all unmet 

measures, the self-assessment tool asks for a written explanation of how 

and when the measure will be met. At the time of our review, CRC was in 

the process of developing a plan to analyze the qualitative responses they 

would receive from the states. CRC anticipates using the information 

provided by these self-assessments and from its on-site reviews to identify 

exemplary practices as well as areas needing improvement. 

In addition to the two on-site reviews CRC conducted in 2003, CRC is in 

the process of conducting two additional reviews in two large 

metropolitan areas in two other states, which it plans to complete during 

fiscal year 2005. To date the monitoring and enforcement efforts that have 

been or are being conducted account for less than 2 percent of the total 

number of local areas and one-stops nationwide. Moreover, the CRC 

Director said that she had not yet determined whether CRC would conduct 

additional on-site reviews. Limited staff and competing work priorities 

may hinder CRC’s ability to conduct additional reviews. The Director 

noted that CRC has experienced an erosion in the number of staff since 

1998, and she did not foresee any change to this trend in the future. The 

44 professional and administrative staff that CRC currently has are 

responsible for not only all issues involving discrimination in one-stops 

and other Labor-funded programs, but also for all discrimination issues 

involving the more than 17,000 employees at Labor. Moreover, the Director 

explained that these staff are also responsible for addressing other 

workload priorities, such as issues to improve access to programs and 

activities for persons who are limited in their English proficiency. 

Information about the employment outcomes of persons with disabilities 

is limited by the extent to which disability data are collected and the 

overall methods used for collecting data for WIA’s performance measures. 

The three WIA-funded programs—Adult, Dislocated Worker, and Youth—

have performance measures established under WIA that states must track 

and report in order to demonstrate the effectiveness of the programs. 

These performance measures gauge program results in such areas as job 

placement, employment retention, earnings changes, and skill attainment. 

In addition to providing information about all participants in the three 

WIA-funded programs, Labor also publishes outcome information about 

certain subpopulations, including veterans, older individuals, and persons 

with disabilities. 

Information on 

Employment 

Outcomes Is Limited 
Page 32 GAO-05-54 Workforce Investment Act 

The information Labor publishes on the employment outcomes of persons 

with disabilities, however, is limited for several reasons. One reason is that 

the information is limited to the subpopulation of persons with disabilities 

who disclose their disability status, and therefore the employment 

outcomes may be misleading for the total population of persons with 

disabilities receiving services through WIA. The WIA Section 

188 regulations require one-stops to collect, maintain, and report job 

seekers’ demographic data—including disability status—to ensure that 

discrimination is not occurring. Labor has issued guidance stating that 

one-stops must inquire about disability status from job seekers upon 

registration for services. Such inquiries must be asked of all job seekers, 

but an individual’s decision to disclose his or her disability status must be 

completely voluntary. Even though an individual declines to indicate his or 

her disability status, the one-stop must still provide services to the 

individual. 

Further, the collection of information on employment outcomes, including 

the information on persons with disabilities, is limited to those persons 

who are registered for WIA services. Current law does not require job 

seekers who receive services that are self-service and informational in 

nature to be included in the performance measures. Labor’s guidance 

instructs states to register and report on adults and dislocated workers 

who receive core services that require significant staff assistance designed 

to help with job seeking or acquiring occupational skills, but states have 

flexibility in deciding what constitutes significant staff assistance.22 We 

have previously reported that most of the one-stop customers who 

participate in self-directed services, and receive only limited staff 

assistance, are estimated to be the largest proportion of job seekers under 

WIA.23 But since they are not registered for services, they are excluded 

from the employment outcome data published by Labor. In that report, we 

also noted that Labor said that it is developing a new reporting system that 

would enable states to report activity and outcomes for all WIA 

participants. According to Labor, tracking all one-stop job seekers will 

enable officials to obtain information about who is served, what services 

 22All youth who receive WIA-financially assisted services are required to be registered. 

23GAO-04-657. 
Page 33 GAO-05-54 Workforce Investment Act 

are provided, which partner programs provided the services, and what 

outcomes are achieved.24

Finally, the performance measurement system developed under WIA may 

have a negative effect on the economic outcomes of some people with 

disabilities because the performance levels may provide a disincentive to 

serve certain clients, including those with disabilities. Under WIA, 

performance levels are tied to incentives and sanctions so that states can 

be financially rewarded if they meet them or penalized if they do not. As 

such, local areas may be reluctant to provide WIA-funded services to job 

seekers, including persons with disabilities, who may be less likely than 

others to find employment or experience an increase in earnings when 

they are placed in jobs. To address this issue, we recently recommended 

that the Secretary of Labor develop an adjustment model or other 

systematic method to account for different populations and local 

economic conditions when negotiating performance levels.25 In 

commenting on our recommendation, Labor agreed with the importance 

of taking economic conditions and characteristics of the population into 

account when setting performance expectations and had commissioned a 

study of adjustment models that could better take these differences into 

account. 

The WIA one-stop system’s ability to provide comprehensive access to its 

programs, services, and activities can affect whether, and how, individuals 

with disabilities participate in the American workforce. Although Labor 

has developed specific regulations requiring that people with disabilities 

have equal opportunity to participate in and benefit from the programs and 

services offered in the WIA one-stop system, its efforts to date may not be 

sufficient to ensure that result. Five years after Labor issued regulations 

implementing the nondiscrimination and equal opportunity provisions of 

WIA Section 188, the agency has yet to develop and implement a long-term 

plan for ensuring that the one-stop system complies with the 

comprehensive access requirements for persons with disabilities. Although 

CRC, ETA and ODEP have worked together on some comprehensive 

 24In addition, on July 16, 2004, Labor published a notice in the Federal Register on a 

proposal to collect additional information on the types of impairments that one-stop 

customers have, including learning disabilities, visual, hearing, and speech impairments, 

and cognitive and psychological impairments. Labor believes that collecting information on 

impairment types will facilitate its ability to focus on, and evaluate its effectiveness in, 

servicing people with disabilities through the one-stop system. 

25GAO-04-657. 

Conclusions 
Page 34 GAO-05-54 Workforce Investment Act 

access projects, they have not developed an overall plan to conduct the 

activities necessary to ensure comprehensive access to one-stops for all 

Americans. 

To improve comprehensive access for persons with disabilities to the onestop system, we recommend that Labor develop and implement a longterm plan for ensuring that the one-stop system complies with the 

comprehensive access requirements for people with disabilities. Moreover, 

in this era of constrained resources, Labor should utilize the expertise of 

CRC, ETA, and ODEP staff in developing such a plan. 

We provided a draft of this report to the Departments of Labor and 

Education for their review and comments. Education did not have 

comments on our report. 

Labor generally agreed with our recommendation and said that even more 

could be done to ensure comprehensive access within the one-stop 

system. Specifically, ETA has pledged to work with ODEP and CRC to 

develop and implement a long-term plan for addressing comprehensive 

access in the one-stop system. ETA also suggested that the development of 

such a long-term plan should include all of the participating agencies and 

programs. Moreover, ODEP stated that the comprehensive plan should 

also address nonspecialized disability supports and services, such as 

transportation. 

ODEP and CRC also provided us with some general comments on our 

report. ODEP noted that, in addition to the WIG and Navigator grants, 

Labor supports other efforts to facilitate the inclusion of people with 

disabilities in the one-stop system. Although our report focuses on those 

grants that are most directly related to facilitating comprehensive access 

in the one-stop system, we have added examples of some of the types of 

grants that ODEP has awarded to support employment-related initiatives 

for people with disabilities. In addition, CRC asked us to clarify our use of 

the term comprehensive access. CRC expressed some concern that we had 

included administrative requirements in the use of the term 

comprehensive access. CRC believed that administrative requirements 

should not be included as they are not specifically disability-related. We 

have modified the language in our report to clarify that the administrative 

requirements are not included in the term comprehensive access. 

 

Recommendation 

Agency Comments 
Page 35 GAO-05-54 Workforce Investment Act 

ETA, ODEP, and CRC also provided us with technical comments and 

clarifications, which we have incorporated as appropriate. Copies of their 

comments appear in appendix I. 

We are sending copies of this report to the Secretary of Labor, the 

Secretary of Education, relevant congressional committees, and others 

who are interested. Copies will also be made available to others upon 

request. The report will be available on GAO’s Web site at 

http://www.gao.gov. 

Please contact me on (202) 512-7215 if you or your staff have any 

questions about this report. Other major contributors to this report are 

listed in appendix II. 

Sigurd R. Nilsen 

Director, Education, Workforce 

 and Income Security Issues 
Appendix I: Comments from the Department 

of Labor 

Page 36 GAO-05-54 Workforce Investment Act 

Appendix I: Comments from the Department 

of Labor 
Appendix I: Comments from the Department 

of Labor 

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Appendix I: Comments from the Department 

of Labor 

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Appendix I: Comments from the Department 

of Labor 

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Appendix I: Comments from the Department 

of Labor 

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Appendix I: Comments from the Department 

of Labor 

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Appendix I: Comments from the Department 

of Labor 

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Appendix I: Comments from the Department 

of Labor 

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Appendix I: Comments from the Department 

of Labor 

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Appendix I: Comments from the Department 

of Labor 

Page 45 GAO-05-54 Workforce Investment Act 
Appendix I: Comments from the Department 

of Labor 

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Appendix I: Comments from the Department 

of Labor 

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Appendix I: Comments from the Department 

of Labor 

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Appendix I: Comments from the Department 

of Labor 

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Appendix I: Comments from the Department 

of Labor 

Page 50 GAO-05-54 Workforce Investment Act 
Appendix II: GAO Contacts and Staff 

Acknowledgments 

Page 51 GAO-05-54 Workforce Investment Act 

Carol Dawn Petersen, Assistant Director (202) 512-7215 

Gretta L. Goodwin, Senior Economist (202) 512-7215 

William E. Hutchinson and Caterina Pisciotta made significant 

contributions to all phases of this report. In addition, Jessica Botsford and 

Richard Burkard provided legal assistance, and Amy Buck assisted in 

report development. 

Appendix II: GAO Contacts and Staff 

Acknowledgments 

GAO Contacts 

Staff 

Acknowledgments 
Related GAO Products 

Page 52 GAO-05-54 Workforce Investment Act 

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. 

Workforce Investment Act: One-Stop Centers Implemented Strategies to 

Strengthen Services and Partnerships, but More Research and 

Information Sharing Is Needed. GAO-03-725. Washington, D.C.: June 18, 

2003. 

Workforce Investment Act: Exemplary One-Stops Devised Strategies to 

Strengthen Services, but Challenges Remain for Reauthorization. 

GAO-03-884T. Washington, D.C.: June 18, 2003. 

Workforce Training: Employed Worker Programs Focus on Business 

Needs, but Revised Performance Measures Could Improve Access for 

Some Workers. GAO-03-353. Washington, D.C.: February 14, 2003. 

Older Workers: Employment Assistance Focuses on Subsidized Jobs and 

Job Search, but Revised Performance Measures Could Improve Access to 

Other Services. GAO-03-350. Washington, D.C.: January 24, 2003. 

Workforce Investment Act: States and Localities Increasingly Coordinate 

Services for TANF Clients, but Better Information Needed on Effective 

Approaches. GAO-02-696. Washington, D.C.: July 3, 2002. 

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. 

Voters with Disabilities: Access to Polling Places and Alternative Voting 

Methods. GAO-02-107. Washington, D.C.: October 15, 2001. 

Workforce Investment Act: Better Guidance Needed to Address Concerns 

over New Requirements. GAO-02-72. Washington, D.C.: October 4, 2001. 

Workforce Investment Act: New Requirements Create Need for More 

Guidance. GAO-02-94T. Washington, D.C.: October 4, 2001. 

Related GAO Products 

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