TRADE 

ADJUSTMENT 

ASSISTANCE

Labor Awarded 

Community College 

Grants in Accordance 

with Requirements, 

but Needs to Improve 

Its Process

Report to Congressional Committees

September 2012

GAO-12-954

United States Government Accountability Office

GAO
United States Government Accountability Office

Highlights of GAO-12-954, a report to 

congressional committees

September 2012

TRADE ADJUSTMENT ASSISTANCE

Labor Awarded Community College Grants in 

Accordance with Requirements, but Needs to 

Improve Its Process

Why GAO Did This Study

The Trade and Globalization 

Adjustment Assistance Act of 2009 

(TGAAA), part of the American 

Recovery and Reinvestment Act of 

2009, authorized assistance to 

communities, workers, farmers, and 

firms affected by trade. One such 

program, the Trade Adjustment 

Assistance Community College and 

Career Training grant program, is 

administered by Labor and authorizes 

grants to eligible institutions of higher 

education for educational or career 

training programs suitable for tradeaffected workers. Total grant funding is 

$2 billion for 4 years and the first round 

of grants was awarded in September 

2011. The TGAAA requires GAO to 

examine the operation and 

effectiveness of the changes made by 

the act to this program. GAO examined

how Labor (1) designed and awarded 

the grants and to what extent it 

complied with applicable requirements; 

(2) monitors the grants and what is 

known about implementation to date; 

and (3) plans to evaluate the program. 

GAO reviewed a nongeneralizable 

sample of 32 grant applications based 

on funding status, total scores, and 

total grant amounts; grantees’ quarterly 

reports; and relevant federal laws, 

regulations, policy and guidance; and 

interviewed federal and state officials. 

What GAO Recommends

GAO recommends that Labor take 

steps to more effectively manage its 

process when states must designate 

grantees by, for example, building in 

additional lead time or providing states 

with guidance to help inform their 

designation of a grantee. Labor agreed 

with the recommendation.

What GAO Found

The Department of Labor (Labor) designed and awarded the grants following its

standard competitive award process by developing and publishing an 

announcement, screening applicants, and convening expert panels to score 

applications. It also collaborated with the Department of Education to develop the 

announcement and identify panelists. Though they varied in terms of target 

populations, as permitted by the grant, the applications GAO reviewed addressed 

trade impact, as required. However, the law’s requirement that every state 

receive a minimum amount of funding created challenges for Labor and certain 

grantees when applicants in 17 states scored below the cutoff score for grant 

awards. In these instances, Labor’s process stipulated that states designate an 

eligible institution. States, however, were given a 3-day deadline—over a 

weekend—to designate a grantee. As a result, these states had little time to 

identify an institution. The states that GAO contacted said that they found this 

process challenging or confusing and that they received no guidance from Labor. 

Moreover, state-designated grantees experienced delays in implementing their 

grants and required assistance from Labor to modify their original proposals and 

comply with grant requirements. Labor has identified lessons learned from the 

first round of grants and applied them to the second round, but the process for 

selecting state-designated grantees has remained similar to that used in the first 

round. 

Labor monitors grantees in various ways and grantees are in the early stages of 

implementation. Most grantees, as anticipated, are building capacity for their 

programs and have not yet enrolled participants. Labor reviews grantees' 

quarterly progress reports, communicates with grantees, and plans to conduct 

on-site monitoring as resources permit. The most recently available progress 

reports indicate that grantees have taken steps to set up their programs by, for 

example, hiring program administrators and developing curricula. In addition, as 

of March 31, 2012, grantees had spent 5 percent of awarded funds, but have 

until September 2014 to spend all the funds. State-designated grantees received 

funds several quarters after the grants were awarded, while awaiting Labor's 

approval of their plans, but Labor’s monitoring did not indicate that these grants

were more likely to have problems with grant integrity or performance than the 

others. Labor rated the overall risk of most grants as low, but identified 

performance accountability as a moderate or high risk area for more than a third 

of grants after the first quarter of fiscal year 2012. In response to this 

implementation challenge, Labor issued additional guidance for grantees. 

Labor plans to evaluate the program at the national and grantee levels. Labor

plans to begin the first phase of the evaluation in fall 2012. Labor stated that the 

evaluation will be based partly on a survey of grant recipients and site visits to a 

sample of grant projects. Given the relatively early stage of grant implementation, 

the national evaluation will focus on program implementation and subsequently 

examine outcome data to assess program effectiveness. Also, round-two 

grantees will be required to obtain third-party evaluations of their projects. Labor 

anticipates challenges in obtaining consistent and comparable grantee outcome 

data. And given that the grant performance period for the first round of grants is 3 

years, it will likely be several more years before Labor can determine overall 

program effectiveness. 

View GAO-12-954. For more information, 

contact Andrew Sherrill at 202-512-7215 or 

sherrilla@gao.gov
Page i GAO-12-954 TAA Community College Grants

Letter 1 

Background 4

Labor Designed and Awarded Grants in Accordance with TGAAA 

Requirements, but Found It Challenging to Award Each State a 

Minimum Amount of Funding 8

Labor Is Tracking and Addressing Issues Raised by Grantees, and 

Grant Implementation Is in an Early Stage 20

Labor Plans to Evaluate the Program at the National and Grantee 

Level, but Anticipates Some Challenges 25

Conclusions 26

Recommendation for Executive Action 27

Agency comments 27

Appendix I Grants Awarded in Round One and TAA Information by State 29

Appendix II Comments from the Department of Labor 32

Appendix III GAO Contacts and Staff Acknowledgments 33

Related GAO Products 34

Tables

Table 1: Evaluation Criteria of TAACCCT Round One Grant 

Applications 9

Table 2: Community College and Career Training Grants Awarded 

in Round One 12

Figures

Figure 1: Labor’s Competitive Grant Award Process 7

Figure 2: Process for Reviewing and Scoring TAACCCT Grant 

Applications 13

Figure 3: Range of Scores and Median Scores for TAACCCT Round 

One Applications 15

Contents
Page ii GAO-12-954 TAA Community College Grants

Figure 4: Timeline of TAACCCT Grant Program for Round One of 

Grants 16

Figure 5: Labor’s Overall Risk Assessments by How Grantee was 

Selected, after First Quarter of Fiscal Year 2012 23

Figure 6: Labor’s Risk Assessment of Grants by Risk Area, after 

First Quarter of Fiscal Year 2012 24

Abbreviations

Education Department of Education

Labor Department of Labor

SGA Solicitation for Grant Applications

TAA Trade Adjustment Assistance

TAACCCT Trade Adjustment Assistance Community College 

and Career Training

TGAAA Trade and Globalization Adjustment Assistance Act 

of 2009

This is a work of the U.S. government and is not subject to copyright protection in the 

United States. The published product may be reproduced and distributed in its entirety 

without further permission from GAO. However, because this work may contain 

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necessary if you wish to reproduce this material separately.
Page 1 GAO-12-954 TAA Community College Grants

United States Government Accountability Office

Washington, DC 20548

September 28, 2012

The Honorable Max Baucus

Chairman

The Honorable Orrin G. Hatch

Ranking Member

Committee on Finance

United States Senate

The Honorable Dave Camp

Chairman

The Honorable Sander Levin

Ranking Member

Committee on Ways and Means

House of Representatives

In an increasingly competitive global economy, America’s economic 

strength depends upon the education and skills of its workers. According 

to the Department of Labor, occupations that usually require a postsecondary degree are expected to account for nearly half of all new jobs 

from 2008 to 2018, and the fastest growth will occur in occupations 

requiring an associate’s degree. Community colleges, which award 

associate’s degrees and other credentials, are major contributors to the 

nation’s higher education system, enrolling more than 7 million students

each year, or about 40 percent of all post-secondary students.1

The Trade Adjustment Assistance Community College and Career 

Training (TAACCCT) grant program was created to support educational 

and career-training programs suitable for workers who have lost their jobs 

or are threatened with job loss as a result of foreign trade. The TAACCCT 

program was authorized by the Trade and Globalization Adjustment 

Assistance Act of 2009 (TGAAA), which was part of the American 

Recovery and Reinvestment Act of 2009.2

 

1

In 2008, we reported how community colleges meet workforce training needs. See GAO, 

Workforce Development: Community Colleges and One-Stop Centers Collaborate to Meet 

21st Century Workforce Needs, 

 Under the TAACCCT grant 

GAO-08-547 (Washington, D.C.: May 15, 2008).

2

Pub. L. No. 111-5, div. B, tit. I, subtitle I, § 1872(a), 123 Stat. 401, codified at 19 U.S.C. 

§2371. The TGAAA amended the Trade Act of 1974, Pub. L. No. 93-618. 

 
 

Page 2 GAO-12-954 TAA Community College Grants

program, the Department of Labor (Labor) awards grants to eligible 

institutions of higher education3

—including consortia of two or more 

institutions—to develop, offer, or improve educational or career training 

programs for workers who are eligible for training under the Trade 

Adjustment Assistance (TAA) for Workers program, which provides 

federal assistance to workers who have been adversely affected by 

foreign trade.4 Congress appropriated $500 million per fiscal year from 

2011 to 2014 to carry out the grants program. Each state, the District of 

Columbia, and Puerto Rico is guaranteed a minimum of 0.5 percent of the 

total funding, or $2.5 million per state per year.5

The first Solicitation for Grant Applications (SGA) was published in 

January 2011 and the grant recipients were announced on September 26,

2011. The first round resulted in a total of 258 applicants and 49 winning 

awards. The second SGA was published in February 2012 and the 

application deadline was May 24, 2012. According to Labor officials, 

Labor plans to announce the second round of winning grants no later than 

September 30, 2012.

While the statute assigns 

Labor the responsibility of awarding and administering the grants, Labor 

has implemented the grant in partnership with the Department of 

Education (Education).

 

3

For purposes of the TAACCCT grants, eligible institutions are institutions of higher 

education eligible to participate in federal student aid programs authorized under Title IV 

of the Higher Education Act of 1965, as amended, offering programs that can be 

completed in 2 years or less, and include public, private non-profit, and for-profit 

institutions. 19 U.S.C. § 2371(b)(1).

4

While the grants are intended to assist institutions in developing, offering, or improving 

training programs for TAA-eligible workers, other workers, such as dislocated and 

unemployed workers, may enroll in these training programs. 

5

Health Care and Education Reconciliation Act of 2010, Pub. L. No. 111-152, § 1501, 124 

Stat. 1070, codified at 19 U.S.C. § 2372(b). 
 

Page 3 GAO-12-954 TAA Community College Grants

The TGAAA mandated that we report on the operation and effectiveness 

of the amendments made by this Act no later than September 30, 2012.6

1. How did Labor design and award the grants and to what extent did it 

comply with applicable requirements?

Given that the first round of grants was recently awarded, this report 

examines the processes that Labor followed in awarding, monitoring, and 

developing plans to evaluate the first round of TAACCCT grants. 

Accordingly, we addressed the following questions:

2. How does Labor monitor the grants and what is known about 

implementation to date?

3. How does Labor plan to evaluate the program?

To determine how Labor designed and awarded the grants and the extent 

to which it complied with applicable federal requirements, we reviewed 

the 2009 legislation and other relevant federal laws, regulations, and 

guidance; Labor’s policies and procedures; and TAACCCT grant 

announcements and solicitations. We also interviewed Labor and 

Education officials to obtain a better understanding of how the TAACCCT 

grants were awarded. In addition, we reviewed a nongeneralizable 

sample of 32 grant applications to determine if Labor complied with 

applicable requirements in awarding the grants. Of the 49 grants 

awarded, our sample included 9 grantees who were awarded a grant 

through Labor’s standard grant award process, and all 17 grantees who 

were awarded a grant based on designations by state higher education 

agencies. In addition, our sample included 6 of the 211 applications that 

were not awarded a grant. Our criteria for selecting the 9 funded and 6 

unfunded applications included (1) grantees’ status as individual or 

consortium grantees, (2) a range of total scores assigned through the 

 

6

The TAA programs provide assistance to farmers and fishermen, firms, workers, and 

communities impacted by trade. See GAO, Trade Adjustment Assistance: Changes to the 

Workers Program Benefited Participants, but Little Is Known about Outcomes, 

GAO-12-953 (Washington, D.C.: September 28, 2012); GAO, Trade Adjustment 

Assistance: USDA Has Enhanced Technical Assistance for Farmers and Fishermen, but 

Steps Are Needed to Better Evaluate Program Effectiveness, GAO-12-731 (Washington, 

D.C.: July 12, 2012); GAO, Trade Adjustment Assistance: Commerce Program Has 

Helped Manufacturing and Services Firms, but Measures, Data and Funding Formula 

Could Improve, GAO-12-930 (Washington, D.C.: September 13, 2012); and GAO, Trade 

Adjustment Assistance: One-Time Grants Awarded to Trade-Impacted Communities; 

Results Will Not Be Known until after 2013, GAO-12-993 (Washington, D.C.: September 

26, 2012). 
 

Page 4 GAO-12-954 TAA Community College Grants

grant selection process, (3) a range of total grant amounts, (4) receipt of a 

supplemental award for certain purposes allowed by the grant, (5) 

number of trade-affected workers in each state, and (6) presence of a 

Department of Commerce grant to trade-affected communities. 

Additionally, to better understand how the grants were awarded and to 

determine how states designated grantees, we interviewed three 

grantees and representatives of four state higher education agencies 

selected based on a mix of factors including an applicant’s total score 

assigned through the grant selection process, whether the application 

went through the scoring process, and the number of applicants within a 

given state.

To determine how Labor monitors the grants and what is known about 

grant implementation, we interviewed Labor officials about the agency’s 

monitoring systems and practices. We also reviewed grantees’ quarterly 

progress and financial reports, as well as Labor’s assessments of these 

reports. To determine how Labor plans to evaluate the program, we 

reviewed Labor’s progress and outcome measures for the program and 

its first annual report on the grants. We also interviewed Labor officials 

about their plans to conduct formal program evaluations.

We conducted this performance audit from February 2012 through 

September 2012 in accordance with generally accepted government 

auditing standards. These standards require that we plan and perform the 

audit to obtain sufficient, appropriate evidence to provide a reasonable 

basis for our findings and conclusions based on our audit objectives. We 

believe that the evidence obtained provides a reasonable basis for our 

findings and conclusions based on our audit objectives.

The TAA Community College and Career Training grant program is one 

of three grant programs that were included in the TAA for Communities 

Program when it was reestablished by the Trade and Globalization 

Adjustment Assistance Act of 2009 (TGAAA).7

 

7

The Trade Act of 1974 as originally enacted included provisions authorizing trade 

adjustment assistance for communities but included a provision terminating the program 

on September 30, 1982. Pub. L. No 93-618, § 284, 88 Stat. 2041. 

The other two grant 

programs—the Department of Commerce TAA for Communities Grant 

Program and Labor’s Industry or Sector Partnership Grant Program for 

Communities Impacted by Trade—were eliminated in 2011 by the TAA 

Background 
 

Page 5 GAO-12-954 TAA Community College Grants

Extension Act.8 The 2011 legislation also expanded the types of data 

required for Labor’s annual report on the TAACCCT program, including 

the amount and duration of grants awarded and certain outcomes for TAA 

recipients participating in activities funded under TAACCCT grants.9

The TAACCCT grants allow community colleges and other eligible 

institutions of higher education to develop, expand, and improve 

education and training programs that can be completed in 2 years or less 

and result in skills, degrees, and credentials that prepare program 

participants for employment in high-wage, high-skill occupations. In 

particular, according to Labor’s grant announcement, the program is 

designed to fund projects that seek to use data and evidence to: (1) 

design program strategies that are likely to produce positive learning and 

employment outcomes for program participants, (2) continuously evaluate 

the effectiveness of their strategies in order to improve their programs, 

and (3) participate in evaluations that determine long-term program 

impacts. Labor encourages partnership building by requiring applicants to 

involve the public workforce system and at least one employer in forming 

programs to help ensure that participants will be prepared with the skills 

needed in the region.

In addition, Labor, in its SGA, required applicants to address one or more 

of the following four priority areas, which reflect strategies to help tradeaffected workers overcome the primary barriers to labor market entry:

1. Accelerating progress for low-skilled and other workers;

2. Improving retention and achievement rates and/or reducing time to 

completion;

3. Building programs that meet industry needs, including developing 

career pathways; and

 

8

The two grant programs were eliminated by section 222(a) of the Trade Adjustment 

Assistance Extension Act of 2011, Pub. L. No. 112-40, tit. II, 125 Stat. 411. The 

Department of Commerce TAA for Communities Grant Program was funded at $36.8 

million in FY 2010, but no funds were appropriated in FY 2011. For more information on 

the Department of Commerce’s TAA for Communities grant program, see GAO, Trade 

Adjustment Assistance: One-Time Grants Awarded to Trade-Impacted Communities; 

Results Will Not Be Known until after 2013, GAO-12-993 (Washington, D.C.: September 

26, 2012). The Industry or Sector Partnership Grant Program was never funded by 

Congress. 

9

Pub. L. No. 112-40, § 222(b), 125 Stat. 411.
 

Page 6 GAO-12-954 TAA Community College Grants

4. Strengthening online and technology-enabled learning.

According to Labor, successful applicants from round one uniformly 

addressed all four priority areas, and many applicants chose projects that 

integrated a combination of the priority areas. Labor indicated that 

applicants from round one covered a wide range of sectors including 

healthcare, manufacturing, energy, information technology, engineering, 

transportation, agriculture/food and natural resources, architecture, 

biotechnology, business, environmental management, law 

enforcement/public safety, and retail.

Labor’s competitive grant award process consists of the following key 

steps, as illustrated in figure 1.

Grant Announcement: Labor begins the competition process by 

publishing a “Solicitation for Grant Applications” (SGA) for each grant 

program. The SGA describes the project to be funded, establishes 

eligibility requirements, identifies the amounts to be awarded, and 

instructs applicants on how to complete and submit the application.10

Application Pre-Screening: Applications are prescreened to determine 

whether they meet specific requirements. Applications are eliminated 

from review if they are received after the deadline or if they do not meet 

all requirements.

The 

SGA also includes criteria used to evaluate applications.

Technical Review of Applications: Applications remaining after prescreening are submitted to technical review panels. Panels review and 

score the applications using the criteria set forth in the SGA. The panel 

assigns points to each application that are added up to derive the 

applicant’s average score. The ranked scores serve as the primary basis 

for selecting the applications to receive awards, although other criteria, 

such as the availability of grant funds, may also be considered. Labor’s 

grants management staff identify the cutoff score that separates 

successful applicants from unsuccessful ones.

 

10“Applying for ETA Grants: A Guide to the Competitive Process,” Department of Labor 

(Washington, D.C.: n.d.).

Labor’s Competitive Grant 

Award Process
 

Page 7 GAO-12-954 TAA Community College Grants

Final Grant Award Decisions: Taking into account peer review panel 

scores and comments for each application and, in some cases, other 

factors, Labor’s grants management office makes the final award 

decision. These decisions are documented in the final funding award 

decision memos, which contain the list of applicants—ranked by scores—

and the final award decisions.

Notification of Award Decisions: Each applicant is sent a letter that 

communicates the grant award decision. All applicants may request 

feedback on the results of the review panel.

Figure 1: Labor’s Competitive Grant Award Process
 

Page 8 GAO-12-954 TAA Community College Grants

Labor’s design of the TAACCCT grants complied with federal 

requirements. The TGAAA required that Labor issue and publish 

guidelines for applicants, and that applicants’ proposals include detailed 

project descriptions.11 Labor’s SGA for the first round of TAACCCT grants 

provided information about grant objectives and invited applicants to 

describe their need for the grant, work plans, and expected outcomes.12

The SGA assigned a maximum number of possible points to criteria to be 

used in scoring the applications, as shown in table 1.

 

1119 U.S.C. § 2371(c).

12Notice of Availability of Funds and Solicitation for Grant Applications for Trade 

Adjustment Assistance Community College and Career Training Grants Program, funding 

opportunity number: SGA/DFA PY 10-03, January 21, 2011. 

Labor Designed and 

Awarded Grants in 

Accordance with 

TGAAA 

Requirements, but 

Found It Challenging 

to Award Each State a 

Minimum Amount of 

Funding 

Labor Designed Grants in 

Accordance with TGAAA 

Requirements
 

Page 9 GAO-12-954 TAA Community College Grants

Table 1: Evaluation Criteria of TAACCCT Round One Grant Applications

Criterion

Maximum Number of 

Points Available

Statement of Need 30

Impact of Foreign Trade in Communities to Be Served 5 

Targeted Population in Communities to Be Served 5 

Targeted Industries and Occupations 10

Gaps in Existing Educational and Career Training Programs 10

Work Plan and Project Management 45

Evidence-Based Design and Overview of Proposed Strategy 15

Project Work Plan 15

Project Management 10

Sustainability 5 

Measurement of Progress and Outcomes 25

Progress and Implementation Measures 10

Outcome Measures 15

Total Possible Points 100

Source: U.S. Department of Labor, Employment and Training Administration, SGA/DFA PY 10-03, January 21, 2011.

Note: Labor made some changes in the criteria and maximum points for round two. The SGA for 

round two allocates 20 points for the Statement of Need, 10 points of which are available for serving 

the education and training needs of TAA-eligible workers, 5 for evidence of job opportunities in the 

targeted industries and occupations, and 5 for gaps in existing education and training programs in the 

community. Additionally, the SGA for round two allows 40 points for project description, including its 

evidence basis; 20 for work plan and project management; and 20 for outcomes. See Notice of 

Availability of Funds and Solicitation for Grant Applications for Trade Adjustment Assistance 

Community College and Career Training Grants Program, SGA/DFA PY 11-08, February 27, 2012.

To develop the SGA, Labor incorporated the TGAAA’s requirement that 

programs be suited for workers eligible for training under the TAA for 

Workers program. Accordingly, the SGA stated that the target population 

for the grant is workers who have lost their job or are threatened with job 

loss as a result of foreign trade. However, the TGAAA did not specify 

eligibility requirements for the workers to be served by these programs, 

and the SGA acknowledged that grant-funded training programs could 

serve other workers.13

 

13According to Labor, eligible participants include TAA-eligible workers as well as other 

individuals whom grantees deem eligible. However, TAA-eligible workers must be given 

enrollment priority if the grantee must choose between two qualified candidates for 

enrollment.
 

Page 10 GAO-12-954 TAA Community College Grants

The grant applications we reviewed defined their target populations 

differently. While virtually all focused on trade-affected workers, some 

also included dislocated,14

Additionally, consistent with TGAAA’s purpose of improving training 

programs for workers impacted by trade, the SGA required applicants to 

demonstrate trade impact in their communities. Virtually all the funded 

applications we reviewed addressed trade impact, by citing TAA 

certifications and in many cases associated estimates of affected 

workers.

unemployed, and low-skilled workers and 

jobseekers.

15

These two criteria—target population and trade impact—represented a 

combined 10 out of 100 points. The applications that we reviewed scored 

between 4.6 and 10 on these criteria.

Also, while not a requirement of TGAAA, the SGA also required 

applicants to address the sustainability of their proposed programs. Our 

review of funded applications shows that the majority addressed this 

requirement by describing specific actions they planned to take.16 For 

example, some applicants proposed to sustain their programs beyond the 

grant period through tuition revenue, and some identified other means, 

such as new revenue from online learning programs, employer support, 

and more efficient practices. Labor officials told us that they also 

consulted with Education to conceptualize the grant design and that 

Education reviewed and provided feedback on initial drafts of the SGA.17

 

14As defined by the Workforce Investment Act of 1998, dislocated workers are those who 

have been terminated or laid off, have received a notice of termination or layoff from 

employment, are eligible for or have exhausted unemployment insurance, or who meet 

certain other conditions. Pub. L. No. 105-220 § 101(9), codified at 19 U.S.C. § 2801(9).

15Under the TAA for Workers program, workers, unions, employers, or other parties may 

file a petition with Labor on behalf of a group of workers for a determination of trade 

impact and certification of eligibility to apply for trade adjustment assistance. 19 U.S.C.§ 

2271. In addition, applicants for TAACCCT grants could demonstrate impact of foreign 

trade if the Secretary of Commerce has determined that the community served by the 

institution is eligible to apply for assistance under the TAA for Communities program. 

16Two of the grant files were incomplete at the time of our review.

17Education reviewed the SGA with particular regard to the design, priorities, and selection 

criteria for grant awards, according to Education officials. 
 

Page 11 GAO-12-954 TAA Community College Grants

In addition to publishing the SGA in the Federal Register, Labor 

publicized the grant opportunity by holding a webinar in January 2011 to 

alert prospective applicants and provide an overview of the grant 

opportunity and the process for reviewing applications. Labor officials 

noted that Education also performed outreach about the grant program.

Labor followed its standard competitive grant award process to screen 

applications, review and score them, and make awards. Figure 2 provides 

an overview of Labor’s TAACCCT grant award process. In all, 258 

institutions applied for the grant.18 Once Labor received the applications, 

it screened and excluded from further review any that did not address one 

or more requirements of the SGA. Labor also screened the grantees to 

identify any that had been excluded from consideration from other federal 

grants.19

For fiscal year 2011, the first year that grant funds for the program were 

appropriated, Labor awarded 49 grants, ranging from $2.5 million for 

individual applicants up to $24.7 million for consortium applicants (see 

table 2). Two grants qualified for and received supplemental funding in 

excess of Labor’s $20 million cap for consortium applicants by showing, 

as provided for in the SGA, evidence-based success of the proposed 

strategies and practices and/or proposing to develop large online or 

technology-enabled programs designed to reach significant numbers of 

individuals over a large geographic area. Overall, about 8 percent of 

funds went to individual institutions and 92 percent went to consortia. 

Grantees must spend their respective award amount within a 3-year 

period of performance. This period began October 1, 2011 and will end 

September 30, 2014. Appendix I contains a list of round one grantees.

For funded grant applications we reviewed, we found that Labor 

screened all of them and did not find any adverse issues.

 

18This total represents the number of applicants that were paneled and scored; it does not 

include those that Labor excluded after conducting an initial review.

19During this step, Labor checks a database to identify any entities that have been 

debarred or suspended from receiving federal grants. As part of this process, Labor also 

checks internal sources to identify any outstanding debts owed by the grantees and to 

identify any relevant audits or investigations.

Labor Followed Its 

Standard Competitive 

Award Process, but 

Making Awards to Each 

State Created Challenges 

for Labor, States, and 

Grantees
 

Page 12 GAO-12-954 TAA Community College Grants

Table 2: Community College and Career Training Grants Awarded in Round One

Number of 

Grants Awarded Grant Type Award Amount

23 Single and multi-state consortia $2.5 to $24.7 million 

9 Individual institutions $2.5 to $5 million

17 State-designated institutionsa $2.7 million

Source: GAO analysis of Labor documents. 

a

After Labor determined that applicants from these states did not meet the cutoff score for grant 

awards, these grantees were designated by state higher education agencies that oversee community 

colleges. These grantees were subsequently determined to be eligible to receive a portion of the 

remaining grant funds, resulting in grant awards of about $2.7 million each. This, in turn, satisfied the 

requirement for minimum grant awards of 0.5 percent of the total funding available. These grantees 

include both individual institutions and consortia.

To comply with TGAAA’s requirement to make awards based on merit, 

and in accord with its competitive grant award process,20 Labor relied on 

panels of three experts each—some of whom were recommended by 

Education on the basis of particular expertise relevant to these grants 

(see fig. 2).21 Labor provided an orientation to the peer reviewers to help 

them evaluate and score applications. The panels then independently 

reviewed the applications and assigned each one a score using the 

criteria established in the SGA. The scores were then averaged to 

produce a final score for each application.22

 

2019 U.S.C. § 2371(d)(1)(A). Additionally, the Federal Grant and Cooperative Agreement 

Act encourages competition where appropriate, in order to identify and fund the best 

possible projects to achieve program objectives. 31 U.S.C. § 6301(3).

Labor then computed a cutoff 

score using total available grant funds as a guide—a standard criterion in 

grant award decisions, according to Labor officials. Labor established a 

cutoff score of 94 out of 100 for round one; all applicants above this score 

were considered for an award, according to Labor. In every instance of 

multiple applications submitted from a given state, Labor awarded the 

grant to the applicant with the highest score. In case of a tie between 

21Education disseminated Labor’s request for expert reviewers within Education and 

among research organizations outside the federal government. These experts served on 

the panels along with other experts identified and recruited by a Labor contractor for this 

purpose.

22The experts recorded their scores, as well as narrative observations about the 

applications they reviewed, in workbooks provided by Labor. According to Labor, the staff 

members who facilitate these panels may seek clarification from an expert whose numeric 

scores and narrative observations regarding a particular application appear inconsistent.
 

Page 13 GAO-12-954 TAA Community College Grants

applicants from the same state, Labor awarded the grant to the applicant 

that demonstrated greater evidence of employer engagement. As a result 

of the scoring process, Labor initially selected 32 grantees, all of whom 

received the full funding amount they requested. Labor clearly 

documented the grant award results in a selection memo that provided 

the agency’s rationale for awarding the grants.

Figure 2: Process for Reviewing and Scoring TAACCCT Grant Applications
 

Page 14 GAO-12-954 TAA Community College Grants

The TGAAA’s requirement that every state23 receive a minimum amount 

of funding created challenges for Labor, states, and selected grantees in 

17 states where applicants scored below the cutoff for grant awards. 

Labor officials told us that they could not recall another discretionary 

Labor grant program with such a requirement. In the absence of such a 

precedent, they said that they worked with Education and the Office of 

Management and Budget to develop a process that would be clear, fair, 

and feasible. This process, as stipulated in the SGA, required Labor to 

first select qualified applications from as many states as possible (i.e., 

those that scored at or above the cutoff). In the event that (1) no 

applications were received from an eligible institution in a given state or 

(2) applications that scored below the cutoff could not be improved by 

placing conditions on the grant, Labor would contact the state agency 

responsible for the state college system to designate a grantee. Labor 

applied this process to the 17 states where institutions did not meet the 

scoring cutoff and requested state education agencies to designate a 

grantee from their state.24 Labor accepted the states’ choice of an 

institution. Of the 17 states, 6 designated the applicant with the highest 

score among multiple applicants from their state;25

The requirement to provide each state a minimum level of funding 

resulted in some anomalies. While some of the state-designated 

grantees’ applications scored close to the cutoff—as high as 92 or 93—

the process resulted in grants to two institutions whose applications had 

scores in the upper 50s, well below the threshold of 70 that Labor 

considers minimally acceptable for any grant applications to be fundable.

10 designated the only 

institution that had applied; and 1 designated an institution that had not 

applied.

 

23For the purposes of this grant, Labor treated the District of Columbia and Puerto Rico as 

states.

24Two of the 17 grantees in this group did not go through the paneling and scoring 

process—in one case, because the institution submitted its application after the 

application deadline; in the other, the state-designated institution submitted its application 

after the paneling and scoring phase.

25In one of these six states, two institutions tied for the highest score, and the state 

designated one of them.
 

Page 15 GAO-12-954 TAA Community College Grants

Figure 3 shows the range of scores and median scores for the initiallyselected grantees, the state-designated grantees, and the unsuccessful 

applicants.

Figure 3: Range of Scores and Median Scores for TAACCCT Round One 

Applications

Note: The scores shown for the state-designated grantees’ applications reflect the scores assigned 

by expert panels to their original applications, not the revised implementation plans that these 

grantees developed and that Labor approved. According to Labor, these plans were reviewed to 

ensure that they met the requirements of the SGA; however, they did not go through the paneling and 

scoring process a second time. Also, the scores for the state-designated grantees’ applications reflect 

all those that were scored; two did not go through the paneling and scoring process.

Another anomaly was that Labor awarded a grant to an institution that 

had never applied. In this case, instead of designating one of the two 

institutions that did apply, the state agency designated an institution from 

that state that had not applied. A representative of the state agency 

explained that the institution was selected on the basis of its 

administrative capacity, the state’s desire to focus on a particular industry, 

and the institution’s strong relationships with employers.

The state-designated process was also challenging for states and 

grantees. Labor initiated the process of soliciting state agencies’ 

designations on September 23, 2011, just 7 days before the deadline for 

awarding grants at the end of the fiscal year, and gave the states until 

September 26, 2011, to designate a grantee. This left states little more 

than the weekend to identify an institution (see fig. 4). Of the four state 

agencies that we interviewed, all said that they found elements of this 
 

Page 16 GAO-12-954 TAA Community College Grants

process to be challenging or confusing. For example, officials in one state 

said that the institution they wished to designate was unaware of the 

urgency of the situation. In addition, state officials said that they did not 

receive guidance or criteria from Labor to help them designate a grantee. 

Officials from one state said it was difficult to select a grantee, as all the 

applications that institutions from that state had previously submitted 

appeared promising. Furthermore, although Labor officials said they took 

steps to identify the appropriate state agency point of contact in each 

state, officials from one state said there was little evidence Labor had 

done so.

Figure 4: Timeline of TAACCCT Grant Program for Round One of Grants

a

According to Labor, the application period in the first round of the TAACCCT grants was longer than 

its typical application periods, which are about 45-60 days.
 

Page 17 GAO-12-954 TAA Community College Grants

States and grantees continued to experience challenges even after the 

state-designated grants were awarded because Labor required these 

grantees to develop implementation plans to meet the requirements of the 

SGA and to obtain Labor’s approval of these plans. All of the grantees 

required assistance with this task, some of it significant, according to 

Labor officials. Labor’s regional grant staff provided technical assistance 

to help these grantees complete their implementation plans, assisted by 

specialist staff that Labor tapped for this purpose.26 In particular, in their 

original applications, 14 of these grantees had requested amounts that 

were larger—in some cases $20 million or more—than the minimum $2.7 

million they ultimately received. Selected state officials and grantees told 

us that, as a result, grantees had to significantly scale back their original 

proposals and essentially develop new ones from scratch, reflecting 

different educational strategies or targeted industries and occupations.27

In addition, Labor officials told us that they assisted the lowest-scoring of 

these grantees to ensure that the grantees’ implementation plans met the 

minimum requirements of the SGA. For example, Labor made sure 

grantees provided more information about their intended target 

population. The revised implementation plans were not, however, rescored by the review panels.

The additional time it took Labor to assist grantees in revising their 

implementation plans resulted in delayed program implementation for 

these grantees. Labor approved the last revised implementation plan in 

June 2012, 9 months after awarding the grants. During that time, these 

grantees could only charge costs related to revising their implementation 

plans and attending a technical assistance conference that Labor 

sponsored, according to Labor officials. One grantee noted that the delay 

allowed little time to develop new curricula and recruit and enroll students 

in time for the fall 2012 semester, as planned. Another noted delayed

 

26Staff from Labor’s Center for Performance Excellence, located in its Philadelphia office, 

reviewed the implementation plans. According to Labor, the Center was established to 

review earmark grants. Since the Center had applicable expertise, and no earmark grants 

were pending at the time, Labor officials asked the Center for assistance.

27Labor required all of these grantees to meet the requirements of the SGA, including 

focusing on one or more of the grant’s four priorities. However, according to a Labor 

official, grantees that scaled back their applications had the option of focusing on fewer of 

these priorities, or pursuing a single priority.
 

Page 18 GAO-12-954 TAA Community College Grants

implementation, citing a need to move forward with purchasing necessary 

equipment.

While the TAACCCT grants are designed to support grantees’ efforts to 

serve trade-affected workers, one result of the requirement that every 

state receive a minimum amount of funding is that some grantees 

received funding even though they were located in states that are less 

adversely affected by trade than others. Labor’s recent data on the 

number of TAA workers suggest that the impact of trade varies widely by 

state (see app. I). However, eight of the initially-selected grantees were 

located in 10 states heavily impacted by trade. Of these grantees, seven 

received grants of $18 million or more each.28 Moreover, in addition to 

these grants, training programs in some of the 10 states with the largest 

TAA worker populations will be offered by institutions that are members of 

consortia led by other grantees. In these 10 states, 6 had institutions that 

were members of multi-state consortia.

Labor has identified lessons learned from the first round of grants to be 

applied to future rounds. The SGA for round two of the grants included 

some changes that, according to Labor officials, had the potential to 

reduce the number of grantees to be designated by state agencies.29

Specifically, Labor reduced the maximum dollar amount of grant awards 

from $5 million to $3 million for individual applicants and from $20 million 

to $15 million for consortium applicants. Another change from round one 

to round two that Labor made was to specify that it would select qualified 

individual grantees before selecting consortium grantees in order to issue 

an individual grant of at least $2.5 million to an eligible institution in every 

state.30

 

28According to a Labor official, all initially-selected grantees in the first round received the 

amount they had requested. 

According to Labor, these changes were expected to make it 

29Notice of Availability of Funds and Solicitation for Grant Applications for Trade 

Adjustment Assistance Community College and Career Training Grants Program, 

SGA/DFA PY 11-08, February 27, 2012. 

30In contrast to the round one SGA, which specified that Labor would first select grantees 

that represent as many states as possible, without regard to their status as individual or 

consortium grantees, the round two SGA specified that Labor would first select qualified 

individual institutions before selecting consortium grantees to ensure that at least one 

eligible institution from each state would receive an individual grant of approximately $2.5 

million. Both SGAs specified that, after these steps, Labor would contact the states that 

needed to designate grantees.

Labor Has Made a Number 

of Modifications to Its 

Second Grant 

Announcement 
 

Page 19 GAO-12-954 TAA Community College Grants

more likely that an eligible institution in every state could be identified 

before the availability of funds criterion is applied. In addition, Labor 

officials said they have continued to raise awareness about the grant 

opportunity in collaboration with Education by, for example, seeking 

Education’s assistance in its outreach efforts and appearing with an 

Education official at a conference to discuss the program. The process for 

selecting state-designated grantees is otherwise identical to the process 

used in round one. Moreover, the SGA for round two stipulates similar 

timeframes for applicants to develop and submit their proposals. 

Additionally, Labor officials anticipate that some state-designated 

grantees in round two will require assistance to revise their 

implementation plans and indicated that, based on their experience 

during the first round, that process could be completed within about 120 

days after the second round grants are awarded. According to Labor, 151 

grant applications went through the paneling and scoring process in 

round two. Individual institutions or consortium leaders in round one could 

only apply as members of a consortium in round two. However, 

consortium members and any unsuccessful applicants from round one 

were eligible to apply for round two grants. For round two, Labor recently 

announced grant awards to 54 grantees and identified 25 states that will 

need to designate grantees.31

Labor made certain other changes to the SGA for round two, beyond 

those that address the potential need for state-designated grantees. For 

example, in the round two SGA, Labor introduced a mandatory priority for 

serving TAA workers and outlined additional flexibility that it will use to 

consider heavily trade-impacted areas when making final award 

decisions. Labor also added specific requirements to the SGA in certain 

areas, such as credit transferability and credentials that facilitate trainees’ 

 

 

31In its press release of September 19, 2012, Labor announced 54 awards to 27 consortia 

and 27 individual institutions, comprising a total of 297 institutions. Regarding statedesignated grantees in round two, Labor noted its plans to contact 25 states that did not 

have a winning individual submission and work with them to develop qualifying projects of 

$2.5 million each. Of this group, 15 states had only consortia grantees while 10 states did 

not have any grantees. Labor must award these grants by September 30, 2012.
 

Page 20 GAO-12-954 TAA Community College Grants

progress,32 and developing relationships with state agencies that 

administer TAA programs. Labor officials said that these changes 

provided more clarification and were partly a response to feedback 

received during the first round of grants.

As with its other grant programs, Labor monitors TAACCCT grants in 

accordance with the guidance and criteria contained in its Core 

Monitoring Guide.33 On a quarterly basis, federal project officers assess 

each grant’s overall risk—the likelihood of having a problem with grant 

integrity and performance—as low, moderate, or high based on the 

following five areas: (1) program design and governance, (2) program and 

grant management systems, (3) financial management systems, (4) 

service and product delivery, and (5) performance accountability. These 

assessments are made on the basis of the project officers’ review of 

grantees’ quarterly financial and narrative progress reports, direct 

communication with grantees, and on-site monitoring as resources 

permit.34

 

32The SGA for round two addresses credit transferability by requiring applicants to ensure 

that other institutions will recognize credits earned for grant-funded courses and 

credentials to provide for streamlined transfers. In addition, it requires applicants to design 

their programs so that they build on previously-learned content, allowing trainees to 

progress within their programs of study or continue to related programs. It also 

encourages applicants to work with employers to ensure that grant-funded training results 

in credentials that are widely recognized by employers and other institutions.

As Labor has done for other grant programs, it is developing a 

33For additional information on Labor’s grant monitoring practices, see GAO, Department 

of Labor: Further Management Improvements Needed to Address Information Technology 

and Financial Controls, GAO-11-157 (Washington, D.C.: March 16, 2011).

34On-site monitoring of TAACCCT grants has not yet occurred. According to Labor 

officials, on-site monitoring ideally occurs midway through the grant period, but may occur 

before or after that point.

Labor Is Tracking and 

Addressing Issues 

Raised by Grantees,

and Grant 

Implementation Is in 

an Early Stage

Labor Monitors Grantee 

Progress Using Several 

Mechanisms
 

Page 21 GAO-12-954 TAA Community College Grants

program-specific monitoring tool that will help officers address oversight 

priorities and obtain information particular to TAACCCT. For example, the 

tool will prompt project officers to capture information about the 

equipment procurement process for consortia members. Labor officials 

envision that the tool will be particularly helpful during site visits to 

grantee institutions that are planned to begin in fiscal year 2013.

Labor also monitors the grants through TAACCCT-specific grantee 

reporting requirements. Labor requires that grantees report on a quarterly 

basis on at least four measures for each strategy identified in their plans 

to help track implementation progress. Grantees have discretion in 

identifying the specific measures, but at least two must be output-related, 

such as the number of students who enroll in particular courses. On an 

annual basis, grantees must report on seven outcome measures for 

program participants: (1) entered employment rate, (2) employment 

retention rate, (3) average earnings, (4) attainment of credits toward 

degrees, (5) attainment of industry-recognized certificates (in less than 1 

year), (6) attainment of industry-recognized certificates (in more than 1 

year), and (7) graduation number and rate for degree programs.35 The 

first grantee annual reports are due to Labor on November 14, 2012. 

Round one grantees must also report these measures for a comparison 

cohort36 to help grantees monitor and improve program performance. 

According to Labor, the cohort requirement is part of the grant’s 

performance reporting requirement and not directly related to Labor’s 

evaluation of program effectiveness at this time.

Our review of grantee progress reports shows that, as of the quarter 

ending December 2011, most grantees had not yet launched programs or 

enrolled participants. Instead, they reported building capacity to support 

the priorities and programs identified in their proposals.37

 

35The first three of these measures are common across Labor’s employment and training 

programs. 

For example, 

36A comparison cohort consists of participants who are not in TAACCCT-funded programs 

but share characteristics with participants who are. 

37Labor defines launched programs as those “developed, delivered, offered, or improved 

in whole or in part with grant funds for which the development or improvements have been 

completed so that they are ready for students to enroll.” We reviewed grantees’ progress 

reports for the quarter ending December 31, 2011, which were the most recently available 

reports at the time of our review. 

Grant Implementation Is in 

an Early Stage
 

Page 22 GAO-12-954 TAA Community College Grants

most grantees reported hiring key personnel for grant implementation and 

several reported developing curricula and setting up administrative 

systems, such as recordkeeping databases to help manage their grant. 

Nevertheless, a few grantees reported enhancing existing programs and 

enrolling participants in these programs. Labor’s program guidance for 

grantees confirms the agency’s expectation that grantees will use the first 

year of funding to build capacity. As a result, the first year of grantee 

progress reports are likely to reflect minimal, if any, participant data.

Grantee spending levels provide another indication of the early stage of 

TAACCCT grant implementation. In total, TAACCCT grantees spent 5 

percent of awarded funds as of the quarter ending March 2012. Grantees 

have a 3-year window, from October 2011 through September 2014, to 

spend their award. According to Labor officials, the low percent of funds 

spent during the first 6 months of the program may be expected given the 

complexities of administrative set-up, particularly for consortia, which 

received the majority of grants. In addition, while most grantees had 

access to funds soon after the grants were awarded, the 17 statedesignated grantees had to wait several quarters while awaiting Labor’s 

approval of their plans. This, in turn, delayed spending. Of the 17 statedesignated grantees, 11 received funds during the program’s second 

quarter (January – March 2012), and 6 received funds during the 

program’s third quarter (April – June 2012).

As of the end of the first quarter of fiscal year 2012, Labor assessed the 

overall risk of most grants as low. Specifically, 27 of the 49 grants were 

assessed as low risk, 19 were moderate risk, and 3 were high risk. A 

comparison between initially-selected grants and state-designated ones 

generally showed a similar risk level for each type of grant (see fig. 5). 

For example, slightly more than half of both the initially-selected grants 

and state-designated grants were assessed as low risk. However, a 

higher percentage of state-designated grants were assessed as high risk, 

compared to the initially-selected grants.

Labor’s Monitoring 

Indicates that Most 

Grantees Are Low Risk
 

Page 23 GAO-12-954 TAA Community College Grants

Figure 5: Labor’s Overall Risk Assessments by How Grantee was Selected, after 

First Quarter of Fiscal Year 2012

While Labor assessed most grants as low risk after the first quarter, many 

grantees faced implementation challenges. For example, grantees sought 

clarification about tracking and reporting requirements for a single 

program with multiple planned improvements. In addition, many grantees 

expressed confusion about implementing the comparison cohort 

requirement. These implementation issues help explain why Labor 

identified performance accountability—more than any other area—as 

moderate or high risk for more than a third of grants (see fig. 6).
 

Page 24 GAO-12-954 TAA Community College Grants

Figure 6: Labor’s Risk Assessment of Grants by Risk Area, after First Quarter of 

Fiscal Year 2012

Labor responded to implementation challenges by providing additional 

guidance to grantees. Specifically, Labor assisted grantees via webinars, 

printed responses to frequently asked questions, and direct 

communication from their assigned project officer. Labor also held a 

conference for grantees in February 2012 to help address implementation 

issues. One session, for example, focused on TAACCCT-specific funding 

restrictions. With regard to the comparison cohort requirement, Labor 

provided responses to frequently asked questions but acknowledged that 

the requirement was confusing and that many Labor staff lacked the 

technical expertise to assist grantees. Consequently, Labor removed this 

requirement from the SGA for round two.
 

Page 25 GAO-12-954 TAA Community College Grants

Although Labor is in the early stages of designing an evaluation of the 

TAACCCT grant program, it plans to evaluate the program at both the 

national and grantee level. At the national level, Labor plans to conduct 

the evaluation in phases, beginning with an initial review of the 

implementation process across all grantees from the first and second 

rounds, followed by a more in-depth analysis of the overall impact of the 

grant program. Labor is in the process of selecting an independent 

contractor to conduct the national evaluation and anticipates a contractor 

will likely begin work by fall 2012. Labor’s Chief Evaluation Officer stated 

that, given the early stage of program implementation, the contractor will 

likely begin with an implementation analysis to determine how and to 

what extent grantees have implemented the activities laid out in their 

proposals, and whether data systems are in place to capture reliable data 

needed for a subsequent impact study. This initial analysis will be based 

primarily on data collected through a survey of grantees, site visits to a 

sample of grant projects, a review of grantees’ quarterly and annual 

reports, and information from grantees’ third-party evaluations of their 

individual projects. The result will likely be a preliminary description of the 

projects funded by the program and identification of any implementation 

issues to date.

Once the initial analysis is completed and additional outcome data are 

available from grantees, Labor anticipates conducting a more 

comprehensive evaluation of the program—possibly an experimental 

design—to determine the extent to which the program is achieving its 

objectives and other important outcomes. This form of evaluation will 

assess program effectiveness by focusing on services delivered by the 

grantees’ programs and the results of those services.38

At the grantee level, while Labor did not require first-round grantees to 

conduct a formal evaluation of their individual projects, grantees from the 

second round are required to contract with a third party entity to design 

However, the 

timing of the more comprehensive evaluation will depend on whether 

grantees have had sufficient time to implement their programs. It will also 

depend on the availability of observable, long-term outcome data, such as 

employment outcomes and earnings. Labor indicated that it may be 

several more years before such an impact evaluation is feasible.

 

38GAO, Designing Evaluations: 2012 Revision, GAO-12-208G (Washington, D.C.: January 

2012). 

Labor Plans to 

Evaluate the Program 

at the National and 

Grantee Level, but 

Anticipates Some 

Challenges 
 

Page 26 GAO-12-954 TAA Community College Grants

and conduct an external evaluation of the grantee’s program. This 

evaluation will be paid for with grant funds. In the proposal for the thirdparty evaluation, grantees must present a detailed plan for rigorously 

evaluating the participant outcomes or impacts, including a complete 

description of the study methodology and data collection methods. 

Grantees must submit a final report to Labor at the end of the grant period 

of performance, and at least one interim report—whose timing is to be 

determined by the grantee—on findings-to-date. According to Labor, this 

evaluation will have both a participant outcome component and an 

implementation component so that Labor can learn more about how the 

program has operated. Furthermore, depending on the adequacy of data 

and the designs of grantees' third-party evaluations, Labor expects results 

from the grantees’ evaluations will be incorporated into the Labor-led 

national evaluation.

Labor anticipates several challenges to conducting the national program 

evaluation. In addition to the timing challenge associated with providing 

grantees sufficient time to implement their programs before the national 

evaluation can get underway, another issue involves obtaining the 

outcome data needed to support the overall program evaluation. 

According to Labor, obtaining consistent and comparable data from 

grantees will be challenging and is dependent on the capabilities of 

grantees’ data systems to collect and track long-term employment 

outcomes data for program participants. Having comparable outcome 

data is important because the goal of an impact evaluation is to determine 

if outcomes are attributable to a program, or if they can be explained by 

other factors. However, Labor noted that this is an issue for all workforce 

programs, in general, and is not unique to this grant program. Another 

challenge Labor cited is obtaining funding to conduct an impact 

evaluation, which is typically expensive and resource intensive. According 

to Labor, no funding has been allocated for conducting evaluations of 

round one or round two; however, it plans to request such authority for 

subsequent rounds. Accordingly, Labor’s fiscal year 2013 budget 

requested authority to reserve up to 3 percent of the funds that have been 

appropriated for the TAACCCT program for fiscal years 2013 and 2014 

for the purposes of program evaluation and technical assistance.

The TAACCCT program represents a significant investment in the 

capacity of community colleges and other eligible higher education 

institutions to serve trade-affected workers as well as dislocated and 

unemployed workers seeking to improve their prospects in the current 

economy. The program’s particular emphasis on the development of 

Conclusions 
 

Page 27 GAO-12-954 TAA Community College Grants

evidence-based strategies, coupled with the grantees’ commitment to use 

data for continuous improvement, may result in a number of effective 

practices that could serve as models for other employment and training 

programs. It is important, therefore, that the grants selected reflect the 

most promising projects. Ensuring that each state received a minimum

amount of funding resulted in Labor non-competitively awarding grants to 

17 institutions, based on states’ designations, whose initial applications 

were either not scored or scored below the cutoff following the paneling 

and scoring process. Moreover, Labor initiated the process for states to 

designate an eligible institution only days before the grants had to be 

awarded, leaving states and grantees little more than a weekend to 

complete this process.

While Labor has taken steps in an effort to reduce the number of statedesignated grants in the second round, its recent announcement of 

second round grants indicated that the number of state-designated 

grantees will be higher than it was for the first round. Moreover, these 

steps do not provide assurance that states will have adequate advance 

notice to vet institutions—something that states we contacted found 

challenging during round one. Without building in adequate time to work 

with states, Labor may impose an unnecessary burden on states and may 

contribute to delays in program implementation, depending on the extent 

to which these grantees require technical assistance to modify their 

proposal. Without providing states guidance or criteria to inform their 

decisions about whom to designate, Labor lacks assurance that states 

will select the best qualified institution.

To provide greater assurance that TAACCCT grants are awarded to the 

most promising projects in every state, we recommend that the Secretary 

of Labor take steps to more effectively manage the process whereby 

states designate a grantee. This could include building in additional lead 

time for states to designate a higher education institution or providing 

states with guidance to help inform their designation of a grantee.

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

Labor for review and comment. Education provided technical comments, 

which we incorporated as appropriate. Labor provided written comments, 

which are reproduced in appendix II. In its comments, Labor agreed with 

our recommendation and noted that while it is not able to determine 

whether a designated recipient is necessary in specific states until after 

the grantees are selected, it will make efforts to provide as much lead 

Recommendation for 

Executive Action

Agency comments
 

Page 28 GAO-12-954 TAA Community College Grants

time as possible to states to identify a designated recipient in future 

rounds. 

We are sending copies of this report to the Secretaries of Labor and 

Education, as well as to relevant congressional committees. In addition, 

this report will also be available at no charge on GAO’s website at 

http://www.gao.gov. 

If you or your staff have any questions about this report, please contact 

me at (202) 512-7215 or sherrilla@gao.gov. Contact points for our Offices 

of Congressional Relations and Public Affairs may be found on the last 

page of this report. GAO staff who made key contributions to this report 

are listed in appendix III.

Andrew Sherrill, Director

Education, Workforce, and

Income Security Issues
Appendix I: Grants Awarded in Round One and 

TAA Information by State

Page 29 GAO-12-954 TAA Community College Grants

Statea Grantee Name Grant Amount Grantee Typeb TAA 

Workersc

Initially-selected grantees

AK University of Alaska Anchorage Community and Technical College $2,500,000 Single-state 

consortium

0 

AL George C. Wallace State Community College - Hanceville $9,500,000 Single-state 

consortium

7,009 

AR Northwest Arkansas Community College $14,794,422 Single-state 

consortium

2,353 

CA West Hills College Lemoore $19,993,050 Single-state 

consortium

21,109 

CO Community College of Denver $17,256,881 Single-state 

consortium

2,054 

DE Delaware Technical and Community College $4,994,200 Individual 8 

GA North Georgia Technical College $2,546,186 Individual 4,561 

HI Honolulu Community College $24,653,118 Single-state 

consortium

43 

IA Northeast Iowa Community College $12,695,959 Multi-state 

consortium

2,937 

IL College of Lake County $19,366,381 Single-state 

consortium

13,356 

KS Washburn University of Topeka $19,619,450 Single-state 

consortium

1,495 

MA Quinsigamond Community College $20,000,000 Single-state 

consortium

6,744 

MD Anne Arundel Community College $19,730,281 Multi-state 

consortium

735 

MI Alpena Community College $2,835,000 Individual 35,939 

MN Northland Community and Technical College $4,794,337 Individual 4,130 

MO Ozarks Technical Community College $19,982,296 Single-state 

consortium

5,991 

NC Robeson Community College $18,835,604 Single-state 

consortium

14,766 

ND United Tribes Technical College $18,947,635 Multi-state 

consortium

453 

NH Great Bay Community College $19,974,792 Single-state 

consortium

682 

NJ Raritan Valley Community College $4,620,265 Individual 3,539 

NY Kingsborough Community College $19,860,087 Single-state 

consortium

8,615 

OH Cincinnati State Technical and Community College $19,613,306 Multi-state 

consortium

27,712 

OR Clackamas Community College $18,679,289 Single-state 

consortium

10,079 

Appendix I: Grants Awarded in Round One 

and TAA Information by State
Appendix I: Grants Awarded in Round One and 

TAA Information by State

Page 30 GAO-12-954 TAA Community College Grants

Statea Grantee Name Grant Amount Grantee Typeb TAA 

Workersc

PA Community College of Philadelphia $20,000,000 Single-state 

consortium

15,964 

RI Community College of Rhode Island $3,405,023 Individual 775 

SC Florence-Darlington Technical College $19,984,039 Single-state 

consortium

5,430 

TN Motlow State Community College $3,291,515 Individual 8,403 

TX Collin College $19,998,974 Multi-state 

consortium

12,896 

VA Tidewater Community College $24,107,474 Single-state 

consortium

8,250 

VT Community College of Vermont $2,500,000 Individual 375 

WA Spokane Community College $20,000,000 Single-state 

consortium

5,478 

WV Mountwest Community and Technical College $5,000,000 Individual 1,943 

State-designated grantees

CT Gateway Community College $2,701,202 Single-state 

consortium

2,395 

DC Community College of the District of Columbia $2,701,202 Single-state 

consortium

0 

FL Florida State College at Jacksonville $2,701,202 Single-state 

consortium

3,463 

ID College of Southern Idaho $2,701,202 Single-state 

consortium

968 

IN Ivy Tech Community College of Indiana $2,701,202 Single-state 

consortium

12,283 

KY Jefferson Community and Technical College $2,701,202 Single-state 

consortium

6,278 

LA Baton Rouge Community College $2,701,202 Individual 1,309 

ME Central Maine Community College $2,701,202 Single-state 

consortium

1,661 

MS Itawamba Community College $2,701,202 Single-state 

consortium

1,876 

NE Metropolitan Community College $2,701,202 Single-state 

consortium

1,077 

NM Santa Fe Community College $2,701,202 Single-state 

consortium

2,278 

NV Truckee Meadows Community College $2,701,202 Single-state 

consortium

63 

OK Oklahoma City Community College $2,701,202 Single-state 

consortium

841 

PR Universidad del Este $2,701,203 Individual 138 
Appendix I: Grants Awarded in Round One and 

TAA Information by State

Page 31 GAO-12-954 TAA Community College Grants

Statea Grantee Name Grant Amount Grantee Typeb TAA 

Workersc

SD Watertown School District dba Lake Area Technical Institute $2,701,202 Single-state 

consortium

794 

UT Salt Lake Community College $2,701,202 Single-state 

consortium

2,526 

WY Northern Wyoming Community College District $2,701,203 Single-state 

consortium

46 

Source: GAO analysis of Labor data.

a

Arizona, Montana, and Wisconsin have at least one institution that is part of a consortium led by 

institutions from other states, but they do not have institutions that were awarded a grant as an 

individual institution or consortium lead. The numbers of TAA workers in these states were 4,531 

(Arizona), 418 (Montana), and 10,292 (Wisconsin).

b

For consortia, the name and state of the lead institution are listed.

c

TAA data are for the number of workers associated with certified TAA petitions in fiscal year 2010 as 

reported by Labor as of February 24, 2012.
Appendix II: Comments from the Department 

of Labor

Page 32 GAO-12-954 TAA Community College Grants

Appendix II: Comments from the Department 

of Labor
Appendix III: GAO Contacts and Staff 

Acknowledgments

Page 33 GAO-12-954 TAA Community College Grants

Andrew Sherrill, 202-512-7215 or sherrilla@gao.gov

In addition to the contact named above, Meeta Engle, Assistant Director; 

Susan Chin, Analyst-in-Charge; Joel Green, and Chris Morehouse made 

key contributions to this report. Also contributing to this report were Susan 

Baker, Divya Bali, Jessica Botsford, Susannah Compton, Jessica Gray, 

Kathy Leslie, Jean McSween, and Mimi Nguyen.

Appendix III: GAO Contacts and Staff 

Acknowledgments 

GAO Contacts

Staff 

Acknowledgements 
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Page 34 GAO-12-954 TAA Community College Grants

Trade Adjustment Assistance: Changes to the Workers Program 

Benefited Participants, but Little Is Known about Outcomes. GAO-12-953. 

Washington, D.C.: September 28, 2012.

Trade Adjustment Assistance: One-Time Grants Awarded to TradeImpacted Communities; Results Will Not Be Known until after 2013. 

GAO-12-993. Washington, D.C.: September 26, 2012.

Trade Adjustment Assistance: Commerce Program Has Helped 

Manufacturing and Service Firms, but Measures, Data, and Funding 

Formula Could Improve. GAO-12-930. Washington, D.C.: September 13, 

2012.

Trade Adjustment Assistance: USDA Has Enhanced Technical 

Assistance for Farmers and Fishermen, but Steps Are Needed to Better 

Evaluate Program Effectiveness. GAO-12-731. July 12, 2012.

Department of Labor: Further Management Improvements Needed to 

Address Information Technology and Financial Controls. GAO-11-157. 

Washington, D.C.: March 16, 2011.

Workforce Development: Community Colleges and One-Stop Centers 

Collaborate to Meet 21st Century Workforce Needs. GAO-08-547. 

Washington, D.C.: May 15, 2008.

Trade Adjustment Assistance: Labor Should Take Action to Ensure 

Performance Data Are Complete, Accurate, and Accessible. 

GAO-06-496. Washington, D.C.: April 25, 2006.

Trade Adjustment Assistance: Reforms Have Accelerated Training 

Enrollment, but Implementation Challenges Remain. GAO-04-1012. 

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(131147)
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